SITE INFORMATION AND CORRESPONDENCE

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Flag City Chevron 6421 Capitol Avenue, Lodi - 2 - 4 June 2001 • Elimination of groundwater analysis for methanol, ethanol, 1,2-DCA, EDB, and total lead from the influent and effluent monitoring program General Order No. 5-00-119. Board staff agree to continue alternating groundwater extraction from the two trench lines. However,based on the MtBE concentrations identified in EW-4, this well should be operated continuously to reduce surrounding MtBE concentrations. Board staff also agree with installation of fuel-dispenser containment pans beneath each fuel dispenser. As required by Senate Bill 989, facilities that were installed after 1 July 1987 without under-dispenser containment and are located within 1,000 feet of a public drinking water well are to install under-dispenser containment by 1 July 2001. Mr. Doug Wilson of the San Joaquin County Environmental Health Division(County)requested you to install dispenser pans and complete a tracer type test on 17 August 2000, and again on 6 October 2000. To date, these requirements have not been met, and failure to complete this required work may exacerbate the contamination problem causing longer cleanup time. In addition, failure to comply with UST regulations may result in loss of reimbursement funding from the UST Cleanup Fund, and subject you to formal enforcement actions including monetary civil liability. Board staff do not agree to eliminate groundwater analyses for methanol, ethanol, 1,2-DCA,EDB, which are required by C&A Order No. 5-00-700. In review of the analytical lab reports presented in the QMR,your lab is running EPA Method 8015/8020 for gasoline and BTEX, and EPA Method 8260 for fuel oxygenates,methanol, ethanol, 1,2-DCA and EDB. Some labs can run the EPA Method 8260B for all constituents,thereby saving considerable cost, and you may want to contact additional labs for cost comparisons. Board staff cannot determine if you have met the requirements for reduction or elimination of methanol, ethanol, 1,2-DCA, EDB, and total lead analyses as required by the monitoring and reporting program under General Order No. 5-00-119 because the reporting requirements are incomplete. This will be discussed below. However, to determine if you have met the requirements, see the footnotes included in the General Order No. 5-00-119 Monitoring and Reporting Program for influent, effluent,and receiving waters. These footnotes identify certain constituents that can be reduced or eliminated from analysis if they are not detected in a set number of sampling events. For example, if lead is not detected in the influent samples for the first two sampling events, then testing for lead may be discontinued thereafter. As required in the Monitoring and Reporting Program for General Order No. 5-00-119 for discharge to surface waters of groundwater from cleanup of petroleum fuel pollution, the influent, effluent, and receiving water must be monitored on a monthly basis and reported. Tables 1 and 2 in the QMR present some of the required data; however, the tables are incomplete. Tables I and 2 are deficient in reporting the following required information: • Influent sample results for lead analysis in February. • Influent sample results for all constituents in the month of March. • Effluent sample results for TDS and nitrate in February. • Effluent results for temperature and flow rate. • Receiving water sample results for all constituents in the month of February. • Receiving water sample results for nitrate in March. • Receiving water results for temperature and flow rate. An additional row is needed in Table 2 to list receiving water parameters at station R-1. If there is no flow at station R-1,please state"no flow" or"dry". As we move into the irrigation season, there will be flow at R-1,