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Mr. Kevin McKibben - 2 - 13 Maroh 1998 Advanced GeoEnvironmental, Inc. a defined treatment zone and an estimated project length; characterization of the groundwater in and around the treatment zone, including specific conductivity, fixed and volatile TDS, pH, nitrogen compounds, and contaminant concentrations; the amounts and concentrations of ammonium nitrate and hydrogen peroxide to be injected into the treatment zone; the calculations used to arrive at those amounts and concentrations; approximate beginning and ending concentrations for both contaminants and nutrients; a monitoring plan which will provide early detection of any migration of nitrogen compounds outside the designated treatment zone. This proposal should include number, placement, and construction details of the monitoring wells, specific constituents to be monitored, and frequency of monitoring. a specific response plan to remediate any groundwater pollution or nuisance caused by this in-situ cleanup project. The meaning of the terms "pollution" and "nuisance" are as defined in Section 13050 of the California Water Code (see enclosed excerpt). Staff needs several months lead-time to write and adopt WDRs, and they must be in place before you can begin discharging. Further, all the requirements of CEQA must be met before we can issue waste discharge requirements. Since we will be the lead agency for CEQA, it would be most efficient if the Initial Study and the RWD are submitted at the same time as companion documents. Please feel free to contact me at(916) 255-3024 if you have any questions regarding these matters. . / Q CHRISTINE M. HOLM Associate Engineer CMH:cmh Enclosures cc (w/o encl): Mr. Mike Huggins, San Joaquin County Environmental Health Division, Stockton Ms. Elizabeth Thayer, Regional Board Underground Tank Unit, Sacramento