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• • ATTACHMENT 1 <br /> MEMORANDUM <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: Wendy L. Cohen FROM: Philip S. Isorena <br /> Senior Engineer Sanitary Engineering Associate <br /> DATE: 10 March 1992 SIGNATURE: Ay- <br /> SUBJECT: SANTA FE PACIFIC PIPELINE PARTNERS (SFPP), L. P. , PORT OF STOCKTON FUEL <br /> TERMINAL, INVESTIGATION REPORTS <br /> I have reviewed the following reports: Tracer Leak Test of Three Underground Pipe <br /> Lines at the Stockton Station, Stockton, California, Tracer Research Corporation, <br /> March 1988; Investigation of Subsurface Fuel Hydrocarbons, Southern Pacific <br /> Pipelines, Inc. , Levine-Fricke, 23 March 1988; and Ground Water Investigation and <br /> Environmental Assessment, Stockton Terminal, Stockton, California, 28 April 1989. <br /> My comments are presented below. <br /> 1. Tracer Leak Test of Three Underground Pipe Lines at the Stockton Station, <br /> Stockton, California. This report describes testing of three SFPP pipelines with <br /> the use of tracer gases which were introduced as liquids in the pipelines which <br /> contained petroleum products. <br /> a. The table below presents the kind of tracer was introduced in each pipeline. <br /> Pipeline Tracer Amount <br /> Mobile/Shell Sulfur Hexafluoride 224 Pounds <br /> SFPP Mainline Bromotrifluoromethane 168 Pounds <br /> Time Oil Line Bromochlorodifluoromethane 170 Pounds <br /> It is evident that three types of tracers were used to identify the source of the <br /> leak. In spite of the different products used in each line, no rationale was <br /> provided for the type and amount of tracer used. Furthermore, The Merck Index <br /> describes sulfur hexafluoride as one of the heaviest known gases. Is this <br /> compound an appropriate tracer? I was unable to find any information on the <br /> other two tracers. <br /> b. The point where each tracer was introduced was not identified. <br /> c. Page 1 of the report says the detection limit was 1-10 parts per trillion. <br /> Results show unidentified units and detection limits of <1000 for sulfur <br /> hexafluoride and bromotrifluoromethane, and detection limits of <1000, <2000, <br /> <5000, and <10000 for bromochlorodifluoromethane. <br /> d. Except in Time Oil ' s case where the report says 80 probe samples were taken to <br /> closely determine the source of the tracer, the rationale for the location and <br /> number of samples was not given. <br />