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Environmental Bio-Systems,Inc. <br /> www.ehsinfo.com Since 1989 , <br /> 707 View Point Road Mill Valley, CA 94941 <br /> TEL: 415-381=5195;FAX: 415-381-5816; e-mail- augerpro@sbcglobal.net . <br /> "Quantification of the potential impacts of other remediation technologies on ISCO <br /> effectiveness may be supported by collecting and sending in specific samples for <br /> laboratory analytical and bench-scale tests prior to completing the ISCO feasibility <br /> analysis or design. The types of analytical tests will vary depending on the chemicals j <br /> known or suspected of being utilized previously or expected to be used,the type of ' <br /> oxidant potentially to be used, and the local geology/geochemistry." <br /> "The difficulty in using bench-scale studies to estimate field-scale oxidant demands may <br /> be explained by the high degree of subsurface heterogeneity and the oxidant demand <br /> testing protocol"(page 51). <br /> • There are no standards for bench testing,nor are detailed methodologies described <br /> in the ITRC document (ITRC, .2005): The ITRC guidance manual has been <br /> reviewed and procedures will be performed in a similar manner to the ITRC In- <br /> Situ Chemical Oxidation guidance document (ITRC.com). Bench testing details <br /> Details:on injection of oxidants will not be described in the bench test workplan <br /> or addendum (this letter), as the results of the bench tests may preclude the use of <br /> ozone. If ozone is selected as a remedial option, details on the methods, and <br /> variations (if any) from the ITRC description, will be noted. I <br /> • With ozone, pH adjustment is typically not a major concern, as it is for Fenton's <br /> Reagent. Nonetheless, EBS will note the quantities of acids, or.other chemicals, <br /> to be utilized for pH control.and the expected impact on water quality; <br /> i <br /> • EBS agrees that the ozone bench-scale test and microbiological bench-scale test j <br /> results can be reported in the same report of findings with a recommendation of <br /> both, one or the other, or neither, for potential use on the site. <br /> • Bioaugmentation is rarely recommended until the full evaluation of the I <br /> indigenous microbial communities is evaluated and, tested in the laboratory and in <br /> the field. A detailed description and justification of bioaugmentation, if <br /> warranted,will be submitted to the appropriate regulatory agencies for review and , <br /> approval; prior to any bioaugmentation, process. Bioaugmentation is not <br /> li recommended at this time. i <br /> Please call me at 415-.381-5195 if you have anyquestions. <br /> Sincerely, <br /> James A. Jacobs, P.G.#4815, C.H.G.#88 <br /> Chief Hydrogeologist <br /> f <br /> Main Office:229 Tewksbury Ave.,Point Richmond,CA 94801 Tel:510-232-2728;Fax:510-232-2823;May 20,2006 4 <br />