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JAN-16-1996 01:32 P.02iO3 <br /> %. 41111.ul AW .c911ariia■ •. uwa .,�a+a..=aJ �, �_ —_- - -- ,� <br /> ia Central Valley Region <br /> Karl E.Longley,SCD,P.E.,Chair <br /> Arnold <br /> Linda S.Adams Sacramento Main office Schwarzenegger <br /> Secrelary for 11020 Sun Centcr Drive#200,Rancho Cordova,Califomia 95670-6114 Governor <br /> Environmental Phonc(916)464-3291 •FAX(916)464-4645 <br /> prorecrion http://www.watorboards.ca.gov/ccntralvallcy <br /> 23 April 2008 APPPC. <br /> Mr. Nam Baek author M ` <br /> Glenn Springs Holdings, Inc. _ <br /> 5005 IBJ Freeway, Suite 1350 FIL7 <br /> Dallas, TX 75244-6119 <br /> COMMENTS ON ADDENDUM GROUNDWATER TREATMENT PROCESS REDUNDANCY <br /> WORK PLAN, OCCIDENTAL CHEMICAL COMPANY, 96777 HOWLAND ROAD, <br /> LATHROP, SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) staff has reviewed the Addendum Groundwater Treatment Process Redundancy Work <br /> Plan (Work Plan), dated November 2007, prepared on behalf of Miller Springs Remediation <br /> Management, Inc. by Conestoga-Rovers &Associates. <br /> The scope of work includes the following elements-. <br /> • a dye tracer study, concentration profiling and a downhole camera survey (all to be <br /> performed prior to this letter); installation and aquifer testing of two new extraction wells <br /> • development of a well optimization plan based on the results; <br /> • evaluation of the treatment plant inputs based on the new data; <br /> • reconfiguring/redesigning the treatment system to assure the use of best available <br /> technology; <br /> • revision of the process and instrumentation drawings; <br /> • preparation of initial and final design reports; <br /> • a system testing and monitoring program that extends for one year; and <br /> • a contingency plan describing specific courses of action in the event that cleanup goals are <br /> not met. <br /> The Regional Water Board staff supports the optimization of the groundwater extraction and <br /> treatment system and concurs with the proposed changes in the Work Plan. I have the <br /> following specific comments. <br /> 1. The Regional Water Board staff continues to be concerned that, from 1982 to 1992, the <br /> system operated without treatment of sulfolane. Concerns remain as to what the <br /> environmental impact has been to the injection zone over time (for example, sulfolane <br /> concentrations sustained above the WDRs in PW-9-338). We request that Glenn Springs <br /> Holdings demonstrate that deep zone water quality is not being degraded. <br /> 2. Once the modified treatment system has been constructed and stabilized, the Regional <br /> Water Board staff plans to revise the WDRs with the consideration that best available <br /> technology has been implemented. The discharge limits for EDB, DBCP, and sulfolane <br /> California Environmental,Protection Agency <br /> a Recycled Paper <br />