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Geweke, PRP 3 - 15 September 1993 <br /> and a table of ground water data for the Ukiah site. Site names and regulatory contacts were <br /> not provided. <br /> b. The Ukiah site was an ex-situ soil case in which the soil was treated above ground and then <br /> placed back in the pit. 'They have recorded a drop in ground water contamination since the <br /> soil was removed from the pit_ They have inferred that the treatment conducted on the soil <br /> has contributed to the decline in ground water contamination. However, similar drops in <br /> contamination have been noted at sites where the contaminated soil has merely been <br /> removed. <br /> 7. It appears that the Apple Valley site was an in-situ soil cleanup and that ground water was <br /> not involved. <br /> 8. Neither case study contained information on depth to water, estimates of volumes of <br /> contaminants lost, number of borings used to introduce bacteria to the subsurface, volume of <br /> bacterial consortia and media used, contents of the medium, species of bacteria in the <br /> consortia, number of bacterial inoculations required, size of the contaminated area and the <br /> locations of borings within the area. Neither case study was an in-situ ground water case. <br /> Soil characteristics were not provided either. <br /> 9. The results of any laboratory experiments, bench scale tests, and/or feasibility tests <br /> conducted for Geweke were not provided, <br /> 10. For Geweke, the contents of the bacteria] medium, the number of bacteria used, species of <br /> bacteria in the consortia, volume of the medium and consortia introduced to the subsurface, <br /> and the number of inoculations required, were not provided_ <br /> 11. The soil characteristics were not provided, including p11, TC, moisture contentlwater-bearing <br /> capacity/moisture retention curves. adsorpttonldesorption rates, metals toxicity, oxygen <br /> demand, nitrogen content, phosphorus content, trace mineral content, porosity, soil particle <br /> size distribution. AIL of these parameters have an impact on soil and ground water in-situ <br /> bioremediation. <br /> 12. The number and location of wells to be used to introduce bacteria into the ground water were <br /> q <br /> not provided. ,v,, t dlcf )�- '� �i• °`dQ�-`p "m grow---IW4 <br /> 1',/( •=li.cc a �j k-e 1 Y +` <br /> X3. There is no mention of ground water monitoring for introduction of medium plus consortia <br /> rY during the soil remediation phase. Without monitoring it will be difficult to determine <br /> whether ground water is being affected positively or adversely. <br /> I el' Other than monitoring contamination levels biannually, there is no mention of how they <br /> 15 propose to determine that the soil treatment system is actually working, if more bacterial <br /> inoculations are needed, if more oxygen is needed, if additional nutrients are needed, or if <br /> the soil has become desiccated. <br /> ti0' d 800' oN ££=6 £6' 91 dag ON X31 <br />