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California Regional Water QualityC n y,Bboard <br /> Central Valley Region r <br /> Terry Tamminen Robert Schneider Chair 04 MAY 24 PM I: 34 <� <br /> Secretary for Sacramento Main Office Arnold Schwarzenegger <br /> Environmental Internet Address: hq://w .sw b.ca.gov/mgcb5 Governor <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464.4797 <br /> 21 May 2004 <br /> Mr. Brian Miller <br /> Agrium <br /> 1220 Potter Drive <br /> West Lafayette, IN 47906 <br /> REVIEW OF CONCEPTUAL REMEDIAL ACTION PLAN, WESTERN FARM SERVICE, <br /> 1905 NORTH BROADWAY AVENUE, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board) has reviewed <br /> the 29 April 2004 Results of 2004 Semi-Annual Groundwater Monitoring and Conceptual <br /> Remedial Action Plan for Groundwater(Report) submitted by GeoSyntec Consultants on behalf <br /> of Western Farm Service, Inc. (WFS) for the agricultural chemical facility at 1905 North <br /> Broadway Avenue in Stockton (site). The Report discusses the groundwater monitoring <br /> conducted in January and proposes to evaluate pump and treat and in-situ treatment technologies, <br /> such as injecting Hydrogen Releasing Compound (HRC(&), soybean oil, chitin, or zero valent <br /> iron. WFS proposes treatability studies to evaluate the remedial alternatives. <br /> We have the following comments on the Report: <br /> 1. The Report states the remedial action objective is to reduce pollution in groundwater <br /> downgradient of the site. WFS needs to amend the objective to include cleanup of <br /> pollution on and off-site. <br /> 2. The Report refers to two active supply wells near the site but does not discuss or show <br /> where these wells are located in relation to the site and groundwater flow direction. WFS <br /> must include this information. <br /> 3. WFS needs to include evaluation of costs for the preparation of and annual fees for Waste <br /> Discharge Requirements, which would be needed for, but not limited to, the injection of <br /> extracted/treated groundwater, zero valent iron, HRC®, soybean oil, and chitin. <br /> 4. Table 4 of the Report lists detection limits for various constituents. The practical <br /> quantitation limits should be verified with Department of Health Services Division of <br /> Drinking Water and Environmental Management and Policy for Implementation of Toxics <br /> Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California lists. <br /> These lists can be found at: <br /> www.dhs.ca.gov/ps/ddwem/publications/download/storlist.xls <br /> www.swreb.ca.gov/iswp/final.pdf <br /> California Environmental Protection Agency <br /> p�a Recycled Paper <br />