SITE INFORMATION AND CORRESPONDENCE_1992

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• MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Antonia K. J. Vorster FROM: Camilla Williams Senior WRC Engineer Engineering Geologist DATE: 30 March 1992 SIGNATURE: �iI/I7LG��Gv,e��iG!/miFJ SUBJECT: REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA) WORK PLAN, DEFENSE DISTRIBUTION REGION WEST (DORW), SHARPE, SAN JOAQUIN COUNTY I have reviewed the RD/RA Work Plan entitled "Selection of a Modeling Approach and Work Plan for Data Acquisition, Central Area, Sharpe Army Depot, Lathrop, California. " The RD/RA Work Plan was submitted on 7 February 1992 and was prepared by Engineering Technologies Associates, Inc. (ETA) and Environmental Science (ESE) and Engineering, Inc. for the U. S. Army Toxic and Hazardous Materials Agency (USATHAMA) . In the 27 February 1992 Project Manager's Meeting, I discussed my preliminary concerns on the document with Sharpe and the other regulatory agencies. I have included those comments in this review. I also had two telephone conversations (on 5 and 13 March 1992) with Mr. Craig MacPhee of USATHAMA as well as telephone conversations with staff of ETA and ESE regarding the proposed field work. Activities for this field effort were originally scheduled to begin on 3 March 1992; less than 30 days after submittal of the document. Commencement of the field activities were delayed by one week, but still began well before the end of the 60 day review period. USATHAMA requested that permits be obtained from San Joaquin County for on- and off.-site well/boring installations. This accelerated field activity adds the risk of the work proposals not being reviewed by the agencies, the field work being unacceptable to the agencies and it causes additional scheduling conflicts with respect to obtaining local permits. Sharpe should submit the proposals for field work sufficiently in advance so that regulatory concerns, if any, can be considered for the field effort. This includes 60 days for agency review or other periods as agreed upon by all parties prior to submittal of the document, and time to respond to the regulatory comments prior to mobilizing. Finally, in this case it is unclear why comments should be provided when it appears that the contracts for the field work were already in-place. It was our understanding that this document was to be a Work Plan for the site-wide ground water RD/RA. However, the majority of the Work Plan clearly focused on development of field information for the Central Area. We have previously indicated that the ground water Record of Decision (ROD) must include any necessary upgrading of the Interim Remedial Actions (IRMs) in the North and South Balloon Areas, as well as the installation of the extraction and treatment systems in the Central Area (refer to our letters dated 2 January 1992 and 20 December 1991) . Once this field information is developed, we recommend that a ten percent design document be submitted to agree on the conceptual approach for upgrading the North and South Balloon Areas and the installation of the Central Area extraction, treatment and disposal systems. A 50 percent design document may need to be submitted prior to final design of the systems. My major concerns, including those discussed during the Project Manager's Meeting, are summarized below.