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EDMUND G. BROWN JR. <br /> w GOVERNOR <br /> C L I I O R N I• `� MCTEHAEq R O <br /> EDRIOUE2 <br /> WaterBoards ENVIRONMNTAL PROTEDTIOn <br /> Central Valley Regional Water Quality Control Board <br /> 19 August 2014 <br /> Belinda May, LTC <br /> Environmental Compliance Officer <br /> 10620 Mather Road <br /> Mather, CA 95655-4176 <br /> RESPONSE TO COMMENTS ON ANNUAL GROUNDWATER MONITORING <br /> REPORT & REMEDIAL ACTION COMPLETION REPORT FOR OXYGEN- <br /> ENHANCED BIOREMEDIATION, ARMY AVIATION SUPPORT FACILITY, <br /> STOCKTON CALIFORNIA ARMY NATIONAL GUARD COMPLEX, SAN JOAQUIN <br /> COUNTY <br /> Central Valley Regional Water Quality Control Board staff (Central Valley Water Board <br /> staff) has reviewed the California Army National Guard's (CA ARNG's) responses to our <br /> comments dated 31 July 2014 on the Annual Groundwater Monitoring Report & <br /> Remedial Action Completion Report for Oxygen-Enhanced Bioremediation (Annual <br /> Report). Your responses satisfy most of our comments except for General Comment 2 <br /> and Specific Comment 3 discussed below. These two comments and CA ARNG's <br /> responses (shown in red) are repeated below along with the additional revisions we are <br /> requesting to fully address our comments on the Annual Report. <br /> General Comment 2: The Annual Report states the AASF meets the general and <br /> media-specific criteria described in the Low-Threat Underground Storage Tank Closure <br /> Policy (Policy) and relies primarily on the Policy to assess whether the site is ready for <br /> closure. While we don't disagree with evaluating the site using the Policy, it only applies <br /> to underground storage tank sites. The AASF site also contains a suspected former <br /> wash rack that appears to be the source of low concentrations of solvents such as <br /> trichloroethene and tetrachloroethene detectec in site groundwater. A complete <br /> evaluation of the AASF site for closure must consider the residual solvents. Therefore, <br /> the Annual Report needs to be revised to provide a summary of the findings from the <br /> 2011 investigation report on potential releases from the wash rack and to explain why <br /> additional actions are unnecessary for the solvents. <br /> California Army National Guard Response, Section 1.2- Site Description and History, <br /> second last paragraph, the following text is inserted. <br /> KARL E. L.ONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 I www.waterboards.ca.gov/contralvalley <br /> ��­CYCLE.1.1— <br />