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ENVIRONMENTAL HEALTH DEPARTMENT <br /> Pp U ry SAN JOAQUIN COUNTY - - <br /> so. �_ �� .c G Unit Supervisors <br /> ¢. "� a� Donna K. Heran, R.E.H.S. Carl Bergman, R.E.H:S. <br /> �' Db ectm 304 East Weber Avenue, Third Floor 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 /> �q . . "v <br /> Program Manager Telephone: (209) 468-3420 Margaret Lagorio, R.E.H .S . <br /> �I FpR� Laurie A. Cotulla, R.E.H.S. - Robert McClellon, R.E.H.S. <br /> Program Manager Fax : (209) 464-0138 Mark Barcellos, R.EB.S. <br /> FLOYD BARNES JUN 14 2004 <br /> 9477 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 "Work <br /> Plan & Remedial Action Plan " dated May 21 , 2004 that was submitted on your behalf by <br /> Clearwater Group (Clearwater) and has the following comments. <br /> To clarify, in correspondence dated March 2, 2004 , SJC/EHD directed the submittal of a <br /> workplan for the installation of proposed oxygen injection points, along with a San <br /> Joaquin County well permit application and the required permit fee. _SJC/EHD did, not <br /> direct the submittal of a Remedial Action Plan (RAP) , as a Corrective Action Plan (CAP) <br /> had already been submitted . SJC/EHD also did not imply that the proposed injection <br /> points would be used for the "facilitation of potential nutrient injections' . SJC/EHD in fact <br /> specifically stated the opposite, that the proposal made by Clearwater in the Addendum to <br /> Corrective Action Plan was for the introduction of oxygen by infusion as a remedial option <br /> for treatment of the groundwater contamination at this site only, that there was no <br /> proposal ma e or t lie injectio—n of-nutrients—, and and that none was implied.. The additionof — -- <br /> nutrients to any subsurface environment requires a Permit for Waste Discharge , issued by <br /> the Regional Water Quality Control Board , Central Valley Region (RWQCB) . If infusion of <br /> nutrients has become an integral part of Clearwater's proposed remediation, SJC/EHD <br /> strongly encourages you to contact the RWQCB about this issue prior to initiating site <br /> remediation . <br /> In the submitted RAP, Clearwater proposes the installation of twelve monitoring wells to <br /> be used as injection points for the proposed oxygen infusion remediation. The wells will <br /> be built as conventional 2-inch diameter monitoring wells , to 25 feet total depth , with <br /> screen intervals that intercept first groundwater. The points will be built approximately 20- <br /> 30 feet apart, located on the eastern side of the site. Clearwater is proposing to initially <br /> use only six of the points in the remediation ; relocation , or use of additional oxygen <br /> infusers will be determined following review of data from the quarterly groundwater <br /> monitoring and sampling events . Clearwater proposes conducting routine Operations & <br /> Maintenance (O&M) on the system , initially at two-week intervals, including taking <br /> measurements of dissolved oxygen , and documentation of oxygen consumption . <br /> SJC/EHD considers that the analysis for natural attenuation parameters, concentrations of <br /> nitrate, sulfate, ferrous iron and pH would be appropriate and should be conducted as <br /> well . <br />