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16 December 2021 AdvancedGeo <br /> Project No. 07-1529 An Employee-Owned Company <br /> Page 2 of 3 � <br /> stem augers will be utilized as a tremie pipe during deployment of the grout mixture. Any <br /> groundwater displaced by the grout mixture will be routed into properly labeled <br /> Department of Transportation (DOT)-approved 55-gallon drums. All investigation derived <br /> waste will be containerized in properly labeled DOT-approved 55-gallon drums and <br /> disposed as a non-hazardous waste. <br /> AGI proposes to destroy well EW-1 using wire-line explosives. Prior to destruction, the <br /> well integrity will be checked using a water level meter. Initially, a cord of 50-grain Special <br /> wire-line explosives will be deployed down the entire length of the well casing to a total <br /> depth of 120 feet bsg. Once the explosives are in place the entire casing will be filled with <br /> the grout mixture as described above. Once filled, the charges will be detonated and EHD <br /> and AGI staff will verify that the grout mixture has dispersed into the surrounding <br /> formation. The remaining space, following formation shrinkage, will be filled with the grout <br /> mixture to near surface grade. <br /> 3.0. REPORTING <br /> Upon completion of field work and disposal of waste, a well destruction report describing <br /> the activities and procedures, including documentation of waste disposal, will be <br /> prepared, and submitted to the EHD and Regional Water Quality Control Board <br /> (RWQCB). The report will be in a format acceptable to the EHD and the RWQCB and will <br /> be reviewed and signed by a California Professional Geologist. <br /> 4.0. MRP RESCISSION <br /> Based on the results of corrective action injections performed historically at the site, AGI <br /> requests that the Waste Discharge Requirement (WDR) permit and associated Amended <br /> MRP be rescinded. Petroleum hydrocarbon-impacted soil and groundwater have been <br /> treated at the site utilizing a combination of soil-vapor extraction (SVE) and in-situ <br /> chemical oxidation (ISCO) injections. An SVE system operated at the site from June 1994 <br /> to December 1996 and removed a total of 16,200 pounds of hydrocarbon impact during <br /> that time. ISCO pilot tests and corrective action have been performed in the "core" area <br /> of the plume near wells MW-9, MW-13, and EW-1 from 2011 to 2018. A detailed history <br /> of SVE remedial operations performed at the site was included in the AGI-prepared, <br /> Corrective Action Plan, dated 10 June 2014. <br /> It is AGI's opinion that the reduction in dissolved mass observed is not sufficient to justify <br /> the costs to perform injections and the monitoring and sampling required by the Amended <br /> MRP. The corrective action injections are not economically feasible relative to the results. <br /> Therefore, AGI requests the WDR permit and Amended MRP be rescinded. <br />