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New West Petroleum #1003 • 2 - . 24 July 2008 ' <br /> Lodi, San Joaquin County <br /> The FRP includes the biding/contracting information, an Operations and Maintenance (O&M) <br /> Manual to be kept onsite for CSI staff responsible for the GWP&TS, and a schedule for the <br /> installation of the GWP&TS modifications. The startup/system shakedown target date of <br /> 30 November 2008, complies with CAO Order 16, which states "Within 60 days of Water Board <br /> staffs approval of the FRP but no later than November 2008, begin implementation of the <br /> approved remedial actions." <br /> Comments: <br /> 1. FRP Section 4.3 states the construction plans are "...preliminary design drawings..."but <br /> does not state when final design drawings will be submitted. There are discrepancies in <br /> the total number of piping runs in the conduits between drawings, and a reference to an <br /> interim extraction well (EW-6). Currently only five (EW-1 through EW-5) extraction wells <br /> have been installed. Please revise the electronic copy of the FRP in Geotracker and <br /> provide replacement pages to this office by 15 September 2008. Any changes made <br /> during construction will be documented in the next Annual Report (see Monitoring and <br /> Reporting Program # R5-2007-0808). <br /> 2. Section 5.3 of the O&M Manual includes a response plan in event of a mechanical failure <br /> or accidental discharge from the GWP&TS. The FRP states that, in case of an <br /> unauthorized release, the existing storm sewer drainage would be protected by berms <br /> and absorbent materials. Please include a figure showing the locations of storm sewer <br /> inlets with the replacement pages listed above by 15 September 2008. The figure will <br /> assist responders in locating said drains. Also, notify Regional Board staff immediately <br /> by phone or email if there has been an unauthorized release from the GWP&TS. <br /> 3. The FRP does not address CAO Order 17, which states "Submit for remediation <br /> system(s), monthly status reports for the first three months of operation of any new <br /> systems. At a minimum, the monthly status reports shall include site maps indicating the <br /> capture zone and waste plumes, average extraction rates of all treatment systems, <br /> influent and effluent concentrations of TPHg, benzene, toluene, ethylbenzene, xylene, <br /> MtBE and other fuel oxygenates, mass of hydrocarbons treated during the reporting <br /> period and cumulative to date, estimated mass of wastes remaining and predicted time <br /> frame for meeting cleanup objectives, running and down time for the remediation <br /> system(s), summary of consultant visits to the site, and evaluation of the overall <br /> remediation program and recommendations to correct deficiencies or increase <br /> efficiency." The monthly reports shall be included in the Annual Report (see Monitoring <br /> and Reporting Program # R5-2007-0808). <br /> 4. CAO Order 21 also provides additional requirements for startup where an unscheduled <br /> shutdown occurs: "Upon startup of any remediation system(s), operate the remediation <br /> system(s) continuously, except for periodic and required maintenance or unpreventable <br /> equipment failure. The Discharger shall notify the Water Board within 24 hours of any <br /> unscheduled shutdown of the remediation system(s) that lasts longer than 48 hours. <br /> This notification shall include the cause of the shutdown and the corrective action taken <br /> (or proposed to be taken) to restart the system. Any interruptions in the operation of the <br /> remediation system(s), other than for maintenance, emergencies, or equipment failure, <br /> without prior approval from Water Board staff or without notifying the Water Board within <br />