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								          		Mr. Alan M. Buehler
<br />      		May 19, 2017
<br />      				o   The soil sample collected at 6 feet bgs from B-55 will also be analyzed for PAI-Is by
<br />   					USEPA Method 8260B
<br />       		Soil samples collected from boring B-57 (6 feet and 13 feet bgs)will be analyzed for the following
<br />       		constituents:
<br />    			•   Title 22 metals by USEPA Method 8260B
<br />       		As mentioned in Section 4.2.3 of the CSM, although no naphthalene soil data are available, as suggested
<br />       		in the technical support document to the LTC Policy (SWRCB 2011), the LTC Policy exclusion criteria
<br />       		derived for benzene are assumed to be conservative for naphthalene, which is relatively less volatile than
<br />       		benzene (i.e., has a much lower solubility value and Henry's Law coefficient than benzene) and similarly
<br />       		susceptible to biodegradation.
<br />       		Investigative Derived Waste Transport and Disposal
<br />       		Investigative derived waste (IDW) generated during drilling operations will be containerized in 55-gallon
<br />       		drums and temporarily stored onsite pending characterization for offsite disposal. A composite sample of
<br />       		the IDW will be collected for waste profiling purposes, if necessary. Following receipt of waste
<br />       		characterization sampling results, the IDW will be transported to an appropriate disposal facility.
<br />       		Dry Well Evaluation
<br />       		An evaluation of dry wells and summary of most recent available groundwater data are presented in
<br />       		Table 1 and shown on Figures 3 and 4. Current and historical groundwater analytical data are
<br />       		summarized on Tables 2 and 3, and well construction details are summarized on Table 4.
<br />       		Shallow Zone Wells
<br />       		Groundwater samples were collected from seven of the 27 shallow zone wells (including vapor extraction
<br />       		wells) during the first quarter 2017 (MW-2, MW-8, VW-2, VS-3, VW-5, VW-6, and VW-10). Seven of the
<br />       		27 shallow wells have often been dry since they were installed (MW-4, MW-6, MW-13, VW-1, VW-4,
<br />       		VW-14, and VW-19). Ten shallow zone wells have been dry since they were installed, and groundwater
<br />       		samples have not been collected from these wells (MW-14, VW-7, VW-8, VW-9, VW-11, VW-12, VW-13,
<br />       		VW-16, VW-18, and VW-20).
<br />       		Deep Zone Wells
<br />       		Groundwater samples were collected from nine of the 21 deep zone wells (including air sparge wells)
<br />       		during the first quarter 2017 (MW-1, MW-10, MW-12, MW-16, MW-17, MW-18, MW-20, AS-313, and
<br />       		AS-6). Three of the 21 deep wells have often been dry since they were installed (MW-5, MW-9, and
<br />       		M"Ll5). Three deep zone wells have been dry since they were installed, and groundwater samples have
<br />       		not been collected from these wells (MW-3, MW-7, and MW-19). Groundwater samples were collected
<br />       		from three air sparge wells during the third quarter of 2016 (AS-1, AS-4, and AS-5); these wells were not
<br />       		accessible for sampling in first quarter 2017. Additionally, groundwater samples have not been collected
<br />       		from air sparge wells AS-2, AS-7, and AS-8; however these wells were not sampled due to inaccessibility,
<br />       		not due to insufficient water.
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