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IPLn e,..n�U • PFTF WII Cf1N r:nyArnn <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD E",I_Tli <br /> ' CENTRAL VALLEY REGION ;,FRVICE <br /> 3443 Routier Road,Suite A fi <br /> Sacramento, CA 95827-3098 - �1 o i <br /> PHONE: (916) 255-3000 J4 KAR —4 `pit M I'. Jv <br /> FAX: (916) 255-3015 <br /> 1 March 1994 <br /> Mr. Steve M. Ferrara <br /> Santa Fe Pacific Pipeline Partners, L. P. <br /> 888 South Figueroa Street <br /> Los Angeles, CA 90017 <br /> ADDITIONAL SITE ASSESSMENT WORK PLAN, SANTA FE PACIFIC PIPELINES, <br /> STOCKTON FACILITY, SAN JOAQUIN COUNTY <br /> I have reviewed your 13 January 1994 letter and Hart Crowser's 6 January 1994 letter and Work <br /> Plan for Additional Environmental Services for your Stockton facility. My comments are presented <br /> below. <br /> 1. Ground water contour maps such as those attached to this letter should be submitted with <br /> quarterly monitoring reports to facilitate my review of ground water monitoring data and <br /> determination of ground water flow direction. A contour map also depicts the overall site- <br /> specific ground water flow regime much more graphically than the arrows used in the Hart <br /> Crowser figures. <br /> 2. The work plan proposes to auger and sample three shallow soil borings, install an upgradient <br /> monitoring well in Zone B, prepare an interim technical memorandum, conduct a field <br /> treatability study for in-situ bioremediation, and prepare a remedial action plan. <br /> Although the regional ground water flow direction is generally from the northwest to southeast, <br /> the data and figures presented in Hart Crowser's 6 January 1994 letter and the ground water <br /> contour maps attached to this Letter show that the ground water flow direction in Zone A varies <br /> considerably depending on the season. It is likely that Zone B ground water also behaves in a <br /> similar manner. Therefore, installation of only one well in Zone B is not adequate. At a <br /> minimum, two additional wells should be proposed. <br /> 3. Due to the proximity of SFPP to other fuel terminals, controls may have to be used to prevent <br /> the migration of contaminants to adjacent terminals during the pilot testing of in-situ <br /> bioremediation at the site. These field study controls need to be specified in the work plan. <br /> 4. I suggest that implementability be included as a criterion in evaluating remedial alternatives for <br /> the site. <br />