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ENVIROAT 4ENTAL HEALTAEPARTMENT <br /> Donna K. Heran, R.E.H.S. SAN JOAQUIN COUNTYUnit Supervisors <br /> m` < Director 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. <br /> T Laurie A. Culotta, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S.,R.D.I. <br /> • c..` FOR�4 • Program Manager Telephone: (209)468-3420Doulas W. <br /> a Margaret L gor Wilson,R.E.SS <br /> Fax: (209) 464-0138 Robert McClellan, R.E.H.S. <br /> Website:www.sjgov.org/ehd/ Jeff Carruesco,R.E.H.S. <br /> March 2, 2006 <br /> PAUL ZUMBERGE <br /> FRONTIER TRANSPORTATION INC <br /> 3577 W PHILADELPHIA STREET <br /> CHINO CA 91710 <br /> RE: Frontier Transportation, Inc. SITE CODE 2251 <br /> 425 Larch Road RO: 252 <br /> Tracy, CA 95376 <br /> San Joaquin County Environmental Health Department (EHD) has received and reviewed <br /> Interim Corrective Action Plan (ICRP), dated 20 December 2005, for the Frontier <br /> Transportation Property located at 425 Larch Road; Tracy, California. The ICAP was <br /> prepared and submitted on your behalf by Biophysics Environmental Assessments, Inc. <br /> (BEAT). In the ICAP, BEAI compared three potential remedial methods to employ as an <br /> interim remedial measure to reduce the mass of dissolved methyl tert-butyl ether(MTBE) <br /> migrating from your former underground storage tank(UST) system across your site. <br /> In the ICAP, BEAI presented an estimate of various dissolved contaminant masses and <br /> compared ozone sparging, soil excavation and soil vapor extraction (SVE), selecting <br /> ozone sparging as the preferred methodology for your site. To design an ozone sparging <br /> system, BEAI states it will be necessary to install four additional wells, conduct an <br /> aquifer test and perform neutron logging of the wells. <br /> EHD cannot approve the ICAP as presented for the following reasons: <br /> • Site-specific characteristics, such as a sorbed contaminant mass estimate, naturally <br /> occurring organic material mass estimate, and contact potential between ozone and <br /> contaminants, to name a few characteristics, were not considered and presented to <br /> justify selection of ozone injection as the most suitable remediation technology for <br /> your site. Ozone injection has not been shown to universally be the most effective <br /> technology for groundwater remediation on all sites. A technical justification, based <br /> on your site's characteristics should be presented to show that ozone injection has <br /> reasonable potential to cost-effectively mitigate the hazard posed by the dissolved <br /> plume. <br /> • The analysis of excavation as a remedial approach to contaminants sorbed to soil was <br /> not sufficiently detailed for EHD to concur that it is not cost-effectively applicable for <br /> your site. The excavation design, most significantly the target excavation depth, was <br /> not specified. EHD inferred from the excavation footprint (30 feet by 30 feet) and <br />