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The PHSEHD, CAP review indicated that the Central Valley Regional Water Quality <br /> Control Board, Region 5 (RWQCB) would require a "Report of Waste Discharge" <br /> (RWD) for the augmented infection of the native biologic microbes PHSEHD has <br /> indicated that moving forward on a remedial option is desirable at this time and that <br /> interim remedial actions would be considered pending implementation of a Remedial <br /> Action Plan. (RAP) <br /> James Barton at the Central Valley Regional Water Quality Control Board, Region 5 <br /> (RWQCB) requested Wright provided additional information available regarding the make up <br /> of the"ung ectable"component of the proposed process He confirmed that there currently <br /> were no WDR or WDO in place for petroleum sites in San Joaquin County using enhanced, <br /> insitu bioremediation In addition, Mr Barton confirmed a Report of Waste Discharge would <br /> be required for mjecting microbes and nutrients into soil and groundwater However, there are <br /> some variables to consider after that since the project could possibly be implemented as a pilot <br /> study and there could be site specific, Waste Discharge Requirements or possibly a General <br /> Permit to implement insitu bioremediation Mr Barton requested additional information from <br /> Wright to finrther consider insitu bioremediation for the Cox and Cox site <br /> • Reactions that will occur when microbes and nutrients are mjected subsurface <br /> • Chemicals released during process <br /> e Would there be any problems with metals <br /> • What was the irijectable substance(proprietary substance claims are problematic) <br /> Mr Barton indicated that interim remedial action (excavation around MW-3 and 9) could <br /> occur with PHS-EHD oversight concurrent to filing a RWD and subsequent permitting <br /> for insitu bioremediation under an approved RAP In addition, Mr Barton indicated that <br /> if the site later met closure guidelines because of interum remedial actions, the RWQCB <br /> permit process could be stopped <br /> After receipt of PHSEHD response to CAP, Wright had telephone conferences with the <br /> PHSEHD representative to revisit the use of biological "in-situ" processes and discuss <br /> interim remedial options It was generally agreed to leave options open for implementing <br /> the insitu biologic approach and implement interim remedial actions near MW-3 and <br /> MW-9 <br /> Both Wright and PHSEHD agreed that filing a RWD and other supporting documents for <br /> any required WDO, or Pilot Study and development of a RAP would add more time for <br /> implementing a cleanup method and ultimately obtaining closure for the site <br /> Considering the trend of increasing levels in MW-3 and MW-9 and what is otherwise a <br /> stable plume both Wright and PHS-EHD agreed interim remediation is indicated in those <br /> areas pending further actions associated with filing a RWD and a RAP <br /> Page 2 <br />