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I <br /> Californiaegional Water Quality Cool Board <br /> Central Valley Region <br /> 40 <br /> Karl E. Longley,ScD,P.E.,Chair <br /> Linda S.Adams 11020 Sun Center Drive#200, Rancho Cordova, California 95670-6114 Arnold <br /> Secretary for Phone(916)464-3291 •FAX(916)464/4645 Schwarzenegger <br /> Environmental http:llwww.waterboards.ca.govlcentralvalley Governor <br /> Protection <br /> 14 January 2010 <br /> Ms. Janet Heikeld <br /> Olympian <br /> 1300 Industrial Road, Ste..2 <br /> San Carlos, CA 94070 <br /> DOCUMENTS REVIEW, JIMCO TRUCK PLAZA, 9022 EAST FRONTAGE ROAD (AKA 22502 <br /> SOUTH HIGHWAY 99), RIPON, SAN JOAQUIN COUNTY(REGIONAL BOARD CASE#390798) <br /> I reviewed the schedule for the Additional Site Assessment(Schedule) and the Response to Request <br /> forAdditional Information (Response), received 11 December 2009 and X30 December 2009, <br /> respectively in emails from your consultant, Conestoga-Rovers and Associates. The documents were <br /> submitted in response to my letter dated 10 November 2009, which requested additional information on <br /> the Bench Scale Testing (BST) Workplan contained in the Corrective Action Plan. The Response <br /> states bench scale testing will evaluate using hydrogen peroxide and sodium permanganate as injected <br /> In- <br /> chemicals, and that the Notice of Intent(NOI)for Waste Discharge Requirements, General Order for In- <br /> Situ Groundwater Remediation at Sites with Volatile Organic Compounds, Nitrogen Compounds, <br /> Perchlorate, Pesticides, Semi-Volatile Compounds, Hexavalent Chromium and/or Petroleum <br /> Hydrocarbons (General Order No. R5-2008-0149) will be submitted after completion of the BST. The <br /> BST will be conducted after submittal of the proposed Schedule 3,1 July 2010 Additional Site <br /> Assessment Report. Free product, when encountered in wells, will be bailed and reported in quarterly <br /> monitoring reports. Quarterly injections for two years and installation of'permanent injection wells are <br /> tF <br /> appropriate, based on the conceptual design for the proposed treatment. <br /> Comments: <br /> The BST Workplan is approved. However, the six months delay for initiating the BST is unacceptable, <br /> since evaluation of the proposed BST technologies is not dependant upon the results of the further <br /> investigation to delineate the extent of contamination. Please revise the Schedule to begin BST by <br /> 1 April 2010. Soil and water samples forthe BSTshall be collected during the Additional Site <br /> Investigation drilling scheduled for March 2010. The Bench Scale Testing report, NOI for General <br /> Order No. R5-2008-0149, and a pilot study workplan are due 1 June 20.'10. The Additional Site <br /> Investigation Report may be submitted on, or before the Schedule 31 July 2010 date. <br /> Be advised that General Order No. R5-2008-0149 requires that the NOI,include a technical justification <br /> for injection of a salt increasing chemical (sodium persulfate) intolan aquifer, when there are other <br /> chemicals (hydrogen peroxide, etc.) available that do not cause increases in salinity of the aquifer. And <br /> F <br /> since there is an onsite domestic well (DW-1) surrounded by the underground storage tanks plume, the <br /> NOI required contingency plan must be able to reverse all impacts to DW-1 in a very short period of <br /> time. Also note that the US Environmental Protection Agency does not recommend injecting sodium <br /> persulfate near drinking water wells, due to potential increases in sulfate levels that may exceed 250 <br /> milligrams per Liter, which is the Taste and Odor Threshold (Secondary',Maximum Contaminant Level <br /> and a Regional Water Quality Control Board - Central Valley Region Water Quality Goal). The NOI <br /> I� � <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br />