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Ground Water Injection FS -4- 10 December 1991 <br /> Marley Cooling Tower Company <br /> there may be potential detrimental hydraulic affects with the Stockton <br /> Diverting Canal location for the injection wells. The FS Report should have <br /> addressed potential hydraulic affects and potential benefits on the plume <br /> with an increase or decrease in the injection well flow rates. <br /> Page 22. Two locations for the injection wells were evaluated in the FS: one at the <br /> North Yard and the other adjacent to the Stockton Diverting Canal . The FS <br /> Report did not state why the evaluation was limited to only two locations. <br /> However, the Report acknowledges that no further optimization of injection <br /> well placement (or rates) was performed. One of the conclusions of the FS <br /> was that capture of the contaminant plume in the deep zone is diminished <br /> when injection occurs at the North Yard. The FS should have considered <br /> other locations than the North Yard and the Stockton Diverting Canal . If <br /> other locations had been evaluated, benefits such as hydraulic control and <br /> increased plume capture could have been determined. <br /> Page 23. The FS Report states that the hydraulic parameters for the deep zone were <br /> revised based on the results of an aquifer test performed on CWS-52. This <br /> well is approximately 1 .25 miles south of the Marley site and is adjacent to <br /> Mormon Slough. The Stockton Diverting Canal is approximately one third of <br /> a mile to the northeast of the site. The distance between Mormon Slough and <br /> the Stockton Diverting Canal is approximately 1.6 miles. Therefore, the <br /> aquifer parameters used in the evaluation of the injection wells performance <br /> at the Stockton Diverting Canal are based on data developed 1 .6 miles to the <br /> south. If the use of these aquifer parameters is appropriate, the FS Report <br /> should have stated that the use of these parameters for a site 1.6 miles to <br /> the north is justified based on the regional hydrostratigraphy. <br /> Page 24. The FS Report refers to four model Layer 1, seven model Layer 2 and two <br /> model Layer 3. It is unclear what is meant by the use of the terms "four <br /> model ", "seven model " and "two model ". <br /> CKW:cw <br />