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• qennedy/Jenks Consultants <br /> Mr. Tim O'Brien <br /> California Regional Water Quality Control Board <br /> 25 August 2006 <br /> Page 3 <br /> CRWQCB comment 4: Section 2 describes sampling of offsite water wells within a one-mile <br /> radius of the site. The usefulness of the data to be collected is questionable because of the <br /> likelihood that the offsite wells are screened in a deeper zone. For example the onsite wells at <br /> the facility have TDS concentrations that range from 180 to 240 mg/l, but the monitoring wells <br /> have TDS concentrations in the range 410 to 1,400 mg/l. <br /> Response: Although offsite wells are likely representative of deeper groundwater, well <br /> completion records have been obtained from the Department of Water Resources. Available <br /> data that are from relatively shallow irrigation and production wells will be used. Water quality at <br /> certain deeper groundwater wells will also be analyzed to conduct a comparative assessment of <br /> the vertical extent of elevated constituents at and within a one-mile radius of the Site. <br /> CRWQCB comment 5: The last paragraph in Section 2.1 implies that the proposed sampling <br /> locations described in Section 2.3 might change based on information gathered from <br /> publications and site reconnaissance. Please inform staff of any changes in proposed drill <br /> locations prior to performing fieldwork. <br /> Response: BTQCLC will inform the CRWQCB of changes or additions to groundwater sampling <br /> locations due to additional information obtained from the site reconnaissance discussed in <br /> Section 2.1 of the Work Plan. BTQCLC will also inform the CRWQCB if CPT/Hydropunch <br /> locations are problematic due to refusal. <br /> CRWQCB comment 6: Section 2.3.1 does not address CPT-5;please describe if the test will be <br /> performed as part of initial work or on an as-needed basis. <br /> Response: The proposed CPT-5 will be performed as part of the initial work pending access to <br /> the proposed location. <br /> CRWQCB comment 7: Section 2.3.3 discusses CPT-15 as an onsite location. Figure 10 shows <br /> CPT-15 as located to the west of the facility. Please clarify the test location. <br /> Response: The proposed CPT-15 is currently an offsite, downgradient location. BTQCLC will <br /> inform the CRWQCB if this location changes due to access issues. <br /> CRWQCB comment 8: The CPT discussion is not adequate for a reader to determine the scope <br /> of the investigation. There is no discussion of the following items: <br /> 1. What traces will be recorded. <br /> 2. What the target sample collection depth interval is. <br /> 3. How samples will be collected, sample containers, preservatives, etc. <br /> 4. How the CPT holes will be grouted. <br /> 5. A discussion of the need for permits issued by the San Joaquin County Environmental <br /> Health Department(SJCEHD). <br /> gags-groupWminl ob1031030118.08_barrelten106-corrspnCNtrsVspns_cmmtslcmmts-01.doc <br />