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MEMORANDUM <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: Antonia K.J. Vorster ��/� ° - FROM: John J. Tomko <br /> DATE: 8 December 1989 SIGNATURE: L 1 � <br /> SUBJECT: REPORT OF WASTE DISCHARGE, GROUND WATER EXTRACTION SYSTEM, DEFENSE DEPOT TRACY, SAN <br /> JOAQUIN COUNTY <br /> On 21 November 1989 I met with Arthur Lee from Ensotech Inc. regarding the proposed ground <br /> water extraction system at the Tracy Defense Depot. Mr. Lee submitted a Report of Waste <br /> Discharge, a report entitled 'Work Plan On The Interim Ground Water Withdrawal , Treatment <br /> and Disposal System for Defense Depot Tracy, California' , and Section C of Ensotech's <br /> contract with the Depot containing the statement of work and schedule for the interim system. <br /> I have reviewed the information contained within these submittals and have determined that <br /> additional information is required prior to the development of waste discharge requirements <br /> for the interim system. These additional information requirements are as follows: <br /> 1) The certification signature of the owner of the facility is required on the waste <br /> discharge requirement application form. <br /> 2) We requested in our comment letter of July 1989 (enclosed) that the Depot's <br /> contractor for the interim system submit to us their strategy for a performance <br /> monitoring program for the extraction and injection wells. Several recommended <br /> objectives for the performance monitoring program were listed in Comment #2 of <br /> this letter. Ensotech's Report of Waste Discharge and accompanying reports do <br /> not discuss the rationale for their proposed performance monitoring program. <br /> Ensotech's performance monitoring strategy, discussing our concerns listed in <br /> Comment #2 of our July 1989 letter, and comments 3, 4, and 5 below, must be <br /> submitted for our review and concurrence. <br /> 3) One of the Regional Board's concerns with the earlier ERC extraction scheme and <br /> modeling effort was that the hydraulic effects in the upper low permeable unit <br /> (the most heavily contaminated unit) were not determined. It is our belief that <br /> this unit should be monitored to determine the hydraulic effects within this <br /> water bearing zone, and its hydraulic interconnection with the underlying <br /> gravelly unit, including possible impacts on the gravelly unit's contaminant <br /> capture zone. Ensotech's performance monitoring strategy should include wells <br /> to collect this information. <br /> 4) The extraction system's performance monitoring program should have monitoring <br /> wells located downgradient of the capture zone to collect 'direct' data on the <br />