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A California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Terry Tamminen yAmold Schwarcenegger Secretary for Sacramento Main Office I[E(/1�,,f �,1�/// i -Governor Environmental Internet Address: http://www.sw b.ca.gov/rwgcb5 `---"J t II V IP 1: Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 Phone(916)464-3291 . OCT 0 5 2004 4 October 2004 ENVIRONMENT HEALTH PERMIT/SERVICES George and Mei Teranishi George's Service Station 1600 Durham Ferry Road Tracy, CA 95376 WORKPLAN, BENCH SCALE TESTING,AND WORK PLANADDEND UM, GEORGE'S SERVICE, 1600DURHAMFERRYROAD, TRACY,SAN JOAQUINCOUNTY, - I reviewed two documents, Work Plan, Bench Scale Testing(Workplan) dated 23 August 2004 and Work Plan Addendum (Addendum)dated 22 September 2004,both submitted by Geological Technics, Inc. (GTI) on your behalf. The Workplan proposes a Bench Scale Test(BST) conducted by subcontractor SECOR International, Inc. (SECOR). SECOR's protocol for the BST is included as an attachment to the Workplan. The Addendum proposes the collection of one groundwater and one soil sample that uses analytical results of dissolved metals and general minerals to produce theoretical calculations in a geochemistry evaluation(GE)report to determine whether a BST is necessary prior to a Pilot Study. The Workplan and Addendum are tentatively approved as written with the following conditions: • GTI/SECOR must collect and analyze at least one representative soil and groundwater sample from the ozone injection target zone at the site. The GE report will compare the results of the soil and groundwater, and thoroughly discuss the expected worst-case scenario reactions, i.e., 100% conversion of constituents of concern into contaminants,reporting the chemical reactions in molar concentrations. • If metals of concern(Cr6+, etc.) are not detected,or general minerals (SO4, etc.)are not present at levels favorable for adverse reactions in saturated soil, then you may proceed to the Pilot Study phase after final approval of the GE report. Note that all Pilot Study analytical detection limits must be sufficiently low to test the theories proposed in the Reports and provide comparisons to Water Quality Objectives in the GE report. You will continue to monitor groundwater during the Pilot Study for the know petroleum hydrocarbon contaminants and general parameters (dissolved oxygen,pH, specific conductance, temperature). • If metals of concern (Cr 6+, etc.) are detected, or minerals of concern (SO4, etc.) are detected at potentially harmful levels,then a BST will be conducted to show which contaminant(s) are produced; and whether the produced contaminant(s) will persist after termination of ozone injection,using the graphed slope of the declining contaminant(s) concentrations versus time to calculate a decay rate (time to revert to non- detect). If a contaminant(s) is produced and persistent,provide that information in a report for my review. If contaminants)produced are not persistent,provide a BST Report containing modifications to the Pilot Study monitoring program, specifically,the frequency of analyses needed to confirm contaminant decay rates as calculated from BST analytical evidence. • During the Pilot Study phase, groundwater sampling and analyses will be conducted immediately before startup of the ozone injection system, and at intervals of one and 2 hours afterwards, in order to validate California Environmental Protection Agency p�d Recycled Paper