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California &gional Water Quality Con l Board <br /> Central Valley Region <br /> Karl E. Longley,ScD,P.E.,Chair " <br /> Linda S.Adams 11020 Sun Center Drive#200,Rancho Cordova,Califomia 95670-6 1 1 4 Arnold <br /> Secretaryfor <br /> Environmental Phone(916)464-3291 •FAX(916)44-6 dl -A�������I \��i/{ ��� Schwarzenegger <br /> Protection http://www.waterboards.ca.gov/cenaIQyC./L i lI V l�t / Governor <br /> DEC 0 2 2008 <br /> 1 December 2008 <br /> ENVIRONMENT HEALTH <br /> Mr. Donald Rodgers PERMIT/SERVIGES <br /> 11900 South Union Rd. <br /> Manteca, CA 95336 <br /> DOCUMENT REVIEW, THE TRANSMISSION STORE, 515 WEST CHARTER WAY, STOCKTON, <br /> SAN JOAQUIN COUNTY(REGIONAL BOARD CASE# 390891) <br /> 1 reviewed the Air Sparging and Biosparging Treatability Test Work Plan (Workplan), received <br /> 25 November 2008 from your consultant Shaw Environmental Inc. (Shaw). The Workplan was <br /> submitted in response to my 9 October 2008 letter (Letter) which requested additional, conclusive <br /> supporting documentation to show why biosparging (BioS) will work at this site after it failed the first <br /> pilot study, and to evaluate other remedial alternatives, such as air sparging/soil vapor extraction <br /> (AS/SVE). The Workplan states that the brief length (2 days) of the initial pilot study, heterogeneities <br /> in the subsurface lithology in respect to the interconnectivity of the fine and coarse grained beds in the <br /> targeted zone, and the lack of a helium tracer may have been instrumental for inconclusive evidence <br /> whether BioS would be a successful groundwater remedial technology. Another factor noted in the <br /> previous BioS report include the leaking air line coupling which apparently biased the test results <br /> negatively by not supplying adequate air flow into the aquifer during the first day of the BioS pilot test. <br /> The second day BioS pilot test results (after repairs) showed increases in water levels in several wells <br /> and an increase in dissolved oxygen (DO) level in one well, but only at air pressures higher than <br /> typically used for BioS. <br /> The Workplan proposes a longer, two technologies (BioS and AS) test to determine the air injection <br /> zone of influence (ZOI). Immediately prior to BioS testing, Shaw will collect baseline measurements <br /> consisting of water levels, groundwater samples for petroleum hydrocarbons, wellhead organic vapor <br /> concentrations by photo ionization detector (PID), wellhead oxygen-carbon dioxide-methane gas levels, <br /> groundwater DO, and wellhead pressure. The existing sparge well, seven SVE wells, five groundwater <br /> monitoring wells will be monitored during both tests. Previously a portable compressor was located <br /> next to the sparge well for the 2-day BioS pilot study. Since the site is an active automotive shop with <br /> limited parking space and testing may take up to a month, new underground piping will be installed <br /> from the compressor (to be relocated in the SVE compound) to the sparge well. BioS testing for ZOI <br /> will be terminated when either the DO level in groundwater reaches 2 milligrams per Liter (mg/L) in the <br /> most distant monitoring well used during the test, or after one week of operations in BioS mode <br /> (20 pounds per square inch, or psi, of air pressure). If DO reaches 2 mg/L, then a five-day oxygen <br /> consumption test will begin to help determine the rate of aerobic biodegradation. Following the BioS <br /> testing, an increasing air pressure AS mode (30+ psi) will be conducted in a similar fashion to BioS, <br /> with the exception that the AS testing will be terminated if the four SVE wells show increasing vapor <br /> concentrations (by PID) over three hourly measurements, or after one week of operations in AS mode. <br /> If wellhead vapor concentrations show this steady rise in vapor concentrations, then an air sample will <br /> be collected (in a summa canister) and analyzed for total petroleum hydrocarbons as gasoline and <br /> benzene, toluene, ethylbenzene, and xylenes by EPA methods TO-3 and TO-15. Post test <br /> measurements will also repeat the baseline measurements listed above. The Workplan also includes a <br /> "provision" to use a helium tracer gas, but does not specify when that activity will occur. A report of the <br /> California Environmental Protection Agency <br /> ciRecycled Paper <br />