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moo <br /><IN <br />Linda S. Adams <br />Secreiaryfor <br />Environmental <br />Protection <br />Californh egional Water Quality Cor ol Board <br />Central Valley Region <br />Karl E. Longley, ScD, P.E., Chair <br />11020 Sun Center Drive (000, Rancho Cordova, California 95670-6114 <br />Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards.ca.govicentralvalley <br />Arnold <br />Schwarzenegger <br />Governor <br />5 November 2009 <br />Kerry Heckman, President <br />Connell Motor Truck Co., Inc <br />2211 North Wilson Way <br />Stockton, CA 95208 <br />• <br />NOV 1 0 2009 <br />D1\11410%1011 BEALTt-t <br />PERMITISOVICES <br />DOCUMENT REVIEW, CONNELL MOTOR TRUCK CO. AND RIVER CITY PETROLEUM, <br />2211 NORTH WILSON WAY, STOCKTON, SAN JOAQUIN COUNTY, CASE NOS. SL1863936 AND <br />390991 <br />I reviewed the Quarterly Report. Third Quarter 2009 (Report) submitted by your consultant Advanced <br />GeoEnvironmental Inc. The Report provides the results of the semi-annual monitoring event <br />conducted 23 September 2009. Active remediation by soil vapor extraction/air sparging (SVE/AS) was <br />shut down in December 2008 due to a lack of funding. A rebound test was conducted through the third <br />quarter 2009, to determine if the remediation system could remain off. The data show groundwater <br />concentrations have steadily increased from non-detect to a maximum 24,000 micrograms per Liter for <br />total petroleum hydrocarbons as gasoline in source area monitoring well MW-1, with lesser increases <br />in benzene, toluene, ethylbenzene, and xylenes, and similar increases in nearby monitoring wells. The <br />Report recommends restarting the SVE/AS treatment system using the catalytic oxidation vapor <br />treatment unit and running it for six months before evaluating the SVE/AS system for cost <br />effectiveness, continuing limited semi-annual monitoring of groundwater, and postponing the deep soil <br />injections for dissolved phase 1, 2-dichloroethane. <br />I concur to the recommendations in the Report with the following condition: before I approve the <br />restarting of the SVE/AS, please provide a cost effectiveness analysis for the treatment unit. In <br />January and April 2009, we discussed changing the treatment unit to less expensive carbon units for <br />soil vapor treatment, since catalytic oxidation requires purchasing natural gas to remediate soil vapor <br />and carbon is more cost effective when vapor concentrations are low enough to warrant the change. <br />Base the cost effectiveness estimate on your historical catalytic oxidation fuel, maintenance costs, and <br />contaminant mass treated, and provide a simple cost comparison in pounds treated per dollars spent <br />for installing and using the carbon units for six months verses continuing use of the catalytic oxidation <br />unit, to me no later than 10 December 2009. Also provide a schedule for the new upgrades <br />(procurement, installation, testing and inspections, changes to air board permit if necessary, etc.) if <br />carbon units are deemed more cost effective than the catalytic oxidation unit. After I have reviewed the <br />requested information, the final decision to restart the treatment system will be provide in a subsequent <br />letter. You may contact me regarding questions by phone at (916) 464-4615; or by e-mail at <br />jbartonwaterboards.ca .qov. <br />_J.7 <br />/, <br />James L.L. Barton, P.G. <br />Engineering Geologist <br />cc: Robert L'Heureux, State Water Resources Control Board, Sacramento <br />Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br />William Little, Advanced GeoEnvironmental Inc., 837 Shaw Rd., Stockton 95215 <br />California Environmental Protection Agency <br />7:1,' PC, 1 t Papc'l