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California PNgional Water Quality Cor*rol Board <br /> Central Valley Region <br /> Karl E. Longley, ScD, P.E., Chair ° <br /> Linda S. Adams Arnold <br /> Secretary for 11020 Sun Center Drive#200, Rancho Cordova, California 95670-6114 Schwarzenegger <br /> Environmental Phone (916) 464-3291 • FAX (916)464-4645 Governor <br /> Protection http://www.waterboards.ca.gov/centralvalley <br /> 15 October 2009 RECERVEDD <br /> Mr. Weldon Church <br /> 104 West Beverly Place QCT ` Z 2009 <br /> Tracy, CA 95376 <br /> EN�IRONT SFR SES F <br /> >aER,Nlti I <br /> DOCUMENT REVIEW, WELDON CHURCH PROPERTY, 104 WEST BEVERLY PLACE, TRACY <br /> SAN JOAQUIN COUNTY(RB CASE# 390292) <br /> 1 reviewed the Request for In-Situ Chemical Oxidation Pilot -fest (Request), received 14 October 2009 <br /> from your consultant Advanced GeoEnviron mental Inc. The Request was submitted in response to the <br /> San Joaquin County Environmental Health Department (SJCEHD) letter dated 22 September 2009, <br /> which directed you to contact the Regional Water Quality Control Board, Central Valley Region <br /> (Regional Board) for our evaluation of the need for Waste Discharge Requirements for the proposed <br /> work. The Request includes a map of the site with three proposed locations for the injection of <br /> RegenOXTM into the aquifer, and the manufacture's directions for using direct push technology to <br /> deliver the chemical oxidant (a solid mixed with a gel). The directions state the mixture has "very high <br /> activity" when treating petroleum hydrocarbons and chlorinated solvents, and recommends no higher <br /> than an 8% solution of RegenOXT"' in water. The Request also included a pilot study report from a site <br /> in Texas, which did not assess potential reactive byproducts (hexavalent chromium, bromate, etc.). <br /> Regional Board staff have determined that the proposed pilot study will require our Waste Discharge <br /> Requirements, General Order for In-Situ Groundwater Remediation at Sites with Volatile Organic <br /> Compounds, Nitrogen Compounds, Perchlorate, Pesticides, Semi-Volatile Compounds, Hexavalent <br /> Chromium, and/or Petroleum Hydrocarbons (General Order) prior to injection of Regenox"'. The <br /> General Order is available as an electronic download from the Internet at <br /> http�//www.waterboards.ca.qov/centraIvaIley/board decisions/adopted orders/general orders/r5-2008- <br /> 0149.pdf. Please review the General Order for compliance with the requirements, prior to submitting <br /> the proposed workplan to SJCEHD, and if compliant, submit a completed application with the <br /> necessary fee as directed in the permit instructions and guidance. The Pilot Study must meet the <br /> requirements of the General Order. Also, there is a 30-day public notice requirement prior to issuance <br /> of the General Order, so provide enough time to receive the Notice of Applicability letter for the <br /> General Order before conducting the work. If you have any questions, you may contact me at (916) <br /> 464-4615, or I can be reached by email at jbarton@waterboards.ca.gov. <br /> ) <br /> AMES L. L. BARTON, P.G. <br /> `Engineering Geologist <br /> cc: Ms. Victoria McCartney, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Daniel Villanueva, Advanced GeoEnvironmental Inc., 837 Shaw Rd., Stockton 95215 <br /> California Environmental Protection Agency <br /> %,I Recycled Paper <br />