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3- <br /> ENVIRON 1"UENTAL HEALTH I)EPARTMENT <br /> SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Donna K.Heran,R.E.H.S. <br /> 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S.Director Mike Huggins,R.E.H.S.,R.D.I. <br /> AI Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> Q"gGIF O.Ra�P Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> Laurie A.Cotulla,R.E.H.S. t mm -0138 Robert McClellon,R.E.H.S. <br /> Program Manager , X' Mark Sarcellos,RT.H.S. <br /> TERRY TARDITI SEP 15 2005 <br /> 11396 HWY 99 N <br /> LODI CA 95240 <br /> RE: T & T Trucking, Inc. Site Code: 1627 <br /> 11396 Hwy 99 Frontage Rd N. RO#: 538 <br /> Lodi, CA. 95240 CUM 015089 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Addendum <br /> to July 27, 2005 letter(Addendum) dated August 23, 2005, submitted by Brown and <br /> Caldwell (B&C) on your behalf and has the following comments. <br /> The Addendum proposes a limited Accelerated Remedial Technology (ART) pilot test. <br /> Research into ART revealed that a combination of soil vapor extraction (SVE) in-situ air <br /> sparging (IAS) and ground water extractionlcircuiation (GWE) are conducted inside one <br /> large well, with.additional smaller perimeter wells installed as designed for site-specific <br /> conditions. The combination of remedial actions of SVE and GWE are commonly called <br /> dual phased extraction (DPE). The B&C original work plan and addendum proposed <br /> installing a large 6-inch main well, VEW-1, and one smaller diameter well, VEW-2, in <br /> phase 1. Phase 2 would then proceed at some unspecified time later to test SVE in <br /> VEW-1 and VEW-2 and IAS through the existing MW-1. No GWE is planned in the pilot <br /> test. Therefore, DPE is not being tested. <br /> EHD still has reservations concerning the proposed use of ART well design, specifically <br /> regarding VEW-1's long screened interval in both the unsaturated and saturated zones <br /> and that GWE-circulation is not proposed to be tested in a well designed for this use. <br /> Additionally, EHD's concerns that the ground water exposed to MtBE vapor emanating <br /> from the vadose zone contaminated soil exposed to the long screened VEW-1 have not <br /> been adequately addressed. <br /> EHD has concluded that pilot testing only the SVE and ]AS portion of the ART <br /> technology, yet proposing to construct a well design for DPE is not necessary. In order <br /> for EHD to approve a pilot test for such a specifically designed technology (ART), EHD <br /> will require the entire technology to be tested, as designed by the manufacturer. <br /> Installation of a full ART system, but only pilot testing part of it, is inadequate. Without <br /> GWE testing, the construction of VEW-1 into the contaminated saturated zone is not <br /> approved. <br />