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Ilk <br /> DEFENSE LOGISTICS AGENCY �q , - <br /> DEFENSE DISTRIBUTION REGION WEST cc <br /> q� P.O. BOX 960001 JOu <br /> STOCKTON, CA 95296- <br /> =". MAY 5 15e? <br /> ENVIRONNAcNiAll_ <br /> IN REPLY <br /> REFER To DDRW-G ' ,1i(V11 rr�t .f�:' 4 May 1992 <br /> SUBJECT: Services Provided by the Environmental Health Division - <br /> Inspection and Review <br /> San Joaquin County <br /> Public Health Services <br /> Environmental Health Division <br /> PO Box 2009 <br /> Stockton, CA 95201 <br /> To Whom It May Concern: <br /> This letter is in response to your billings for review and <br /> inspection at the former Defense Depot Tracy. I have consulted <br /> with my clients and they have authorized me to make this response. <br /> The invoices indicate that the services are from the "Site <br /> Mitigation Unit" . After talking to your accounting department, I <br /> was unable to ascertain what services were rendered and under what <br /> authority the billings are authorized. In particular, I 'm <br /> interested in learning what federal statute the billings are <br /> related to. <br /> As you know, the former Defense Depot Tracy is on the National <br /> Priority List. As such, the "site" is being remediated under <br /> CERCLA guidelines. The federal government has signed a <br /> Defense-State Memorandum of Agreement (DSMOA) with the state to <br /> cover oversite costs at the site. Additionally, the depot has <br /> signed a Federal Facilities Agreement (FFA) with the EPA, state <br /> (DHS/DTSC) and Regional Water Quality Control Board. All state <br /> requirements are identified to EPA as Applicable, Relevant, and <br /> Appropriate Requirements (ARARs) . This state involvement is <br /> provided for in CERCLA sections 120 (f) and 121 (f) . The only place <br /> in CERCLA that mentions local (county) participation in federal <br /> facility NPL cleanups is at CERCLA section 120 (f) . That section <br /> does not allow the county to collect the costs of their <br /> involvement. <br /> Since an NPL site is defined as including areas where <br /> contamination comes to be located, the plume of contamination <br /> extending off the depot is part of the NPL site. The Tracy FFA <br /> memorializes this fact. I am unaware of any county government in <br /> the nation receiving monies from EPA, for instance, for oversite <br /> at their NPL site cleanups. The depot cleanup falls in the same <br /> category of response action undertaken by EPA. <br />