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Robert A. Evans, RWQCB <br />Page 3 <br />September 30, 1991 <br />APPROVAL OF CORRECTIVE ACTION PLAN (CAP). AUSTIN ROAD LANDFILL. CITY OF STOCKTON <br />it would be unwarranted to add these parameters to the list of constituents of <br />concern. <br />The elevated levels of TDS and EC in ground water from upgradient well MW -3, and <br />the presence of tetrachloroethane in ground water from upgradient well MW -5, may <br />be a result of upgradient diffusion from the landfill. Since the direction of <br />ground -water movement is towards the landfill, no further action is proposed at <br />this time. <br />Comment <br />If the City pursues reinjection of treated ground water, an underground injection <br />permit may be required by the Environmental Protection Agency. Discharge to the <br />City sewer system will require an industrial user permit from the local sewage <br />treatment plant. <br />Response <br />The City's current plan is to obtain a National Pollution Discharge Elimination <br />System permit and discharge treated ground water to Littlejohns Creek, which will <br />allow for indirect recharge to ground water through the creek bed. <br />Comment <br />Before the final treatment technology for extracted ground water is selected, the <br />CAP indicates that pilot studies will be conducted to determine the compatibility <br />of the wastewater with each treatment method. The City should continue other <br />efforts required by the CAP until the results of the pilot studies are received. <br />Response <br />The City has authorized EMCON to begin designing and preparing the technical <br />specifications for the ground -water extraction system, as well as the conveyance <br />piping from the extraction wells to the treatment system, and from the treatment <br />system to the discharge point at Littlejohns Creek. The City has also authorized <br />EMCON to begin the design of a concrete support pad on which to place the <br />treatment system equipment. The City will continue efforts required to implement <br />the CAP consistent with the project time line displayed on Figure 1. <br />Comment <br />Send more detailed information on the Kendall -tau test which is proposed for the <br />statistical analysis of the data received from the CAP activities. <br />