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Mr. Curt M. Richards -3- 24 January 2012 and it is likely a regional background constituent. Central Valley Water Board staff agrees and has incorporated the change in the Draft MRP. 13.The MRP Request proposes to remove the requirement for sulfate analysis because the concentration has been stable or declining in recent years, there are no sources on the Site, it is likely a regional background constituent, and the concentrations in analyses 2010 were below 250 milligrams per liter. Central Valley Water Board staff agrees and has incorporated the change in the Draft MRP. 14.The MRP Request proposes to remove the requirement for nitrite analysis because Olin has not detected it since 2007. Central Valley Water Board staff agrees and has incorporated the change in the Draft MRP. 15.The MRP Request proposes to discontinue analyses of total iron, ferrous iron, sulfite, and total organic carbon (TOC) because iron concentrations since 2007 have established aquifer conditions, and sulfite and TOC analyses were conducted for evaluation of monitored natural attenuation (MNA). Olin is no longer evaluating MNA as a remedial option. Central Valley Water Board staff agrees and has incorporated the changes in the Draft MRP. After a 30-day review period beginning with the date of this letter, Central Valley Water Board staff will consider all comments and send you the Final MRP. Prior to abandoning groundwater monitoring wells, Olin must obtain permits from San Joaquin Department of Health. If you have any questions, please contact Jim Brownell at (916) 464-4675, or by email at jbrownell@waterboards.ca.gov. MARIE McCRINK, P.G. Senior Engineering Geologist Site Cleanup Unit Chief Enclosure: Draft Monitoring and Reporting Program cc: Harlin Knoll, San Joaquin County Health Department, Stockton Eva Hey, Stantec Consulting Corporation, Lafayette Gwen Solomon, Olin Corporation, Tracy Maurice Benson, Defense Logistics Agency, Tracy