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EvmMnu 6. Bemwn JN. <br /> - az v.e.noR <br /> NVIR w Rvovn,vuez <br /> GNV RDNMGNiN VREiGEi1EN <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board VED <br /> OCT 08 2014 <br /> 7 October 2014 <br /> ENVIRONMENTALHEALTH <br /> PERMITISERVICES <br /> Mr. John Parker <br /> P.O. Box 1692 <br /> Manteca, CA 95336 <br /> COMMENTS ON NOTICE OF INTENT, BOULEVARD AUTOMOTIVE SERVICE, <br /> 2151 COUNTRY CLUB BOULEVARD, STOCKTON, SAN JOAQUIN COUNTY, <br /> LUSTIS No. 390044 <br /> California Regional Water Quality Control Board (Central Valley Water Board) staff <br /> reviewed the 25 August 2014 Notice of Intent (NOI) and Monitoring and Reporting <br /> Program (MRP) submitted by Advanced GeoEnvironmental, Inc., (AGI) for the subject <br /> site. AGI submitted the NOI to apply for coverage under Waste Discharge <br /> Requirements General Order R5-2008-0149 General Waste Discharge Requirements <br /> for In-Situ Groundwater Remediation at Sites with Volatile Organic Compounds, <br /> Nitrogen Compounds, Perchlorate, Pesticides, Semi-Volatile Compounds and/or <br /> Petroleum Compounds (General Order). AGI proposes to conduct in-situ chemical <br /> oxidation (ISCO) by injecting hydrogen peroxide solution into the subsurface to <br /> remediate petroleum contaminants at the site. The NOI was not complete and <br /> additional information is needed before Central Valley Water Board staff can concur <br /> with the proposed injection project. <br /> Central Valley Water Board staff has the following comments: <br /> 1. On Page 28 of the RAP, AGI proposes to conduct four tri-weekly ISCO applications <br /> utilizing wells MW-1A/B, DPE-1, DPE-2, MW-2, MW-3, MW-4, MW-9, MW-15, <br /> MW-17 and sixteen proposed injection wells. According to Tables 1A and 1B of the <br /> MRP, the monitoring wells (MWs) are also proposed to be used to monitor the <br /> effectiveness of the ISCO applications. <br /> Utilizing the monitoring wells for the ISCO applications will alter the data from the wells <br /> making them unsuitable for evaluating water quality in the aquifer. During the <br /> remediation process, the monitoring wells should only be used to monitor the progress <br /> and effectiveness of the ISCO applications. <br /> 2. In the NOI, you propose using MW-9 and MW-17 as transition zone wells and <br /> MW-7 and MW-19 as compliance zone wells. Based on groundwater elevation <br /> contour maps, the transition zone wells appear to be cross-gradient of the <br /> groundwater flow direction, and compliance zone wells are approximately 180 feet <br /> KARL E. LONOLEY ScD, P.E., c.Aie I PAMELA G GnEEDON P.E., BCEE, LXECOTIVE ornc6n <br /> 11020 Sun Center Drive#200,nencho C.,d*va,CA 95670 1 www,wator oar .va.gov/ventrelvalley <br /> 0 ReerEiev rAree <br />