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David Wang, P.E. , Chief <br /> Page 3 <br /> Novemher R, 1990 <br /> o Monitoring a network of forty new and existing wells <br /> for chemical parameters and water levels. <br /> o Surface water monitoring at five selected locations. <br /> o Perform slug and pump tests to establish the local <br /> hydraulic conductivities. <br /> GENERAL COMMENTS <br /> 1) The primary concern regards the piecemeal manner in which <br /> the RI/FS has been conducted at NAVCOMM. Major <br /> investigations have been separated by periods exceeding <br /> several years. Continuance of this practice delays <br /> completion of the RI/FS and jeopardizes the continuity of <br /> data. <br /> In order to correct this concern, it is recommended that <br /> a Federal Facilities Agreement (FFA) be negotiated <br /> between the Department and NAVCOMM. The FFA would fall <br /> under the jurisdiction of the California Health and <br /> Safety Code Sections 25355. 5, 25353 , and 25347 . 6. The <br /> primary purpose of the FFA would be to establish a <br /> schedule to govern the RI/FS process. The schedule would <br /> prioritize RI/FS activities as well as set start and <br /> completion dates. Included in the FFA would be <br /> stipulated penalties for failure to perform scheduled <br /> activities. If negotiations can not be concluded in a <br /> timely manner, the FFA could be issued as a unilateral <br /> order. <br /> 2) off-site sampling of existing private wells was a <br /> recommendation of the previous regulatory comments dated <br /> May 26, 1988 . It is not included as an activity under <br /> the Interim Workplan. Off-site sampling continues to be <br /> a recommendation by the Department. <br /> 3 ) The Interim Workplan proposes to limit water samples <br /> (surface and ground) to volatile organic compounds <br /> contained in EPA' s test Method 8240. Previous studies <br /> have detected compounds that are not part of Method 8240. <br /> Detected compounds include arsenic, selenium, various <br /> pesticides, chloride, sulfate, and petroleum products. <br /> It is recommended that the sampling parameters be <br /> expanded. <br /> Additional reasons for not limiting the sampling parameters <br /> are: <br />