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Mr. Nathan Crum - 2 - 3 October 2008 <br /> Valley Pacific Petroleum Services <br /> 31 July letter to collect four quarters of biodegradation and baseline groundwater <br /> parameters prior to determining whether SVE/AS is the appropriate remediation technology <br /> for this Site and whether an SVE/AS pilot study is needed prior to implementing full scale <br /> remediation. <br /> 2. The list of parameters selected for the biodegradation and baseline analysis does not <br /> propose a sufficient number of biodegradation parameters to adequately perform the <br /> baseline study. Valley Pacific must supplement the analyte list for the five wells with <br /> laboratory analyses for the following: <br /> a) total organic carbon and biochemical oxygen demand to assess the dissolved <br /> oxygen concentrations that will be needed to implement the pilot study; <br /> b) nitrate, manganese, ferrous iron and sulfate to evaluate the concentrations of <br /> electron acceptors; <br /> c) carbon dioxide, methane, and sulfide to assess whether biodegradation is already <br /> occurring; <br /> d) total phosphate to evaluate the need for nutrients; and <br /> e) trivalent chromium to assess the potential for the formation of toxic secondary by- <br /> products. <br /> Laboratory analysis for total bacterial counts must also be conducted to assess the <br /> presence of aerobic bacteria. However, it may only be necessary to conduct this analysis <br /> twice; once for a baseline measurement and once during the pilot test to evaluate whether <br /> an increase in cell mass is occurring. <br /> 3. During the 10 September telephone call with you and in the 15 September email, Valley <br /> Pacific stated that they would place a pan beneath the AGT fill spouts to catch any spills <br /> that could occur during the filling process. As stated in my 10 September email, while this <br /> solution addresses containment of future spills, a preferable course of action would be to <br /> implement a solution that prevents the spills from occurring. <br /> Following the four-quarter period of parameter assessment monitoring, Valley Pacific must <br /> submit a Pilot Study Work Plan incorporating the results of the baseline assessment monitoring <br /> by 1 November 2009. <br /> If you have any questio s regarding this letter, you may contact me at (916) 464-4811 or <br /> betaylor� ca.gov. <br /> BRIAN T OR, P.G. <br /> Engine ng Geologist <br /> cc. Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Gregory Stahl, Ground Zero Analysis, Inc., Escalon <br /> Mr. Patrick Riddle, Law Offices of Patrick D. Riddle, Acampo <br /> Mr. John Miller, Valley Pacific Petroleum Services, Inc., Stockton <br />