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STATE OF CALIFORNIA-Environmental Protect0gency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3098 » <br /> PHONE: (916)255.4000 <br /> DOD FAX (916)255-3052 R E C E I VE" D <br /> 12 March 1993 MAR 1 7 1993 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Abel Haines <br /> Environmental Protection Office <br /> Bldg. S-108, Sharpe Site <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, C,4 95296-0710 <br /> RESPONSE TO REGULATORY AGENCIES' COMMENTS ON MODELING REPORT, DEFENSE DISTRIBUTION <br /> REGION WEST (DDRW) , SHARPE, SAN JOAQUIN COUNTY <br /> We have reviewed the Response to Regulatory Agencies' Comments on the Modeling <br /> Report submitted on 12 February 1993 for DDRW, Sharpe. The responses to our <br /> 14 December 1992 comments on the Three-Dimensional (3-D) Modeling Report are <br /> adequate. <br /> However, we are concerned that DDRW, Sharpe has misinterpreted our concerns <br /> regarding use of the 3-D model versus an evaluation of the system using field data. <br /> We believe that the 3-D model has proved to be a useful tool for the design of the <br /> ground water remedial action at DDRW, Sharpe. But, as with any model , it does not <br /> substitute for an evaluation of the remedial action using field derived data. We <br /> believe that the quarterly/annual ground water monitoring program will continue to <br /> serve as the vehicle for this evaluation. <br /> We continue to maintain that there appears to be data gaps for the purposes of <br /> monitoring, regardless of whether or not the remedial action has been implemented. <br /> In addition, we continue to believe that additional extraction wells may be needed <br /> in the future, if it is determined that complete hydraulic capture of the plumes to <br /> the aquifer cleanup levels has not been achieved, as is currently apparent with the <br /> existing Interim Remedial Measures (IRMs) . Future evaluations for the adequacy of <br /> the system, conducted through the annual reports and the five year review process, <br /> must be based on field derived data presented in quarterly/annual monitoring <br /> reports, not on current model predictions. <br /> If you have any questions, please call me at (916)255-3069 or Mr. James Taylor at <br /> (916)255-3065. <br /> CAMILLA WILLIAMS <br /> Engineering Geologist <br /> CKW:cw <br />