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i <br /> 3 <br /> Mr . Gordon Boggs <br /> RWQCB - Central Valley Region <br /> November 8, 1988 <br /> Page 2 <br /> Number 18 specifies a rain gauge which will automatically shut <br /> the system down if rainfall exceeds 1/2 inch per hour . Verbal <br /> permission must be secured before restart . Discussion with <br /> the Utilities District as to why the rain gauge is required <br /> indicated the sewer system has difficulty handling high flow <br /> rates generated during storm events and that any additional <br /> water is a strain on the system. We would prefer to install <br /> a system which is not dependent on the limitations of the <br /> sewer system. Kayo has engineered a system to meet this <br /> requirement cbnsisting of an electronic rain gauge connected <br /> to a computer controller and alarm. The system is untried and <br /> we are concerned as to the reliability and longevity of the <br /> system under field conditions . <br /> Economically, a balanced system would be far less expensive . <br /> The design of the system has been expensive, construction, <br /> maintenance and required reporting would be more so . No sewer <br /> discharge would eliminate sewer fees - approximately <br /> $24, 000 . 00 per year . The above ground bioreactor to treat the <br /> groundwater would not be required . The man-hours required for <br /> sampling, maintenance and monthly reporting would also be <br /> reduced . <br /> A balanced system would be more efficient in terms of nutrient <br /> and hydrogen peroxide use as these materials would be recycled <br /> in a closed, balanced system. <br /> 2 ) The effect of the pumping change on the low permeability <br /> surface soils in this area of Stockton: <br /> There should be no effect on the low permeability surface <br /> soils as extraction and injection wells are screened starting <br /> at 30 to 40 feet below ground surface . <br /> 3 ) What are the proposed modifications to the remediation system <br /> and what are the effects in relation to this site : <br /> Phase I proposed to extract 10 gpm from R-1 (see figure 1 ) <br /> and 14 gpm from R-2 for a total of 24 qpm extracted . A total <br /> of 20 gpm were to be injected into a ring of eight wells . To <br /> balance the system, we propose to extract 8 gpm from R-1 and <br /> 12 gpm from R-2, balancing the system at 20 gpm injected and <br /> 20 gpm withdrawn. <br />