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Staliworth Auto Detail December 15, 2011 602 Califomia Street page 2 I h Also of consideration is control of the displacement of the groundwater that will occur as a result of the injection . Few of these factors were addressed or adequately discussed in the Study. Please proceed with submittal of a detailed Pilot Test Work Plan that addresses the following concerns: �1 . Is the ISCO remediation proposed to be hydrogen peroxide or Fenton's Reagent? \ If it is strictly hydrogen peroxide , please explain the role/need of the muriatic acid . "F If Fenton's Reagent is to be used , please provide detailed information on the application rates and concentrations. The Guidance notes that the two reagents, hydrogen peroxide and iron catalyst must be injected separately, either sequentially or concurrently, so they may mix at the end of the well or borehole. Provide process and calculations used to determine the concentration and amount 3 ' of the proposed reactants that will be needed for the pilot test: The stoichiometric demand of the contaminant mass targeted for treatment and the oxidant demand of the natural conditions must be factored in to this . Baseline iron content in the groundwater should also be taken into consideration to determine the dosing requirement. 4\ If Fenton's Reagent is to be used , note that the addition of acid is necessary to �ei1 ( 611, start the reaction only, and should not be administered through out the test. If acid is to be used , baseline alkalinity measurements must be taken to determine the amount of acid that would be necessary to reduce the pH level to the appropriate level to maintain solubility of the iron . Hydroxyl radicals may also be scavenged in the presence of highly alkaline water, so this needs to be known to determine the amount of reactants needed. 6. Establish a field monitoring and sampling program that will adequately monitor the dispersion of the oxidant and the effectiveness of the treatment in three dimensions. A sufficient number of monitoring wells should be utilized , at differing distances from the injections points , to track dispersion of the oxidant and collect adequate monitoring data. The work plan is due for submittal to the EHD no later than February 10, 2012. If you have any questions or comments please contact Lori Duncan at (209) 468-0337, or by email at Iduncan@sjcehd.com . Lori Duncan , REHS Nuel C. Henderson , Jr. , PG Senior Registered Environmental Health Specialist Engineering Geologist c: Jim Barton , CVRWQCB , 11020 Sun Center Drive #200, Rancho Cordova CA 95670 Ally Colavita , AGE, 837 Shaw Road , Stockton CA 95212