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San Joaquin County <br /> QP <br /> Environmental Health Depnartment DIRECTOR <br /> MDonna Heran,REHS <br /> 600 East Main Street <br /> Stockton, California 95202-3029 PROGRgMCOOR,REBS RS <br /> Robert McClellan,RENSJeff Carruesco,REHS,RDI <br /> KaseyWebsite: www.sjgov.org/ehd Linda Foley,RENS <br /> Linda Turkatte,RENS <br /> Phone: (209)468-3420 <br /> Fax: (209)464-0138 bt <br /> June 24, 2011 <br /> Ms. Catherine Kahler Mr. George Betker <br /> JM Equipment Co Inc. Geo Corp <br /> 819 S. 9T" St. 2306 Jackie Court <br /> Modesto, CA 95351 Oakdale, CA 95361 <br /> Subject: JM Equipment LOP Case#: 9401 <br /> 1245 W. Charter Way CUF#: 12607 <br /> Stockton, CA. 95206 Geotracker ID#: T0607700794 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Remedial <br /> Action Plan Addendum (RAP) dated May 27, 2011, which was submitted by your consultant, <br /> Geological Technics Inc. The RAP was submitted in response to a request made by the EHD <br /> during a phone conference with your consultant on April 29, 2011. <br /> In correspondence dated April 12, 2011, your consultant advised the EHD that the use of ORC <br /> (an oxygen releasing compound) in wells set in large diameter borings (LDB) was being omitted <br /> as part of the RAP. During the conference call of April 29, 2011, the EHD advised your <br /> consultant that with the omission of ORC from the proposed remedial action plan, only the <br /> installation of the four LDBs remained as a remedial action. The EHD concluded that installation <br /> of large diameter boreholes does not constitute a remedial action plan and that a RAP <br /> addendum that meets the requirements of a remedial action plan was to be submitted to <br /> GeoTracker. <br /> The RAP addendum received on Geotracker June 7, 2011, proposes to advance four LDBs, <br /> install a plastic casing into each, and test the effectiveness of three different oxygen releasing <br /> technologies into three of the four LDB wells. The fourth LDB well would be constructed as a <br /> control well with no injection in the well planned during Phase I of the RAP addendum. <br /> The EHD considers testing and evaluating multiple insitu chemical oxidation (ISCO) compounds <br /> during one phase of work to be a feasibility study, whereas remedial action plans (RAP) are <br /> detailed plans for implementing a remedial alternative selected on the basis of the feasibility <br /> study. The RAP addendum to test several oxygen-bearing injectants does not meet the criteria <br /> for a remedial action plan and is therefore inadequate and cannot be approved. [H&S <br /> 25296.10(c)(3)]. The EHD does approve the portions of the RAP addendum that can be <br /> considered a revised feasibility study as modified by email communications in response to EHD <br /> comments and inquiries. <br /> GTI has submitted to the EHD by email documentation demonstrating that low oxygen <br /> concentrations exist in impacted groundwater, therefore there is a possibility that increasing the <br /> concentrations of oxygen and oxygen radicals in the subsurface may directly reduce the <br /> 1245 W Charter RAP addn CML 6-24-11.doc FILE <br /> ILc ('0P ■ <br />