SITE INFORMATION AND CORRESPONDENCE

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NAVCOMSTA 2 19 August 1992 Shell Facility in which Shell has already agreed to investigate off-site in the direction of the Naval facility. Investigation in this area would be a duplication of effort, (2) sampling methodologies must be specified according to EPA SW 846, (3) soil and ground water samples in the clothing landfill area need to be analyzed for a gamma isotopic scan, gross alpha, and gross beta particles by a State Certified, EPA Approved laboratory, and (4) monitoring wells denoted as WB-1, WB-2, and WB-3 "destroyed" should be located and abandoned properly per San Joaquin County ordinances and State Department of Water Resources Bulletin 74-81 . We request that Navcom within 30 days submit an addendum to the Sampling and Analyses Plan proposing cleanup of hot spot contamination in the drainage ditches, sampling and analysis of surface water discharging into Burns Cutoff, additional monitoring wells in the Agricultural and Warehouse Areas, and a description of specific locations for the CPT soundings. A time schedule for completion of this additional work should also be included. In addition to the Sampling and Analyses Plan addendum submittal of a long term schedule for work including further source identification and proposed removal and remedial actions must also be presented. Navcom has proposed that all soil and ground water samples be analyzed for priority pollutants and ground water analyses for priority pollutants to continue for a minimum of two consecutive quarters in all existing, and newly installed monitoring wells. After two quarters of analysis, constituents of concern should therefore be evaluated at lower detection limits. Quarterly monitoring reports are to be submitted by the 15th day of the first quarter month (i .e. January, April , July, and October) . Quarterly reports are to include; the status of the investigation and cleanup activities including results (tabulated) of all investigations implemented to date, the proposed continuing or next phase of investigation, a site map showing contours of contamination and gradient measurements over the last quarter, and time schedules for the completion of the investigation of the site and remediation. All results of the Sampling and Analyses Plan are to be submitted in a Technical Report to the Department of Toxic Substance Control and this office by 1 February 1993. This Report must include data presentation and evaluation, summary tables and graphics to support the field investigation, recommendations for additional work to define plume boundaries, assess off- site migration of contaminants, and evaluate background water quality. We appreciate the opportunity to review and comment on your proposed work prior to implementation. We believe that this kind of participation will result in a better quality investigation and ultimately, a more acceptable final remediation. We look forward to a good working relationship directed to rd a s ccess/fuI cleanup at the Naval Communications Station. CORI Associate Engineering Geologist cc: Mr. James McKevitt, U.S. Fish and Wildlife Service Mr. Jim Pinasco, Department of Toxic Substance Control Ms. Diane Hinson, San Joaquin County Department of Environmental Health Mr. Phillip Isorena, Central Valley Regional Water Quality Control Board Mr. Greg Reller, PRC Environmental , Rancho Cordova