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Lincoln Center - 2 - 29 August 2019 <br /> San Joaquin County <br /> I <br /> cis-1,2-dichloroethene. The Discharger conducted a pilot test for ISCO of the groundwater <br /> during 2013 under General Order No. R5-2008-0149-046. Remedial alternatives, including <br /> ISCO, were analyzed in an Engineering Feasibility Study, and the selected alternative was <br /> presented in a Remedial Action Plan (RAP). <br /> The Discharger submitted a Remedial Design/Remedial Action Work Plan (RD/RA Work <br /> Plan)with the NOI to perform full-scale groundwater remediation of VOCs and a Notice of <br /> Intent to be covered under General Order No. R5-2015-0012 for the associated activities. <br /> Central Valley Water Board staff concurred with the design and proposed work in the RD/RA <br /> Work Plan in a 23 October 2015 letter. As proposed in the approved RAP and the RD/RA <br /> Work Plan, the project consists of injecting dilute, liquid potassium permanganate over a <br /> three-year period across two transects, while simultaneously extracting and treating <br /> groundwater from the downgradient area. Following the potassium permanganate injection <br /> period, groundwater will continue to be extracted, treated, and injected for an additional five <br /> years. Before, during, and after the above-proposed remediation program, the groundwater <br /> will be monitored to determine the efficacy of the remediation and to monitor for secondary <br /> reaction byproducts. A contingency plan, as outlined below, will be implemented if monitoring <br /> indicates exceedance of water quality limitations in downgradient compliance wells or if <br /> groundwater in the treatment zone does not show adequately declining concentration of <br /> secondary reaction byproducts following the injection phase. No comments were received on <br /> the draft Notice of Applicability and MRP during the 30-day public comment period ending on <br /> 11 January 2016. <br /> The first phase (Phase 1) of ISCO injections along the western side of Pacific Avenue began <br /> during October 2016 and are ongoing. Monitoring and reporting has been conducted as <br /> required by the MRP and has shown significant decreases in VOC concentrations in <br /> downgradient monitoring wells including MW-108A, MW-121A-U, MW-123A-L, MW-128A, <br /> Al-U, A2-U, A4-U, A4-L, A5-U, and A5-L. Downgradient groundwater extraction has also <br /> removed a significant mass of VOCs, and additional extraction wells were installed in the <br /> central portion of the VOC plume during 2019. Groundwater monitoring has also shown an <br /> increase in VOC concentrations in the original source area along a former sewer line. In <br /> response, LCERT has submitted a work plan to perform ISCO injections at 24 locations along <br /> the sewer line to target the vadose zone and underlying groundwater to remediate the <br /> remaining VOCs in the source area. The ISCO will be conducted with a potassium <br /> permanganate solution as permitted under the previous NOA. <br /> Monitoring and Reporting Program: <br /> As part of the Order, the Discharger is required to perform groundwater monitoring and <br /> reporting in accordance with the attached Monitoring and Reporting Program (MRP) to <br /> confirm the extent of the treatment area and efficacy of the treatment, and to verify that no <br /> adverse groundwater impacts occur due to ISCO treatment. The MRP includes monitoring <br /> requirements for two phases of ISCO (Phase 1 and Phase 2) to be conducted across the two <br /> transects. The MRP includes the locations of the injection wells and the extraction wells, and <br /> monitoring requirements for treatment zone monitoring wells and compliance zone monitoring <br /> wells. Background data will be collected from the compliance zone wells to establish <br />