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Nutrien Ag Solutions, Inc. - 2 - 18 December 2023 <br /> construction issues, such as fouling, MW-9 will be installed and monitored after <br /> development. If the pH remains above 9 and 1,2,3-TCP concentrations are similar to <br /> those recently observed in MW-6RR, the Work Plan indicates a lactic or citric acid <br /> solution will be injected into groundwater to create an environment that supports <br /> denitrifying and dechlorinating bacteria. Once monitoring results indicate a stable pH at <br /> a safe level for these bacteria, a carbon source will be injected upgradient of MW-9 to <br /> support EISB. <br /> To address elevated nitrate concentrations in MW-3R, the Work Plan proposes injecting <br /> RNAS Remediation Product's Newman Zone, a carbon source intended to stimulate <br /> anaerobic microbial respiration of nitrate. Should the groundwater become sufficiently <br /> anaerobic as a result of adding Newman Zone to the treatment area, reduction of 1,2,3- <br /> TCP through biotic and abiotic pathways is a possible secondary effect. Injections are <br /> proposed up-gradient of MW-3R, and possibly in the northern corner of the Site, <br /> pending results from installing and monitoring MW-9. Exact specifications will be <br /> finalized in the forthcoming Notice of Intent for coverage under Order R5-2015-0012, <br /> General Order for In-Situ Groundwater Remediation and Discharge of Treated <br /> Groundwater to Land (General Order). <br /> Monitoring of MW-9 is anticipated to have happened prior to issuance of a Notice of <br /> Applicability which would permit EISB injections upgradient of MW-9 and/or MW-3. <br /> Upgradient of MW-3, and potentially MW-9, seven temporary injection wells will be <br /> advanced to 70 feet bgs using a truck-mounted direct-push drilling rig. At five-foot <br /> intervals and in each boring, three injections will occur between 55 feet bgs 70 feet bgs. <br /> A mixture of 200 pounds of Newman Zone and 420 gallons of water — per the <br /> manufacturers specification — will be applied to each boring, distributed approximately <br /> evenly between the three application depths. This material will be injected at a rate and <br /> pressure not to exceed 20 gallons per minute and 50 pounds per square inch, <br /> respectively. Upon completion, the temporary wells will be tremie grouted with neat <br /> cement and drill cutings stored in 55-gallon drums for characterization and disposal. <br /> Site monitoring wells will be sampled prior to conducting the pilot test, which will serve <br /> as a baseline. Following implementation of the pilot test, samples will be collected from <br /> the Site monitoring wells monthly for six months, followed by quarterly for one year, and <br /> incorporated into the semi-annual monitoring routine thereafter. Monitoring wells MW- <br /> 5R and MW-8R are intended to serve as compliance wells and MW-4 will serve as a <br /> background well, in respect to the General Order requirements. <br /> Central Valley Water Board concur with the proposed Work Plan, including the <br /> monitoring well replacement and EISB specifications. Please proceed with the <br /> destruction of monitoring well MW-6RR and installation of monitoring well MW-9 and <br /> notify Central Valley Water Board staff of the field schedule at least 48 hours in <br /> advance. Injection well construction and application of Newman Zone at the Site may <br />