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Stratus Environmental, Inc. sqS011 <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 <br /> for the above site. The purpose for the Waterboard's involvement in <br /> your proposal is that we need to evaluate all injections into aquifers <br /> for site-specific Waterboard Waste Discharge Requirements (WDRs, or <br /> 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 <br /> testing (BST) , due 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 <br /> degradation of water quality is occurring as a result of the injection, <br /> how long that degradation will persist after cessation of treatment, and <br /> whether there are risks to sensitive receptors which make a specific <br /> treatment unacceptable. Pilot studies are also normally required prior <br /> to full scale implementation to show the effectiveness of a treatment, <br /> unless the data show that expedited, interim treatment is necessary to <br /> reduce the risk from a release. <br /> That being said, I cannot presume that all of these concerns were <br /> addressed at the adjacent site, since we only began asking for BSTs and <br /> geochemical evaluation of the data in the last few years. And as <br /> geologists, we try to find correlations related to geologic and <br /> geochemical data when transferring results from one site to another. <br /> Prior to any meeting, I would need to review the geologic cross sections <br /> and determine whether the two sites share a similar lithology and <br /> chemistry, and evaluate soil and groundwater investigation data that <br /> 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 <br /> referenced in any ISCO workplan. I am concerned that the mobile unit <br /> may present a health hazard to the public, due to the potential for <br /> exposure to a toxic gas if the unit is inadvertently damaged. Finally, <br /> the San Joaquin County Environmental Health Department will be the <br /> agency to approve the Corrective Action, if it is appropriate and <br /> necessary. <br /> Jim Barton <br /> James L.L. Barton, P.G. <br /> Engineering Geologist <br /> California Regional Water Quality Control Board Central Valley Region, <br /> 11020 Sun Center Drive, Suite 200, Rancho Cordova, CA 95670 office (916) <br /> 464-4615 <br /> fax (916) 464-4704 <br /> >>> "Sarah Salcedo" <ssalcedo@stratusinc.net> 10/10/2007 11:22 AM >>> <br /> Good morning Jim and Vicki- <br /> As you may know, Stratus is providing environmental consulting services <br /> to the Parkinson's for this site. We have finally (mostly) straightened <br /> things out with the Cleanup Fund for the Parkinson's and I wanted to <br /> 3 <br />