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

Hello everyone:

Here is the latest on the Petroleum Cleanup on Philadelphia Avenue…Things are proceeding and there is success, but some difficulties continue with this very ambitious remediation system…The good news is the results are starting to show on the cleanup of most of the petroleum byproducts…But we had to call again yesterday to report the return of the steady stream of high-pitched noise emanating from the system…

Best regards,
Louise Mills

From: Damon.Taylor@ocfl.net [mailto:Damon.Taylor@ocfl.net]
Sent: Monday, October 01, 2007 12:12 PM
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 (Twelfth update- October 1, 2007)

Ms. Mills,

I would like to take this opportunity to give you our twelfth monthly update on the project. The startup occurred in late February 2007 and we are on a 4-year cleanup schedule.

In my last update, I said that we’ve been experiencing problems with the remediation system processes. This has continued since my last update on September 13th.

Vapor Recovery System Update:
This part of the system that is still down due to the need to use a catalytic oxidizer. Terramax has since worked out the issue of fueling the oxidizer. We have what I believe is an approvable Change Order request from Terramax now and I have forwarded it on for complete approval. If it is approved this week, I believe I will be able to provide a more definitive schedule on implementation in next month’s update.

The Groundwater Recovery System:
It is reportedly been running but there have been shut downs due to power failures and low water coming into the air stripper. Terramax had addressed the air stripper problem before the last update by having the system shut down when the air stripper was producing the high pitch whining sound. However, I got a copy of a complaint from the onsite business owner yesterday. I don’t know why there would be a problem with the air stripper, but Terramax is aware of it and will fix it and report back to us at Orange County.

As stated in the last update, I have been concerned that we weren’t able to accurately evaluate the recovery rate from each well and were only getting the total flows. Terramax suggested we put individual flow meters on the wells in place of the existing air flow pulse measurement devices. I agree this would be better and this is something I will pursue as a priority when the oxidizer is installed.

Report Status:
The next report is the Second Quarterly Operation and Maintenance Report, which is due today (October 1, 2007). As of 11am it hasn’t arrived, but I did speak with Terramax on Friday to get a preview of most current groundwater data from late August. If there are any non compliance items noted in the report with respect to the Remedial Action Imitative program, Orange County will be taking any such issues up with Terramax. I will need to review the report in full before I will know for sure though.

A response to comments for the Division’s August 7, 2007 letter is currently past due. The Division issued a late letter a few weeks ago asking that it be submitted no later than October 5, 2007.

On the positive side, we have seen a significant reduction in contaminants in most of the milestone evaluation wells. In spite of all the problems we have seen since startup and the inability to run the SVE system for a long while now, Terramax is meeting almost all of the milestones now.

Milestone Update:
This section of the monthly update will be the most useful to show the reduction in contaminants. We only get data once per quarter though so the next couple of updates that follow this one will not contain new data. This month though, I am happy to report the following:

I am providing you with the tables this time in a PDF format that show all the key performance evaluation monitoring wells (AW-3, AW-7, AW-11, AW-22, AW-24 and MW-5). AW-5 is supposed to be a key milestone evaluation well also. However, this well was not located and may have to be replaced. There are many errors on the table, so I went through the milestone schedule on all six wells to compare the August 2007 data to where we should be on the schedule. I thought this was our third quarterly sampling event and so I marked up my pages accordingly. However, the data is really for the second quarterly sampling event and should be compared against the targeted milestone goals for the second quarter and not the third as I had marked it up. The way the table works, each quarterly set of data should be in the row # of (N+1) with the baseline sampling being row #1. Regardless of the way I marked up the milestone table on the attached PDF file, the pass/fail status for the milestones works out to be the same in either case (second vs. third). Please call me if you have any questions about the milestones.

From this I see that we are meeting milestones on all six wells that data was provided for except for AW-3 and AW-7.

The results in AW-11, AW-22 and AW-24 are very favorable by being way ahead of schedule and almost having reached Florida Groundwater Cleanup Target Levels.

MW-5 is meeting milestones, but is further away from our groundwater cleanup target goal than the wells mentioned in the above bullet point. This is a well for us to keep an eye on in the future. I believe that with proper run time and treatment in this area, that we may see improvements next quarter. AW-3 and AW-7 are not quite meeting milestones for the Naphthalene compounds. I think that this is statistically explained by these wells having low concentrations for the Naphthalene compounds in the baseline data to start with. Groundwater fluctuations often cause minor spikes that are most visible when the treatment system experiences down time. For AW-7 , the baseline concentration for 1-Methylnaphthalene was below the cleanup target value of 28 ug/L. A spike has caused it to rise to 30 ug/L (only 2ug/L above the Florida Groundwater Cleanup Target Level), which automatically is flagged as a failed milestone. Also, since the baseline data AW-3 for Naphthalene was 23.2 ug/L (fairly low but above the cleanup target concentration for Naphthalene of 14 ug/L), a spike is more statistically significant with the recent concentration of 56 ug/L. Still, the milestones are not met in these cases and must be addressed in the upcoming report with a proposed remedy. I looked at the other compounds for these two wells that are meeting milestones and I can see that they are doing so with a much smaller margin than the wells mentioned in the above bullet point. I think that after the oxidizer is brought online and Terramax is vigilant in their operation of the system at a high run time and high performance specification, this will no longer be an issue.

AW-5 must be addressed in the upcoming report! Since this is a milestone evaluation well, we must have data to determine the system effectiveness in this area.

As mentioned two updates ago, we generally expect that with a system running a high run time and high performance efficiency that we won’t see any milestones missed.

As a quick summary, the system needs to be brought up to the full operating potential with the oxidizer in order for us to get the most out of the system. The status of one of our milestone evaluation wells is unknown, but we are seeing a pretty favorable reduction in most of the wells in spite of the downtime we have experienced.

Site Plan.pdfSite Plan

Artist Studio milestone Rpt.pdf> Milestone Report

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 discuss the site in detail.

Damon Taylor, CFEA, LEP
Orange County Environmental Protection Division
800 N. Mercy Drive, Suite 4, Orlando, FL 32808
Main (407) 836-1400
Direct (407) 836-1480
Fax (407) 836-1417

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