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Californiegional Water Quality Cool Board <br /> ( Central Valley Region <br /> Karl E. Longley,ScD,P.E.,Chair e.c..x✓- <br /> Linda S.Adams Arnold <br /> Secretaryfor Sacramento Main Office Schwarzenegger <br /> Enwronmenia/ 11020 Sun Center Drive#200.Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAx(916).464-4645 <br /> hap//www.waterboards.ca.gov/centralvalley (//l^1/l��,u, j�r�� M r�� '� <br /> RECIE V E <br /> 5 December 2007 <br /> DEC 0 g 2007 <br /> ENVIRONMENT HEALTH <br /> Mr. James Taylor PERMITJSERVICES <br /> ContiGroup Companies <br /> AON Center <br /> 200 E. Randolph, Suite 1900 <br /> Chicago iL 60601 <br /> REFINED GROUNDWATER RECIRCULATION PILOT STUDY, FRENCH CAMP GRAIN <br /> ELEVATOR, 9504 S. HARLAN ROAD, SAN JOAQUIN COUNTY <br /> In a February 2007 Remedial Action Plan for French Camp Grain Elevator, prepared by your <br /> consultant, Huff & Huff Inc., ContiGroup Companies proposed a pilot study to extract <br /> groundwater and inject it into existing subsurface zero-valent iron. In a 4 October 2007 letter, <br /> Central Valley Regional Water Quality Control Board (Regional Water Board) staff <br /> conditionally concurred with the Remedial Action Plan and requested a work plan for <br /> monitoring well MW-13B, the extraction wells, and the injection wells. <br /> In response, ContiGroup provided the October 2007 Pilot Study Work Plan also prepared by <br /> Huff & Huff Inc. The Pilot Study Work Plan provides design details for the groundwater <br /> extraction and injection system, incorporates the changes requested in Regional Water Board <br /> staff's 4 October letter and includes a discussion of the extraction, injection, and monitoring <br /> well designs. <br /> The pilot study will withdraw up to 1 gallon per minute of groundwater and inject at this rate <br /> into the existing subsurface zero-valent iron. Due to the low flow rate of injection, the <br /> demonstrated ability of the existing iron to reduce constituent concentrations in groundwater, <br /> the limited extent of the treatment area, and the limited duration of the pilot study, the pilot <br /> study will not adversely affect beneficial uses of groundwater. Regional Water Board staff <br /> have determined that Waste Discharge Requirements are not required for this activity. <br /> In a 9 November 2007 telephone conference with you, Ms. Linda Huff, Mr. Jim Huff and me, <br /> we discussed the Pilot Study Work Plan and agreed to the following modifications and <br /> clarifications to the pilot study. <br /> The second extraction/injection well pair EW-12B and IW-BH1 may be operated after the first <br /> extraction/injection well pair (EW-11 B and IW-BH2) has been in operation for at least three <br /> months. The two extraction/injection well pairs may not be operated concurrently. <br /> California Environmental Protection Agency <br /> 0 Recnc/ed Paper <br />