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STATE OF CALIFORNIA-Environmental Protea Agency - PETE WILSON,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 958273098 ///��** <br /> PHONE: (916)255-3000 <br /> DOD FAX: (916) 2553052 6 E 7 <br /> t ,�m <br /> MAY 0 7 1,093 <br /> 4 May 1993 ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Abel Haines <br /> Environmental Protection Office <br /> Bldg. S-108, Sharpe Site <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0710 <br /> THIRTY PERCENT/DRAFT SUBMITTALS FOR CENTRAL AREA OPERABLE UNIT (OU-1) REMEDIAL <br /> DESIGN, DEFENSE DISTRIBUTION REGION WEST (DDRW), SHARPE, SAN JOAQUIN COUNTY <br /> We have reviewed the above referenced submittals received 5 March 1993. <br /> Overall the reports contain the basic elements needed to proceed with the 60 <br /> percent design phase. Our major concerns are summarized below and are <br /> discussed in more detail , along with other specific comments, in the enclosed <br /> memorandum. <br /> 1 . The Army Environmental Center (AEC) is overseeing the construction and <br /> testing of the extraction and injection wells. The Remedial Design Plans <br /> do not address the coordination between the U. S. Army Corps of Engineers <br /> (COE) and AEC with respect to the RD. We expect that DDRW, Sharpe will <br /> provide the assurance that the RD work conducted by AEC will be <br /> transmitted to and incorporated by the CoE. <br /> 2. The 30 Percent Remedial Design Report and Analysis states that transfer <br /> pumps at the air stripper discharge will provide sufficient head for the <br /> treated groundwater to facilitate injection through gravity flow. <br /> Contingencies need to be described should gravity flow not meet the <br /> injection performance goals. The performance of the injection pilot <br /> system must be evaluated to enhance the design of the final injection <br /> system. <br /> 3. The 30 Percent Remedial Design Report and Analysis refers to the potential <br /> use of biocides, should biological growth become a problem in the <br /> injection wells, evaporation ponds, or treatment system equipment. <br /> Mechanical methods are preferred over chemical treatment methods because <br /> common biocides contain chlorine, which have the potential to produce <br /> trihalomethanes such as chloroform. We do not support use of a post <br /> stripping tower continuous feed chlorine injection program, unless <br /> DDRW, Sharpe can conclusively show that degradation of the groundwater <br /> will not occur. <br />