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. y � • <br /> EnvTT-E ORoonancnox <br /> Mnnxcw Roonmuez <br /> Water Boards v <br /> Central Valley Regional Water Quality Control Board <br /> 11 July 2013 <br /> Mr. Joe Niland <br /> Geosyntec <br /> 3043 Gold Canal Drive, suite 201 <br /> Rancho Cordova, CA 95670 <br /> COMMENTS ON IN-SITU CHEMICAL OXIDATION PILOT TEST WORK PLAN AND NOTICE <br /> OF INTENT APPLICATION FOR COVERAGE UNDER THE WASTE DISCHARGE <br /> REQUIREMENTS GENERAL ORDER FOR IN-SITU GROUNDWATER REMEDIATION <br /> (ORDER NO. R5-2008-0149)—LINCOLN VILLAGE SHOPPING CENTER, STOCKTON, SAN <br /> JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff has <br /> reviewed the report titled In-situ Chemical Oxidation Pilot Scale Test Work Plan (Work Plan) <br /> dated 15 May 2013 and the Notice of Intent (NOI) application for coverage under the Waste <br /> Discharge Requirements General Order for In-Situ Groundwater Remediation (Order No. R5- <br /> 2008-0149). The Work Plan and the NOI application were submitted by Geosyntec Consultants <br /> on behalf of Lincoln Center Environmental Remediation Trust (Trust). <br /> Previously submitted environmental documents indicate that the main constituents of concern <br /> (COCs) in the groundwater at the Site are tetrachloroethylene (PCE) and its degradation <br /> products trichloroethylene (TCE), and 1,2-dichloroethylene (cis and trans 1,2-DCE), collectively <br /> referred to as chlorinated volatile organic compounds (cVOCs). As part of the cleanup strategy <br /> for the Site, the Trust has proposed to implement an in-situ chemical oxidizing (ISCO) injection <br /> program to treat cVOC impacted groundwater. <br /> The Work Plan proposes to test the efficacy of ISCO by introducing a potassium permanganate <br /> (KMn04) product in four dual-nested injection wells (eight wells total) spaced approximately 40 <br /> feet apart. The injections will be multi-depth at 35-45 feet below ground surface (bgs) and 65- <br /> 75 feet bgs. Each injection well will have a 10 foot screening interval. An estimated 12,000 <br /> gallons of KMn04 will be injected into each well. Three dual-nested groundwater monitoring <br /> wells (six total) and one single completion B-zone well (approximately 110 feet bgs) will be <br /> installed to monitor the efficacy and mobility of the injections. Additional existing groundwater <br /> monitoring wells will be used to determine up-gradient and down-gradient KMn04 transport. All <br /> monitoring wells will be sampled and analyzed in accordance with an approved Monitoring and <br /> Reporting Program as required by Waste Discharge Requirements General Order R5-2008- <br /> 0149- <br /> Based on our review of the Work Plan, the Central Valley Water Board staff concurs with the <br /> scope of the Work. Since the Trust has already submitted a NOI application with the associated <br /> fee of$3,422, Central Valley Water Board staff will now begin working with the Trust to prepare <br /> a draft Fact Sheet along with a Notice of Applicability (NOA) and Monitoring and Reporting <br /> KARL E. LONGLEV SCD, P.E.,CHAIR I PAMELA C. CAEEDON P.E., BCEE,EXECUTIVE OFFICER <br /> 11020 Sun Center Drive 11200,Rancho COHIOV ,CA 95670 1 www_waterboards.ca.gov/Centralveney <br />