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Californi Zegional Water Quality Co ' vol Board <br /> I Central Valley Region <br /> Karl E. Longley, ScD, P.E., Chair —� '1`\ If 1 � <br /> Linda S. Adams � L� Arnold <br /> Seoemn. fol <br /> Sacramento Main Office Sgghwarzenegger <br /> 11020 Sun Center Drive #200, Rancho Cordova, California 956786114 Governor <br /> q QQll <br /> Fmlrornnemal Phone (916) 464-3291 • FAX (916) 464-4645 rr 2 <br /> l'rnrecrimi <br /> htt p_7/wIrw.waterbo a rds.ca.gov/cent ral r al Icy <br /> 31 December 2007 E�1V�'g1SRVIG�� <br /> PE. <br /> Mr. Bill Stoermer Mr. Lawrence Beasley <br /> Fremont Plaza Investments Apache Plastics <br /> 7015 Morton Court 2120 Pebble Drive <br /> Stockton , CA 95209 Alamo , CA 94507 <br /> WORKPLAN REVIEW, FORMER APACHE PLASTICS, 2050 FREMONT STREET, STOCKTON, <br /> SAN JOAQUIN COUNTY <br /> I reviewed the Additional Site Assessment Work Plan ( Workplan) , downloaded electronically from <br /> GeoTracker on 7 December 2007 and submitted on your behalf by Advanced GeoEnvironmental , Inc . <br /> (AGE) . In a letter (Letter) to you dated 4 December 2007 , the San Joaquin County Environmental <br /> Health Department (SJCEHD) directed you to seek California Regional Water Quality Control Board , <br /> Central Valley Region (CVRWQCB ) approval for the bench scale testing ( BST) portion of the <br /> Workplan. The Letter states "Performance of such test ( BST), however, is not a requirement of <br /> (SJCEHD), but of the Regional Water Quality Control Board, Central Valley Region (CVRWQCB) . <br /> Approval of the proposed test methodologies and results analysis must be first obtained from the <br /> CVWQCB. " This statement is incorrect, in that Waterboard staff may only concur with , but not <br /> approve , proposals for work at your site . The SJCEHD is the lead agency for your case , and by <br /> requesting fees for borings and approving your collection of the additional samples , the SJCEHD has <br /> provided conditional approval to proceed with work. In response to the SJCEHD statement that the <br /> BST is a requirement of the CVRWQCB , this test is but one tool recognized by multiple States and <br /> Federal agencies to determine whether in-situ chemical oxidation (ozone injection) will be successful in <br /> remediating the groundwater, and whether secondary effects from ozone injection will impact water <br /> quality. An electronic copy of the latest Interstate Technical Regulatory Council BST guidance <br /> (ISCO-2) is available at http ://www. itrcweb . org/qd ISCO . asp . <br /> Workplan Comments : <br /> 1 . Bullet four on page 5 lists the General Minerals , and includes the term "Others" . The General <br /> Minerals analysis list should also include bromide/bromate . If, after ozone injection , the <br /> bromide/bromate results exceed CVRWQCB Water Quality Goals (available at <br /> http: //www.waterboards . ca . gov/centralvalley/water issues/water quality standards limits/water <br /> quality goals/index . html ) , then the methodology for hexavalent chromium/metals testing <br /> described in Section 3 . 3 , paragraph 2 is necessary for bromide/bromate , to determine whether <br /> the water quality degradation will reverse after stopping ozone injection . Also , the time required <br /> for a constituent to revert back to Water Quality Goals should be stated in the report . <br /> 2 . Section 2 . 5 states "An Ozone Infusion Bench Scale Test was required by the EHD . . . " The <br /> SJCEHD has already responded to this statement. <br /> California Environmental Protection Agency <br /> ea Regr)ed Paper <br />