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Mr. Denis L. Brown -4W '"W <br /> Page 3 of 3 <br /> 2494 E. Fremont Street 23 July 2008 <br /> Stockton, CA <br /> • For reducing conditions analysis for total and dissolved iron, total and dissolved <br /> manganese and total and dissolved arsenic, nitrate, ammonium, sulfate, pH, total <br /> organic carbon (TOC), and expected breakdown products from the interaction between <br /> the injectant, chemicals of concern (COCs) and soil. <br /> The BST should be designed to evaluate if naturally occurring minerals or metals will be <br /> mobilized as a result of the injection; including but not limited to leaching constituents out of the <br /> soil into the groundwater and/or chemical changes that could allow constituents to become <br /> more mobile. Groundwater sample analysis should be designed to evaluate if naturally <br /> occurring minerals or metals will precipitate out of groundwater as a result of the injection. The <br /> BST also provides an opportunity that should be utilized to test contingency plans to abort or <br /> reverse the geochemical processes induced by the injectant should undesirable products be <br /> generated. <br /> Revise the CAP and work plan to address the issues noted above and resubmit to the EHD by <br /> 01 September 2008. Contact Michael Infurna, Senior Registered Environmental Health <br /> Specialist, at (209) 468-3454 if you have any questions or comments. <br /> Sincerely, <br /> Michael J. Infurna, Jr., REHS Nuel C. Henderson, Jr., PG <br /> Senior Registered Environmental Engineering Geologist <br /> Health Specialist <br /> c: Mr. James Barton, CVRWQCB - 11020 Sun Center Dr. #200, Rancho Cordova, CA 95670 <br /> Mr. Mark Owens, SWRCB-CUF - PO Box 944212, Sacramento, CA 94244 <br /> Mr. Mike Murphy, Connestoga-Rovers - 19449 Riverside Dr. Suite 230, Sonoma, CA 95476 <br /> CAP and WP Comment Letter 0708 <br />