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C�LIIORXI♦ Water Boards Central Valley Regional Water Quality Control Board 30 June 2014 Belinda May, LTC Environmental Compliance Officer 10620 Mather Road Mather, CA 95655-4176 JUL 12014 ENVIRONMENTAL HEALTM PERMIT/SERVIC,ES DRAFT FINAL WORK PLAN FOR IMPLEMENTING REMEDIAL ACTION BY /N -SITU CHEMICAL OXIDATION TREATMENT, FIELD MAINTENANCE SHOP #24, STOCKTON CALIFORNIA ARMY NATIONAL GUARD COMPLEX, SAN JOAQUIN COUNTY Central Valley Regional Water Quality Control Board staff (Central Valley Water Board staff) has reviewed the Draft Final Work Plan for Implementing Remedial Action by In - Situ Chemical Oxidation Treatment (Work Plan) received on 4 June 2014. The Work Plan provides the rationale and methods that will be used to treat the petroleum hydrocarbons source area at Field Maintenance Shop #24 with in-situ oxidation. Central Valley Water Board staff comments on the Work Plan are provided below. COMMENTS Based on the information presented in the Work Plan, Central Valley Water Board staff has concluded that the proposed reagent for the second phase of injections is not substantially different from the one injected in September 2013. Therefore, Notice of Applicability R5-2008-0149-045 does not require updating. 2. The Work Plan indicates only the one-, three-, and six-month monitoring events will be conducted after injection. However, the Notice of Applicability R5-2008-0149-045 contains a requirement to conduct a 12 -month monitoring event if one or more of the target parameters are more than 20% above background during the six-month monitoring event (see footnote 3 of Table 1 a in the Monitoring and Reporting Program). Revise Section 4.1 and Table 3 in the Work Plan to include this potential monitoring event. KARL E. LONGLEV SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive #200, Rancho Cordova, CA 95670 1 www.waterboards.ca.gov/centralvalley Zi R CYGLtU I- EDMUND G. BROWN JR. OO-VEFNOR MATTHEW ODRIOUEZ F SECRETARY FOR ENVIRONMENTAL PROTEGT101. JUL 12014 ENVIRONMENTAL HEALTM PERMIT/SERVIC,ES DRAFT FINAL WORK PLAN FOR IMPLEMENTING REMEDIAL ACTION BY /N -SITU CHEMICAL OXIDATION TREATMENT, FIELD MAINTENANCE SHOP #24, STOCKTON CALIFORNIA ARMY NATIONAL GUARD COMPLEX, SAN JOAQUIN COUNTY Central Valley Regional Water Quality Control Board staff (Central Valley Water Board staff) has reviewed the Draft Final Work Plan for Implementing Remedial Action by In - Situ Chemical Oxidation Treatment (Work Plan) received on 4 June 2014. The Work Plan provides the rationale and methods that will be used to treat the petroleum hydrocarbons source area at Field Maintenance Shop #24 with in-situ oxidation. Central Valley Water Board staff comments on the Work Plan are provided below. COMMENTS Based on the information presented in the Work Plan, Central Valley Water Board staff has concluded that the proposed reagent for the second phase of injections is not substantially different from the one injected in September 2013. Therefore, Notice of Applicability R5-2008-0149-045 does not require updating. 2. The Work Plan indicates only the one-, three-, and six-month monitoring events will be conducted after injection. However, the Notice of Applicability R5-2008-0149-045 contains a requirement to conduct a 12 -month monitoring event if one or more of the target parameters are more than 20% above background during the six-month monitoring event (see footnote 3 of Table 1 a in the Monitoring and Reporting Program). Revise Section 4.1 and Table 3 in the Work Plan to include this potential monitoring event. KARL E. LONGLEV SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive #200, Rancho Cordova, CA 95670 1 www.waterboards.ca.gov/centralvalley Zi R CYGLtU I-