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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD — CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS: 8-495-5600 TO: Gary Reents, Senior Engine FROM: David Brent, Project Engineer DATE: 27 April 1989 SIGNATURE: V-D SUBJECT: REPORT OF WASTE DISCHARGE (RWD) FOR THE SOUTHERN PACIFIC PIPE LINE-ARCADY OIL SITE, GROUND WATER CLEANUP, SAN JOAQUIN COUNTY I have reviewed the subject. RWD, dated 3 April 1989, prepared by Levine-Fricke, for Southern Pacific Pipe Lines. SPPL proposes to discharge treated ground water to Trapper Slough as part of their cleanup at the Arcady Oil site. The RWD lacks sufficient detail for the determination of NPDES effluent and receiving water limitations. An SPPL pipeline traversing the Arcady Oil property ruptured in February 1986 during heavy rains, discharging an unspecified amount of gasoline and jet fuel onto the adjacent land, waterways, and shallow ground water. The pipeline may have leaked prior to this event, but this has never been confirmed. Some initial ground water investigation work was completed by the Mark Group Inc., for SPPL. Monitoring wells confirmed that spilt fuels had leaked into the ground water and were moving away from the Arcady site in a southeasterly direction. Levine-Fricke replaced the Mark Group as SPPL's consultants and submitted a conceptual remedial action plan in August 1988. A final remediation plan has never been received. As ascertained through sporadic phone conversations with SPPL and Levine-Fricke, progress on the project since the August submittal has been minimal. Extraction wells have been installed and negotiations have reportably been completed with adjacent land owners. However, SPPL has not prepared a plan that goes beyond the conceptual phase and the RWD was essentially a revision of the conceptual design submitted in August. The RWD's description of the extraction, treatment, and discharge of the ground water is limited to general parameters and a non-detailed schematic of the overall process. The conceptual plan to pump, treat, and discharge the polluted ground water appears workable. But, approval for the project and waste discharge requirements should not be given until the details and parameters of the project are fully determined. Specific comments related to the RWD and overall plan are as follows: 1. The full extent of ground water contamination is unknown and the extraction rate and extraction well pattern necessary to capture the entire plume must be reevaluated. First of all, the existing monitoring wells should be resampled for BTX, TPH, and lead and ground water gradients should be