FIELD DOCUMENTS AND WORK PLANS 1989

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State of California Department of Health Services Memorandum To Donn Diebert f MAR 141989 Date March 9 , 1989 Senior Waste Management Engineer �ISubject: REVIEW COMMENTS . � i I SERVICu From :Jim Austreng Waste Managetp(ht Engineer I have reviewed the Marley Cooling Tower Company' s (MCTC' s) February 2, 1989 submittal entitled "QUARTERLY GROUNDWATER MONITORING AND INTERIM RESULTS OF PHASE IV GROUNDWATER ASSESSMENT" . I have also reviewed the Regional Water Quality Control Board' s (Water Board' s) comments (dated 24 February 1989) pertaining to the report. My comments and recommendations follow: The report was well organized and presented a fairly comprehensive view of ground water conditions at the site. There are however issues which remain to be resolved. Some of these issues have been addressed in the Water Board' s 24 February 1989 correspondence. Others have not and are discussed below. Please note too that I do concur with all of the Water Board' s "Comments and Recommendation" (ref; page 4 of their transmittal) . I might add however that more emphasis should be placed on the recommendation to investigate the source and consequences (both actual and potential) of the North Yard "mound" . Additional Comments/Recommendations- o Current up-gradient wells do not provide means to sample the "deep" aquifer zone. MCTC therefore cannot adequately determine, as required by both state and federal statute, up-gradient ground water conditions. I therefore recommend MCTC be required to install an upgradient "deep" aquifer monitoring well during the Phase V work schedule. o Because of the proximity and the potential for contamination of California Water Services wells #52 and #62 , I suggest MCTC be required to sample these wells during their next quarterly sampling round. Analysis should at a minimum include the determination of total chromium, copper, and arsenic concentrations.