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Mr.John Lane June 2,2006 <br /> Ground Zero Analysis, Inc <br /> Comment 2: The work plan does not reference the ITRC In-Situ Chemical Oxidation <br /> guidance (ITRC.com), which should be the basis for the ISCO work plan (and later the <br /> pilot study). <br /> The ITRC does not have any guidance for neutral pH based Fenton's Reagent ISCO. <br /> There is only one company in the United States that implements this patented technology: <br /> ISOTEC. ISOTEC has completed over 200 field applications of the process over the last <br /> 10 years and can provide references if required. The ITRC references items such as <br /> SOD, aquifer acidification and metals mobilization which are not applicable for this <br /> technology. Although, there is no reason not to implement a safeguard groundwater <br /> monitoring program for metals, etc. <br /> Comment 3: The full-scale workplan is informational at this time, and will not be <br /> approved until the lead agency has reviewed and concurs with a corrective Action Plan. <br /> A full-scale work plan has not been submitted. The work plan submitted gave a <br /> conceptual full-scale framework for moving forward with the technology to allow for a <br /> review of the "Work plan for Vertical Investigation and Bench Test for In-Situ <br /> Oxidation" within the context that is expected to be implemented. Following the <br /> investigation and bench test a work plan will be submitted for the next appropriate phase <br /> of the project(pilot test or full-scale). <br /> Comment 4: The addition of a soil Oxygen Demand Test analysis prior to the BST would <br /> be beneficial for estimating the dose for the reactors, and for design of a pilot study or <br /> full scale remediation. <br /> As discussed earlier,the SOD test is not appropriate for a Fenton's remediation program. <br /> As a clarification to the work plan: Mr Barton States that the plan calls for "using <br /> groundwater alone and groundwater/soil slurry in sealed reactors". <br /> The bench test will evaluate a groundwater/soil slurry,there will not be groundwater only <br /> test. Groundwater only tests are not very useful since the majority of mass, metals and <br /> organics are present in the soil. <br /> I hope these responses help clarify the plan and the nuances of the ISOTEC process as an <br /> ISCO technology. Please give me a call for further discussions or clarifications. <br /> Sincerely, <br /> In-Situ Oxidative Technologies,Inc. <br /> St2 Haskins,P.G. <br /> Director-Western Region <br /> 6452 FIG STREET,SUITE C,ARVADA,COLORADO 80004 <br /> PHONE: 303-843-9079 FAx: 303-843-9094 <br />