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CaliforniaVegional Water Qualit0Control Board <br /> Central Valley Region s3 <br /> Peter M.Rooney Sacramento Main Office Ed J.Schnabel <br /> Secretaryfor Intemet Address: http://www.swrcb.ca.gov/—mgcb5thome.html Chair <br /> Environmental 3443 Routier Road,Suite A,Sacramento,Califomia 95827'300} <br /> Protection Phone(916)255-3000•FAX(916)255-3015 <br /> 16 June 1998 <br /> Ms. Leah Goldberg <br /> Hanson-Bridgett <br /> 333 Market Street, 23rd Floor <br /> San Francisco, California 94105-2173 <br /> REVIEW OF REPORTS AND WORK PLAN FOR KOPPEL STOCKTON TERMINAL, <br /> PORT OF STOCKTON, SAN JOAQUIN COUNTY <br /> I have reviewed the following documents for the Koppel Stockton Terminal: 22 January 1998 <br /> Quarterly Groundwater Monitoring Report-December 1997, 30 January Annual Groundwater <br /> Monitoring Report- 1997, 13 February Submittal of Pilot Test Work Plan (revision 1) and <br /> Interim Report, 27 March Quarterly Groundwater Monitoring Report-January 1998, 29 April <br /> Poplar Tree Planting, 12 May Revised Cleanup Schedule, and May 1998 (received 9 June 1998) <br /> Monitoring Well Installation Work Plan. These documents were prepared by CH2M Hill, your <br /> consultant. The following are my comments. <br /> 1. All documents reviewed are missing the signature and stamp of a California registered <br /> engineer or geologist. <br /> 2. The annual groundwater monitoring report states that no data exist to assess the ponding of <br /> water on the north end of the site. This ponding needs to be investigated to determine <br /> whether it affects the direction of groundwater flow and the concentration of chemicals of <br /> concern in groundwater. As stated in the March 1998 report, field filtering of samples to <br /> stabilize ammonia concentrations is appropriate. Laboratory reports show that nitrate analysis is <br /> performed using Environmental Protection Agency (EPA) Method 353.3. If the nitrate <br /> analysis were performed using EPA Method 300, additional ions could be reported. The <br /> additional data could show other trends and show localized areas of pollutants that may <br /> account for the differences in concentrations of fertilizer chemicals detected in groundwater. <br /> However, the holding time for nitrate analysis using EPA Method 300 is 48 hours. <br /> 3. During the 2 April 1998 meeting with Ms. Miriam Barbonio of Chevron and Messrs. Gerald <br /> Vogt and Jim Hartley of CH2M Hill, we agreed that the revised pilot test work plan was <br /> appropriate. In addition, we concurred that early results of the pilot test showed the test plots <br /> were not effective at removing nitrate from soil, so the test should be terminated and other <br /> remedial options considered. <br /> California Environmental Protection Agency <br /> n#Recycled Paper <br />