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San Joaquin County DIRECTOR <br /> Donna Heran, REHS <br /> PAWN. .� Environmental Health Department <br /> f� ASSISTANT DIRECTOR <br /> r. ` 600 East Main Street Laurie Cotulla, REHS <br /> l pile Stockton , California 95202 -3029 PROGRAM COORDINATORS <br /> Carl Borgman, REHS <br /> Website: wwws ov. or /ehd Mike Huggins, REHS , RDI <br /> 4 (iFOR �\ 19' 8 Margaret Lagorio, REHS <br /> Phone: (209) 468-3420 Robert McClellon, REHS <br /> Fax: (209) 464-0138 Jeff Carruesco, REHS, RDI <br /> Kasey Foley, REHS <br /> January 30, 2009 � (gT 1w <br /> Mr. Denis L. Brown Mr. David Hoover <br /> Shell Oil Products US California Fuel Supply Inc. <br /> HSEQ / Science & Engineering 587 Ygnacio Valley Road <br /> 20945 S. Wilmington Ave. Walnut Creek, CA 94596 <br /> Carson , CA 90810 <br /> Subject: Former Shell Station Site Code: 1070 <br /> 2575 Country Club Blvd. APN: 123-020-12 <br /> Stockton , CA 95204 Global ID#: T0607732095 <br /> i The San Joaquin County Environmental Health Department (EHD) has reviewed Final Remediation Plan dated <br /> November 26 , 2008 submitted by Conestoga Rovers and provides the following comments. <br /> The submittal of an alternative remedial plan was required in EHD correspondence dated October 21 , 2008, since <br /> operation of the ground water extraction system at the site was stopped in March 2008 and Shell informed the EHD <br /> that the system would no longer be utilized . <br /> j In the plan , your consultant concluded that in-situ chemical oxidation (ISCO) was the feasible (technical and <br /> practical) alternative for cleaning up the petroleum impacted ground water at the site and proposed that sodium <br /> Persulfate with a hydrogen peroxide catalyst be Injected into the shallow ground water through twelve (12) injection <br /> wells to be installed onsite. Soil samples were to be collected during the well installations and used to conduct a <br /> bench scale test (BST) to determine if metals or minerals of concern will be produced by the process. If the BST <br /> indicates that no undesirable byproducts are formed by the ISCO injection , the remedial action will continue until <br /> water quality objectives are met. <br /> The EHD requires that soil samples be collected and subjected to a BST prior to installing all twelve injection wells . <br /> If the results of the BST indicate that no undesirable byproducts are formed by the sodium Persulfate injection , you <br /> may install a few of the injection wells and conduct a Pilot test to determine the radius of influence of the ISCO and <br /> compare the impact of the chemical on the ground water to the BST results. <br /> If it can be justified that no undesirable byproducts are formed by the Persulfate injection and that a reduction of the <br /> petroleum mass is occurring and the concentrations of the constituents of concern are being reduced , you may <br /> install the remaining injection wells and put the remedial alternative into full operation . <br /> Please submit a Well Permit Application form and $89 permit fee with an updated map by February 17, 2009 that <br /> shows the locations of the limited number of injection wells you plan on installing for the Pilot test. <br /> If you have any questjon e e c act Michael Infuma at (209) 468-3454. <br /> Michael J . Infurna Jr. , RENS Margam , REHS <br /> Senior Registered Environmental Health Specialist Program Coordinator <br /> MJ I/ml <br /> c: James L. Barton, CVRWQCB <br /> Mark Owens , SWRCB-CUF, P.O. Box 944212 Sacramento, CA, 94244-2120 <br /> Joe Neely, Conestoga Rovers, 19449 Riverside Drive #230 , Sonoma, CA 95476 <br /> i <br />