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Memera Ind um CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD . CENTRAL VALLEY REGION 3201 S Street Sacramento, California 95516 Phone: 445_0270 TO: Paul E. Jepperson I' d FROM,: Robert E. Fujii Supervising Engineer Associate Water Resource Jerrold A. Bruns, Chief Control Engineer Standards, Policies, and Special Studies Section DATE: 22 July 1986 SIGNATURE: SUBJECT: MARLEY COOLING TOWER COMPANY (MITIGATION ACTIVITIES WORK(PLAN) Based on my review of the Marley Cooling Tower Company (MCTC) document entitled Proposed Work Plan for Mitigation Activities I have developed the following comments: Settlement Agreement Tasks In this section MCTC summarized the current status of the work activities specified in the Compliance Time Schedule which is a part of the Settlement Agreement between MCTC and the State. MCTC's assessment of the present status of these activities appears to be accurate. However, it should be noted that the U.S. Environmental Protection Agency (EPA) is not a party to the Settlement Agreement and their Remedial Investigation' - Feasibility Study (RIFS) require- ments must also be satisfied. Additional Work ComDleted Page 2; Pond Closure - The closure of the stormwater retention pond is being handled separately from the mitigation activites for the overall site. Comments on the Closure Plan are being finalized and will be submitted jointly by the Department of Health Services (DHS) and the Board. Page 4; Other Improvements - The installation of the curbing near the retort pit area is not shown on the finished elevations plan which was submitted on 4 April 1986. Please revise this plan to show the location of the curbing and any other improvements not al.ready shown on the plan. Future Work Items Page 4; Plume Characterization - We recommend an intermediate monitoring well be placed next to the shallow well located 250 feet east of the retort Pit. Information from this well should better define the vertical extent in the upgradient portion of the contamination plume. With the addition of this well the proposed Phase III Ground Water Assessment Program appears to be adequate to define the 0.05 mg/l level of ground water contamination plume that exists at the MCTC site. If contamination in excess of 0.05 mg/1 is detected, then additional monitoring will be required. In addition, since the contamination plume has migrated off-site, MCTC should resample and analyze the off-site domestic wells located downgradient from the site.