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Stantec <br /> Site History and Previous Investigations <br /> BP Stockton Terminal No. 40T <br /> June 17, 2009 <br /> was limited to a radius of a few ft from the well casing over the study period (IT, September <br /> 2001). <br /> Pacific Environmental Group (PEG) incorporated the results of the natural attenuation <br /> evaluation into the Corrective Action and Management Plan (1996). The plan recommended <br /> setting a trigger boundary at Stork Road, located down-gradient of the terminal lease area and <br /> an attenuation zone at the eastern boundary of the Port of Stockton property. Natural <br /> attenuation was proposed as the approach for addressing the petroleum hydrocarbon impacts <br /> within the attenuation zone. Impacts to groundwater within the terminal lease and up-gradient <br /> of the trigger boundary would also be addressed via natural attenuation. The plan proposed <br /> maximum contaminant levels (MCLs) as the water quality objectives at the trigger boundary and <br /> a monitoring and data evaluation plan was proposed to assess concentration trends (IT, <br /> September 2001). <br /> Stantec started an Iso-Gen feasibility test at the site on June 20, 2002. Due to safety concerns, <br /> Stantec on behalf of STTC, terminated the Iso-Gen feasibility test on July 25, 2002. It was <br /> discovered that during several Iso-Gen tests, the integrity of the wires within the wells had <br /> become compromised, causing the wires to short circuit, which created a potential explosive <br /> hazard. With this new information, the test was deemed unsafe due to the high hydrocarbon <br /> concentrations within the wells and the test being performed within an active terminal (SECOR, <br /> November 2002). <br /> URS conducted an enhanced bioremediation pilot study in 2004 and 2005. Approximately 720 <br /> gallons of an aqueous nitrate/sulfate solution were prepared at the site for each injection event. <br /> The aqueous solution consisted of 137 milligrams per liter(mg/L) of sodium nitrate, 400 mg/L of <br /> sodium sulfate, and approximately 500 grams of Miracle GRO that was added as a nutrient <br /> supplement. Once the solution was prepared, the injection system was started and the solution <br /> was injected into each well at a rate of 0.2 gallons per minute (gpm). Approximately 240 gallons <br /> of the solution were pumped into each well over a period of approximately 18 hours. The <br /> injection events began on May 25, 2004 and were performed weekly until June 22, 2004. <br /> Injections were temporarily stopped after the fifth event because the levels of sulfide exceeded <br /> the baseline limits set for monitoring well AR/MW-1A. The injections were restarted in August <br /> 2004, following a change in the baseline levels. During the course of the URS pilot study, a <br /> total of 11 nitrate/sulfate injection events were performed, during which, approximately 7,920 <br /> gallons of the nitrate/sulfate solution were injected. <br /> URS concluded that the impact of the nitrate/sulfate injections on the hydrocarbon <br /> concentrations only appeared to be significant near the injection points. GRO and benzene <br /> concentrations in groundwater monitoring well AR/MW-5A decreased compared to groundwater <br /> monitoring wells farther from the point of injection. Therefore, the pilot study indicated that <br /> nitrate/sulfate injections may be able to remediate dissolved hydrocarbons at the site (Pilot <br /> Study Evaluation Report Enhanced Bioremedation Pilot Study, URS, 2005). <br /> Stantec submitted a work plan to the RWQCB on May 7, 2007 for injection of nitrate/sulfate as <br /> part of the Enhanced Bioremediation Pilot Study (SECOR, 2007). The RWQCB developed a <br /> waste discharge requirement permit using background concentrations the previously <br /> established for groundwater based on the URS-2005 study. The problem with the background <br /> concentrations were that many of on-site wells contained groundwater with concentrations <br /> 0040T Site History and Previous Investigations.doc 3 <br />