SITE INFORMATION AND CORRESPONDENCE

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The regulations pertaining to disposal are not considered ARARs for this action because a stricter state regulation is being complied with (Title 22 of the California Code of Regulations Division 4.5 Chapters 14 and 15). Thus, the subject regulations are not ARARs for this action. The Navy is not discharging to soil or water as part of this action. Further, the Navy will propose no further action only if the data indicate that a release has not occurred or if no additional contaminants present pose a threat to human health, the environment, or water quality. If these conditions are met, the listed regulations are not ARARs. It is currently the Navy's understanding that if soil poses no threat to water quality, the soil is not regulated by the RWQCB. The Navy also understands that the determination regarding a threat to water quality is made by performing a water quality assessment. The Navy is planning to conduct waste extraction test (WET) testing to support a water quality assessment and enable this determination. If this is not correct, then the Navy requests that the RWQCB provide the Navy with the substantive steps needed to document that a threat to water quality is not present. Comment 3: Page 3-10, Removal Action Objective, Site SA At Site 5A, the EE/CA proposes to sample the soil and ground water (if encountered) beneath the center of the sump for VOCs, SVOCs, pesticides/PCBs, and metals. If the sample results show concentrations below levels of concern, the Navy will propose no fitrther action after sump closure. The EE/CA describes the Site SA as being composed of the sump in Building 8168, the former 4-inch drain line, and the swale into which the former drain line discharged. As stated in Item I above, the extent of soil and ground water contamination in the swale has not been folly characterized. Furthermore, a water quality assessment, which will determine if the soils beneath the drain line pose a threat to ►vater, has not been completed. Therefore, Site 5A cannot be closed until soil and ground water contamination beneath the drain line and in the sivale has been cleaned up. Response: It is the Navy's intent to document no further action for the sump and beneath the former drainline if no contaminants above levels of concern are detected in soils. No further action will not be proposed at the swale, or for groundwater at this time. Future actions (if necessary) will be taken to address remaining soil or groundwater contamination beneath the drainline and at the swale. The text has been made more specific. EECARESP.STA:044-5}:1REREI:11/15/95 1I:M.n 4