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! 7906 N. EI Dorado St., Stockton Page 2 of 2 The proposal to inject oxygen into the subsurface must be evaluated by the Central Valley Regional Water Quality Control Board (CVRWQCB) for waste discharge requirements (WOR) before the EHD can approve your recommendation . Please contact Mr. James Barton of the CVRWQCB at (916) 464-4615 for work plan submittal requirements for bench scale testing prior to oxygen injection . After the CVRWQCB has determined WDR, the EHD will comment on your plan to inject oxygen . The EHD cannot approve the periodic injection of oxygen into the subsurface at this time. In preparing your proposals for this site the EHD directs that you also evaluate the site for lateral and vertical delineation of the plume . Existing monitoring and vapor wells (containing ground water) that repeatedly have petroleum constituents in the ground water samples cannot be used as points to support conclusions that the plume is laterally and vertically defined. Wells that are at the perimeter of the site and contain contaminated ground water do not provide lateral definitions of the plume. Additional wells that have screens in the same interval are required for groundwater delineation . Wells that have deep screens and have contaminated ground water consistently detected cannot be used for vertical definition conclusions. Please continue to investigate (install monitoring wells) to define the lateral and vertical extent of 1 ,2-DCA, MtBE and GRO in all areas where the most lateral wells consistently detect petroleum in the ground water samples and at depths where the wells with the deepest screened interval continue to detect contamination in the ground water samples. A work plan for this continued investigation is due at the EHD by February 15, 2007. The EHD noted errors in the Report and SCM submitted to Geotracker. As a result, the EHD denied the Geotracker submittal on January 8, 2007 . The errors were discussed with your consultant who will make corrections and resubmit the document for the EHD to review. Thank you for your cooperation during this review process. If you have any questions, you may contact Michael Infurna at (209) 468-3454. Donna Heran , RENS , Director Environmental Health Department Al" AZ Michael J . Infurna Jr. , Senior REHS Margaret Lagorio, REHS LOP ! Site Mitigation Unit IV Program Coordinator, Unit IV MI / cc: CVRWQCB — J . L . Barton , Sacramento. SWRCB—CUF — Mark Owens, Sacramento. SECOR — Kristin Shelton 3017 Kilgore Rd #100, Rancho Cordova 95670