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Mr. Nathan Esformes -2- 6 July 1993 expected from the best known available technology, then it may not be acceptable. It is up to you, as the responsible party, to show that the proposed treatment technology will achieve acceptable results. The Board has requested Triple E Produce to provide bench test results and/or case studies to show the bioremediation proposed will be effective. Since Mr. Crosby has indicated there are no such studies, the proposed treatment is considered to be experimental. If acceptable results are not achieved, you may be required to use more conventional treatment methods. Assuming the proposed method is to be conducted on an experimental basis, I have the following comments: 1. The proposal to saturate the plume betv.;e:t .*.111W-4A and 1%VV-2 .vith bacteria and oxygen does not assure that the contaminated ground water downgradient of MW-2 will be remediated. The latest sample results show chloroform levels up to 200 ug/1 in MW-6, approximately 300 feet downgradient of MW-2, and up to 10 ug/1 in MW-7, approximately 1,650 feet downgradient of MW-2. To assure remediation of all known contaminated ground water the plume should be saturated with bacteria, nutrients, and oxygen between MW-4A and MW-7. 2. In addition to monitoring for chloroform during the treatment phase, the presence of bacteria should be monitored in each of wells MW-4A, MW-2, MW-6, and MW-7. The presence of bacteria in these wells will indicate whether or not bioremediation has even had a chance to occur. 3. The proposal to sample MW-7 for four consecutive quarters to assure remediation is complete is not acceptable. Four consecutive quarters of chloroform levels below the final cleanup level are needed in each of the eight monitoring wells before remediation will be considered complete. 4. The proposed schedule should include baseline testing of nitrate and phosphorous. 5. As stated in uhe work plan, monituri��g wells ivies-4A, ivies-2, Ivies-6, and MW-7 should be monitored weekly for chloroform during treatment until the chloroform either decreases to below 4.5 ug/1 or stabilizes. The results of all monitoring shall be included in regular quarterly monitoring reports submitted to the Board. 6. A progress report shall be submitted to the Board within six months after treatment begins. The progress report shall include the results of all sampling and an evaluation of effectiveness of the treatment.