SITE INFORMATION AND CORRESPONDENCE 1995-2004

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Ms. Frances E. Anderson Page 4 Improving Coordination to Achieve Project Coals in a More Timely Manner It is apparent from your July 2 letter that DTSC is dissatisfied with the progress (or perceived lack of progress) of the site investigation process. You point out that"...more than three years have passed and we are discussing the same issues," and provide DTSC's assessment that"...past meetings and conference calls have not resulted in significant progress." Accordingly, you request that PG&E"...manage this project with more commitment to achieving project goals in a timely manner." In furtherance of this request, you invite a discussion of ways to improve coordination between PG&E and DTSC to ensure that work products meet DTSC expectations. I am looking forward to that discussion at our meeting on August 8, and agree that it is essential that PG&E's work products meet DTSC expectations, as well as those of the RWQCB. At the same time, it would be beneficial to discuss those ways in which, in PG&E's opinion, DTSC can better exercise its lead agency responsibilities. Of particular concern is the manner in which comments from the RWQCB have been handled by DTSC. On several occasions, RWQCB comments have been seemingly at odds with approvals and directives from your agency,yet have been passed on for response by PG&E without comment by DTSC. The most recent(July 2, 1996) RWQCB comments on the draft Phase IV Groundwater Investigation Report illustrate this problem. The RWQCB comment No. 3 calls into question the adequacy of the Risk Assessment report dated August, 1993, implying that the report was somehow deficient in not considering groundwater as a receptor. The Risk Assessment, which was approved by DTSC on October 21, 1993, was prepared in full conformance with all U. S. Environmental Protection Agency and DTSC guidance. Nowhere in that guidance is there a provision for treatment of groundwater as a receptor; the guidance is clear that groundwater is a medium, as it was considered in our Risk Assessment. Similarly, we are not aware of any regulation or policy adopted by the State Water Resources Control Board, or any written policy adopted by any RWQCB, which calls for risk assessments to consider groundwater as a receptor. Given this, I do not think it unreasonable to expect that the apparent conflict between the RWQCB comment and DTSC's approval would have been resolved between the agencies before the joint comments were issued. Instead, however,the RWQCB comment was simply attached to the DTSC cover letter and comments, with the simple direction that the "...RWQCB comments must be addressed prior to the Report being approved." The agencies' failure to coordinate comments or recognize prior approvals is also apparent in RWQCB comments dated December 14, 1995 regarding the draft Soil Operable Unit Feasibility Study. In those comments (see especially comment nos. 9 through 13), the RWQCB is critical of inconsistencies in sampling depth and types of analyses performed for various phases of soils investigation in Area I; yet each of those phases of the investigations were performed using sampling depths and analyses clearly specified in workplans approved by DTSC. Where we would expect to find coordination