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Geological rec/ucics tltc. Page 2 <br /> IRAP—Pilot Test <br /> Project No. 425.2 <br /> June 14,2005 <br /> In the letter dated June 28, 2004, Nuel C. Henderson, Jr., R.G., San Joaquin County <br /> Environmental Health Department (SJC/EHD) reviewed and accepted the proposed method <br /> of in situ oxidation remedial method in the Feasibility study dated April 28, 2004, and <br /> directed GTI to prepare .and submit the work plan for Bench Scale Testing. GTI prepared and <br /> submitted the Work Plan dated August 16, 2004 for Bench Scale Study to Mr. Nuel <br /> Handerson of SJC/EHD and Mr. James Barton of California Regional Water Quality Control <br /> Board — Central Valley. Region (CRWQCB-CV). Mr. James Barton on a telephone <br /> conversation (September 22, 2004) with GTI discussed the issue of pre-bench scale testing to <br /> determine to go to pilot testing by skipping the full Bench Scale Testing. After the telephone <br /> conversation with Mr. James Barton, GTI discussed this issue with Dr. Angus McGrath of <br /> SECOR International Incorporated. Dr. Angus McGrath agreed to write the report based on <br /> his other similar studies of chemical oxidation from the groundwater and soil analysis from <br /> the anticipated target zones of chemical oxidation. Mr. James Barton directed GTI to write <br /> the Work Plan Addendum for Pre Bench Scale/Pilot Testing. GTI prepared and submitted <br /> the Plan Addendum — Pre Bench Scale/Pilot Testing dated September 22, 2004 to SJC/EHD <br /> and CRWQCB-CV. Mr. James Barton approved the work plan in the letter correspondence <br /> dated October 4, 2004 with some conditions. The purpose of this Pre Bench Scale Testing <br /> and study was to detenYrune whether a full Bench Scale Testing is necessary prior to a Pilot <br /> Study. <br /> GTI performed bench scale testing/study in the months of December 2004 thru March 2005 <br /> according to the work plan approved in a letter correspondence dated October 4, 2005 by <br /> CRWQCB. GTI prepared and submitted the bench scale testing/study report dated March 10, <br /> 2005 to county and CRWQCB. <br /> However, Mr. James Barton (CRWQCB) in his e-mails dated February 23 and 24, 2005 gave <br /> the indication to skip the full scale bench scale testing. GTI interprets from these e-mails that <br /> CRWQCB should not have any objection if GTI moved forward to the pilot testing. <br /> GTI prepared and submitted the Interim Remediation Action Plan, In Situ Remedial Pilot Test <br /> (Plan) dated March 21, 2005. SJC/EDH reviewed the plan and described their response in <br /> their letter correspondence dated May 24, 2005. In this correspondence SJC/EHD described <br /> the reasons for the disapproval of the Plan and provided some recommendations to address <br /> the issues they (SJC/EDH) mentioned in the letter. SJC/EHD also asked to submit the <br /> feasibility work plan. The following sections of this Work Plan(WP) describes the changes <br /> made in the Plan (dated March 21, 2005) in accordance with the SJC/EHD responses. <br /> 2.0 PROPOSED PILOT TESTING <br /> In response to SJC/EHD's May 24, 2005 letter, GTI proposes to amend the Plan and conduct <br /> two pilot tests: An Ozone Sparging Pilot Test and a Soil Vapor Extraction Pilot Test. <br />