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California "-gional Water Quality Con -t)1 Board <br /> Central Valley Region~ <br /> Karl E. Longley,ScD,P.F,.,Chair j <br /> Linda S.Adams Arnold <br /> Secrerurj!or Sacramento Main Office Schwarzenegger <br /> 11020 Son Center Drive 4200.Rancho Cordova.California 956746114 <br /> f mvrnnmeivul overnor <br /> l'raecnon Phone(916)464-3291 •fAX(916)464-4645 <br /> http://www.waterboards.ca.gov/centralvalley IunuS <br /> 1 May 2008 MAY 0 2 2008 <br /> Ms. Kerry Heckman ENVIRONMENT HEALTH <br /> Connell Tire PERMIT/SERVICES <br /> 2211 North Wilson Way <br /> Stockton, California 95205 <br /> DOCUMENT REVIEW, FORMER RIVER CITY PETROLEUM & FORMER CONNELL MOTOR <br /> LIFT TRUCK, 2211 NORTH WILSON WAY, STOCKTON, SAN JOAQUIN COUNTY, <br /> MONITORING AND REPORTING PROGRAM NO. R5-2005-0827 <br /> I reviewed the Soil Vapor Extraction/in-Situ Air Sparging Work Plan Addendum (SVE/AS <br /> Workplan) and the In-Situ Chemical Reduction Pilot Study (ISCR Workplan). Both documents <br /> were received 10 April 2008 from your consultant Advanced GeoEnvironmental, Inc. (AGE). <br /> The workplans were submitted in response to my 29 January 2008 letter requesting an <br /> SVE/AS Workplan for expansion of the existing SVE/AS soil/shallow groundwater treatment <br /> systems (35 to 75 feet below ground surface, or bgs) and an ISCR Workplan pilot study for <br /> dissolved phase petroleum hydrocarbons treatment in deeper groundwater (80 to 160 feet <br /> bgs). <br /> Depth to groundwater varied from 47 to 49 feet bgs in November 2007, while maximum <br /> groundwater concentrations were total petroleum hydrocarbons (TPH) as gasoline, <br /> 80,000 micrograms per Liter, or ug/L; TPH as diesel, 35,000 ug/L; benzene, 890 ug/L; <br /> toluene, 74 ug/L; ethylbenzene, 170 ug/L; xylenes, 1,060 ug/L; 1 , 2-dichoroethane, 200 ug/L; <br /> di isopropyl ether, 8.8 ug/L and tert-amyl methyl ether, 240 ug/L <br /> (enclosed Figures 3 through 7). <br /> The SVE/AS Workplan proposes installation of four additional SVE wells (enclosed Figure 8) <br /> screened from 35 to 55 feet bgs, and ten AS wells screened from 70 to 75 feet bgs. Existing <br /> monitoring wells MW-7 and MW-8 (screened 47 to 60 feet bgs) will also be used as SVE wells, <br /> while MW-25 and MW-26 (screened 90 to 100 feet bgs) will be converted to AS wells. <br /> The ISCR Workplan (pilot study) proposes injection of Regenesis Inc HRC Advanced'"' <br /> (Advanced Formula Hydrogen Release Compound, or HRC-A) into an injection treatment area <br /> grid of 30 feet wide by 15 feet length for five injection points over a 100 foot saturated <br /> thickness between 80 and 160 feet below ground surface (enclosed Figure 9). A total of 3,720 <br /> pounds of HRC-A mixed with 4,460.5 gallons of water will be pumped into the treatment zone <br /> using direct push technology or hollow stem auger drilling. Pump pressures will vary from 150 <br /> to 200 pounds per square inch (psi) for permeable sands and gravels, and 800 to 1,600 psi for <br /> silts and clays. The injections will start at the 160-foot depth and proceed upwards at a steady <br /> pace as the rods are retracted, until stopping at the 80-foot depth. The pilot study will last six <br /> months, due to the typical slow reaction rates for ISCR treatment systems. However, the full <br /> California Environmental Protection Agenev <br /> ��. Ren clrrl Paper <br />