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California Regional Water Quality Control Board <br />Central Valley Region ,u, <br />Robert Schneider, Chair Arnold <br />Alan C. Lloyd, Ph.D. <br />Secretaryfor Sacramento Main Office Schwa <br />Environmental 11020 Sun Center Drive #200, Rancho Cordova, California 95670-6114 <br />Governor <br />negger <br />Protection Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards.ca.gov/centralvalley <br />16 February 2005 <br />Mr. Eric Jenks <br />John Taylor Fertilizers <br />900 North George Washington Blvd. <br />Yuba City, CA 95993-9062 <br />[E-�Dgj(CgF� ' <br />LSD <br />3 2005 <br />Eh'lV'RCNMENTTH <br />PEr?MIT/SEHVICES <br />SOURCE AREA INVESTIGATION, JOHN TAYLOR FERTILIZERS CO' 11819 SOUTH <br />ARGONAUT WAY, STOCKTON, SAN JOA Q UIN CO UNTY <br />Thank you for providing the 31 January 2005 .Work Plan for Source Area Investigation and Submittal of <br />Proposed Well Construction Diagram (January 2005 Work Plan) prepared by GeoSyntec Consultants. <br />The Work Plan responds to Central Valley Regional Water Quality Control Board (Regional Board) <br />staff's 23 August 2004 letter request and includes a proposed well construction diagram for MW -6. <br />John Taylor Fertilizers (JTF) is also planning on conducting a downgradient and upgradient grab <br />groundwater investigation and installing MW -6 this spring, as proposed in JTF's 30 March 2004 <br />December 2003 Downgradient Delineation Report, and in its 5 October 2004 Response to Request for <br />Work Plan. <br />In the January 2005 Work Plan, JTF proposes to obtain soil samples from depths of about one foot, five <br />feet, and 10 feet below ground surface (bgs) from each of 17 proposed soil borings at the JTF facility. <br />The borings are located upgradient of areas where pollutants have been identified in groundwater in <br />order to identify source areas for the constituents of concern. JTF proposes to analyze soil samples for <br />nitrate, ammonium, 1,2-dichloropropane (1,2-DCP), and 1,2,3-trichloropropane (1,2,3 -TCP). <br />Shop #2 and Shop #3 are potential source areas for constituents identified in MW -4, and JTF proposes <br />one boring (SSI -16) downgradient of these buildings. Alternatively, Board staff request that JTF add an <br />additional boring and a minor adjustment to the placement of SSI -16 such that one boring is placed <br />downgradient of each of the shop buildings. Otherwise, the soil borings are well distributed. <br />Other constituents that are consistently identified in groundwater at this site to date include bromacil and <br />dinoseb. In the January 2005 Work Plan, GeoSyntec comments that the detections of these compounds <br />are less than the water quality objective, and that it would be difficult to find a source area for such low <br />concentrations. Bromacil is detected up to 8 ug/1, whereas the water quality objective is 90 ug/l, and <br />dinoseb is detected up to 1.5 ug/1 whereas the water quality objective is 7 ug/l. GeoSyntec also <br />recognizes that the Regional Board must protect all beneficial uses of water which includes cleanup to <br />background concentrations. At this site, background concentrations will be identified when the <br />California Environmental Protection Agency <br />Q, Recycled Paper <br />