SITE INFORMATION AND CORRESPONDENCE

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Geweke, FRP 2 - 15 September 1993 contamination has not migrated ahead of the bacrteria. The samples will be analyzed for TPHg, BTEX, and pH. Monitoring pH may ensure the carbon dioxide "is not adversely affecting ground water quality". Because of the "indigenous nature of the bacteriological culture, not composing a waste or waste product, it is not anticipated that a waste discharge permit" will be required. Instead, Geweke would like to prepare a negative declaration. GeoAudit states that the completion time for in-situ bioremediation is dependent upon the number of inoculation wells, the number of inoculation events, the rate of bacterial migration in soil, and the suitability of selected bacterial cultures to the contaminants. In sandy soil GeoAudit estimates that it could take 12 to 24 months and up to 36 months in clayey soils. They assert that in-situ bio has the potential to remediate soil and ground water to non-detectable levels. Because of the significant quantities of soil contamination, the Fluctuation of ground water, and permit acquisition, GeoAudit proposes to initiate soil remediation in the first phase, immediately upon approval of the regulatory agencies, and to begin ground water remediation in the second phase, at a later date. GeoAudit was told by me, in June 1993, and subsequently by Pat Leary, that Waste Discharge Requirements were necessary for the discharge of the bacterid and medium to ground water, Pat recently sent a letter to the dischargers, requiring submittal of a Report of Waste Discharge and fee. This discharge falls under the General Permit for Underground Tanks but issuance of the permit will likely Cause Geweke to miss their deadlines. The Cleanup and Abatement Order requires that they begin startup activities by 15 October and begin remediation by t5 November 1993, The PRP is incomplete_ The following information was not in the FRP: 1. Some of the cross-sections refer to borings or wells, GL-3 and GL-4, that are not described in other figures or the text. Other wells, VW-1 through VW-4 are mentioned in the text but not shown in the figures. 2. A letter in Appendix C is addressed to me, but I have not received a copy of this letter by mail or Fax. The tetter does not have a signature block and is not signed_ 3. No mention is made of soil contamination in the "smear cone" or soil zone that has become contaminated due to contact with fluctuating contaminated ground water. The extent of soil contamination shown in the FRP is limited to the vadose zone above the water table and smear zone. 4. No mention is made of remediadtlg the smear zone and the wells that are proposed for introducing bacteria into the vadose zone and ground water may not affect the full extent of soil contamination in the smear zone, 5. In the FRP, sketchy case studies were provided for two sites, one in Ukiah and one in Apple Valley. The only information provided are graphics for the Apple Valley site, and graphics 20' d 800 ' ON 212:6 25, 91 daS . oPJ 131