SITE INFORMATION AND CORRESPONDENCE

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Mr. Ken Price • - 3 - • 7 March 2002 during the wet season. In my 1 March telephone conversation with Mr. Souther, he noted that the site is bermed to contain all stormwater on-site, and that he has observed 18 inches of water standing in puddles during the wet season. This seasonal hydraulic head is creating non-uniform gradients beneath the site. Monitoring and Reporting Program Revision In its June 2001 2000 Annual and First Trimester 2001 Monitoring Report, Oxychem requested that Monitoring and Reporting Program 96-817 be revised to eliminate the requirement for organochlorine analyses for newly installed monitoring wells, since of these compounds, only dieldrin was detected in one well one time near the detection limit. Staff concur with this request, and as Mr. Souther suggested, it will be most efficient to revise the MRP prior to the third trimester monitoring event and in conjunction with developing Waste Discharge Requirements for the phytoremediation treatment Oxychem proposed in its November 2001 Phytoremediation Work Plan. Phytoremediation Schedule In our 14 February letter responding to Oxychem's Phytoremediation Work Plan, we suggested that if Oxychem wishes to have the Regional Board consider WDRs at its 7 June meeting, Oxychem would need to provide Board staff with a Report of Waste Discharge (ROWD)by 15 March. In our conversation,Mr. Souther proposed that since winter would be the next time to plant trees, Oxychem would prefer to target a Board meeting towards the end of the year. Board meetings are scheduled for 19 July, 6 September, 18 October and 6 December 2002. If Oxychem chooses to irrigate trees with polluted groundwater,Board staff should receive the ROWD at the earliest possible date. When the application is deemed to be complete, Board staff will schedule the next available Board meeting. By 15 April 2002, please advise Board staff when the ROWD will be available. Groundwater Remediation The Phytoremediation Work Plan specifically targets remediation of soil. Groundwater must also be remediated. Oxychem needs to provide a Feasibility Study/Remedial Options Evaluation Report (FS/RO) for groundwater that essentially conforms to the attached outline Items to be Included in a Feasibility Study/Remedial Options Evaluation Report. In our conversation, Mr. Souther stated that a pump test may be needed before an FS/RO could be developed, and that a pump test could be incorporated into the Phytoremediation Work Plan. Accordingly, please provide a schedule to develop an FS/RO for groundwater by 15 April 2002. Summary Since Oxychem obtained ownership of this site, it has proceeded to remediate the core source area of soil contamination and provided a phytoremediation plan to remediate soil in the remainder of the site. Oxychem has installed and is sampling an extensive network of monitoring wells, is preparing to establish a permanent monitoring well network at the Bridgeport property and has nearly defined the lateral and vertical extent of groundwater pollution. It is a pleasure working with you.