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California 0-gional Water Quality Cont 11 Board <br /> RCentral Vallee Region ;` <br /> Karl E. LongleN,ScD, P.E..Chair :'_ <br /> Linda S. AdamsArnold <br /> �, 11020 Sun Center Drive#200. Rancho Cordo\a.Ct�lilm9167 <br /> iva 0-6 1 14 Schwarzenegger <br /> Il <br /> "m <br /> Phone(916)464-3291 •FAX(916)464-4641 <br /> l.rn � nrrnl,�l �ECE���� l�nrrrxu <br /> Ir I Nollhttp://ww\�.waterboards.ca.govicentrtivallcv <br /> 22 May 2009 MAY 2 8 2009 <br /> Mr. Nam Baek ENVIRONMENT HEALTH <br /> Glenn Springs Holdings, Inc. PERMIT/SERVICES <br /> 5005 LBJ Freeway, Suite 1350 <br /> Dallas, TX 75244-6119 <br /> FEASIBILITY STUDY WORK PLAN, PW-18 SULFOLANE IMPACTED SOIL REMEDIAL <br /> OPTIONS, FORMER OCCIDENTAL CHEMICAL CORPORATION, 16777 HOWLAND ROAD, <br /> LATHROP, SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Central Valley <br /> Water Board) staff has reviewed the Feasibility Study Work Plan, PW-18 Impacted Soil <br /> Remedial Options (Work Plan), dated 13 May 2009. This Work Plan was prepared on behalf <br /> of Glenn Springs Holdings, Inc. (GHSI) by Conestoga-Rovers & Associates (CRA). In the <br /> Work Plan, CRA describes the scope of work for the treatability testing of the in-situ remedial <br /> technologies and the scope of work for the installation of a new permanent monitoring well <br /> cluster (designated PW26) near soil boring SB-3. <br /> The technologies for which bench-scale treatability studies are proposed are in-situ soil <br /> washing and in-situ chemical oxidation (ISCO). CRA proposes to evaluate both technologies <br /> to determine the effectiveness of the processes in removing sulfolane from soil and to <br /> determine factors that may limit the implementability of these methods. Representative soils <br /> will be collected at approximately 4 to 5 feet below ground surface in the sulfolane-impacted <br /> area, and characterized for the key constituents pertinent to each technology. For in-situ soil <br /> washing, the key parameters are sulfolane, total metals, and total organic carbon. For ISCO, <br /> the key parameters are sulfolane, pH, total organic carbon, and metals. Soils will then <br /> besubjected to a series of laboratory tests under varying conditions. The results of the bench- <br /> scale treatability studies will be included in a treatability report. Although the Work Plan did <br /> not specify a due date for this report, we request that you submit this document by 20 August <br /> 2009. <br /> 1 have reviewed the Work Plan and concur with the approach and methodologies for the <br /> proposed treatability studies. This letter also provides my concurrence with the work plan for <br /> the installation of the PW26 well cluster.. although this activity is proposed to take place in the <br /> fourth quarter of 2009. <br /> The draft Feasibility Study (FS) is due 30 September 2009. In addition to the two treatment <br /> options discussed above, the FS should also evaluate soil excavation with on-site treatment <br /> and disposal, and soil excavation with off-site disposal. <br /> California Environmental Protection Agener <br />