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Graunclwat <br /> er Monitaring for Biological Activit <br /> To sufficiently monitor biological activity and migration, representative wells should be <br /> sampled on a regular basis The draft RMRP (RMRP Table 2) requires monitoring MW-12, <br /> MW-14 and EW-1 on a twice-monthly basis for dissolved oxygen, pH, EC, bacterial <br /> composition and numbers and monitoring on a monthly basis for TPH as gasoline and <br /> BTE&X The RMRP also requires monitoring MW-6 through MW-11 and MW-13 on a <br /> monthly basis for dissolved oxygen, pH, EC, bacterial composition and numbers <br /> GeoAudit recommends monitoring of wells MW-6, MW-10, MW-7, MW-11 and MW-13 on <br /> a monthly bans for dissolved oxygen, pH, EC, bacterial composition and bacterial numbers, <br /> wells EW-1 and MW-14 should be monitored on a twice-monthly bans for the same <br /> parameters as well as monthly for TPH as gasoline and BTE&X <br /> We believe that the wells chosen will satisfy the concerns of the CVRWQCB and provide <br /> sufficient data to monitor the bioremediation progress Monitoring well MW-6 will provide <br /> an up-gradient well, MW-10 will provide a cross-gradient well, MW-7 and MW-11 provide <br /> down-gradient wells near the edges of the hydrocarbon plume (contaminated zone), MW-13 <br /> provides a down-gradient well beyond the extent of the plume, and EW-1 and MW-14 <br /> provide wells within the hydrocarbon plume <br /> Monitoring wells MW-8 and MW-9 were deleted because both are within the current <br /> hydrocarbon plume, we believe EW-1 and MW-14 will provide representative data for wells <br /> within the plume Wells MW-8 and MW-9 will continue to be sampled on a quarterly basis <br /> to monitor hydrocarbons, which will provide indications of biological activity in the areas of <br /> these wells These wells should provide data to meet all the concerns of the CVRWQCB <br /> On page two of the October 12, 1994 letter, MW-12 is characterized as being contaminated <br /> However, during the past four years, Hydrocarbons have only been detected (at low <br /> concentrations) twice in MW-12, MW-12 has been non-detect for the past two quarters This <br /> indicates that the hydrocarbons detected in MW-12 during the March, 1994 sampling were <br /> not representative of the well Therefore, we do not agree with the statement that MW-12 <br /> is contaminated Based upon this, we do not belie-*a it is necessary to monitor two down- <br /> gradient wells for biological activity <br /> Soil Gas/Vapor-Monitoring <br /> Similar to the groundwater monitonng, we would like to reduce the number of wells to be <br /> monitored to avoid redundant or useless data, as well as save costs to GLDM GeoAudit <br /> suggests modifications to the sampling frequency and the sample locations for the soil <br /> gas/vapor monitoring The parameters to be measured are agreeable to GeoAudit <br /> We suggest monitoring all inoculated wells on a twice-monthly basis during "start-up" <br /> GwbgxaIA dpi Sc <br /> RrvKrs inc MRP 111h)Wt 97 2 <br />