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California Regional Water Qualit "Wrd <br /> vCentral Valley Region <br /> Robert Schneider,Chair Jl1N 21 2004 <br /> Terry Tamminen Arnold Schwaaenegger <br /> secretary for 11020 Sun Center Drive#200 Rancho Cordova,CA 95 Governor HEALTH Governor <br /> Environmental (916)464-3291•Fax(916)464-4704 <br /> Protection hnp:H/ .sw b.ca.gov/mgcb5 PERMIT/SERVICES <br /> 17 June 2004 <br /> Mr. Cecil Dillon Mr. Richard Bokides Mr. Navtej Dhingsa <br /> Flag City Ltd. Partnership Bokides Family Ltd. Partnership First Investment Flag City, Inc. <br /> 1820 W. Kettleman Lane, Suite E 6421 Capitol Avenue 517 Coronawood Lane <br /> Lodi, CA 95242 Lodi, CA 95242 Carmichael, CA 95608 <br /> REPORT REVIEW, FLAG CITY CHEVRON, 6421 CAPITOL AVENUE, LODI, SAN JOAQUIN <br /> COUNTY, CLEANUP AND ABATEMENT ORDER (CAO)NO. 5-00-700 <br /> I reviewed the Addendum to the Quarterly Report—First Quarter 2004: 2003 Annual Report(Report), <br /> received 2 June 2004 (due on April 30 per CAO No. 5-00-700), submitted on Chevron's behalf by <br /> Advanced GeoEnvironmental, Inc (AGE). The Report states that the Flag City Chevron Pump and <br /> Treatment (P&T) System is approaching the asymptotic point of diminishing returns and estimates the <br /> completion of remedial activities by May 2005. The Report recommends that: "The pump and treat <br /> system should be continued at the site until a point of diminishing return is achieved, which can be argued <br /> is when the resulting concentrations vary less than 10%for six consecutive months; based on the data ... <br /> it appears that the Flag City Chevron pump-and-treat remediation system is approaching a point of <br /> diminishing returns." The Report does not recommend changes to the groundwater pump and treatment <br /> system (P&T System) or the MRP. <br /> I agree that "...groundwater pump and treat is the most effective available and practical remediation <br /> method far at least an additional six to twelve months." However, I do not unequivocally agree that the <br /> P&T system should be turned off when extraction concentrations vary by less than 10% over a six to <br /> twelve month period,nor that the rebound test should be initiated "Upon approaching this "asymptotic" <br /> condition,... " Completion of remedial activities is based upon restoration of beneficial uses to the <br /> resources to the greatest extent feasible. Even if extraction rates are asymptotiical but significant amounts <br /> of contamination are still being removed, or water quality objectives are not met, future remediation is <br /> required. <br /> My 25 May 2004 letter requested information on individual extraction well concentrations/operations in a <br /> tabular format, to help assess status of the groundwater extraction pumps and provide a rationale for <br /> operation/non-operation of each extraction well. The Report did not include the tabular information. hi <br /> order to demonstrate the tabular format you are to use, I have included a draft table (enclosure), compiled <br /> from the four 2003 quarterly reports, the first 2004 quarterly report, and information from phone <br /> conversations with AGE staff on 17 May and 9 June of 2004. In addition to the draft table, I have also <br /> included graphs (enclosure) of the Methyl tert-Butyl Ether concentrations for each extraction well over the <br /> last five quarters. Please include the updated tabular information and graphs of chemical data in future <br /> reports. An electronic copy will be provided to AGE. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />