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Page 2,2360 Grant Line Road <br /> Two remedial methods were tested for feasibility for interim remediation at(his site, oxygen <br /> injection and groundwater extraction One sparge point and one extraction well were installed to <br /> conduct these tests The oxygen injection test was conducted on June 21, 2004 SECOR <br /> injected 150 cubic feet of oxygen over a period of 30 minutes Dissolved oxygen cancentralions <br /> In observation wells located approximately 5 and 10 feet from the injection point were measured <br /> immediately before and after the injection Concentrations of dissolved oxygen increased an <br /> average of only 0 1 milligrams per liter in the measurement taken after the injection Based on <br /> this result, SECOR recommends that oxygen injection is not a feasible remedial alternative for <br /> this site However, in the"Work flan for Additional Site Assessment and Intenm Remediation, <br /> SECOR had proposed to inject 150-300 cubic feet of oxygen over a period of up to two hours, <br /> and to take dissolved oxygen measurement readings in the observation welts 24 hours after the <br /> injection Before SECOR dismisses oxygen injection as a remedial option at this site, SJCIEHD <br /> considers that the test should be conducted as proposed and approved,or a justification and <br /> vabdation for the test method employed should be presented to SJCIEHD for further evaluation <br /> Please demonstrate the test design as conducted provided adequate response time for dissolved <br /> oxygen to migrate through fine grained sod to the observation wells <br /> The groundwater extraction tests were conducted August 11-12, 2004 A step drawdown test <br /> was followed by a 24-hour constant rate pumping lest SECOR reported that during the constant <br /> rate lest, the maximum drawdown in the observation wells was 0 09 feet in well S-1 and 0 07 feet <br /> in well MW-5 SECOR stated that they considered this observed drawdown to be due to earth <br /> tides, and the values were therefore not used in the data analysis Please provide a <br /> demonstration to SJCIEHD that the observed drawdown was an effect of"earth tides" Maximum <br /> drawdown in the extraction well, EX-'I,was 6 17 feel This data was used in the analysis using <br /> the AQTESOLV and FLOWPATH modeling software From the models SECOR predicted a <br /> capture zone of°280 feet in the 'a'direction and 440 feet in the W direction" <br /> SECOR proposes to conduct an extended groundwater pump test"to confirm the ROI and <br /> drawdown calculations determined during the 48-hour pump test "Although a 24-hour pump <br /> lest has been performed at the site, and SECOR has not yet stated what the target ROI has been <br /> determined to be.SJCIEHD approves conducting an extended groundwater pumping test <br /> Please submit a work plan addendum by April 1,2005 describing the pumping test design <br /> SJCIEHD recommends designing the test so that earth tidal effects can be demonstrated and <br /> compensated for in the test evaluation If necessary, piezometers should be installed to obtain <br /> drawdown measurements closer to the pumping well to help compensate for pumping well <br /> inefficiency and its effect on the evaluated hydraulic conductivity In addition, please submit a <br /> work plan to continue the investigation of the vertical and lateral extent of the documented <br /> contamination by the same date <br /> If you have any questions please call Lori Duncan at(209)468-0337 <br /> Donna Heran,REHS,Director <br /> Environmental Health Department <br /> Lon Duncan, Senior REHS Nuel C Henderson,Jr , RG <br /> LOP/Site Mitigation Unit IV LOP/Site Mitigation Unit IV <br /> cc James Barton CVRWQCB <br /> JaFE Auchler[orne, SECOR <br /> I <br />