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SENT BY:EMCON 2-14-96 ; 835A EMCON SACRAMENTO— 209 4653078;# 4/ 7 Gabriel Karam Project 20939-001,015 February 13, 1996 Page 3 7. Monitoring and Reporting program,Page 8,Item 3.Monitoring points If the RW QCB has revievmd and approved of the EMP,then this section is should be changed to read as follows: "The groundwater monitoring points for detection monitoring shall be UPVzdient well MW-1 and downgradient wells MW-3 and MW-4. The groundwater monitoring points for evaluation monitoring shall be dOwugradient monitoring well MW-2." If they have not yet approved the EMP,then mention of the evaluation monitoring should this stricken from this section. 8. Monitoring and Rqmrting Progrmn,PAP 9,Item 4.Points of Compliance The third sentence states that"MW-4 is not a compliance well for chloride due to the possibility Of interference form the sewage disposal ponds located directly Upgradient.tv However,as no in comnwnt 2,MW-4 has significantly higher concentrations of chloride,total dimlved solids and electrical conductivity than bw-kgmund well MW-1-Thus,this section should also eliminate TDS and EC from compliance monitoring from compliance monitoring for MW-4. 9- Monitoring and Reporting Prograin,PaW 9,Statis&W ftvmdures for Determining Significant Increases As described in the Be,because VoCs are not n ocmrring the concentration limit for VOC9 is the method detection limit. However,once VOCs are detected.the UVW analysis method is mom appropriate. Since VOCs have been detected s In MW-Z the concentration limits for all monitoring parameters in well MW-2 should be"no statistically significant increasing trends." Thus,this Section of the WDR should specify that concentration limits for MW-2 will be no statistically significant increasing t=ds-" The Proposed method for evaluating trends in the EMP is the Kendall- tau,which is a method approved by Article 5. SAC%H.'kVVINWORDIHARNWDRDoc.95vxtci