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\J Department of Toxic Substances Control ;0 4 <br /> Maziar Movassaghi <br /> Linda S.Adams Acting Director Arnold Schwarzenegger <br /> Secretary for Governor <br /> Environmental Protection 8800 Cal CentVW (��D <br /> Sacramento,Califom u� 3 EV <br /> ED <br /> 23, 2010 <br /> FEB 2 6 20'10 <br /> ENVIRONMENT HEALTH <br /> Mr. Maurice Benson PERMIT/SERVICES <br /> Remedial Project Manager <br /> Defense Distribution Depot—Tracy Site <br /> P.O. Box 960001 <br /> Stockton, California 95296-0320 <br /> COMMENTS ON THE DRAFT FEDERAL FACILITIES AGREEMENT (FFA) ANNUAL <br /> MONITORING REPORT FOR DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN <br /> CALIFORNIA (DDJC), TRACY SITE, TRACY, CALIFORNIA <br /> Dear Mr. Benson: <br /> The Department of Toxic Substances Control (DTSC) received the above-mentioned <br /> report on December 22, 2009, submitted by HDR/e2M of Folsom, California, on behalf <br /> of Defense Enterprises Support San Joaquin California (DESJC). The Annual Report is <br /> a primary document and affords the regulatory agencies a 60-day review period. <br /> The Annual Progress Report summarizes the results from the quarterly sampling events <br /> for fourth quarter 2008 (4Q08), 1 Q09, 2Q09, and 3Q09. Specific objectives of the <br /> Annual Progress Report are to: update the conceptual site model; present the results of <br /> the groundwater and groundwater treatment plant monitoring; update the nature and <br /> extent of contaminant groundwater plumes; review the annual and cumulative <br /> effectiveness and efficiency of the treatment systems; summarize soil vapor extraction <br /> (SVE) operational data and system modifications; and recommend potential <br /> optimization efforts to improve remedy efficiencies. <br /> DTSC has reviewed the report and has the following comments: <br /> 1.) Page ES-1, section ES.1.2, Document Objectives: The last bullet in the section <br /> recommends the need to implement contingency response actions, yet the <br /> decision components of the Water Contingency Plan are not presented in the <br /> Annual Report. Additionally, the agencies have not formally approved the <br /> proposed sampling frequency rationales or agreed with the overall <br /> protectiveness of the proposed changes. The Annual Monitoring Report <br /> represents a primary document; thus, any future decision logic or proposed <br /> changes to the DDJC-Tracy Well Monitoring Program should be captured in the <br />