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r y • • <br /> Memorandum - 2 - 9 December 1993 <br /> Geweke, 16 S. Cherokee, Lodi <br /> 7. They stated that they intend to dump one well volume of clean water into each injection point <br /> per month but they did not explain how this procedure will improve the moisture content in <br /> the vadose zone or if this water will percolate to the ground water and cause movement of the <br /> ground water plume. Control of the contamination plume and ground water flow must be <br /> maintained. <br /> 8. We have not been provided data on soil nitrogen and phosphorus, yet they have stated that <br /> addition of the nutrients is not necessary. <br /> 9. The radii of influence of the air injection points and bacteria injection points have not been <br /> provided, therefore, it is not possible to determine if the number of injection points is <br /> adequate. <br /> 10. The monitoring program they have recommended may not be extensive enough to determine if <br /> bioremediation is working adequately within the first six months of remediation. <br /> In order to attempt to determine if the in-situ bioremediation system is working, changes or <br /> additions to the existing monitoring program in the Cleanup and Abatement Order and Monitoring <br /> and Reporting Program are necessary. I recommend that the following be added to the Monitoring <br /> Program: <br /> A. Soil Borings in the vicinity of the injection wells - Quarterly <br /> 1. gasoline constituents <br /> 2. bacteria numbers, types <br /> 3. soil moisture <br /> 4. oxygen content <br /> B. Vapor monitoring - Monthly for the first 6 months, quarterly thereafter. I recommend a grid <br /> of vapor monitoring points. Additional points must be added. <br /> 1. Contaminant vapors <br /> 2. COD OZ <br /> 3. Methane and nitrogen gas <br /> C. Ground water monitoring - Monthly for the first 6 months, quarterly thereafter <br /> 1. COD OZ <br /> 2. Dissolved oxygen <br /> 3. Bacteria count, types <br /> 4. Intermediate breakdown products <br /> Geweke states that they will not need to add nutrients. Pat Leary of Wayne Pierson's Unit has <br /> informed me that they believe the proposed system does not pose a contamination threat unless, <br /> Geweke intends to introduce nitrates as a nutritional supplement. The addition of nitrates may pose <br /> a threat to groundwater. At a minimum, without adding nitrates, the system will require a Waiver <br /> of Waste Discharge Requirements and adoption of the waiver by the Board at the hearing in January <br />