SITE INFORMATION AND CORRESPONDENCE_1993-2003

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STATE OF CALIFORNIA - Environmental Protection 0 PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION EWRTASENTA}L HEALTH aa'� 3443 Routier Road, Suite A �Fj+i:IIT C ,7\1�1 L p Sacramento, CA 95827-3098 C F PHONE: (916) 25-3000 DOD FAX: (916)5255-3052 93 SEP 20 PM 2142 14 September 1993 Mr. Abel Haines Environmental Protection Office Bldg. S-108, Sharpe Site Defense Distribution Region West P. O. Box 960001 Stockton, CA 95296-0710 DRAFT SOILS FEASIBILITY STUDY REPORT (FS) AND SOILS RISK ASSESSMENT REPORT (RA), DEFENSE DISTRIBUTION REGION WEST (DDRW), SIIARPE, SAN JOAQUIN COUNTY We have reviewed the Draft Soils FS Report submitted on 1 July 1993. We defer the review of the Soils RA Report to the Department of Toxic Substances Control (DTSC). Overall, we believe that there has been an inadequate investigation of the majority of the solid waste management units (SMWUs) and nonfuel underground storage tanks (USTs). There is generally inadequate information and/or presentation of existing data in the Draft Soils FS Report to determine if there has been a release of contamination from the SMWUs that could pose a threat to human health and the environment, including water quality. The Draft Soil FS Report does not consider all of the contamination at the site and therefore, does not recommend appropriate remedial actions. Resolution of these complex issues must be discussed at Remedial Project Manager's (RPM) meeting scheduled for 21 September 1993. Our major concerns are summarized below and are discussed in detail, along with other specific comments, in the enclosed memorandum. 1. The Board's comments on the February 1992 Draft Soils FS Report which have not been adequately addressed in this version of the Draft Soils FS Report. 2. The Draft Soils FS Report addresses only 17 sites with soil and/or ground water contamination, however, it does not address an additional 110 sites for which no further action (NFA) is recommended. 3. The Draft Soils FS Report does not adequately show that landfills and burn pits are in compliance with State Applicable or Relevant and Appropriate Requirements (ARARs), particularly Division 3, Chapter 15 of Title 23 of the California Code of Regulations. In addition, there are two additional issues which the Draft Soils FS Report does not address: 1. The impact of the dry wells along the western boundary of the site with respect to arsenic and bromacil ground water contamination.