Monthly update for Sellers Auto / Artist Studio petroleum cleanup site 489201547 / 489201548 (eighth update- June 1, 2007)

From: Damon.Taylor@ocfl.net [mailto:Damon.Taylor@ocfl.net]
Sent: Fri 6/1/2007 10:31 AM
To: Mills, Louise P21324
Cc: Carlos.Gonzalez2@ocfl.net; Renee.Parker@ocfl.net; hortonra@terramaxinc.com
Subject: Monthly update for Sellers Auto / Artist Studio petroleum cleanup site
489201547 / 489201548 (eighth update- June 1, 2007)

Ms. Mills,

I would like to take this opportunity to give you our eighth monthly update on
the project. As you recall, the system started up in February and we are on a
4-year cleanup schedule.

Since my last update, Terramax has gotten the system fully functional. 1) the
leaks we saw in many of the 24 multiphase wells were fixed. Kevin Scharlau and
I (from the Division) went there to verify every one of them with Terramax on
May 21st. 2) the Biosparge portion is also functional and we verified this on
the same day. All 8 wells seem to have similar pressure and flows, which would
be appropriate for biosparge rates. 3) the soil vapor extraction portion of
the multiphase wells was also functional since my last update, but bringing very
high vapor concentrations to the carbon treatment.

However, are the current problems with the site since our last update:

* The vapor extraction portion is bringing such high concentrations up from the
ground that it is more than the carbon vessels can handle. This can be
considered to be both a good thing and bad thing. It is good that the system is
efficiently removing contaminant mass, but bad because we can’t use carbon to
treat the off gas with such high concentrations. Instead a thermal or catalytic
oxidizer may be used, which will take some effort to get put on line. This
means that the soil vapor extraction portion has been shut down and will remain
down for a while. This portion will be restarted, but I am not certain how long
it will take to do so. As a guess, I would say a month or two. I will call
you to give you a better update when I know for sure.

* To date, we still have not received the startup report that documents all of
the various parts of the startup and the overall operating efficiency of the
system, so I am unsure of exactly what the run times or performance efficiencies
have been. However, I received some tables yesterday via E-Mail and have been
in close communication with Terramax from week to week about the site’s progress
as well as making several site visits. As mentioned in the last update, the
Division’s sent out a informal notice on April 25, 2007 detailing the
deficiencies so far and request a response in writing that all of them have been
addressed. Yesterday, I forwarded my final late letter for the Orange County
Petroleum Cleanup Program supervisor to sign. I expect it to be mailed out
Monday to the property owner and the consultant, Terramax. The Division regrets
that the Startup Report has still not been received, as we had expected I would
have received and reviewed most of it before this update.

Below are general updates on portions of the system including some prior
problems that were already addressed:

* We regret the noise issue that occurred on May 20th, which was caused by the
compressor shutting down due to a power surge. When the compressor was down and
no longer driving water through the air stripper, the blower unit was still
operating and causing a very annoying whistling sound from the air through the
many holes in the treatment trays. This shouldn’t happen again because the
programmable logic controller on the control panel was modified to shut down the
air stripper blower unit concurrent with a shutdown of the compressor. In
other words, if one of them goes down for any reason the other one will too.
Terramax posted signs with emergency contact numbers too.

* The groundwater recovery portion of the multiphase effort is still on and will
not have to be interrupted for this. As of May 24, 2007, they had treated just
under 1,167,000 gallons of groundwater with an average pumping rate of 12.2
gallons per minute. One issue I am working on resolving is to determine the
amount pumped from each well each month or from one field visit to the next.
There are counters on each pumping manifold that seem to get stuck a lot, so the
calculated amount of water from each well may show to be artificially low.
This doesn’t affect the number of gallons above, but it is important to know
flow per well to track the flows and how they may change over time, to catch
failures if they should occur.

* In our last update I mentioned that the off gas from the air stripper would be
plumbed into the same treatment line that handles the soil vapor extraction
gases. The odors from the air stripper greatly diminished and this is no longer
necessary. Terramax has not submitted the change order I had mentioned in the
last update because of this.

* I had mentioned in the last update that the soil vapor extraction system (SVE)
has been operating at a much lower flow rate than anticipated. Terramax had
told me that the original goal of over 100 standard cubic feet per minute per
well was not realistic and that the data was based on a pilot test performed by
another consultant. As an update to this, Terramax has since informed me that
the goal of 100 standard cubic feet per minute may be achievable or near
achievable for some wells. In other words, they expect an optimized flow to
vary from well to well in the range of 30-100 standard cubic feet per minute. I
have asked for individual well-specific target flow rates to be submitted in the
startup report. These values will have to be evaluated and approved by the
Division during our review of the report before they can be considered the
design flow rates though.

* Terramax will be performing the first quarterly groundwater sampling next
week. Therefore, we expect this first set of post-startup groundwater data in
approximately three weeks from now. This will be the first sampling in our four
year cleanup (16 quarterly sampling events), and I am looking forward to sharing
these results with you.

Please feel free to call me anytime if you need additional information or if you
would like me to find something in our files. Also. I am always available to
meet you onsite if you want to show me of any concerns you have.

Damon Taylor CFEA, LEP
Orange County Environmental Protection Division
Petroleum Cleanup Team
800 N. Mercy Drive, Suite 4, Orlando, FL 32808
Voice (407) 836-1480, Fax (407) 836-1417

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