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Quality Control Boarda California Regio0 nal Water Qu y Central Valley Region Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swreb.ca.gov/—rwgcb5 E Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Cti I Phone(916)255-3000•FAX(916)255-3164 U �7 12 June 2001 JUN 14 2 U 01 ENVIRON'h Ms. Jill Jefferson PERMIT/.' ; Kinder Morgan Energy Partners 1100 Town and Country Road Orange, California 92868 REMEDIAL STATUS, KINDER MORGAN ENERGY PARTNERS, HOLT RELEASE SITE, SAN JOAQUIN COUNTY We have reviewed the current remedial status at the Kinder Morgan Energy Partners (KMEP) through its operating partnership SFPP, L.P. Holt petroleum release site. We have the following comments. On 16 July 1999, we issued a Requirement for Documents Pursuant to Water Code Section 13267 for this site. Our concerns at the time were twofold. First, there was clearly an inability of KMEP and its consultant LFR to implement approved work plans within the proposed work schedule. Our second concern was that this release of pollution to the environment occurred in 1986 and remedial measures have occurred piecemeal since then, without a long-term remedial action plan. Unfortunately, we still have the same concerns. The 30 April 2001 Quarterly Groundwater Monitoring Report for the First Quarter of 2001 states that the groundwater extraction and treatment system was shut down on 29 March 2001 because of a tertiary butyl alcohol (TBA) effluent violation. Waste Discharge Requirements Order No. 5-00-217 contains an effluent limit for TBA of 20 µg/1, and the 25 April 2001 National Pollution Discharge Elimination System (NPDES)Monitoring Report, First Quarter 2001 states the 22 January and 15 March effluent contained 38 µg/1 and 23 µg/1, respectively. KMEP collected two effluent samples in February, and these contained no TBA at a detection limit of 10 µg/l. At the time the Board adopted the NPDES Order on 27 October 2000, we knew that the ambient concentration of MTBE in Trapper Slough was about 3 µg/1, but we had no information about TBA. In addition, the detection limit for TBA in your influent samples is elevated because of the presence of other petroleum fuel products. Therefore, dilution credits written in this Order for barium, iron and zinc were not considered for methyl tertiary butyl ether(MTBE) and TBA and do not apply for any other compounds except those listed. Order No. 5-00-217 contains the protocol KMEP must follow once effluent limitations are exceeded, including a schedule to California Environmental Protection Agency 0a Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5