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Ms. Shelby Lathrop -2 - 12 January 2012 <br /> Former Tosco Bulk Terminal, <br /> 3505 Navy Drive, Stockton, San Joaquin County <br /> Our comments are: <br /> 1. Central Valley Water Board staff concur that the Site may be reviewed for low risk <br /> closure. By 15 March 2012, please prepare a No Further Action request in accordance <br /> with the requirements of the 16 April 2004 Appendix A — Reports Tri Regional Board <br /> Staff Recommendations for Preliminary Investigation and Evaluation of Underground <br /> Tank Sites (Appendix A). <br /> 2. Central Valley Water Board staff do not concur with the HHRA conclusion that Site <br /> groundwater concentrations will reach water quality objectives without any additional <br /> active remediation within five-to-ten years. The QMR shows that TPHd and TBA <br /> concentrations are stable or slightly increasing in several wells. <br /> 3. The QMR only includes isoconcentration contours for MTBE and TBA. The MRP <br /> requires ConocoPhillips to prepare isoconcentration contour maps for all contaminants <br /> of concern. The next monitoring report is due 1 February and needs to include <br /> isoconcentration contour maps for all contaminants. In addition, ConocoPhillips must <br /> continue to monitor the Site in accordance with MRP No. R5-2004-0824 during the <br /> closure evaluation. <br /> In summary, by 15 March 2012 ConocoPhillips needs to submit a No Further Action Request <br /> that includes the information outlined in Appendix A. In addition, future groundwater <br /> monitoring reports need to include trend graphs, updated estimates of when wells will reach <br /> WQOs, and isoconcentration contours for all contaminants of concern. If you have any <br /> questions regarding this letter, you may contact me at (916) 464-4819 or by email at <br /> kshelton waterboards.ca. ov. <br /> KRISTI SHELT N, P.E. <br /> Water Resources Control Engineer <br /> Aboveground Tanks Cleanup Unit <br /> cc: Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Richard Stiffler, City of Stockton — Department of Municipal Utilities, Stockton <br /> Ms. Debbie Callie, Port of Stockton, Stockton <br /> Mr. Mark O'Brien, Port of Stockton/ERSC, Alamo <br /> Mr. Jeff Kasper, Deputy Port Director, Environmental Planning & Facilities, Stockton <br /> Mr. Gabe Stivala, ATC, North Highlands <br /> Mr. Joe Aldridge, NuStar Energy, Texas <br /> Ms. Carol Campagna, Shell OPUS, Carson <br />