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MEMORANDUM <br /> CALIFORNIA REGIONAL VV#R QUALITY CONTROL BOARAENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: Antonia K. J. Vorster FROM: Camilla Williams <br /> Senior WRC Engineer Engineering Geologist <br /> DATE: 29 August 1991 SIGNATURE: 12 t4 <br /> SUBJECT: REVIEW OF INTERIM REMEDIAL MEASURE (IRM) PROVE-OUT PHASE REPORTS, DEFENSE <br /> DISTRIBUTION REGION WEST (DDRW), TRACY, SAN JOAQUIN COUNTY <br /> I have reviewed the reports for the Prove-Out Phase of the IRM. The reports were <br /> prepared by Ensotech, Inc. for the Corps of Engineers and were submitted on 10 July <br /> 1991 . Submittal of the following reports were required by required by Waste Discharge <br /> Requirements Order No. 90-275. <br /> "Prove-Out of the Interim Ground Water Remediation System", <br /> "Installation Data Report", <br /> "Geologic Well Logs", <br /> "Site Specific Quality Management Plan (SSQMP)", <br /> "Start-up Schedule" . <br /> My overall comment on the reports is that there appears to be a lack of an exchange of <br /> data between the different contractors for the IRM and the Remedial Investigation/ <br /> Feasibility Study (RI/FS) . Therefore, all of the available data are not being used in <br /> making technical decisions. Tracy needs to implement a system by which the data <br /> developed in the RI/FS can be used for the IRM and any future expansions of the IRM, <br /> and likewise, to use the data developed for the IRM for the site-wide RI/FS and final <br /> remedial design for the ground water cleanup. <br /> The major deficiency of the IRM, as reported in these documents, is that one of the <br /> injection wells does not perform as designed. There was no discussion in the reports <br /> on the possible reasons for the poor performance of this injection well . Tracy should <br /> evaluate all of the hydrogeologic data to determine if the poor well performance can <br /> be attributed to well design, construction, lithology, or some other factor. Tracy <br /> should use the evaluation of this well performance to avoid similar problems with <br /> future injection wells and to optimize the performance of the final ground water <br /> remedial action. <br /> My review concentrated primarily on the Prove-Out of the Interim Ground Water <br /> Remediation System, Installation Data and Geologic Well Logs Reports. My comments and <br /> concerns on these documents are discussed below. <br /> PROVE-OUT OF THE INTERIM GROUND WATER REMEDIATION SYSTEM REPORT <br /> 1. Page 4. The static water level (SWL) in the injection wells appears to have been <br /> monitored between 1500 and 1555 (about one hour) on 11 April 1991. The WDRs do not <br /> specify any requirements for monitoring of the SWL. Generally, a 24 hour period <br /> is used to monitor the SWL prior to conducting any aquifer test. Because the IRM <br />