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Mr. David Johnson -2- 22 December 2010 , <br /> Herman and Helen's Marina <br /> depth to water ranged from about 3 to 28 feet. Flow gradients were to east-southeast and <br /> ranged from 0.22 feet per foot (ft/ft) at the levee to about 0.004 ft/ft in the field area. <br /> During the third quarter, the highest concentrations of CDCs were observed monitoring wells <br /> MW=2, MW-3, and MW-4 in the center of the Site. MW-2 contained 1 1 ,000micrograms per <br /> liter (pg/L) of TPHg, MW-3 contained 7,900 ug/L of TBA, and MW-4 contained 11 pg/L of <br /> MTBE. Groundwater at the Site also contains elevated concentrations of benzene, ethyl <br /> benzene, and total xylenes. <br /> Between September 2007 and February 2008, the highest concentrations of CDCs were <br /> generally detected in MW-2, the well that was degraded by the 2007 AGT gasoline release. <br /> The third quarter TBA results for MW-3 represent an order of magnitude increase, and a <br /> historic high, over the TBA concentrations last observed in this well in February 2009. TPHg <br /> and TBA concentrations in MW-2 were also sharply higher. <br /> During an 18 May 2010 meeting, Centra! Valley Water Board staff discussed with AGE and <br /> H&H the 5 May 2010 ORC Advanced TM Pilot Study Work Plan, which proposed to implement <br /> an ORC pilot study in the vicinity of MW-4. At a later date, based on information provided by <br /> Regenesis, the contractor who will conduct the pilot study, staff informed AGE that the <br /> requirement to perform bench scale testing could be replaced by monitoring for select metals <br /> that could be mobilized by the in-situ application of Regenesis' oxidants. We requested that a <br /> revised Work Plan include a pre- and post-injection sampling plan to monitor for byproducts <br /> and metals that could be mobilized by the oxidants. <br /> A Revised Work Plan was submitted on 30 June 2010, and a Revised Work Plan Addendum <br /> was submitted by email on 8 July.The Addendum provides for monitoring for bromide, <br /> bromate, trivalent and hexavalent chromium (Cr III and Cr VI), total chromium, and vanadium. <br /> Baseline concentrations for these parameters will be determined from a one-time, pre-injection <br /> sampling event. Depending on the pre-injection monitoring results, post-injection monitoring <br /> for the metals may.exclude Cr VI and bromate and will be conducted on a monthly basis in <br /> select wells. Central Valley Water Board requested that AGE provide the Pilot Study Report by <br /> 3 January 2011, and monthly reports of the pre- and post injection monitoring. The Annual <br /> Report states that execution of the Work Plan is awaiting the negotiation of an access <br /> agreement with Reclamation District 2029 for permission to inject the oxidants described in the <br /> Work Plan. <br /> The Annual Report also contains a recommendation to determine whether the City of <br /> Stockton's Delta water supply pipeline construction dewatering activity has exerted a hydraulic <br /> influence on the hydrocarbon plume at the Site. The Central Valley Water Board's <br /> 25 May 2010 Notice of Applicability (NOA) authorizedthe City to perform groundwater <br /> extraction and land disposal to dewater the proposed alignment for the pipeline. The Annual <br /> Report shows that water levels in monitoring wells screened in a deep water bearing zone <br /> beneath H&H were about four feet lower in July than in April. In a 23 September 2010 letter, <br /> the City's consultant informed Central Valley Water Board staff that the dewatering operation <br /> would be terminated and the dewatering wells and monitoring piezometers properly <br /> abandoned by.30 September. <br />