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.�� California Regional Water Quality Cdontrol Board <br /> Central Valley Region o <br /> Robert Schneider,Chair <br /> Alan C.Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.waterboards.ca.gov/centralvalley <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> 8 February 2005 �ECEVE ri <br /> Ms. Sandy Galganski FEB U S 2005 <br /> The Dow Chemical Company ENVIRONMENT HEALTH <br /> 901 North Loveridge Road PERMIT/SERVICES <br /> Pittsburgh, CA 94565 <br /> REVIEW OF MONITORING REPORTS, DOW CHEMICAL, 400 WEST G_ANDY DANCER <br /> DRIVE,TRACY, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)reviewed the <br /> following reports submitted by URS Corporation on behalf of The Dow Chemical Company for the <br /> former Celotex facility at 400 West Gandy Dancer Drive in Tracy(site): <br /> • 30 July 2004 Second Quarter 2004 Groundwater Monitoring Report(Second QMR); <br /> • 13 October 2004 Third Quarter 2004 Groundwater Monitoring Report(Third QMR); <br /> • 1 November 2004 Letter Addendum to Third QMR(Letter); and <br /> • 31 January 2005 Fourth Quarter 2004 Groundwater Monitoring Report(Fourth QMR). <br /> The Second, Third, and Fourth QMRs discuss the groundwater sampling activities conducted in June, <br /> September, and December 2004,respectively. The Fourth QMR includes a discussion of statistical tests <br /> to determine the time needed for the concentrations to decrease to nondetectable levels without active <br /> remediation. Based on the limited consecutive quarterly data for the site, the tests were inconclusive. <br /> The Letter provided additional information regarding the third quarter sampling event, as requested by <br /> Regional Board staff. <br /> We have the following comments on the Fourth QMR: <br /> 1. The Fourth QMR lists Maximum Contaminant Levels (MCLs) in Table 3. The MCLS are not <br /> necessarily the appropriate cleanup goal for the site. The Regional Board's Water Quality <br /> Control Plan for the Sacramento River and San Joaquin River Basins, Fourth Edition establishes <br /> both numeric and narrative water quality objectives (WQO). The MCL is a numeric WQO,but <br /> may not be the appropriate cleanup goal. For example, the cleanup goal for Freon 12 is the State <br /> Action Level of 1,000 micrograms per liter(ug/1) and for trichloroethene is 0.8 ug/l based on the <br /> Public Health Goal. For Freon 11,Freon 113, and 1,1-dichloroethene,the cleanup goal is the <br /> MCL. However, Table 3 states there is no MCL for Freon 113,which is not accurate. The MCL <br /> for Freon 113 is 1,200 ug/l. Tables listing groundwater sampling results should list the <br /> appropriate cleanup goal. <br /> California Environmental Protection Agency <br /> 0Recycled Paper <br />