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California Regional Water Quality Control Board Central Valley Region lefos'Litminen Robert Schneider,Chair 0Arnold Schwarzenegger ryfor 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 Governor Environmental (916)464-3291- Fax(916)464-4704 Protection http I/www sws b ca guv/rwgcb5 13 May 2004 OPY ' y �. X Mr Robert Cochran Ivern and Roger Baffont ' Chevron Environmental Management Company 1175 Orangewood Drive P O Box 6012 Lodi, CA 95240 San Ramon, California 9458 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 Infection Work Plan (Workplan),each ' received 15 April 2004, submitted on behalf of Chevron Products Company and Ivern 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 'ifthe Workplan states there is a need for a more aggressive treatment for the A-zone contaminants around a hot pot 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 tertbutyl 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(H20sS.2K) first,to be followed by hydrogen peroxide (H202) mjection 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 infection proposal The Workplan is not approved at this time 0 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/rnsds/englishhtmVH4065 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 H202 solution into the aquifer, namely all anticipated interactions, including valence changes for metallic ions (i e , oxidizing naturally occurring Cr 3+ to toxic Cr6+) The ' study must also include California Environmental Protection Agency p� Recycled Paper