SITE INFORMATION AND CORRESPONDENCE_1993-2003

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*MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 255-3000 Sacramento, CA 95827-3098 CALNET: 8-494-3000 TO: Antonia K. J. Vorster A *01 FROM: James Taylor Senior WRC Engineer Assooci/atee Engineering Geo gist DATE: 14 September 1993 SIGNATURE: SUBJECT: DRAFT SOILS FEASIBILITY STUDY REPORT AND SOILS RISK ASSESSMENT REPORT, DEFENSE DISTRIBUTION REGION WEST (DDRW), SHARPE, SAN JOAQUIN COUNTY I have reviewed the Draft Soils Feasibility Study Report (FS) submitted on 1 July 1993. The Draft Soils FS and RA were prepared by Environmental Science and Engineering (ESE) for the U. S. Army Environmental Center (AEC). We defer the review of the Soils Risk Assessment (RA) Report to the Department of Toxic Substances Control (DTSC). The history of the activities leading to the development of this Soils FS/RA is complex and difficult to follow. The Soils FS/RA was developed to comprehensively address soil and groundwater contamination not addressed in the separate Operable Unit No. 1 (OU-1) Record of Decision (January 1993), which specifically deals with solvent contamination of the groundwater. The Underground Storage Tank (UST) Program separately and independently addresses soil and groundwater contamination at fuel USTs located at DDRW, Sharpe. The activities associated with the separate OU-1 Remedial Actions and the UST Program are concurrently underway. 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. Due to the magnitude and scope of the many comments provided for the above referenced documents, a complete reiteration of all unaddressed comments is not provided in this review, rather reference is made to previous comment letters. DDRW, Sharpe should reevaluate all referenced comments for the above referenced documents to assure that all of the Boards concerns are adequately addressed. I have several major concerns with the Draft Soils FS Report which are summarized below. Specific comments of this Report are summarized after the discussion on the major concerns.