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California Regional Water Quality Control Board <br />Central Valley Region <br />Robert Qch 'de Cha <br />Terry Tamminen <br />Secretaryfor <br />Environmental <br />Protection <br />8 October 2004 <br />11020 Sun Center Drive #200 Rancho Cordova, CA 95670-6114 <br />(916) 464-329 1 • Fax (916) 464-4704 <br />http://www.swrcb.ca.gov/rwgcb5 D <br />Mr. Robert Cochran <br />Chevron Environmental Management Company <br />P.O. Box 6012 <br />San Ramon, California 9458 <br />Arnold Schwarzenegger <br />Governor <br />OCT 1 9 'I <br />Messrs. Ivern end Roaer Baffoni <br />1175 Orangewood Drive <br />Lodi, CA 95240 <br />WORKPLANREVIEW, CLEANUPAND ABATEMENT ORDER NO. 5-00-704, <br />CHEVRONSTATION #9-5775,301 WEST KETTLEMANLANE, LODI, SANJOAQUIN COUNTY <br />I reviewed the Work Plan for Hydrogen Peroxide Bench -Scale Study (Workplan), dated <br />24 September 2004 and submitted on behalf of Chevron Products Company and Messrs. Ivem and Roger <br />Baffoni by SECOR International Incorporated (SECOR). The Workplan proposes a Bench -Scale Study <br />(BSS) using soil collected from a boring near monitoring well MW -9B and groundwater from EX -1, <br />prior to a Pilot Study injecting hydrogen peroxide (H2O2) into A -zone extraction wells EX -1 and EX -2. <br />The BSS proposes to measure the efficiency of the H2O2 treatment and soil oxygen demand (SOD). <br />The Workplan is approved to collect additional soil and groundwater samples for the BSS, and <br />conditionally to conduct the BSS, with the addition of analyses for dissolved metals (including Cr6+) and <br />general minerals, and: <br />• SECOR must provide analytical results of dissolved metals and general minerals to produce <br />theoretical calculations in a geochemistry evaluation (GE) report, be included as an Appendix to <br />BSS. The GE report is to compare the results of the BSS and the theoretical calculations, and <br />thoroughly discuss the expected worst-case scenario reactions, i.e., 100% conversion of <br />constituents of concern into contaminants, reporting the chemical reactions in molar <br />concentrations, and be signed by a Chemist experienced in assessing geochemical reactions in <br />soils. <br />• If metals of concern (Cr6+, etc.) are not detected, or general minerals (SO4, etc.) are not present at <br />levels favorable for adverse reactions in saturated soil, then you may submit a Pilot Study <br />Workplan. Note that all analytical detection limits must be sufficiently low to test the theories <br />proposed in the BSS report and provide comparisons to Water Quality Objectives. You will <br />continue to monitor groundwater during the Pilot Study for the know petroleum hydrocarbon <br />contaminants and general parameters (dissolved oxygen, pH, specific conductance, temperature), <br />and sample, at a minimum, at least once before and 1 hour after startup of ozone injection. <br />• If metals of concern (Cr6+, etc.) are detected during the BSS, or minerals of concern (SO4, etc.) <br />are detected at potentially harmful levels, then the BSS will show which contaminant(s) are <br />produced; and whether the produced contaminant(s) will persist after termination of ozone <br />California Environmental Protection Agency <br />(d Recycled Paper <br />