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California Regional Water Quality Control Board <br /> Central Valley Region . , <br /> Robert Schneider,Chair <br /> .Vinston H. Hickox Gray Davis <br /> Secretaryfor Sacramento Plain Office Governor <br /> Environmental Internet Address: httpJ/www.swrcb.ca.gov/twgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 on <br /> r—, <br /> 21 September 2001 NOV 0 9 2001 <br /> 4iEALTH <br /> Ms. Nancy Bishop <br /> Western Farm Service <br /> 3650 Mt. Diablo Blvd., Suite 260 <br /> Lafayette, CA 94549 <br /> CONDITIONAL APPROVAL ADDEND UV OF WORK PLAN FOR FIELD-SCALE PILOT TEST, <br /> WESTERN FARM SER VICE, VERNALIS, SAN JOA QUIN COUNTY <br /> In our 13 September 2001 letter, Board staff approved your 8 June 2001 Work Plan for Field-Scale Pilot <br /> Test (Work Plan) that proposed an insitu pilot test at the Western Farm Service facility in Vernalis <br /> (WFS) using Hydrogen Release Compound® (HRC) to degrade 1,2-dichloropropane in groundwater. In <br /> our approval letter, we neglected to discuss two conditions that we apply to insitu pilot tests: <br /> containment and contingency. This letter supercedes the 13 September unconditional approval and <br /> conditionally approves the work plan subject to the conditions described below. <br /> Containment <br /> WFS will be injecting HRC into the aquifer. If, as a result, byproducts are formed that threaten water <br /> quality, Board staff will require that WFS capture, contain, or treat the groundwater affected with such <br /> byproducts. WFS provided the 14 July 2000 Capture Zone Analysis that demonstrates that the influence <br /> of the existing extraction well (near MW-3) encompasses the HRC pilot test area and downgradient <br /> monitoring wells. During our 18 September 2001 telephone conversation with your consultant, Ms. <br /> Carolyn Kneiblher of Geosyntec, she suggested that WFS could install an extraction pump and extract <br /> the HRC and any byproducts directly from MW-2, which is immediately downgradient from the HRC <br /> application area. <br /> Contingency <br /> According to the Work Plan, WFS will perform baseline sampling in upgradient and downgradient <br /> wells (MW-2, MW-4, MW-5,and MW-6) for a range of general mineral constituents. During the two- <br /> year pilot test, WFS will sample MW-4 and MW-5 annually and MW-2 and MW-6 quarterly for these <br /> general mineral constituents. In a reducing environment, pH may change and immobilized metals may <br /> become soluble. In order to evaluate the extent and duration of these changes in the geochemical <br /> environment, WFS should add the following constituents to the proposed general mineral suite. <br /> • pH (in the field and in the laboratory) <br /> • Soluble metals: arsenic, chromium, copper, mercury, nickel, and zinc. <br /> California Environmental Protection Agency <br /> C.1, Recycled Paper <br /> llie energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. =or a:ist of simple ways <br />