SITE INFORMATION AND CORRESPONDENCE_FILE 2

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+� Eonunu G. Beuwry Jn. '"Aovfnxan �ftll- M.. Rooa..........�Wo icuez WaterBoards v `NvIaONMfxfx``xarf`r'°x Central Valley Regional Water Quality Control Board RECEIVED 19 May 2014 , ICMA`Y/2 0 20144 Jennifer Sedlachek ENVIRONMENTAL HEALTH ExxonMobil Environmental Services Company PERMIT/SERVICES 4086 Piedmont Avenue, #199 Oakland, CA 94611 NOTICE OF INTENT, FORMER EXXON SERVICE STATION #73942, 4444 PERSHING AVENUE, STOCKTON, SAN JOAQUIN COUNTY On 4 March 2014, Cardino ERI submitted a Notice of Intent (NOI) and supporting technical information (work plans and reports) to operate under Waste Discharge Requirements of General Order R5-2008-0149 (General Order) on your behalf for your site at 4444 Pershing Avenue in Stockton. The NOI describes the proposed injection of PersulfOX(D into groundwater from an injection system consisting of existing monitoring and remediation wells UVB-MW-1, UVB-MW-2, V1, V2, V4, SW1, SW2, IP 1B, IP1B, IP2A, IPA26, IP3A, IP36, PSV1, and PSV2, screened from 12 feet below ground surface (' bgs) to 45' bgs. The injection system has been designed to oxidize petroleum hydrocarbon contaminants, including methyl tertiary butyl ether (MTBE), in groundwater found between 15'-45' bgs. A bench scale test was conducted in 2006 and involved injection of a combination of ozone gas and hydrogen peroxide, with removal of resulting fugitive vapors by the soil vapor extraction system. Rebound occurred within four months, and the ozone gas and hydrogen peroxide injections were not continued. The NOI Contingency Plan addressed physical daylighting of the injected product but did not address potential adverse impacts to groundwater quality including increases in sulfate and total dissolved solids. The NOI did not include a proposed Monitoring and Reporting Program (MRP) which should provide background levels for all constituents of concern and practical quantitation limits for analyses. The NOI did not show or describe locations for the background sampling, treatment zone (monitoring, not injection), transition zone or compliance zone wells in alignment with the requirements for Operating under the General Order. Please submit a revise NOI by 30 June 2014 addressing a Contingency Plan for implementation if adverse impacts are observed in compliance wells, a proposed Monitoring and Reporting Program with map figures identifying the treatment zone monitoring wells, transition zone monitoring wells , compliance zone and background wells with rationale for their designation, and PQLs for all constituents analyses. All of the information required in Attachment B must be addressed including completion of the enclosed CEQA document. An example of an MRP (Attachment C) can be downloaded with the General Order at: KARL E. LONGLEY SEE), P.E., CnAIR I PAMELA C. CREEDON P.E., EICEE, EXECunvc orrwcn 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centra$vall.y Ir, 1Ar.