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Fmr. Unocal . - 2 - 24 January 2008 Fmr. Montgomery Wards 5400-5606 Pacific St., Stockton • Submit a tentative schedule with dates for the proposed fieldwork and reports, so that 1 may input the proposed work into Geo Tracker as milestones to be completed. • Add Regional Board staff to the list of recipients for the well installation activities report. Appendix 8, Section 4.0 Schedule currently lists only the California Department of Water Resources and the San Joaquin County Environmental Health Department (SJCEHD) as recipients of that report. All reports are to be submitted in paper copy to this office, as well as electronically to GeoTracker (Appendix 8 Section 3.6). • Give the SJCEHD and myself at least 3 working days notice for start of fieldwork. The Addendum memorandum provides an adequate explanation of the criteria evaluated by ENSR to determine that the AS/SVE needs a major redesign, and shows that wells of the existing AS/SVE treatment system were not operating correctly or may not be connected to the system. The Addendum also addresses my prior concerns and provides the requested information for the Workplan. However, I have additional comments based on my review of the Addendum and the requirements of CAO No. 5-00-0707. Additional Comments: 1. The Addendum schedule lists permitting as an unknown for scheduling. The new AS/SVE system needs to comply with all current local building codes so that the City of Stockton permitting process does not get bogged down and delay implementation of the restarting of the AS/SVE treatment system. The CAO No. 5-00-0707, Order #12 states the Discharger must "...Obtain all necessary local and state permits prior to beginning work. Failure to apply for any permits in a timely manner, which result in missed compliance dates, constitutes a violation of this Order, unless permitted by the Executive Officer.° • Please contact the City of Stockton, explain to them what work has been proposed, and provide their response to us in writing concerning whether permits are needed for the upgrades and whether the increased air pressure in the reused AS system (existing lines) is acceptable to the City of Stockton. • As stated above, all extensions to the schedule must be requested in writing to the Regional Board Executive Officer, with a cc: to me. • All construction delays must be reported to Regional Board staff within 24 hours by voice mail or email (my contact information is listed below). 2. The Addendum states the specified operational pressure for the air compressor for the AS portion of the treatment system is 80 to 125 psi (pounds per square inch) at 110 CFM (standard cubic feet per minute). On Sheet 4, Piping and Fitting No. 10.8, the Workplan specifies a 100 psi test of the lines with no pressure loss for one hour. Considering pressure losses due to friction in the piping will reduce air pressure at the wells, does the design of the piping allow pressures exceeding 100 psi, or will the