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Mr. Scott Hilyard - 2 17 October 2005 <br />California Army National Guard <br />that CANG test the powder for a full suite of potential contaminants (if it hasn't already been done) <br />and submit the additional test results by 30 November 2005. <br />The PA/SI Update Report uses the phrase "below actionable levels" when describing analytical <br />results. There are currently no negotiated cleanup levels at this site and background threshold limits <br />were never developed for inorganics at the CANG site, so it is misleading to use this phrase. It is <br />reasonable, for example, to state "the metals in the soil sample are below California Human Health <br />Screening Levels" or make a similar comparison to a potentially applicable cleanup level. CANG <br />needs to delete this phrase throughout document and replace it with a factual comparison of the <br />analytical data to potentially applicable cleanup levels. <br />There is an ongoing collaborative effort between the State of California and Department of Defense <br />to identify and investigate potential sources of perchlorate. The uplifted pavement areas at the <br />CANG site were originally identified as areas where tear canisters were potentially buried. Tear gas <br />canisters are a potential source of perchlorate and perchlorate has been detected in several public <br />supply wells in the South Stockton Area. Regional Board staff request that CANG analyze the <br />bluish-white powder for perchlorate and sample shallow groundwater beneath the facility to verify it <br />is not a source of perchlorate. <br />Specific Comments <br />Page 10, Section 3.3: This discussion of the bluish-white powder belongs in Section 3.2, so move it. <br />Page 12, Section 4.3: Revise "east and northwest" in the fourth sentence of the second paragraph to <br />"west". <br />Please submit the Revised PA/SI Update Report along with responses to our comments in this letter by <br />30 November 2005. As requested by San Joaquin County Public Health Services, Regional Board staff <br />will provide lead regulatory oversight on all aspects of environmental investigation and cleanup at this <br />site, including the petroleum hydrocarbon release areas. CANG should continue to provide copies of all <br />future correspondence, work plans, and reports to San Joaquin County Public Health Services. If you <br />have any questions, please contact me at (916) 464-4733 (mpierce@waterboards.ca.gov). <br />/ a/La" ci <br />Marcus L. Pierce, C.Hg. <br />Engineering Geologist <br />cc: <br />Mr. Mike Infurna, San Joaquin County Environmental Health Department, Stockton <br />Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br />Mr. Tim Berger, Versar, Sacramento