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Mr. Terry Lau Page 3 <br /> July 24, 1995 <br /> site-specific threats to water quality using the Designated Level <br /> Methology or some other methods such as "Sesoil." The RI work plan <br /> must be modified to acknowledge that a water quality assessment will <br /> be conducted to evaluate potential impacts of soil contaminates on <br /> ground water. Enclosure 2 is a copy of our 5 Novemeber 1992 Draft <br /> Water Quality Assessment document which describes how this <br /> assessment must be conducted. <br /> Response: The soil sampling and analysis plan will be revised to <br /> accommodate the RWQCB's recommendations. A Waste Extraction <br /> Test (WET) will be performed and its results will be used to assess site <br /> specific threats to groundwater quality. <br /> 6. The ground water sample for total lead described on Page 4-10 should <br /> be filtered and compared with the background total lead in ground <br /> water from filtered samples. <br /> Response: Total lead concentrations from filtered groundwater samples <br /> will be compared to filtered background levels and regional total lead <br /> concentrations for filtered samples if such information are available. <br /> 7. Page 4-10 of the work plan proposes to dispose of purge water onsite if <br /> consituent concentrations in the water are below the maximum <br /> contaminant levels (MCLS). The presence of organic chemicals, which <br /> are not naturally occurring, in ground water is an indication of <br /> pollution. Therefore, the discharge of such water is a waste discharge. <br /> The Porter-Cologne Water Quality Control Act requires any person to <br /> file a report of waste discharge (RWD) with the board prior to the <br /> discharge of waste. Therefore, if you wish to discharge purge water <br /> onsite you must file an RWD with the Board. The discharge will be <br /> allowed under General Order No. 91-25000 which prescribes waste <br /> discharge requirements for the land disposal of treated ground water <br /> from the investigation and cleanup of ground water polluted with <br /> petroleum fuels. Enclosure 3 is a copy of General Order 91-25000 with <br /> the application requirements attatched. <br /> Although the Board can allow onsite discharge of purge water from <br /> this investigation, the Navy should consider discharging to the City of <br /> Stockton wastewater treatment plant as this may be a more cost- <br /> effective and efficient disposal option. <br /> Response: The purge water disposal options mentioned above will be <br /> evalutated and the most cost-effective and efficient alternative will be <br /> used to dispose of the water generated from the investigation. <br />