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Draft Soils FS Memorandum -2- 14 September 1993 <br /> DDRW, Sharpe <br /> MAJOR CONCERNS <br /> 1. Responses To Agency Comments On Soils FS, July 1992 - CVRWQCB Comments On <br /> Draft Soils Feasibility Study (FS) Report: We have reviewed the Response To Agency <br /> Comments on the Draft Soils FS Report, July 1992 which we found inadequate to meet most <br /> of the Board's concerns. There are several outstanding issues which have still not been <br /> adequately addressed in the June 1993 version of the Draft Soils FS. Board comments on the <br /> February 1992 Draft Soils FS have been grouped together and are used as a starting point for <br /> the current comments: <br /> Ia. Comments 1 and 2 of our July 1992 comment letter refer to the WMUs and USTs at DDRW, <br /> Sharpe. Additional work has been done to address some of the issues that were raised by the <br /> Board, specifically, Volume II, Section 2 of the June 1993 Draft Soils FS titled USTs <br /> (Nonfuel). This section states that nonfuel USTs will be addressed under the Comprehensive <br /> Environmental Response, Compensation, and Liability Act (CERCLA) and the Superfund <br /> Amendments and Reauthorization Act of 1986 (SARA). Preexisting data regarding the status <br /> of nonfuel USTs were summarized in an appendix to the February 1992 Draft Soils FS <br /> [Appendix A - Problem Assessment Report for Underground Storage Tanks (PAR)]. This <br /> section states that none of the nonfuel USTs were investigated completely prior to the issuance <br /> of that report, and some have not been investigated at all. DDRW, Sharpe removed 39 fuel <br /> and nonfuel USTs in 1990 and several others prior to 1990. As part of the Draft Soils FS <br /> investigation, Environmental Science and Engineering (ESE) performed soil borings, and <br /> installed monitor wells at several UST sites in 1991. Additional studies during 1990 by <br /> Petrotek. Inc. and Kleinfelder & Associates in 1986 produced data at or adjacent to some of <br /> the nonfuel UST sites. Monitor wells installed as part of the overall RI/FS study yielded data <br /> which can be used to assess the potential environmental impact from some of the nonfuel <br /> USTs. <br /> The PAR discusses the fuel and the nonfuel USTs together. The June 1993 Draft Soils FS <br /> only addresses the additional work conducted at USTs 35, 48, and 27. The February 1993 <br /> Draft Soils FS fails to specifically identify and address all of the nonfuel USTs. The FS must <br /> account for all of the nonfuel USTs and show that they meet the requirements of CERCLA <br /> which require compliance with State Applicable or Relevant and Appropriate Requirements <br /> (ARARs). In its current form the Draft Soils FS does not adequately address the nonfuel <br /> USTs. <br /> Comment 2 refers to two solvent waste tanks, one pesticide waste tank and eight tanks of <br /> waste oils. The data that is scattered throughout the reports referenced above must be <br /> summarized in an orderly fashion and evaluated in the FS. The FS must demonstrate that the <br /> investigation and removal actions at nonfuel USTs meet the requirements of CERCLA and <br /> State ARARs. In addition, the Response to Comment 2 states that additional work is proposed <br /> at USTs 27, 49, and 55. The Draft Soils FS discusses additional work at UST 27, but does <br /> not discuss USTs 49 and 55. This discrepancy must be clarified. Table 1-2 in the PAR <br /> describes UST 35 as containing contaminated fuel. It is not clear if the other USTs which <br />