SITE INFORMATION AND CORRESPONDENCE

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STAY- Cr CALSFCFNIA - ENVIROWENTAL PAOTECTICN A CY PETE MIL`.GN, GaV RTMrnar DEPAENT OF TOXIC SUB ANCES CONTROL Region 1 10151 Croydon Way,Suite 3 Sacramento, CA 95827-2106 (916)855-7700 -. October 29, 1991 ENVIRONMENTAL HEALTH PERMIT/SERVICES Mr. Marshall Cloud Defense Distribution Region West Tracy Site Office of Environmental Protection 25600 South Chrisman Road Tracy, CA 95376-5000 Dear Mr. Cloud: CONCERNS REGARDING THE AIR STRIPPING TOWER AT DEFENSE DISTRIBUTION, REGION WEST (DDRW) , TRACY SITE This letter transmits the Department of Toxic Substances Control ' s (Department) concerns regarding the construction and operation of the air stripping tower at DDRW, Tracy site. The letter also recommends a course of action to address our concerns and improve the reliability of the tower' s operation. The Department' s concerns were the result of observations made during our October 8 , 1991 inspection, and information imparted to us due to the ground water treatment system' s failure on October 12 , 1991. During the October 8, 1991 inspection, conducted jointly with the Regional Water Quality Control Board, numerous leaks were observed in piping connections throughout the tower complex. Discussions with your contractor were not satisfactory in providing a reasonable explanation for the leaks. The system failure on October 12 , 1991 exposed additional problems. The system' s failure was apparently due to a sensor malfunction which allowed water to back up and fill the tower. Back up continued and eventually caused an off-site release of potentially contaminated water. The off-site release triggered a Proposition 65 notification, a copy of which is enclosed for your records. Of as great an importance as the initial malfunction, is the time interval between its start and discovery. This time interval is the direct cause of the off-site release. The Department questions why the system operated in an improper manner long enough to allow such a release.