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AUG � 7 2009 <br /> `- ENu[RGW �lnent of Toxic Substances Control <br /> v <br /> PERMIT/SERVICES Maziar Movassaghi <br /> Linda S.Adams Acting Director Arnold Schwarzenegger <br /> Secretary for 8800 Cal Center Drive Governor <br /> Environmental Protection Sacramento, California 95826-3200 <br /> August 26, 2009 <br /> Mr. Phil Dawson <br /> Defense Logistics Agency <br /> Staff Director, Environmental Management <br /> Defense Logistics Agency Headquarters <br /> 8725 John J. Kingman Road <br /> Fort Belvoir, Virginia 22060-6221 <br /> RESPONSE TO DEFENSE LOGISTICS AGENCY (DLA) AUGUST 13, 2009 LETTER <br /> FOR INFORMAL DISPUTE RESOLUTION FOR DEFENSE DISTRIBUTION DEPOT <br /> SAN JOAQUIN CALIFORNIA (DDJC), TRACY SITE, TRACY, CALIFORNIA <br /> Dear Mr. Dawson: <br /> The Department of Toxic Substances Control (DTSC) and California Regional Water <br /> Quality Control Board, Central Valley Region (Central Valley Water Board), collectively <br /> the State, received the above-mentioned DLA response letter electronically on August <br /> 13, 2009. DLA's response letter was the first attempt to address the informal dispute <br /> initiated by the State rejecting the DDJC-Tracy Northwest Corner Feasibility Study due <br /> to technical differences in the interpretation of observed data and compliance with <br /> applicable or relevant and appropriate State requirements (ARARs). The DLA response <br /> letter was intended to offer a formal response to the State's proposed four Pump and <br /> Treat shutoff criteria and included a new alternative not identified in the DDJC-Tracy <br /> NWC Dieldrin Feasibility Study Report. <br /> In an attempt to resolve the informal dispute, DLA responded to the State with a <br /> proposed remedial alternative of Institutional Control with long-term monitoring coupled <br /> with a contingent alternative of pump and treat if the plume migrates. The State <br /> identified that the draft final FS and the alternative presented in DLA's August 13 letter <br /> are not supported by the site-specific data demonstrating the feasibility of the pump and <br /> treat remedy. The alternatives proposed by DLA are not in compliance with ARARs <br /> because the requirements of State Water Resources Control Board (SWRCB) <br /> Resolution 92-49 have not been met. <br /> 0 Printed on Recycled Paper <br />