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San Joaquin County <br /> °31 ` " Environmental Health Department DIRECTOR <br /> Donna Heran, REHS <br /> s 600 East Main Street <br /> LoStockton , California 95202-3029 PROGRAM COORDINATORS <br /> r- Robert McClellon, REHS <br /> Jeff Carruesco, REHS, RDI <br /> Kasey Foley, REHS <br /> q <iFdR �� Website: www.sjgov. org/ehd <br /> Phone: (209) 468.3420 <br /> Fax: (209) 464=0138 <br /> May 28 , 2010 <br /> Raymond Farmer Enterprises , Inc. <br /> 3810 Fourteen Mile Drive <br /> Stockton , CA 95219 <br /> Subject: Farmer Property Site Code: 1151 <br /> 610 Hunter St <br /> Stockton CA 95202 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Ozone <br /> Treatment Suitability Report (Report), dated October 14, 2009, prepared by your consultant <br /> ATC Associates Inc. (ATC) for the above referenced subject site. In the Report, ATC concludes <br /> that ozone sparging appears to be a suitable and effective alternative for remediating petroleum <br /> hydrocarbon-impacted soil in the saturated zone and groundwater beneath the site. ATC <br /> recommends conducting a limited duration ozone treatment pilot test using ozone and <br /> converted air sparge wells on-site for ozone diffusion . ATC referenced Work Plan to Conduct a <br /> Feasibility Study for Ozone Pilot Testing (WP) dated August 6 , 2008 , Section 4. 5, for the <br /> proposed pilot testing activities. <br /> In the WP, ATC proposed installation of three ozone sparge wells . However, during a phone <br /> conversation with ATC on May 14, 2010, ATC indicated to the EHD that no additional ozone <br /> sparge wells are to be installed for this pilot test; and only the existing air sparge wells will be <br /> utilized . <br /> The EHD approves ATC's recommendation in the Report and directs you to have the proposed <br /> work performed by July 31 , 2010. The EHD requires a minimum 48-hour notice prior to initiation <br /> of any field work on the site. Prior to conducting the pilot test, contact Mr. James Barton with the <br /> Central Valley Regional Water Quality Control Board (CVRWQCB) at (916) 464-4615, <br /> concerning the requirement for a General Permit for injecting oxidants into the subsurface. You <br /> may not inject any substances into the subsurface without the approval of the CVRWQCB. <br /> In the report of findings, for the pilot test, please include a discussion of the potential <br /> effectiveness of the ozone injection in terms of the contaminant mass estimated to be in place, <br /> specifically the approximately 24,500 pounds in soil in the saturated zone and 11 ,860 pounds in <br /> the vadose zone. Ignoring competing reactions , the table of ozone stoichiometry in the WP <br /> shows that the ozone-to-target chemical ratio for most identified gasoline components as <br /> approximately 9: 1 , indicating that without competing reactions or other causes of ozone loss, <br /> approximately 9 pounds of ozone will be needed to destroy 1 pound of contaminant. How much <br /> ozone will be required to make a significant reduction of contaminant mass and what length of <br /> time will be required to deliver it? <br />