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Corrective Action Plan I%wWl lw� Page 8 Cutter/Western Lift Site GPE Project No. 102.3 December 12,2003 u impacted soil that it serves will be partially recharged, and eventually the well will be returned to production. Using this system, each well will be in a recharging state for about half of the time, and will be in active production for half of the time. This method should help allow the maximum feasible recovery of gasoline hydrocarbons. 4.1.4 Catalytic Oxidizer Installation Based on results of the pilot test, it is anticipated that on completion and start-up of the system, the extracted vapor will be heavily laden with gasoline. Cost analysis shows that it situations where the vapor is gasoline-rich a thermal catalytic oxidizer "Catox" will be most cost effective in destroying the extracted gasoline. Such a system will be installed and operated during the early phases of the project. Later, as the gasoline concentrations decline, it will become more cost effective to replace that Catox system with activated carbon filters. Engineering data are insufficient to predict at what point this point will be reached, but it is likely to be weeks or perhaps a few months. 4.1.5 Carbon Unit Installation As the extracted vapor becomes leaner, the Catox system will be replaced with two carbon filters connected in series. The specific filter size will be evaluated at the appropriate time, but they are likely to consist of a single 6,000-pound carbon filter as the main vapor treatment device and a smaller, 2,000-pound activated carbon filtration unit will be installed down- stream as a "polish" unit to remove and residual gasoline that may escape the main unit prior to discharge to the atmosphere. 4.2 Remedial System Operation Once the system has been installed, it will be operated for an indefinite period until the site has been deemed to be adequately mitigated. u 4.2.1 Soil Vapor Extraction System Start Up On the first day of system operation, two vapor extraction wells will be placed in service, and an air sample will be collected from both the influent and effluent sides of the treatment system to satisfy an Air Pollution Control District permit condition. The vapor extraction rate is expected to be about 150 scfm. A manifold connecting the wells to the surface equipment will be equipped with gate valves so that the extraction rates for each well can be controlled and balanced. 4.2.2 Air Sparge System Start Up The air sparge compressor will be started on the first day of system operation. The rate of air injection will be monitored and adjusted so the each sparge well is injection approximately the same air volume. Initially the sparge rate will be held to about 3 scfm, per well, and then gradually increased to at least 5 scfm. 2937 Veneman Ave.,#B240 Geo-Phase Environmental Inc. Phone(209)569-0293 Modesto,CA 95356 Fax(209)569-0295