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EomRNORG. SxuwN JR. <br /> GOVERNO <br /> MnrrxEw gooRlausz <br /> Water Boards CEN <br /> At PROIGNOON <br /> Central Valley Regional Vater Quality Control Board E°vi°r^' <br /> MAR 19 201,5 <br /> 17 March 2015 ENVIRONMENTAL HE�LTH <br /> MIT/SERVICEg <br /> Bill Stoermer <br /> Fremont Plaza Investments , LP <br /> 7015 Morton Court <br /> Stockton, CA 95209 <br /> REQUEST TO OPERATE UNDER GENERAL ORDER NO, R5-2015-0012 Waste Discharge <br /> Requirements General Order for In-Situ Remediation and Discharge of Treated Groundwater to <br /> Land, former Apache Plastics, 2050 East Fremont Street, Stockton, San Joaquin County <br /> California Regional Water Quality Control Board — Central Valley Region (Central Valley Water Board) <br /> staff reviewed the Waste Discharge Permit Application and Notice of Intent (NOI) submitted on your <br /> behalf by Advanced GeoEnvironmental , Inc. (AGE) , on 23 September 2014. In addition to the Permit <br /> Application , AGE included a check in the amount of $4, 581 . 00 for coverage under the General Order No. <br /> R-5-2015-0012 (General Order) for In-Situ Remediation at the former Apache Plastics , 2050 East <br /> Fremont Street, Stockton facility. The fee for coverage under the General Order is dictated by California <br /> Code of Regulation, Title 23 , Division 7, Chapter 9, Waste Discharge Report and Requirements Article 1 <br /> -- fees for a discharge. The fee for a threat and complexity of 3B this year is $4,699. Submission of the <br /> remaining $118 was received 26 February 2015. <br /> In addition to the Permit Application and NO] , AGE submitted the following documents to support the <br /> proposed project: <br /> • Corrective Action Plan dated 11 August 2014 <br /> In-Situ Chemical Oxidation Pilot Study Report dated 19 August 2014 <br /> • Corrective Action Plan Addendum dated 21 August 2014 <br /> Notice of Intent dated 9 September 2014 <br /> • Injection Well Installation Report dated 24 December 2014 <br /> We understand AGE proposes to inject a 5-8% hydrogen peroxide solution into groundwater using <br /> injection wells VEW- 1 , VEW-2 , EW-1 , and IW-1 through IW-5 installed for the project. Hydrogen peroxide <br /> injection is proposed to occur at each well during four (4) tri-weekly injection events. During each of the <br /> tri-weekly injection events , AGE has proposed to pressure inject approximately 200-gallons of the 5-8% <br /> hydrogen peroxide solution into each of the injection wells. AGE states in the Corrective Action Plan <br /> Addendum that in total , approximately 2, 600-gallons of hydrogen peroxide solution are proposed to be <br /> injected into the subsurface during each event. We understand the injection rate may vary depending on <br /> the observed field conditions at each injection location. We are concerned there is a discrepancy in the <br /> volume of injectant, proposed as 200 gallons in 8 wells, is significantly less than the total 2, 600 gallons <br /> proposed for each event. Please provide clarification of the volume of injectant that will be used during <br /> each injection event in an Addendum to the NO] by 30 May 2015, <br /> KARL E. LoNGLEY SCD , P.E. , CHAIR I PAMELA C, CREEDON P .E. , 6CEE, EXEOUTIVE OrrIOER <br /> 11020 Sun Center Drive 4200, Rancho Cordova, CA u5m I www.waterboerCs,cs.gov/centrelvalley <br /> iS REovcteo PAPER <br />