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amended in this addendum. Additional modifications to the interim investigation work plan will <br /> be discussed in future addenda, if required. <br /> 1.2 PURPOSE <br /> The purposes of this addendum are to address the DHS and RWQCB comments by <br /> clarifying the work plan text and to present modifications to the original work plan where <br /> necessary. Additional modifications to the work plan may be desirable as the interim site <br /> investigation progresses and new information becomes available. <br /> 2.0 CALIFORNIA DEPARTMENT OF HEALTH SERVICES COMMENTS <br /> The DHS made both general and specific comments about the final draft interim <br /> investigation work plan in its letter to the Navy dated November 8, 1990, Attachment 1. General <br /> comments pertain to the overall planning and management of the RI/FS process at NCS Stockton <br /> and are better discussed separately from this interim investigation work plan and addendum. The <br /> specific comments pertain to the technical approach of the interim investigation. These <br /> comments are addressed below by category. <br /> 2.1 GENERAL DHS COMMENTS <br /> 1) The primary concern regards the piecemeal manner in which the RI/FS has been conducted <br /> at NAVCOMM. Major investigations have been separated by periods exceeding several <br /> years. Continuance of this practice delays completion of the RI/FS and jeopardizes the <br /> continuity of data. <br /> In order to correct this concern, it is recommended that a Federal Facilities Agreement <br /> (FFA) be negotiated between the Department and NAVCOMM. The FFA would fall under <br /> the jurisdiction of the California Health and Safety Code Sections 25355.5, 25353, and <br /> 25347.6. The primary purpose of the FFA would be to establish a schedule to govern the <br /> RI/FS process. The schedule would prioritize RI/FS activities as well as set start and <br /> completion dates. Included in the FFA would be stipulated penalties for failure to perform <br /> scheduled activities. If negotiations can not be concluded in a timely manner, the FFA <br /> could be issued as a unilateral order. <br /> Discussion of the terms and conditions of a Federal Facilities Agreement (FFA) is beyond <br /> the scope of the interim investigation work plan. An FFA for NCS Stockton is better discussed <br /> between NCS-Stockton and state personnel. <br /> 3 <br />