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Mr. Robert Jackson • <br /> -2- 1. 3 <br /> 20 <br /> proximity to each other, which could be done quickly and efficiently, while minim i ng they 2012 <br /> transfer of contaminants between water-bearing zones. <br /> Central Valley Water Board staff concur with San Joaquin County and strongly recommend <br /> that CPS install well pairs near each other, with conductor casing used for the B-zone well <br /> installations, and not as nested wells within a single casing. <br /> Well Destruction Work Plan <br /> CPS proposes to destroy existing MW-2 by pressure grouting to the surface, and removing the <br /> well vault. MW-2 contains pollutants, and San Joaquin County regulations require that wells <br /> that contain pollutants have their contents removed. Pressure grouting does not remove the <br /> well contents, so another destruction technique must be employed. CPS must provide a <br /> revised well destruction workplan that achieves the objective of removing the contents. This <br /> revised well destruction work plan may be provided electronically, and needs to include a <br /> boring log for MW-2 and a diagram identifying the location of MW-2. <br /> Treatability Study <br /> CPS proposes to conduct a bench-scale treatability study to evaluate various amendments <br /> that may be effective at removing 1,2,3-trichloropropane from groundwater insitu. When the <br /> design of the treatability study is formulated, CPS should transmit a study design to Central <br /> Valley Water Board staff for review. <br /> Soil and groundwater sampling from the proposed monitoring wells include parameters for the <br /> treatability study design such as porosity, bulk density, organic carbon content, oxygen, <br /> nitrogen, dissolved and total iron, hexavalent chromium, and phosphate. In order to assess <br /> total oxidative or reductive demand, CPS should also include analyses for dissolved and total <br /> manganese, and sulfate. <br /> General Order for InSitu Remediation <br /> As Rubik suggests, the General Order for InSitu Remediation (R5-2008-0149) may be suitable <br /> for permitting of oxidizing or reducing conditions, with or without recirculation systems. After <br /> the treatability study has demonstrated which amendments have a likelihood of success with <br /> the site pollutants and the site aquifer materials, then CPS may apply for coverage by <br /> submitting a Remedial Action Plan describing the insitu proposal, and a Notice of Intent. The <br /> Remedial Action Plan, Notice of Intent, or additional submittals should include the following <br /> items: <br /> • A check written to the State Water Resources Control Board and delivered to Central <br /> Valley Water Board staff for the amount of$3,422. <br /> • The North American Industry Classification System (NAICS) code of the industry that <br /> originated the pollution. <br /> • The targeted concentration of amendment(s) in the aquifer at the point of injection. <br /> • An analysis of the amendment(s) at the targeted aquifer concentration for volatile organic <br /> compounds, semi-volatile compounds, metals, general minerals, and TDS. <br /> • Geologic cross-sections (reference to documents that contain cross-sections is <br /> satisfactory). <br />