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1117 Lone Palm Ave;Suite 201 <br /> Modesto,CA 95351 <br /> Phone:209-579-2221 <br /> (:YAFax: 209-579-2225 <br /> CONCLUSION <br /> ATC spoke with Mr. Jim Barton of the Regional Water Quality Control Board (RWQCB) on the <br /> permitting and testing requirements of the biological treatment and bio-enhanced infiltration <br /> approach. According to Mr. Barton, there is no extensive record of field trials under rigorous <br /> testing and monitoring conditions and no general permit that covers this remediation method. <br /> This confirms that all of the testing steps mentioned above would be required at great length <br /> and expense, with concurrence required by both the RWQCB and the California Environmental <br /> Protection Agency (Cal EPA). Because the proposed process of bio-filtration coupled with re- <br /> injection is not a previously tested or approved method and lacks extensive documentation of <br /> effectiveness in California, the likelihood of the preparatory testing being funded by the State <br /> UST Cleanup Fund is low given the current fiscal conditions within the State of California. <br /> RECOMMENDATIONS <br /> ATC feels that the bio-remediation option may still be technically viable as a solution for this <br /> site, but understands that the absence of.an extensive field trial record for this method <br /> lengthens the regulatory approval process to.a year or more and may preclude State funding for <br /> any of that approval process. <br /> Based;on the information presented here and the recommendations contained in previous. <br /> CSWRCB'correspondence, ATC withdraws its prior recommendation for this method at this time, <br /> arid-recommends proceeding with the use of ozone injection as previously described in the <br /> Feasibility Study. <br /> Upon Agency concurrence, a detailed workplan will be prepared summarizing the appropriate <br /> path-forward steps. <br /> If you have questions or comments regarding this report or ourrecommendations, please call us at <br /> your convenience at(209) 579-2221. <br /> Respectfully submitted, <br /> ATC Associates-Inc: <br /> JEANNE �. <br /> HOMSEY <br /> Jim Kundert 1 <br /> Staff Geologist .? <br /> No. Gt47,4ifl <br /> u s Exp, oZo <br /> Jeanne Homsey, P.E. OF C- <br /> CA Registered Civil Engineer No. 47410 <br /> cc: Mr. Robert Eggiman <br /> Mr. James Barton, RWQCB <br /> s:\environmental\22493\reports\feasibility.doc 4 <br />