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R•oval Water Quality Control Board <br /> California g > " <br /> Central Valley Region <br /> Robert Schneider,Chair Gray Davis <br /> Governor <br /> Winston H.Hickox Sacramento Main Office <br /> secretaryfor <br /> Environmental Internet Address: her Rad,Suite A s, w <br /> , mento, .clifonia95b <br /> Protection 3443 Roupho eo (91)255-3000 r FAX(916)255-3015$27 3003 <br /> 28 March 2001 <br /> Mr. Jeff Goold <br /> Equiva Services LLC <br /> 10602 NE 38th Place <br /> Kirkland,WA 98083 <br /> REVIEW <br /> F REPORTS,EQUILON <br /> EMONTORINGNTEIRPRISES LLC BULK FUEL TERMIIREPORTING NAAL ,SSTOCKTON,SAN JOAQUIN COUNTY <br /> We have reviewed the following reports prepared for Equilon Enterprises, LLC `s (Equilon) Stockton <br /> Bulk Fuel Terminal (site)by Toxichem Management Services,Inc. (Toxichem). <br /> 9 January 2001 Site Investigation Report(Investigation Report); and <br /> 9 January 2001 Quarterly Monitoring Report—Fourth Quarter 2000 (Quarterly Report); <br /> 31 January 2001 Annual Monitoring Report—2000(Annual Report) <br /> These reports were submitted by Equiva Services,LLC (Equiva), a service organization that manages the <br /> environmental assessment and remediation for Equilon. The Investigation Report discusses the soil and <br /> groundwater analytical results of two monitoring wells installed on 6 October 2000. The Quarterly <br /> Report discusses the 2 November 2000 groundwater sampling event and the groundwater extraction <br /> system operation. The Annual Report discusses groundwater trends and data for 2000 and provides <br /> comments to the draft revised Monitoring and Reporting Program (MRP). <br /> We have the following comments on these reports: <br /> 1. The Quarterly Report does not discuss all analytical results,highest concentrations, trends and if <br /> results are consistent with historical data. It also does not discuss groundwater elevations, <br /> gradients, and trends. Subsequent reports must discuss this information. <br /> 2. The Quarterly Report does not include a quality assurance/quality control (QA/QC) section that <br /> discusses QA/QC samples submitted to the laboratory or interpretation of how samples analyzed <br /> outside of the recommended EPA holding times impacted data quality. It also does not discuss <br /> how analyzed dates for volatile groundwater samples are several days after the preparatory date <br /> and why the duplicate groundwater sample results for monitoring well MW-15 are significantly <br /> different than the primary results. Subsequent reports should include a QA/QC section to discuss <br /> analytical data. <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br /> 1'he energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> Fora list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5 <br />