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Mr. Michael Roesner 2 performing a pump test of the Fire Protection Well and measuring the effect on Well MW-2. investigation of the well construction details for the water supply well and other wells used in L comparisons would be required. As an alternative to further investigation of Well MW-2, Owens-Brockway can destroy the well and ,. replace it. If well destruction and replacement is selected, all well destruction and construction activities shall be performed consistent with the California Well Standards Bulletin 74-90 and the San Joaquin County Environmental Health Department Well Standards. By 29 September 2000 please address which alternative Owens-Brockway plans to implement in an addendum to the workplan. LMonitoring Plan Comments L Section 4.0 of the report states monitoring wells will be sampled quarterly through the duration of the interim remedial actions or one year. Waste Discharge Requirements (WDRs) Order No. 0-00-056 requires regular monitoring as described in the Monitoring and Reporting Program (MRP). The MRP requires the Dischazgerdo perform quarterly monitoring of the groundwater monitoring wells. The Discharger shall continuejmonitoring consistent with the MRP. Section 4.2.2 of the report proposes using intrawell comparisons of analytical data. Intrawell comparison procedures are<considered appropriate when samples can be collected prior to application of wastewater. Because the Owens-Brockway site has been in operation since at least 1965, adequate historical data is not available. In addition, it is noted that the Owens-Brockway site is not regulated under Title 27 of the California Code of Regulations, and the procedures presented in Title 27 are generally.not applicable to-this site. hi-any event, the intrawell procedure is not an appropriate method to evaluaterthe data generated in the monitoring program. Intrawell comparisons are properly used when a background well cannot be installed in the same aquifer or site heterogeneity prevents installation of groundwater monitoring wells in similar geologic materials; this is not the situation at the site. To Yf evaluate the spatial variability of ` ty the groundwater data, Owens-Brockway may elect to install additional groundwater monitoring wells in the vicinity of the wastewater and stormwater ponds to better define spatial variation in water quality at the site. If this option is selected, please resubmit the workplan with the new monitoring well locations by 29 September 2000. Otherwise,proceed with interwell ` comparison of the analytical data. _ Well Installation Procedures Well installation procedures are presented in Appendix A. The proposed location of replacement Well MW-1 is acceptable. I have the following comments on the well installation procedures: - Please provide a revised schedule including the tasks presented above. him - It is not acceptable to use bentonite chips to seal the annular space. Bentonite is not an appropriate annular seal material at the site because bentonite seals tend to dry, shrink, and crack in and environments. In addition, bentonite possesses a high cation exchange capacity and may affect the quality of groundwater samples. Annular seal material shall consist of neat cement or neat cement with up to five-percent by weight bentonite placed using a tremie pipe. The driller shall use caution to prevent the grout's heat of hydration from damaging the PVC well casing. r cv��s,_ea>s�ww.nummoewx.�aeaeaon.aoc