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CaliforniVegional Water Quality Cowl Board <br /> Central Valley Region <br /> d <br /> Karl E. Longley,ScD,P.E.,Chair <br /> Arnold <br /> Linda S.Adams 11020 Sun Center Drive 92O0,Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Secretaryfor Phone(916)464-3291 •FAX(916)4644645 Govemor <br /> Environmenml http://www.waterbouds.ca.gov/centralvalley <br /> Protection j-H��-,...y� �� <br /> 18 December 2008 HE <br /> 2 2008 <br /> ENVIRONMENT HEALTH <br /> Mr. Dale Gillespie PERMIT/SERVICES <br /> Geweke Land Development and Marketing <br /> PO Box 1210 <br /> Lodi, CA 95241 <br /> DOCUMENT REVIEW, CLEANUP AND ABATEMENT ORDER (CAO) NO. 93-701, <br /> GEWEK.E PROPERTY, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY <br /> I reviewed the 10 December 2008 In-Situ Chemical Oxidation Pilot Study (Workplan) <br /> submitted on your behalf by Advanced GeoEnvironmental, Inc. (AGE) for the subject site. The <br /> Workplan contains a proposal to conduct either a six (6) month, or (up to) twelve (12) month <br /> pilot test using Oxygen Release Compound Advanced® (ORC-A) as an in-situ remedial <br /> process. Five injection points around offsite monitoring well MW-9 will be used one time to <br /> inject up to 50 pounds of slurry into each boring. The Workplan also proposes sampling wells <br /> MW-8 and MW-9 for additional parameters during quarterly monitoring, to determine the <br /> effectiveness of the testing and to identify if any adverse subsurface conditions are created <br /> that may require mitigation. <br /> Please note that the Regional Board has recently adopted General Order R5-2008-0149 that <br /> regulates the type of action being proposed (ORC-A injection). Further, that said General <br /> Order also addresses bench scale testing as well as pilot testing. In that the proposed actions <br /> were in consideration well before the General Order was adopted, I am seeking advice <br /> regarding the applicability of being allowed to perform those pilot tests in the works prior to the <br /> adoption of the General Order without the issuance of said General Order. In that it may take <br /> a number of weeks before I am responded to, and in order to protect water quality and ensure <br /> that human health and safety is achieved, you are to proceed with the proposed pilot testing <br /> as soon as possible with the below noted modifications. Once I have received the information <br /> I am seeking and based upon the results of the pilot testing, a permit issued (as applicable) <br /> pursuant to the said General Order will be discussed with your environmental consultant AGE. <br /> In light of the above your proposed pilot testing is determined to be reasonable and tentatively <br /> approved with the following modifications: <br /> 1. You are to report results of the pilot study quarterly for two quarters, and to complete <br /> the pilot study in six (6) months. The final report of the results is to be submitted in the <br /> second quarter 2009 monitoring report, which is due 1 August 2009. <br /> 2. For purpose of monitoring the pilot test you are to use monitoring wells MW-8, MW-9, <br /> MW-10, MW-11, and MW-12 for all pilot study analyses, and sample said wells <br /> California Environmental Protection Agency <br /> Qd Recycled Paper <br />