Laserfiche WebLink
SSE OF C,%IFORNIA - ENVIRONMENTAL PPOTECTION AGENCY PETE WILSON, Gavrner <br /> DEPARTMENT OF TOXIC SUI&ANCES CONTROL • <br /> Region 1 <br /> 10151 Croydon Way,Suite 3 •�,,. <br /> Sacramento,CA 95827-2106 <br /> (916)855-7700 <br /> August 23,1991 RKLII <br /> AUG 2 8 1991 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Marshall Cloud <br /> Defense Distribution Region West <br /> Tracy Site <br /> Office of Environmental Protection <br /> 25600 South Chrisman Road <br /> Tracy, CA 95376-5000 <br /> Dear Mr. Cloud: <br /> REVIEW OF THE SCOPE OF WORK FOR THE SUBSISTENCE WAREHOUSE <br /> CONSTRUCTION SITE, DEFENSE DISTRIBUTION REGION WEST (DDRW) , TRACY <br /> SITE <br /> The Department of Toxic Substances Control (Department) has <br /> reviewed the scope of work (SOW) for the proposed removal action <br /> (RA) at the subsistence warehouse construction site. Generally, <br /> we agree with the SOW as written . Our comments are designed to <br /> clarify several issues and insure the continued close <br /> coordination achieved with DDRW, Tracy. <br /> The Department agrees with the implementation of the SOW as <br /> a RA under section 11. 4 of the Federal Facilities Agreement. The <br /> Department recommends limiting proposed actions to the <br /> construction area and removed debris. Although it is evident <br /> that additional characterization and possible remedial actions <br /> may be necessary outside these areas, only the construction site <br /> and debris piles pose an immediate health threat. Other remedial <br /> actions can be incorporated into the Depot wide RI/FS. <br /> Page 8 and Table 1 outline the sampling criteria for the <br /> SOW. Generally, we agree with the outlined criteria. However, <br /> we do recommend the incorporation of the California Waste <br /> Extraction Test (WET) into the sampling protocol . It has been <br /> our experience that the WET is more stringent than comparable <br /> methods for soluble analyses. <br /> The Department will endeavor to meet the three day <br /> turnaround time for comments on the follow up workplan to the <br /> SOW. However, meeting this goal on all aspects of the workplan <br /> seems unlikely. On those activities we can not meet the three <br /> day criteria, we will defer review. Our primary reviewing <br /> concern for the three day turnaround would be the health and <br /> safety plan. We therefore recommend that previously approved <br /> health and safety plans at DDRW, Tracy be used as a model. <br />