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California Regional Water Quality Confrool Board <br /> Central Valley Region r; <br /> Robert Schneider,Chair <br /> Linda Adams Arnold <br /> Secretory Sacramento Main Office ,. Schwarzenegg <br /> 11020 Sun Center Drive#200,Rancho Cordova,California 9567061 14 Govemor <br /> Phone(916)464-3291 •FAX(916)4644645 <br /> htip://www.waterboards.ca.gov/centrelvalley .:o 6 t 0 <br /> 2 June 2006 <br /> T <br /> Mr. Brian Miller <br /> Agrium <br /> P.O. Box 2300 <br /> West Lafayette, IN 47996-2300 <br /> ZERO VALENT IRON PILOT TEST, WESTERN FARM SERVICE INC., 1905 <br /> BROADWAYAVENUE, SAN JOAQUIN COUNTY <br /> Western Farm Service has been investigating and monitoring the extent of pollutants in <br /> groundwater emanating from former shallow evaporation ponds that were excavated in <br /> 1995 and capped in 1996. The predominant pollutants are 1,2,3-trichloropropane <br /> (1,2,3-TCP), 1,2-dichloropropane (1,2-DCP), nitrate, ammonium, dibromochloropro- <br /> pane (DBCP), and ethylene dibromide (EDB). The pollutants are found in the greatest <br /> concentrations in the first encountered water-bearing zone (A-zone), about 60 feet !!, <br /> below ground surface (bgs), downgradient of the former ponds. Pollutants are also <br /> found in lesser concentrations in the second water-bearing zone, which is about 100 ' <br /> feet bgs. <br /> Western Farm Service proposes to conduct a pilot study evaluating zero valent iron to <br /> treat these pollutants in situ. This proposal is described in Western Farm Service's <br /> 21 July 2005 Zero Valent Iron Pilot Test Work Plan (Pilot Test Work Plan) prepared by <br /> its consultant, GeoSyntec Consultants. GeoSyntec also provided two supplemental <br /> submittals: an 8 March 2006 Memorandum describing EHCTM, the product containing } <br /> the zero valent iron; and a revised proposed injection area in the 25 April 2006 Semi- <br /> Annual Monitoring Report. Regional Water Board staff review and comment on the <br /> Work Plan and supplements below. <br /> Bench-Scale Test Results ' <br /> Western Farm Service has been exploring groundwater treatment technologies for this <br /> site, and in late 2004 enlisted Sirem Laboratories to conduct a bench-scale treatability 1. <br /> study to test the insitu degradation potential of several groundwater treatments. The i <br /> treatability study results were reported in the 18 March 2005 Results of Treatability ! <br /> Study prepared by GeoSyntec Consultants. In the study, microcosms prepared with <br /> site groundwater obtained from one of the most polluted monitoring wells were treated <br /> with one of the following: chitin, Hydrogen Releasing Compound® (HRC), a slow- !' <br /> release emulsified vegetable oil (EOS), EOS plus KB-1 (a micro-organism capable of <br /> dechlorinating compounds), zero valent iron, untreated and sterile controls. Within the <br /> four-month study period all of the carbon-containing amendments began degrading <br /> nitrate and sulfate before the period was over, and appeared to begin degrading the I. <br /> chlorinated compounds at the end of the period. Some degradation of ammonium was <br /> California Environmental Protection Agency <br /> Irl Recycled Paper is <br />