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.e <br /> Mike Infurna [EHu <br /> From: Jim Barton Dbarton@waterboards.ca.gov] <br /> Wednesday, March 12, 2008 6:30 AM <br /> o: Mike Infurna [EH] <br /> Cc: Nuel Henderson [EH] <br /> Subject: Re: Bench Scale Test review <br /> .Hi Mike, J <br /> II <br /> I will review it and get back to you with more detailed answers. <br /> My first response to #1 is what does the workplan say? If it is a shotgun approach (we'll { <br /> give you three choices and you decide) ,. then it is incomplete. It needs ta. justify y <br /> (provide the rationale for) each oxidant- and provide examples where they have been <br /> combined and used successfully. If they are targeting different aquifer zones for each <br /> oxidant, they need to provide an explanation for each application, answer the why- <br /> question. ' <br /> Your comment ##2 is correct. They may not be aware of the ITRC guidance for ISCO. As <br /> such, we can recommend using it although they can provide a workplan that provides a <br /> functional equivalent of the guidance. They would need to reference which guidance, if <br /> any, they used for the workplan. <br /> #3 Bromide/Bromate is. a general mineral that, along with hexavalent chromium, has a <br /> potential in the Central Valley to oxidize to toxic levels; therefore we are justified in <br /> asking for that analysis. <br /> #4 I haven't encountered the Precision Enviro-Tech lab protocol. Prima Lab has a protocol <br /> which follows the ITRC ISCO guidance. <br /> ( 3 Enhanced Bioremediation is associated with Monitored Natural Attenuation (USEPA) . <br /> aeasically they add amendments to encourage the bacteria to break down the contaminants. <br /> More to follow. <br /> Thanks. <br /> Jim <br /> James L.L. Barton, P.G. [ <br /> Engineering Geologist 4 <br /> California Regional Water Quality Control Board Central Valley Region, 11020 Sun Centex d <br /> Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 <br /> fax (916) 464-4704 <br /> >>> "Mike Infurna [EH] " <Mlnfurna@sjcehd.com> 3/11/2008 11:32. AM >>> <br /> Jim, <br /> I 've gotten my first BST work plan and I have some questions on how to evaluate it. It' s. <br /> on Nuels 'waiting' list for his comments, but he's pretty busy now. <br /> It's a Port of Stockton UST site (#3, GT# T0607700817) . I received the Plan on GT and you <br /> can see it there. <br /> Questions: <br /> 1- They appear to want to BST (3) THREE oxidants, Sodium Persulfate w/Fe EDTA catalyst I� <br /> and NO pH adj , Fenton's Reagent w/pH adj , and Ozone . <br /> all in this ONE Plan. Do I allow 3 oxidants to be tested on one work <br /> -lan? or should only one oxidant be evaluated at a time? $10K for a <br /> pical Ozone BST isn't uncommon. Will adding two more oxidants nearly triple the costs? <br /> r is the data from one BST translate across for three? seems like each oxidant needs its <br /> own Time runs, right? <br /> 1 <br /> 4' <br /> t: <br />