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f t Mr. Mike Pitta - 2 - 30 January 2004 KMEP has worked to remove a large quantity of pollution from the groundwater using a groundwater pump and treat system (GWTS) and soil vapor extraction (SVE). However, pollution remains and the existing remedial measures may not continue to be the optimal strategy. KMEP proposes to conduct a bioremediation pilot study southeast of South Whiskey Slough Road at the downgradient portion of the pollutant plume, and implement phytoremediation in the source area. During our meeting, we discussed the groundwater cleanup plan including the 3 July 2003 Bioremediation Pilot Study in Lieu of Continued Pump and Treat(Bioremediation Work Plan) and the 18 September 2003 Phytoremediation as the Final Measure for the Source Area (Phytoremediation Work Plan), submitted by CH2M Hill on behalf of KMEP for the site. As discussed, Regional Board staff concurs with the strategies outlined in the Phytoremediation Work Plan and the Bioremediation Work Plan. The following comments summarize the items we agreed to during our meeting and specify the work necessary in addition to what KMEP proposed in the work plans. 1. The Phytoremediation Work Plan needs an implementation plan, so we agreed that by 1 August 2004, KMEP would submit a detailed final phytoremediation plan as a cleanup plan for the source area. Subject to Regional Board staff review, the final plan may be given Regional Board Executive Officer approval. In addition, we agreed that phytoremediation will be implemented in a phased approach so that planting in cell "C" as detailed in the Phytoremediation Work Plan would be delayed until the fall or winter of 2005. This will allow KMEP to implement our agreed upon items for the Bioremediation Work Plan. 2. The pilot study detailed in the Bioremediation Work Plan needs groundwater monitoring that will show whether the study is successful. Thus, we agreed to additional groundwater monitoring that includes the bioremediation parameters listed on Table 3-2 of the Bioremediation Work Plan. KMEP will conduct the additional analyses at the same frequency and for the same wells already required by Monitoring and Reporting Program No. R5-2003-0811 (MRP) that was issued on 4 April 2003. The written reports will continue to be submitted on a semi-annual basis, and KMEP will submit electronic data reports semi-annually in the quarters with no written report. Revised MRP No. R5-2004-0803 reflecting these changes is enclosed. A draft was made available to you via e-mail on 28 January 2004, and we incorporated the comments CH2M Hill sent to us on 29 January. Thus, the MRP is final and KMEP will implement it in the first quarter 2004 monitoring. We also agreed that if the pilot study data show bioremediation is occurring and the concentration of pollutants and plume size are decreasing, then it would be appropriate to reduce the monitoring requirements at that time. Thus, during the implementation of bioremediation as a final measure, KMEP would show progress by monitoring on a regular California Environmental Protection Agency �a Recycled Paper