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1 <br /> sampling frequency (as opposed to weekly) and on a monthly basis dunng regular sampling <br /> frequency Furthermore, we suggest that the start-up penod extend only through December, <br /> 1994 <br /> For the uninoculated wells, we recommend monthly monitonng dunng the "start-up" period <br /> and quarterly during regular sampling frequency We do not recommend changes to the <br /> methane and nitrogen monitoring at this time <br /> Soil Sampling <br /> The RMRP states that a minimum of sax soil borings will be dnlled each quarter GeoAudit <br /> realizes that a significant number of soil borings should be drilled each quarter However, <br /> in the interest of limiting costs for the monitoring program, while still providing accurate <br /> and relative data for the project, we propose to dnll four soil borings per quarter We <br /> believe that four bonngs will provide enough data to determine the progress of the <br /> remediation project <br /> Four borings will also allow the drilling to be completed in one day with minimal <br /> disturbance to site operations, thereby reducing costs for the client,while providing sufficient <br /> data to determine the on-sate remediation <br /> The RMRP states that one soil bonng will be drilled near MW-S, MW-I1, EW-1 and three <br /> borings should be drilled within the inoculated area The necessity for borings within the <br /> inoculated area is obvious However, the reasoning for drilling borings near MW-8, MWA I <br /> and EW-1 were not included in the RMRP <br /> No impacted soil was encountered during the drilling of MW-11 and EW-1, soil sample <br /> analyses for TPH as gasoline and BTE&X were non-detect in these «ells In MW-8, only <br /> 7 ppm TPH was detected in a single soil sample at a depth of SO feet Based upon these <br /> data, we do not believe the soil borings 'outside" the inoculated area are justified Weils <br /> MW-8, MW-11 and EW-1 are not within the impacted soil plume <br /> GeoAudit agrees with the analyses requested for the soil sample However, we believe that <br /> only selected samples analyzed for TPH as gasoline and BTE&X should undergo additional <br /> analysis for nitrates, nitrites, phosphates and pH <br /> Schedule <br /> We believe that we have proposed a reasonable, cost-effective alternative to the draft <br /> RMRP prepared by the CVRWQCB The data to be collected will provide sufficient <br /> information for analysis of the progress of the bioremediation project <br /> The initial driIIing for the collection of soil samples is scheduled for November 14, 1994 <br /> Please contact us with any changes to the monitoring and sampling program pnor to that <br /> RMPP 11'a 33110,90, 3 <br />