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California Rgh^ional Water Quality Cool Board <br /> Central Valley Region <br /> Katherine Hart, Chair ° <br /> Linda S. Adams <br /> Secretary for 11020 Sun Center Drive#200, Rancho Cordova,California 95670-6114 Arnold <br /> Environmental Phone(916)464-3291 •FAX(916)464-4645 Schwarzenegger <br /> Protection http://www.waterboards.ca.gov/centralvalley Governor <br /> 3 November 2010 <br /> Mr. Gil Moore RECEIVED <br /> P.O Box 529 <br /> Wilton, CA 95693 NOV 0 5 2010 <br /> DOCUMENT REVIEW, NEW WEST PETROLEUM#1003 (SHELL BRANDES IRONMENIENVALCE TM <br /> 6437 BANNER STREET, LODI, SAN JOAQUIN COUNTY RMIT/SE <br /> S T11 <br /> (GENERAL NPDES PERMIT R5-2008-0085-013, CASE 391163) <br /> 1 reviewed Third Quarter 2010 Groundwater Monitoring Report (Report), received 1 November 2010 <br /> from your consultant Advanced GeoEnvironmental, Inc. The Report states groundwater was sampled <br /> on 22 and 29 September 2010. Depth to water varied from 14 feet below ground surface (' bgs) to <br /> 16' bgs. Groundwater flow direction varied from radially inward towards the groundwater extraction wells <br /> EW-6A and EW-7A in Zone A, and east-southeast at 0.002 ft/ft gradient in Zone B. Maximum <br /> groundwater concentrations in EW-6A were methyl tent butyl ether(MTBE), 89 micrograms per Liter <br /> (ug/L). The groundwater extraction treatment system (GWETS) treated approximately 2,098,000 <br /> gallons of extracted water and removed 1.07 pounds of MTBE during the third quarter of 2010 under <br /> Regional Water Quality Control Board — Central Valley Region, General Order No. R5-2008-0085, <br /> Waste Discharge Requirements for Discharge to Surface Waters of Groundwater from Cleanup of <br /> Petroleum Fuel Pollution (R5-2008-0085). The downgradient EW-8B pump, which apparently failed in <br /> June 2010, was replaced with the pump from cross gradient EW-10A in October 2010. Groundwater <br /> sample EW-10A was non-detect for MTBE in September 2010. The GWETS MID-1 (after the first <br /> carbon treatment unit) and MID-2 (after the second carbon treatment unit) water samples were reported <br /> as non-detect for MTBE in monthly monitoring for R5-2008-0085-013 in August and September of 2010. <br /> The GWETS monthly influent water sampling reported total petroleum hydrocarbons as gasoline <br /> (TPHg), 720 ug/L; ethylbenzene, 22 ug/L; and xylenes, 26 ug/L in August 2010; all influent water sample <br /> constituents were non-detect in September 2010, and likewise, non-detect during the two months prior <br /> to the August 2010. The Report recommends the following changes: <br /> • Reduce the semi-annually monitored wells to annual monitoring (MW-4B, MW-7A, MW-8B, EW-4 <br /> and EW-5) <br /> • Reduce the R5-2008-0085-013 requirement for quarterly acute toxicity testing to annual acute <br /> toxicity testing. <br /> • Continue operation of the GWETS using extraction wells EW-6A, EW-7A, EW-7B, EW-8B and EW- <br /> 9B, and discontinue operation of EW-10A. <br /> • Continue monthly collection and MTBE analysis of influent, MID-2, and effluent samples for <br /> R5-2008-0085-013 analysis, and discontinue collection of MTBE analysis of GWETS MID-1 <br /> sampling as redundant when MID-2 is analyzed. <br /> California Environmental Protection Agency <br /> V4 Recycled Paper <br />