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Mr. Scott Hilyard - 2 - 17 October 2005 <br /> California Army National Guard <br /> that CANG test the powder for a full suite of potential contaminants (if it hasn't already been done) <br /> and submit the additional test results by 30 November 2005. <br /> 3. The PA/SI Update Report uses the phrase "below actionable levels"when describing analytical <br /> results. There are currently no negotiated cleanup levels at this site and background threshold limits <br /> were never developed for inorganics at the CANG site, so it is misleading to use this phrase. It is <br /> reasonable, for example, to state"the metals in the soil sample are below California Human Health <br /> Screening Levels" or make a similar comparison to a potentially applicable cleanup level. CANG <br /> needs to delete this phrase throughout document and replace it with a factual comparison of the <br /> analytical data to potentially applicable cleanup levels. <br /> 4. There is an ongoing collaborative effort between the State of California and Department of Defense <br /> to identify and investigate potential sources of perchlorate. The uplifted pavement areas at the <br /> CANG site were originally identified as areas where tear canisters were potentially buried. Tear gas <br /> canisters are a potential source of perchlorate and perchlorate has been detected in several public <br /> supply wells in the South Stockton Area. Regional Board staff request that CANG analyze the <br /> bluish-white powder for perchlorate and sample shallow groundwater beneath the facility to verify it <br /> is not a source of perchlorate. <br /> Specific Comments <br /> 1. Page 10, Section 3.3: This discussion of the bluish-white powder belongs in Section 3.2, so move it. <br /> 2. Page 12, Section 4.3: Revise "east and northwest" in the fourth sentence of the second paragraph to <br /> "west". <br /> Please submit the Revised PA/SI Update Report along with responses to our comments in this letter by <br /> 30 November 2005. As requested by San Joaquin County Public Health Services,Regional Board staff <br /> will provide lead regulatory oversight on all aspects of environmental investigation and cleanup at this <br /> site, including the petroleum hydrocarbon release areas. CANG should continue to provide copies of all <br /> future correspondence, work plans, and reports to San Joaquin County Public Health Services. If you <br /> have any questions, please contact me at(916) 464-4733 (mpierce(a,waterboards.ca.gov). <br /> Marcus L. Pierce, C.Hg. <br /> Engineering Geologist <br /> /�c: <br /> 1/ Mr. Mike Infurna, San Joaquin County Environmental Health Department, Stockton <br /> Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Tim Berger, Versar, Sacramento <br />