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` <br /> California Water Quality CAtrol Board <br /> a <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/—rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 D <br /> Phone(916)255-3000•FAX(916)255-3164 <br /> 8 September 2003 SEP 0 9 2003 <br /> Mr. Mike Pitta - ENVIRONMENT HEALTH <br /> Kinder Morgan Energy Partners PERMIT/SERVICES <br /> 1100 Town and Country Road <br /> Orange, California 92868 <br /> BIOREMEDIATION PILOT STUDY, HINDER MORGAN ENERGY PARTNERS, <br /> HOLT PIPELINE RELEASE SITE, SALIN JOAQUIN COUNTY <br /> We have reviewed the 3 July 2003 Bioremediation Pilot Study in Lieu of Continued <br /> Groundwater Pump and Treat for the SFPP, L.P. Holt Release Site Work Plan (Work Plan) <br /> completed by CH2M Hill on behalf of Kinder Morgan Energy Partners, L.P., through its <br /> operating partner SFPP, L.P. (KMEP) for the Holt Pipeline Release Site in Holt, San Joaquin <br /> County(site). The Work Plan proposes to 1)permanently shutdown the groundwater pump and <br /> treat and soil vapor extraction systems, 2) conduct groundwater monitoring and reporting in <br /> accordance with MRP No. R5-2003-0811, and 3) perforin a final evaluation and submit a report. <br /> We have also reviewed the 31 July 2003 First Semiannual 2003 Groundwater Monitoring Report <br /> for the SFPP, L.P. Holt Release Site (GMR). The GMR reported that for the last sampling event <br /> in June 2003 benzene concentrations in the source area at monitoring well N-7 were at 9,100 µg/1 <br /> and total petroleum hydrocarbons in the gasoline range (TPHg) were at 48,000 µg/1. The highest <br /> pollutant concentrations in the toe of the plume were in monitoring well N-17, which contained <br /> 330 µg/1 of benzene and 1,100 µg/l of TPHg. <br /> Our 20 February 2003 meeting summary letter stated, "During the meeting, we also discussed <br /> site characterization and remedial options... we concurred with your recommendation to submit <br /> a technical memo that outlines previous interim remedial measures and proposes <br /> phytoremediation for a final remedial measure for the source area clays and peat, as well as <br /> bioremediation pilot study in lieu of continued groundwater pump and treat at the toe of the <br /> pollutant plume." <br /> We have not yet received the phytoremediation work plan for the source area. We will not <br /> authorize KMEP to cease their current treatment methods without an approved final remedial <br /> action plan (RAP) that includes the phytoremediation component as plain-led. Thus, at this time <br /> we do not concur with the Work Plan. <br /> California Environmental Protection Agency <br /> Zp Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to tale immediate action to reduce energy consumption. For a list of <br /> simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5 <br />