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------------ San Joaquin County Environmental Health Department DIRECTOR Donna Heran,REHS 1868 East Hazelton Avenue t< Stockton, California 95205-6232 PROGRAM COORDINATORS Robert McClellon,REHS _. Jeff Carruesco,REHS,RDI KaseWebsite:www.s ov.O 1ehd Foley,REHS cq�IkoR`�)P �'g � Linda indaTurkalte,REHS Phone: (209)468-3420 Rodney Estrada,REHS Fax: (209)464.0138 Adrienne Ellsaesser,REHS March 19, 2014 Mr. Vincent Victorine Mr. George Betker J.M. Equipment Company, Inc. Geo Corporation 321 Spreckles Avenue 2306 Jackie Court Manteca, California 95336 Oakdale, California 95361 Subject: Former J.M. Equipment Company LOP Case No.: 9401 1245 West Charter Way CUF No.:12607 Stockton, California 95206 GeoTracker ID No.: T0607700794 Dear Messrs. Vincent Victorine and George Betker: The San Joaquin County Environmental Health Department (EHD) has received and reviewed Phase III Corrective Action Plan Implementation (Phase III CAP), dated 28 February 2014, prepared and submitted by your consulting firm, Ground Zero Analysis, Inc. (Ground Zero), on your behalf for the above-referenced site. Due to budgetary constraints, Ground Zero has proposed implementing Corrective Action Plan dated 12 December 2012, and approved by the EHD by letter dated 31 January 2013, in phases and has submitted Phase III CAP as a modification of Corrective Action Plan. In the Phase III CAP, Ground Zero has proposed a work plan that includes: • Installation of the next four of ten EHD approved injection wells (IW-8 through IW-11) screened between 15 and 25 feet below surface grade (bsg) at new locations illustrated on Figure 2 of the Phase III CAP; • Injection of hydrogen peroxide into the seven previously-installed and four newly- installed injection wells; • Collection of soil samples at five-foot intervals between 5 and 25 feet bsg for lithologic classification, to target boundaries of the geologic units, and for field observation using a photo-ionization detector (PID) during the advancement of the initial boreholes during installation of the four proposed injection wells; submittal of the five-foot soil sample and up to two additional soil samples per borehole for chemical analysis of total petroleum hydrocarbons as gasoline (TPH-g); benzene, toluene, ethylbenzene and total xylenes (BTEX) and methyl tertiary-butyl ether (MTBE) by a California certified laboratory; • Injection of between 7.5 and 12.5 percent hydrogen peroxide weekly over a two-day period, injecting in six wells on the first day and five wells on the second day, or less frequently based on dissolved oxygen (DO) concentrations and oxygen-reduction potential levels, for the remaining weeks of the fiscal year, while suspending hydrogen peroxide injections at least two weeks prior to a quarterly groundwater monitoring event;