Laserfiche WebLink
ff.-OF CALIFORNIA—ENVIRONMENTAL PROTECO AGENCY • PETE WILSON,Govemor <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> 10151 CROYDON WAY,SUITE 3 <br /> SACRAMENTO,CA 95827-2106 <br /> February 14, 1992 <br /> IU6 <br /> Mr. David W. Bates FEB 18 19 <br /> The Marley Cooling Tower Company ENVIRONP/1ENTAL '` <br /> 5800 Foxridge Road <br /> Mission, Kansas 66202 PERI'v1{ f/SL'': <br /> Dear Mr. Bates: <br /> IN SITU FULL SCALE DESIGN AND PILOT SCALE FLUSH & TREAT REPORT <br /> The Department of Toxic Substances Control (Department) has <br /> reviewed the November 25, 1991, In Situ Soil Flushing Pilot Study <br /> Evaluation Report and full scale design drawings and <br /> specifications authored and submitted by Black & Veatch. The <br /> documents were provided pursuant to the Department's June 29, <br /> 1990, Remedial Action Plan (RAP) for the Marley Cooling Tower <br /> Company's, (MCTC's) Stockton facility. <br /> As discussed during recent telephone conversations with Mr. <br /> Thomas A. Hickey, Black & Veatch, the Department concurs in <br /> principle with the proposed design. The monitoring scheme <br /> however was found to be deficient. Consequently, an additional <br /> monitoring tube and lysimeter cluster will be required. This <br /> additional monitoring system should be located in the vicinity of <br /> MCTC's east fence line and the former wood treatment building; <br /> see also the Regional Water Quality Control Board's, January 24, <br /> 1992, letter with attached memorandum. Please note the <br /> Department considers it crucial that the fate of injected waters <br /> be understood. Therefore, pending evaluation of initial full <br /> scale monitoring reports and data evaluation, supplemental <br /> monitoring requirements may be imposed. <br /> In regards to the Pilot Study Evaluation Report (Report) , <br /> the Department has found the Report to be deficient in areas of <br /> data evaluation and presentation. A detailed discussion and <br /> response requirement will be provided to MCTC under separate <br /> cover letter. However, for purpose of summarizing these <br /> concerns, the following comments are provided: <br /> 1. The Report lacks in its evaluation of the fate of the <br /> approximately 1 million gallons injected during the pilot <br /> study. The extent of lateral flows and the potential <br /> injected water may escape the (assumed) capture zone remain <br /> in question. <br /> 2 . The Report notes, but fails to sufficiently explain the <br /> variable and contradicting pre- versus post-flushing soil <br /> moisture contents, i.e. , why were moisture contents lower <br /> during flushing operations versus pre-flushing samples. <br />