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Californi-- 7egional Water Quality Cc ' •ol Board ~�, <br /> Central Valley Region ,�'_ ) <br /> i Robert Schneider,Chair �'°°�..�' <br /> Linda S.Adams Arnold <br /> Secretaryfor Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAX(916)4644645 <br /> http://www.waterboards.ca.gov/centralvalley <br /> 6 February 2007 RECEwvEDD <br /> Mr. Scott Hilyard FEB 0 8 2007 <br /> California Army National Guard ENVIRON10P4 T HEALTH <br /> 10620 Mather Blvd. PERMIT/SERVICES <br /> Sacramento, CA 95655 <br /> DRAFT TYPE II WORK PLAN—ADDENDUM UXO CONSTR UCTIONA CTIVITIES AND SOIL <br /> REMOVAL ACTION, CALIFORNIA ARMY NATIONAL GUARD FACILITY, 2000 STIMPSON <br /> ROAD, STOCKTON, SAN JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff(Regional Water Board staff) has reviewed <br /> the Draft Type H Work Plan—Addendum UXO Construction Activities and Soil Removal Action (Draft <br /> Addendum) for the California Army National Guard (CA ARNG) Facility received on 20 November <br /> 2006. Regional Water Board staff comments on the Draft Addendum are provided below,; A revised <br /> Draft Addendum addressing our comments should be submitted to our office no later than 9 April 2007. <br /> General Comments <br /> I: As part of the review of the Draft Addendum Regional Water Board staff also reviewed the Final <br /> Type 11 Work Plan, UXO Construction Activities and Soil Removal Action dated September 2005 <br /> and the Investigation Report, UXO Construction Activities and Soil Removal Action dated January <br /> 2006. These documents cover planning and implementation of soil/debris investigation and <br /> removal actions. These actions were completed without involvement of Regional Water Board <br /> staff. The removal actions were focused on a historical disposal area containing copper sulfate and <br /> airplane parts. Regional Water Board staff does not agree with CA ARNG's conclusion to leave <br /> the copper sulfate-contaminated soil and assorted airplane parts in-place because they "do not pose <br /> a significant threat to the environment". The Investigation Report does not provide a complete <br /> assessment of the risks proposed by the residual contamination to support this conclusion, but does <br /> indicate the copper sulfate contamination is toxic if ingested. Furthermore, the extent of the soils <br /> containing copper sulfate and airplane parts was not fully defined due to budget limitations. <br /> CA ARNG needs to define the extent of the copper sulfate contamination left in-place and assess <br /> potential receptors and exposure pathways before Regional Water Board staff can consider <br /> concurring on no further action. At a minimum, institutional controls (ICs) will be required if CA <br /> ARNG chooses to leave the contamination in-place. A State land use covenant may be required to <br /> implement the ICs. The Draft Addendum should be revised to collect the necessary data to <br /> delineate the extent of the copper sulfate contamination and buried airplane parts and fully assess <br /> the risks (including threat to water quality) posed by the residual contamination. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />