SITE INFORMATION AND CORRESPONDENCE FILE 2

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San Joaquin County DIRECTOR Po N Donna Heran, REHS .�o Environmental Health Department ASSISTANT DIRECTOR 600 East Main Street Laurie Cotulla,REHS Stockton, California 95202-3029 PROGRAM COORDINATORS Cad Borgman,REHS Mike Huggins,REHS, RDI Website: www.sjgov.org/ehd Margaret Lagodo,REHS FOR Phone: (209)468-3420 Robert McClellon,REHS Fax: (209)464-0138 Jeff Carruesco,REHS,RDI Kasey Foley,REHS r�T September 25, 2008 ?� Mr. Bill Borgh Hardev &Amarjit Khinda Etal ConocoPhillips 27000 S. Leeward 76 Broadway Tracy, CA 95304 Sacramento, CA 95812 Subject: Circle K/ Service Station #01205 R0#:0138 16470 Cambridge Drive Site Code: 507198 Lathrop, CA 95330 Global ID#: T0607700822 The San Joaquin County Environmental Health Department (EHD) has reviewed and received on Geotracker Work Plan for Remediation Pilot Test dated September 5, 2008 and Request for Modification to Monitoring and Sampling Plan dated June 18, 2008 and has the following comments. The Modification and Sampling Plan is adequate and approved. The Pilot Test Work Plan (Plan) was in response to the EHD's August 6, 2008 correspondence requiring a pilot test for the recently approved ozone injection bench scale test. The Plan proposes the installation of five ozone sparge wells onsite (SP-1 through SP-3, SP-5, and SP-6), three soil vapor extraction wells onsite (SVE-1 through SVE-3), two soil vapor sampling points onsite (SV-1 and SV-2), and the ozone sparge/soil vapor extraction unit. After the EHD and the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) approve the work plan, the ozone sparge/soil vapor extraction system will be operated for six months to evaluate the effectiveness of the system. The EHD has evaluated the ozone injection well proposed locations and has concerns with the effectiveness of the monitoring plan. Existing monitoring wells are to be used to monitor the dispersion/effect of the ozone injection. The EHD is concerned that most of the proposed ozone injection wells are too far from the existing monitoring wells. Technical justification/calculations are to be submitted to the EHD to demonstrate that the monitoring wells, approximately sixty feet (MW-5) to more than 90 feet (MW-6) from the closest injection points, can accurately monitor the effectiveness of ozone injection and detect the generation of any harmful byproducts in the six-month test period proposed. The plan is inadequate and not approved at this time. iH&S Code 25296.10(c)(3)]. A revision is required that adequately addresses the monitoring point concern.