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California Regional Water Quality Control Board Central Valley Region : ' Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 30 May 2001 John A. Corpos Naval Facilities Engineering Command, West 900 Commodore Drive San Bruno, CA 94066-2402 DRAFT FIELD SAMPLINGIQUALITYASSURANCE PROJECT PLAN FOR LEACHABLE LEAD AT THE PISTOL RANGE, NAVAL COMPUTER AND TELECOMMUNICATIONS STATION, SAN DIEGO DETACHMENT, STOCKTON We have reviewed the Draft Field Sampling/Quality Assurance Project Plan for Leachable Lead at the Pistol Range, (FSP) dated 27 April 2001. The purpose of the investigation outlined in the FSP is to obtain the data necessary to perform a water quality assessment to determine if lead present at the Pistol Range and the Habitat Area due to site activities is leachable to the extent that it might pose a threat to groundwater quality. The FSP proposes sample collection and chemical and physical properties analyses methods, and also proposes data evaluation method. We have one significant comment on the FSP that pertains to the proposed data evaluation method to be used for the water Section 1.2.2, pages 7 through 10. We do not concur that the-two-phase approach to the water quality assessment is appropriate. Specifically, we do not agree with the proposal for the first phase, which evaluates the site as a whole by comparing the mean of the entire 72 sample data set to the background concentrations in groundwater(if available at that time) or the appropriate water quality objective. Using the mean of the entire data set has the potential to underestimate the threats to water quality from localized"hotspots", which the initial total lead concentration data indicate are present at the site. Also, although the FSP indicates that the water quality assessment will be performed in accordance with the Regional Board's draft 1992 technical report methodology, this method differs from the draft methodology. Another way of looking at this is that the water quality assessment is designed to identify those areas of the site that contain designated waste classified in accordance with the Water Code that presents a threat to water quality. In the same manner that it is inappropriate to identify localized areas of hazardous waste at a site by averaging the data from across the whole site, it is inappropriate to identify localized areas of designated waste at a site by averaging data from across the whole site, especially when simple visual examination of the data should be sufficient to indicate whether or not localized areas of relatively higher concentrations exist at the site. Therefore, the proposed phase one of the water quality assessment should be deleted. Instead, the statistical comparisons should be conducted for each of the eight water quality assessment areas individually (currently described as phase two) as outlined in the FSP. The t-test, calculated using the California Environmental Protection Agency �a Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5