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PETE WILSON, Governor <br /> STATE OF CALIFORNIA +•'�� <br /> I CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION S, <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 361.5600 <br /> FAX: (916) 361-5686 <br /> 1. <br /> 21 March 1991 �J N x <br /> MAR 2 7 tin' <br /> ENVIRONMENTAL HEALTH <br /> Colonel James W. LaBounty PERMIT/SERVICES <br /> Defense Logistics Agency <br /> Defense Distribution Region West, Sharpe Site <br /> Lathrop, CA 95331 <br /> DRAFT FINAL REMEDIAL INVESTIGATION REPORT, DEFENSE DISTRIBUTION REGION WEST <br /> (DORN) , SHARPE SITE, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Final Remedial Investigation (RI) Report for the <br /> Sharpe Site. Enclosed is a memorandum of our comments on the draft final RI <br /> Report. The draft memorandum was faxed to Mr. Abel Haines and the U. S. Army <br /> Toxic and Hazardous Materials Agency (USATHAMA) on 4 March 1991 . <br /> We commend the DDRW, Sharpe Site on the extensive data base which has been <br /> developed on this site since the first Groundwater Assessment Report was <br /> submitted in August of 1987. We believe that significant work has been <br /> accomplished with respect to data collection. <br /> The RI should, however, not only result in data adequate in technical content <br /> to characterize the site, but should also support the development and <br /> evaluation of remedial alternatives during the Feasibility Study. As in the <br /> past, we continue to find that the data interpretation and presentation are <br /> inadequate to provide a sound technical basis for the development of effective <br /> cleanup strategies. More specifically, we find after our review of the RI <br /> Report that the hydrogeology of the site is not well understood nor is the <br /> technical rationale provided for the conclusions, in spite of the wealth of <br /> data available. We therefore, question the conceptual model which was <br /> developed to describe the hydrogeology at the Sharpe Site. The present level <br /> of understanding of. the hydrogeology and the support documentation may lead to <br /> the design and installation of an ineffective extraction system resulting in <br /> unnecessary delays in the cleanup of the aquifer and may increase project <br /> cost. <br /> We will discuss our concerns with your representatives at our next Technical <br /> Review Committee meeting on 27 March 1991 and attempt to resolve our concerns <br /> with the RI Report. In our preliminary conversations with Mr. Craig MacPhee <br /> of USATHAMA, he indicated that USATHAMA intends to use a three dimensional (3- <br /> D) model and that seasonal variations in the extraction system may be <br /> considered. These two issues are significant improvements over previous <br /> hydrogeologic analyses and may resolve many of our concerns. <br />