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d —I <br /> John and Margaret Marci Page 2 <br /> 20 Mobile Lane December 31, 2008 <br /> Crescent City,California 95531-8409 <br /> To address the EHD reservations regarding the DPE test design due to the limited screen lengths of <br /> EW-1 and EW-101, and the very limited vadose zone addressed by the longer screened well <br /> (MW-5)under natural conditions, the EHD recommends the following: <br /> • If possible, monitor depth-to-water in the active extraction well; if depth-to-water is not <br /> significantly below the top of the screen interval,terminate the test. <br /> • Monitor air flow rate continuously as depth-to=water increases; one would anticipate an <br /> increase of air flow as the vadose zone expands and is addressed by a larger portion of the <br /> well screen interval. <br /> • Demonstrate that the soil intervals addressed by the fairly small screened intervals are <br /> representative of site conditions and that the findings of the test are applicable to the whole <br /> impacted soil plume. <br /> By email dated November 26, 2008, the EHD was notified by GTI that TP.Hd results were <br /> significantly different between the two environmental laboratories employed to analyze <br /> groundwater samples collected from MW-5 and MW-7 on October 28, 2008. Argon Laboratories <br /> reported TPHd at 580 micrograms per liter.(µg/L) for groundwater collected from MW-5, and 620 <br /> µg/L for groundwater collected from MW-7; Excelchem Environmental Laboratories reported <br /> TPHd at 2,210 gg/L for groundwater collected from MW-5, and 7,480 pg/L for groundwater <br /> collected from MW-7. The EHD approved by email on December 2, 2008, sending groundwater <br /> samples collected from MW-4, MW-5, and MW-7 to Argon Laboratories and two additional <br /> laboratories for comparison of the TPHd results during the first quarter sampling event of 2009. <br /> The EHD has reconsidered having three different laboratories analyze groundwater samples for <br /> TPHd. Instead, the EHD believes sending the groundwater samples collected from MW4, MW-5, <br /> and MW-7 to Argon Laboratories and one other laboratory (different from Excelchem <br /> Environmental Laboratories).should be sufficient for comparison of the TPHd groundwater results <br /> during the first quarter 2009 sampling event. <br /> Provide the EHD a response to these comments and a revised work plan, if appropriate, for DPE <br /> pilot testing by February 26, 2009. If you have any questions, please contact Vicki McCartney at <br /> (209)468-9852 or by email at vmccartn.ey, i?s'cehci..com. <br /> Sincerely, <br /> Victoria L. McCartney,REHS Nuel C. Henderson, Jr.,PG <br /> Senior Registered Environmental Health Specialist Engineering Geologist <br /> c: Mr. Reza Namdar Ghanbari, Geological Technics Inc., 1101 7`h .Street, Modesto, California <br /> 95354 <br /> Mr. James L.L. Barton, PG, California Regional Water Quality Control Board Central Valley <br /> Region, 11020 Sun Center Drive, Suite 200,Rancho Cordova, California 95670 <br /> I <br /> i <br />