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i <br /> San Joaquin County DIRECTOR <br /> Po WN Donna Heran, REHS <br /> Environmental Health Department ASSISTANT DIRECTOR <br /> a : „ % 600 East Main Street Laurie Cotulla, REHS <br /> N { <br /> Stockton , California 95202 -3029 <br /> i rPROGRAM COORDINATORS <br /> - Carl Borgman, REHS <br /> Mike Hu <br /> • �' "�P Website: www.s Ov or /ehd t Lag RENS, RDI <br /> Zi -F. . . 18 8 Margaret Lagorio, REHS <br /> Phone: (209) 468-3420 Robert McClellon, REHS <br /> Fax: (209) 464=0138 Jeff Carruesco, REHS, RDI <br /> - - Kasey Foley, REHS <br /> October 9 , 2008 <br /> Ms . Sherri Keys <br /> Westrec Marinas <br /> 14900 W . Highway 12 <br /> Lodi , CA. 95242 <br /> Subject: King Island Resort-UST RO#: 309 <br /> 11530 W. Eight Mile Rd . SWRCB-CUF#: 003668 <br /> Stockton , CA . 95219 Global ID#: T0607700310 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Corrective Action Plan (CAP ) dated August 28 , 2008 and has the following <br /> comments . <br /> The CAP was submitted as a requirement of the EHD after the lateral and <br /> vertical extent of the dissolved hydrocarbon ground water plume was completed . <br /> The soil and ground water data collected from monitoring wells MW-8 through <br /> MW-14 installed in May 2008 supports the delineation conclusions included in <br /> the CAP . <br /> The CAP also evaluated four remedial alternatives for cost-effectiveness and <br /> feasibility. Your consultant, ATC Associates Inc. (ATC) concluded that insitu <br /> chemical oxidation ( ISCO ) would be the best choice and recommended injecting <br /> Slow Release Neutral PH compounds by Legacy Environmental Services LLC <br /> into the subsurface . <br /> The EHD , the Central Valley Regional Water Quality Control Board <br /> (CVRWQCB ) , and the State Water Resources Control Board (SWRCB ) are not <br /> familiar with this product and in researching this product, the EHD learned that <br /> this compound has not been used in California . <br /> In order to continue our evaluation of this compound and to determine if it can be <br /> used at this site , please submit technical justification for its use over conventional <br /> and California regulatory agency approved and reimbursed ISCO products . <br /> Chemical stoichiometry equations and data from other sites with similar <br /> lithological conditions and contaminants must be included in the technical <br /> justification . After reviewing the documents and technical justification , the EHD <br /> will notify you if you may proceed with the bench scale test that is required by the <br /> CVRWQCB for waste discharge requirements . <br />