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STATE+7F CALIFORNIA—ENVIRONMENTAL CTION AGENCY -_ PETE WILSON, Govsma, <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (918) 255-3000 <br /> FAX: (918) 255-3015 <br /> 30 November 1992 DEC <br /> VED <br /> C 0 2 162 <br /> ENVIRONMENTAL <br /> NVIR9N <br /> fi%�TAL1MEA�TN <br /> Mr. Steve M. Ferrara <br /> Santa Fe Pacific Pipeline Partners, L. P. <br /> 888 South Figueroa Street <br /> %a Los Angeles, CA 90017 <br /> COMMENTS ON ADDITIONAL SITE ASSESSMENT WORK PLAN AND VERTICAL GROUND WATER <br /> GRADIENT EVALUATION, SANTA FE PACIFIC PIPELINE PARTNERS (SFPP) , STOCKTON <br /> FACILITY, SAN JOAQUIN COUNTY <br /> We have received two documents prepared by your consultant, Hart Crowser, <br /> Inc. , for your Stockton facility: Vertical Ground Water Gradient Evaluation <br /> dated 13 October 1992 and Additional Site Assessment Work Plan dated 20 <br /> October 1992. We have reviewed the two documents, and our comments are <br /> presented below. <br /> Vertical Ground Water Gradient Evaluation <br /> Analysis of soil liquid extracts is complicated by the variability of the <br /> matrix solution that is extracted from the soil because soils typically <br /> contain a variety of naturally-occurring organic and inorganic compounds which <br /> interfere with the detection capabilities for the hydrocarbons of concern <br /> (Presto, et. al ) . Furthermore, the attached table shows adsorption of <br /> constituents of concern to soil is much less than their solubility in ground <br /> water. Therefore, low or nondetection of petroleum hydrocarbons in saturated <br /> soil samples is not a good indicator of downward migration of these <br /> constituents. In addition, the results are not reproducible. <br /> We concur that the data from the ARCO investigation show that the horizontal <br /> velocities are greater than the vertical velocities. Nonetheless, the data <br /> show that the ground water flow has a vertical component. This vertical <br /> component has resulted in migration of contaminants into the next water <br /> bearing zone as shown by samples taken at ARCO. Furthermore, according to <br /> EMCON Associates, the results of the recently-concluded investigation at the <br /> other Port of Stockton fuel terminals also show contamination in the next <br /> water bearing zone (the investigation report is due on 23 December 1992) . <br /> Therefore, SFPP must determine if the next water bearing zone beneath its <br /> facility in Stockton has been affected by petroleum hydrocarbons. <br /> 1 j <br />