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L <br /> 7-Eleven #14117 page 2 <br /> 2725 Country Club Blvd., Stockton. <br /> COMMENTS AND CONDITIONS: (continued) <br /> • Groundwater samples and selected soil sample analyses are to <br /> include 1,2-dichloroethane (1,2-DCA), Ethylene dibromide (EDB), <br /> lead, and ethanol and methanol and, <br /> • The Central Valley Region Water Quality Control Board (CVRWQCB) <br /> has recently advised that the injection of materials into the ground <br /> water will require a Waste Discharge Requirement evaluation. <br /> Please contact James Barton at (916) 464-4615 and ascertain if he <br /> has concerns with this proposal or if he can issue a waiver to the <br /> WDR requirements. When EHD has been advised of the CVRWQCBs <br /> decision, the oxygen injection-testing proposal can then be modified <br /> or approved by EHD and the well permit for the injection wells can be <br /> issued. <br /> • EHD recommends a general mineral/metal solubility ground water <br /> analysis and a laboratory `bench scale test' be conducted PRIOR to <br /> Oxygen injection. If it can be shown that the injection of an oxidizer <br /> does not cause unwanted reactions in the ground water and the <br /> CVRWQCB approves, the plan may proceed. A copy of the <br /> CVRWQCB's bench scale procedure has already been forwarded to <br /> Mr. Auchterlonie. <br /> • Interim remedial actions may occur at any phase of investigation and <br /> are not intended to replace the required investigation. Currently the <br /> petroleum plume is not completely defined. Southland is to continue <br /> to propose and conduct continuing investigations to delineate the <br /> plume concurrently with this interim remedial action. <br /> REASONS FOR DISAPPROVAL OF THE WORK PLAN fH&S 25296.10(c)(3)1: <br /> • Monthly ground water extraction appears inadequate, as historically <br /> identified by EHD, and is NOT approved unless it can be shown that <br /> this rate is successful at keeping TBA and other petroleum <br /> constituents from migrating off of this site. <br /> • Oxygen injection process approval contingent upon CVRWQCB / <br /> WDR approval. <br /> May 21 2004 b <br /> DATED. y Y _ <br /> ichael Infurn , Seni REHS (209) 468-3454 <br /> [X]Faxed to Secor Intl on: <br />