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page 2, 16 Harding Way <br /> will be submitted for analysis of total petroleum hydrocarbons as gasoline (TPHg), <br /> benzene, toluene, ethyl benzene and xylenes (BTEX), fuel oxygenates, 1,2- <br /> dichloroethane and ethylene dibromide <br /> ' The proposed groundwater extraction well will be a 4-inch diameter well built to 50-feet <br /> bsg with 25-feet of screen interval, and will be located on-site near SB-2 The proposed <br /> ' feasibility test will be a hydraulic step-drawdown test performed to further evaluate <br /> hydrogeologic conditions beneath the site, and to determine the viability of using <br /> groundwater extraction as a remediation method for the site Groundwater will be <br /> pumped from the extraction well with a submersible pump and discharged to a holding <br /> ' tank on-site A valve and flow meter connected in line with the discharge hose will be <br /> used to control and measure flow rate All discharged water will be transported off-site for <br /> proper disposal Monitoring wells MW-1, MW-3, MW-4, MW-5, MW-6 and MW-7 will be <br /> used as observation points during the test Groundwater extracted during the test will be <br /> stored on-site in a holding tank pending characterization for disposal Groundwater <br /> samples will be collected during and following the completion of the test and will be <br /> analyzed for TPHd,TPHg, BTEX and fuel oxygenates SJCIEHD approves the work plan <br /> for additional site assessment and feasibility testing as outlined above <br /> Two'Project Schedules'were submitted with the work plan In the Project Schedule-Site <br /> ' Assessment SECOR proposes a time frame for completion of the site assessment by <br /> 10/22/02 and submittal of a report of findings by 12106102. SJCIEHD does not consider <br /> nearly ten months to be a reasonable time frame for completion of the plume definition at <br /> this site The consistently very high levels of contaminants present in the groundwater <br /> 110 require a faster response time Specifically, problems and questions with the Project <br /> Schedule-Site Assessment include <br /> 1 Task ID#9, Submit well permits This task was listed prior to the tasks of <br /> submitting and receiving city encroachment permits and access agreements <br /> The County cannot issue drilling permits prior to receipt of copies of all <br /> ' encroachment permits and access agreements <br /> 2 Task ID#10, Receive Approved Permlts. The schedule listed the duration to <br /> receive approved permits at 21 days This is not accurate If SECOR has an <br /> approved work plan and has submitted all necessary paperwork and fees, a <br /> drilling permit can usually be issued within a couple of days <br /> 3 Task ID#12, Receive Encroachment Permits and Access Agreements The <br /> ' duration of this task was listed at 90 working days. In conversation with City of <br /> Stockton Public Works Department personnel, SJCIEHD was informed that a <br /> revocable permit should take a maximum of approximately one month and that <br /> following issuance of the revocable permit an encroachment permit should be <br /> obtainable in a day SJCIEHD acknowledges that access agreements from <br /> private parties are sometimes difficult However, work at a highly <br /> contaminated site such as this should not be delayed by lengthy negotiations <br /> ' with a private party If a private property owner is not cooperative, proposed <br /> work should be relocated to city or county right-of-ways and should proceed <br /> quickly In addition, SJCIEHD fails to see why SECOR has to wait until <br /> ' 3115102(the start date noted in the schedule)to submit the requests for <br /> revocable permits and access agreements SECOR should begin the <br /> submittal of these items immediately <br /> 4 Task ID#14, Schedule Utility Locator and Drilling The duration for this task <br /> was listed at 21 days Please explain why this task takes so long <br />