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Wendy L. Cohen - 3 - 21 September 1999 <br /> 8. Board correspondence dated 16 July 1999,Requirement for Documents Pursuant to Water Code <br /> Section 13267, required KMEP to submit an individual NPDES permit application for the Holt <br /> petroleum release site. In response, LFR Levine-Fricke submitted NPDES application Form 2D and <br /> Form 200 on behalf of KMEP. This submittal is seriously deficient. Form 1 was not submitted and <br /> Form 2D and Form 200 are incomplete. The supplemental information required by Section VI of <br /> Form 200 was addressed by submitting documents dated 26 July 1995 and 7 June 1993, which cite <br /> Santa Fe Pacific Pipeline Partners, L.P.'as the Discharger and contain very old data. I will provide <br /> detailed comments and a request for additional information in separate correspondence. <br /> 9. As recommended in the Results of the Installation and Sampling of Groundwater Monitoring Well <br /> N-20, the revised draft MRP has been modified to include well N-20 in the quarterly sampling. <br /> 10. The Preliminary Results of Lithologic and Deeper Groundwater Investigation states that the vertical <br /> extent of contamination will be assessed when ire iaboiatory results are available. LFR Levine- <br /> Fricke states they will submit a final report of results by 24 September 1999. <br /> 11. The Work Plan to Conduct a Capture Zone Analysis of the Groundwater Extraction System <br /> recommends that the capture zone be evaluated for the design flow rate of 10 gallons per minute <br /> (gpm) for each extraction well RW-1,RW-3 and N-17. However, the design flow rate of 30 gpm for <br /> this system will have a different capture zone than the current operating flow rate of between four <br /> and six gpm. KMEP needs to conduct a capture zone analysis using its typical operating parameters. <br />