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Mr. Jeff Baker -4 - 17 February 2011 <br /> Stockton Terminals Technicoommittee ' <br /> aerobic degradation enzymes for TPHd, BTEX and TPHg are present in TS/MW-3DR, <br /> the well with the highest pollution levels. Anaerobic and MTBE degrading bacteria were <br /> non-detect and present at much lower levels, respectively, than the aerobic enzymes. <br /> The Annual Report did not include the DO, ORP, pH and conductivity data for the pilot <br /> study. These data were emailed to Central Valley Water Board staff at our request with <br /> a message stating that they would be included in future reports. The data show that DO <br /> is absent in the well with highest concentrations and present in very low concentration <br /> in other pilot study wells. The ORP data did not correlate directly with the DO <br /> concentration distribution and showed that the well with the lowest pollutant <br /> concentration (TS/MW-1D) had the lowest reduction potential. <br /> Oxygen injection commenced on 25 January 2011 in TS/MW-3DR and TS/MW-4D. <br /> Groundwater monitoring for the oxygen injection study will be conducted monthly during <br /> the first three months of the 1-year study and quarterly thereafter. The data will be <br /> presented in quarterly reports. A final report will be prepared following receipt of the <br /> final laboratory analytical results of the Bio Traps@, contaminant and redox parameter <br /> data.. <br /> Tesoro is also conducting a hydrogen peroxide injection (HPI) pilot study at the <br /> southwest property boundary shared with FTOC in the vicinity of TS-4R. Baseline <br /> groundwater monitoring was conducted in four wells described by Tesoro as upgradient <br /> well (TO/T-3), treatment zone wells (TS-4R, TS/M-2), and downgradient well (TS-5) for <br /> four-quarters to determine basetine values-for total chromium, hexavalent-chromium <br /> (Cr VI), vanadium, bromide, and bromate. The baseline values are used to monitor for <br /> the potential mobilization of Cr VI, bromate, and vanadium following injection of the <br /> hydrogen peroxide into wells TS/RW-1 and TS-RW-2. The baseline monitoring data <br /> were used to calculate a 95% upper confidence limit (UCL) compliance level for <br /> chromium, vanadium, and bromate. The compliance limits are listed at the top of <br /> Table 8. However, the Central Valley Water Board staff has not yet concurred with the <br /> STTC's suggested compliance level of 44 pg/L for Cr VI. <br /> The HPI pilot study began on 23 March 2010. Bimonthly monitoring for chromium, <br /> vanadium, and bromate (TS-5) was reduced to monthly in October 2010. In addition, <br /> monthly monitoring was initiated in TONT-3 in November 2010. The Annual Report <br /> shows that the metals mobilization compliance levels have not been exceeded in any of <br /> the four monitoring wells. <br /> Monthly monitoring to determine the effect of the HPI injections is performed for CDCs <br /> in treatment zone wells TS-4R and TS/M-2. The results listed in Tables 6 and 7 of the <br /> Annual Report show that between March and December 2010, COC concentrations <br /> have remained stable. Maximum concentrations of TPHg, TPHd, and benzene between <br /> October and December 2010 were 46,000 pg/L, 94,000 pg/L, and 11,000 pg/L, <br /> respectively. These concentrations are consistent with historical observations. <br /> Our comment is presented below. <br /> The absence of nitrate/nitrite and OZ electron acceptor data indicates that conditions at <br /> the TS/MW-1 D plume are strongly anaerobic. Under these conditions, biodegradation <br />