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California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H.Hickos Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 E WED n�D Phone(916)255-3000•FAX(916)255-3015 �� 11U// 2 May 2002 MAY 0 3 2002 ENVIRONMENT HEALTH Mr. Ronald Burt PERMIT/SERVICES Patterson Planning and Services, Inc. 2525 West End Avenue, Fourth Floor Nashville, TN 37203 REVIEW OF MONITORING REPORTS,KEARNEY KPF, STOCKTON, SAN JOAQUIN COUNTY We have reviewed the following reports submitted by Dudek &Associates, Inc. on behalf of Kearney- National, Inc. (Kearney) for the Kearney-KPF facility at 1624 East Alpine Avenue in Stockton: • January 2001 Summary of Groundwater Quality (2000 Annual Report); • 20 April 2001 Review of Quarterly Sampling Activities, January 2001 (January QMR); • 27 July 2001 Review of Quarterly Sampling Activities, April 2001 (April QMR); • 16 October 2001 Review of Quarterly Sampling Activities, September 2001 (September QMR); and • January 2002 2001 Annual Groundwater Monitoring Report(2001 Annual Report). The Department of Toxic Substances Control (DTSC)has reviewed four of the monitoring reports and their comments are attached. The 2000 Annual Report discusses the groundwater monitoring activities performed in October 2000 and summarizes production well activities and water quality trends for 2000. The January, April, and September QMRs discuss the groundwater monitoring activities performed in those months. The 2001 Annual Report discusses the groundwater monitoring activities performed in. December 2001, three releases during 2001, modifications and work pertaining to the groundwater extraction and treatment system, and the water quality trends for 2001. We have the following comments on these reports: 1. Each of the listed reports references Groundwater Protection Standards (GPS) for cleanup levels. Board staff uses water quality objectives (WQOs), which are established based on the Fourth Edition of the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins (Basin Plan). The Basin Plan designates beneficial uses of the waters of the State and establishes WQOs to protect these uses. WQOs listed in the Basin Plan include numeric WQOs, e.g., state drinking water standards, or narrative WQOs, including the narrative toxicity objectives for surface and groundwater. As stated in previous correspondence and meetings, Kearney must use the lowest cleanup level as established by the WQOs of the Basin Plan and DTSC's Post-Closure Permit. 2. Based on the differences between GPS and WQOs,pollutant contour figures need to contour to non-detect values as opposed to GPS levels. California Environmental Protection Agency Recycled Paper - The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/wgcb5