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STATE OF CALIFORNIA PETE WILSON Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD_ SUITE A UF SACRAMENTO. CA 95827-3098 <br /> PHONE: (9161 361 <br /> FAX ;976( 361-5686 <br /> � M <br /> � a <br /> �cwwr.,It <br /> 7 August 1992 AUG 12 1992 <br /> ENVIRONMENTAL HEALTH <br /> P <br /> Mr. Abel Haines ERMIT/SERVICES <br /> Environmental Protection Office <br /> Bldg. 231, Tracy Location <br /> Defense DiStributi0ii Rey ion Wes' <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0250 <br /> DRAFT OPERABLE UNIT NO. 1 FEASIBILITY STUDY REPORT, DEFENSE DISTRIBUTION REGION <br /> WEST (DDRW) , TRACY, SAN JOAQUIN COUNTY. <br /> We have reviewed the Draft Operable Unit No. 1 (OU-1) Feasibility Study (FS) <br /> Report for DDRW, Tracy. In general , we found the Draft OU-1 FS Report to be well <br /> prepared and organized. Summary tables and graphics in the Report helped to <br /> expedite our review. Our detailed review of the Report can be found in the <br /> enclosed memorandum. <br /> Our major concern with the document is that disposal alternatives, other than <br /> reinjection, do not appear to have been thoroughly investigated. As proposed in <br /> the Draft OU-1 FS Report, extraction of almost 1 .3 million gallons per day (mgd) <br /> are estimated to be needed to capture the complete extent of the plume to the <br /> aquifer cleanup level . We believe that shallow reinjection may be insufficient <br /> to reliably handle this quantity of flow on a long term basis. Parallel disposal <br /> alternatives should be available to dispose of all of the treated ground water. <br /> We have previously notified you of this concern in our 5 July 1991 letter. <br /> Reuse of the treated ground water, by local industry or to meet local irrigation <br /> needs, appears to be to be a viable disposal alternative, but was not given <br /> sufficient consideration. Reuse is equally preferred by the Board along with <br /> reinjection because of the benefits to the ground water resource. However, reuse <br /> is generally a more economical method of disposal . We recommend that DDRW, Tracy <br /> conduct a survey of the area to determine if there are any potential year-round <br /> or seasonal users of a portion or all of the treated ground water. <br /> Finally, with respect to disposal , we are concerned that the treated ground water <br /> may contain constituents other than volatile organics which could degrade the <br /> water quality of the receiving water. In order to meet the State Water Resources <br /> Control Board Resolution No. 68-16 (Anti-Degradation Policy) , discharge of the <br /> treated effluent must meet background concentrations, unless the Board finds that <br /> it is in the public interest to allow a level above background which still meets <br /> water quality objectives. Therefore, after re-start of the Interim Remedial <br />