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TECHNICAL REVIEW COMMENTS - CVRWQCB <br />Draft Type II Work Plan — Addendum UXO Construction Activities and Soil Removal Action <br />California Army National Guard Facility, 2000 Stimpson Road, Stockton, San Joaquin County <br />General Comments: <br />Central Valley Regional Water Quality Control Board staff (Regional Water Board staff) has reviewed the Draft Type II Work Plan — <br />Addendum UXO Construction Activities and Soil Removal Action (Draft Addendum) for the California Army National Guard (CA <br />ARNG) Facility received on 20 November 2006. Regional Water Board staff comments on the Draft Addendum are provided below. <br />A revised Draft Addendum addressing our comments should be submitted to our office no later than 9 April 2007. <br />As part of the review of the Draft Addendum Regional Water Board staff also reviewed the Final Type II Work Plan, UXO <br />Construction Activities and Soil Removal Action dated September 2005 and the Investigation Report, UXO Construction Activities and <br />Soil Removal Action dated January 2006. These documents cover planning and implementation of soil/debris investigation and <br />removal actions. These actions were completed without involvement of Regional Water Board staff. The removal actions were <br />focused on a historical disposal area containing copper sulfate and airplane parts. Regional Water Board staff does not agree with CA <br />ARNG's conclusion to leave the copper sulfate-contaminated soil and assorted airplane parts in-place because they "do not pose a <br />significant threat to the environment". The Investigation Report does not provide a complete assessment of the risks proposed by the <br />residual contamination to support this conclusion, but does indicate the copper sulfate contamination is toxic if ingested. Furthermore, <br />the extent of the soils containing copper sulfate and airplane parts was not fully defined due to budget limitations. <br />Response to General Comments: <br />CA ARNG met with CVRWQCB staff on 22 February 2997. The issues as described in the "General Comments" were discussed <br />during that meeting. Please see the attached copy of the 26 February 2007 email correspondence summarizing the meeting. <br />FOR OFFICIAL USE ONLY <br />28 March 2007 <br />Page 1 of 4