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Cyeologkot Techtda lnc. Page 2 <br /> Cost Pre-approval Letter <br /> Project No.507.2 <br /> January 11,2006 <br /> • November 12, 2004- GTI submitted report on the pilot test to SJC EHD for review. GTI <br /> proposed additional ISCO in the recommendations section of the report as a viable <br /> remedial alternative. <br /> • June 27, 2005- In a letter correspondence the SJC EHD stated that the Regional Water <br /> Quality Control Board-Central Valley Region (RWQCB) must approve any additional <br /> chemical oxidant injection work. Further site investigation and remedial work were <br /> placed on hold pending concurrence from the RWQCB. <br /> • June 30, 2005- GTI contacted Mr. James Barton of the RWQCB via telephone regarding <br /> their requirements for ozone/peroxide injection. Mr. Barton confirmed that a bench scale <br /> (laboratory) pilot study would be acceptable to determine if the proposed injection would <br /> cause deleterious effects to groundwater. He directed that a work plan for the bench scale <br /> pilot test(BST)be submitted for his review. <br /> • August 8, 2005- GTI submitted our "Ozone Sparging SECOR Benchscale Test, July 18, <br /> 2005" work plan for approval. The draft plan was developed by SECOR's Mr. Angus E. <br /> McGrath, Ph.D. at GTI's request. <br /> • September 8, 2005-The RWQCB issued a letter stating their concerns regarding chemical <br /> analyses & methods and stated that the GTI/SECOR work plan was tentatively approved <br /> if their concerns were alleviated. The RWQCB wanted additional analyses of <br /> groundwater including general minerals, metals and demonstrated degradation rates. <br /> • October 28, 2005- After consulting with SECOR's Angus E. McGrath, GTI submitted a <br /> work plan addendum confirming changes to the SECOR BST that we thought met with <br /> RWQCB concerns. Specifically, it was our understanding from Mr. McGrath's <br /> conversations with RWQCB staff that analyses would be limited to hexavalent <br /> chromium, total chromium, bromate, arsenic, total dissolved solids (TDS), specific <br /> conductivity, and pH. <br /> • November 9, 2005- The RWQCB issued a letter stating that the GTI addendum didn't <br /> satisfy their concerns and that CAM 17 metals and general minerals would have to be <br /> analyzed pre-BST and post BST. They further stated that the work plan was tentatively <br /> approved if all analyses were included. <br /> • December 5, 2005- In order to comply with UST Cleanup requirements for three bids, <br /> GTI issued a request for bid from SECOR and Prima Environmental (the only two firms <br /> GTI could identify to perform the BST). The request for bid used the SECOR July 18, <br /> 2005 work plan as the base document with the stipulation that the study must include <br /> additional analyses for the CAM 17 metals and general minerals analyses as required by <br /> the RWQCB. At this point GTI awaited responses from the two BST companies. <br /> Since the issuance of the request for bids Prima Environmental submitted a bid (December <br /> 21, 2005) and SECOR has declined to bid. The reasons given by Mr. McGrath for SECOR's <br /> decline to bid is essentially that the changes mandated by the RWQCB are significantly more <br /> work than they are prepared to do for a BST. <br /> GTI is requesting a cost pre-approval from the UST Cleanup Fund for the Prima <br /> Environmental bid. We feel this is necessary because the original SECOR work plan BST <br />