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a .- s San Joaquin County Environmental Health Department DIRECTOR Donna Heran,REHS s: y 600 East Main Street Q.: WPROGRAM COORDINATORS'� Stockton, California 95202-3029 Robert McClellon, REHS • Jeff Carruesco,REHS,RDI Gq. —: •��P Website: www.sjgov.org/ehd Kasey Foley,REHS �/FOR Phone: (209)468-3420 Fax: (209) 464-0138 April 13, 2010 Andrew Eggiman c/o Robert Eggiman PO Box 580 Mountain Ranch, CA 95246 Subject: Eggiman's Hydraulic 1112 East Harding Way Stockton, CA 95205 San Joaquin County Environmental Health Department (SJC/EHD) has reviewed "Work Plan to Conduct Ozone Treatability Pilot Testing"(Work Plan) dated February 8, 2010, submitted on your behalf by ATC Associates, Inc. (ATC) and has the following comments. In the Work Plan ATC proposes the installation of six ozone sparge infusion points in four borings, and performance of a four-week long ozone infusion pilot test for remediation of the documented petroleum hydrocarbon contamination in soil and groundwater at this site. During the proposed pilot test the site will be closely monitored for the production of unwanted chemical by-products and contingency actions will be taken if they are produced and/or do not attenuate within a reasonable time frame. The most significant reported soil contamination at this site is from approximately 10 to 20 feet below surface grade (bsg) near the location of the former underground storage tanks (UST's) in borings SB-1, SB-4 and SB-7, followed by the 30 to 40-foot interval in borings MW-1, MW-2, MW-5 and MW-6. Of the eleven groundwater monitoring wells associated with this site, only two, MW-8 and MW-11, do not have consistently reported petroleum hydrocarbon contamination in the groundwater samples collected from them. The EHD approves the proposed ozone infusion pilot test with the following conditions: 1. An additional sparge point needs to be placed to address the soil contamination present in the former tank pit area at a depth of 10-15 feet bsg. 2. The deeper sparge points should be placed at total depth of 55 feet bsg. The proposed total depth of 70 feet bsg for these points is not appropriate as there is no documented contamination at this depth. The vertical extent of the groundwater contamination at this site was defined by a grab-groundwater sample collected at 70 feet bsg from boring CPT-1, with reported laboratory analytical results all non-detect. 3. Please proceed with submittal of a San Joaquin County well installation permit application, required $89.00 permit fee, $345.00 inspection fee and with scheduling the approved work. Additionally, please contact the Regional Water Quality Control Board to verify whether a permit for general waste discharge is required for the proposed and approved pilot test.