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*..i `ow <br /> San Joaquin County DIRECTOR <br /> PQ i N Donna Heran,REHS <br /> �O op Environmental Health Department ASSISTANT DIRECTOR <br /> QrF 600 East Main Street Laurie Cotulla,REHS <br /> ' t{ Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> •'• V• Carl Borgman, REHS <br /> F OV.O/ /ehd Mike Huggins, REHS,RDI <br /> Website: www s <br /> c��iFOR��P 15 g 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 /> THOMAS O'NEILL NOV 0 1 2007 <br /> PO BOX 923 <br /> STOCKTON CA 95201 <br /> RE: Valley Motors Site Code: 1166 <br /> 800 E. Main St. RO#: 594 <br /> Stockton, CA 95202 CUF#: 12540 <br /> The San Joaquin County Environmental Health Department (SJCEHD) has reviewed Air <br /> Sparging Pilot Test(Report) dated August 20, 2007 submitted by Upgradient <br /> Environmental Consultants (UEC) on September 12, 2007 and has the following <br /> comments. <br /> The SJCEHD had required that you evaluate remedial alternatives for this site since <br /> concentrations in the soil and ground water exceed levels that would be acceptable for <br /> considering site closure. <br /> The SJCEHD approved the in situ air sparging test in order to evaluate air sparging as a <br /> remedial alternative. According to the report, "pumping air into the deeper sand bed <br /> does not cause air to rise upward through the silt-clay interval into the overlying <br /> permeable sand bed"and concluded "vapor extraction wells within the latter bed would <br /> not be able to suck volatilized hydrocarbons from the deeper sand bed through the silt- <br /> clay interval" Even with the installation of a new sparging well, UEC stated there would <br /> be no advantage gained and that air sparging at this site is not recommended. The <br /> SJCEHD concurs. <br /> Other remedial alternatives were listed in the Options section of the Report and UEC <br /> indicated that ground water pump and treat has the greatest potential for success. <br /> Additionally, UEC discussed conducting a feasibility test of in-well air stripping in VM-2 <br /> as a viable remedial alternative. <br /> Please prepare a feasibility study that evaluates at least two feasible remedial <br /> alternatives for cost-effectiveness and include your chosen method. The feasibility <br /> study should be submitted to the SJCEHD before December 7, 2007. The cost <br /> comparison of the remedial alternatives should include well installation costs and costs <br /> to properly dispose of any extracted and treated ground water. <br /> The last option provided in the Report, close the case and placing development <br /> limitations on future use of the property, is not acceptable. Remediation is required at <br /> this site. <br />