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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Terry Tamminen <br /> Robert Schneider,Chair a <br /> Secretary for Sacramento Main Office Arnold Schwarzenegger <br /> Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 LI 11� (���� ernor <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 IJ ll 1� 1w e v <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> 27 February 2004 MAR o 1 2004 <br /> ENVir ONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Richard Brandes <br /> ST Services <br /> 2801 Waterfront Road <br /> Martinez, CA 94553 <br /> REVIEW OF BIOREMEDIATION PILOT STUDY IMPLEMENTATION REPORT, <br /> ST SERVICES TERMINAL #29, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board) has reviewed <br /> the 16 February 2004 Enhanced Bioremediation Pilot Study Implementation Report(Report) <br /> submitted by Hart Crowser(HC) on behalf of Support Terminals Operating Partnership, LP <br /> (ST Services) for Terminal#29 in Stockton(site). As required by Waste Discharge <br /> Requirements (WDRs) Order No. R5-2003-0165, the Report discusses the installation of two <br /> extraction wells, three injection wells, six groundwater monitoring wells, and the remediation <br /> system, and provides the results of the baseline and two-week sampling events. <br /> The Report is insufficient. WDRs Order No. R5-2003-0165 requires the Pilot Study <br /> Implementation Report to include results from the first month of operation. The Report includes <br /> a discussion of the baseline and two-week samples, but not the first month sample,which was <br /> collected 39 days after start-up of the system. Furthermore, we are concerned that although a part <br /> of the system was shut down for an unknown amount of time, Regional Board staff was not <br /> notified once ST Services noticed the problem, as required by WDRs Order No. R5-2003-0165. <br /> Even more disturbing is the 16 December 2003 letter from Enzyme Technologies, Inc. (ETI) to <br /> HC that is included in Appendix D of the Report that states, "site personnel may not fully <br /> understand that they need to check the system weekly(daily, if possible)to ensure that it <br /> continues to operate." Despite this recommendation, the Super OxTM was not operating when <br /> ETI returned to the site on 16 January 2004. The Report does not discuss the one-month samples <br /> collected from three wells or how the shutdown of the Super OxTM unit may have affected the <br /> sampling results. <br /> In addition to not complying with the WDRs, ST Services did not comply with Monitoring and <br /> Reporting Program (MRP)No. R5-2003-0165. Table 1 of the MRP requires additional wells to <br /> be sampled if PS-2 sample results showed injected materials had reached it. Based on nitrate <br /> increasing from nondetectable (ND) to 290 milligram per liter(mg/1),potassium increasing from <br /> ND to 3.8 mg/l, and ortho-phosphorus increasing over 200 percent between the baseline and two- <br /> week samples collected from PS-2, ST Services should have also sampled wells PS-3, PS-5, and <br /> California Environmental Protection Agency <br /> Za Recycled Paper <br />