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average TPH concentration, only 47 . 8 pounds of nitrogen, 2 .4 <br /> pounds of phosphorous, and 14 , 400 cubic feet of oxygen are <br /> required to oxidize all of the hydrocarbons at this site. An <br /> in-situ concentration of 0. 85 ppm nitrogen is all that is <br /> required. A phosphorous concentration of only 0. 037 ppm would <br /> be sufficient. <br /> Three additional inoculation wells are planned. Samples will <br /> be collected and undergo agricultural analysis. If nitrogen is <br /> required for effective remediation, it will be added as UN32 , <br /> an agricultural grade liquid urea nitrate. The quantity added <br /> will be based on mass balance equations to convert TPH to <br /> biomass. Any phosphorous component needed will be determined <br /> during the agricultural analysis; however, experience has <br /> shown that it is unlikely that phosphorous would need to be <br /> added. <br /> 13) Only conditions above wilt are necessary for this <br /> bioremediation process; in a sandy soil, this is as low as <br /> 4 . 6% moisture on a weight basis. Soil desiccation due to <br /> aeration in the vicinity of the well bore has therefore not <br /> been a serious problem at similar sites. To avoid the problem, <br /> one ( 1) well volume of tap water will be added to each <br /> inoculation well on a monthly basis. <br /> 14) Samples collected during biannual drilling will be monitored <br /> for soil moisture to ensure that desiccation is not occurring. <br /> As stated in the FRP, we propose to monitor several wells on <br /> a monthly basis during the first quarter after inoculation. <br /> The wells will be monitored for groundwater depth, TPH as <br /> gasoline, BTE&X and pH. We feel that monitoring for nitrates <br /> is unnecessary unless nitrogen must be added as a nutrient. <br /> After the first quarter, the data will be evaluated and it <br /> will be determined whether a monthly monitoring program is <br /> still necessary. The regular quarterly program will continue <br /> in effect. <br /> 15) Your memorandum to Mr. Boggs stated that Pat Leary contacted <br /> GeoAudit concerning the Waste Discharge Requirements for the <br /> discharge of bacteria and medium to groundwater. GeoAudit was <br /> not contacted by Ms. Leary until your letter was received on <br /> 22 September 1993 . It is our understanding that a completed <br /> Report of Waste Discharge has since been submitted to Ms. <br /> Leary and the fee will be submitted as soon as the amount is <br /> determined. <br /> We hope that the information provided will be sufficient for you to <br /> complete your review and approval of the FRP. If additional <br /> information is required, please contact our office and we will make <br /> 5 <br />