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0 <br /> Tracie Billington, P.E. <br /> August 14, 1992 <br /> Page Four <br /> b. Evaluation of the presence of metals above health based <br /> risk levels in filtered samples. <br /> C. Evaluation the impact of potentially naturally <br /> occurring chemicals may have (i.e. arsenic) on the <br /> metals investigation. <br /> 4) The FS indicates there may be a separate monitoring program <br /> to evaluate the performance of the ground water extraction <br /> system. The Department would prefer that all monitoring <br /> requirements be combined in one comprehensive program. We <br /> believe this would be less confusing. <br /> 5) Woodward Clyde presents an argument for keeping bio- <br /> remediation technologies in the FS treatment train. The <br /> Department agrees with this argument. - Weare in support of <br /> any treatment technology that may reduce the time and/or <br /> cost of remediating the DDRW Tracy site. However, the data <br /> presented does not show any advantages to implementing a <br /> bio-treatment program at this time. We therefore recommend <br /> that bio-treatment be continued as a technology to be <br /> evaluated and implemented if further research finds it to be <br /> reasonable. <br /> 6) A proposed plan is a document designed to disseminate <br /> information to the public. Our review found the draft <br /> Proposed Plan lengthy and highly technical. We recommend <br /> that the technical jargon be reduced and the entire document <br /> be rewritten targeting a lay audience. <br /> SPECIFIC FS COMMENTS <br /> 7) Page 1-1 section 1. 1. 1.2 states that the remediation level <br /> will be determined by the Regional Water Quality Board's <br /> nondegredation policy. <br /> The Department is not clear what is meant by remediation <br /> level (i.e. does this refer to aquifer cleanup goals or <br /> effluent discharge requirements?) This statement needs to <br /> be clarified so the proper jurisdictional guidance can be <br /> applied. <br /> 8) Page 1-9 section 1.2 .4 . 1 states that TCE and PCE -are the <br /> primary constituents of concern for OU # 1. <br />