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' STATE OF CALIFORNIA- Environmental Prot Agency PETE WILSON Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Rootier Road, Site A tah(I; ,flb,-Sacrad ( HFAI Tit <br /> PHONE(916 ) 255nto, CA 5098 3000 Pt.,VJT ``,n- HFAI <br /> DOD FAX: (916) 255-3052 93 NOV — 4` <br /> 3 Pt1 2: 20 <br /> 29 October 1993 <br /> Mr. Wesley J. Harris <br /> Environmental Protection Office <br /> Bldg. S-108, Sharpe Site <br /> Defense Distribution Region West <br /> P. O. Box 960001 <br /> Stockton, CA 95296-0710 <br /> DRAFT SOILS FEASIBILITY STUDY REPORT (FS), NO FURTHER ACTION SITES, <br /> DEFENSE DISTRIBUTION REGION WEST (DDRW), SHARPE, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Soils FS Report (June 1993) and submitted comments on 14 September <br /> 1993. Concerns regarding solid waste management units (SWMUs) and nonfuel underground <br /> storage tanks (USTs) were provided in our comments of the Draft Soils FS Report. The Board has <br /> agreed to provide a list of sites for which we have continuing concerns. We want to emphasize that <br /> the Board does not wish to have Sharpe reinvestigate all of the NFA sites, or hinder the progress <br /> being made on the remediation of known contaminant source areas. The Board is concerned that <br /> releases may have occurred from unidentified source areas at SWMUs and nonfuel USTs that could <br /> continue to degrade ground water quality and prolong the ground water remedial actions that are <br /> proposed or underway. Due to the large number of sites and issues involved, the Sharpe Remedial <br /> Project Managers (RPMs) have agreed to meet on 9 and 10 November 1993 to start resolution of the <br /> concerns regarding the SWMUs and nonfuel USTs. <br /> The Draft Soils FS Report addresses 17 sites with soil and/or ground water contamination, which we <br /> commented on in our September 14, 1993 letter. However, the Report does not address an <br /> additional 110 sites for which no further action (NFA) is recommended. Only a few of the_ 17 sites <br /> have been proposed for remediation and the rest is recommended for no further action. At the 21 <br /> September 1993 RPM meeting, agreement was reached that the final disposition of the NFA sites <br /> has not been adequately documented. Available information is not presented or is inadequate to <br /> support NFA decisions in the previous reports and in the Draft Soils FS Report. It was agreed that <br /> it is premature to proceed with a Site-Wide Comprehensive Record of Decision (ROD). An <br /> Operable Unit (OU) ROD will be prepared for the currently proposed actions so that remediation <br /> can proceed on selected sites. The Board fully supports expediting the proposed cleanup of the <br /> contaminated soils. <br /> Additional documentation addressing the 110 NFA sites must be prepared. Preparation of NFA <br /> documentation should not interfere with the progress being made on the contaminated sites <br /> previously identified for remediation. A separate time schedule may have to be developed for the <br /> remaining sites to meet the regulatory agency's concerns. <br /> kt/— <br />