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r ' <br /> i <br /> '*?dike Infurna [EH] <br /> From: Jim Barton obarton@waterboards.ca.gov] <br /> Sent: Monday, September 26, 2011 10:05 AM <br /> To: Jenny Weese <br /> Cc: Liz Emmons; Ezariallona; Ray Kablanow; Adrienne Ellsaesser [EH]; Mike Infurna [EH]; Nuel <br /> Henderson [EH] <br /> Subject: Re: JM Equip NOI/WDR <br /> Attachments: Draft MRP submitted w NOI draft final 9-26-11.doc <br /> Draft MRP <br /> ibmitted w NOI draf <br /> Hi Jenny, <br /> the purpose of the NOI and draft MRP were to determine whether a permit is needed for the <br /> injections. This is in lieu of issuing a permit, which could take another 60 days and require a fee <br /> (currently being increased from $2560 per year). I do realize that funding is an issue here, so I am <br /> willing to modify your requests to the minimum necessary to ensure water quality is protected. <br /> The background data did not include baseline groundwater sampling for all listed constituents. The <br /> fact that cadmium, mercury, and molybdenum were non-detect, and lead was 3.6 ppb in soil does not <br /> necessarily correlate to an expected groundwater concentration when oxidization occurs. Therefore <br /> the entire B list of metals in the draft MRP will be analyzed from the background well prior to <br /> injections, and the treatment wells will be likewise sampled for the entire B list at the first sampling <br /> event after the injections . If the metals are not detected at detection limits comparable to the water <br /> quality goals, then those metals may be deleted from future sampling. <br /> The other request to do the first sample event after 3 months of injections does not provide data <br /> necessary to evaluate whether the reactions are producing secondary impacts to groundwater, which <br /> usually occur rapidly. And unanticipated metals reactions have been documented in nearby sites <br /> (see Circle K in Lathrop) after the injections. <br /> Therefore the first sampling event after the injections will occur at one month. When that data is <br /> available to you, I will need an email with the data attached to evaluate the first month results. If <br /> there are no impacts, then I will approve the second event at 3 months after the first event, and <br /> likewise, if not impacted again, approve sampling at 6 months after the second event. This sampling <br /> is strictly for evaluating the need for a permit, and any changes to routine monitoring are to be <br /> approved by the lead regulatory agency. <br /> If you respond and agree to the requirements in the draft MRP (attached), then you have approval to <br /> proceed with the pilot study, pending further evaluation for need for a permit. <br /> Thanks. <br /> Jim Barton <br /> James L.L. Barton, P.G. <br /> Engineering Geologist <br /> California Regional Water Quality Control Board Central Valley Region, 11020 Sun Center Drive, <br /> Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 <br /> 1 <br />