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 �V I FROM: Camilla Williams Senior WRC Engineer Engineering Geologist DATE: 22 December 1992 SIGNATURE: SUBJECT: REVIEW OF THE DRAFT FINAL RECORD OF DECISION (ROD), DEFENSE DISTRIBUTION REGION WEST (DDRW), SHARPE, SAN JOAQUIN COUNTY I have reviewed the Draft Final ROD for DDRW, Sharpe submitted on 23 November 1992. The Draft Final ROD was submitted by the U. S. Army Toxic and Hazardous Material Agency (USATHAMA) . Sharpe has made considerable progress in the Remedial Investigation/Feasibility (RI/FS) Study and in the overall cleanup of the site. Sharpe has conducted three-dimensional (3-D) modeling, has proposed effluent treatment standards based on best available technology (BAT) for the Central Area Treatment Plant and has accepted the State Water Resources Control Board Resolution No. 68-16 (Anti-Degradation Policy) as an Acceptable or Relevant and Appropriate Requirement (ARAR) . In addition, Sharpe has operated two Interim Remedial Measures (IRMs) in the North and South Balloon Areas which have been treating volatile organic constituent (VOC) contaminated ground water since 1987 and 1990, respectively. We commend Sharpe for these actions. However, I have two major concerns with the Draft Final ROD. First, the Substantive Waste Discharge Requirements (SWDRs) were not attached and were not referenced within the text of the Draft Final ROD. Second, the Draft Final ROD did not summarize the results of the 3-D numerical modeling and its affects on the conceptual plan for the RD. There appears to have been sufficient time for Sharpe/USATHAMA to make changes to the text of the Draft Final ROD regarding these issues. These major issues, as well as other comments, are discussed in more detail below. The draft of the SWDRs was attached to our 21 May 1992 letter on the Draft ROD. The SWDRs were negotiated during September and October 1992 with USATHAMA and the Corps of Engineers (COE) and on 6 November 1992, we transmitted the SWDRs to the Environmental Protection Agency (EPA) and the Department of Toxic Substances Control (DTSC) , as well as to USATHAMA and COE. The 12 November 1992 letter from the EPA stated that the Draft Final ROD should incorporate Table 8 (aquifer cleanup levels) and Table 9 (effluent treatment standards) , the SWDRs and a response to our 6 March 1992 letter on the Proposed Plan in the Responsiveness Summary. By letter dated 11 December 1992, we were notified by DDRW, Sharpe that there had been confusion in the preparation of the Draft Final ROD regarding the EPA's directives in their letter but that appropriate action was being taken to remedy the omission of the SWDRs from the Draft Final ROD. In addition, the 3-D Modeling Report was submitted on 14 October 1992, more than a month prior to submittal of the Draft Final ROD. The ROD must be revised to acknowledge the SWDRs and reflects actual knowledge about the RI/FS and conceptual plans for the Remedial Design/Remedial Action (RD/RA) . If the content of the revisions can be negotiated between Sharpe and the Board, then the ROD would become acceptable for signature by the Board.