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ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> .0 Unit Supervisors <br /> 2` t A Donna K. Heron, R.E.H.S. 304 East Weber Avenue, Third Floor Carl Borgman, R.E.H.S . <br /> A�I'I Director <br /> 1lMike Huggins, son, 5 ., R.D.I. <br /> l l�'11 Al Olsen, R.E.H.S. Stockton , California 95202-2708 Douglas W. Willson, R.E.H.S. <br /> • cy c ' �P • Program Manager Telephone: (209) 468 -3420 Margaret Lago io, R.E.H.S. <br /> coa `' Laurie A. Cotulla, R.E.H.S. _ Fax : (209) 464-0138 Robert McClellon, R.E.H.S . <br /> Program Manager Mark Barcellos, R.E.H.S. <br /> FLOYD BARNES LIAR 0 2 2004 <br /> 9744 FOUNTAIN VALLEY <br /> STOCKTON CA 95209 <br /> RE : Barnes Trucking SITE CODE : 2506 <br /> 1817 Fresno Avenue <br /> Stockton CA 95206 <br /> O <br /> X01 ., �;o San Joaquin County Environmental Health Department (SJC/EHD) has reviewed <br /> `Addendum to Corrective Action Plan Explanation of iSOC Technology" (Addendum) <br /> . d daCecTU( cember 313 2003, submitted on your behalf by Clearwater Group, Inc. <br /> X (Clearwater) and has the following comments. <br /> In correspondences dated February 21 , 2003 and June 9, 2003 SJC/EHD responded to <br /> the original Corrective Action Plan (CAP) submitted by Clearwater and requested further <br /> information and documentation regarding their proposed remediation alternative, "isOC. <br /> SJC/EHD specifically requested information documenting basic site models , before and <br /> after remediation analytical data and site history information from petroleum hydrocarbon <br /> release sites at which iSOC had been successfully used , and a technical demonstration <br /> that the method would be applicable to your site . <br /> The submitted addendum states that based on the findings of the biodegradation pilot <br /> study, Clearwater believes that the best remediation option for this site is enhanced <br /> bioremediation using oxygen infusion by iSOC technology. Clearwater makes this <br /> recommendation based on cost comparison and their opinion that the technology has <br /> been used successfully at sites with contaminant profiles and soil conditions similar to <br /> this site. Supporting documentation for their recommendation included the previously <br /> submitted PowerPoint slides from the iSOC manufacturer, and a letter from CytoCulture <br /> International Incorporated , which discusses the decreasing concentrations of aerobic <br /> bacteria populations and depletion of the nutrients nitrogen and phosphate. Please note <br /> that the addendum proposes the introduction of oxygen by infusion only, there is no <br /> proposal for the injection of nutrients and none is implied . <br /> SJC/EHD has not received conclusive supporting documentation , or is aware of any <br /> sites, where this technology has been used successfully. SJC/EHD cannot compare the <br /> two case histories presented in the PowerPoint presentation to the subject site as <br /> numerous variables are not discussed and no detailed hydrogeological models were <br /> shown. SJC/EHD discussed the iSOC technology with staff from the California State <br /> Water Resources Control Board Clean Up Fund . The Fund staff indicated that they had <br /> heard of the technology, and though they were not familiar with any contaminated site at <br /> which it had been used , they would be receptive to approving reimbursement for its <br />