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M e m o r a n d u m CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS: 8-495-5600 TO: Gregory Vaughn FROM: Camilla Williams Senior WRC Engineer Engineering Geologist DATE: 6 March 1989 SIGNATURE: SUBJECT: KEARNEY KPF, SAN JOAQUIN COUNTY; REVIEW OF HARGIS AND ASSOCIATES DRAFT GROUND WATER ASSESSMENT PLANT I have reviewed the Hargis and Associates' Draft Ground Water Assessment Plan. The Hargis Sampling and Analysis Plan (SAP) was also included in the assessment plan. However, I have not provided written comments on the SAP as this plan is reviewed by the RCRA Comprehensive Monitoring Evaluation (CME) Process. I have incorporated my comments in the CME. My comments on the Hargis Draft Ground Water Assessment Plan are listed below: Page 4 The site base map ( Figure 2) should be revised to include California Water Service Well (CWS) 77-01. Page 8 Waste oils are reported to have been stored in the former drummed waste storage area for a two-year period. However, in the document entitled "Initial Definition of Problem and Assessment of Liability", dated 6 February 1986 and prepared by Canonie Environmental , it was reported that oils may have been disposed of in an area west of the parking lot. This past disposal practice should be confirmed or discounted prior to soils gas or background soils data collection. Page 10, Samples from two soils borings (T-6 and T-7) have been previously Table 2 analyzed for organochlorine pesticides ( refer to letter dated 6 February 1987 from Canonie Environmental ) . This information may be useful in conjunction with the Appendix IX Ground Water Sampling which also includes analyses for organochlorine pesticides. Page 10, The constituents listed for analyses by soil gas did not include Table 2 1 ,1-dichloroethane (DCA) . The highest concentration of DCA detected in ground water similar to that of trichloroethylene (TCE) (41 ppb versus 56 ppb] and DCA was the second highest volatile organic constituent (VOC ) detected in sludge samples collected by SNR (3 December 1987) . DCA should be included in the soils gas analyses. Pages 13 The approximate vertical extents of the shallow and intermediate & 14 water-bearing zones are not defined. Both zones are jointly described The basis for identifying an intermediate zone was not presented. Therefore, from the descriptions provided in text there appear to be only two distinguishable water-bearing zones; the upper zone; from the