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Mr. Maurice Benson August 20, 2009 Page 5 ecological receptors. DTSC cannot concur with the determination of NFA when in reality implementing LUCs constitute a remedial action. The ROD Amendment should clarify the difference between the IC remedy and NFA in terms of additional remedial actions required for one versus the other. DTSC cannot concur with a no further remedial action planned determination for soil sites P-1 G, P-1 E, and P-8A for reasons cited below. Currently innovative technologies are in operation in the south balloon, central area and north balloon to remediate the persistent VOC sources related to P-5A and these above- mentioned sites. In particular, DTSC cannot support a NFA determination for Sites P-1 G/P-1 E when active in-situ technologies are ongoing and uncertainties still remain on the levels of contaminants that currently exist in both saturated (C-zone) and unsaturated soil, especially after the completion of the innovative technology. DTSC will reserve its approval of the NFA determination for these sites until the technologies are completed and confirmation sampling in the vicinity of former USTs adjacent to Building 649 collaborated with the Department to address the data gaps and discrepancies presented in the CPT report. Finally, DTSC cannot support a NFA determination for Site P-8A until the in-situ technology is completed in the North Balloon and subsequent monitoring and confirmation data from both unsaturated/saturated soil and groundwater demonstrate that the cleanup objectives have been achieved and no-further source remains in the saturated or unsatured vadose zone. If you have any questions or concerns with the comment letter, please contact me at: (916) 255-3713 or e-mail at: pmacnichCcDdtsc.ca oov Sincer Peter MacNichooll, P.E. Remedial Project Manager Sacramento Office Brownsfield and San Joaquin Cleanup Program cc: See next page.