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Other possible sources of measured TBA in groundwater, including abiotic <br /> transformation in the environment, or presence of TBA as an artifact of chemical analysis <br /> methods, for the conditions investigated, are likely insignificant contributors for the <br /> levels of TBA observed at the investigated sites <br /> Microcosm analyses conducted on soils (collected below the water table) as part of this <br /> work showed degradation of MTBE and TBA in both aerobic and anaerobic conditions <br /> Investigation of co-metabolism of TBA or MTBE in the presence of propane was <br /> inconclusive, since degradation had been observed without the presence of the selected <br /> (propane) co-metabolic substrate <br /> In further conclusion, the identified prevalence of observed biodegradation of MTBE and <br /> TBA at the investigated sites is encouraging evidence for either a monitored natural <br /> attenuation or enhanced natural attenuation solution for these sites, as well as other <br /> similar underground storage tank remediation project sites Either existing natural <br /> attenuation guidance (ASTM E1943-98, Wiedemeier et al 1995, 1997) or a modified <br /> guidance to-be-developed would aid in this application As a preliminary proposal, along <br /> the lines of evidence commonly used in natural attenuation studies <br /> • To establish plume stability Continued groundwater monitoring of MTBE, TBA, and <br /> other chemicals of concern in quarterly monitoring events Evaluation of trends in <br /> data using statistical or other methods to establish that concentrations in the <br /> groundwater plume are stable or decreasing in time and extent <br /> Geochemical indicators Monitoring of relevant electron acceptors, primarily <br /> dissolved oxygen, sulfate, and nitrate, as well as methane, as evidence of biological <br /> activity <br /> • Biological indicators In selected cases, laboratory microcosm studies of site media <br /> samples to establish the level and type of biological transformation occurring at a site <br /> Finally, we note that the selected sites exhibited low groundwater gradients and inferred <br /> low groundwater seepage velocities We would expect the effects of biological <br /> degradation to be more significant and observable at these types of sites, than at sites with <br /> higher groundwater flow rates (high permeability/high recharge sites) This is especially <br /> true if degradation in anaerobic conditions is the significant transformation and removal <br /> mechanism <br /> 9. References <br /> ASTM 1998 Standard Guide for Remediation of Ground Water by Natural Attenuation <br /> at Petroleum Release Sites,E1943-98, American Society for Testing Materials West <br /> Conshohocken,PA <br /> 23 <br />