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s, <br /> GAVIN NEWSOM <br /> =� GOVERNOR <br /> C 0.LIF0 RNIA JAIREo NFELD <br /> RECRETARRV FOR <br /> Water Boards ENVIRONMENTAL PROTECTION <br /> Central Valley Regional Water Quality Control Board <br /> 2 August 2021 <br /> Joshua Hernandez Zavala <br /> San Joaquin County Dept of General Services — Capital Projects <br /> 44 North San Joaquin Street, #590 <br /> Stockton, CA 95202 <br /> RESPONSE TO PROPOSED REMEDIAL ACTION, HUMAN SERVICES AGENCY, <br /> 145 SOUTH SUTTER STREET, STOCKTON, SAN JOAQUIN COUNTY, CASE# <br /> 390296, GLOBAL ID T0607700218 <br /> Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff <br /> reviewed the following documents: <br /> • Remedial Action Work Plan (Work Plan), dated February 2021, received <br /> 4 February 2021 <br /> • Remedial Action Work Plan Addendum (Addendum), dated June 2021, received <br /> 6 June 2021 <br /> • Revised Remedial Action Work Plan Addendum (Revised Addendum), dated July <br /> 2021, received 27 July 2021. <br /> These documents were submitted on your behalf by Weston Solutions Inc. (Weston) for <br /> the Human Services Agency underground storage tank (UST) petroleum release case <br /> at 145 South Sutter Street in Stockton (Site). In the Work Plan, Weston proposes <br /> remedial injections of BOS-200 into the subsurface via borings in the vicinity of <br /> impacted source area well MW-2. BOS-200 is powdered activated carbon which has <br /> added micro- and macro- nutrients as well as microorganisms. The carbon traps <br /> hydrocarbons, and the nutrients and microorganisms promote biodegradation of the <br /> trapped hydrocarbons. As the macronutrients included in BOS-200 include nitrate and <br /> sulfate, the injection of this material must be performed under permit coverage in <br /> accordance with Order No. R5-2015-0012 Waste Discharge Requirements General <br /> Order for In-Situ Groundwater Remediation and Discharge of Treated Groundwater to <br /> Land (Order). As part of this permit, a Monitoring and Reporting Program (MRP) will be <br /> established, which will include Action Levels for the concentrations of select analytes. <br /> In the Addendum, Weston proposes a revised Contingency Plan to be implemented if <br /> concentrations of these analytes exceed the as-yet unestablished Action Levels in <br /> remedial compliance zone monitoring wells during the course of BOS-200 injection. <br /> However, after initial review of the Addendum, Central Valley Water Board staff believed <br /> KARL E. LONGLEY SCD, P.E., CHAIR I PATRICK PULUPA, ESQ., EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200, Rancho Cordova, CA 95670 1 www.waterboards.ca.gov/centralvalley <br />