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Mike Infurna [EH] <br /> From: Jim Barton [jbarton@waterboards.ca.gov] <br /> Sent: Tuesday, November 15, 2011 8:30 AM <br /> To: Daniel Villanueva <br /> Cc: Robert E.Marty, Tim Cuellar; wlittle@advgeoenv.com; Mike Infurna [EH]; Nuel Henderson <br /> [EH] <br /> Subject: RE: Boulevard Automotive Service: 2151 Country Club Boulevard, Stockton, CA- ISCO Pilot <br /> Study Work Plan Response <br /> Hi Daniel. <br /> My main safety concern was with the mixing of HCI and an oxidizer (H2O2) which <br /> could release chlorine gas if present in a higher concentration than proposed, not the <br /> chlorine in the tap water. Additional water testing for chlorine is not necessary. <br /> Please submit the Notice of Intent (NOI, or injection permit application) as a signed <br /> document and a draft Monitoring and Reporting Program (MRP) as an MS Word <br /> document for my review and editing. AGE has several approved NOls and MRPs to <br /> use as templates. <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 <br /> Center Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 <br /> fax (916) 464-4704 <br /> >>> Daniel Villanueva <dvillanueva@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 />