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California RE 'onal Water Quality C6ntrol Board <br /> Central Valley Region <br /> Steven T.Butler,Acting Chair <br /> Sacramento Main Office <br /> Internet Address: httpJ/wwwswrcb.ca.gov/-rwgcb5 <br /> 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 7 June, 1999 <br /> Mr. Alfonso T. Jesena, Jr. <br /> Navy Environmental Facility Activity-West <br /> Code 6424 <br /> 900 Commodore Drive <br /> San Bruno, CA 94066-2402 <br /> INVESTIGATION-DERIVED WASTE SOIL, NAVAL COMPUTER AND <br /> TELECOMMUNICATIONS STATION SAN DIEGO DETACHMENT(NCTS), STOCKTON <br /> The Navy's faxed cover letter of 1 April 1999, requests dic iivatti's �ommeiits on an attached <br /> 1 February 1999 document prepared by Tetra Tech EM Inc. The document describes the storage and <br /> disposal of Investigation-Derived Waste (IDW) soil from activities related to drilling and installing <br /> monitoring wells at Installation Restoration (IR) landfill sites at NCTS, Stockton. <br /> Soil samples from drilling operations were found to contain metals at concentrations exceeding <br /> background, as well as, pesticides (4,4'-DDD at 200 µg/kg, 4,4'-DDE at 65 µg/kg, and 4,4'-DDT at 96 <br /> µg/kg) as shown on Table 1 of the Navy's letter. The Navy proposes to dispose of contaminated soil <br /> around the individual well sites in an area that would preclude soil erosion or runoff to adjacent property <br /> or drainage channels. <br /> Title 27, California Code of Regulations (CCR) states that the disposal of contaminated soil constitutes <br /> waste discharge to land. Therefore, IDW must be properly disposed in a classified waste management <br /> unit (WMU) depending upon the waste characteristics [Title 27, CCR, Subchapter 2, Article 2, <br /> §20200(c)]. Since there are no classified WMUs or approved closure plans for landfills where the soil <br /> could be used as a component of the final cover at NCTS, Stockton, the Navy is required to dispose of or <br /> contain (e.g., barrel) the contaminated soil. This action is consistent with other Department of Defense <br /> (DoD) facilities regulated by the Board. <br /> The Navy should address this issue in a response letter stating how the contaminated soil will be <br /> handled. <br /> If you have any questions, please contact me at (916) 255-3078 or schwabk@rb5s.swrcb.ca.gov. <br /> Kim A. Schwab <br /> Associate Engineering Geologist <br /> DoD, Cleanup Unit <br /> cc: Mr. Jim Austreng, DTSC, Region 1, Sacramento <br /> Mr. Scott Flint, CA Dept. of Fish and Game, Sacramento <br /> Mr. Ron Rowe, San Joaquin County Environmental Health, Stockton <br /> Mr. Brad Beeman, NCTS, Stockton <br /> Mr. Jay Jahangiri, Port of Stockton <br /> Mr. Christopher M. Fennessy,Tetra Tech EMI, Rancho Cordova <br /> KAS:NCS IDW soil.2 <br /> California Environmental Protection Agency <br /> Ca Recycled Paper <br />