SITE INFORMATION AND CORRESPONDENCE

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7.0 Compliance and Performance Monitoring Compliance and performance monitoring will be conducted during the startup and routine operation of the treatment system. This section describes both monitoring activities, including their objectives, procedures, and frequencies. System logs will be developed prior to system startup to assist in system monitoring and data recording during the treatment period. 7.1 Compliance Monitoring During routine operations, periodic vapor influent/effluent monitoring and other system process operation data will be conducted at the treatment system to document compliance in accordance with SJVUAPCD permit requirements. Vapor samples will be taken at the influent and discharge of the oxidizer for calculation of the destruction efficiency. The samples will be collected in SUMMA° canisters and will be analyzed for total volatile hydrocarbons. 7.2 Performance Monitoring Performance monitoring will be conducted to assess the treatment progress and to evaluate its effectiveness in meeting the treatment goals. Data from the groundwater samples will be used to support this evaluation. Water levels from the on-site monitoring wells will be taken quarterly to provide groundwater flow direction during system operation. Groundwater samples will also be collected from the monitoring wells and submitted to the off-site State-certified analytical laboratory for VOC analysis using EPA Method 8015B and 8264B. Select groundwater wells will be sampled quarterly for the first three years of AS/SVE treatment. Afterwards, groundwater monitoring will be conducted semi-annually for the remaining years of treatment, along with other on-site monitoring wells. Wells proposed to be monitored quarterly during the AS/SVE treatment are MW-7S, MW-8I, MW-9I, MW-104 and VW-2D. VW-2D has consistently exhibited the highest hydrocarbon concentrations. Frequent monitoring of the concentration changes at this well will help assess the timeframe of the treatment. The other three wells are located on the downgradient edge of the plume. These wells will provide information concerning movement of the hydrocarbon plume during AS. Wells to be monitored semiannually are MW-4RD, MW-4RS, MW-11D, MW-12D, VW-1D, and VW-3D. MW-4RD, MW-1 ID, and MW-12D may be monitored on an annual basis after the first 3 years of AS/SVE treatment of the groundwater. Decisions about changes in the monitoring schedule will be based on the previous monitoring results. System performance data will be provided in the groundwater monitoring reports. RA Work Plan OdO9 Revl.doc 7-1 Shaw Environmental,Inc.