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Mr.Leon Brasowski,Ogden -2- 25 February 1993 necessary at this time. As we discussed on 19 February,final closure of the facility cannot be determined complete until Regional Water Board staff has reviewed recent ground water monitoring data for the facility and data on representative samples from the treated soil stockpile. Treated Soil Stockpile Characterization In our 19 February 1993 telephone conversation,I requested that a minimum of four composite samples be taken so as to be representative of the treated soil stockpile. These samples should be analyzed for TPH(diesel) and for oil and grease using EPA Method 5520. Deionized water extractions,using the California Waste Extraction Test method, should also be performed on the samples with the resulting extract analyzed for CCR Title 22 metals, chloride,sulfate, and total dissolved solids. Detection limits for the extract analyses should be low enough to enable the Board to determine whether any of the samples exceed Soluble Designated Levels in the attached table. Stockpiled treated soils for which: ❑ all constituents are below these Soluble Designated Levels and which ❑ do not contain detectable levels of TPH(diesel) and ❑ do not contain Method 5520 oil and grease hydrocarbons in excess of those found in background soil samples obtained in 1992 confirmation sampling may be used to backfill the excavation in the area of the former contaminated soil stockpile. Ground Water Monitoring Monitoring reports have not been received by the Board since your 18 February 1992 report for the period ending with the December 1991/January 1992 monitoring well samplings. Missing are reports of quarterly sampling of the ground water monitoring network for TPH(gasoline),TPH(diesel), TRPH, BTEX and lead, and the monthly sampling for lead requested in my 4 October 1991 letter. You have explained that the closure of Ogden's San Diego office resulted in the transfer of the Stockton Soils Treatment Facility files to your New Jersey office. Please review those files and submit the missing monitoring reports to the Regional Water Board without delay. My 4 October 1991 letter also requested the construction and sampling of a more representative background monitoring well than well MW-3,prior to establishment of a new waste pile on the site. Considering that Ogden does not now plan to construct such a waste management unit, and considering the lead data for filtered samples contained in your 18 February 1992 monitoring report, such a well may not be needed. A review of monitoring data for samples taken subsequent to January 1992 should clarify the need for the additional monitoring well. As stated in my 4 October 1991 letter, "trace" analytical results (those for which constituent concentrations are above the analytical detection limit but below the practical