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Groundwater & Surface -Water Monitoring Response Plan <br />Currently, this monitoring system is being used by AMSO in each of the three L -3 wells and <br />MWP2 -BG. Pressure -head data are generally downloaded from the data logger and reduced at <br />each well on a monthly basis. The pressure -head data that AMSO is currently collecting are being <br />used to establish baseline conditions and to identify trends in pressure heads over time. This <br />information provides the basis for assessing potential changed conditions during the pilot retort <br />test. For example, a change in pressure head in one or more of the L3 wells that are not consistent <br />with the established baseline and trend analysis could indicate potential communication between <br />the pilot retort test interval and the L -3 hydrostratigraphic unit. Hydrologic monitoring during <br />pilot retort operations will be implemented as shown in Figure I and summarized as follows: <br />1. The data record at each well will be downloaded immediately prior to the initiation of <br />pilot retort testing operations. The data will be reviewed, incorporated into the baseline <br />(pre -pilot retort test) database, and used to monitor baseline water -level trends and <br />conditions. <br />2. Once pilot retort testing begins, the continuous data record at each well will be <br />downloaded daily. The downloaded data will be evaluated to identify any potential <br />deviations from baseline conditions. If the data are consistent with background trends, <br />monitoring continues with daily data downloads. If the data are not consist with <br />background trends, the following procedures will be implemented: <br />a. The data from all wells will be examined collectively to assess whether the <br />combined data suggest a regional trend affect in pressure head. <br />b. If the combined data show a regional trend affect in pressure head, the daily data <br />download schedule will resume. <br />c. If the data do not indicate a regional trend affect, formation temperature <br />monitoring data will be examined to assess whether the pressure deviations <br />correspond with potential excursion through the pilot -retort confining interval. <br />d. If the formation temperature readings corresponding with the pressure deviations <br />suggest potential excursion through the confining interval, pilot retort test heating <br />will be shut down, pressures reduced in a rapid safe manner, and groundwater <br />samples will be collected from all wells to begin groundwater protection <br />procedures (see Section 3.0 of this plan). Heating operations may resume after <br />the problem has been corrected. <br />e. If potential excursion through the confining interval is not indicated by the <br />formation temperature data, groundwater samples will be collected from the <br />suspect well(s) on a weekly basis. The groundwater samples will be submitted to <br />an analytical laboratory for expedited analysis of total petroleum hydrocarbons <br />(TPH) as diesel range organics (DRO) and gasoline range organics (GRO); <br />benzene, toluene, ethylbenzene, and xylenes (BTEX), total organic carbon <br />(TOC), and total dissolved solids (TDS). Field parameters (pH, conductivity and <br />2 <br />