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San Joaquin County <br /> oP 0 Environmental Health Department DIRECTOR <br /> .o Donna Heran, REHS <br /> r 1868 East Hazelton Avenue <br /> v. A PROGRAM COORDINATORS <br /> Stockton , California 95205 -6232 Robert McClellan, REHS <br /> Jeff Carruesco, REHS, RDI <br /> . ° Website: wwwsjgov. org/ehd Kasey Foley, REHS <br /> Linda Turkatte, REHS <br /> Phone : (209) 468 -3420 Rodney Estrada, RENS <br /> Fax: (209) 464-0138 Adrienne Ellsaesser, REHS <br /> November 26 , 2014 <br /> Floyd and Helen Barnes <br /> 9477 Fountain Malley <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. Corrective <br /> Action Plan (CAP), dated 29 September 2014, prepared and submitted by your consulting firm , <br /> Stratus Environmental, Inc. (Stratus) , on your behalf for the above-referenced site; in addition, the <br /> EHD has reviewed Modified Remedial Action Plan and Feasibility Study (MRAP) , dated 24 <br /> December 2012 , and. other reports pertaining to potential remediation technologies for your site. <br /> In the CAP, Stratus concluded that ozone injection would be the most cost-effective .technology to <br /> implement to achieve case closure under the recently adopted Low-threat Underground Storage <br /> Tank Case Closure Policy (LTCP) and recommended that the EHD approve the CAP with ozone <br /> injection as the preferred remediation technology. <br /> The EHD does not approve the CAP as submitted for several reasons. A technical evaluation. <br /> incorporating site-specific characteristics demonstrating the likely success of the technology was <br /> not presented to justify use of the technology on this site ; ozone injection is not the cost-effective <br /> I technology that works on every site and it should be demonstrated why the characteristics of the <br /> subject site , contaminant type and distribution lend themselves to potentially successful <br /> application of ozone injection ; <br /> The cost estimate does not appear to be based on an estimated mass of contaminants that <br /> should be remediated to achieve remediation goals and the anticipated mass of ozone, required to <br /> accomplish the required contaminant mass reduction . <br /> In MRAP , Stratus had proposed dual phase extraction (DPE) as the most cost effective remedial <br /> technology to employ on the site to achieve case closure under the LTCP; estimating the cost for <br /> DPE at $137 , 000 for a 3-month remediation period verses the current $345,000 for an 18-month <br /> remediation period. It. is not clear why 3 months was considered an adequate time estimate <br /> previously or why the estimated time frame should now be 18 months to reach the: isame <br /> remediation goal <br /> The estimated cost for ozone injection in MRAP was $268, 000, but declined to $18.1 , 000 in the <br /> CAP. Again , it is not clear to the EHD why the costs are so different for utilizing the same <br /> technology to achieve the same cleanup goal . . - <br />