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Page I of 4 <br /> Mike Infurna [EH] <br /> From: Mike Infurna [EH] <br /> Sent: Wednesday, July 16, 2008 10:31 AM <br /> To: 'Harms, Clint' <br /> Subject: RE: Circle K 1205, Lathrop <br /> Clint, <br /> I just met with Jim Barton regarding WDRs, the BST, and the CAP for this site. <br /> -Seems your attenuation of CrVi and Bromate is acceptable. <br /> -as for implementation of the CAP since the BST went well, guidelines offered by <br /> the CVRWQCB request a Pilot test be conducted to verify the BST results. This <br /> Pilot test should be a smaller version of the CAP. The EHD will require a Pilot test. <br /> -Contingency Plan: <br /> A plan, a paragraph should be included in the Pilot test work plan due to me and <br /> then it can/may need to be modified as needed if sucessful later on in the CAP. This <br /> paragraph should call out a contingency plan in a phased approach. First phase <br /> should be monitoring gw for by products. If found, phase one may say, "shut the <br /> system down and monitor" . Pahse II could say "lower the rate of injection and <br /> monitor" or "pulse the injection and monitor". Phase III could say "if CDCs don't <br /> attenuate after Phase II, agressive actions will be taken, (i.e: GWE, or some <br /> cancelling action taken). <br /> Jim was clear that GWE is extreme and may not be your first reaction to impacts of <br /> COCs. <br /> - vapor monitoring just before the houses is a good idea. Plan on including it. (Pilot <br /> work plan?) <br /> -additional monitoring wells is also a good idea. Plan on including them. (Pilot work <br /> plan?) <br /> -report of findings of the Pilot test will be reviewed by Jim for WDRs....He'll let us <br /> know. <br /> -if WDRs not needed and Pilot test shows feasible and COC production, if <br /> applicable, is managable, then the CAP may be implemented as initially submitted <br /> or a revised CAP should be submitted to the EHD. I will generate a comment letter <br /> for the Pilot Test report you send me. <br /> ALL of these concerns will be in a letter out of my office soon. I included this list so <br /> you have an idea of what I plan to do. So a RAP from you is slightly premature. You <br /> can start prep on a Pilot Test work plan. Plan on installing the additional monitoring <br /> 7/16/2008 <br />