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Geological Audit Services, Inc. <br /> w Environmental Professionals <br /> low1803W.MarchLune.SuwleA• Stockton.CA 95207 -(2091956-026a FAX(2091966-0700 <br /> December 28, 1993 <br /> (GeoAudit-1.33) <br /> Ms. Elizabeth Thayer <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road <br /> Sacramento, CA 95827-3098 <br /> Subject: Geweke Site - 16 South Cherokee Lane, Lodi, San Joaquin County <br /> Dear Ms. Thayer: <br /> In response to your memo to Mr. Gordon Boggs, dated 9 December 1993, Geological Audit <br /> Services (GeoAudit) has the following comments: <br /> 1) As with any remediation project, we would like to achieve non-detectable (ND) <br /> levels in both soil and groundwater, and this is indeed our goal. However, as you are <br /> aware, few in-situ technologies can achieve ND. We believe that bioremediation <br /> offers the greatest opportunity to achieve ND in both soil and groundwater. We <br /> believe that levels of <100 parts per million (ppm) in soil is realistic. We believe that <br /> ND can be achieved in groundwater. <br /> 2) The smear zone has indeed been addressed. The bacteria to be utilized are motile <br /> (they have flagella) and are capable of movement in both "free water" (saturated) <br /> and near-dry soil. Since the smear zone is thinner than the vadose zone and moisture <br /> content in the smear zone is greater than that in the vadose zone, we expect the <br /> smear zone to be remediated faster than the unsaturated (vadose) zone. <br /> 3) An agricultural analysis of soil from the site was performed by Agricultural Advisory <br /> Service (AAS). A copy of the analysis is included. It must be noted that information <br /> in the "comment" column is for agricultural purposes and does not necessarily apply <br /> for bioremediation. GeoAudit's microbiologist, Mr.James B. Hoeltgen, has reviewed <br /> the analytical data and has performed mass balance calculations on nutrient <br /> concentrations (see item 8) and has found the site suitable for bioremediation. <br /> O [%-1 Aw h-. I.., 1 <br /> Full Spectrum Environmental Services • Hydrogeology <br />