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• <br /> New West Petroleum #100 2 - 23 February 2009 <br /> Lodi, San Joaquin County <br /> and EW-10A) are scheduled to go online in March 2009 to increase the MTBE plume capture rate and to <br /> reduce risk of MTBE impacting municipal well CSA-31 Well 2. <br /> My comments and additional directives are: <br /> 1). The Request is approved with the following modifications to the proposed changes: <br /> There will be no changes to municipal well CSA-31 Well 2 sampling frequency (quarterly), due to <br /> the need to protect human health and due to its proximity (<500 feet) to the known extent of the <br /> MTBE plume; however, the analyses are reduced to MTBE. <br /> Municipal well CSA-31 Well 1 is removed from the MRP required sample list for petroleum <br /> hydrocarbons, due to the distance (>1,000 feet) downgradient from the known extent of the <br /> MTBE plume and from municipal well CSA-31 Well 2. <br /> 2). Currently the required monthly sampling of effluent discharged from the Site treatment plant under <br /> the existing NPDES general order discharge permit (Permit) is reported quarterly in the Site <br /> monitoring reports, as previously directed by Regional Board staff to reduce the cost to the UST <br /> Cleanup Fund. Recently Regional Board staff have been directed to request monthly reports for all <br /> Permits, to prevent the possibility of Mandatory Minimum Penalties (MMP) multiplying over several <br /> months due to accruing late report violations (i.e., one MMP violation in January that is not reported <br /> until last day of April in a quarterly report, would be considered a late report violation for January, <br /> February, and March with three times the fine for one month's violation). Therefore, you are to <br /> submit monthly Permit reports by the I oth day of the following month, consisting of the required <br /> effluent sample analytical lab data sheets with an updated section of Table 4 Groundwater <br /> Treatment System Analytical Data for that month onl as an email attachment (PDF format) to <br /> myself at the email address below. You are to continue submitting the entire Table 4 and copies of <br /> the three months of all treatment system analytical lab sheets as EDF data and Quarterly Reports to <br /> GeoTracker, and in Quarterly Reports as a paper copy to this office. Note that anon-detect sample <br /> result after initial treatment (first treatment unit) shall be considered to be the functional equivalent of <br /> an effluent sample as long as there is no technical reason to suspect that an effluent sample taken <br /> farther downstream, if analyzed, might be impacted by a Site constituent of concern. <br /> If contaminant concentrations increase significantly in any of the wells, Regional Board staff will <br /> reevaluate the approved changes to the MRP and may reinstitute quarterly monitoring for those wells as <br /> appropriate. In the future, I will be your one point of contact for the Permit and for the CAO/MRP. <br /> If you have any questions or comments, you may call me at (916) 464-4615 or email me at <br /> i ba rton(a)wate�rbbo)a r1d�s,.cca..g ov. <br /> JAMES L.L. BARYON, P.G. <br /> Engineering Geologist <br /> UST Enforcement Unit II <br /> cc: Mr. Mark Owens, UST Cleanup Fund, SWRCB, Sacramento <br /> Ms. Margart Lagorio, San Joaquin County Environmental Health Departme <br /> Mr. Ron Chinn, Closure Solutions, Inc., 1243 Oak Knoll Dr., Concord 94521 nt, Stockton <br />