Laserfiche WebLink
Ake Infurna [EH] <br /> From: Jim Barton pbarton@waterboards.ca.gov] <br /> Sent: Thursday, September 21, 2006 8:00 AM <br /> To: Mike Infurna [EH] <br /> Cc: Nuel Henderson [EH]; Richard McHenry <br /> Subject: Re: 1245 Charter Way, Stockton <br /> Attachments: benchscaletext3.DOC; General Cleanup WDR.doc <br /> ® q <br /> benchscaletexO.D General Cleanup <br /> OC(31 KB) WDR.doc(69 KB... <br /> Mike, <br /> you might preface your response by explaining that the purpose for the Bench Scale Test <br /> (BST) is greater than the proposed alternative, which is to determine if there are effects <br /> from a prior in-situ chemical oxidation test that are still impacting water quality over a <br /> year later. <br /> The BST should do the following (attachment) : <br /> 1) provide the data (Report of Waste Discharge) necessary to determine whether there are <br /> threats to water quality from the proposed treatment, <br /> 2) if impacted, provide a decay rate (time to restore water quality under natural <br /> conditions) after stopping the treatment, <br /> 3) provide concentration data over a specific time interval, to help estimate the distance <br /> from the injection that effects to water quality may be detected , and to refine the <br /> design of the monitoring program for the treatment, <br /> 3) provide results of the efficiency of the proposed method to remediate petroleum <br /> hydrocarbons, to refine the design of the injection process. <br /> In lieu of the new proposal to sample post-remediation as a substitute for the BST, I <br /> would provide GTI with an alternative, to submit a geochemical evaluation (GE) signed by a <br /> geochemist or chemist familiar with how the interaction between the oxidant and soil <br /> chemistry (using stoichiometry) affects on water quality. The GE must state that water <br /> quality will not be impacted by the treatment, and that the presupposition must be <br /> confirmed by field data. <br /> Or ask them to proceed with the BST without pre-approval from the SWRCB CUF. You might <br /> also add that the proposed cost for the rejected BST seemed much higher than known costs <br /> for BSTs at other sites, and that GTI should seek competitive bids to reduce the cost if <br /> they decide to .further pursue the BST option. <br /> The bottom line is that their proposal does not meet the Regional Board requirement for a <br /> ROWD, to determine whether the treatment will degrade water quality, which would require <br /> Waste Discharge Requirements (Permit) . <br /> GTI also should have received the draft General Permit (attached) by now. We are <br /> soliciting comments prior to bringing it before the Regional Board for adoption. Richard <br /> McHenry is the contact for the General Permit. <br /> Thanks. <br /> Jim <br /> James L.L. Barton, P.G. <br /> Engineering Geologist <br /> California Regional Water Quality Control Board Central Valley Region, 11020 Sun Center <br /> Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 <br /> fax (916) 464-4704 <br /> 1 <br />