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David Wang, P.E. , Chief <br /> August 12, 1991 <br /> Page 2 <br /> Effluent disposal options considered were: <br /> 1. Water reuse; <br /> 2 . Evaporation ponds with connector wells (i.e. , reinjection) ; <br /> and <br /> 3 . Surface water discharge to either the: South San Joaquin <br /> Irrigation District Canal (SSJIDC) or San Joaquin River. <br /> The majority of the remedial alternative analysis was <br /> concentrated on the selection of a VOC technology. The Draft <br /> Final Ground Water FS recommended air stripping with GAC emission <br /> control as a preferred remedial alternative for the remediation <br /> of the VOC contamination. Treatment for arsenic will be <br /> dependent on whether surface water discharge is selected as part <br /> of the effluent disposal option. No specific alternative for <br /> effluent disposal was recommended. Therefore, since the effluent <br /> disposal option was not recommended; treatment for arsenic i <br /> still in question. <br /> Generally, the Draft Final Ground Water FS and Risk <br /> Assessment Report appear to be well prepared and technically <br /> adequate. However, the following comments should be addressed: <br /> GENERAL COMMENTS <br /> 1. The Draft Final and Final Ground Water FS must be signed and <br /> stamped with registration number and expiration date by a <br /> Civil Engineer or Geologist registered in the State of <br /> California. This item has been previously discussed with <br /> Sharpe, who has generally complied. <br /> 2 . CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) - The CEQA <br /> review process for the ground water remediation should be <br /> started. Therefore, a CEQA "Environmental InformationForm" <br /> (Appendix H) shall be forwarded to Sharpe for completion. <br /> It is recommended that a draft negative declaration be <br /> circulated concurrently with the public comment period for <br /> the Proposed Plan. <br /> I have some reservations about proposing a negative <br /> declaration if the preferred effluent disposal option <br /> includes discharge to the San Joaquin River. According to <br /> the Draft Final Ground Water FS, that option would require <br /> the construction of approximately 20, 000 feet of pipeline <br /> and a lift station. That may result in the conclusion that <br /> a "no significant impact" determination is not appropriate. <br />