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HomeMy WebLinkAboutRWQCB_RAP Concurrence Ltr (3 15 15)April 15, 2015 Sent Via Electronic Mail Mr. Andy Smith Chevron Environmental Management Company P.O. Box 1332 San Luis Obispo, CA 93406 smith.andy@chevron.com Dear Mr. Smith, SITE CLEANUP PROGRAM: UNOCAL (CHEVRON) SAN LUIS OBISPO TANK FARM, 276 TANK FARM ROAD, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – CONCURRENCE WITH THE FINAL REMEDIAL ACTION PLAN (MARCH 31, 2015) Central Coast Regional Water Quality Control Board (Water Board) staff is providing this letter to indicate our concurrence with the Final Remedial Action Plan, San Luis Obispo Tank Farm Final RAP) dated March 31, 2015, which was prepared by Avocet Environmental, Inc. on behalf of Chevron. Chevron adequately addressed Water Board staff comments related to water quality issues in the previous August 13, 2014 Revised Remedial Action Plan (Revised RAP) for the San Luis Obispo Tank Farm (Tank Farm) property. The Final RAP addresses comments on the Revised RAP that the following agencies provided to Chevron and Water Board staff1: the San Luis Obispo County Air Pollution Control District (APCD), County of San Luis Obispo Health Agency, Public Health Department (PHD), and California Department of Fish and Wildlife CDFW). Copies of these agencies’ comments and Chevron’s associated responses are included in Appendix N of the Final RAP. Based on information provided to Water Board staff by Chevron and staff from these agencies, it is our understanding that staff from the APCD, PHD, and CDFW are satisfied with responses to their respective comments that Chevron incorporated into the March 31, 2015 Final RAP. Background Chevron prepared the Final RAP (as well as previous versions) to address the cleanup of constituents associated with petroleum hydrocarbons at the Tank Farm property. The Final RAP includes the proposed scope of work for the remediation portion of Chevron’s multi-phased 1 On most Site Cleanup Program sites, the Water Board is solely responsible for approving RAPs. The typical process for RAP approval is as follows: Water Board staff notifies the public about the existence of a draft RAP, and solicits comments on the document. Water Board staff subsequently responds to comments and requires the responsible party (RP) to make any necessary changes to the RAP. The RP cannot initiate cleanup activities until Water Board staff agrees that the final RAP appropriately complies with the required changes. However, due to the size of the Tank Farm property, the variety of proposed remediation activities, the various permits Chevron must obtain to conduct the proposed activities, and the existence of the Surface Evaluation, Remediation, and Restoration Team (SERRT), all SERRT members were given the opportunity to review and comment on all documents associated with the Tank Farm remediation activiities, up to and including the March 31, 2015 Final RAP. Mr. Andy Smith - 2 - April 15, 2015 remediation, restoration, and development (RRD) project at the Tank Farm property. Chevron initially submitted a Draft RAP to the federal, state, and local agencies and municipalities participating in the SERRT in 2007. Chevron modified this Draft RAP (also in 2007) to address comments from SERRT members. Water Board staff included a public notification of the revised Draft RAP - - and solicitation for public comment - - along with the Draft Environmental Impact Report (EIR) for Chevron’s RRD project, which was released for a 45-day public review period on June 20, 2013. As the lead agency 2 for the California Environmental Quality Act CEQA) process, the City of San Luis Obispo received comments on various topics addressed in the Draft EIR. Responses to some of the comments resulted in changes to the Draft EIR. Water Board staff did not receive any comments on the revised 2007 Draft RAP; however, Chevron modified the document to conform to information contained in the Final EIR (FEIR, dated December 28, 2013). Chevron therefore provided Water Board staff with a Revised Remedial Action Plan dated May 15, 2014 (May 2014 Revised RAP). Water Board staff reviewed and commented on this document and Chevron incorporated responses to our comments into the August 13, 2014 Revised RAP. Based on the variety of proposed remediation activities and associated permits and approvals Chevron must obtain to accomplish site remediation, staff from the W ater Board and Chevron provided SERRT members with an additional opportunity to review and comment on Chevron’s plan for cleanup at the Tank Farm property. In a September 9, 2014 email from Chevron to SERRT members, Mr. Rik Williams invited the SERRT to review the August 13, 2014 Revised RAP located on the GeoTracker database and provide comments to Water Board staff by September 23, 2014. As noted above, copies of SERRT members’ comments and Chevron’s associated responses are included in Appendix N of the March 31, 2015 Final RAP. Water Board staff appreciate Chevron’s efforts to finalize the RAP and arrive at this remediation phase of its multi-phased, multi-year RRD project, and we encourage Chevron to proceed with remediation activities as soon as possible. W e look forward to the net environmental benefits that cleanup activities described in the Final RAP will accomplish. If you have any questions, please contact Water Board staff Diane Kukol at (805) 542-4637 Diane.Kukol@waterboards.ca.gov) or Angela Schroeter at (805) 542-4644. Sincerely, for Kenneth A. Harris Jr. Executive Officer 2 Because the Tank Farm property is outside the city limits of San Luis Obispo - - but may be annexed into the City in the near future - - the City and County of San Luis Obispo were the co-lead agencies for preparing the EIR for Chevron’s overall RRD project. Based on a Memorandum of Understanding concerning each jurisdiction’s role in the CEQA process (and recorded by the San Luis Obispo County Clerk on February 7, 2013), the City became the lead agency for FEIR certification and will continue in this role for future development after annexation occurs. The County is the lead agency for the project phases that deal with remediation, restoration, and grading in preparation of development. In the event annexation does not occur, the County will assume lead agency status for the development phase of the project as well. Mr. Andy Smith - 3 - April 15, 2015 cc: Mr. Rik Williams, Chevron RikWilliams@chevron.com Ms. Kim Tulledge, Chevron Kim.Tulledge@chevron.com Mr. Bill Almas, Chevron WAlmas@chevron.com Mr. Robert Van Hyning, Avocet rvanhyning@avocetenv.com Mr. Chuck Lambert, McDaniel Lambert celambert@mclam.com Mr. Phil Dunsmore, City of SLO pdunsmore@slocity.org Mr. Jay Johnson, SLO Co. jgjohnson@co.slo.ca.us Mr. Gary Arcemont. SLO Co. APCD garecemont@co.slo.ca.us Mr. Aaron LaBarre, SLO Co. Environmental Health alabarre@co.slo.ca.us Ms. Melissa Boggs, Fish and Wildlife Melissa.Boggs@wildlife.ca.gov Ms. Thea Tryon, Central Coast Water Board thea.tryon@waterboards.ca.gov Ms. Diane Kukol, Central Coast Water Board diane.kukol@waterboards.ca.gov Ms. Kendall Stahl, Central Coast Water Board (GeoTracker) kendall.stahl@waterboards.ca.gov P:\SCP\SITES\SLO Co\San Luis Obispo\SLO Tank Farm\Surface Restoration\RAP\Comm_RAP_Concur_041315.doc SL203011375