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,l'• t.' j ,{ .� 1 Eu.u.0 G. BRuw JR GOr¢Rt10R MAnnEvf C A l 1 I O n R 1 A fiKc AR rR0OC1el0UE2 WaterBoards EIHIRORMEIIN,t PPOIEC TIOR Central Valley Regional Water Quality Control Board i� NCIV j �i 20 ) 7 November 2014 Mr. Donald Rodgers 11900 South Union Road Manteca, CA 95336 IN-SITU CHEMICAL OXIDATION PILOT TEST WORK PLAN, THE TRANSMISSION STORE, 515 WEST CHARTER WAY, STOCKTON, SAN JOAQUIN COUNTY, CASE# 30891 California Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) staff reviewed the 28 May 2014 In -Situ Chemical Oxidation Pilot Test Work Plan (the Work Plan) submitted by Advanced GeoEnvironmental, Inc (AGE) on your behalf for the underground storage tank (UST) release at 515 West Charter Way in Stockton (the Site). The Site is a currently an automotive service and tire sales facility. In the Work Plan, AGE provides a summary and evaluation of potential remedial approaches to address residual petroleum hydrocarbons in soil and groundwater beneath the Site. Based on Site conditions and concentrations of residual petroleum hydrocarbons, AGE recommends completing a pilot test to evaluate the efficacy of injecting hydrogen peroxide as a remedial approach for the Site. AGE proposes injecting a 5% solution of hydrogen peroxide and water into the Site's shallow and intermediate water -bearing zones using the following injections wells: • Shallow (0 to 50 feet below ground surface [bgs]): VW -1 D, VW -21D, VW -3D, MW -4R -S • Intermediate (50 to 70 feet bgs): SP -1, SP -6, SP -7, MW -91, and MW -101 AGE proposes completing three injection events, each of which will include 200 -gallons of 5% hydrogen peroxide and water solution injected at 30 pounds per square inch of pressure across the eight proposed wells. AGE proposes completing these injection events on a biweekly basis. Prior to initiating the injection events, AGE proposes completing background monitoring and performance monitoring in the eight proposed injection wells for petroleum hydrocarbons and potential adverse oxidation byproducts (e.g., mobilization of hexavalent chromium). Central Valley Water Board Staff conditionally concurs with the scope of work presented in the Work Plan. However, Central Valley Water Board staff request that the following be submitted prior to implementation: Prior to initiating the proposed scope of work, a contingency plan must be submitted to the Central Valley Water Board for review and concurrence. The contingency plan must include corrective actions for addressing potential mobilization of adverse byproducts of the injection event. The contingency plan must have established background concentrations for hexavalent chromium and bromate as well as proposed action levels that will trigger the contingency plan. KAnL E. LONGLEY SCD, P.E., CIlAIn I PAMELA C. CnEE0014 P.E., BCEE, Execumc orrlcen 11020 Sun Center Drive 11200. nancho Cordova, CA 95670 I www.waterboards.ca.gov/centralvalley C,y nrc. ciao rarer.