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�= Geological Audit Services, Inc. Environmental Professionals v 1803W.March Lane,SuiteA•Stockton.CA95207-(209)956-0264 FAX(209)956-0700 February 2, 1994 Ms. Elizabeth Thayer California Regional Water Quality Control Board Central Valley Region 3443 Routeir Road Sacramento, CA 95827-3098 Subject: 16 South Cherokee Lane, Lodi, Saa Joaquin County Dear Ms. Thayer: In response to your request that a bioremediation pilot study of the vadose zone be conducted at the referenced site, and in response to your additional concerns brought to our attention, we propose the following: 1) To ensure that groundwater is not in anyway impacted, we will use pneumatic packers or bentonite to plug each well as identified on the attachment at a depth of 40 feet. This should enable us to control the area impacted by the inoculum from surface to a depth of 40 feet. This would place the inoculum at a minimum of 20 feet above groundwater. 2) To monitor progress of bioremediation, we propose to measure organic vapors (OV) in each well on a weekly basis, along with any other reasonable monitoring that the Board may deem necessary. A PID will be used to measure organic vapors. 3) After 30 days, at the Boards designation, one soil boring will be drilled to monitor continuing progress. Samples will be analyzed for hydrocarbon concentration and bacteria plate counts. 4) The Pseudomonas aerigonosa is not a pathogen. At the most, it is a secondary pathogen and is common to the environment. There is no evidence to suggest that the public will come in contact with P. aerigonosa at any increased likelihood. 5) As stated before, the bacteria used are not slime-formers. However, in the event of the occurrence of a "bacterial sludge," EW-1 will be used to contain any sludge by pumping and storage in an above-ground tank. Full Spectrum Environmental Services• Hydrogeology