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�,rATE OF CALIFORNIA - Environmental Protes Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> -CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> ,dacramento, CA 95827-3098 <br /> ONE: (916) 255-3000 <br /> AX: (916) 255-3015 ' <br /> 12 October 1994 <br /> Mr. Mark Geweke <br /> Geweke Land Development and Marketing <br /> P.O. Box 1210 <br /> Lodi, CA 95241 <br /> GEWEKE SITE, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY <br /> We have reviewed the following reports, prepared by your consultant Geological Audit Services <br /> (GeoAudit): <br /> 1. "Bioremediation of Hydrocarbon Impacted Soil and Groundwater", dated 10 June 1994, and a <br /> time schedule amendment, dated 22 July 1994; <br /> 2. "Workplan for Completion of an Aquifer Test", dated 27 June 1994, and; <br /> 3. "Quarterly Report: June 1994", dated 19 July 1994 <br /> • A memorandum containing staff comments on the three reports is attached. The quarterly report <br /> and the work plan were acceptable. GeoAudit has completed the aquifer testing proposed in the <br /> work plan, however, the results have not yet been submitted. <br /> Bioremediation Report Comments <br /> 1. Board staff had reservations about the usefulness of the data gathered during the pilot study. <br /> Our memo sent to you, dated 3 June 1994, explained those reservations in greater detail. <br /> 2. Regarding cleanup goals; note that remediation projects are designed to attempt to achieve <br /> non-detectable levels for soil and ground water. <br /> 3. The contingency plan for an alternative remediation system was provided, as required, to <br /> provide a backup in case bioremediation fails to work. The remediation technology proposed <br /> is acceptable: vapor extraction, "interim" ground water extraction, above ground <br /> biotreatment, and discharge of treated ground water to the storm or sanitary sewer. However, <br /> the contingency plan lacked a mechanism that would trigger its implementation and a time <br /> schedule for set up should implementation be necessary. Also, discharge to a storm drain may <br /> require application to the Regional Board for an NPDES Permit, which may take several weeks <br /> to process from the time a complete application has been submitted. <br /> 4. The comments in the attached memo, regarding the proposal to conduct full-scale <br /> • bioremediation, were primarily concerned with lack of explanation and rationale for <br /> inoculation of some wells and not others. However, Board staff believes that if bioremediation <br /> works at all, at this site, wells may be inoculated or reinoculated at a later date, as data <br /> indicate. Therefore, by telephone on 3 August 1994, staff informed GeoAudit that, although <br />