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Registry, General Reporting Protocol, Version 3, April 2008, annual CO2 emissions would <br /> amount to approximately 9,900 tons per year. <br /> 4.0 CONCLUSIONS <br /> It is concluded that neither aerobic cometabolism-based biosparging nor air-based biosparging <br /> is feasible for treating dissolved phase contamination near the City of Ripon WWTP Lagoons <br /> based on the analysis of effectiveness, implementability and cost of implementing a full-scale <br /> biosparging biobarrier described herein. <br /> The effectiveness analysis concluded that: <br /> • Air or oxygen injection alone would not effectively treat TCE. <br /> • TCE is not amenable to aerobic biodegradation and would not be treated by injecting <br /> air or pure oxygen into the subsurface with co-metabolites. <br /> • Aerobic cometabolism has been shown to treat the target CDCs in laboratory and <br /> research applications but would involve injecting hazardous, explosive gases into the <br /> subsurface under high pressure. <br /> • Aerobic cometabolism has not been widely used or further demonstrated and therefore <br /> it's effectiveness is highly uncertain <br /> • Achieving adequate distribution of air channels in heterogeneous, layer geology would <br /> be extremely challenging. Biosparging would likely not be effective based on delivery <br /> considerations. <br /> The implementability analysis concluded that: <br /> • The length of the barrier and likely duration of treatment would require long term <br /> access to a number of properties along the Stanislaus River. There are significant <br /> implementation challenges associated with property access. <br /> • The final full-scale system would be an almost mile long fenced compound adjacent to <br /> the Stanislaus River. There are significant implementation challenges associated with <br /> public acceptance of an almost mile long fenced remediation compound adjacent to <br /> the Stanislaus River. <br /> The estimated cost and energy requirements analysis concluded that: <br /> • The total cost for a biosparging barrier is estimated to be approximately $86.5 million. <br /> This is not cost effective compared to other measures such as water replacement, <br /> institutional controls and intrinsic remediation (these other measures would likely still <br /> be required in addition to biosparging given its dubious effectiveness). <br /> AMEC Geomatrix, Inc. <br /> \\oad-fs1\doc_safe\9000s\9837.006\4000 REGULATORYTS Assessment_Apx B_012711\Attachment B.1\Attach B1.doc Bl-10 <br />