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David Wang, P.E. <br />Page 2 <br />ERM -West agreed with DHS's recommendations. The additional <br />recommendations are to be incorporated into the health and <br />safety plan and submitted to DHS. <br />Specific comments regarding the workplan addendum are <br />contained in section 2 of this review. In addition, the <br />review of the health and safety plan is supplied as an <br />attachment. <br />2) Specifications of the workplan were not followed in the <br />field. DHS scheduled an inspection of Site 5 field work for <br />1 February 1989. During that inspection DHS staff observed <br />several discrepancies between field procedures and those <br />outlined in the workplan. These discrepancies were <br />communicated to NAVCOMM, WESDIV, and ERM -West personnel. <br />WESDIV requested that ERM -West follow procedures outlined in <br />the workplan. ERM -West was reluctant to change their <br />procedures at this point in the investigation. <br />DHS field staff concluded that the deviations from approved <br />procedures will have a minimal impact on the Site 5 <br />investigation. Our primary concern is that the changes in <br />specified procedures were not communicated to DHS. In order <br />to insure the continued validity of NAVCOMM's RI, field <br />procedures must be followed as specified in the workplan and <br />changes must be approved by DHS prior to adoption. <br />The specific deviations from the workplan will be described <br />in section 3. <br />RECOMMENDATIONS <br />With respect to Site 5, the problems resulting from poor <br />coordination were mitigated by the staffs of DHS, NAVCOMM, and <br />WESDIV. Due to time constraints, problems were resolved <br />verbally. As NAVCOMM's RI becomes more complex, relying on <br />verbal communication to manage the project will become a less <br />useful technique. <br />We therefore offer the following recommendations to improve the <br />management of NAVCOMM's RI: <br />1) To improve the coordination between the regulatory <br />agencies and the Navy, DHS recommends that a technical <br />review committee (TRC) be formed. Members of the TRC should <br />include representatives of the responsible regulatory <br />agencies, NAVCOMM, WESDIV, and the contractor for the next <br />phase of the RI. <br />