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Vicki McCartney [EH] <br /> From: Sarah Salcedo [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 1-5 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 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, etc. ) normally <br /> require BST and pilot studies, to show whether degradation of water quality is occurring <br /> as a result of the injection, how long that degradation will persist after cessation of <br /> treatment, and whether there are risks to sensitive receptors which make a specific <br /> treatment unacceptable. Pilot studies are also normally required prior to full scale <br /> 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. Prior to any <br /> meeting, I would need to review the geologic cross sections and determine whether the two <br /> sites share a similar lithology and chemistry, and evaluate soil and groundwater <br /> 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 /> 1 <br />