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d <br /> San Joaquin County <br /> RECTOR}q. Environmental Health Department DILinda Turkatte, REHS <br /> 1868 East Hazelton Avenue <br /> W Stockton , California 95205-6232 PROGRAM COORDINATORS <br /> Robert McClellon, REHS <br /> Jeff Carruesco, REHS, RDI <br /> Website: www.sjgovorg/ehd Kasey Foley, REHS <br /> Cr F o R Rodney Estrada, REHS <br /> Phone: (209) 468-3420 Adrienne Ellsaesser, REHS <br /> Fax: (209) 464.9.13 $ <br /> February 23, 2015 <br /> Floyd and Helen Barnes <br /> 9477 Fountain Valley <br /> Stockton, CA 95209 <br /> Subject: Barnes Trucking <br /> 1817 Fresno Avenue <br /> Stockton, CA 95206 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Addendum to <br /> Corrective Action Plan (ACAP), dated 31 December 2014, prepared and submitted by your <br /> consulting firm, Stratus Environmental , Inc. (Stratus) , on your behalf for the above-referenced site. <br /> In ACAP, Stratus provided a rational for the differing estimated costs for dual phase extraction <br /> (DPE) verses ozone injection (OI) in previous documents (Modified Remedial Action Plan dated <br /> December 2012 , and Corrective Action Plan dated 29 September 2014) ; the cost differences <br /> primarily a consequence of differing system design requirements and estimated remedial time <br /> period . <br /> In ACAP Stratus appears to have misinterpreted the EHD directive to provide a technical <br /> justification for either implementing or pilot testing OI ; the EHD does not expect or request 'proof" <br /> that OI would work on the site , the EHD only needs to know the technical reasons Stratus offered <br /> a recommendation for its use. Stratus states that the site is similar to other sites where the <br /> technology has been successfully implemented and the EHD seeks to have 'the points of similarity <br /> with these other sites specified in order to have a technical basis for concurring with the <br /> professional opinion offered by Stratus. <br /> As part of the justification for use of OI , Stratus stated their belief that most of the rernediation <br /> through OI occurs through degradation of ozone to oxygen which then stimulates biologic <br /> degradation of the petroleum hydrocarbons. An oxygen infusion system , referred to as an iSOC <br /> system , was operated on the site from 2004 to 2011 to increase oxygen concentrations for such <br /> an effect. Technical review of that remedial action may be beneficial for the technical justification <br /> for OI . <br /> Anticipating receipt of Stratus' technical justification for use of OI , the EHD approves preparation <br /> of the pilot-scale remedial action work plan which should include the technical justification . Also <br /> prepare and submit a one-page summary of the overall CAP for use for a 30-day public <br /> participation period required for CAP approvals, the EHD recommends meeting the criteria for the <br /> Low-threat Underground Storage Tank Case Closure Policy (LTCP) as the cleanup goal . Please <br /> submit the work plan and one-page summary to the EHD by May 1 , 2015 . <br />