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California Re g Water Quality CRtrol Board Y Central Valley Region Robert Schneider, Chair rerry Tamminen Arnold Schwar-zenegger Secretaryfor 11020 Sun Center Drive #200 Rancho Cordova, CA 95670-6114 Governor Environmental (916) 464-3291 • Fax (916) 4644704 Protection http://www.swrcb.ca.gov/rwgcb5 13 May 2004 Mr. Robert Cochran Chevron Environmental Management Company P.O. Box 6012 San Ramon, California 9458 �NOOpu Ivern and Roger Baffoni 1175 Orangewood Drive Lodi, CA 95240 REVIEWS, CLEANUP AND ABATEMENT ORDER NO. 5-00-704, CHEVRON STATION #9-5775, 301 WEST KETTLEMAN LANE, LODI, SAN JOAQUIN COUNTY I reviewed the First Quarter 2004, Quarterly Progress Report, Chevron Station #9-5775, 301 West Kettleman Lane, Lodi, San Joaquin County (Report), and the Hydrogen Peroxide Injection Work Plan (Workplan), each received 15 April 2004, submitted on behalf of Chevron Products Company and Ivem and Roger Baffoni by SECOR International Incorporated (SECOR). Your Report recommends continuing the groundwater extraction (GWE) from EX -3 for hydraulic control. I concur with the Report recommendation to continue the GWE pump and treat remediation for hydraulic control. The Workplan states there is a need for a more aggressive treatment for the A -zone contaminants around a hot spot at extraction well EX -1. EX -1 does not produce enough water to be effectively used in the GWE pump and treat remediation system, and typically has methyl tert-butyl ether (MtBE) concentrations two to three orders of magnitude above the two other extraction wells EX -2 and EX -3. EX -2 is adjacent to and downgradient from EX - 1. The Workplan proposes to inject potassium persulfate (H208Ss.2K) first, to be followed by hydrogen peroxide (HZOZ) injection into A -zone extraction wells EX -1 and EX -2 over a two-day event. The Workplan states that a revised Site Health and Safety Plan (SHSP) will be prepared, or an existing SHSP will be modified, for the chemical mixing and injection process. In a phone conversation on 27 April 2004 with Dave Evans, SECOR, I discussed the problems associated with writing Waste Discharge Requirements (WDRs) for potassium persulfate injection. Mr. Evans said that SECOR would withdraw the proposal for potassium persulfate, and inject hydrogen peroxide only. After my conversation with Mr. Evans, Regional Board senior staff reminded me that all injections require consideration of WDRs. Since potassium persulfate is no longer proposed, the following text refers only to the hydrogen peroxide injection proposal. The Workplan is not approved at this time. • A Workplan must include the SHSP as an appendix, since hydrogen peroxide is a highly reactive substance at the proposed concentration. See http://www.jtbaker.com/msds/englishhtrnl/H4065.htm for more details. • The fact that the site is an active car wash complicates execution of the Workplan. All state, county, and local permits/approvals are necessary prior to implementation of the Workplan, including the Lodi Fire Department. • Prior to Regional Board approval of the Workplan, a bench scale laboratory study (study) is required to evaluate the effects of injecting an HZOZ solution into the aquifer, namely all anticipated interactions, including valence changes for metallic ions (i.e., oxidizing naturally occurring Cr" to toxic Cr6+). The study must also include: California Environmental Protection Agency p�a Recycled Paper