SITE INFORMATION AND CORRESPONDENCE

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Mr. Mike Nakagawa - 4 - 17 February 2000 Koppel's well, KP-2, has consistently contained nitrate concentrations similar to those found in MW-6 throughout the four quarters of the MW-6 record. Although I agree that this nitrate could be in part attributed to either influences from Koppel Stockton or stonnwater, I need to see analytical results from stormwater samples from the ponded water before accepting the influence that overland runoff may have on this localized area. Monitoring and Reporting Program (MRP) IT recommended several changes to the MRP. Since June 1998, IT has only identified petroleum hydrocarbons in MW-1, and in the last quarter found MTBE in MW-1 and MW-5. Based on this history,IT recommends analyzing for petroleum hydrocarbons only in MW-1 and MW-5. I suggest that MW-1 is the only well that needs to be analyzed for petroleum hydrocarbons, whereas MTBE and other oxygenates should be analyzed for in MW-1, MW-5 and MW-81 since all of these lie downgradient from the former underground storage tank. IT also requested that the analyses for pesticides and herbicides be reduced or eliminated in several of the monitoring wells since these constituents have not been detected for several quarters. The only well that has contained constituents of concern within the last year has been MW-3, near the warehouse building. The remaining wells have not contained pesticides or chlorinated herbicides for at least four consecutive quarters. I concur with IT's recommendation that we eliminate the analyses for pesticides and herbicides from the MRP for monitoring wells MW-1, MW-2, MW-4, MW-5, MW-8 and MW-9. The analyses for pesticides (EPA Method 619 and 8081A) and herbicides (EPA Method 8151A) should continue quarterly in MW-3. Although herbicides have not been detected in MW-7 since September 1998, I agree with IT's suggestion that we continue sampling for these compounds annually since it monitors the deeper aquifer beneath the facility. The annual sample event should occur in the third quarter, since the most recent herbicide detections have been during low groundwater periods. Since pesticides have not been detected in this well since monitoring began (December 1997), I recommend we eliminate the pesticide scans from the schedule for MW-7. Feasibility Study In our 8 June 1999 meeting with you, Ms. Martha Bowman (the bankruptcy trustee), Ms. Sandra Pezillo and Mr. David Smith of IT Group, Ms. Wendy Cohen and myself of Board staff, all agreed that IT has identified the extent of petroleum, nitrate and ammonia contamination in groundwater and that a feasibility study report would be completed by 30 October 1999. This date was extended until 30 November 1999, but the court has not yet released funding for the study. You relayed in your 19 October letter that the bankruptcy court is reluctant to release funds since the San Joaquin Area Flood Control Agency may foreclose on the site. The court stayed for six months the decision to release funds. The site is ready for remedial action, and the value of the property will increase after remediation commences and will increase again once remediation is completed. The responsibility for remediation primarily is with Cal Farm Supply Company, although any other parties that have title to the land may also be held financially responsible. Thank you for performing the quarterly monitoring events regularly and for submitting the quarterly monitoring reports. Please review the draft revised MRP, submit comments to me by 17 March 2000, and submit a revised timeline for the feasibility study and a work plan to replace MW-6 and resurvey the