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California R*nal Water Quality C- ltrol Board <br /> Central Valley Region - a <br /> l;d J.Schnabel,Chair <br /> Winston Hickox Gray Davis <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/-rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 19 January, 1999 <br /> Mr. Stewart Cheang <br /> Naval Environmental Facility Activity-West <br /> Code 6427 <br /> 900 Commodore Drive <br /> San Bruno, CA 94066-2402 <br /> PRE-FINAL UNDERGROUND STORAGE TANKINVESTIGATIONAND CORRECTIVE <br /> MEASURES STUDY FOR FORMER UNDERGROUND STORAGE TANKS SITE 517, SITE 617 <br /> SUMP AND SITE 816D <br /> We have reviewed the Navy's response to Board comments, dated 15 September 1997, for the Pre-Final <br /> Underground Storage Tank Investigation and Corrective Measures Study dated January 1997. The sites <br /> include UST Sites 517-1, -2 (Parcel 92) and Site 816D-1 (Parcel 181), and Sump 617 (Parcel 89). <br /> Throughout the document, the Navy states that investigations may or may not proceed "subject to <br /> funding." Since this project was formulated in fiscal year 1997, we request the Navy clarify if there <br /> continues to be a funding problem with regards to proceeding with finalizing the document and/or <br /> initiating investigations. <br /> Prior to finalizing the final document, we request the Navy address the following issues. Our responses <br /> reflect specific numbered comments based on the Navy's response letter. <br /> Specific Comments <br /> 2. Subsections a), b), and c) reference the proposed location of MW-4 and HydropunchTM location on <br /> Figure 6-1. Figure 6-1 was not included in the document; therefore, we can not comment on these <br /> subsections. <br /> Subsection d) describes the use of Geoprobe techniques to define the extent of impacted <br /> groundwater. Please elaborate on the use of GeoprobeTM techniques versus HydropunchTM. <br /> Subsection e) discusses the initiation of a groundwater monitoring program. The Navy proposes to <br /> discontinue MTBE analysis if it is not detected during the first event. Sample all wells quarterly <br /> for the first year, then reduce the sampling frequency for wells showing non-detect for two <br /> consecutive quarters. For the wells proposed in a) and b) above, the Navy will include analysis for <br /> intrinsic remediation parameters and biodegradation indicators in the analytical suite. <br /> We request the Navy run the normal EPA Methods 8015 and 8020 for volatile and extractable fuel <br /> hydrocarbons and BTEX, respectively, and confirm, at least once, with EPA Method 8260. EPA <br /> Method 8260 includes MTBE and all other oxygenate compounds required to be analyzed as listed <br /> in the Board's letter of 18 July 1997 (see attached). If MTBE, or any of the other listed gasoline <br /> California Environmental Protection Agency <br /> Ca Recycled Paper <br />