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• <br /> California Regional Water Quality Control Board <br /> Central Valley Region r `` <br /> Karl E.Longley,SO,P.E.,Chair <br /> Linda S.Adams 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Arnold <br /> Secretogfor Schwaraenegger <br /> Environmental Phone( w, aterbo 1•FAX(916)tWvali y <br /> http://www.waterAoards.ca.gov/cenUslvallcy Gnvernnr <br /> Protection <br /> 1 July 2009 [REE WEED <br /> JUL 0 3 2009 <br /> DESJC, M.BENSON ENVIRONMENT HEALTH <br /> Defense Distribution Depot San Joaquin PERMIT/SERVICES <br /> P.O. Box 960001 <br /> Stockton, CA 95296 <br /> INITIATION OF INFORMAL DISPUTE RESOLUTION PROCESS AND PROPOSED <br /> PATHWAY FORWARD FOR NORTHWESTERN CORNER DIELDRIN PLUME REMEDY, <br /> DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN— TRACY SITE <br /> California Department of Toxic Substances Control and California Regional Water Quality <br /> Control Board, Central Valley Region staff(jointly referred to as the State) have reviewed the <br /> Defense Distribution Deport (DDJC) Draft Final Northwestem Comer Dieldrin Plume Feasibility <br /> Study Report(Draft Final FS), dated 10 June 2009. The Draft Final FS was prepared by URS <br /> Corporation on behalf of Defense Logistics Agency Enterprise Support San Joaquin, California <br /> (DLA) for the DDJC Tracy site. <br /> The Draft FS was submitted on 21 November 2008 and evaluated alternatives for response <br /> actions to address the presence of dieldrin in groundwater beneath the MING area. DLA <br /> concluded that dieldrin removal by pumping was not effective. The State mailed comment <br /> letters to DLA on 12 March 2009 and 4 March 2009. The State concluded that the pumping <br /> tests present evidence to the contrary. DLA prepared Response-to-Comments documents <br /> and submitted them to the State on 18 June 2009. DLA rejected the State's conclusion and <br /> submitted a Draft Final FS on 10 June 2009. <br /> The State cannot accept the Feasibility Study in its current form due to technical differences <br /> with the remedial alternative presented for the pump and treat remedy. The State would like <br /> to meet with the stakeholders to come to a consensus for a pathway forward following the <br /> informal dispute resolution process. If necessary, the State will invoke the formal dispute <br /> process established in the DDJC Tracy site Federal Facility Agreement. However, the State <br /> requests that DLA agree to extend the deadline for filing such a dispute to allow adequate time <br /> for informal dispute resolution discussions to;$ake place. Within the Background section of <br /> this letter, the State presents summaries of'past dieldrin investigation and remedial response <br /> activities. Within the Remediation of the NWC Area section of this letter, the State presents <br /> a pathway forward regarding the duration and termination of the pump and treat remedy. <br /> California Environmental Protection A.-ency <br /> (3 Req sled Paper <br />