SITE INFORMATION AND CORRESPONDENCE

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Mr. Ronald Burt • - 2 - 2 May 2002 3. Several of the estimated pollutant contour figures included in the reports show contour lines with question mark symbols within estimated lines or incomplete contours. Kearney must evaluate these areas and include recommendations for additional monitoring wells, if necessary. 4. Each of the listed reports, with the exception of April QMR, include monitor well sampling forms that show water quality parameters collected at the beginning of the purge but not at the end of the purge. Kearney must also collect water quality parameters at the end of the purge because these readings are most representative of the groundwater samples collected. 5. The April QMR does not include monitor well sampling forms. These forms are required by Monitoring and Reporting Program (MRP)No. 5-01-269 and previous MRPs. 6. The September QMR did not include contour figures for the intermediate zone. This information is required by the current and previous MRPs. 7. The 2000 and 2001 Annual Reports show volatile organic compound data in tables separated by year. This presentation makes it difficult for Board staff to readily discern trends of analytes in specific monitoring wells over time. The MRP requires data reported in tabular form be readily discernible. Kearney needs to present historical analyte data in table(s)that groups all historical data for each individual well in chronological order. 8. The 2001 Annual Report states that the list of GPS levels is included in Table 6 and summaries of the four quarterly sampling events are included in Appendix F. The GPS levels are listed in Table 7, and Appendix F only includes the groundwater field sampling forms for December. Kearney must submit reports that discuss the information provided and accurately describe where the information can be found. 9. The 2001 Annual Report states that Table 3 includes the results from the December sampling event. Table 3 shows analytical data collected in April and December. The table would be more useful if it contained all of the year's analytical data as opposed to just the second and fourth quarter data. 10. The 2001 Annual Report states that bleach was poured into KI-6 for biofouling four hours prior to sampling and during sampling a chlorine odor was noted. Adding a chemical to a groundwater monitoring well without Board staff approval or proper permitting is unacceptable and a violation of state law. 11. The 2001 Annual Report states there were three releases during 2001. Provision E.6 requires Kearney to report spills or releases to Board staff within 24 hours. By 31 May 2002, Kearney must provide a response to the comments in this letter and the attached DTSC letter. If you have any questions, you may contact me at(916) 255-3119 or by email at lewisd(@rb5s.swrcb.ca.gov. s J2JlM,0. x-z" DEVRA LEWIS Environmental Scientist Attachment cc: Mr. Doug O'Neal, Department of Toxic Substances Control, Sacramento Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton Mr. H. Derrick Peterson, Esq., Austin, TX Mr. Peter Quinlan, Dudek &Associates, Encinitas, California