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California Regional Water Quality Con'-,)I Board <br /> Central Valley Region <br /> Karl E.Longley,ScD,P.E.,Chair <br /> Linda S.Adams (0 <br /> Secretaryfor Sacramento Main Office Arnold <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670.6114 Schwarzenegger <br /> Protection Phone(916)464-3291•FAX(916)464-4645 Governor <br /> http://www.waterboards.ca.gov/centralvalley <br /> 27 July 2007 <br /> Mr. Scott Hilyard <br /> California Army National Guard <br /> 10620 Mather Blvd. <br /> Sacramento; CA 9,5655 <br /> WORK PLAN FOR THE UNDERGROUND STORAGE TANK LOCATION AT THE ARMY <br /> AVIATION AND SUPPORT FACILITY, CALIFORNIA ARMY NATIONAL GUARD, <br /> STOCKTON, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region, staff(Regional Water <br /> Board) staff has reviewed the Work Plan for the Underground Storage Tank Location at the <br /> Army Aviation and Support Facility(Work Plan) for the California Army National Guard (CA <br /> ARNG) site received on 28 June 2007. Regional Water Board staff comments on the Work <br /> Plan are provided below. <br /> General Comments <br /> 1. It is unclear why the investigation proposed in the Work Plan is only focused on the <br /> former 20,000-gallon underground storage tanks (USTs) that were used to store aviation <br /> fuel. Section ES.3 indicates the three adjacent 5,000-gallon USTs leaked and <br /> contaminated soil removed along with these tanks may have been placed back in the <br /> UST excavation pit. The Work Plan should be revised to include investigation of the <br /> 5,000-gallon USTs and all associated piping and fuel dispensers, or CA ARNG needs to <br /> explain why the former 5,000-gallon USTs do not require further investigation. A <br /> summary of any previous investigations of the former 5,000-gallon USTs, piping, and fuel <br /> dispensers along with figures/tables depicting sample locations/results should be <br /> included in the Work Plan. <br /> If leakage from the former 5,000-gallon USTs or potential leakage from the former fuel <br /> dispensers and underground piping has not been adequately characterized, the Work <br /> Plan should be revised to include additional borings in these areas. CA ARNG should <br /> follow Tri-Regional Staff Recommendations on Preliminary Investigation and Evaluation <br /> of Underground Storage Tank Sites (2004) in conducting the investigation. <br /> 2. Given that groundwater appears to flow north beneath the Army Aviation and Support <br /> Facility (AASF), the existing three monitoring wells (MW-1 through MW-3) are not located <br /> down gradient from the former 20,000-gallon USTs, 5,000-gallon USTs, or the associated <br /> fuel'dispensers and underground piping. Additional groundwater samples north of the <br /> California Environmental Protection Agency <br /> Cos Recycled Paper <br />