Laserfiche WebLink
4 <br /> STATE OF CALIFORNIA PETE WILSON. Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— %0%mm <br /> CENTRAL VALLEY REGION Al <br /> q ) <br /> 3443 ROUTIER ROAD, SUITE A ( <br /> SACRAMENTO, CA 95827-3098 FW <br /> PHONE'. (916) 361-5600 <br /> FAX: (916) 361-5686 SEP 2 0 1^1 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> 16 September 1991 <br /> Mr. Abel Haines <br /> Director, Environmental Protection Office <br /> Defense Distribution Region West, Sharpe Site <br /> Lathrop, CA 95331 <br /> DRAFT GROUND WATER FEASIBILITY STUDY REPORT, DEFENSE DISTRIBUTION REGION WEST <br /> (DDRW), SHARPE SITE, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Ground Water Feasibility Study (FS) Report for the <br /> DDRW, Sharpe Site (Sharpe) . The Report was submitted on 18 June 1991 by the <br /> U. S. Army Toxic and Hazardous Materials Agency (USATHAMA) and was prepared by <br /> Environmental Science and Engineering (ESE) . The Report was prepared as a site- <br /> wide FS. We have enclosed two memoranda on the FS Report: one on our technical <br /> concerns and the other on Applicable or Relevant and Appropriate Requirements <br /> (ARARs) for the Regional Board. <br /> With respect to our major technical issues, we are primarily concerned that the <br /> North and South Balloon extraction systems have not yet demonstrated that there <br /> is complete plume capture. The existing in-place systems must be reevaluated and <br /> revised to demonstrate that there is complete plume capture. In addition, we are <br /> concerned with the approach taken for the design of the extraction wells and <br /> field for the Central Area. We have previously written regarding our concerns <br /> with the Central Area extraction system in our letter dated 13 March 1991 . The <br /> Draft FS Report did not adequately address our concerns. Finally, we are opposed <br /> to the installation of extraction wells near MW-505A, MW-407C and MW-524C. The <br /> installation and operation of these extraction wells in uncontaminated areas will <br /> only exacerbate the extent of the volatile organic constituent (VOC) plumes. <br /> We are also concerned that the extent of the different plumes at the site have <br /> not been completely defined. The lack of plume definition was one of our <br /> outstanding concerns in the Remedial Investigation. Sharpe needs to submit a <br /> time schedule and plan for the installation of additional monitor wells. <br /> As discussed in the Draft FS Report and in the August 1991 Project Manager's <br /> Meeting, disposal of the treated ground water will be a critical factor in the <br /> design of the final remedial action for ground water. The Board commends Sharpe <br /> on the existing reuse of treated ground water and encourages Sharpe to further <br /> consider other recycle/reuse disposal options. However, the impacts of the <br /> disposal to land of treated VOC contaminated ground water, which has any elevated <br /> concentrations (above background) of inorganics, must be considered in the <br /> selection of the final remedial action. We believe that inorganics, such as <br />