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w <br /> r <br /> California Regional Water Quality Control Board <br /> Central Valley Region . <br /> Robert Schneider,Chair <br /> Winston H.Aickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swreb.ca.gov/mgcb5 <br /> Protection _ 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255.3015 <br /> 20 May 2003 �90 <br /> Mr. Ronald A. Burt 111�dN ' <br /> Patterson Planning& Services, Inc. <br /> 4525 West End Avenue, Suite 215 <br /> Nashville, TN 37205 <br /> REVIEW OF TREATMENT SYSTEM PROVE-OUT REPORT, KEARNEY KPF, <br /> STOCKTON, SAN JOAQUIN COUNTY <br /> We have reviewed the April 2003 Treatment System Prove-Out Report(Report) submitted by <br /> Dudek&Associates, Inc. on behalf of the former Kearney-KPF (Kearney) facility at 1624 East <br /> Alpine Avenue in Stockton. The Report describes the treatment system, initial and continued <br /> prove-out tests, and problems with the system which have prevented full-scale operation. <br /> Kearney recommends continued operation while continuing to troubleshoot the system and to <br /> inject treated water into injection well INJ-1. Attached are Department of Toxic Substances <br /> Control (DTSC) comments on the Report,which includes recommendations for treatment system <br /> modifications. <br /> We have the following comments on the Report: <br /> 1. Section 1.1 of the Report discusses discrepancies with the analysis of 1,4-dioxane and <br /> explains that Kearney has subtracted the concentration detected in corresponding blank <br /> samples from the values reported from the laboratory. This is not an acceptable practice. <br /> The laboratory reports included in the Report do not qualify any of the 1,4-dioxane <br /> detections as potential false positives. Waste Discharge Requirements Order No. <br /> 5-01-269 (Order) requires a maximum detection limit of 1.0 micrograms per liter. If <br /> Kearney believes detections by the laboratory below this level are unreliable,Kearney <br /> should request the laboratory to not report"J"values. Kearney must report all data as it is <br /> submitted by the laboratory and only qualify data with approved data qualifiers based on <br /> quality assurance/quality control review of the data. <br /> 2. The organization of the Report is confusing based on the use of the term"prove-out." <br /> Sections 4.0 and 5.0 use the terms"prove-out" and"startup"prior to the system check <br /> and conformance inspection. Kearney needs to organize the discussion of activities <br /> moving towards full-scale operation as it appears in the Order. Furthermore, the Report <br /> California Environmental Protection Agency. <br /> 01 Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.sweb.ca.gov/mqcbS <br />