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r <br /> Page 2, 2360 Grant Line Road <br /> Prior to the February 14, 2005 letter In addition, <br /> from another quarter, possibly15' SECOR appears to have included data <br /> has not been reported to either SJCIEHD or 5, OnGeotrfigure <br /> u re in the eddendumr This data <br /> reported, S.JC/EHD can review and comment on it P operly <br /> The March 2005 work plan to conduct an extended groundwater extraction test Is almost <br /> word for word the same work plan SECOR submitted for the onginat extraction test, the <br /> differences being that SECOR is proposing a longer test and to use fewer monitorin <br /> Points than in the original test. SECOR did not Include any design Modifications to g <br /> demonstrate and compensate for the earth tidal effects they reported as being a factor in <br /> the previously conducted 24-hour extraction test In lieu of answering SJC/EHD's request <br /> for a demonstration that the observed drawdown was an effect of earth tides, SECOR <br /> simply gave reference information This is not sufficient Justification to support a site- <br /> specific conclusion There are several potential causes for groundwater level fluctuations <br /> Of a few hundredths of a foot What are the characteristics of the fluctuations previously <br /> observed that are the signature of an earth tlde? <br /> previously approYed by SJCIEHD. To verify earth t des�cSEHD recorrimeting another tnds water <br /> level nl nitortrtg in a well mare distant from the pumping well Also, although Its shorter <br /> screen length may cause some response lag, being only 5 feet from EX-1 well S-1 should <br /> also be utilized for water level monitoring_ <br /> In lieu of demonstrating,Justifying or explaining why they did not conduct the o <br /> infusion test as proposed. SECOR has proposed to conduct the testagain, oxygen <br /> originally proposed and approved method Note that this test should JOorradeq�rate <br /> time for oxygen to migrate 5-10 feet cross-gradient into the observations wells; SJCIEHD <br /> requests that calculations showing this be submitted with the report <br /> Thank you for the copy of the chromatogram from the analysis of sample CPT-1-60 The <br /> inference that SECOR made in their September 30, 2004 report was that the detection of <br /> TPHg reported in this sample was actually 2-ethyl-1-hexanol and that it was Possiblyfrom <br /> Pipe dope, SJCIEHD requested this conclusion be explained in response SECOR has <br /> submitted comments from Kiff Analytical stating that while they no material <br /> could find <br /> safety data sheets listing thhis chemical as an ingredient of pipe dope, ridiff believes there is <br /> a relationship betWeen the detection of this analyte in groundwater samples and pipe <br /> dope based on their many years of testing water samples from groundwater treatment <br /> systems SJC/EHD still does riot seethe connection between this explanation for the <br /> detection and the sample in question for this site, which was collected from a discrete <br /> CPT hydropunch boring at 64 feet below surface Please provide the mechanism for this <br /> Compound to be detected in the CPT water sample In other words, how did it get there? <br /> What SJC/EHD Is trying to get to is a technically sound demonstration by SECOR that <br /> 2-ethyl-1-hexanol is or is not a contarntriant in the aquifer that requires additional <br /> assessment It it is a CrosS-contaminant, how and at what point did it enter the sample? <br /> Haw can the answer be verified? In addition to 2-ethyl-l-hexanol, the sample in gr�estiort <br /> was reported to contain 0 74 4g/l MtBE <br /> Please submit to SJC/EHD documentation that 7-Eleven has taken possession of the <br /> Valero monitoring well within 30 days of the date of this letter or SJCIEHD will direct the <br />' current well owner to have It properly destroyed, and a work plan for 7-Eleven to continue <br /> their investigation will be due no later than,lune 17, 2005 <br />