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STATE OF CALIFORNIA • • PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION --.M <br /> 3443 ROUTIER ROAD. SUITE A q <br /> a <br /> SACRAMENTO. CA 95827-3098 <br /> PHONE: (9161361-5600 <br /> FAX '916( 361-5686 PIP�s t <br /> Q` <br /> ON �¢j <br /> Mr. Abel Haines AUG 12 1982 7 August 1992 <br /> Environmental Protection Office ENVIRONMENTAL HEALTH <br /> Bldg. 231, Tracy Location FER MIf/,5ERVIft$ <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0250 <br /> DRAFT PROPOSED PLAN FOR OPERABLE UNIT NO. 1, DEFENSE DISTRIBUTION REGION WEST <br /> (DORW) , TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Proposed Plan (PP) for Operable Unit No. 1 (OU-1) at <br /> DDRW, Tracy submitted on 10 June 1992. The preferred alternative for the OU-1 <br /> ground water cleanup is extraction, treatment by air stripping and vapor-phase <br /> carbon and disposal by reinjection. Our major concerns with the Draft OU-1 PP <br /> are listed below. Once the Draft Feasibility Study (FS) Report is revised to <br /> meet the concerns of the agencies, the PP should be revised accordingly. <br /> 1 . Disposal of the treated ground water using injection wells is a waste <br /> discharge to land and the discharge must meet the substantive requirements <br /> in the existing permit, Waste Discharge Requirements (WDRs) No. 90-275. The <br /> WDRs will be revised to include these wells. <br /> 2. Confusion between the terms "cleanup level " for the aquifer and "treatment <br /> standard" needs to be clarified. The terms cannot be used interchangeably. <br /> 3. Numerical aquifer cleanup levels for all of the constituents of concern <br /> should be presented. <br /> 4. Semi-annual monitoring of all monitor wells for the duration of the remedial <br /> action appears inadequate. A quarterly program to be evaluated on an annual <br /> basis would be more appropriate. <br /> These concerns, as well as our other comments, on the Draft OU-1 PP are <br /> discussed in more detail in the enclosed memorandum. <br /> If you have <br /> any questions, please call me at (916)361-5670. <br /> �CQ�yy,�J W�ti�C�oGtir//I'nf� <br /> CAMILLA WILLIAMS <br /> Engineering Geologist <br /> CKW:cw <br /> Enclosure <br />