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STATE OF CALIFORNIA PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION } <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 361-5600 <br /> FAX: (916) 361-5686 <br /> 20 December 1991 <br /> Mr. Abel Haines <br /> Chief, Environmental Protection Office <br /> Bldg. S-4, Sharpe Location <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0250 <br /> DRAFT PROPOSED PLAN, DEFENSE DISTRIBUTION REGION WEST (DORW) , SHARPE SITE, SAN <br /> JOAQUIN COUNTY <br /> We have reviewed the Draft Proposed Plan for the DDRW, Sharpe Site submi ted on <br /> 4 December 1991 by Environmental Science and Engineering. The Draft P oposed <br /> Plan evaluates and summarizes the five treatment alternatives presented in the <br /> Feasibility Study (FS) Report and states that air stripping is the pr ferred <br /> treatment alternative for ground water contaminated with volatile organic <br /> constituents (VOCs) . <br /> In Attachment 2 of the amended Federal Facilities Agreement, the submitta dates <br /> for the Draft Proposed Plan and the (Draft) Final FS Report are the sane. We <br /> have previously provided comments on the treatment and disposal alternat ves in <br /> our reviews of the Focused FS Report and the Draft Ground Water FS Report dated <br /> 13 March 1991 and 16 September 1991, respectively. We are in the process of <br /> reviewing the Draft Final FS Report. Upon completion of our review, our position <br /> on treatment and disposal will be made available for inclusion in the Proposed <br /> Plan. <br /> Our major concerns with the Draft Proposed Plan are discussed below. <br /> 1 . A number of disposal alternatives will be needed for the treated a fluent <br /> and therefore, the Remedial Action must include each disposal alternative <br /> to be used. Discussions on remediation have not adequately addressed <br /> disposal and a preferred alternative(s) for disposal was not present d. In <br /> addition, the disposal alternatives may determine whether or not the ground <br /> water must be treated for arsenic. This will in turn, affect the se ection <br /> of the remedial technology. We recommend that a separate section <br /> addressing the disposal alternatives be incorporated into the P oposed <br /> Plan. <br /> 2. The Proposed Plan must emphasize that the Record of Decision (ROD) will be <br /> for the final expansion of the North and South Balloon Area tr atment <br /> systems, in addition to the installation and implementation of the entral <br />