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Al Jesena - 6 - 1 March 2000 Draft RI for OU#3 NCTS, Stockton The presumptive remedy of capping is more complex than the Navy projects in the report. In order for the Navy to be in compliance with Title 27 for closure of landfills, they should apply the engineered alternative option for containing the waste, capping the trenches for closure. providing leachate management, and alternatives for groundwater remediation. Without knowing the contents of the trenches, the State would consider requiring Class I (i.e., hazardous waste) containment. The Navy continues to avoid the issue of waste characterization as shown in SAP correspondence/ documents and in this RI for the landfill sites. Without knowing the nature of the waste during the remedial investigation, there continues to be a major data gap in determining feasible cleanup options. VOLUME III Appendix B. Remedial Investigation Management Approaches RI Management Approach for Groundwater 1. Section B.2.2.2. Please see the attached list of State Requirements for soil and groundwater in response to the Navy's comments regarding ARARs. 2. The Navy states that, "Containment of groundwater contamination is a presumptive remedy for landfills and will be the probable remedial alternative for the groundwater sites contaminated by landfills." The purpose of the RI is to gather pertinent data in support of all potential remedies. There remain data gaps in defining the nature and extent of groundwater contamination at this point in the process (i.e., Aquifer 4). The Navy should revise the RI to include all potential feasible alternatives as "best available technology"(BAT) for active cleanup rather than the strictly passive alternative selection of containment. 3. Potential treatment technologies on page B-20 appears to be incomplete. Please insert the missing information in the revised draft RI report. RI Management Approach for the Drainage System 1. Drainage System Remedy— We agree that "emplacing sediment traps at the downstream end of the upper reach of the drainage system" is appropriate. The FS should show that maintenance responsibilities should remain with the Navy. Sampling, analysis, characterization, and disposal/treatment of sediment must also be the responsibility of the Navy until all upstream IR sites are considered no longer a threat to water quality,human health or other environmental factors. 2. Even though pesticides were legally applied in the past, it does not relieve the Navy from cleaning up known detrimental substances to the environment. We do not believe that DDT, or any other pesticide, is a naturally occurring substance as applied to Section 104 (a)(3) of CERCLA which states: