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McCormick and Baxter 3 12 July 1990 <br /> 9) An annual evaluation of the collected data and a modification of the <br /> extraction system if it is determined that (1) the target areas are not <br /> being captured, or (2) remedial action goals outside the target areas are <br /> being exceeded. This annual evaluation also provides for the shutting down <br /> of extraction wells when remedial action goals are met, and the reevaluation <br /> of an extraction well if concentrations have not decreased within five <br /> years. <br /> 10) Treatment at the SRWCF. An application has been sent to Stockton (23 March <br /> 1990) regarding these additional flows. Approval has not yet been given. <br /> Our comments on the draft RAP, dated 8 December 1990, appear to be adequately addressed <br /> in this final RAP. The phased approach to the extraction of contaminated ground water <br /> is consistent with the approach we've taken on other RI/FS projects. The proposed six <br /> month evaluation of the initial extraction system and the various steps in the <br /> performance monitoring program provide ample opportunity to evaluate the effectiveness <br /> of the ground water extraction system and to modify it as needed. The number of <br /> additional monitoring wells and piezometers for the initial system appear adequate to <br /> (1) verify the areal and vertical extent of contamination, and (2) to determine the <br /> effectiveness of the initial extraction system and to make necessary adjustments. The <br /> proposed pilot testing of a biological soil treatment process should generate the data <br /> needed to evaluate the technical and economic feasibility of soil treatment at this <br /> site. Finally, McCormick and Baxter has applied for a permit to discharge the <br /> extracted groundwater from the initial system into the SRWCF sewerage system. <br /> Hence, this final Phase I RAP is adequate. However, I do have some minor concerns that <br /> should be addressed during the design of the extraction system and/or during the <br /> implementation of the Phase I program. <br /> 1) Based upon the consultant's capture zone analysis the three downgradient <br /> wells south of the freeway will be required to capture the target areas <br /> within zones B through D, and to meet remedial action goals. The initial <br /> extraction system does not include these wells. As part of the six month <br /> evaluation of the initial extraction well system, the consultant should re- <br /> evaluate the design of the extraction wells within the area south of the <br /> freeway. <br /> 2) Figure 7-7 indicates that 26 piezometers will be installed with the initial <br /> extractions system, however, Figure 7-12 states that 18 will be installed. <br /> This needs clarification. <br /> 3) Extraction wells and monitoring wells (including the Gold Bond wells) should <br /> be sampled on a quarterly basis. Water elevations should be taken monthly <br /> in all wells and piezometers. Reduced frequency of sampling and water level <br /> measurement should not be proposed until at least one full year of data has <br /> been collected, and a rationale for the reduced frequency is presented. <br />