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Stantec • <br /> April 13, 2009 <br /> Page 12 of 13 <br /> Reference: Response to RWQCB March 11, 2009 Letter <br /> This will be based on the evolution of geochemical and microbial conditions as the pilot <br /> test progresses. These analyses are expensive to collect and interpret. As the pilot <br /> test evolves, the suite of bioparameters and BioTraps® analyses utilized as indirect <br /> evidence that biodegradation is occurring will likely be superseded by newly acquired <br /> site empirical data, especially as the evaluation monitoring results begin to document <br /> decreases in contaminant concentrations. <br /> 11 Some of the most recalcitrant occurrences of SPH and elevated concentrations <br /> of dissolved phase hydrocarbons occur in monitoring wells TS/MW-2 and TOIT-2, <br /> which is located in the southwest entry area of the Time Oil and Tesoro facilities. <br /> There is no documentation that remediation has been attempted in this area of the <br /> facilities. Regional Water Board staff will be reviewing the remedial site history at <br /> these facilities and, depending on our findings, may request submittal of a work <br /> plan to clean up this area. STTC needs to explain why remediation of this area <br /> adjacent to Navy Drive has not been attempted <br /> Stantec recently submitted its Monitoring Well Replacement and Hydrogen Peroxide <br /> Pilot Study Work Plan, dated April 1, 2009 to address this comment. Tesoro is <br /> mobilizing to address the impacts cited in this comment. Tesoro requests RWQCB <br /> cooperation and timely review of the work plan to address this area as terminal <br /> operations-related construction is slated for this area and prompt well emplacement is <br /> needed. <br /> I:\STTC-Stockton\Reports\Response to Comments\RWQCB Letter 3-11-09\STTC Response to RWQCB 3-11-09 Letter Final do <br />