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California Vional Water Quality Co of Board .t <br /> `\- Central Valley Region yv ' <br /> v Katherine Hart, Chair <br /> Linda S. Adams 11020 Sun Center Drive#200, Rancho Cordova, California 95670-6114 Arnold <br /> Secretary for Phone(916)464-3291 •FAX (916)464-4645 Schwarzenegger <br /> Environmental http://www.waterboards.ca.govlmntralvalley Governor <br /> Protection I�, <br /> 13 July 2010 �EC CEP "M ED <br /> jul_ 15Z010 <br /> Mr. David Johnson E"VIRONIVOT HEALZH <br /> Delta Transport, Inc. p tAITISER%GES <br /> dba Herman and Helen's Marina <br /> 15135 West Eight Mile Road <br /> Stockton, CA 95219-8721 <br /> REVISED IN SITU CHEMICAL INJECTION PILOT STUDY WORK PLAN AND ADDENDUM, <br /> HERMAN AND HELEN'S MARINA, 15135 EIGHT MILE ROAD, STOCKTON, SAN JOAQUIN <br /> COUNTY <br /> Staff of the Regional Water Quality Control Board, Central Valley Region (Central Valley <br /> Water Board) reviewed 30 June 2010 Revised In-Situ Chemical Injection Pilot Study Work <br /> Plan (Revised Work Plan) and the 8 July 2010 Revised In-Situ Chemical Injection Pilot Study <br /> Work Plan Addendum (Revised Work Plan Addendum). The Revised Work Plan and <br /> Addendum were submitted by Advanced GeoEnvironmental, Inc. (AGE) on behalf of the H&H <br /> Marina located at 15135 Eight Mile Road in Stockton (Site). <br /> A meeting was held on 18 May 2010 that was attended by you as the new lessee and <br /> potential buyer of H&H Marina; Mr. George Hartmann, attorney for H&H Marina; <br /> representatives of AGE; and Central Valley Water Board staff. During the meeting we <br /> discussed the 5 May 2010 ORC AdvancedTM Pilot Study Work Plan, prepared by AGE on <br /> behalf of H&H Marina, which proposed to implement an ORC pilot study in the vicinity of <br /> MW-4. Central Valley Water Board staff requested that a bench-scale test be conducted prior <br /> to conducting the pilot study in order to determine what byproducts might be produced. Our <br /> 24 May letter requested submission of an ORC Work Plan Addendum by 10 June, including <br /> the procedures for the bench-scale test. <br /> Before the Revised Work Plan could be submitted, AGE informed Central Valley Water Board <br /> staff that Regenesis, the contractor who would be conducting the pilot study, said the bench- <br /> scale test could cost up to $8,000 and might not provide the desired information. Regenesis <br /> provided additional information to AGE and staff during a 14 June 2010 teleconference. In a <br /> follow-up teleconference call on 15 June, staff informed AGE that the requirement to perform <br /> bench scale testing could be replaced by monitoring for select metals that could be mobilized <br /> by the in-situ application of Regenesis oxidants. We requested that the Revised Work Plan nn <br /> include a pre- and post-injection sampling plan to monitor for byproducts and metals that could <br /> be mobilized by the oxidants. <br /> Section 2.3.1 of the Revised Work Plan proposes a list of physiochemical and contaminant of <br /> concern (COC) parameters to be analyzed in soil and groundwater samples. Section 2.3.3 <br /> provides a list of field parameters proposed for analysis during monthly post injection <br /> California Environmental Protection Agency <br /> OdRecycled Paper <br />