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EDMUND G. QPOWN JP. <br /> « r <br /> OOVERNOF <br /> 01.1 .G A <br /> .O 1 A \� MCRFHAERW R ODRIOUEZ <br /> Water Boards ENVIRONMENTAL PROTECTION <br /> Central Valley Regional Water Quality Control Board <br /> RENEE <br /> 31 July 2014 AUG 04 2014 <br /> Belinda May, LTC ENVIRONMENTAL HEALTH <br /> Environmental Compliance Officer PERMIT/SERVICES <br /> 10620 Mather Road <br /> Mather, CA 95655-4176 <br /> ANNUAL GROUNDWATER MONITORING REPORT& REMEDIAL ACTION <br /> COMPLETION REPORT FOR OXYGEN-ENHANCED BIOREMEDIATION, ARMY <br /> AVIATION SUPPORT FACILITY, STOCKTON CALIFORNIA ARMY NATIONAL <br /> GUARD COMPLEX, SAN JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff (Central Valley Water Board <br /> staff) has reviewed the Annual Groundwater Monitoring Report & Remedial Action <br /> Completion Report for Oxygen-Enhanced Bioremediation (Annual Report) received on <br /> 30 May 2014. The Annual Report provides the groundwater monitoring data collected <br /> from 2011 to 2014, the results of the oxygen-enhanced bioremediation pilot study, and <br /> the rationale to support a recommendation for no further action (NFA) at the Army <br /> Aviation Support Facility (AASF). Central Valley Water Board staff comments on the <br /> Annual Report are provided below. <br /> GENERAL COMMENTS <br /> 1. Central Valley Water Board staff has reviewed the information presented in the Annual <br /> Report and concur that additional actions appear unwarranted for the AASF site. <br /> However, before we can issue a letter of concurrence with NFA, the California Army <br /> National Guard (CA ARNG) needs to submit a revised Annual Report that adequately <br /> addresses our comments below. <br /> 2. The Annual Report states the AASF meets the general and media-specific criteria <br /> described in the Low-Threat Underground Storage Tank Closure Policy (Policy) and <br /> relies primarily on the Policy to assess whether the site is ready for closure. While we <br /> don't disagree with evaluating the site using the Policy, it only applies to underground <br /> storage tank sites. The AASF site also contains a suspected former wash rack that <br /> appears to be the source of low concentrations of solvents such as trichloroethene <br /> and tetrachloroethene detected in site groundwater. A complete evaluation of the <br /> AASF site for closure must consider the residual solvents. Therefore, the Annual <br /> KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P,E., BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley <br /> P.1 HECYCLEU PA"H <br />