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4 - <br /> STATE OF CALIFORNIA _ PETE WILSON Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3463 ROUTIER ROAD. SUITE A4t, pd <br /> SACRAMENTO. CA 95827-3098 <br /> PHONE: (916) 361-5600 kti��I O 7 1992FAX. )916) 361 5666 I f L <br /> ENVIRONMENTAL l if-AILT;i <br /> PERM ff/S'Ei N1 GES <br /> 21 May 1992 <br /> Mr. Abel Haines <br /> Environmental Protection Office <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0250 <br /> DRAFT DECLARATION FOR THE RECORD OF DECISION (ROD) FOR THE GROUND WATER <br /> OPERABLE UNIT (OU) , DEFENSE DISTRIBUTION REGION WEST (DDRW) , SHARPE, SAN <br /> JOAQUIN COUNTY <br /> We have reviewed the Draft ROD for the Ground Water OU for DDRW, Sharpe <br /> submitted on 6 April 1992. We believe that Sharpe has placed considerable <br /> time and energy into the investigation of solvent contaminated ground water <br /> and that Sharpe has been pro-active in the remediation of the volatile organic <br /> constituent (VOC) contaminated ground water through the installation of the <br /> Interim Remedial Measures (IRMs) in the North and South Balloon Areas. We <br /> commend Sharpe on its efforts during the Remedial Investigation/Feasibility <br /> Study (RI/FS) and we agree with the proposed Remedial Action. <br /> However, this ROD for the Ground Water OU cannot be considered a comprehensive <br /> ground water ROD because the Remedial Action only addresses the known solvent <br /> plumes. The recent Draft Soils FS Report showed that ground water is also <br /> contaminated in certain areas with polychlorinated biphenyls (PCBs) and heavy <br /> metals. At a recent meeting, Sharpe agreed to address the additional ground <br /> water contamination in a subsequent site-wide ROD. <br /> The ROD for the Ground Water OU should distinguish between aquifer cleanup <br /> levels (the goal of the remedial action) and treatment standard. The cleanup <br /> level is the concentration at which the aquifer is to be restored whereas, the <br /> treatment level is the concentration in the effluent after treatment. We have <br /> previously expressed concern about inappropriate cleanup levels and did not <br /> concur with the Proposed Plan. <br /> We object to the proposed cleanup levels for xylene and bromacil . The ROD <br /> must be revised to include the cleanup levels of 20 micrograms per liter <br /> (µg/1 ) and 90 µg/l for Ilene and bromacil , respectively, or remove the <br /> cleanup levels for the petroleum based contaminants (benzene, toluene, xylene <br /> and ethylbenzene) and bromacil from the ROD. Cleanup of the ground water <br /> contamination with these constituents can be dealt with at a later date, <br /> outside of this OU ROD. If these constituents are to remain a part of this <br />