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San Joaquin County DIRECTOR <br /> Donna Heran,REHS <br /> Environmental Health Department ASSISTANT DIRECTOR <br /> Pp•U I lv <br /> °' co <br /> 600 East Main Street Laurie Cotulla, REHS <br /> i, ?{ Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> Carl Borgman, REHS <br /> Mike Huggins, REHS,RDI <br /> c •.. ;.. �Q Website: www.sjgov.org/ehd Margaret Lagorio,REHS <br /> i 0R� Phone: (209)468-3420 Robert McClellon,REHS <br /> Fax: (209)464-0138 .teff Carruesco, REHS, RDI <br /> Kasey Foley, REHS <br /> January 23, 2009 `�r +� 7 <br /> Port of Stockton <br /> Mr. Jeff Wingfield <br /> 2201 W, Washington St <br /> Stockton CA 95201 <br /> Subject: UST Site #3 RO#: 673 <br /> Port Rd 13 at G St CUF#: 013777 <br /> Stockton, CA. 95201 Global ID #: T0607700817 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Work <br /> Plan for Site Assessment and Remediation Bench Tests, dated February 14, 2008 <br /> submitted by your consultant, WGR Southwest, Inc. and has the following comments. <br /> This plan was submitted as the result of a meeting held on January 9, 2008 and is a <br /> proposal to evaluate if in situ chemical oxidant (ISCO) injection would be feasible at this <br /> site. In addition, one shallow monitoring well (MW3-8) and two deeper monitoring wells <br /> (MW3-9 and MW3-10) are to be installed to further delineate the lateral and vertical <br /> extent of the petroleum hydrocarbon ground water plume as required by the EHD. In <br /> addition, two Geoprobes will be installed in the former underground storage tank (UST) <br /> pit for soil sample collection for the bench scale test (BST) required for ISCO feasibility <br /> evaluation. <br /> The plan calls for collecting soil samples and conducting a BST for three ISCO <br /> chemicals, Sodium Persulfate, Fenton's Reagent, and Ozone and an enhanced <br /> bioremediation study via oxygen injection. The soil samples are to be sent to Precision <br /> Enviro-Tech laboratory for analyses. <br /> The EHD requires that only one of the four ISCO chemicals be evaluated by the BST <br /> initially. If the results of the BST indicate that this chemical cannot successfully be <br /> injected into the subsurface without producing unacceptable byproducts, then the EHD <br /> will approve the BST for one of the other ISCO chemicals you included in this plan. <br /> If you advise the EHD that only one ISCO will be tested initially, then the plan can be <br /> approved without a revision being submitted. <br /> The Environmental Protection Agency (EPA) provides guidance for evaluating <br /> ozone injection and other potential remediation technologies on their web site. <br /> Another useful guidance document for evaluating ozone injection with discussion <br /> of the pertinent variables is the Technical and Regulatory Guidance for In Situ <br /> Chemical Oxidation (ISCO) of Contaminated Soil and Ground water, Second <br /> Edition, prepared by the Interstate Technology & Regulatory Council (ITRC). <br />