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Mr. I nomas Kosel - 2 - 21 July 2006 <br /> 110-volt single-phase or 220-volt three-phase electricity. An alarm system connected to an <br /> automated telephone will notify the system operator of shutdown conditions such as loss of <br /> power or activation of high or low pressure control switches. Anticipated permits to be <br /> obtained include a well installation permit from San Joaquin County Environmental Health <br /> Department, a City of Stockton building permit, and a fire department permit for the use of <br /> compressed oxygen. <br /> Baseline groundwater sampling will be conducted before the pilot test system becomes <br /> operational. Samples will be collected from wells MW-2, MW-8, MW-14, MW-19C, <br /> piezometers P-1 through P-6, and all twelve injection wells. Physical parameters of pH, <br /> dissolved oxygen, oxygen reduction potential, electrical conductivity, and temperature will be <br /> measured in the field at each well after 6 weeks of operation and every four weeks thereafter. <br /> Samples from wells MW-2, MW-8, MW-14, and MW-19C will also be analyzed for <br /> geochemical parameters of nitrate, sulfate, and phosphate using EPA Method 300.0, iron <br /> using EPA Method 6010/7000, Total Petroleum Hydrocarbons as gasoline and diesel using <br /> EPA Method 8015M, and benzene, toluene, ethylbenzene, xylenes, and fuel oxygenates using <br /> EPA Method 8260B. A microbial study of MTBE/TBA utilizing bacteria quantitative real time <br /> polymerase chain reaction (qRT PCR) will be performed on samples from wells MW-2, MW-8, <br /> and MW-14. This suite of laboratory analyses will be repeated after 10 weeks and 26 weeks <br /> of system operation. System operation will be monitored on a weekly basis for the first four <br /> weeks and every two weeks for the remainder of the pilot test. <br /> A summary report will be prepared at the end of the pilot test activities. The report will include <br /> data collected during the pilot test and provide conclusions regarding the test effectiveness <br /> and recommendations for the final remedial alternative. <br /> WORK PLAN REVIEW COMMENTS <br /> Regional Water Board staff conditionally concurs with the activities proposed in the Work Plan. <br /> The following comments are offered in review of the Work Plan and should be addressed in <br /> writing before work commences: <br /> 1. A Regional Water Board letter dated 28 March 2006 requested submittal of a feasibility <br /> study work plan to evaluate remedial alternatives for the Site in response to your 8 <br /> March 2006 letter that requested shutdown of the HiPOx system. The Work Plan states <br /> that the selected remedial alternative of oxygen injection was approved in a 3 April . <br /> 2006 phone conversation with Regional Water Board staff. The document also states <br /> that the proposed pilot test will be used to evaluate whether oxygen injection is a viable <br /> remedial alternative. These two statements are somewhat contradictory. A final <br /> remedial alternative has yet to be approved by Regional Water Board staff for the Site. <br /> 2. As the injection wells will be constructed below the water table, coated bentonite pellets <br /> should be used for the well seals to allow for hydration after settling in the well annulus <br /> as it may be filled with groundwater. <br /> 3. A report of system startup is required as well as a periodic report of system operation <br /> after the first quarter. The startup report should include baseline sampling data, <br /> descriptions of pilot test system installation activities, any problems encountered, and <br /> other information that is outside of the scope of work provided in the Work Plan. The <br />