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02 October 2003 AGE-NC Project No. 01-0865 Page 3 of 4 not provide the rationale for selecting injection points around MW-3, the distance of the injection from MW-3, or an estimation of how far the ORC will travel. Futhermore,H&H Manna proposes to analyze groundwater samples in MW-3 every two weeks for 12 weeks, but does not provide calculations or rationale to support this sampling frequency. H&H Marina must include this information. Monitoring well MW-3 was chosen as the test location because it was the more accessible of the two most-impacted wells(MW-2 being the other). AGE designed the model for implementing and sampling the injection of ORC based on a phone conservation with Regenesis, the manufacture of ORC. Additional information provided by Regenesis states that"after delivery of ORC to the subsurface, samples can be collected every two to three months. After the initial biodegradation and geochemical trends have been identified,the monitoring frequency can be decreased to a semiannual or annual program." Also; "samples should be collected from an upgradient pocation to identify groundwater conditions outside the treatment area, inside the treatment area,an appropriate distance downgradient of the treatment area to identify potential residence time requirements for complete biodegradation, and at a downgradient compliance point to confirm offsite migration is not occurring." 7. H&H Marina needs to include analysis for carbon dioxide by RSK- 175 because it is the end product ofpetroleum degradation and for the total dissolved and suspended solids to evaluate the effects of ORC on the water bearing zone. AGE concurs with the CVRWQB and will include the requested analysis for carbon dioxide when performing the ORC pilot study. 8. The Work Plan proposes to collect baseline samples prior to injecting ORC and the submit the results in a report after the 12'week sampling event.This is not sufficient.H&H Manna needs to submit a report that details the ORC injection activities and results of the baseline and two week sampling events within 60 days of the injection of ORC. AGE concurs with the CVRWQB and will submit reports as requested by the above statement. 9. The Work Plan only proposes to collect ORC injection monitoring samples from MW-3. H&H Marina should also propose a monitoring schedule to collect injection monitoring samples from monitoring well MW-9,which is about 50 feet downgradient of the proposed injection are and screened in the same interval as the injections. AGE proposes to sample the water from monitoring well MW-9 in conjunction with Advanced Ge Ruvimnmental,Inc