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N ENVIRONMIUA VYALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Donna K. Reran, R.E.R.S. Carl Bor man, R.E.H.S. <br /> Q 304 East Weber Avenue, Third Floor g <br /> Director Mike Huggins, R.E.H.S., R.D.I. <br /> Al Olsen, R.E.H.S. Stockton, California 95202-2708 Douglas W. Wilson, R.E.H. S. <br /> • cq . .- -; . �P • Program Manager Telephone: (209) 468-3420 Margaret Lagorio, R.E.H.S. <br /> tiPoR � Laurie A. Cotulla, R.E.H.S. Robert McClellan, R.E.H.S. <br /> Program Manager Fax: (209)-464-0138 <br /> g g Mark Bazcellos, R.E.H.S. <br /> FLOYD BARNES FEB 2 1 2003 <br /> 9744 FOUNTAIN VALLEY <br /> STOCKTON CA 95209 <br /> RE : Barnes Trucking SITE CODE : 2506 <br /> 1817 Fresno Ave . <br /> Stockton CA 95206 <br /> San Joaquin County Environmental Health Department (SJC/EHD) has reviewed the <br /> "Corrective Action Plan and Groundwater Monitoring Report Third Quarter 2002" dated <br /> November 20 , 2002 that was submitted on your behalf by Clearwater Group, Inc. <br /> (Clearwater) and has the following comments . <br /> The Corrective Action Plan (CAP) submits Clearwater's proposal for remediation of the <br /> soil and groundwater contamination that has been documented at your site by the use of <br /> enhanced bioremediation through a new technique, referred to as iSOC , that diffuses <br /> y10 oxygen into <br /> -the ground water, though they state quite clearly that they are proposing this <br /> alternative based on "unknown technical feasibility and cost' , The CAP recommends <br /> \ that a pilot test be performe o etermine the feasibility of using this method to boost <br /> the natural degradation processes that may be present at the site. Previous pilot tests <br /> have -been-performed at- the site to test the feasibility of using groundwater extraction <br /> (GWE) , soil vapor extraction (SVE);air sparging (AS) or a combination11for <br /> site remediation . In a report of those tests, Clearwater had concluded that they might be <br /> (j V the acceptable remedial alternative for this site. <br /> 07 7 SJC/EHD cannot approve a corrective action that is based on unknown feasibility and <br /> cost. In addition , Clearwater is proposing this method to remediate both the soil and <br /> groundwater, while the manufacturer's brochure submitted with the CAP discusses its <br /> application to groundwater only. Before SJC/EHD can evaluate this proposed method, <br /> �6 Clearwater must provide documentation that it has been used successfully at other <br /> �p petroleum hydrocarbon contaminated sites. Submit to SJC/EHD copies of: 1 ) The basic <br /> site models , and 2) before and after remediation analytical data and site history a%P information showing that this method was used effectively at these sites to remediate <br /> \� petroleum hydrocarbon contamination in both soil and groundwater. If this information is <br /> 1,' not available , then SJC/EHD recommenBslhat a different remedial alternative be <br /> considered . In addition , please specify the mass transport laws that govern the <br /> distribution of oxygen and render permeability and hydraulic conductivity properties of <br /> .�Xvthe subsurface geologic framework incapable of impeding the injected oxygen from <br /> q�6 i addressing the contaminants . <br /> �. 1 ., <br /> ri <br />