SITE INFORMATION AND CORRESPONDENCE

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David Wang Page 2 September 16, 1988 GENERAL COMMENTS The Kleinfelder report provides the regulatory agencies (DHS, RWQCB, EPA, and San Joaquin County) with the first scientific evaluation of Rough and Ready Islands subsurface characteristics. Although the data accumulated is quite extensive, DHS Staff is concerned over the time lag between the NEESA study and the production of this report. For better utilization of investigative results, the time lag between phases of work should be shortened. Schedules and timetables for the next phase of work should be provided to the regulatory agencies for review within thirty days of the receipt of these comments. Kleinfelder developed a list of recommendations based on their analysis of the data. Staff finds these recommendations too general for the development of the next phase of work. WESDIV and it's contractor should screen Klienfelder's recommendations and produce a set of specific objectives for the investigation. It is important to involve the regulatory agencies early in the development work proposals, for this investigation and any subsequent work. Early and constant involvement will reduce the possibility of additional required work near the end of the investigation. To aid in the achievement of a cooperative working atmosphere, DHS staff has discussed with WESDIV the possibility of a joint technical meeting. The meeting should include all the regulatory agencies, NAVCOM and WESDIV personnel, and representatives of the Mark Group. This meeting should take place as soon as possible, preferably within the next thirty days. Kleinfelder concentrated their investigation on the four source areas described earlier. While these four areas are major sources contributing to the contamination on Rough and Ready Island, NAVCOM should not preclude the investigation of other possible source areas. Candidates for investigation include other industrial operations on Rough and Ready Island and underground tanks. Information from the San Joaquin County oversight of underground tank removals should be incorporated into the RI/FS data base. The investigation emphasized the shallow aquifers, which are subject to influences of the islands drainage system and the San Joaquin River. Little data was gathered on how deep contamination has penetrated. A major aspect for the upcoming phase of the investigation will be to determine to what extent the contamination has migrated. Whether contamination is limited to the shallow aquifers and subject to local influences or has migrated into deeper aquifers will be a controlling factor in designing a remediation system.