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California Regional Water Quality Control Board. <br /> Central Valley Region ` <� <br /> Steven T.Butler,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swreb.ca.gov/—rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 7 August 2000 <br /> Captain Kenneth Koop <br /> California Army National Guard <br /> 9800 Goethe Road <br /> Sacramento, CA 95826-9101 <br /> PRELIMINARYASSESSMENT/SITE INVESTIGATION REPORT, CALIFORNIA ARMY <br /> NATIONAL GUARD FACILITY, STOCKTON, CALIFORNIA <br /> Thank you for the opportunity to review the Preliminary Assessment/Site Investigation Report(PA/SI <br /> Report) for the California Army National Guard(CA ARNG) Facility in Stockton, California. The <br /> PA/SI Report was submitted on 31 May 2000. Our general and specific comments on the PA/SI Report <br /> are provided below. <br /> GENERAL COMMENTS <br /> 1. The PA/SI Report compares metals concentration in site soils to concentrations across the <br /> conterminous United States. This is not an appropriate method for assessing potential metals <br /> contamination at the CA ARNG site. The PA/SI Report needs to compare metals concentrations in <br /> site soils to local background concentrations. The local background can be developed from an <br /> investigation of metals concentrations in soils from portions of the site that are unaffected by <br /> historical activities or from existing studies in the vicinity of the site. <br /> 2. Table 3 provides a summary of the historical groundwater analytical results collected from three <br /> monitoring wells located at the Army Aviation and Support Facility(AASF). It is unclear why <br /> these wells were not sampled between April 1997 and March 2000. The March 2000 sampling <br /> results indicate benzene is a concern at the site. The CA ARNG needs to monitor these wells <br /> annually(at a minimum)to track changes in COC concentrations and determine if remediation may <br /> be warranted. <br /> 3. The geophysical survey conducted at the Combined Support and Maintenance Shop (CSMS) <br /> detected objects that the PA/SI Report concluded may be buried tear-gas canisters east of the <br /> Armory and unknown non-metallic objects beneath the uplifted pavement areas. These areas need <br /> further investigation,but the PA/SI Report does not provide any recommendations. Please add a <br /> recommendation to determine the nature of these geophysical anomalies. <br /> SPECIFIC COMMENTS <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />