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! • California Regional Water Quality Control Board �° Central Valley Region -" Robert Schneider,Chair Terry Tamminen Sacramento Main Office Secreta for Arnold Soverno enegger Secretary Internet Address: http://www.swrcb.ca.gov/rwgcb5 Governor Environmental 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 Protection Phone(916)464-3291 Fax(916)464-4797 DCDDD 23 August 2004 AUG 2 4 2004 Mr. Eric Jenks ENVIRONMENT HEALTH John Taylor Fertilizers PERMIT/SERVICES 900 North George Washington Blvd. Yuba City, CA 95993-9062 REVIEW OF REPORT, JOHN TAYLOR FERTILIZERS, 1819 S 0 UTH A R G ONA UT WAY, STOCKTON, SAN JOA Q UIN CO UNTY John Taylor Fertilizers (JTF) has detected pollutants in groundwater beneath its retail agricultural distribution facility in Stockton. Central Valley Regional Water Quality Control Board (Regional Board) staff have reviewed the distribution of pollutants and the results of downgradient groundwater delineation as presented in the following reports prepared by GeoSyntec Consultants: • 30 March 2004 December 2003 Down gradient Delineation Report(Delineation Report) • 30 April 2004 2004 Semi Annual Groundwater Monitoring Report Monitoring Well Proposal The Delineation Report proposes to install a shallow downgradient monitoring well on Argonaut Drive. The well is downgradient of MW-4, which has contained 1,2-dichloropropane (1,2-DCP) in concentrations ranging from 8 to 37 ug/l. We concur with the proposed location. The Delineation Report also proposes an upgradient monitoring well positioned off-site and states that the neighboring property owner is being contacted for aoxess. We concur that an upgradient well should be off-site, since pollutants are detected in groundwater beneath the upgradient end of the JTF property. In MW-5, downgradient from the former tank farm and positioned at the edge of the JTF facility,nitrate (as nitrogen)has been steadily increasing and in February 2004 contained 144 mg/l. JTF needs to install an additional downgradient monitoring well to delineate the nitrate plume. In our 9 July 2003 letter, we requested that JTF propose monitoring wells within the operations center of the facility, since the existing wells surround the operations area. JTF obtained data in grab groundwater investigations conducted in January and November 1999 (reported respectively in the 1 July 1999 Site Investigation Work Plan and in the 30 January 2000 Site Investigation Work Report, both by GeoSyntec Consultants). In the Delineation Report, JTF states that these data identify the constituents of concern in the operations area, and at this time a monitoring well in the center of the site would not provide additional information: Regional Board staff believe that strategically placed monitoring wells in the operations center will confirm suspected source areas for the various pollutants California Environmental Protection Agency �a Recycled Paper