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`� California*gional Water Quality Corol Board <br /> l\v- Central Valley Region <br /> Karl E. Longley,ScD,P.E.,Chair <br /> Linda S.Adams I� <br /> 0 <br /> Secrerogfor I�1���'l�//,h� Sacramento Main Office Arnold <br /> Fnvrronmenral llll IIJJ ul +2 Ste' enter Drive#200,Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Prorecrron Phone(916)464-3291 •FAX(916)464-4645 Governor <br /> APR - 7 2008 http://wwwwaterbouds.ca.gov/centralvalley <br /> 3 April 2008 ENVIRONMENT HEALTH <br /> Mr. Gil Moore PERMITiSERVICES <br /> New West Petroleum, Inc. <br /> 1831 16" Street <br /> Sacramento, CA 95814 <br /> DOCUMENT REVIEW, NEW WEST PETROLEUM #1003 (SHELL BRANDED), <br /> 6437 BANNER STREET, LODI, SAN JOAQUIN COUNTY(CAO R-5-2007-0709) <br /> I reviewed the Feasibility Study (FS), submitted 2 April 2008 by your consultant Closure <br /> Solutions, Inc. (CSI) in response to the Regional Board Cleanup and Abatement Order No. <br /> R5-2007-0709 (CAO). The CAO requires in Order #12, "By 18 April 2008, submit a Feasibility <br /> Study that provides a summary of remedial alternatives evaluated to address applicable <br /> cleanup levels for the affected or threatened human health and/or waters of the State. The <br /> Feasibility Study shall propose at least two remedial technologies that have a substantial <br /> likelihood to achieve cleanup of all impacted soils and groundwater and shall include a schedule <br /> for achieving cleanup. The remedial technologies must be evaluated with respect to their ability <br /> to be implemented, cost, and effectiveness. The Feasibility Study shall include the rationale for <br /> selecting the preferred remedial alternative. The Discharger shall attempt to clean up each <br /> constituent to background concentrations, or to the lowest level that is technically and <br /> economically achievable and which complies with all applicable WQOs of the Basin Plan and <br /> promulgated water quality criteria."and in Order#13, "The Feasibility Study shall evaluate <br /> remedial options to prevent MtBE and other petroleum hydrocarbon impacts to CSA-31 Well 1 <br /> and Well 2." <br /> The maximum groundwater concentrations reported in October 2007 during routine quarterly <br /> monitoring were methyl tert butyl ether (MTBE), 3,300 micrograms per Liter (ug/L); total <br /> petroleum hydrocarbons as gasoline (TPHg), 300 ug/L; benzene, 8.4 ug/L; ethylbenzene, <br /> 3.0 ug/L; toluene, 6.7 ug/L; xylenes, 3.0 ug/L; tertiary amyl methyl ether, 1.7 ug/L; ethanol, <br /> 31 ug/L; and methanol, 94 ug/L. Depth to groundwater is approximately 15 feet below ground <br /> surface. <br /> The FS lists TPHg, benzene, and MTBE as constituents of potential concern (COPCs). MTBE <br /> is listed as the primary COPC due to the lateral extent of the MTBE groundwater plume in the <br /> aquifer A-zone (enclosed Figure 5) and in the aquifer B-zone (Enclosed Figure 6), and the <br /> predominantly southeastern plume migration path towards municipal supply wells (one well, <br /> CSA-31-2, is shown in the enclosed figures). Since April 2006, an interim Groundwater Pump <br /> and Treatment (GWP&T) involving five onsite extraction wells has reduced the MTBE <br /> concentrations up to two orders of magnitude onsite; however, the current treatment system <br /> does not extract water from the leading edge of the groundwater plume and does not provide <br /> hydraulic control of the MTBE plume. The estimate of residual MTBE mass in soil is 91 gallons, <br /> California Environmental Protection Agency <br /> �d Recycled Paper <br />