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EuvcnxonG. Bnvwry JR. <br /> MATTHEW <br /> Water Boards Roo <br /> xPgmeenox <br /> Central Valley Regional Water Quality Control Board <br /> 23 October 2014 RECEIVED <br /> OCT 24 2014 <br /> Mr. Bill Stoermer ENVIRONMENTAL HEALTH <br /> Fremont Plaza Investments PERMIT/SERVICES <br /> 7015 Morton Court <br /> Stockton , CA 95209 <br /> COMMENTS ON NOTICE OF INTENT, FORMER APACHE PLASTICS FACILITY, <br /> 2050 EAST FREMONT STREET, STOCKTON, SAN JOAQUIN COUNTY, <br /> LUSTIS No. 390329 <br /> California Regional Water Quality Control Board (Central Valley Water Board) staff reviewed the <br /> 9 September 2014 Notice of Intent (NOI) and Monitoring and Reporting Program (MRP) <br /> submitted by Advanced GeoEnvironmental, Inc. , (AGI) for the subject site. AGI submitted the <br /> NOI to apply for coverage under Waste Discharge Requirements General Order R5-2008-0149 <br /> General Waste Discharge Requirements for In-Situ Groundwater Remediation at Sites with <br /> Volatile Organic Compounds, Nitrogen Compounds, Perchlorate, Pesticides, Semi- Volatile <br /> Compounds and/or Petroleum Compounds (General Order) . AGI proposes to conduct in-situ <br /> chemical oxidation (ISCO) by injecting hydrogen peroxide solution into the subsurface to <br /> remediate petroleum contaminants at the site. The NOI was not complete and additional <br /> information is needed before Central Valley Water Board staff can prepare the Notice of <br /> Applicability. <br /> Central Valley Water Board staff has the following comments: <br /> 1 . During the ISCO pilot studies in August and September 2013, chemical oxidants were <br /> injected into site monitoring and extraction wells including MW-9 and MW-13 . In the NOI , <br /> AGI also proposes to utilize wells MW-9 and MW-13 for ISCO injections . <br /> The last groundwater sampling event occurring on 9 October 2013, and current data is needed <br /> to assess groundwater conditions and evaluate the effects of the ISCO injections on water <br /> quality at the Site. Please collect groundwater samples from all available monitoring wells, <br /> including previously identified vapor extraction wells that can yield representative water quality <br /> data . <br /> Please note, utilizing the monitoring wells for the ISCO applications makes them unsuitable for <br /> evaluating water quality in the aquifer. During the remediation project, the monitoring wells <br /> should only be used to monitor the progress and effectiveness of the ISCO applications. <br /> Additional injection wells will be needed for ISCO applications in the water bearing zone <br /> targeted by MW-9 and MW-13. <br /> KARL E. LONGLEY SCD, P . E. , CIIAIR PAMELA C. CREEOON P. E. , BCEE, EXECUTIVE 0MOCR <br /> 11020 Sun Center Drive 0200, Rancho Cordova, CA 95670 1 www.waterboarde:ca.0ov/centralvalley <br /> CA nECYGL[D PAren <br />