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Bioremediation Report - 6 - 3 October 1994 <br /> 16 S. Cherokee Lane, Lodi <br /> • <br /> D. Clean-Up Goals <br /> They propose to inoculate the bacteria the week of 15 August 1994, probably on the <br /> 16th. They estimate that soil clean-up will take from one to two years and ground <br /> water clean-up will take six months to a year. They state "Clean-up goals for the <br /> project will follow Leaking Underground Fuel Tank (LUFT) guidelines. However, as <br /> with all* remediation methods, LUFT levels are not always attainable." They also state <br /> that clean-up target levels for ground water are MCLS. However, they state "MCL's are <br /> often unattainable by any* groundwater remediation method." <br /> (* GeoAudit emphases) <br /> Comment - I am not sure what guidelines in LUFT they are referencing. We require that <br /> remediation projects attempt to reach non-detectable levels per State Board Policy 92-49. <br /> E. Contingency Plan <br /> As directed, they came up with a contingency plan consisting of a Vapor Extraction <br /> System (VES).. The VES will consist of an internal combustion engine to "extract <br /> hydrocarbons from the soil" and a blower to provide air sparging. <br /> The wells, VW1 through VW7, MW4, and MW5 will be used for vapor extraction. • <br /> MW14 and EWl will be used for air sparging. The VES and air sparging will operate <br /> 24 hours/day. Air samples will be collected monthly. An "interim" ground water <br /> pumping system will be implemented. Extracted ground water will be discharged to <br /> the sanitary sewer or bio-treated above ground and discharged to the storm drain. <br /> Treated ground water will be sampled monthly for TPHg, BTEX, and volatile <br /> halocarbons. A work plan detailing the system will be submitted to the Board one <br /> month prior to implementing the contingency plan. <br /> Comment - How the internal combustion engine will extract hydrocarbons from the subsurface is <br /> not explained. <br /> Comment - Why ground water will be pumped on an interim basis is not explained. <br /> Comment - An NPDES permit may be necessary for discharge to the storm drain and would <br /> require more than a month of preparation. <br /> Comment - No mention was made as to what circumstances would result in implementation of <br /> the contingency plan. <br /> • <br />