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Mr. Harry Mossberger -2- 1 February 1991 The higher TDS levels in the intermediate zone, relative to those in the deep zone, where the treated ground water will be injected, raise the concern of degrading the deep zone. The effects of mixing the intermediate and deep zone waters must be addressed. The results should be related to the recommended and upper limits of the secondary maximum contaminant level (MCL) for TDS, and the benefits of removing the VOCs should be weighed against any degradation of the deep zone by increased TDS. The schedule of implementation of the Remedial Action Plan should be clarified. As the report states, it would take three to six months to obtain a permit from the San Joaquin County Air Pollution Control District (SJCAPCD) , and equipment delivery would take two to three months. Will the equipment be ordered after the SJCAPCD permit is obtained, resulting in a five to nine month period before start-up, or will the equipment be ordered so that it will be ready by the time the SJCAPCD permit is ready? In addition, Waste Discharge Requirements (WDRs) must be obtained from the Regional Water Quality Control Board. At least three months must be allowed for the drafting, public review, and adoption of WDRs. As you are aware, Wendy Cohen, Cam Williams, and I will meet with you on 7 February 1991 to discuss these comments and any other concernsou have. If you have any questions before the meeting, please call me at (916 361-5649. POLLY LOWRY Associate Engineering Geologist PAL:ej cc: Mr. Douglas O'Neal , Department of Health Services, Sacramento California Integrated Waste Management Board, Sacramento �,_Ms. Diane Hinson, San Joaquin County Department of Public Health Services, Stockton Mr. William Olive, Kearney-National , Atlanta, Georgia Mr. Derrick Peterson, Bryan, Cave, McPheeters, and McRoberts, Washington, D.C. Mr. Peter Quinlan, Hargis and Associates, La Jolla Mr. Terry Turner, Hargis and Associates, Mesa, Arizona