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I* MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 255-3000 Sacramento, CA 95827-3098 CALNET: 8-494-3000 TO: Antonia K.J. Vorster FROM: Charles Aukland Senior WRC Engineer Assistant Engineer James Taylors L, Associa a Engineering a logia DATE: 15 October 1993 SIGNATURE: zz A/ l J SUBJECT: GROUNDWATER TREATMENT PILOT PLANT SYSTEM START-UP, PROVE- OUT, AND EVALUATION REPORTS, DEFENSE DISTRIBUTION REGION WEST (DDRW), TRACY, SAN JOAQUIN COUNTY I have reviewed the documents prepared by Montgomery Watson (M-W) for the U.S. Army Corps of Engineers (CoE). These reports are designed to provide conclusive evidence that the full scale Interim Remedial Measures (IRM) air stripper plant will effectively reduce volatile organic compound (VOC) concentrations to levels consistent with the requirements of the Regional Board as described in Section B, Effluent Limitations, of the Waste Discharge, Requirements (WDR), Order No. 90-275. The documents reviewed included the following: ► System Start-up and Prove-Out Report ► Three Month Evaluation Report No. 1 ► Three Month Evaluation Report No. 2 ► Operation and Maintenance Manual Specific comments to the above referenced submittals are summarized below. System Start-up and Prove-out Report 1. Page 1-3, Section 1.2.1.5; This section states that industrial waste is contained in a lined compartment of the sanitary settling ponds. Specifically, what type of waste is contained in these ponds and what type of liner is being utilized? 2. Page 1-4, Section 1.2.2.2; This section states that treated water will be injected into the lower part of the aquifer. It is unclear whether this refers to a lower horizon of the Upper Tulare Formation, or simply a deeper part of the uppermost horizon. 3. Page 2-3, Section 2.3.1.1; The text suggests that the difference between the flow rates of the influent and effluent of the air stripper is due to a calibration error of the effluent flow meter. However, this is unlikely due to the inconsistency of the data. A calibration error would yield inaccurate data, but the error would be consistent with respect to the influent meter. As shown in Table 3.1, page 2-3, the effluent meter does not give readings consistently higher or lower than the influent meter; the readings are lower in some instances and higher in others.