Laserfiche WebLink
02 October 2003 <br /> AGE-NC Project No. 01-0865 <br /> Page 2 of 4 <br /> provided in the Report. The calculations were provided in Appendix M and were <br /> further discussed in Section 4.0. <br /> 3. The Report recommends injection of ORC without providing the rationale for the <br /> recommendation.Regional Board staffbelieves there are additional remedial alternatives that <br /> are viable for this site,including a combined groundwater/soil vapor extraction system.H&H <br /> Marina needs to provide rationale for the recommendation of ORC injection and why other <br /> alternatives were not considered. <br /> AGE believed that ORC injection would be the most effective way to inhibit the <br /> spread of contamination off-site.The ORC medium canbe easilyinjected atmultiple <br /> points on and around the perimeter of the property utilizing GeoProbe technology, <br /> thus creating a barrier against further contaminate migration. At this time,AGE <br /> concluded that since lateral/vertical extent of contamination is not completely <br /> assessed and location/s of source/s still uncertain, remediating a point source (e.g., <br /> dual-phase extraction) may not be the most effective technology. <br /> 4. H&H Marina may stop sampling surface water locations DDN,DDS,IDCE,and IDC W and <br /> monitoring well MW-4 for ethanol and DDS and IDCW for methanol.The remaining sample <br /> locations have not met the required maximum method detection limits for ethanol and/or <br /> methanol as required in Monitoring and Reporting Program No. 5-01-835. <br /> AGE concurs with the CVRWQB and the above statement. <br /> 5. Appendix B of the Work Plan includes information on a site in South Carolina where ORC <br /> was used and information on degradation of methyl tertiary butyl ether(MTBE) by nitrate <br /> in the absence of oxygen. H&H Marina needs to provide the rationale for why this <br /> information is pertinent to the Work Plan. There is no discussion of how the site in South <br /> Carolina is similar to the H&H Marina site, other than both sites are discharging into a <br /> surface water, and the Work Plan does not propose nitrate analysis to determine whether <br /> nitrate may be degrading MTBE. <br /> Apart from the evidence from that article that ORC appears to accelerate MTBE <br /> degradation,physico-chem analyses of site soil boring samples suggest nutrient levels <br /> (nitrate, phosphate, potassium, etc) in the peat are sufficiently high to support <br /> bacterial growth; increasing oxygen demand should stimulate anaerobic bacterial <br /> activity. AGE concurs that nutrient levels need to be monitored for ORC-injection <br /> remediation. <br /> 6. The Work Plan proposes four borings, each 12 feet from monitoring well MW-3, but does <br /> Advanced GeoEnvironmental,Inc <br />