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� � • <br /> Department of Toxic Substances Control `.. <br /> Edwin F. Lowry, Director >. <br /> 8800 Cal Center Drive <br /> Winston H. Hickox Sacramento, California 95826-3200 Gray Davis <br /> Agency Secretary Governor <br /> California Environmental <br /> Protection Agency <br /> March 6, 2003 REfi= VEDD <br /> MAR 1 0 2003 LUI <br /> Mr. Marshall Cloud ENVIRONMENT HEALTH <br /> Remedial Program Manager PERMIT/SERVICES <br /> Defense Logistics Agency <br /> Defense Distribution San Joaquin California <br /> P.O. Box 960001 <br /> Tracy, California 95376-5000 <br /> COMMENTS ON DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN CALIFORNIA <br /> (DDJC)-TRACY DRAFT 2002 ANNUAL MONITORING REPORT <br /> DATED DECEMBER 19, 2002, TRACY SITE, TRACY, CALIFORNIA <br /> Dear Mr. Cloud: <br /> The Department of Toxic Substances Control (DTSC) received the above-mentioned <br /> report on December 24, 2003. The report summarizes groundwater analytical data from <br /> all wells sampled, presents conclusions drawn from those results, and provides <br /> recommendations for sampling, analysis, and remediation. DTSC has the following <br /> comments: <br /> General Comments <br /> 1.) Overall, the extraction wells and treatment systems are not meeting the <br /> performance standards set forth in DDJC's Operation Maintenance and Monitoring <br /> Plan by failing to identify extraction well capture zones, the large number of <br /> extraction wells offline, lack of plume capture in one or more aquifers, lack of <br /> optimization of well production rates, and only estimating the total mass of <br /> Trichloroethene and Tetrachloroethene removed by Ground Water Treatment Plant <br /> 1 (GWTP1) and GWTP2. Before the five-year certification can be approved, the <br /> remediation systems will need to have a minimum of several months of optimized <br /> operation in which the system demonstrates its effectiveness and reliability in <br /> remediating contaminants in the groundwater according to the design. <br /> 2.) GWTP1 and GWTP2 appear to be operating at half their intended design <br /> capacities. In addition, the estimated average flow rates of the respective <br /> extraction wells are anywhere from 75% to 10% of the expected design flow rates. <br /> If these extraction wells continue to operate at this unacceptable level then cleanup <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at www.dtsc.ca.gov. <br /> ® Printed on Recycled Paper <br />