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v N=W Vicki McCartney [EH] From: Jim Barton obarton@waterboards.ca.gov] Sent: Wednesday, October 10, 2007 11:37 AM To: ssalcedo@stratusinc.net Cc: Margaret Lagorio [EH]; Nuel Henderson [EH]; Vicki McCartney[EH] Subject: Re: Parkinson's Hammer 1-5 Arco, 3250 W. Hammer Lane, Stockton Good morning Sarah. Thank you for contacting me concerning the proposal for the above site. The purpose for the Waterboard's involvement in your proposal is that we need to evaluate all injections into aquifers for site-specific Waterboard Waste Discharge Requirements (WDRs, or permits) . Based on past experience, we have determined that air injections (air sparging) and pure oxygen injection do not require WDRs or bench scale testing (BST) , due to the associated low reactivity within the aquifer. However, ozone as one of the more reactive reagents (Fenton's Reagent, etc.) normally require BST and pilot studies, to show whether degradation of water quality is occurring as a result of the injection, how long that degradation will persist after cessation of treatment, and whether there are risks to sensitive receptors which make a specific treatment unacceptable. Pilot studies are also normally required prior to full scale implementation to show the effectiveness of a treatment, unless the data show that expedited, interim treatment is necessary to reduce the risk from a release. That being said, I cannot presume that all of these concerns were addressed at the adjacent site, since we only began asking for BSTs and geochemical evaluation of the data in the last few years. And as geologists, we try to find correlations related to geologic and geochemical'rata when transferring results from one site to another. Prior to any meeting, I would need to review the geologic cross sections and determine whether the two sites share a similar lithology and chemistry, and evaluate soil and groundwater investigation data that also include metals and general minerals (hexavalent chromium, bromide, bromate, etc. ) . We use the ITRC guidance for Insitu Chemical Oxidation (ISCO) , which should be followed as applicable and referenced in any ISCO workplan. I am concerned that the_mobile unit may present a health hazard to the public, due to the potentia or exposure to a toxic gas if the unit is ina vertently damaged. Finally, the San Joaquin County Environmental Health Department will be the agency to approve the Corrective Action, if it is appropriate and necessary. Jim Barton James L.L. Barton, P.G. Engineering Geologist California Regional Water Quality Control Board Central Valley Region, 11020 Sun Center Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 fax (916) 464-4704 >>> "Sarah Salcedo" <ssalcedo@stratusinc.net> 10/10/2007 11:22 AM >>> Good morning Jim and Vicki- As you may know, Stratus is providing environmental consulting services to the Parkinson's for this site. We have finally (mostly) straightened things out with the Cleanup Fund for the Parkinson's and I wanted to re-open some dialogue with you both on moving the site forward toward remediation and closure. The previous consultant (Shaw) had submitted a CAP on October 26, 2004 providing a cost evaluation of several remedial alternatives and selecting ozone sparging as the preferred remedial alternative. In a letter to Parkinson dated May 27, 2005, San Joaquin County EHD approved this CAP and concurred with Shaw's proposal to install an ozone system at the site, contingent upon the RWQCB's approval of this plan. We have reviewed the site and the groundwater data collected in the past few years since the CAP was written and approved, and although concentrations have decreased significantly since that time, we concur that ozone sparging could be a good choice for remediation at the site. Further, at the property immediately adjacent (east) of the site at 3202 Hammer Lane, ozone sparging has been successfully ongoing for more than three years (May 2004) . Because of the already-implemented ozone sparging on the adjacent parcel, I would assume there would be little need for geochemical testing for valence state conversions of 1