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STATE OF»CALIFORNIA - Environmental Protectil!Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routiar Road, Suite A ' <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 <br /> FAX: (S 16) 255-3015 IV� <br /> 30 September 1994 <br /> OCT U 3 1994 <br /> ENVIRONMENTAL RMILTH <br /> PERMIT/SERVICES <br /> Mr. Steve M. Ferrara <br /> Santa Fe Pacific Pipeline Partners, L. P. <br /> 888 South Figueroa Street <br /> Los Angeles, CA 90017 <br /> STATUS REPORT, SANTA FE PACIFIC PIPELINES, STOCKTON FACILITY, SAN <br /> JOAQUIN COUNTY <br /> I have reviewed Hart-Crowser's 28 July 1994 Status Report and 14 September 1994 Work <br /> Plan for Pilot Testing of Air Sparging for your Stockton facility. My comments are <br /> presented below. <br /> 1. The status report provided the following tasks and schedule: <br /> Task Completion Date <br /> Step-rate Pumping Test Week of 15 August 1994 <br /> Submit Biosparge Work Plan to RWQCB Week of 15 August 1994 <br /> Select and Install Extraction Pump in Well M-1 Week of 29 August 1994 <br /> Perform Biosparge Test Week of 5 September 1994 <br /> Submit Remedial Action Plan to RWQCB Week of 26 September 1994 <br /> The completion dates for all of the tasks have already passed. I request that you <br /> submit a report describing the status of each task with a revised schedule for tasks <br /> which have not been completed to date. <br /> 2. On 27 September 1994, I verbally approved the work plan for the pilot test which is <br /> part of the remediation alternatives evaluation needed to determine a cost-effective <br /> means of remediating contaminated soil and ground water at the site. However, I am <br /> concerned about the proposed method specifically with regards to contaminated vapor <br /> and ground water migration. If the pilot test shows biosparging is a viable option, <br /> measures must be provided to control offsite migration. Migration and remediation <br /> issues can be more easily addressed area-wide than on a site-by-site basis. Therefore, I <br /> strongly urge you to join the Stockton Terminal Technical Committee since it is likely <br /> that contamination from each site has commingled with the contamination from other <br /> sites and delineation of the source of contamination is infeasible. <br />