SITE INFORMATION AND CORRESPONDENCE

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• • Mr. Eric Jenks - 3 - 9 July 2003 because the related gasoline constituents BTEX and MTBE are included in the volatile organic compound suite using EPA Method 8260B. If these compounds are detected in the monitoring wells, then JTF may be requested to also analyze groundwater for TPH as gasoline. Any new monitoring wells installed subsequent to the issuance of the MRP must be monitored quarterly for all constituents identified in the MRP for at least four consecutive quarters, then semi-annually. If no compounds in any specific analytical suite are detected in the first year, then that suite of compounds may be removed from the monitoring schedule for that well with staff concurrence. The draft MRP reflects these changes and is attached for your review and comment. Monitoring Reports The monitoring reports are complete and well organized. The figures portray the data in a format that is easily interpreted. The First QMR, which is the most recent monitoring report, includes a change in the format of the analytical data table. In this report, the data table does not show all the analytical suites that JTF routinely monitors. The organophosphate suite of compounds, TPH as gas, TPH as diesel, and ammonium are regularly analyzed but have not been detected. It is significant that these compounds are not detected, and this should be illustrated in the table. Please restore the results of these analyses to the data tables in future monitoring reports. Data Gaps JTF is closing the data gap relating to off-site migration of constituents as discussed above. Other data gaps that need to be closed before the extent of pollution is determined relate to upgradient water quality and groundwater in the operations area. Upgradient MW -3 contains nitrate at about 130 mg/l, bromacil at about 6 ug/l, and dinoseb at about 1.3 ug/1. While this is the most upgradient well at the facility, the detected constituents suggest that an additional monitoring well is needed that is far enough upgradient to characterize water quality unaffected by site operations. A grab groundwater sample obtained near the upgradient corner of the property in 1999 contained nitrate at about 200 mg/l. JTF and Board staff need to have a good understanding of whether there is an off-site source contributing to the nitrate, bromacil and dinoseb detected on-site. The monitoring well network surrounds the site and identifies constituents that could be migrating off-site. The 1999 and 2000 grab groundwater investigation identified constituents in the operations areas that have not been detected in the monitoring wells. These constituents include MTBE, toluene, xylene, TPH diesel, atrazine, dacthal, and dicamba. JTF should propose additional wells within the operations area of the facility to identify the constituents that are of concern on-site and whether future remediation efforts are effective. JTF should include this proposal in the downgradient investigative results report.