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1 uL • �rwseaff(ii�� iAHii <br /> Former Apache Plastics <br /> I 2050 East Fremont Street. <br /> - 2 - <br /> 23 October 2014 <br /> 2. In the NOI, you propose using and MW- gyp as compliance zone we sM he compliance zone wells <br /> and MW-fig as transition <br /> the treatment zone and would re <br /> response could be observed at this location. Compliance zone time <br /> are r, a wells and from <br /> quire monitoring for ave <br /> reasonable distance downgradient of the treatment zone to ry long time bep ver e l feet at <br /> f IIs should a groundwater <br /> ensure break be located at a <br /> groundwater limitations. <br /> and site litholo Considering the location of theproposed quaaY wn products <br /> j gy consisting of silty clay, groundwater co stituents from th y ozJe a we and <br /> potentially may not be observed in the compliance wells for over 10 mplrance <br /> Water Board staff is concerned that the proposed co zone wells <br /> Site to provide useful data in determining if water years a ISCO reaction <br /> p p compliance zone wells Central V <br /> limitations are exceeded, alley <br /> quality objectives and are too far from the <br /> graundwafer <br /> Central Valley Water Board staff recommends installing <br /> zone wells as compliance zone wells, transition In addition zone wst� <br /> estimated groundwater velocity to support the proposed transition and com <br /> locations. pleas and uti1121ry9 I <br /> pliarlProvide an <br /> Ce <br /> 3• A contingencyZone well <br /> (Groundwater Limitations) of the General ordeust be included in the r l tThe hat econtingenc compliance wit <br /> constituent concentration trigger <br /> implementation of the contingenclevels in compliance zone wells that will Plan resth Section E <br /> include <br /> Y plan. gUlre <br /> According to the General Order, <br /> unacceptable water a contingency <br /> quality effects from ISCO plan is required to be implementeq <br /> describe in detail actions that will be taken to bring limitations from the ISCO injections back into bringcomplianceyc with <br /> contingency to correct <br /> Order 9 any constituents exceedlnyplWQQ uld <br /> h the requirements of the and <br /> Based on Central Valley Water Board staff's review of your NOI, <br /> • Determine the groundwater flow velocity YOU are to submit the <br /> zones wells that are closer and downgradient of the treatment zone. following <br /> required to install new wells, including injection d identify or install transition and compliance <br /> Proposed ISCO injection wells. Exclude '4 work <br /> wells that will be used to for i jechon and monls, and in an tordi�d NOI and MR ton, plan will be <br /> 9 wells as <br /> g of the project. properly identify the <br /> • Include in the amended NOI a contingenc ' r <br /> actions that will be implemented if deleterious b <br /> water quality objectives are observed et the compliance bes detailed corrective <br /> y products exceed 20% of background °r <br /> • According to Site reports, other than well VEW_ wells. <br /> downgradient monitoring wells screened across the water table in <br /> Water Board staff recommends installing2 there does not appear to be any <br /> tr <br /> interface w is to at <br /> screened monitoring wells to al Valley <br /> Monitor If <br />