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Tracie Billington, P.E. <br /> August 14, 1992 <br /> Page Five <br /> This statement must be qualified for OU # 1 based on the <br /> current level of knowledge. Additional investigations <br /> conducted under the site wide RI/FS may change our <br /> understanding of OU # 1. <br /> 9) Page 1-10 section 1. 2 . 4 . 5 and 1. 2 . 4 . 6 states that lead, <br /> arsenic, chromium, nitrates, and boron have been detected at <br /> elevated levels. <br /> The Department requires assurances that the questions <br /> concerning these metals will be addressed in the site wide <br /> RI/FS . <br /> 10) Page 1-17 section 1. 2 . 7 . 2 outlines the "fence line" approach <br /> for the construction of extraction wells for the IRM <br /> previously proposed for DDRW Tracy. <br /> The Department has never approved the "fence line" approach ---for the placement of extraction wells depicted in the IRM <br /> treatment alternative. The need for an evaluation of <br /> aquifer parameters and placement of extraction wells based <br /> on such parameters has always been maintained by the <br /> Department as the best construction method. <br /> 11) Page 1-19 section 1. 3 . 2 outlines a monitoring program to <br /> evaluate the ground water treatment system's performance. <br /> It has been the Department' s experience that a separate <br /> monitoring system can be confusing and detrimental to the <br /> overall project. We recommend that any separate monitoring <br /> for system performance be incorporated into the present and <br /> ongoing quarterly monitoring system. <br /> 12) Page 2-2 section 2 . 2 . 1. 1 states the objectives of the FS for <br /> OU # 1 is to identify a preferred remedial measure for the <br /> present on and off-site plume. <br /> The Department agrees with this concept and supports the <br /> establishment of OU # 1 for VOCs in the upper Tulare <br /> geologic formation. The Department does expect DDRW Tracy <br /> to fully pursue the delineation of all potential <br /> contaminants, both soil and ground water, in the site wide <br /> RI/FS. <br /> 13) Page 2-18 section 2 . 3 . 3 . 3 estimates the quantities of TCE <br /> and PCE in the ground water at 137 lbs. and 63 lbs. <br /> respectively. <br />