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California Ref conal Water Quality Coontrol Board Central Valley Region 4 Robert Schneider,Chair Terry Tamminen Sacramento Main Office Arnold Schwarzenegger Secretary for Intemet Address: http://www.swrcb.ca.gov/rwgcb5 Governor Environmental 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 Protection Phone(916)464-3291 Fax(916)464-4797 10 November 2004yy, R,L�. �!_ U) Mr. Robert Mihalovich NW 16 2004 ChevronTexaco Environmental Management Company 6001 Bollinger Canyon Road,Rm K2072 EWRONMENT HEALTH San Ramon, CA, 94583-2324 PERMIT(SEWCES MONITORING AND REPORTING PROGRAM NO. R5-2004-0835, KOPPEL STOCKTON TERMINAL, 2025 W. HAZELTON AVE, STOCKTON, SAN JOA QUIN CO UNTY Thank you for providing your comments on the draft Monitoring and Reporting Program (MRP) that Central Valley Regional Water Quality Control Board (Regional Board) staff transmitted in our 27 September 2004 letter. In a 28 October 2004 comment letter, your consultant, Ms. Alexa Stamets of CH2MHill stated that the requirement that any new monitoring wells be monitored quarterly for one year is overly stringent, given that eight years of monitoring at the site have already established seasonal trends in analyte concentrations. A review of the monitoring history shows that Koppel monitored its wells quarterly for four years. During that four years, nitrate concentration extremes were strongly correlated with the extreme groundwater elevations that occurred in the wet and dry seasons. Therefore, we concur with your suggestion and any new monitoring wells Koppel installs shall be monitored semi- annually in the first and third quarters for the first year. We have incorporated this change into MRP No. R5-2004-0835 which is enclosed and now in effect. In our 27 September letter, we requested that Koppel provide a cleanup plan for the area between the warehouse and the railroad spur, and a work plan to install a monitoring well to evaluate the northern extent of groundwater pollution. In the 28 October letter, Koppel states that the area between the warehouse and railroad spur is impractical to access at the present time for the following reasons: • The spur line services Koppel Stockton Terminal's tenant and is constantly in use. • The Burlington Northern and Santa Fe Railway(BNSF) operates on one of the railroad tracks west of the warehouse, and invasive actions within 25 feet of the centerline of an active rail line should not occur. • The strip of land that Regional Board staff is concerned about is 15 feet wide and 600 feet long and extends to within 15 feet of the railroad tracks. • The area in question is paved with asphalt, and removing the asphalt and conducting regular maintenance that may be required with a remediation plan is difficult, given the current uses of the site and railroad lines. • Ammonium is relatively immobile. If the asphalt is removed for remediation, ammonium may convert to nitrate, become mobile, and further pollute groundwater. California Environmental Protection Agency C4 Recycled Paper