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t 1 <br /> EDMVHe G. Bnown JR. <br /> ;jffA.i cavunon <br /> 0o <br /> 7. 161%, MIRXEW RDaPIO°EE <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board <br /> 21 June 2012 <br /> Mr. Dave Isola <br /> Isola &Associates <br /> 405 West Pine Street <br /> Lodi, CA 95240-2023 <br /> REVIEW OF NOTICE OF INTENT, RIPON FARM SERVICE, 938 FRONTAGE ROAD, <br /> SAN JOAQUIN COUNTY <br /> The owners of the former Ripon Farm Service facility at 938 Frontage Road in Ripon, Isola and <br /> Associates (Isola) and Genesis Engineering and Redevelopment (Genesis Engineering) have <br /> proposed remediating groundwater at this site. The proposed remediation of nitrate and <br /> ammonium is described in the 10 May 2012 Treatability Study Work Plan, prepared by Genesis <br /> Engineering. The Treatability Study proposes a pilot study using the proprietary formulation, <br /> EHC, to biologically reduce nitrogen concentrations in groundwater. The Treatability Study <br /> includes a Notice of Intent, which is an application for enrollment in the General Order for Waste <br /> Discharge Requirements for In Situ Groundwater Remediation at Sites with Volatile Organic <br /> Compounds, Nitrogen Compounds, Perchlorate, Pesticides, Semi-Volatile Compounds, <br /> Hexavalent Chromium and/or Petroleum Hydrocarbons (General Order No. R5-2008-0149). <br /> California Regional Water Quality Control Board, Central Valley Region (Central Valley Water <br /> Board) staff conditionally concurred with the Treatability Study Workplan in its 21 June 2012 <br /> letter. This letter reviews the Notice of Intent and requests additional information. <br /> In the Notice of Intent, Genesis Engineering provided well logs, stratigraphic cross-sections, a <br /> draft Fact Sheet, an interested parties list, an Initial Study, a Material Safety Data Sheet for the <br /> EHC, a Sampling and Analysis Plan, draft groundwater monitoring schedule, Quality Control <br /> and Quality Assurance Plan, and a Health and Safety Plan. Genesis Engineering has provided <br /> most of the elements requested in an application for enrollment in a General Order. <br /> Genesis has identified background wells based on assumed direction of groundwater flow. <br /> Genesis also acknowledges that groundwater flow direction shifts 180 degrees occassionally, <br /> and proposes to select alternate background wells if a groundwater shift is observed. <br /> Alternatively, Genesis should consider background wells that are cross-gradient to the <br /> presumed flow directions. <br /> In the Treatability Study, Genesis Engineering proposed to develop a Contingency Plan once <br /> the pilot study has been completed. Genesis Engineering should be ready to prepare and <br /> implement a contingency plan in the event that any deleterious effects of treatment persist or <br /> extend into compliance zone. <br /> The Treatability Study included a Material Safety Data Sheet for the proposed amendment, <br /> EHC, but not a chemical analysis. Central Valley Water Board staff has previously obtained an <br /> KARL E. LONOLEY Sc D, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br /> 11020 Bun Center Dnve#200,Rancho Cordova,CA 95670 I www.waterboards.ca.9ov/ce.tralva1l.y <br /> 1.a nmroieo R.ren <br />