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ENVIROJIMENTAL HEALTh ,DEPARTMENT <br /> I <br /> I ° SAN JOAQUIN COUNTY <br /> E <br /> Donna K. Heran, RX.H.S. Unit Supervisors <br /> < Director 304 East Weber Avenue , Third Floor Cad Borgman, R.E.H.S . <br /> Laurie A. Cotulla, R.E.H.S. Stockton, California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. <br /> R-ograna Munger Douglas W. Wilson, R.E.H.S . <br /> i gCiFO.F P\ <br /> Telephone: (209) 468-3420 Margaret Lagorio, R.E.H.S. <br /> Fax : (209) 464-0138 Robert McClellon, R.E. H.S. <br /> Website: www.sjgov.org/ehd/ teff Carruesco, R.E.H .S . <br /> VELMA MASTERSON FEB O 8 2006 <br /> BENETO INC <br /> PO BOX 980220 <br /> WEST SACRAMENTO CA 95798 <br /> RE: DARPETRO, INC Site Code: 1060 <br /> 749 E CHARTER WAY <br /> STOCKTON, CA 95202 <br /> San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed Amended Feasibility Study (AFS), dated 30 January 2006 , Work Plan (WP- <br /> SVE ) dated 20 January 2006 , and Work Plan (WP-MW) dated 24 January 2006, all <br /> prepared and submitted on your behalf by California Geophysical Group (CGG ). CGG <br /> prepared the AFS , WP-SVE and WP-MW in response to EHD's directives conveyed by <br /> letters dated 27 September 2005 and 06 January 2006 to submit a feasibility study for <br /> groundwater remediation , a work plan to install a deeper groundwater monitoring well <br /> and a work plan to test the vapor wells on your site to assess the potential for additional <br /> benefit utilizing a focused application of the existing soil vapor extraction (SVE) system <br /> on your site on areas still yielding significant contaminant vapor. The 06 January 2006 . <br /> letter contained a directive to submit the two then overdue work plans within 14 days. <br /> EHD's 06 January 2006 letter had also directed that the original Feasibility Study (FS ) <br /> dated 14 December 2005 , for interim groundwater remediation be amended to include a <br /> technical justification for the recommended remediation method , namely ozone <br /> injection . EHD considered the FS to be inadequate and had included a list in the 06 <br /> January letter of some of the important site and contaminant characteristics that should <br /> be considered , in addition to time and cost, in selecting a preferred remedial alternative. <br /> These characteristics can generally be used to present the technical justification for the <br /> selected alternative . Compared to the FS , the AFS contained three additional sentences <br /> under "Groundwater Concepts", substituted " Process 3" for natural attenuation in <br /> section W Remedial Action Objectives and Processes", added the statement "This work <br /> plan will control the majority of the plume" under the section on Process 1 , and gave a <br /> short non-technical three-sentence discussion of use of RegenOX under the "Process <br /> 3" section . The AFS dropped a recommendation for any of the remedial alternatives . <br /> What was not included in the AFS was the technical justification , based on the criteria <br /> noted in the EHD letter of 06 January 2006 , that forms the basis for a sound <br /> professional judgment of which remedial option is likely to be the most effective for your <br /> site based on site conditions and contaminant characteristics . EHD finds the AFS to still <br />