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� Nnr Yaur I�tsal Corrruffartf <br /> The Port will comply with Items A and B of the approval letter and will instruct the <br /> L analyzing laboratory and subcontractors.accord ingly. With respect to Item C, we <br /> have the following two comments: <br /> 1 The Port 'proposes to evaluate for two oxidants, ozone and an <br /> ozonelhydrogen peroxide mixture ("perozone"); in the initial BST. From <br /> discussions with. the EHD, it has been stated that there is a lack of <br /> background evidence of successful case studies using Sodium Persulfate <br /> and 'Fenton's Reagent (the other oxidants proposed in the Work Plan) in <br /> sites of similar'.hydrogeology to San Joaquin county. Of the three <br /> oxidants, it appears that ozone is. preferred by the EHD. In order to <br /> optimize the usefulness of the initial BST, The Port thinks it more prudent <br /> and cost-effective to evaluate perozone.effectiveness as well as ozone. <br /> The addition of hydrogen peroxide to ozone has been shown to catalyze <br /> k and strengthen its oxidizing capacity. Successful case studies and <br /> E <br /> comments are attached for your reference. We also feel that using more <br /> than one oxidant in the initial BST will provide a clearer assessment of the <br /> E oxidants and soil characteristics at the Site and will likely further preclude <br /> the need for additional Persulfate and Fenton's Reagent BSTs. <br /> 2) The Port would dike to clarify that the enhanced bioremediation study <br /> (EBS) was never -intended to-be part of the BSTs. The response letter <br /> seems to indicate that it was. The purpose of the EBS is to characterize <br /> groundwater conditions at the edge of the plume whereas the purpose of <br /> the BST is to characterize oxidant soil characteristics-in the source area <br /> of the plume. The. EBS will be-performed during.quarterly groundwater . <br /> sampling by analyzing for extra constituents from wells-located along the <br /> edge of 'the contaminated plume. Based 'on our understanding of the <br /> letter, The Port will plan to_perform the EBS sampling and analysis during <br /> the second quarter 2009 well sampling event. <br /> Should you have questions or comments regarding this report, please contact Chris . <br /> Strong at (209) 334-5363, extension 214. <br /> s <br /> C <br /> Regards, xkoKA At G <br /> g Z" Fo <br /> WGR Southwest, Inc. l� <br /> crura �. <br /> �'- STAONRu'i <br /> u, No.8070! <br /> Chris Strong <br /> 0 <br /> � California P.G. #8070 . o F <br /> 1 F CAL-1 <br /> Cj cc: Mr. Jeffrey D. Wingfield, Port of Stockton <br /> i Mr. James Barton, Central Valley Regional Water Quality Control Board <br /> Mr. Mark Owens, State Water Resource Control Board — Cleanup Fund <br /> i4 736. PRIM 2 Work Plan Addendum <br />