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California Regional Water Quality Control Board <br /> Central Valley Region M' <br /> Robert Schneider,Chair <br /> Dr.Alan Lloyd <br /> Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.waterboards.ca.gov/centralvalley <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> 22 December 2004 <br /> DEC 2 3 2004 <br /> ENVRUNMEW N`cl;Li!1 <br /> Mr. Richard Brandes PEi li IT/SERVICES <br /> ST Services <br /> 2801 Waterfront Road <br /> Martinez, CA 94553 <br /> REVIEW OF MONITORING REPORT AND PROPOSED POST-PILOT STUDY OPERATION <br /> MONITORING PLAN, SUPPORT TERMINALS OPERATING PARTNERSHIP, <br /> LP TERMINAL#29, 2941 NAVY DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board)reviewed the <br /> 29 October 2004 Groundwater Monitoring Report Third Quarter 2004 (Report) and the <br /> 11 November 2004 Proposed Post-Pilot Study Operation Monitoring Plan (Letter) submitted by <br /> HartCrowser on behalf of ST Services bulk fuel terminal#29 at 2941 Navy Drive in Stockton (site). The <br /> Report discusses the groundwater monitoring activities conducted in August and status of the <br /> bioaugmentation pilot study and proposes to eliminate sampling for four of the seven fuel oxygenates <br /> required by Monitoring and Reporting Program (MRP)No. R5-2004-0822. The Letter proposes two <br /> additional post-pilot study monitoring events to evaluate the pollutant concentrations up and <br /> downgradient of the pilot study treatment area. <br /> We have the following comments on the Report: <br /> 1. The Report states detections of pollutants in off-site wells OW-7C and OW-8C are potentially <br /> from an off-site source unrelated to ST Services operations. ST Services needs to collect <br /> additional data that would support this conclusion and identify the off-site source. <br /> 2. The laboratory analytical data sheets do not state the method for analyzing total petroleum <br /> hydrocarbons as diesel (TPHd),but does state the extraction and silica gel cleanup method. The <br /> water quality standard for TPHd is not based on results after silica gel cleanup,which is <br /> inappropriate to use. Furthermore, the analytical method required by MRP No. R5-2004-0822 <br /> for TPHd is EPA Method 8015. <br /> 3. Regional Board staff does not concur with removal of any fuel oxygenates from the required <br /> sampling. The fuel oxygenate sampling must meet the requirements of MRP No. R5-2004-0822 <br /> before any constituent is no longer required for sampling. Based on review of historical data for <br /> the site, the following is the list of monitoring wells with fuel oxygenate sampling requirements: <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />