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+.w s <br /> In-Sit-Li Oxidative Technologies,Inc. <br /> Iseltic <br /> June 2, 2006 MM <br /> .....:...... <br /> Mr. John Lane <br /> Ground Zero Analysis, Inc. <br /> 1714 Main Street <br /> Escalon, California 95320 <br /> RE: Response to Comments <br /> California Regional Water Control Board Review <br /> Work plan for Vertical Investigation and Bench Test for In-Situ Oxidation <br /> 7835 Thornton Rd, Stockton, CA <br /> Dear Mr. Lane, <br /> I reviewed the comments from Mr. James Barton, P.G. of the Central Valley Board. I <br /> will address the issues I can with this letter. First, let me differentiate ISOTEC's <br /> modified Fenton's process from other oxidants. The following are ISOTEC modified <br /> Fenton's qualities: <br /> • Neutral pH catalyst(Patented—no other companies utilize this approach). <br /> • Both oxidizing and reducing radicals are produced at neutral pH. <br /> • Reducing species cause desorption of contaminant mass from soil. <br /> • Nearly instantaneous reactions. <br /> • Treatment occurs within hours of injection. <br /> • Oxidizing conditions only persist for days after injection. <br /> When the ISOTEC process is compared to permanganate or persulfate treatment <br /> processes there are very distinct differences. Permanganate and persulfate have the <br /> following qualities: <br /> • No reducing radicals are produced. <br /> • Little or no desorption of contaminant mass, except through concentration <br /> gradients. <br /> • Oxidizing conditions persists for months after injection. <br /> However, all oxidants have two things in common, 1) They are non-selective with regard <br /> to the organic compounds they degrade and 2) they are all phase sensitive. By this I <br /> mean that the oxidants will attack all organics simultaneously, but they attack the <br /> dissolved phase first. In-situ chemical oxidation (ISCO) treatment using these oxidants <br /> occurs primarily in the dissolved phase; the oxidation reactions are aqueous reactions. <br /> Therefore, oxidation of the dissolved phase contaminant mass occurs almost instantly <br /> with all oxidants, as long as the oxidant is strong enough to address the contaminant type. <br /> 6452 FIG STREET,SurrE C,ARVADA,COLORADO 80004 <br /> PHONE: 303-843-9079 FAX: 303-843-9094 <br />