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ENVI•NMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> Cnit Su(Jel tiSore <br /> ' <br /> Donna K.Heran,R. .H.S. Carl Borman REH.S- <br /> �. <br /> Dire,,tai, 304 East Weber AVenLle, Third F100C dike Hu_�insR.E.H.S.. R.D.1. <br /> Al (nsen,R.E.H. . Stockton, California 95202-2708 Dou las iv Wilson.R.E.H.S. <br /> o �_r Program Alawgc ' Telephone: (209) 468-3420 Margaret LaLorio R.E.H.S. <br /> Laurie A.Cotulla, R. LH.S. Robert McClellon,R.E.H.S- <br /> Program,tla ag r Fax: (209) 464-0138 Mark Barcellos, R.E.H.S. <br /> NANCY NELSON JAN 2 1 2001F <br /> JM EQUIPMENT CO INC <br /> 819 S 9TH ST <br /> MODESTO CA 95351 <br /> RE: JM Equipment Site Code:#: 9401 <br /> 1245 W. Charter Way RO#: 297 <br /> Stockton, CA 95206 CUF#: 12607 <br /> San Joaquin Count Environmental Health Department (SJCEHD) has reviewed <br /> In Situ Chemical Ox dation Pilot Test prepared by Geological Technics Inc, (GTI) <br /> dated November 12 2004. The report included the test period from March 19, <br /> 2004 through July 8 2004. SJCEHD has evaluated the report and comments as <br /> follows. <br /> GTI states the folio ing: "The test demonstrated that oxidants can destroy the <br /> contamination in groundwater at the site but the radius of influence is limited due <br /> to the clayey soils at the site" and then discusses some of the experimental <br /> design limitations. 3JCEHD does not agree with the first part of the statement, <br /> but does agree thal there are significant experimental design limitations. <br /> Whereas SJCEHD oes not dispute that oxidants, especially those that generate <br /> reactive molecules r radicals, can breakdown hydrocarbon contaminants, <br /> SJCEHD is unconv nced that the results of this pilot test demonstrate such <br /> reactions are prim rily responsible for the observed hydrocarbon concentration <br /> decrease in MW-9 ind GP-1, and believes other factors may have contributed <br /> substantially toward the observed effects. <br /> Observation 1: DE creased contaminant concentrations in MW-9 and GP-1, <br /> which GTI interpre s to indicate that the hydrocarbon contaminants were <br /> degraded by the oxidant injected. <br /> While some degradation of hydrocarbons may have occurred, dilution of the <br /> impacted groundw 3ter may have also been a significant factor. GTI addressed <br /> this possibility by calculating the volume of water within a 4-foot radius of the 20- <br /> foot screened interval of MW-5 to be 3,762 gallons if soil had 50% porosity. <br /> Applied Process Technology, Inc. (APT) states that 60 gallons of distilled water <br /> and 15 gallons of hydrogen peroxide solution were injected into MW-9 during the <br /> test, less than 2% of the pore-volume water. <br />