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- <br /> San Joaquin County <br /> oP� I Environmental Health Department DIRECTOR <br /> Donna Heran, REFS <br /> 600 East Main Street <br /> m PROGRAM COORDINATORS <br /> 7 Stockton , California 95202 -3029 Robert McClellen , REHS <br /> Jeff Carruesco, REHS , RDI <br /> • cq . . .s : P Kasey Foley, REFS <br /> Foo Website: : (209)gov. or20 Linda Turkatte, REHS <br /> Phone : (209) 468-3420 <br /> Fax : (209 ) 464-0138 <br /> November 10, 2011 <br /> Bill Stoermer Lawrence Beasley <br /> Fremont Plaza Investments Apache Plastics <br /> 7015 Morton Court 2120 Pebble Drive <br /> Stockton , CA 95209 Alamo , CA 94507 <br /> Subject: Former Apache Plastics <br /> 2050 Fremont Street <br /> Stockton , CA 95209 <br /> The San Joaquin County Environmental Health Department (EHD ) has reviewed In-Situ <br /> Chemical Oxidation Pilot Test Report ( Report) , and ISCO Pilot Study Extension Work Plan <br /> (Work Plan ) both dated August 31 , 2011 , submitted on your behalf by Advanced <br /> GeoEnvironmental , Inc. (AGE ) and has the following comments. <br /> AGE proposes in the Report to extend the pilot study by one or more rounds of injection of In <br /> Situ Chemical Oxidation ( ISCO ) media to determine the efficiency of ISCO to treat the <br /> dissolved hydrocarbon contamination at this site. AGE outlines briefly in the Work Plan a <br /> procedure modified from the original pilot test work plan , proposing to use a different branded <br /> injectant and injecting it under pressure into an onsite groundwater well . The previous <br /> injection was done with a series of direct push borings . AGE identifies well EW- 1 as the <br /> treatment/observation well ; well MW-9 as the transition well , and MW-8 as the compliance <br /> well . <br /> The EHD approves one additional injection event with the following conditions : <br /> 1 . The test design must be improved to include : <br /> a . An average of 'baseline conditions' , including pH , SC, ORP , DO , total <br /> hardness , COD , BOD and TOC must be established over several <br /> measurement events , not just one as was done just prior to the previous <br /> injections . As these parameters vary naturally over time , more than one <br /> measurement is needed to be able to differentiate significant effects of the <br /> injection from natural variation . <br /> b . Control wells located outside of the injection area must be included in the <br /> monitoring and sampling regimen . <br /> c . All parameter data collected , both before and after the injection , must be <br /> analyzed and interpreted in context of the injection effects . <br /> 2 . The fare of the increased dissolved contaminant concentrations must be explained . <br /> 3 . Approval to perform the injections must be obtained from the Central Valley Regional <br /> Water Quality Control Board . <br />