SITE INFORMATION AND CORRESPONDENCE_1993-2003

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Draft Soils FS Memorandum -5- 14 September 1993 DDRW, Sharpe 2. Solid Waste Management Units (SWMUs): At the request of the agencies, a table (Volume 1I, Appendix G) was prepared to summarize the solid waste management units (SWMUs), potential SWMUs (PSs), and areas of concern (ADCs) identified in the Remedial Investigation (RI) Sampling Plan (June 1989) and the RI Report (November 1990). This table provides, for the first time, a comprehensive listing of the identified sites. This data base attempts to summarize the location, critical activities, potential contaminants, previous investigations, and results at each site. It has been difficult to impossible to find information on each of these sites; it is scattered over various documents, not reported or reported unrelated to a particular site, which is impossible to locate, unless you happen to know about it. During the RI activities at DDRW, Sharpe, 38 SWMUs, 14 PSs, and 75 AOCs were identified for a total of 127 sites. Some of the sites were given two designations. Out of the 127 sites, 71 sites were sampled, and the remaining 56 sites were not recommended for sampling in the RI Sampling Plan. Only 31 of the 71 sampled sites were discussed in the RI Report. The RI Report did not discuss 40 of the 71 sites for which sampling was proposed. The RI Report states that soil and/or groundwater contamination exists at only 17 sites. The Draft Soils FS (both February 1992 and June 1993) addresses the 17 sites with contamination, however, it does not document the existence or status of the additional 110 sites. The Board commented on inadequate data to support findings of the 17 sites evaluated in the Draft Soils FS in our July 1992 comments. It should be emphasized that the Board does not wish to have Sharpe reinvestigate all of the NFA sites, or hinder the progress being made on the remediation of known contaminant source areas. The Board is concerned potential that unidentified source areas may exist that could continue to degrade ground water quality and prolong the remedial actions that are proposed or underway for cleanup of the groundwater. Source control is rudimentary to any meaningful ground water cleanup action. The RI documents provide little information on many sites that may have the potential to be sources of contamination due to past activities. The Board has agreed to provide by 29 October 1993, a listing of the sites for which we have continuing concern. Once a site has been listed in the Installation Restoration Plan (IRP) or as part of the Remedial Investigation, then the final decision regarding sites slated for no further action (NFA sites) must be documented and approved by the regulatory agencies. To date, no such accounting for these 110 sites has been provided since the RI Work Plan listed them. My review of the information available on the NFA sites indicates that faulty logic may have been used for recommending no further action. The most frequently cited reasons for no further action presented in the RI Sampling plan were: 1. Site has paved surface. 2. No record of waste releases reported. 3. Soil gas investigations did not reveal any elevated levels of VOCs in the soil gas for several hundred feet downgradient of the site. 4. Soil borings with soil sampling did not confirm elevated soil gas readings.