SITE INFORMATION AND CORRESPONDENCE_1992

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STATE OF CALIFORNIA '^ , PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— APR G C 1."292 l CENTRAL VALLEY REGION ENV IR0 11,7 I„j{,' iI LTI � 3443 ROUTIER ROAD, SUITE A pl SACRAMENTO, CA 95827-3090 PHONE: (916) 361-5600 FAX: (916) 361-5686 30 March 1992 Mr. Abel Haines Environmental Protection Office Bldg. S-4, Sharpe Location P. 0. Box 960001 Stockton, CA 95296-0250 REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA) WORK PLAN, DEFENSE DISTRIBUTION REGION WEST (DDRW) , SHARPE, SAN JOAQUIN COUNTY We have reviewed the RD/RA Work Plan entitled "Selection of a Modeling Approach and Work Plan for Data Acquisition” submitted on 7 February 1992. Overall , the Work Plan was well prepared and provided adequate supporting technical information and graphics. Many of our preliminary concerns with the proposed pumping and injection tests for the Central Area were discussed in the Project Manager's Meeting on 27 February 1992. The enclosed memorandum discusses these, as well as other concerns, with the RD/RA Work Plan. We understood that this document would be the Work Plan for the RD/RA and therefore, would include proposals for upgrading the Interim Remedial Actions (IRMs) in the North and South Balloon Areas. However, other than the section on modeling, specific proposals for the Balloon Areas could not be found. Therefore, we request that a ten percent design document be submitted to agree on the conceptual design approach for the North and South Balloon and Central Area extraction, treatment and disposal systems. We also request that updates on modeling status be provided on an on-going basis to address regulatory concerns during model development, rather than after model calibration. We also request that a stand alone document on the modeling be provided for regulatory review. We are concerned that field activities were scheduled to begin only a month after submittal of the Work Plan and well before the end of the 60 day review period. We believe that this accelerated field activity has caused additional scheduling conflicts with respect to obtaining local permits and that DDRW, Sharpe incurs the risk that the field work may be unacceptable. We request that future field programs begin no sooner than after the regulatory review period has been completed. Although most of our concerns have been previously discussed either at the Project Manager's Meeting or during telephone conversations with the U. S.