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,olCalifornia Rlional Water Quality coontrol Board <br /> :000/ <br /> Central Valley Region <br /> Robert Schneider,Chair Arnold Schwarzenegger <br /> Terry Tam (-, _ . Governor <br /> Secretary C D 11020 Sun CenterDrive 4200 Rancho Cordova,CA 95670-6114 <br /> Environm t (916)464-3291•Fax(916)464-4704 <br /> Protection hnp://w".swreb.ca.gov/mgcb5 <br /> NOV <br /> 22 Ni ii12004 n °.LTH <br /> ERMIT/SERVi1L; <br /> Mr. Cecil Dillon Mr, Richard Bokides Mr.Navtej Dbingsa <br /> Flag City Ltd. Partnership Bokides Family Ltd. Partnership First Investment Flag City, Inc. <br /> 1820 W. Kettleman Lane, Suite E P.0 Box 1411 5517 Coronawood Lane <br /> Lodi, CA 95242 Woodbridge, CA 95258 Carmichael, CA 95608 <br /> REVIEW, FLAG CITY CHEVRON, 6421 CAPITOL AVENUE, LODI, SAN JOAQUIN COUNTY, <br /> CLEANUP AND ABATEMENT ORDER (C&A) NO. 5-00-700 - <br /> I reviewed the Evaluation of Additional Remedial Alternatives (Report), received 15 November 2004, <br /> submitted on Chevron's behalf by Advanced GeoEnvironmental, Inc (AGE). In-situ Air Sparging, In-situ <br /> Ozone Sparging(IOS), Bioremediation/Bioenhancement, and Natural Attenuation were evaluated as <br /> additional remedial alternatives as requested by Regional Board staff in a Letter dated 13 August 2004. In <br /> the Letter,the Regional Board Executive Officer approved the shutdown of the groundwater pump and <br /> treatment system, which occurred on 17 August 2004. As the final remediation, the Report proposes: <br /> 1. "Performance of ozone bench-scale testing to evaluate whether or not an IOS remediation <br /> technology would negatively impact the subsurface environment at the site. " and <br /> 2. "Preparation of an addendum (Addendum) to the Final Remediation Plan (FRP) (dated 31 August <br /> 2000), to detaining the proposed installation and operation of the IOS system. This workplan <br /> should include the installation of sparging points, sparge wells and ozone generator. " <br /> I concur to your proposal to evaluate IOS. The Addendum FRP Workplan for a full-scale IOS remediation <br /> requires successful completion of an IOS bench scale test (BST) and/or an IOS Pilot Study. Please submit an <br /> IOS Workplan describing a BST and a Pilot Study, to include the following: <br /> 1. A schedule for the Workplan, fieldwork, laboratory (BST) work, a Geochemical Evaluation (GE) <br /> Report signed by a Chemist or similarly credentialed professional, and a Pilot Study Workplan and <br /> Pilot Study Report. <br /> 2. Laboratory protocol for conducting the BST. The protocol must also include the following decision <br /> tree: <br /> a. AGE must collect and analyze at least one representative soil and groundwater sample from the ozone <br /> injection target zone at the site. Laboratory Detection Limits must be sufficiently low to allow <br /> comparison to the Water Quality Goals,which may be downloaded at our website at <br /> http://www.swrcb.ca.gov/Mcb5/available docimients/index html#WateroualitvGoals. <br /> Analyses shall include CAM 17 metals and Chromium 6+, and General Minerals suite (including <br /> sulfate,nitrate, etc.). The GE Report will compare the results of the soil and groundwater, and <br /> thoroughly discuss the expected worst-case scenario reactions, i.e., 100% conversion of constituents of <br /> concern into contaminants, reporting the chemical reactions in molar concentrations. <br /> California Environmental Protection Agency <br /> (a Recycled Paper <br />