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-----Original Message-----
<br /> From: Sarah Salcedo [mailto:ssalcedo@stratusinc.net]
<br /> Sent: Thursday, October 11, 2007 3 :51 PM
<br /> To: Jim Barton
<br /> Cc: Margaret Lagorio [EH] ; Nuel Henderson [EH] ; Vicki McCartney [EH]
<br /> Subject: RE: Parkinson's Hammer I-5 Arco, 3250 W. Hammer Lane, Stockton
<br /> Hi Jim, Margaret, Nuel, and Vicki-
<br /> Thank you very much for the quick response, Jim. Certainly, I think we all need to take
<br /> some time to look at Parkinson's site data, history, geology, contaminant trends, etc as
<br /> well as look at data from SECOR's BP/CP site next
<br /> door, regarding both geo/hydro and their ongoing ozone sparging. Could
<br /> we
<br /> all take some time to do that, then plan to meet in early December to discuss our pat? I
<br /> know it's hard to know schedules out so far ahead, so how about if I plan to email
<br /> everyone again near end of November and we can plan specifics then? Please let me know
<br /> your thoughts on that.
<br /> Thanks,
<br /> Sarah O. Salcedo, P.G.
<br /> Senior Geologist / Project Manager
<br /> Stratus Environmental, Inc.
<br /> 3330 Cameron Park Drive, Suite 550
<br /> Cameron Park, California 95682
<br /> (530) 313-9966 -- voice
<br /> (530) 676-6005 -- fax
<br /> -----Original Message-----
<br /> From: Jim Barton [mailto:jbarton@waterboards.ca.gov]
<br /> Sent: Wednesday, October 10, 2007 10:37 AM
<br /> To: ssalcedo@stratusinc.net
<br /> Cc: MLagorio@sjcehd.com; Nhenderson@sjcehd.com; vmccartney@sjcehd.com
<br /> Subject: Re: Parkinson's Hammer I-5 Arco, 3250 W. Hammer Lane, Stockton
<br /> Good morning Sarah. Thank you for contacting me concerning the proposal for the above
<br /> site. The purpose for the Waterboard's involvement in your proposal is that we need to
<br /> evaluate all injections into aquifers for site-specific Waterboard Waste Discharge
<br /> Requirements (WDRs, or permits) .
<br /> Based on past experience, we have determined that air injections (air
<br /> sparging) and pure oxygen injection do not require WDRs or bench scale testing (BST) , due
<br /> to the associated low reactivity within the aquifer.
<br /> However, ozone as one of the more reactive reagents (Fenton' s Reagent,
<br /> etc. ) normally require BST and pilot studies, to show whether degradation of water quality
<br /> is occurring as a result of the injection, how long that degradation will persist after
<br /> cessation of treatment, and whether there are risks to sensitive receptors which make a
<br /> specific treatment unacceptable. Pilot studies are also normally required prior to full
<br /> scale implementation to show the effectiveness of a treatment, unless the data show that
<br /> expedited, interim treatment is necessary to reduce the risk from a release.
<br /> That being said, I cannot presume that all of these concerns were addressed at the
<br /> adjacent site, since we only began asking for BSTs and geochemical evaluation of the data
<br /> in the last few years. And as geologists, we try to find correlations related to geologic
<br /> and geochemical data when transferring results from one site to another.
<br /> Prior to any meeting, I would need to review the geologic cross sections and determine
<br /> whether the two sites share a similar lithology and chemistry, and evaluate soil and
<br /> groundwater investigation data that also include metals and general minerals (hexavalent
<br /> chromium, bromide, bromate, etc. ) . We use the ITRC guidance for Insitu
<br /> Chemical Oxidation (ISCO) , which should be followed as applicable and referenced in any
<br /> ISCO workplan. I am concerned that the mobile unit may present a health hazard to the
<br /> public, due to the potential for exposure to a toxic gas if the unit is inadvertently
<br /> damaged. Finally, the San Joaquin County Environmental Health Department will be the
<br /> agency to approve the Corrective Action, if it is appropriate and necessary.
<br /> 3
<br />
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