COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

first two Specific Comments, and the two demands for further action made by the CVRWQCB in the letter dated 27 May 2014. The first Specific Comment states: "Data gaps regarding ground water impacts exist at IAS-09, mainly in the northern section of the site. POS will be required to conduct additional site assessment of soil and groundwater impacts in the areas along IAS-09 where these gaps occur." The CVRWQCB provides no details about these"data gaps"nor the areas where they occur. The simple absence of ground water data is not a data gap. The level of ground water investigation completed at IAS-09 is entirely appropriate. Due to their low solubility in water, OCPs are not a common ground water contaminant.Thus, OCPs were analyzed in ground water in areas where the soil concentrations were the highest. It is the Port's position that OCPs were properly identified as the only contaminant of concern at IAS-09;that the distribution of these compounds in soil at IAS-09 has been adequately assessed by sampling and analyses completed by the Navy and the Port; that residual OCPs in soil do not pose an unacceptable risk to future users of the site; and that there is no credible threat of dissolved OCPs in ground water based on the results of ground water monitoring in the area of greatest OCP impacts in soil. The second Specific Comment states: "Central Valley Regional Board staff request groundwater sampling and submittal of groundwater monitoring reports for site IAS-09 be submitted semi- annually until further notice. Data collected from the recent groundwater sampling conducted during monitoring well abandonment shall be utilized in the first semi-annual report." As noted above, ground water samples from four consecutive quarters collected from wells adjacent to the southern portion of IAS-09 did not reveal any detectable OCPs in ground water. Based on this result, ground water at IAS-09 has not been affected by the release of OCPs from IAS-09. Semiannual monitoring is only appropriate where there is a demonstrated impact to ground water. There are no ground water impacts associated with IAS-09;therefore the demand by the CVRWQCB for semi-annual monitoring is unjustified. The Comment letter concludes with two required actions to be completed by the Port. First, "Please provide a Work Plan to conduct additional site assessment at site IAS-09 (in its entirety). But,due to the urgent nature of conducting site assessment in the northern site area prior to UPRR construction (and the expansive size of IAS-09), Central Valley Board staff will concur with the implementation of the Work Plan to be localized between the northern boundary of the site and IAS-16(the limits of the UPRR construction)." The Port cannot prepare a plan to fill data gaps that have not been identified.The portion of IAS- 09 north of IAS-16 has yielded no soil samples with OCP concentrations exceeding industrial exposure levels.The results of the 1996 sampling indicated that OCPs in soil were much lower in the northern half of IAS-09 than in the southern half; this result was confirmed by the 2010 sampling and analyses. With respect to ground water, monitor wells RRI-W177 and RRI-W184 are located less than 100 feet from IAS-09 in the northern portion of the site; these wells yielded four consecutive quarters of non-detected concentrations of OCPs between 1998 and 1999. The Page 3of4 ers