SITE INFORMATION AND CORRESPONDENCE

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OF CALIFORNIA - Environmental Protectiogency i PETE WILSON, Governor ..;ALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION 3toRoad, Suite A *Sacramento, nto,, CA 95827-3098 PHONE: (916) 255-3000 FAX: (916) 255-3015 aw,n 7 June 1994 - Mr. Mark Geweke JUN 0 9 1994 Geweke Land Development and Marketing ENVIRONMENTAL HEALTH Lodi, CA 952241 P.O. Box 12 PERMIT/SERVICES MEETING TO DISCUSS BIOREMEDIATION PILOT STUDY, GEWEKE SITE, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY Thank you for meeting with us on 13 May 1994 to discuss the Bioremediation Pilot Study results. The Pilot Study was an attempt to monitor a small-scale version of the proposed in-situ bioremediation system. The enclosed memo contains Board staff comments on the pilot study data. As we discussed during the meeting, Regional Board staff have serious reservations about the ability to monitor in-situ bioremediation systems to determine if hydrocarbon consuming bacteria are present, that they metabolize hydrocarbons in-situ, and that the bacteria are able to move through the subsurface and reach all the contamination. Generally, pilot studies are conducted to determine that an established remediation alternative will work at a site. Therefore, those setting up the pilot study know what parameters will prove the system is working or not, where evidence of system operation may be found, and which analyses are needed. However, when the Pilot Study was set up for this site, the necessary parameters, evidence, and sample locations were not well known. Rather than a completed Pilot Study, the result was more of a failed experiment. The data obtained and presented did not show that the inoculated bacteria were present, did not show that they were metabolizing hydrocarbons, and did not show that the bacteria moved through soil. The data failed to support the theory that the evidence of bacterial activity in soil, water and vapor could be detected. We do not believe enough was known about the bacteria and the in-situ bioremediation process to set up a meaningful pilot study, what kind and how many samples to collect, and the time period necessary. There were not enough data points to observe any trends or draw meaningful conclusions. During the meeting, your consultants, GeoAudit, stated that they would submit a report regarding the pilot study in about two weeks from the date of the meeting. The report is due by 10 June 1994. As discussed, in addition to narrative and all pilot study data, the report must contain the following: I. A map showing the location of the new borings; 2. Logs of the borings; 3. Estimates of the zone of influence of soil inoculation;