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San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> Donna Heran, REHS <br /> Q: y� 600 East Main Street <br /> Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> Robert McClellon, REHS <br /> Jeff Carruesco, REHS, RDI <br /> Website: www.sjgov.org/ehd Kasey Foley,REHS <br /> 4��FOR <br /> Phone: (209) 468-3420 <br /> Fax: (209) 464-0138 <br /> March 3, 2010 <br /> Mr. Weldon Church <br /> 1958 Yosemite Road <br /> Berkeley, California 94707 <br /> Subject: Weldon Church Property <br /> 104 West Beverly Place <br /> Tracy, California 95376 <br /> Dear Mr. Church: <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed In-Situ <br /> Chemical Oxidation Pilot Test Work Plan, dated December 2, 2009, prepared by Advanced <br /> GeoEnvironmental, Inc. (AGE) on your behalf for the above-referenced site. Included in the <br /> work plan was a letter dated October 15, 2009, sent by James Barton, PG, stating that the <br /> California Regional Water Quality Control Board, Central Valley Region (CRWQCBCVR) <br /> has determined that the proposed pilot study will require a Waste Discharge Requirements, <br /> General Order for In-Situ Groundwater Remediation at Sites with Volatile Organic <br /> Compounds, Nitrogen Compounds, Perchlorate, Pesticides, Semi-Volatile Compounds, <br /> Hexavalent Chromium, and/or Petroleum Hydrocarbons (General Order) prior to injection of <br /> RegenoxTM. Upon reviewing the General Order and determining that the pilot study will <br /> meet the requirements of the General Order, you should submit a completed application and <br /> associated fee to the CRWQCBCVR for the General permit rior to submitting the work <br /> plan, with appropriate revisions, to the EHD. Mr. Barton also stated that the CRWQCBCVR <br /> requires a thirty-day public notice (Notice of Applicability letter) prior to issuance of the <br /> General Order and prior to conducting the work. <br /> In the pilot test work plan, AGE proposes to inject five percent RegenOxTm at five discrete <br /> injection points located approximately seven feet from a proposed monitoring well as <br /> illustrated in Figure 2 to assess the effects of in-situ chemical oxidation (ISCO) to remediate <br /> petroleum hydrocarbon contamination in soil and groundwater at the above-referenced site. <br /> A second injection of five percent RegenOxTM is proposed two weeks after the initial <br /> application, followed by a third injection of five percent RegenOxTM two weeks after the <br /> second application. Each application of RegenOxTM will be injected into discrete boreholes <br /> surrounding the proposed monitoring well. AGE proposes to inject two separate volumes of <br /> RegenOxTM into each borehole since two subsurface lithologies have been identified by <br /> AGE (clay from approximately five to twelve feet bsg, and sand with silt from approximately <br /> twelve to twenty-five feet bsg). AGE proposes to inject RegenOxTM from five to twenty-five <br /> feet bsg using a van-mounted geoprobe followed by backfilling the borehole with type II, or <br /> equivalent, portland cement. AGE proposes to monitor and sample groundwater collected <br />