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ENVIRONMENTAL HEALTH DEPARTMENT!COUNTYSAN JOAQUINUnit Supervisors Donna K.Heran,R.E.H.S. - Carl Borgman,R.E.H.S. Director 304 East Weber Avenue, Third F oor Mike Huggins,R.E.H.S.,R.D.I. Al Olsen,R.E.H.S. Stockton, Califomia!,95202'-2708 Douglas W.Wilson,R.E.H.S. Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. Laurie A.Cotulla,R.R.H.S. Robert McClellon,R.E.H.S. Fax: (209) 464-0139 Program Manager Mark Barcellos,RI.E.S. JOHN CERVANTES OCT 0 12003 PO BOX 6008 STOCKTON CA 95206-6008 RE: JC Trucking SITE CODE: 2571 1207 Aurora Street Stockton CA 95206 San Joaquin County Environmental Health Department (SJC/EHD) has reviewed "Work Plan to Conduct Remediation Efforts—Addendum 2"(Addendum) dated September 10, 2003 that was prepared on your behalf by JJW Geosciences Inc. (JJW) and has the following comments. In correspondence dated February 18, 2003 SJC/EHD requested the submittal of additional information to allow completion of the review o i f"Work Plan to Conduct Remediation Efforts—Addendum 1" Specific informati6n requested were the calculations used by JJW to estimate the contaminant mass remaining at the site, copies of all field logs from soil boring and monitoring well installations at the site, and documentation of the successful use of ozone injection to remediate petroleum hydrocarbon impacted vadose zone soil. Of these three requested items, the calculations used to estimate the remaining contaminant mass was the only information submitted with th6y Addendum. 1 In lieu of data supporting the use of ozone injection to remediate contaminated soil in the vadose zone, PowerPoint slides were submitted which ��,reseni ied an ozone/hydrocarbon reaction model for a site at which ozone injection was to ;be utilized on petroleum hydrocarbon contaminated soil in the saturated zone. The presentation made predictions of the impact of ozone injection on contaminated soil in the saturated zone, it did not provide before and after data documenting the successful use`of ozone to remediate contaminated vadosezone soil, and therefore does not provide support for the use of this application of the technology at your site. In the interest of moving your site forward, SJC/EHD approves the installation of the proposed nine ozone sparge points and the initiation of ozone.,injection for remediation of, ,Work Plan to Conduct the petroleum hydrocarbon impacted groundwater. Per'!the "W Remediation Efforts—Addendum 1"dated December 18, 200the sparge paints will be set approximately 15 feet below the groundwater surface, that, is approximately 50 feet below surface grade (bsg), at all nine locations, and in at least four of the locations sparge points will also be installed at 80 and 130 feet bsg for remedi2.i I tion of the groundwater contamination at those depths. SJC/EHD cannot approye installation of sparge points in the vadose zone without supporting documentation that,it is an' effectivetechnologyfor .1 remediation of vadose zone contamination. Please note that remediation of the vadose zone soil contamination at your site remains an issue that must be addressed. A work plan for remediation of the vadose zone soil contamination is due November 24, 2003..