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page 2, 2360 Grant Line Road <br /> prior to the February 14, 2005 letter. In addition, SECOR appears to have included data <br /> from another quarter, possibly 1St quarter 2005, on figure 2 in the Addendum. This data <br /> has not been reported to either SJC/EHD or Geotracker. When the data is properly <br /> reported, SJC/EHD can review and comment on it. <br /> The March 2005 work plan to conduct an extended groundwater extraction test is almost <br /> word for word the same work plan SECOR submitted for the original extraction test, the <br /> differences being that SECOR is proposing a longer test and to use fewer monitoring <br /> points than in the original test. SECOR did not include any design modifications to <br /> demonstrate and compensate for the earth tidal effects they reported as being a factor in <br /> the previously conducted 24-hour extraction test. In lieu of answering SJC/EHD's request <br /> for a demonstration that the observed drawdown was an effect of earth tides, SECOR <br /> simply gave reference information. This is not sufficient justification to support a site- <br /> specific conclusion. There are several potential causes for groundwater level fluctuations <br /> of a few hundredths of a foot. What are the characteristics of the fluctuations previously <br /> observed that are the signature of an earth tide? Conducting another extraction test was <br /> previously approved by SJC/EHD. To verify earth tides, SJC/EHD recommends water <br /> level monitoring in a well more distant from the pumping well. Also, although its shorter <br /> screen length may cause some response lag, being only 5 feet from EX-1 well S-1 should <br /> also be utilized for water level monitoring. <br /> In lieu of demonstrating,justifying or explaining why they did not conduct the oxygen <br /> infusion test as proposed, SECOR has proposed to conduct the test again, per their <br /> originally proposed and approved method. Note that this test should allow for adequate <br /> time for oxygen to migrate 5-10 feet cross-gradient into the observations wells; SJC/EHD <br /> requests that calculations showing this be submitted with the report. <br /> Thank you for the copy of the chromatogram from the analysis of sample CPT-1-60. The <br /> inference that SECOR made in their September 30, 2004 report was that the detection of <br /> TPHg reported in this sample was actually 2-ethyl-1-hexanoi and that it was possibly from <br /> pipe dope. SJC/EHD requested this conclusion be explained. In response SECOR has <br /> submitted comments from Kiff Analytical stating that while they could find no material <br /> safety data sheets listing this chemical as an ingredient of pipe dope, Kiff believes there is <br /> a relationship between the detection of this analyte in groundwater samples and pipe <br /> dope based on their many years of testing water samples from groundwater treatment <br /> systems. SJC/EHD still does not see the connection between this explanation for the <br /> detection and the sample in question for this site, which was collected from a discrete <br /> CPT hydropunch boring at 60 feet below surface. Please provide the mechanism for this <br /> compound to be detected in the CPT water sample. In other words, how did it get there? <br /> What SJC/EHD is trying to get to is a technically sound demonstration by SECOR that <br /> 2-ethyl-1-hexanol is or is not a contaminant in the aquifer that requires additional <br /> assessment. If it is a cross-contaminant, how and at what point did it enter the sample? <br /> How can the answer be verified? In addition to 2-ethyl-1-hexanol, the sample in question <br /> was reported to contain 0.74 µg/I MtBE. <br /> Please submit to SJC/EHD documentation that 7-Eleven has taken possession of the <br /> Valero monitoring well within 30 days of the date of this letter or SJC/EHD will direct the <br /> current well owner to have it properly destroyed, and a work plan for 7-Eleven to continue <br /> their investigation will be due no later than June 17, 2005. <br />