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L <br /> San Joaquin County DIRECTOR <br /> Donna Heran,REHS <br /> Environmental Health Department ASSISTANT DIRECTOR <br /> c Za 600 East Main Street Laurie Cotulla,REHS <br /> Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> .': Carl Borgman,REHS <br /> P Website: www.S/gov.org/ehd Mike Huggins,REHS,RDI <br /> ��IFOR� Jgov.or g Margaret Lagorio,REHS <br /> Phone: (209)468-3420 Robert McClellon,REHS <br /> Fax: (209) 464-0138 Jeff Carruesco,REHS,RDI <br /> Kasey Foley, REHS <br /> 17 October 2008 <br /> John and Margaret Marci <br /> 20 Mobile Lane <br /> Crescent City, California 95531-8409 <br /> Subject: John and Margaret Marci Property <br /> 2969 Loomis Road <br /> Stockton, California 95205 <br /> The San Joaquin County Environmental Health Department (EHD) has received <br /> and reviewed Report Pilot Test Bioventing and Biosparging Marci Property <br /> (Report), dated 05 March 2008, prepared by Geological Technics Inc. (GTI) and <br /> submitted on your behalf. In addition to the report, the EHD reviewed Procedures <br /> for Conducting Bioventing Pilot Tests and Long-Term Monitoring of Bioventing <br /> Systems (Guidance), dated May 2004, prepared by Parsons, Inc. and utilized by <br /> the Air Force Center for Environmental Excellence, Brooks Air Force Base, San <br /> Antonio, Texas. <br /> The Report documents procedures, results and conclusions from three pilot tests <br /> conducted between 21 November 2007 and 14 December 2007 on your site. The <br /> three pilot tests included bioventing (29 November to 7 December 2007), <br /> biosparging (4 December to 14 December 2007) and dual phase extraction <br /> (10 December to 14 December 2007). From the test results, GTI concluded that: <br /> • Bioventing is a viable cleanup option for the site; <br /> • Biosparging is a viable cleanup option for the site; and <br /> • Dual phase extraction (DPE) is a potential remedial alternative for the site. <br /> GTI recommended preparation of a corrective action plan (CAP) for the site <br /> comparing bioventing, biosparging and DPE. The EHD comments as follows: <br /> • The biosparging test period overlapped the test periods of both the <br /> bioventing pilot test and the DPE pilot test, potentially introducing <br /> interferences on all three tests and thereby skewing the results in a way that <br /> cannot be quantified or evaluated; <br /> • Opening valves during the bioventing test to allow atmospheric air to enter <br /> the deeper vadose zone also may have introduced an interfering effect on <br /> the test results, that again cannot be quantified or evaluated; <br /> Bioventing Pilot Test Comment Letter 1008.doc <br />