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� U San Joaquin County DIRECTOR Po t N Donna Horan, REHS 0. „' , ' C Environmental Health Department ASSISTANT DIRECTOR c F�. Z\ 600 East Main Street Laurie Cotulla,REHS U): - i� Stockton, California 95202-3029 PROGRAM COORDINATORS Carl Borgman, REHS Mike Huggins,REHS, RDI C4C/FOR�\P Website: www.S/gov.org/ehd Margaret Lagono, REHS Phone: (209) 468-3420 Robert McClellon,REHS Fax: (209)464-0138 Jeff Carruesco, REHS,RDI Kasey Foley,REHS July 15, 2008 Joe Toste Jr. JT Storage 2480 Toste Road Tracy, CA 95376 Subject: Curtiss Pontiac-Cadillac SITE CODE: 1877 2450 Toste Road Tracy, CA 95376 San Joaquin County Environmental Health Department (SJC/EHD) has reviewed Ozone Injection Bench Scale Work Plan (Work Plan) dated May 15, 2008, and Quarterly Groundwater Monitoring Report — First Quarter 2008 (Report) dated May 29, 2008, both submitted on your behalf by Advanced GeoEnvironmental, Inc. (AGE) and has the following comments. In the Work Plan AGE proposes procedures for conducting an ozone infusion bench scale test to determine the feasibility of using ozone infusion to remediate the petroleum hydrocarbon contamination remaining in the groundwater at your site. AGE proposes the advancement of one soil boring to collect soil samples for the ozone infusion bench scale test from the saturated zone at depths of 15 feet below surface grade (bsg) and 35 feet bsg. AGE states that up to twelve soil samples will be selected for analysis, and also states that soil samples from each interval will be utilized for the bench scale test. Approximately 4.4 pounds of soil sample is needed for the bench scale test. AGE states in the Work Plan Appendix C that groundwater samples for the ozone infusion bench scale test will be collected from onsite groundwater monitoring wells MW-1B and MW-4, screened from 23-28-feet bsg and 5-15-foot respectively. Monitoring well MW-1 B, however, is screened from 5-15 feet bsg. Clarification is needed to identify whether the groundwater sample will be collected from MW-1 B which has the same screen interval as MW-4, or MW-1A which has a deeper screen interval from 23-28 feet bsg. An addendum to the Work Plan is needed to add the following analysis and procedures: 1. Baseline analysis of soil and groundwater samples must include tertiary butyl formate (TBF), bromate, bromide and tungsten. 2. Stoichiometry or chemical equations with concentrations in moles of all expected intermediate and end products from the reaction between the injectant and the soil and groundwater. 3. A proposal for testing of a contingency plan to abort or reverse geochemical processes induced by the injectant. 4. Specific location of the collection of the groundwater samples to be used in the bench scale test.