Laserfiche WebLink
California Regional Water Quality Control Board ` <br /> Central Valley Region <br /> Winston H.Hickox Sacramento Main Office Gray Davis <br /> Secretaryfor Internet Address: http://www.swrcb.ca.gov/—rwgcb5 Governor <br /> Environmental 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Protection Phone(916)255-3000•FAX(916)255-3015 <br /> 12 September 2002 <br /> 9` a.�SZo <br /> Captain Kenneth Koop 1A �d , <br /> California Army National Guard <br /> 9800 Goethe Road <br /> Sacramento, CA 95826-9101 <br /> DRAFT WORK PLAN FOR PRELIMINARYASSESSMENT/SITE INVESTIGATION UPDATE, <br /> CALIFORNIA ARMY NATIONAL GUARD FACILITY, STOCKTON, CALIFORNIA <br /> Thank you for the opportunity to review the Draft Work Plan for Preliminary Assessment/Site <br /> Investigation Update (Work Plan) at the California Army National Guard Facility in Stockton, <br /> California received on 23 August 2002. Our comments on the Draft UST PAR are provided below. <br /> General Comments <br /> 1. The California Army National Guard (CARNG)has not responded to our comments dated 7 <br /> August 2000 on the PA/SI Report. It is important to maintain a written record of comments and <br /> responses on all project work plans/reports to properly document actions at the site. Therefore,we <br /> require a response in writing to our comments on the PA/SI Report and this Work Plan before we <br /> can fully concur with the actions proposed in this Work Plan. <br /> 2. Although our 7 August 2000 comment letter requested a recommendation for further investigation' <br /> in the PA/SI Report, the Work Plan does not address the area identified as potentially having <br /> buried tear-gas canisters. These items may pose a hazard to site workers or threaten groundwater <br /> quality, and this area potentially contains other buried munitions or hazardous waste. CARNG <br /> needs to provide strong rationale for why this area needs no further investigation, or revise the <br /> Work Plan to include investigation of it. <br /> 3. The Health and Safety Plan (HASP) in Appendix A does not address the proposed excavation work <br /> at the site. The cause of the uplifted areas that will be excavated is currently unknown and there is <br /> potential risk of exposure to unknown chemicals/materials. Therefore, this portion of the field <br /> work appears to have potentially higher health and safety risks than the drilling that CARNG is <br /> proposing to do. We recommend revising the HASP to address the specific precautions/procedures <br /> that will be used during excavation of the uplift areas. Also, further investigation of the potential <br /> buried tear-gas canisters will also require special precautions (if any drilling/digging is planned) <br /> and should be detailed in the HASP. <br /> California Environmental Protection Agency <br /> C1 Recycled Paper <br />