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Weldon Church Property Page 2 <br /> 104 West Beverly Place March 3, 2010 <br /> Tracy, California 95376 <br /> from the proposed well and monitoring well MW-4 prior to the applications, one week after <br /> each of the three applications, and weekly for one month following the final application. <br /> Prior to any application of RegenOxr"', AGE proposes to perform a water injection test to <br /> assess the aquifer's volumetric injection capacity limitations. To assess whether the <br /> proposed volume of RegenOxTM solution injected into the aquifer is feasible, AGE proposes <br /> to inject 365 gallons of potable water into MW-3 since the stratigraphy encountered at MW-3 <br /> is representative of the general site stratigraphy, and except for one sampling event when <br /> TPH-g was detected in groundwater at 100 micrograms per liter in December 2007, <br /> groundwater collected from this monitoring well has been free of contaminants of concern. <br /> AGE proposes to have the potable water proposed for injection analyzed for total petroleum <br /> hydrocarbons quantified as gasoline (TPH-g); benzene, toluene, ethylbenzene, and total <br /> xylenes (BTEX); methyl tertiary-butyl ether (MTBE), ethyl tertiary-butyl ether (ETBE), <br /> tertiary-amyl methyl ether (TAME), di-isopropyl ether (DIPE), tertiary butyl alcohol (TBA), <br /> 1,2-dichloroethane (1,2-DCA), and 1,2-dibromoethane (EDB) prior to injection to ensure that <br /> contaminants of concern will not be injected into the aquifer. AGE proposes to position the <br /> hose for injecting the potable water one foot from the bottom of MW-3 (at approximately 24 <br /> feet bsg); however this well, and monitoring wells MW-1, MW-2, and MW-4 are screened <br /> between five and twenty feet bsg, not five and twenty-five feet bsg, as indicated in reports <br /> submitted by AGE. <br /> The EHD conditionally approves the proposed preliminary aquifer volume test; however, the <br /> EHD recommends that borings advanced outside of the intended treatment area be used <br /> instead of MW-3 for performing this test. (Since MW-3 is screened from five to twenty feet <br /> bsg, the EHD does not understand how injections would be limited from five to twelve feet <br /> bsg, and thirteen to twenty/twenty-five feet bsg.) The EHD-proposed boreholes should be <br /> injected with water in the same manner proposed in the pilot test work plan for the <br /> application of RegenOxTM into each of the five proposed borings. Regenesis Technical <br /> Support has calculated 653 gallons for the total volume of water required for initial <br /> application into the clay layer, and 1,466 gallons for the total volume of water required for <br /> initial application into the silty-sand layer. Since AGE proposes to inject the two volumes <br /> among five boreholes, intuitively, it seems to the EHD that the total injection volume (653 <br /> gallons and 1,466 gallons) should be divided by five to equal 130.6 gallons and 293 gallons. <br /> Multiplying these two numbers by 1.25 (the factor recommended by Regenesis for <br /> calculating the volume of water to inject into the aquifer during the preliminary aquifer <br /> volume test), the EHD calculates that approximately 163 gallons of water should be injected <br /> from approximately five to twelve feet bsg (the clay layer) followed by injecting <br /> approximately 366 gallons of water from approximately thirteen to twenty-five feet bsg (the <br /> silty-sand layer). If this is correct, you may change the proposed injection volumes; if not, <br /> the volumes proposed by AGE should be used. Submit a site map to the EHD by April 15, <br /> 2010, showing the proposed location for the injection test boreholes and provide technical <br /> justification for selecting the location for this borehole. <br /> AGE proposes to install one monitoring well, screened between approximately five and <br /> twenty-five feet bsg, located approximately seven feet southeast of soil boring B18 where <br /> high concentrations of TPH-g and BTEX were detected in groundwater in June 2003. AGE <br />