SITE INFORMATION AND CORRESPONDENCE FILE 2

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Former Boulevard Automotive �,, _2 - 2151 Country Club Blvd. 7 October 2014 from the treatment zone. Transition zone wells should be located between the treatment and compliance zones to assess constituent reactions down-gradient of the treatment zone before reaching the compliance wells. In addition, the compliance zone wells should be located at a reasonable distance downgradient of the treatment zone to ensure breakdown products generated or mobilized from the ISCO reactions do not exceed water quality objectives and groundwater limitations. With the proposed compliance wells MW-7 and MW-19 over 100 feet from the site, site lithology consisting of silty clay, and calculated conservative flow rates of 6 to 10 feet per year in the shallow and intermediate zones, groundwater constituents from the ISCO reaction potentially may not be observed in the compliance wells for 10 to 16 years'. Central Valley Water Board staff is concerned that the proposed compliance zone wells are too far from the site to provide useful data in determining if water quality objectives and groundwater limitations are exceeded. According to the General Order, a contingency plan is required to be implemented to correct unacceptable water quality effects from ISCO applications. Other than a note below Table 1 B in the MRP indicating that ISCO injections will cease and impacted monitoring wells will be monitored monthly should adverse conditions occur, a contingency plan was not included in the NOI. The contingency plan should describe in detail actions that will be taken to bring any constituents exceeding WQOs and limitations from the ISCO injections back into compliance with the requirements of the General Order. 3. The ISCO treatment and monitoring zones proposed in the MRP do not match those depicted on the MRP's Figure 2. The correct zones should be correctly identified and depicted on a revised figure. Based on Central Valley Water Board staffs review of your NOI, you are to conduct the following: • Determine the groundwater flow direction and rate and identify or install transition and compliance zones wells that are closer and downoradient of the treatment zone. A work plan will be required to install new wells. Exclude monitoring wells as proposed ISCO injection points, and properly identify the wells and zones in an amended NOI and MRP. • Include in the amended NOI a contingency plan that describes detailed corrective actions that will be implemented if violations of the General Order are observed at the compliance wells. You submitted a check for $1,097 with your General Order application; however, for fiscal year 2014/2015 the base fee with surcharge for coverage under the General Order has increased to $4,581. Please submit an additional check for the balance to ' Freeze,Allan R. and John A. Cherry, Groundwater. Englewood Cliffs: Prentice-Hall, 1979. Print