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San Joaquin County <br /> No. Environmental Health Department DIRECTOR <br /> Donna Heran, REHS <br /> 600 East Main Street <br /> ROGRAM COORDINATORS P <br /> ( Iz Stockton , California 95202-3029 Robert McClellon, REHS <br /> Jeff Carruesco, REHS, RDI <br /> cgCr�.a P Website: www.sjgov. org/ehd Kasey Foley, REHS <br /> FOR Phone : (209) 468-3420 Linda Turkatte, REHS <br /> Fax : (209) 464=0138 <br /> March 13 , 2012 <br /> Bill Stoermer Lawrence Beasley <br /> Fremont Plaza Investments Apache Plastics <br /> 7015 Morton Court 2120 Pebble Drive <br /> Stockton , CA 95209 Alamo , CA 94507 <br /> Subject: Former Apache Plastics <br /> 2050 Fremont Street <br /> Stockton , CA 95209 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed ISCO Pilot <br /> Study Extension Work Plan Addendum (Addendum) dated December 23 , 2011 , submitted on <br /> your behalf by Advanced GeoEnvironmental , Inc. (AGE) . In the Addendum , AGE has proposed <br /> to perform one or more injection events of in situ chemical oxidation ( ISCO) media to evaluate <br /> the efficacy of ISCO for treating the dissolved petroleum hydrocarbon contamination at this site . <br /> The Addendum was submitted to address issues identified by the EHD in correspondence dated <br /> November 10 , 2011 . <br /> The issues the EHD wanted to have addressed included what parameters to monitor prior to the <br /> tests and an evaluation of the environmental fate of the contaminants released into the <br /> dissolved state by use of the product RegenOx. <br /> The EHD had directed that an adequate number of measurements of several groundwater <br /> parameters be obtained to determine the natural range of background conditions , including pH , <br /> specific conductivity (SC) , oxidation-reduction potential (ORP) , dissolved oxygen (DO) , total <br /> hardness , chemical oxygen demand (COD) , biological oxygen demand (BOD) and total organic <br /> carbon (TOC) . AGE proposes to measure only pH , SC , ORP , and DO prior to and during the <br /> course of the pilot test to monitor effects of the RegenOx applications . <br /> The EHD had asked for the COD, BOD and TOC as these parameters indicate potential <br /> competing reactions that may consume a significant portion of the chemical action of the <br /> RegenOx, having this data may help with calculating the dosing requirements for addressing the <br /> chemicals of concern. Review of the available data collected over the site to date shows these <br /> parameters to be fairly stable with a few departures from the average range. You may monitor <br /> the pilot test with the parameters proposed by AGE . <br /> While the increase of dissolved contaminant concentrations may have been "predicted and <br /> expected" , the EHD inquired on the environmental fate of the increased concentrations to <br /> ascertain that this would not normally lead to increased plume migration ; as the pilot test is <br /> designed to detect migration of the plume you may proceed with the pilot test. <br /> ISCO Extended Pilot Test WP Addendum Approval Letter 0312 <br />