SITE INFORMATION AND CORRESPONDENCE_1988-1991

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ARAR Memorandum -2- 16 September 1991 DDRW, Sharpe Site receiving water quality. This Plan includes chemical and location specific ARARs. 4. Compilation of Water Quality Goals - This staff report contains numerical limits used to implement the narrative water quality objectives of the Water Quality Control Plans. The most pertinent narrative objective is that ground and surface waters shall not contain chemical constituents that adversely affect beneficial uses. Water quality goals are potential chemical and location specific ARARs. 5. Statement of Policy with respect to Maintaining High Quality of Waters in California, State Board Resolution No. 68-16 (Anti-degradation Policy) - This resolution requires the continued maintenance of high quality waters of the state even where the quality is greater than needed to protect all beneficial uses. This resolution has been incorporated into the Water Quality Control Plans and it is a chemical and location specific ARAR. 6. The Policy defining 'Sources of Drinking Water' , State Water Resources Control Board Resolution 88-63. This Policy states that, "All surface and ground waters of the state are considered to be suitable, or potentially suitable, for municipal or domestic water supply. . . ", with only a few specific exceptions. The policy is intended to clarify the applicability of this beneficial use designation in cases where the Water Quality Control Plans may not provide definitive designations. This resolution has been incorporated into the Water Quality Control Plans and it is a chemical and location specific ARAR. The recommended disposal alternative is still in the conceptual stage. Until we receive more information on specific disposal methods and on the quality of the treated ground water, we are unable to provide actual action or chemical specific numerical ARARs. The following more specific comments were developed after reviewing the Draft FS Report: 1. The Conclusions section, on page 1-114, state that nitrate will not be addressed in any remedial action objectives. All disposal alternative for treated ground water will have to consider nitrate. 2. Table 2.2-1 lists compounds which pose a threat to human health and the environment. These compounds as well as any other compounds including metals that exceed or could potentially exceed background or upgradient concentrations in the receiving water, as a result of the disposal of treated ground water, will have to comply with the State of California's Antidegradation Policy and the Basin Plan. 3. Section 2.2.4 describes Cleanup Objectives. a. Table 2.2-3 appears to reflect the appropriate numerical values with a few exceptions, including arsenic, toluene and benzene. Table 2.2-3 needs to be revised to reflect the numerical values from Tables 1 and 2 in the California Inland Surface Water Plan. The table should be expanded to include all Title 22 metals.