SITE INFORMATION AND CORRESPONDENCE

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Ms. Jill Jefferson • - 2 - 16 July 1999 reported the presence of MTBE in Trapper Slough. The highest reported concentration of MTBE in Trapper Slough was 4.7 µg/1 in December 1998. The NPDES report shows that KMEP conducted MTBE analysis on the influent and effluent samples for January 1999, but failed to conduct these analyses in February and March. Since KMEP has not complied with our request to sample for MTBE, and since the General Order does not require sampling for MTBE, KMEP is now required to apply for an individual NPDES permit for this site so that appropriate requirements may be set. Application forms to begin this process are enclosed. 2. The presence of contaminants in Trapper Slough has been a concern. KMEP proposes to conduct surface water monitoring from three additional locations. This is acceptable provided S-1 and S-2 are sampled at the same time. Board staff initially requested that an evaluation of the contaminants in Trapper Slough be included with the 1998 third quarter monitoring report. Board staff approved a 9 October 1998 work plan to conduct this study in our 15 October 1998 letter. Despite repeated requests and approvals, this work is not done. 3. The NPDES monitoring report cites a drained battery as causing a 27-day shutdown of the treatment system. Also, during the operational periods, the treatment rate for the first quarter was only 2.2 gallons per minute (gpm). KMEP must evaluate the operation and maintenance program for the Holt remediation system to ensure satisfactory progress is made toward final remediation. 4. The annual report states that because monitoring wells M-8, N-18 and N-19 were below detection limits for the constituents of concern, the plume was stable. However, during the first quarter analysis, N-18 contained MTBE, and N-8 and N-16 intermittently contained separate phase product. Board staff previously requested KMEP to conduct a capture zone analysis (15 October 1997), and that request is reiterated herein. 5. The 9 October 1998 Work Plan for Additional Investigation and Additional Remedial Activities contained plans to install monitoring well MW-20. In a letter dated 15 October 1998, Board staff approved this work plan. KMEP has not installed this well, and the annual report again contains a plan to install it. The placement of this well has been an issue since Board correspondence dated 15 October 1997. To provide KMEP clear guidance, ivlW-20 must be installed and should be placed east of SV-06 and south of SV-13. 6. The annual report proposes deeper groundwater investigation at five locations. The location along the former pipeline shall be moved closer to the initial source and within the area of highest known concentration of contaminants, which is identified by N-7. Also, monitoring wells shall be placed in the deeper groundwater zone where the highest contamination is found. 7. It is evident from the format of the quarterly reports that the monitoring and reporting program (MRP) is outdated. A draft revised MRP is enclosed for your review. The annual report makes a number of recommendations for additional work. However, the placement of MW-20 and the surface water investigation of Trapper Slough have been previously approved and must be completed now. Due to inconsistent terminology and an overall brevity, it is unclear if the `Scope of