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Mr. Ronald Burt • - 2 - • 20 May 2003 <br /> divides the prove-out phase into quarters as opposed to the prove-out being a continual <br /> phase. Regional Board staff considers the prove-out to be an ongoing process until the <br /> system is in full-scale operation or until it is determined that the remediation system will <br /> not reach full-scale operation. <br /> 3. Section 7.0 of the Report states, "Upon full scale startup of the system, Dudek plans to <br /> continue monitoring 1,4-dioxane concentrations exiting the UV treatment unit effluent <br /> while adjust gjhe HZOZ dosage to more efficient levels." This is not acceptable. The <br /> dosage of hydr4en peroxide must be set prior to proposing full-scale operation. <br /> 4. Section 10.0 of the Report proposes to begin discharging to injection well INJ-1 while <br /> still in the prove-out stage. Kearney may not discharge treated water to INJ-1 during the <br /> prove-out activities because Discharge Specification B.3.b.iii. of the Order only allows <br /> discharge to the retention basin during prove-out. <br /> Regional Board staff concurs with the recommendation to continue operation of the system in the <br /> prove-out mode because Kearney has not optimized the hydrogen peroxide dosage, there is the <br /> continued problem of air build up in the carbon vessel, and the treatment system has been unable <br /> to maintain an extended period of operational time. By 29 August 2003,please submit a <br /> supplement to the Report that describes the evaluation and implementation, if appropriate, of the <br /> recommendations made by DTSC and work performed to move the system into full-scale <br /> remedial status, and provides recommendations for full-scale operation as required by the Order <br /> if the system is capable. If the treatment system is not capable of full-scale operation, Kearney <br /> needs to make recommendations for the evaluation of alternative remedial actions. If you have <br /> any questions, you may contact me at (916) 255-3119 or by email at lewisd(a,rb5s.swrcb.ca.gov. <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> Attachment <br /> cc: Mr. Doug O'Neal, Department of Toxic Substances Control, Sacramento <br /> Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Mr. H. Derrick Peterson, Esq., Austin, TX <br /> Mr. Peter Quinlan, Dudek& Associates, Encinitas <br />