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James L.L. Barton, P.G. <br /> Engineering Geologist <br /> California Regional Water Quality Control Board Central Valley Region, 11020 Sun <br /> Center Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 <br /> fax (916) 464-4704 <br /> >>> Daniel Villanueva <dviIlan ueva@advgeoenv.com> 11/14/2011 12:13 PM <br /> Mr. Barton, <br /> AGE provides the following response to your comments below: <br /> 1) AGE will be taking protective health measures by initially diluting the oxidizer with <br /> water, than diluting the acid-oxidizer solution down to a 5% solution. All mixing will be <br /> done outdoors, diluting any potential adverse reaction, which may occur during <br /> preparation. The final above ground solution will be in such a form that it is very <br /> unlikely that chlorine gas will be produced due to the diluted nature of the prepared <br /> media; further, chlorine in the public water supply should be absent or at a minimum, <br /> thus reducing the potential for chlorine gas production. <br /> 2) If necessary, prior to performance of the field scale test, onsite tap water would be <br /> sampled and evaluated for chlorine. Results could be used to evaluate the potential of <br /> any adverse chlorine gas production. <br /> 3) To further protect the safety of the onsite AGE representative during mixing and <br /> injecting of the solution, level C personal protective equipment will be used, which will <br /> include the use of an air purifying respirator, rubber gloves, eye goggles and a full face <br /> shield. <br /> 4) AGE has previously performed similar pilot test injections at the Davis Texaco site <br /> located at 2002 Lyndell Terrace, Davis, California. During mixing and injection <br /> activities, AGE did not experience any adverse effects that would prevent proposing <br /> such work at the Boulevard Auto site. Findings from the AGE-prepared, In-Situ <br /> Chemical Oxidation Pilot Study Report, dated <br /> 06 October, 2010, can be referenced on the California state Geotracker website. <br /> Should you have any further question or concerns, please do not hesitate to contact <br /> me. <br /> Best Regards, <br /> Daniel Villanueva <br /> Staff Geologist <br /> z <br />