OF THE STATE OF ILLINOIS

PAUL JOHNSON INC.,

)

Petitioner,

)

V.

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY and•

)

CITY OF WATERMAN, ILLINOIS,

)

),

Respondent.

.

)

CLERK’S OFFICE

DEC

10

200’i

STATE OF ~LLU’~O~S

PoUUt~OflCofltrO~~oard

)

PCBNO.

To:

Tom Difasio

-

Director ofPublic Works

Village. ofWaterman

NOTICE OF FILING

Lynn Dunaway

Illinois Environmental Protection Agency

Public Water

Supplies

-

Field Operation Headquarters

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Clerk ofthe Pollution

Control Board the Petition

For

Community Well SetbackException ofPaul Johnson Inc., a

copyof which is herewith, seived upon you.

Richard M. Saines

BAKER & McKENZIE

130 East Randolph Drive,

Suite 3500

Chicago, illinois

6060.1

(312)861-8000

Respectfully submitted,

December

10, 2004

SUBMITTED

ON RECYCLED PAPER

---

CERTIFICATE OF SERVICE

I, Richard M..Saines, certify that I have served the attached

Petition For Community Well

Setback Exception, by first-class mail, up~on

the following persons:.

•

Tom Difasio

,

•

•

•

Director of Public Works

Village ofWaterman

215 Adams Street

Waterman, IL

60556

(815)264-3652

.

•

Lynn Dunaway

•

Illinois Environmental Protection Agency

Public Water Supplies

-

Field Operation Headquarters

1021 North Grand Ave., East

P.O. Box 19276

•

•

•

.

Springfield, IL 62794-9276

(217) 782-1020

~McKENZIE

---

•

.

~CE~V~!D

•

CLERK’S OFFICE

DEC

10

2004

BEFORE

THE

POLLUTION CONTROL BOARD

STATE OF

ILLINOIS

OF THE STATE OF ILLINOIS

.

Pollution Control Boar*~1

PAUL JOHNSON INC.,

.

)

Petitioner,

)

)•

V.

•

)

PCBNo.

0

)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY and

)

CITY OF WATERMAN, ILLINOIS,

.

)

)

•

Respondent.

.

.

)

PETITION FOR COMMUNITY WELL SETBACK EXCEPTION

•

NOW

COMES

the Petitioner,

Paul

Johnson

Inc.

(“PJI”), by

and

through

its

attorneys,

Baker

~

McKenzie, and pursuant to

Section

14.2(c) of the Illinois Environmental Protection Act

(“Act”) and

Part 106

of the Board’s Procedural

Rules

(35

Ill.

Adm~Code

§

106.300,

et seq.),

hereby petitions the

Illinois Pollution

Control

Board (“Board”),

to

grant

PJI

an

exception from

the community water

supply well setback ~equirethentsin

Section

14.2 ofthe Act.

In support of

its Petition, PJI states as follows:

I.

BACKGROUND

PJI

is

seeking

this

waiver

from the

setback requirements

in

Section

14.2 of the Act

to

enable PJI ,to remediate existing shallow groundwater contamination.

The shallow groundwater

located

within

the

setback

zone

of the

Waterman,

Illinois

community

water

supply

well

is

contaminated

with~hydrocarbons,most likely

residues

from

former underground

storage tanks

p

(“USTs”) used to store fuel for vehicles.

The preferred clean up method

is the use ofdirecfpush

technology

(i.e.

Geoprobe) to inject microbes, nutrients,

and oxygen release compound (“ORC”)

directly into the plume of impacted groundwater (referred to herein as “in-situ bioremediation”).

Upon

completion of each

injection,

the

open

hole

is

backfilled with

granular bentonite

and

---

hydrated,

thereby eliminating

the

risk

of future

pathways

of contamination

into

the shallow

groundwater zone.

The location ofthe Site is shown on Figure

1 in Attachment A.

Section

14.2 ofthe Act prohibits the installation of

any

“new potential route” within 200

feet of an exi’~tingmunicipal water well. 415

ILCS

5/14.2.

The use ofdirect push technology to

•

•

inject microbes, nutrients,

and

ORC

into the

plume

of impacted groundwater technically

falls

within the definition of “new

potential

route”.

415

ILCS

5/3.350.

Section

14.2

allows

for

sources

to

petition

the

Illinois

Pollution

Control

Bpard

and

the

Illinois

EPA for an ,exception

from this setback requirementunder appropriate circumstances.

As discussedin this petition, PJI

meets

all

of the

requirements

for granting

the

exception

from the

set

back

requirements of

•

Section

14.2 of the Act.

•

A.

The Reasons

for and Basis of theRequested Exception

The need for the set

back exception arises

from broadly worded statutory definitions that

•

technically

include

the

current

remediation

activities

within

the. definition

of “new

potential

route.”

Most “inj~ction

wells” are considered pathways of contamination, either intentionally as

a

disposal

route,

or

unintentionally

as

an

easy

migration

pathway.

Both

concerns

are

inapplicable

in

this

case.

PJI

seeks

to

use

in-situ

bioremediation

to

clean

up

an

existing

contaminated groundwater source rather than allow this contaminated groundwater to remain in

the shallow aquifer.

The use ofin-~itubioremediation is the

most cost effective and technically

feasible

alternative in this

case.

In addition,

the

shallow contaminated

groundwater that is the

subject of ongoing

remediation efforts is

not

hydraulically

connected to the

deep

aquifer from

which

the

community

water

supply well

draws

its

water.

Thus,

there

is

no

significant risk

of

cross-contamination of the

community

water

supply

by

use of in-situ

bioremediation.

As

a

2

---

•

result,

pursuant to

Section

14.2(c),

the Board should grantthe requested exception as set forth in

detail below.

•

.

•

.

•

B.,

Nature of the PJI’s Operations

•

1.

P.11’s

Former and Current Operations.

•

PJI

formerly operated

a truck maintenance and leasing operation in Waterman, Illinois.

•

As

part of those

operations, PJI owned and operated

several USTs

used for storing

fuel for the

trucks.

PJI,

upon

removal

of the

USTs,

discovered that

they

had

leaked.

PJI

subsequently

entered into the Leaking Underground Storage Tank (“LUST”) program with Illinois EPA under

which

it

is

currently conducting

soil and

groundwater remediation

activities in pursuit of a No

Further

Remediation

(“NFR”)

letter

from

Illinois EPA.

These

clean up

efforts

have

included

,

removal

of ,approximately

4,730

cubic

yards

of

impacted

soil,

83

gallons

of

free

phase

•

hydrocarbon, application of 800 pounds of ORC to the base ~f the excavation and installation of

•

•

.

.

.

,

,

‘

22 monitoring w~lls.During the process ofthe

ongoing remediation activities,

PJI learned that a

•

portion ofthe current shallow groundwater contamination is within approximately

150 feet ~of

the

•

‘

existing

community water supply well for Waterman,

Illinois.

PJI’s environmental consultants,

Clayton Group Services, Inc. (“Clayton”), have recently installed additional borings to determine

the extent ofthe shallow groundwater plume:

The plume ‘extends to

an area not’yet treated with

ORC, and located within the setback zone ofthe Waterman community supply well.

With

the

exception

of the

above-mentioned

ongoing

clean

up

efforts,

PJI

no

longer

conducts any operations.

Mr. Paul Johnson, the sole shareholder ofPJI, passed away in February

of 2002.

Since

then,

PJI

has

remained

in ~existenceand

adequately funded for the purpose of

•

completing the necessary clean up ofthe site and obtaining an NFR from Illinois EPA.

Once PJI

obtains

an

NFR,

the

remaining

assets

of the

corporation

will

be

distributed

to

the

intended

beneficiaries ofMr. Johnson’s estate,

‘

‘

3’

---

2.

PJI’s Control Equipment.

‘

Prior

to

treating

the

hydrocarbons,

‘a

series

of injections

are

completed

around

the

perimeter of the

hydrocarbon

plume.

The

purpOse

of the.perimeter injections

is

to

form

a

hydraulic barrier that prevents the lateral migration ofthe contaminant plume

during treatment.

Furthermore,

t_he

upon

reaching

a

depth

of approximately

14. ‘feet

.

below bound

surface,

the

ORC, thicrobes and nutrients are injected in a horizontal pattern to treat the surrounding area,and

‘control the depth ofthe injection~Upon completion of each injection, the open hole is backfilled

with

granular

beiitonite

and

hydrated,

thereby

eliminating

the

risk

of

fçiture

pathways

of’

contamination into the shallow groundwater zone.

The

shallow

groundwater

zone is

separated

from

the

deeper

aquifer from

which. the

community water supply ~el1 draws its

water by a shale unit at a depth ofapproximately 40

feet

Felow ground surface.

The disconnection between the shallow groundwater zone

and the deeper

aquifer is

evjdent in

the lack of influence

continued pumping ofthe community well has on the

shallow

groundwater

zone,

(i.e.

cone

of depression).

If connected,

the

shallow

groundwater

should

move

towards the well..

Instead, the

groundwater. flow direction,is

to the northeast and

away from the municipal

well.

Further discussion of the geology below the Site

is provided

in

Section V ofthis Petition.

.

•

•

•

‘

II.

COMPLIANCE WITH.THE SETBACK

REQUIREMENTS

WOULD

IMPOSE,AN ARBITRARY AND UNREASONABLE HARDSHIP

(35

IAC

104.310(A))

.

.

The Board

should

grant an

exception in this

case

because preventing PJI from utilizing

in-situ bioremediation to remediate the contaminated shallow aquifer would delay the cleanup of

the

shallow

aquifer

and

add

significant

and

unnecessary

costs.

The

other

remediation

altern~tives

are

discussed in

more

detail in

Section IV of this

Petition,

but

with

each of them,

theirrespective negatives

outweightheir respective benefits.

‘

.

4.

---

There are three primary factors that make adherence to the setback requirements arbitrary

and unreasonable

in this

case.

First, the use of in-situ” bioremediation within the setback area is

intended to improve the water quality.

The area is already contaminated with hydrocarbons, and

the sooner remedial activities are undertaken, the sooner the shallow groundwater will be cleaned

up.

.

Second,

in-situ bioremediation would

only be utilized for the shallow groundwater zone,

which is not hydraulically connected to the deeper aquifer from, which the‘Waterman community

•supply

well

draws

its

water.

Accordingly,

the

injection

wells

at

issue

will

not

affect

the

groundwater zone utilized by

the community supply well.

Evidence ‘that the two water bearing

zones

are

not~

connected

is

presented

in

more

detail

below,

but

the ‘fact

that

the

existing

hydrocarbon

contamination

has

not,’ reached

the

deeper

aquifer

(as

demonstrated

by

the

community water testing) supports this

important fact.

The 2003

Consumer ‘Confidence Report

for the Village ofWaterman is included in Attachment B.

Third,

Mr.

Paul Johnson,

the

sole shareholder of PJI, passed away in

February of 2002,

and

the

Estate

has

continued

to

maintain

PJI

‘for

the

purpose

of

funding

the

,

ongoing

environmental remediation.

The longer it takes to

complete the remediation and obtain ‘an NFR,

the longer P’JI’s assets remain undistributed to the intended beneficiaries of Mr. ‘Johnson’s Estate.

PJI has and will continue to maintain adequate resources to fund the completion of remediation

and obtain

an NFR,

but it does not want to

prolong’or delay this process unnecessarily.

B~ecause

PJI is in the LUST program and entitled

to reimbursement for approved remediãtion expenses, it

‘

is

likely

that

significant

funds

will’ be

available

for distribution

to

the

beneficiaries

once

the

remediation

is

complete.

As

such,

any

delay

in

obtaining

an

NFR

prevents the

beneficiaries

from receiving’ theseEstate assets.

‘

‘

,

‘

5,

---

-

Because the most cost efficient and expedient remediation technology is the use ofin-sim

bioremediation.~

to’ remediate

the

shallow

aquifer,

adherence

to

the

prohibition

on

locating

“injection wells” within a minimum setback ofa community supply well

would be arbitrary and

unreasonable under these circumstances.

III.

IN-SITU

BIOREMEDIATION IS

THE BEST

AVAILABLE

CONTROL

TECHNOLOGY ECONOMICALLY ACHIEVABL’E’(35 IAC 106.310(B))

PJI

is seeking the exception to

the setback requirements to enable it to

clean up existing

N

contamination located within the setback area of a community supply well.

Thus, the regulatory

Criterion mandating the

best

available

control technology

economically achievable to

minimize

the

likelihood

of

contamination

of the potable

water

supply

well

should

be

analyzed

more

broadly.

In’essence, the key inquiry in this

case involves selecting a remediation technology that

will be most

effective in

cleaning up

the‘existing contamination

and not, by

itself,

increase the

risk

of ‘exacerbating

such

contamination.

This

inquiry

must

also

consider

the

“economic

achievability”

of any

potential

technology.

When

these

factors

are

considered

under

the

circumstances ofthis

case, in-situ bioremediation is

the best available technology economically

achievable.

Clayton has evaluated several potential

alternatives to

in-situ bioremediation.

Each one

ofthe potential

alternatives is described below.

The potential alternatives include:

(‘1) installing

a traditional “pump and t~eat”

system;

(2) attempting to use Electric Resistive Heating (“ERR”),

an emerging technology described in more detail below; ~r (3) relocating

the, community supply

‘well

.

to

an

area

free

of

existing

contamination.

As

shown

in’

this’

section,

each

of

these

alternatives’ presents’ technical,

practical

and

financial

obstacles

that

eliminate

them

as

the

preferred approach.

‘

6

\

---

A.,

Pump & Treat

-

,

-

The

effective removal

and

subsequent treatment of groundwater from the contaminated

shallow

aquifer is limited

in

this case due

to the

low permeability of the

soils

(1 0~cm/sec) and

the adsorption ofthe contaminants to’ the matrix ofthe aquifer that hinder the ability to meet ~the

Class I Groundwater Remedial Objectives for the contaminants ofconcern.

The in-situ hydraulic

conductivity

testing of monitoring

wells

completed

in

the

unconsolidated

overburden indicate

that the hydraulic

conductivity of the unconsolidated overburden ranges from 2.57

x

I0~

cm/sec

to 6.29

x

10~cm/sec.

The

average hydraulic conductivity of the unconsolidated overburden is’

4.36

x

I0~cm/sec.

‘

Thus,

pump

and

treat

technology

is

not

recommended

based

upon

its

technical feasibility.

Moreover, the estimated cost to

design and install the pump & treat system

is $100,000

to

$150,000, with long-term operation and maintain costs of approximately $400,000’

-

$500,000 over 20 years.

B.

Electrical

Resistive Heating (ERR)

ERR

is

an

emerging

in-situ remediation technology that

uses the heat generated by the

resistance

off the

soil

to

the

flow

of electrical

current

(through

electrodes

installed

into

the

subsurface)’to raise subsurface temperatures and

force the contan~inant

into the vapor phase.

A

vapor recovery system is then used to remove the vapor from the subsurface.

ERR

can be used

to remediate tight

clays (l06 cm/sec or less), used around buried utilities, under buildings.,

ERR

is in use’in certain sites with volatile organic compound (“VOC”) contamination.

To

date,Ithas

not

been

utilized

to

remediate

residual hydrocarbon

contamination

in

a

shallow

aquifer.

The

estimated cost to

complete the PJI site utilizing ERR is between $600,000

and $700,000 with an

estimated completion time of one to two years.

Accordingly, given its high ~ostand the fact that

7

---

this would be the first installation ofERR to rèmediate, hydrocarbon contaminated groundwater,

ERR isnot the preferred alternative..

C.

Replacement and Relocation ofMunicipal Well

‘

-

The cost

to move ,the municipal

well ‘is

currently unknown but estimated to be

between

$750,000 and $1,000,000;

Unknown factors that need to be

addressed prior to

a final estimated

price ‘include the~numberof test borings/pump

tests to

determine• the

sustainable

yield

of the’

aquifer, distance req~iired

to connect the,new well to the existing water.supply network, and the

-

neçd

to

purchase the

parcel

‘on which

to

locate the

well,

as

well

as

securing

easements

or

condemning property to locate the pipeline.

Furthermore, following replacem~entofthe well, PJI

will

s’till

be

required

to

either

minimize

rernediation

under

TACO

or

complete ‘remediation

through in-situ bioremed.iation, ERH, or anothçr form of alternative technology in order to obtain

‘‘closure o,f this incident.

This alternative is cost prohibitive and uncertain.

D.

In-Situ Bioremediation

.

‘

In-Situ bioremediation uses

direct push technology to

deliver the microbes and nutrients

directly

to the areas ofcontamination.

By delivering the microbes, oxygen and nutrients directly,

remediation ofthe ‘site is not hindered by the low permeability of the aquifer or dependent on the

migration of the’ groundwater

to

transport the

nutrients

and

oxygen to

the contaminants.

The

estimated

cost

to

complete

the remediation of the

PJI

site

utilizing

in-situ

bioremediation

is

approximately $210,000 and will take approximately one year to

complete.

,

‘

In-situ bioremediation is the best alternative for remediation ofthe PJI

site.

It will work,

it is safe, and it is the most cost effective.

The treatment will consist ‘of multiple injection points

via

direct

push

equipment

With

an

injection

point

designed

tO

inject

in

a

horizontal

pattern

autward from

the injection point.

Each injection point will first undergo a pre-injection pathway

8

---

,development consisting of a

10’ second blast of’ 175 psi

air stream.

Following the pre-injection

pathway

development,

approximately

100

gallons

of

bio-slurry

and

10

gallons

of

liquid

hel~ertrophs

(hydrocarbon degrading bacteria) will be injected into the subsurface.

Following the bio-slurry injection, additional injections will be completed to provide both

ORC ‘and a mixture of nutrients

and

dilute

hydrogen peroxide to ‘accelerate degradation.

The

ORC injections are completed in the same manor as the bio-siurry injections.’

‘Pu

is proposing the injection of in-situ bioremediation into’ the saturated zone

in the area

within the setback zone ofthe

municipal well.

The

treatment will

consist ORC injection points

each consisting of approximately

‘15 pounds

of .ORC and

50

gallons of water.

The

bio-slurry

injection points

will

consist of approximately

9.6

gallons of bio-slurry and

approximately

100

gallons ofwater

‘

‘

,

To

provide

hydraulic

‘control

of the~contaminatedshallow

groundwater,.

Clayton

will’

.

‘

H

strategically place ORC

injection points

along the east, west, and south ,edge of the excavation:,

Further discussion

Of the

technology and material

safety

datq sheets

for the microbes, nutrients

and ORC’ are provided in Attachment C.,

IV.,

THE MAXIMUMFEASIBLE ALTERNATIVE SETBACK WILL BE

.

UTILIZED (35 IAC 106.310(C)).

,

The data collected to date demonstrates that the contaminated shallow groundwater exists

-

in

a plume

loCated

underneath

the PJI

site.

The

closest’ edge

of the plume

to

the

community

-

supply well

is

approximately

60

feet southeast of the

municipal well.

Direct push technology

allows

PJI

to

maintain

hydraulic

control

of

the

contaminated

shallow

groundwater

while

delivering

microbes,

nutrients

and

ORC

directly

to

the

contaminated

shallow

groundwater.

Since PJI

,is able

to

treat only the impacted shallow groundwater, PJI

is making every effort to

9’

---

minimize the number

of injections within the

setback of’the

municipal

well.

PJI

will

work

closely With Illinois EPAin finalizing the precise locations ofeach ORC injection well.

V.

IN-SITU BIOREMEDIATION INJECTIONS

WILL NOT

HARM

THE

COMMUNITY WATER SUPPLY (35 IAC 106.310(D))

The use ofin-situ bioremediation

in this case is

the appropriate remediation ‘technology

because it will work without

harming the

community

water

supply.

The ke~hydrogeologic

features of this site, discussed in

detail below,

demonstrate that

in-situ bioremediation i~

a safe

technology ‘for use in this

case in part because, the natural

features of the

site provide a barrier

betweenthe shallow and deep groundwater zones.

The shallow groundwater zone underlying the

PJI

site

is

nOt

hydrogeologically

connected to

the

deeper aquifer

from

which

the

community

water

supply

well

draws

its

water.

‘

PJI

has

not’. observed,

any

influence

on

the

shallow

groundwater

beneath

the

Site

(ie.

cone

of

depression)

by

the

continued

pumping of

the

municipal

well.

Instead, the groundwater flow direction is‘to

the northeast and

away from the

municipal well as shown on Figure 2 in AttachmentA.’

Soil

borings

completed

at the

‘site

by

Clayton

indicate

that

the

site

is

underlain

by

approximately

12

feet of silty

clay.’

The’ silty clay

is

underlain by

approximately two

feet of

• medium to fine-grained sand, (‘14 to

16 feet bgs):

The sand is underlain by approximately 8

to

10

feet of silty

clay

(16

to

24

feet bgs).

Below

the silty

clay,

silty

sand was encountered

to

the

termination of the soil boring (24 to 29 feet bgs).

Shallow groundwater’at the Site was identified

within

an unconfined silt and

silty clay unit at a depth of apprwdmately

1,0

feet below

ground

surface.

‘

‘

The well log for community municipal well #2 (located approximately

150 feet northwest

ofthe Site) indicates that the unconsolidated overburden extends to

a.depth ofapproximately .40

feet bgs

and

is underlain by

a “shale”

unit with’ a’ thickness of approximately

17

feet.

Beneath

10

---

the shale unit is a gravel unit with

a thickness of approximately

23

feet underlain by

a second

shale unit with a thickness ofapproximately 42 feet.

The second

shale unit extends to the top of

‘limestone at a depth of approximately

122

feet bgs.

According to the well log, Well #2

is cased

from the ground surface to bedrock (124 ft bgs) and is completed at a depth of 400 feet bgs.

The

‘presence oftwo shale units between the unconsolidated overburden and bedrock is evidenCe that

the shallow groundwater in the unconsolidated overburden

and the bedrock aquifer used by the

Village of Waterman are not hydraulically connected.

A Geological

Cross Section based on the

municipal

well

logs

is

shown on

Figure

3

in

Attachment A.

The’ well

logs

used in

the

Cross

•

Section are included

ui

Attachment D.

‘

-

VI.

PROOF OF NOTICE TO AFFECTED

POTABLE

WELL SUPPLY

•

OWNERS

•

,

PJI

has

caused written notice

and

a

copy of this

Petition

to

be

sent to

the ~fol1owing

•

affected

potable

well

supply

~Wners:

Village

of Waterman,

215

Adams

Street,

Waterman,

Illinois,

C/U

Tom

Difásio,

Director of Public

Works.

The

above notified person was

selected

based upon

a

survey conducted by Clayton to identify all potable water supply owners within the

setback area of the proposed ORC injection

wells pursuant

to

35

IAC

106.302(b),, 35

IAC

101

and Section 14.2(c) ofthe Act.

.

‘

,

‘

•

VII.

REQUEST FOR EXPEDITED HEARING

,

‘

-

The intended beneficiaries of Paul Jc~hnson’sEstate

will not receive the remaining assets

,of PJI until

it

is

appropriate

to

disburse such assets.

Obtaining

the ‘requested waiver

from

the

setback

requirements

‘is

a

key

‘

step

in

furthering

the

ongoing

remediation

process

toward

completion.

The parties request a

hearing on

this’ petition as soon as the Board can reasonably

schedule it.

‘

,

11

---

I

WHEREFORE, for the foregoing reasons, PJI respectfully requests the Board to

grant an

exception from the setback\requirements contained in Section

14.2 of the Act.

PAIJLJ

,

NINC.

B~

One ofIts Attorneys

‘

Richard M; Saines

.

BAKER & McKENZIE

130 East Randolph Drive,

Suite 3500

‘

Chicago, Illinois

60601

(312)861-8000

,

‘

CHIDMSI/453326.3

12

---

m

—1-

---

QUADRANGLE

LOCATION

1

MILE

3

1000

0

1000

2000

3000

FEET

~I~F-I

I

I

FIGURE

1

SITE

LOCATION

MAP

PAUL

JOHNSON, INC.

340 WEST ADAMS

WATERMAN, ILLINOIS

(SOURCE OF

MAP

IS USGS 7.5 MINUTE QUADRANGLE MAPS, WATERMAN, ILLINOIS)

Scale

1:24000

0

1/2

(

)

---

I

BUILDING

—----i----~I

JOHNSON~

BUILDING

2

MARATHON

ABOVE

GROUND

STORAGE

TANK

FARM

_I

APPROXIMATE

LOCA11ON—/’

OF

FiRE

I-fYDRANT

n

—

-

-__-

-

~7i

-

-__

I

PROPERTY

LINE—’

I

GRAVEL

PARKING

L/////////////

I’

//////l

FOR

JOHNSON

/

APPROXIMATE

SIDE

AND

LOCA11ON

OFID&M

~

/

EXCAVATING

B1~IWING

H-”-

/

I

/////////

~

‘/71/7/7//i

.

~—_~•

.

~(ABANDONED

6/12/03)

~

-

UMIFS

OF

D(cWA11ON_\\\

MA~NSON

(

)

SEED

&

GRAIN

I

ADAMS

STREET

I-Ui

Ui

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I0

_________

_________

NH,

~

1)

,~N~DONEO

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_____--

~~~‘~P1o

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CIDENT#20024

PROPERTY

LINE

LEGEND

+

MONIrORING

WELL

LOCA11ON

(CLAYTON)

*

MONIrORING

WELL

LOCA11ON

(WARTYN)

+

MUNICIPAL

POTABLE

WATER

WELL

(ABANDON)

i~

MUNICIPAL

POTABLE

WATER

WELL

(ACTIVE)

(9

1,00)

GROUNDWATER

ELEVATiON

MEASUREMENT

—

GROUNDWATER

CONTOUR

(FEEt)

‘—~——

GROUNDWATER

FLOW

DIRECTION

PLAYGROUND

&

PARK

SCALE

IN

FEET

0

20

40

80

‘CHECK

BY

SRS

1DRAWN

BY

OS

~

DATE

11—0—04

SCALE

AS

SHOWN

CAD

NO.

01192060

PR,)

NO.

10—01192

I

I

I

~

~

~

POTEN11OMETRIC

SURFACE

MAP

9—14—04

PAUL

JOHNSON,

INC.

340

W.

ADAMS

STREET

WATERMAN.

ILLINOIS

FiGURE

I

Claytoff

GROUP

SERVICES

2

---

NORTH

AA

850—

800

—

700—

_J

i-

600—

LULU

500

—

400

—

NOTES:

1.

VERTICAL

EXAGGERATION

X2

HORIZONTAL

SCALE:

1

“=200’

VERTICAL

‘SCALE:

1

“=100’

2.

CROSS

SECTIONS

ARE

BASED

ON

BEST

PROFESSIONAL

JUDGMENT

USING

AVAILABLE

DATA.

THE

THICKNESS

AND

EXTENT

OF

THE

LITHOLOGIC

UNITS

ARE

APPROXIMATED

AND

GEOLOGIC

CONTACTS

BETWEEN

BORING

LOCATIONS

ARE

INFERRED.

CHK

BY

SRS

OWN

BY

OS/BCP

DATE

9—16—04

SCALE

AS

SHOWN

CAD

NO.

0119206B

PRJ

NO.

15—01192.06

CROSS

SECTION

M

—

PAUL

JOHNSON,

INC.

WATERMAN.

ILLINOIS

SOUTH

AA’

T

850

—

800

H-

700

—

600

H

500

—

400

-J

U)

I-

w

w

U.

ir~

Claytort

GROUP

5ERVICES

FiGURE

3

—I--,

-.1

~J

~

SITE

-J-J

‘-‘~-‘

---

Exhibit

B

---

Page

1

of2

11/4/2004

Annual

Drinking

Water

Quality

Report

WATERMAN

1L0370600

Annual

Water

Quality

Report

For

the

period

of

January

1

to

December

31,

2003.

This

report

is

intended

to

provide

you

with

important

information

about

your

drinking

water

and

the

efforts

made

by

the

WATERMAN

water

system

to

provide

safe

drinking

water.

The

source

of

drinking

water

used

by

WATERMAN

is

Ground

For

more

information

regarding

this

report,

contact:

Name:

_______________________________

Phone:___________________________

Este

informe

contiene

información

muy

importante

sobre

el

agua

que

usted

bebe.

TradUzcalo

O

hable

con

alguien

que

lo

entienda

bien.

Source

of

Drinking_Water

The

sources

of

drinking

water

(both

tap

water

and

bottled

water)

include

rivers,

lakes,

streams,

ponds,reservoirs,

springs,

and

groundwater

wells.

As

water

travels

over

the

surface

of

the

land

or

through

the

ground,

it

dissolves

naturally-occurring

minerals

and,

in

some

cases,

radioactive

material,

and

can

pickup

substances

resulting

from

the

presence

of

animals

or

from

human

activity.

Drinking

water,

including

bottled

water,

may

reasonably

be

expected

to

contain

at

least

small

amounts

of

some

contaminants.

The

presence

of

contaminants

does

not

necessarily

indicate

that

water

poses

a

health

risk.

More

information

about

contaminants

and

potential

health

effects

can

be

obtained

by

calling

the

EPA’s

Safe

Drinking

Water

Hotline

at

(800)

426-4791.

Contaminants

that

may

be

present

in

source

water

include:

Microbial

contaminants,

such

as

viruses

and

bacteria,

which

may

come

from

sewage

treatment

plants,septic

systems,

agricultural

livestock

operations

and

wildlife.

Inorganic

contaminants,

such

as

salts

and

metals,

which

can

be

naturally

occurring

or

result

from

urban

storm

water

runoff,

industrial,

or

domestic

wastewater

discharges,

oil

and

gas

production,mining,

or

farming.

Pesticides

and

herbicides,

which

may

come

from

a

variety

of

sources

such

as

agriculture,urban

storm

water

runoff

and

residential

uses.

Organic

chemical

contaminants,

including

synthetic

and

volatile

organic

chemicals,

which

are

by-products

of

industrial

processes

and

petroleum

production,

and

can

also

come

from

gas

stations,

urban

storm

water

runoff,

and

septic

systems.

Radioactive

contaminants,

which

can

be

naturally-occurring

or

be

the

result

of

oil

and

gas

production

and

mining

activities.

In

order

to

ensure

that

tap

water

is

safe

to

drink,

EPA

prescribes

regulations

which

limit

the

amount

of

certain

contaminants

in

water

provided

by

public

water

systems.

FDA

regulations

establish

limits

for

contaminants

in

bottled

water

which

must

provide

the

same

protection

for

public

health.

Some

people

may

be

more

vulnerable

to

contaminants

in

drinking

water

than

the

general

population.

Immuno-compromised

persons

such

as

persons

with

cancer

undergoing

chemotherapy,

persons

who

have

undergone

organ

transplants,

people

with

HIV/AIDS

or

other

immune

system

disorders,

some

elderly

and

infants

can

be

particularly

at

risk

from

infections.

These

people

should

seek

advice

about

drinking

water

from

their

health

care

providers.

EPA/CDC

guidelines

on

appropriate

means

to

lessen

the

risk

of

infection

by

Cryptosporidium

and

other

microbial

contaminants

are

available

from

the.

Safe

Drinking

Water

Hotline

(800.426-4791).

---

Source

Water

Assessment

Availabilty.

When

available,

a

Source

Water

Assessment

summary

is

included

below

for

your

convenience.

To

determine

Waterman’s

susceptibility

to

groundwater

contamination,

information

obtained

during

a

Well

Site

Survey

performed

by

the

Illinois

Rural

Water

Association

on

June

23,

1998

was

reviewed.

Based

on

this

information,

numerous

potential

sources

of

contamination

were

identified

within

proximity

of

this

water

supply’s

wells.

The

Illinois

EPA

does

not

consider

the

source

water

susceptible

to

contamination.

This

determination

is

based

on

a

number

of

criteria

including:

monitoring

conducted

at

the

wells;

monitoring

conducted

at

the

entry

point

to

the

distribution

system;

and

the

available

hydrogeologic

data

on

the

wells.The

Illinois

Environmental

Protection

Act

provides

minimum

protection

zones

of

200

feet

for

Waterman’s

community

water

supply

wells.

These

minimum

protection

zones

are

regulated

by

the

Illinois

EPA.

To

further

minimize

the

risk

to

the

community

water

supply’s

groundwater

source,

the

Illinois

EPA

recommends

that

three

additional

activities

be

assessed,

First,

the

community

may

wish

to

enact

a

“maximum

setback

zone”

ordinance.

These

ordinances

are

authorized

by

the

Illinois

Environmental

Protection

Act

and

allow

county

and

municipal

officials

the

opportunity

to

provide

additional

protection

up

to

1,000

feet

from

their

wells.

Second,

the

water

supply

staff

may

wish

to

revisit

their

contingency

planning

documents.

Contingency

planning

documents

are

a

primary

means

to

ensure

that,

through

emergency

preparedness,

a

water

supply

will

minimize

their

risk

of

being

without

safe

and

adequate

water.

Finally,

the

water

supply

staff

is

encouraged

to

review

their

cross

connection

control

program

to

ensure

it

remains

current

and

viable.

Cross

connections

to

either

the

water

treatment

plant

(for

example,

at

bulk

water

loading

stations)

or

in

the

distribution

system

may

negate

all

source

water

protection

initiatives

provided

by

the

community.

---

Regulated Contaminants Detected

in

2003 (collected in 2003

unless noted)

0

ppb

IS ppb

B

J

1.3

ppm

1.3

ppo~

J

1,1

I

J

Cotnosion

ofhousehold

plotnbing

systems; Erosion of natural

deposits

tYater

Quality Test Results

Definitions: The following

tables contain scientific

terms and

measures.

some of which may

require explanation.

Maximum Contaminant Level (MCL): The

highest level ofa contaminant that is allowed

in

drinking water. MCL’S are set

as close

to the Moxium

Contaminant Level

Goal

as feasible using

lire best available

treatment technology.

Maximum Contaminant Level Goal (MCLG): The

level ofa contaminant in drinking water below whclftherno-knowns~r’expectedTisk’to

health,MCLG’s

allonv for a margin ofsafety,

n,g/l:

milligrams per

litre or

parts

per million-or

ooe ounce in

7,350 gallons of water,

ug/l:

Inicrograms per litre or parts per billion

-

or one ounce in

7,350,000 gallons of water,

na: not applicable.

Avg:

Regulatory compliance with sonic MCLs

are based

on

running

annual average ofmonthly samples.

Maximum

Residual

Disinfectant Level (MRDL):

The

highest level ofdisinfectant allowed

in

drinking water.

Maximum

Residual

Disinfectant Level (M’RDLG): The

level of disinfectant

in

drinking

water below

which there

is

no

known

or expected risk

to

healllr.MRDLG’s

allow

for a margin of

safety,

Page 2

o

Rrgnlatrrl

C,,ntotninonto

Fligltest

Range of Levels

11,11 of

~?CLC

MCL

Violation?

Likely Source ofContamination

L,vnl

Detected

&t,asor—

Disinfectant,

& Disinfection

By—Prodnct,

Total

Haloac,t,c Ac,ds

lI’IAAS)

‘2.5

2.5.2,5

ppb

60’

No

By-peodt,ctofdr,okingwater

chlorination

Ti HM5

Total Trdtalo,oetIto,,esl

I.?

1.2-1.2

ppb

n/a

00’

Na

By-productofdr’irrking lOoter stdorinalion

Inorganic

Contnn,inants

Arsotoc

411

0.9.40

pplr

t/n

Is

No

Erosiottolnatirral deposits;

ttonoff

fror,t

orchards;

Rasofffrom electronics prodttclien

tvastes

Barium

0.23

0.1.0.23

pp.,,

2

2

No

Dmscha,ge ofdrilling

svasles; Discharge

from

osetat refineries;

Erosion ofnatural

deposits

Flmtormde

1.05

0.90-1.05

ppm

4

2

No

Erosion ofoottmrat

deposits; Waler

additive nvlsirlt proutotes strong bell,;

Ferbilicor discharge

Radioactive Cn,tnminonls

Alpha

Emitters

I0/30/200t

4

2-4

pCi/L

0

No

Erosion ofnassral

deposits

State Regulated Contanrinarit,

ron

0000

330-10000

t’tamrgonese

,

70

20-70

Sradius,,

5t

16-51

J

ppmtt

,Ja

swaIn, softenerregerrerotion

There

is

101

a slate

of federal

MCL

Forsodtttns.

Mottitonitrg

is

reqtsired

10 provide irrfornrstiotr

10 cotisotoers and IreallI,

ofhicials Iltat are cotreerned

abool

sodisnr

salake cttre

to dietary

precatrltolts.

II

you

are aIrs sodistnr-reslricted diet,

yost

sltouldconsstlt

a

plrysiciasi abosit

lIds level

ofsodiom

in the

nvater,

‘MCI. Srateasersr: TIte nrasit,tutn cotrlaoroterrl

level

(MCL)for TTHM

attd

HAA5

is

00

ppb

attn

60

ppb

respectively attsl’is’cttrreatty only applicable Ia

sua’tisee

nvssev

sttppltes

lital

serve

0.000 or more people.

These MCLs

tvill

hecotoe eliective

01/01/2004 for all grosttrdnvster

ittpplies

strd streface

strppties

serving less

llrart 10,000

people,

Uttlsl

01/21/2004, sstrface

avaler

sstpphies

servtttg

less tlraur

0.000 people, any size nvater snpply Iltat

prtrcltose

Fronr a sstrfacn uvalgr’sosrrce

.

ansI

grottndsvater

sttpplies

servarg. more tlsao

10,000 people

tostst meet

a

stale ittrposed TTHM MCL of

100 ppm.

Sotrre people wlto

tlrirrk nEater contaitming lrilralonrellrsnes

in

excess of

lie MCL over marty years expertettce

problesrrs svillr

tlreir

livers, kidtteys, or

cesrlral nervosts sysleltis,

arrd

may

Itave

ittcreased risk

ot’gelting

catrcer.

Learl anti Copper

Defrtritionrs:

Action

Level (AL): Tire concentration of a colnlarniraant svhaicli. if exceeded, Iriggers treatment

or

other requirements which a water system

nsust follow,

Action

Level GoaI(AGL): TIne

level ofa contansinatst in

clritsking water

belouv whicls there

is no known

or expeciedrisk’to’hesitia. ALG’s allow

for amargin of

safety.

Leant

Lead Action

Lead 90th

0 Sites Over

Cnl,tmer

Cotrer

Action

Cnp~rer9Otl,

OSiten Over

Likely

Smmarve of Conlnn,ir,otion

STCLG

Level IALI

Percentile

Lend AL

SICLG

Lend

hALl

Percentile

Copper AL

Erosion fco,tt

rraotratly

occttrving

deposits

or, ofnatorally

occurring deposits

EPA has

reviewed the drinking water standard

for arsenic

because ofspecial concerns that it

sissy sot

be stringent enottgla.

Arseisic

is

a

saturally-occurring

mineral

ktsonvnto cause

cancer

itt

humans at sigh

concenlrations.

---

m

0~

-~

C)

---

Proposal to Perform In-Situ Bioremediation of Soil and

Groundwater

to

Clayton

Group Services

For

Paul Johnson Property

Waterman, Illinois

June

2003

Innovative Environmental Technologies, Inc.

830 Bear Tavern Road

Suite 301

Ewing, New

Jersey 08628

(888) 721-8283

---

Project Summary:

INTRODUCTION

Innovative Environmental Technologies has reviewed the field data collected by

Clayton Group

Services including well logs,

soil and groundwater sample data from The Paul Johnson Property

Waterman, Illinois.

The targeted constituents would appear to be suitable for accelerated

attenuation via biological mineralization.

Innovative Envioronmnetal Technologies, Inc. Has

delineated, broadly, three areas, (Areas “A”, “B” and “C”).

lj/f~~~//~/

/

/

/~

/

/

A

/

/

/

/

/

/

/

/

‘I

s~ro~~fr/~/

sO’,OS+

+~°‘7

,/‘

sn~na,~

~am

//

‘ADAMS STREET

.

ron,.,on

1.000

SAL.ouSocINr

/

/////

~‘~LJI

/

//////////////////,.77//

//

I

///~~~/~///A—

r~p

/

/

/

/

/

/

~‘

I

‘r’IY

/sy~’/IX~1V

/~4

lJ/l/

/

~/

/

A

t~

“C”

//

‘::;

/

/

/

/

/

/

/

/////,

o

•

+

55

Paul Johnson Property

-

Targeted Treatment Areas

---

JET has structured a program, which will allow for significant removal over a two-year period,

with accelerated attenuation enhanced by the biomass established during the active phases.

Data Evaluation:

The recommendations made hereinby Innovative Environmental Technologies, Inc. incorporate

the field data and remedial experience such that accelerated attenuation may occur outside’ofthe

source area and active remediation

may occur within the source area.

The

results ofthe field enumeration analyses indicate that the

environment is not toxic

and is suitable

for the

proposed remedial

action.

The

results

indicate

that there

is little

selective activity

based on

source area samples from:

Selective

Pseud. Count

Total Hetero Count

MW-15

100

CFU/ml

12,600 CFM/mL

MW-16

100

CFU/ml

4,700 CFM/ml

Sump-4

800 CFU/mL

6,000 CFU/mL

The population

dynamics at the site indicated,

that, although there is

no toxicity present, there exists

significant

competition

for

nutrients

and

terminal

electron

acceptors

by

non-aromatic

degrading

species.

The

relatively low target

compound concentration

compared to the

background BOD/COD

indicates

that

simple stimulation without augmentation

will not result in prefential

target

compound

mineralization.

General Site Plan Discussion:

If,

the

remedial

plan

were

to

consist

solely

of oxygen

enrichment,

greater

consumption

of

the

resources

would

occur

by

the

non-aromatic degrading,

gram

positive

population

sub-set.

The

lab

evaluation and the plating process indicate whether there exists bacteria at the site,

it does not evaluate

the

activity of that population.

It

is

important

to

recognize

that

the

plating process

allows

for the

dormant cultures to become active.

It is difficult to judge the in-situ conditions,

where competition for

resources is present.

The capabilities of the

dormant Pseudomonas to become vegetative and utilize

resources consumed by

the competing gram-positive population will significantly vary from laboratory

enumerations.

It

is

most

probable that

the nutrient

and

terminal

acceptor

limiting

conditions

have

existed at the

site for some

period of time.

As

a consequence the

total plate count represents

spored

gram-positive organisms.

The pHs of6.9 to 6.6 indicate that the historical processes have been slightly anerobic, however, given

the

low substrate seen in the monitoring wells, the

anerobic processes have

not ggeneratedsignificant

depression

in

the

pH

to

warrant

the

application

of a

pH

control prograkm.

Had

the

pHs

been

depressed

the

JET

proposal

would

integrates

calcium peroxide as

an

oxygen

release

source

within

portions

of the

plume.

Calcium peroxide

revert to

calcium

hydroxide

during

the

release process,

allowing

for elevated

pH via

the reversion

to

calcium hydroxide during

the

oxygen release process.

better pH control.

The results for the essential nutrients, nitrogen and

o-P04, further substainiate the

remedial approach proposed which consists ofessential nutrients, vegetative cultures (pseudomonads),

---

and

terminal

electron

acceptors

(oxygen release

compounds in

as calcium and

magnesium

peroxide

and dilute hydrogen peroxide).

Innovative Environmental

Technologies,

Inc.

(JET)

has utilized dilute

hydrogen peroxide within

the

bioslurry component to meet the SCOD demand.

This demand will come from primarily the inorganic

sources such

as

iron

and

manganese.

Further

the

sequestration

of bioavailable o-P04

by

the

non-

oxidized

cationic

species

shall

be

addressed

by

the

integration

of

additional

o-P04

within

the

bioslurry.

The

agency’s

request

for

copper,

zinc and

lead analysis

can

only be

assumed

to

be

an

outgrowth of cationic sump feature which

is addressed

both by the H202, o-P04

and biosequestion

that will occur within the JET program.

The

remedial

program

recommended

by

JET

integrates

vegative

pseudomonas

so

as

to

compete

effectively

with

the

ingenious

gram

positive,

general

BOD

degrading

population.

Further,

the

incorporation ofthe vegative BTEX degrading pseudomonas allows foreffective bio-film formation in

the

vadose

zone

during

the

critical

“mounding”

stage of the

process.

It

is

during

this

phase

that

abundant oxygen and nutrients are present with the vegetative cultures in

the capillary area.

Without

the incorporation ofthe cultures, stimulation with oxygen and nutrients

will drive the population ratios

in the saturated zone further toward

the non-BTEX degrading gram positive strains and in the vadose

zone entirely allow for gram positive bio-film formation.

Innovative Environmental has evaluated the

site data.

The ammonia,

pH, o-P04, iron and biological

enumerations

all indicate that the proposed remedial plan is suitable

for the site.

JET has the terminal

electron

acceptor demand based on

the sorbed and dissolved fractions.

Sorption can be defined as the

interaction

of a

contaminant

with

a

solid.

More specifically,

the

term can

be

further

divided

into

adsorption

and absorption.

The former refers to an excess contamination concentration at the surface

of a solid

while the latter implies

a more or less uniform penetration of the solid

by

the contaminant.

Unfortunately,

in

this

environment

and

most

environmental

settings,

there

is

no

information

concerning the specific nature ofthe interaction.

As

a result sorption shall be used in

a generic way to

address both phenomena.

As a general rule, assuming a petroleum hydrocarbon is equally distributed

between

phases

is

ill

advised.

As

hydrophobic

compounds,

these

compounds

will

partition

preferentially to the soils.

Within

a system where the pore water occupies 30

ofthe aquifer volume,

two (2) liters ofaquifer would contain 600 mL ofwater and 3500 grams ofsoil (soil is about

2.5

times

more

dense than water).

As

a

result, if there was equal distribution of the

contaminant between

the

phases, slightly less than

15

ofthe contaminant mass would reside within the aqueous phase.

Give

the hydrophobic

nature of the

targeted compounds

much

less

of the

targeted

contaminant’s mass is

found in the dissolved phase.

This partitioning is strongly associated

with an individual compound’s

solubility, as the solubility of a hydrophobic compound decreases, the absorption coefficient increases.

Since

adsorption

is

an exothermic

process, values

ofK00~decrease with

increasing

temperature.

A

10

increase

in

K50~

will

accompany

a

100

Celsius

system decrease.

(

A

compound

that

is highly

soluble

will

have

a

small

solubility

product

constant.)

Thus,

given

the

changes

in

measured

temperature across a site

the phase distribution of the

contaminant and

the

potential

aqueous phase

increases due

to the temperature decrease may be estimated to be 36.2

to 40

with just

a ten degree

temperature decrease.

Absorption ofmolecules can be represented as a chemical equation:

---

A+B

4iiiiiii!

AS

B,

where A

is the adsorbate, B

is

the adsorbent and AB

is

the absorbed compound.

Adsorbates are held on

the surface by a variety of chemical forces.

Ifthe reaction is reversable, as it

is

for many compounds

absorbed

to

carbon and

soils,

molecules continue

to

accumulate

on

the

surface

until

the

rate of the

forward reaction

is

equal

equals

the

rate

of the reverse

reaction

(Adsorption

=

desorption).

When

this

condition

exists,

equilibrium

has been

reached

and

no

further

accumulation

will

occur.

One of the most important characteristics of an absorbent

is the quantity of absorbate it

can

accumulate.

Regardless

of

the

absorbent

an

eventual

equilibrium

is

achieved.

Individual

compounds absorb and desorb based on that compound’s adsorpstion isotherm.

This

data may be used

to estimate the equilibrium point via the Freunich equation:

q ~

=

KC11’~~

q

e

Equilibrium Surt~iceConcentration

C~

Equilibrium Solution

Concentration

K

Constant related to the capacity oJ’the absorbent Jbr the absorbate

I/n

Constant is aflinction o/the

strength o!’absorption

The constants are generally known for activated carbon, but not soils, primarily due to the variability

throughout soil types.

However, given a sample point with known analytical values for both the

aqueous phase and the soil phases a comparison ofthe calculated concentrations using the Freunich

equation both for q

and

C~is possible.

Back calculating the calculated soil concentration from the

known liquid value and the theoretical liquid concentration from the know soil concentration generates

an agreed proportional relationship between the site’s soils and carbon.

This is possible when soil

samples from the

saturated zone are obtained.

When no saturated samples are

available some assumed

correlations between the site’s soil matrix and GAC is applied.

As

an

Example:

Benzene

data utilizing

the

constants

below

and

an

aqueous

concentration of 0.463

ppm and a soil concentration of47 ppm

a corrected absorption factor may be calculated.

K

50

(mg/g)(L/mgy

1/n

1/n

0.533

Aq

Conc.

.

~ppm

CaIc.(qe)o

33.16841148

mg/g

Yields

a theoretical

q

e

o/33.

17

ppm.

In

that

the

site’s

soils

tend

to be clays,

an

assumed correction

percentage of

35

(indicating

that

the

soils

tend

to

retain

35

of what

a

true

carbon particle

will

entrain).

Thus applying this assumption to the previous calculation yields.’

K

50

(mg/g)(L/mg)”l/n

1/n

0.533

Aq

Conc.

_____________________

CaIc.(qe)o

33.16841148

mg/g

---

Soil Corr.

35

Estimated Volume

567.4074074

Cu. Yds

Estimated Pore Volume

0.3

Calculated Soil Targeted

770490462.2grams

Targeted

Substrate

in Soil

8944.580642 grams

Theoretical Substrate Oxygen Demand from

Substrate

42826.6S2l2grams

Biological Assimilation Correction

2141 3.326O6grams

Calculated Soil Concentration

11.60894402ppm

Partition Coefficient,

General:

Partitioning can be viewed simply as the preference of a particular organic molecule for

either the aqueous or organic phase. Another way ofdescribing this is to use the term

hydrophobicity,

or the tendency ofthat

substance to leave the aqueous phase. The

greater the hydrophobicity, the greater is the tendency ofthat substance to

partition

into

the hydrophobic organic phase.

• The

partition

coeffIcient,

therefore, is simply the ratio of the equilibrium

concentrations between the two

immiscible phases in contact,

i.e.

P

=

organic/aqueous

=

K

(5-I)

---

=~

This

simple relationship assumes that there are no significant solvent

interactions (solvent is a continuum), solute-solute interactions (activity

coefficient independent ofconcentration), or anything

else.

=~°

The constant ofproportionality is called the

partition coefficient,

or

distribution ratio.

The partition coefficient can be a vapor/solid,

vapor/liquid,

liquid/liquid,

or liquid/solid measurement.

~c

In this context the system ofsolvents are taken as a continuum, without

discrete molecular structures.

Using the filed demonstrated formula:

(Calculated

Concentration)/(soil correctionpercentage)

=

Corrected soil value

Applying this correction, a high

correlation between observed and theoretical values

are obtained,

To

obtain

the

correction

value,

a

variety of calculations are

involved such that corrected

water and soil

concentrations

are

established.

Based

on

the

calculated

target

concentrations,

COD

values

are

developed and essential

injectants calculated.

These individual calculations are attached in “appendix

In

addition

to

the

effect

of temperature

on

solubility product

constants,

an

increase

in

the

specific

conductivity

of a solution

will significantly lower

the

adsorption coefficient

of cations.

Of specific

interest at the site is how the increase in conductivity

will effect

the bioavailability ofnutrients.

If the

decrease

in the coefficient for hydrogen ion due to the increases in salinity

is balanced

by the increase

in the

coefficient due to

the

increase in pH across the

site

the cation availability

can be

expected

to

remain

unaffected

by

the

physical

chemical

changes

of the

environment.

The

issues

of solubility

product, sorption and desertion are not addressed in the states’

assertion that a single ORC injection is

capable of supplying all

the necessary

components necessary for biological growth.

Neither does

the

states’

assertion

address the population management

issues that will accompany

the disproportionate

growth

of

non-petroleum

degrading

gram

positive

species

that

is

expected

without

vegetative

pseudomonad

augmentation.

These

issues

have

been

addressed

by

the

Innovative

Environmental

Technologies,

Inc. proposal.

---

The site has generally been broken into threeregions:

Area “A”, “B”,

and “C”.as follows:

/,//////

2

~/////////////////27?/

/

/

o

---

Area

“A” evaluation: Phase I

Treatment Area

Of Soil Load Targeted

100

Soil Correction Value

~

Area

Area of Zone

4090.215278

sq. ft

Average soil coulumn targeted

4

ft

Estimated

radius of injection

9

ft

Estimated Area Volume

605.9578189

C.Yards

Estimated Pore Volume

30

pH

6.9

BTEX Calculations

Groundwater Analyses

Benzene Concentration

0.275

ppm

Toluene Concentration

0.771

ppm

E.

Benzene Concentration

0.313

ppm

Xylenes Concentration

0.388

ppm

Total

Soil Analyses

Benzene Concentration

0.0991

ppm

Toluene Concentration

0.366

ppm

E.

Benzene Concentration

2.97

ppm

Xylenes Concentration

2.69

ppm

Total

Number of Oxygen

Injection Points

17 Points

Raw Amount

of

ORCIpt

9.10 Pounds

Raw Amount

of CaH2O2/pt

7.15

Pounds

Gallons of Slurry

850

gallons

Corrected

ORCIpt

8.0

(corrected for excess 11202 usage)

Corrected CaH2O2/pt

6.29

(corrected of excess H202

usage)

Number of Bio Injection Points

19

Points

Gallons of LPD/Pt

9.68726

Gallons

Gallons

ofSlurry

1900

Gallons

---

Area “B” evaluation Phase

I:

Of Soil Load Targeted

100

Soil Correction

Value

~__.

~as

~rea

Area of Zone

9979

sq.ft

Average soil

coulumn targeted

2

ft

Estimated

radius of injection

20

ft

Estimated Area Volume

739.1851 852

C.Yards

Estimated Pore Volume

60

pH

6.59

6.6

BTEX Calculations

Groundwater Analyses

Benzene Concentration

0.0716

ppm

Toluene Concentration

0.005

ppm

E.

Benzene Concentration

0.005

ppm

Xylenes Concentration

0.041

ppm

(Average of MW-2 and MW-3)

Total

Soil Analyses

Benzene Concentration

0.02

ppm

Toluene Concentration

0.02

ppm

F.

Benzene Concentration

0.05

ppm

Xylenes Concentration

0.15

ppm

(Average of MW-2

and MW-3)

Number of Oxygen Injection

Points

8

Points

Raw Amount of

ORCIpt

1.01

Pounds

Raw Amount of CaH2O2/pt

0.67

Pounds

Gallons of Slurry

.

600

gallons

Corrected ORC/pt

10

(corrected for excess H202

usage)

Corrected CaH2O2/pt

6.04

(corrected of excess H202 usage)

Number of Bio Injection Points

6

Points

Gallons of LPD/Pt

660

Gallons

Gallons of Slurry

9000

Gallons

---

Area “C” Phase

I:

Area General

Data and

Calculations

Of Soil Load Targeted

100

Soil Correction Value

-

~as

Area

Area of Zone

3708.256944

sq.

ft

Average soil coulumn targeted

4

ft

Estimated radius of injection

15

ft

Estimated Area Volume

549.3713992

C.Yards

Estimated

Pore Volume

30

pH

6.6

BTEX Calculations

Groundwater Analyses

Benzene Concentration

0.05

ppm

Toluene

Concentration

0.0058

ppm

F.

Benzene Concentration

0.005

ppm

Xylenes Concentration

0.0151

ppm

Total

Soil Analyses

Benzene Concentration

0.05

ppm

Toluene Concentration

0.05

ppm

F.

Benzene Concentration

0.09

ppm

Xylenes Concentration

0.2

ppm

Number of Oxygen Injection Points

6

Points

Raw Amount of ORC/pt

10.70

Pounds

Raw Amount of CaH2O2/pt

10.19

Pounds

Gallons of Slurry

450 gallons

Corrected

ORC/pt

11

(corrected for excess

H202 usage)

Corrected CaH2O2/pt

9.73

(corrected of excess

H202 usage)

Number of Bio

Injection Points

17

Points

Gallons of LPD/Pt

10

Gallons

Gallons of slurry

1700

Gallons

---

The objectives of the accelerated attenuation program proposed by Innovative Environmental

Technologies, Inc. are:

1)

Provide for sufficient dissolved oxygen across the site so as

to sustain aerob~ic

conditions,

2)

Provide for sufficient bioavailable nutrients

so as

to

sustain the respiratory processes

of the heterotrophic populations,

3)

Manage the population, utilizing indigenous and exdigenous heterotrophs and

4)

Focus biomineralization processes on

petroleum hydrocarbon constituents.

Technical

Review

ofthe Project

Bioremediation has been successfully demonstrated for many years.

The ability of hetertrophic

bacteria to mineralize petroleum hydrocarbons in contaminated soils

and groundwater is well

documented.

JET has

demonstrated through engineered deliveiy systems that these enzymatic

pathways

may be

utilized to accelerate in-situ attenuation process, treatingboth soils and

groundwater.

In the process, soil microorganisms convert the hydrocarbons to carbon dioxide,

water and biomass.

The factors that affect the extent.ofhydrocarbon removal from the

contaminated soils include:

*

p1-I

of the soil and water,

*

temperature of the soil and the water,

*

moisture content of the soil,

*

concentration ofnutrients within the soil and water,

*

aeration (dissolved oxygen) in the aqueous fractions,

-

*

total and selective microbial populations,

*

contaminant characteristics,

*

time,

*

the availability of the

contaminant to biocatalysis, and

*

consistent,

professional management of the

site.

The in-situ program shall address each of the parameters above in order to accelerate the natural

processes presently occurring in

such site soils and groundwater to meet or exceed Soil and

Groundwater Cleanup Criteria much more rapidly than had these processes been allowed to

continue at their current rates.

In-situ biodegradation occurs through the action of naturally occurring microorganisms,

which

are encouraged to grow through addition of nutrients, oxygen, organic substrates or other

materials.

If naturally occurring organisms are absent or few in number, or when a more rapid

clean up is desired, acclimated organisms are added to

the surface environment.

By combining

the two approaches (organism addition with an enhanced environment for growth) a rapid and

continuous

remediation may take

place.

---

~11

To insure the maintenance ofproper operating pH throughout the in-situ remediation process a

nutrient blend consisting ofMono Sodium Phosphate as the phosphorous source is used.

By

utilizing the MSP, the treatment zones’ pH will be buffered by the nutrient augmentation.

In the

case that the time zero pH levels are below the optimal range, pH management will not be a

component ofthe program.

Further, in that the pH levels are assumed to be between6.5 and

7.5

throughout the site, the attenuation phase oftheproject (elevated DO resulting from the

decomposition ofthe magnesium peroxide slurrypoints) is expected to truncate, due to an

accelerated decomposition rate ofthe stabilized magnesium peroxide.

Temperature

Although control ofthe soil’s temperature is not feasible, the bacterial blend selectedfor the

project has a high proportion ofPseudomonas putida,

a culture which has demonstrated excellent

degradation kinetics at the temperatures typically associated with soils and groundwater. Further,

some temperature management will occur via the source area treatment system.

Moisture Content

Controlling the moisture

content within the soil matrix is critical in establishing and maintaining

an environment supportive ofthe natural biodegradation of the contaminants at the site.

To

maximize the water introduction into the targeted soil areas, JET shall apply the nutrients and

terminal electron acceptor into the soils in diluted aqueous solutions. These injections shall be

accomplished via specially designed equipment and direct push drilling equipment.

Nutrients

Also critical to establishing and maintaining the activity ofthe bacteria in the site’s soil is the

control ofthe inorganic nutrients required by the bacteria for the cellular metabolism.

Bacteria

require both nitrogen and phosphorus

in order to carry out cellular functions.

The organism for

microbial wall components, nucleic acids and proteins requires nitrogen.

Nitrogen makes up

nearly

15

of the molecular composition

ofa bacterial cell; any limitation on

the nitrogen

seriously impacts the metabolic functions ofthe organisms.

Inorganic nitrogen sources will be

required in the bioremediation program at the site.

The microorganisms in the synthesis ofphospholipids and nucleic

acids use phosphorus, in the

form ofinorganic phosphates.

Phosphorus

is also essential for the energy transfer reactions of

ATP.

The enzymes that hydrolyze the phosphate ester arepresent in nearly all organisms.

In

phosphorus limiting environments the metabolism of microorganisms decreases sharply,

reducing theircapacity to utilize the hydrocarbons in the soil as an organic carbon source.

Inorganic phosphorus sources shall be applied with thephosphorus sources in order to stimulate

and maintain the remediation project.

---

In developing a coordinatedNitrogen and Phosphorus nutrient-augmentation programforthe

site, Innovative Environmental Technologies, Inc. has considered the potential for impacting the

groundwater with nitrates.

The nutrients

to be added to the bioslurry shall be composed ofthe

components: MSP (Mono

Sodium Phosphate), Urea, and

a small percentage of Dicyanodiamide.

This component inhibits the nitrification of the ammonium to nitrate.

Keeping the nitrogen in a

more usable form and allowing for the injectedoxygen to go towards respiration rather than

being incorporated into the nitrate molecules resulting from the nitrification process.

Applications ofthe nutrient mix with the oxygen source shall be at concentrations below the

inhibitory or toxic levels ofthese materials to insure that growth is stimulated, rather than

inhibited in the areas.

Aeration

Respiration processes require oxygen,

generally an oxygen atmosphere ofless than 1

in soil

will change metabolism from aerobic to anaerobic.

In aqueous and soil environments, oxygen

concentrations less than

1 mg/l can switch metabolism from aerobic to anaerobic.

Therefore,

maintaining dissolved oxygen in the aqueous phase in and around the soil particles an organism

is in contact with

is critical to maintaining good degradative characteristics.

The options

available to a practitioner ofbioremediation are limited generally to aeration ofwater and soils in

the treatment area, the introduction ofhydrogen peroxide, or the use ofpure oxygen sources.

Innovative

Environmental Technologies has selected to utilize hydrogen peroxide in the injection

slurry

so as

to accelerate the mineralization process within the treatment zones during the active

phase ofthe project.

Dilute

H202 has been chosen for the active phase ofthe remediation for the

following reasons:

1)

Sparging into the small, concentrated contaminated zones will not allow for the

surgical-like remediation available via the injection technique,

2)

SVE system installation into the areas would significantly impair the continued

commercial use ofthe site,

3)

SVE systems consists ofexpensive equipment, requiring long term operating and

maintenance costs, and

4)

The overall electron acceptor requirements are moderate to low for meeting the

requirements.

Oxygen will be additionally supplied to the ground water via a slow release solid magnesium

peroxide product.

This patented technology controls and prolongs

the release of oxygen while

maintaining moderate pH levels.

Together with enhanced population density ofheterotrophs

with TPH degrading capacity, the low-level extended release ofoxygen

to the groundwater will

enhance the efficacy ofthe soil remediation injections, which shall occur during the active phase

of the remediation.

---

In treating the soil

matrix via injections, each treatment cell shall have a maximum H202

concentration of 800

ppm injectedwith each application, limiting the potential toxicity issues,

which would limit biological activity at higher H2O2 concentrations.

Total and Selective Microbial Populations

Over the years numerous field experiences, laboratory studies and third party evaluations have

shown that biodegradation ofpetroleum hydrocarbons can be accelerated in contaminated soils

by optimizing culture conditions and introducing high

concentrations ofviable, specialized

strains of hydrocarbon degrading organisms.

As compared to aprogram in which enhancement

of the indigenous organisms

is the sole source ofbacterial action, an augmented bioremediation

approach allows for a more

competitive environment establishing a high proportion ofselective

bacteria for hydrocarbons.

These largerpopulation ratios allow for greater utilization of

nutrients and oxygen in degrading the contaminants

ofthe site.

Although enhancement

technologies alone have had field successes, frequently the steps takentowards enhancement are

more expensive

and time consuming than an augmented approach.

Through an augmented

approach, selective counts quickly approach that ofthe total counts, increasing the biological

degradation ofthe hydrocarbons by orders ofmagnitude early in the remedial process.

As the

treatment area’s population dynamics stabilizes, higher activity with regard to TPH degradation

is still seen.

In structuring the bioremediation program for the site, Innovative Environmental Technologies

shall utilize a proprietary blend of bacterial cultures specifically designed and manufactured to

JET’s specifications.

Targeting and degrading the light-distilled oil fractions as well as the

heavier fractions of hydrocarbons normally associated with

fueF oils, crude oil and coal tar.

Many ofthe cultures within JET’s hetertrophic blend are those which were evaluated and

recommended by the EPA’s Risk Reduction Laboratory in Cincinnati, Ohio and involvedtesting

the effectiveness of treating, through bioremediation, the weathered Prudhoe Bay crude oil in sea

water frOm Prince William Sound.

The results were compared against those produced by

inorganic fertilizers.

At a confidence level of

95,

the culture recommended by NETAC

biodegraded the hydrocarbons in the oil significantly befterthan the fertilizer control.

These

cultures and one other company’s product were identified‘asthe’most-promisingcommercially

available technologies from a field of

39 proposals from companies having bioremediation

technologies for potential application in the Exxon Valdez

oil spill cleanup.

lET’s

“LiquidPetroleum Degrader” (LPD),

is composed of twelve strains of Pseudomonads

consisting of: Pseudomonas aeruginosa (for biosurfactant production), Pseudomonas stutzeri,

and Pseudomonas putida.

Combined, these organisms target the following compounds:

Anthracene, Methyl naphalene, Napthalene, Xylenes,

Ethyl Benzene, Toluene, Benzene, and

C20

aliphatics.

These cultures have been demonstrated to perform at optimal kinetics when

applied under the following conditions:

pH

6.0-8.5

(6.8-7.4 optimal),

Temperature

40°F-l00°F

(65°F-85°F

optimal),

Dissolved Oxygen

2.0

mg/i (1.0 mg/l minimum),

Nutrients (N&P)

1.0

mg/I Ammonium Nitrogen,

0.5

mg/l Ortho Phosphate.

---

Availability ofthe Contaminant to Biocatalysis

Based on the

data available, the techniques practicedby Innovative Environmental Technologies

and proposed herein are expected to greatly accelerate the biological mineralization ofthe

petroleum constituents in both the targeted soil and the groundwater ofthe site outside the source

area.

Some limitations may appear through the remediation related to the closure ofthe must

contaminated areas.

These limitations may be a result oflow-bioavailability or low-accessibility

areas with regardto residual hydrocarbons.

Should these conditions appear during the final

stages of the remediation in the site, additional

slurry

introductions, inoculations, and additional

ORC points should be considered.

Injection Techniques and Applications

ORC has been usedin the successful remediation ofdissolved phase TPH and BTEX

compounds.

It is most frequently used to address dissolved phase contamination in-the ground

water in addition to sorbed material in the saturated capillary fringe and smear zones. It is these

latter areas that if not addressed at the same time the ground water is ~tddressed,

re-contamination

ofthe water will continue to occur.

-

How Is It Applied?

When first introduced into the remediation market, it’s form for use in accelerating the bio-

remediation ofdissolved phase petroleum compounds in ground water was “filter socks”. The

“socks” consisted ofORC mixed in a ratio with

a carrier matrix,

encased in

a fabric pouch which

was wrapped in

a protective plastic webbing.

The “socks” measured approximately

3” x

12” for

use in 4” diameter monitoring wells, with grommets

on both ends that were laced together to

form a chain.

These were then lowered into the well. The number of“socks” used in each well

depended on the length ofthe water column. Optimum

effectiveness was obtained when the total

saturated area was filled.

The observation was that although the effect ofthe ORC on

the ground water in the well could

be measured, it was difficult to measure the effect of the ORC treatment outside the well. The

combination ofground water moving into the casing to replace the displaced volume ofthe ORC

when it is removed forsampling,

combined with the effect ofpurging

3 to

5

casing volumes

prior to ground water sampling resulted in oxygen depleted upgradient ground water being

introduced into the well. The sampleresults reflected this condition.

In addition, unless a significant number ofORC packed wells were installed throughout the

affected area, especially upgradient of the area ofinitial release, the whole affected areawas not

being remediated, only the water immediately in and passing through

the original monitoring

wells. A combination ofbarrierwells installedjust downgradient ofthe areaof initial release and

at the downgradient property boundary, helped to treat and contain some ofthe contamination,

but another method needed to be developed fordelivering the ORC throughout the affected area.

---

SLURRY INJECTION

A more cost-effective and efficient method for placing ORC throughout the affected area ofa

site has evolved. Bulk

ORC powder is prepared as a slurry, mixed with water at varying

concentrations. The slurry is injected directly into the SATURATED ZONE, at locations

predetermined to facilitate accelerated attenuation, through the use ofdirect-push boreholes

introduced by

a Geoprobe or similar equipment.

Until recently, the pump most often used to inject the

slurry has been the Geoprobe GS- 1000.

Although

it is rated at 1000 psi, the

maximum injection pressure usually attainedwas between

250 and

275

psi. Most often, the slurry was found to

escape under these pressures from around

the probe, making

it

necessary to install boreholes

closer in order to be ableto affect all the

impacted groundwater.

Recently made available to the remediation industry, designed specifically for injecting ORC

slurry

and

the subsurface introduction ofother remedial materials, is

JET’s licensed injection

process.

The use of

air as adriving

force rather than

pumps offers flexibility to the remedial

contractor, offering prefracturing, post fracturing and high volume injections.

The benefits of

this increased injection flexibility are:

1)

Theability to affect a much larger radius ofinfluenceper injectionpoint,

2)

Theinjection points can be spaced fartherapart without sacrificing subsurface area

coverage, hencefewer

boreholes will need to be installedto affect the same area,

3)

More even distribution ofthe injected slurry insures pH excursions are minimized

due to localizedpockets of ORC,

4)

Usin,! our newly desijined horizontal iniection point in conjunction with the injection

process enables contaminated areas underpreviously inaccessible areas (i.e.;

buildings, small rivers orstream beds) to be accessed and treated.

Another limitation of the

ORC slurry injection process has been the expendable point and

adapter that is

used by borehole installers. Both the adapter and expendable point used on the

end ofboth

1” and

1.25”

rods were originally designed to inject grout when backfilling a

borehole. They were designed to inject themixture in a vertical direction, which served the

purpose well.

-

The problem with using these same tools to inject ORC

slurry is the inability to control the

horizontal extent of

sluny distribution. The engineer must rely on the existing pathways ofthe

geologic formation to disburse the sluny. Even in an optimum matrix, such as medium/fine

grained sand,

the mixture will seek preferential pathways rather than equal distribution (similar

to “air channeling”

that occurs in sparging systems).

Factoring in the additional possibility

of silt

or

clay lenses, or an entire matrix composed of silts or clays, only exacerbates the problem.

We have designed an injection point and adapter that can be used with existing, industry

standard

1” and 1.25” direct push rods that will inject the ORC slurry in a HORIZONTAL

pattern. The

distribution of the slurry will be much morepredictable when combined with the

---

utilization of our novel and patented injection process.

In addition, fewer boreholes are

necessary to completely affect treatment in all

areas.

Innovative Environmental Technologies shall address the impacted soil and groundwater via in-

situ injection of essential cultures, nutrients andoxygen sources.

A sample was obtained from the site and analyzed at TMI Analytical Services, LLC.

The sample was

be

evaluated

for both Total

Selective

Heterotrophs and

Selective Heterotrophs

(McKonkey’s Plate).

The

McKonkey’s

agar utilized

is

specific

for

Pseudomonads.

The

literature

and

our

experience

indicates that the majority

ofheterotrophs capable of aromatic degradation are pseudomonads.

This is

born

out by the

attached Battelle paper.

In

this paper we evaluated toluene

degraders via

the MPN

method and pseudomonads via the McKonkey’s agar.

As you will

see there is a very high coorelation

between the toluene

degraders and the pseudomonads in all

wells except G- 103,

where there appears

to

be

additional gram

positive (probably bacilli)

capable of degrading

toluene.

In that

G-103

is

the

center of the plum and, has been

exposed to the aromatics the longest period of time

the assimilation

of some non-pseudomonad aromatic degraders should be expected.

If,

the

remedial

plan were

to

consist

solely

of oxygen

enrichment,

as

the

JEPA

seems

to

request,

greater

consumption

of the

resources

would

occur

by

the

non-aromatic

degrading,

gram

positive

population sub-set.

The lab evaluation and the plating process indicate whether there exists bacteria at

the site, it does not evaluate the activity of that population.

It is important to recognize that the plating

process allows for the dormant cultures to become active. It is difficult

to judge the in-situ conditions,

where competition for resources is present.

The capabilities of the dormant Pseudomonas

to become

vegetative

and

utilize

resources

consumed

by

the

competing

gram-positive

population

will

significantly vary

from

laboratory

enumerations.

It is

most

probable that

the

nutrient

and terminal

acceptor limiting conditions have

existed at the

site for some period of time.

As a consequence the

total plate count represents spored gram-positive

organisms.

Innovative

Environmental Technologies,

Inc.

(JET) has

utilized dilute hydrogen peroxide

within the

bioslurry component to meet the SCOD demand.

This demand will come from primarily the inorganic

sources such

as

iron and

manganese.

Further

the

sequestration

of bioavailable

o-PO4

by

the

non-

oxidized

cationic

species

shall

be

addressed

by

the

integration

of

additional

o-P04

within

the

bioslurry.

The

agency’s

request

for

copper,

zinc

and

lead

analysis

can

only

be

assumed

to

be

an

outgrowth

of cationic sump feature which is

addressed both by

the H2O2,

o-PO4

and biosequestion

that will occur within

the JET program.

The

remedial

program

recommended

by

JET

integrates

vegative

pseudomonas

so

as

to

compete

effectively

with

the

ingenious

gram

positive,

general

BOD

degrading

population.

Further,

the

incorporation of the vegative BTEX

degrading pseudomonas allows for effective bio-film formation in

the

vadose

zone

during

the

critical

“mounding”

stage

of the

process.

It

is

during

this phase

that

abundant oxygen and nutrients are present with

the vegetative cultures in the capillary area.

Without

the incorporation of the cultures, stimulation with oxygen and nutrients will drive the population ratios

in the saturated zone further toward the non-BTEX degrading gram positive strains and in the vadose

zone entirely allow for gram positive bio-film formation.

In

addition

to

the

effect

of temperature

on

solubility

product

constants,

an

increase

in

the

specific

conductivity

of a solution will

significantly

lower

the

adsorption

coefficient of cations.

Of specific

---

interest at the site is how the increase in conductivity will effect the bioavailability of nutrients.

If the

decrease in

the coefficient for hydrogen ion due to the increases in salinity is balanced by the increase

in the

coefficient due to

the increase in pH

across

the site the

cation availability

can be

expected to

remain

unaffected

by

the physical

chemical

changes

of the

environment.

The

issues

of solubuility

product,

sorption and desertion are not addressed in the

states’

assertion that a single

ORC injection is

capable of supplying all the necessary components necessary for biological growth.

Neither does the

states’

assertion address the population management

issues that will

accompanie the disproportionate

growth

of

non-petroleum

degrading

gram

positive

species

that

is

expected

without

veragative

pseudomonad augmentation.

Only

those

chemicals

that

tend to

ionize

are

affected significantly

by pH.

The

only

influence on

neutral

molecules

would

be a

change

in

the

character

of

the

soils’

surface.

However,

the

general

increase

in

pH

across

the

site

will

significantly

affected

the

soil

sorption

of

charged

species,

in

particular

cationic

ions.

Given the

logarithmic

nature of the pH

scale and

the

general

0.5

or more

increase in pH expacted at the site, the soils will have been

transformed from acidic to alkaline.

This

change in pH has also resulted in a decrease in the charge of the

soils.

Under

alkaline conditions, soil

surface hydroxyls lose

their protons and the resulting surface

will be anionic.

The

overall effect of

this change in charge will be a significant. decrease in cationic ions in the aqueous -phase.

The nutrient

augmentation and monitoring program

is designed to address these issues through periodic monitoring

and adjustment ofnutrient feed.

Selective enumeration of the samples utilizing McKonkey’s agar was utilized by TMI.

McKonkey’s

agar selects

for Pseudomonas.

The

correlation between

toluene

degrading capability

of a consortia

and Pseudonomad counts

is well documented.

Further,

the Battelle paper delineates this

correlation.

Also

as an outgrowth of our activities at the site in Princeton Illinois

on which the paper was

written,

the methodology employed by

JET to manage the population clearly indicates the augmentation of the

indigenous population yiclds a high proportion of selective bacteria (Pseudomonas)~

As shown above, in a case were no populations were present in the water sample the

methods applied

by JET at a similar site yielded excellent population management.

~3-1 03

BiolQgioaI

ID~ta

•

PCA

(ofu/~vil)

-

~_

-

-

I.~.

(cfu~J

~1

.OOE--O9

1.OO~O5

I

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....

‘.

..

1

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.

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.OOE-.-O1

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~

---

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Biological

Data

~Pc~cf~i~J

I

.00E1-07

:j

i”

~

I.OOE*03

-~

\

.-

I

,.

I

.00E~-02

-

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I

.OOE+O1

I.OOE+O0

F~r-00

P~y-0O

Jun-00

Aug-00

Oot-00

Nov-00

Jan-01

Feb-01

Apr-01

J~n-OI

~te

As shown above in

an extreme incidence

where the

population ofpseudomonas was

relatively high at

time

zero,

again

the

processes

applied by

JET

at

the

site

produced

good

population

management.

Generally, the BTEX:BOD:SCOD loading ratios at particular a well will produce the varied time zero

variances

in

population

ratios.

It

is

interesting

to

note

that

the

graphs

presented

here

are

from

monitoring wells at the same

site.

The extreme differences in population dynamics is the result of the

target constituent

chemical loadings

and the time with which the soils in

the

well areas have been in

contact with the petroleum hydrocarbons.

This heterogenaity

is common andmust be expected.

Phase One:

Primary

Active Remedial Phase

—

Time zero

Phase one of the remediation shall consist of the preliminary inoculation of the site via liquid

injection followed by bioslurry treatment.

The primary objective is to mound the groundwater

through the capillary zone and supply the needed essential nutrients for bio-mineralization and

dissolved oxygen

forthe heterotrophic respiration processes.

By utilizing the entrained

petroleum distillates within the targeted zone as a primary growth substrate, the active vegetative

cultures shall acclimate and grow, utilizing the components

ofthe bioslurry in their respiratory

processes.

Phase I (Time zero)

and Phase II (Time 100

days):

JET andits

subcontractors shall inject, via the direct push equipment and the air driven injection

tanks into Areas

“A” and “C”

150 gallons/pt ofbioslurry (or as much as the point will accept at

the injecting pressure) and a pretreatment of 10 gallons of liquid heterotrophs, based

on

BOD/COD/TPH loadings, biological counts andhistorical soil contact with contaminants.

Before each injection, the zone will undergo a pre-injection fracture

-

utilizing a ten seconds, 175

psi, 500 cfm (minimally) fracture.

The location of these points’

locations and the anticipated

impact zone for each is presented in diagram “Phase I”

-

All points’

field notes shall be recorded

and reported in the final project report.

Into area “B”, 110 gallons of LPD and 1500 gallons of

bioslurry shall be introduced into the six sumps.

Following the bio-inoculation and bio-slurry injection, slow release oxygen sourcespoints shall

be installed through the gridto insure continued dissolved oxygen over the site as accelerated

---

attenuation occurs.

Each oxygen point shall receive 10 lbs of ORC in a slurry no Calcium

peroxide shall be utilized due to pH management issues.

Dosing based on attached calculations.

Active Remediation components:

---

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