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i <br /> Soils FS Work Plan Addendum -2- 21 September 1992 <br /> DDRW, Sharpe <br /> was inadequate justification to support these levels and because the potential <br /> leachability of these contaminants was not considered. <br /> 4. We believe that in-situ soils gas data are needed to assess the extent of VOC <br /> contamination in the unsaturated zone, to design the vapor extraction system <br /> (UES) and to evaluate the efficiency of the UES. <br /> 5. We are opposed to the concept that air stripping is the appropriate treatment <br /> technology for the remediation of PCBs and heavy metals in ground water. <br /> Specific remedial technologies for these consitiuents must be considered for <br /> the site-wide FS. <br /> We believe that Sharpe will need to present a spread sheet summarizing all of the <br /> non-fuel USTs and WMUs, the respective analytical findings and the background <br /> concentrations in soil and ground water for inorganic contaminants. This <br /> information is needed as a comprehensive summary for all of the contaminated soil <br /> sites and to help track the appropriate soil and ground water remedial actions for <br /> each respective UST or WMU. We continue to request that this information be <br /> submitted in a manner similar to what Sharpe prepared for the fuel USTs. <br /> We concur with the Environmental Protection Agency (EPA) and the Department of <br /> Toxic Substances Control (DTSC) that the field work for this Work Plan Addendum <br /> may proceed. However, we believe that an additional work plan must be presented <br /> to address the non-fuel USTs and WMUs that appear to be inadequately investigated. <br /> We are willing to further discuss what we believe is necessary to complete the <br /> soils and associated ground water investigations for non-fuel USTs and the WMUs at <br /> the next Project Manager's Meeting. <br /> If you have any questions, please call me at (916)361-5670. <br /> CAMILLA WILLIAMS <br /> Engineering Geologist <br /> CKW:cw <br /> Enclosure <br /> cc: Mr. Craig MacPhee, U. S. Army Toxic and Hazardous Materials Agency, Aberdeen <br /> Proving Ground, Maryland <br /> Mr. Steve Light, U. S. Army Corps of Engineers, Huntsville, Alabama <br /> Mr. Richard Seraydarian, U. S. Environmental Protection Agency, Region IX, <br /> San Francisco <br /> Ms. Tracie Billington, Department of Toxic Substances Control , Region 1, <br /> Sacramento <br /> Mr. Fred Kaufman, Public Health Services of San Joaquin County, Environmental <br /> Health Department, Stockton <br />