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ENVIRONMENTAL HEALTH VEPARTMENT <br /> o°'° c <br /> SAN JOAQUIN COUNTY <br /> Q m.., Donna K. Heran, R.E.H.S. Program Coordinators <br /> Director 304 East Weber Avenue,Third Floor Carl Borgman, R.E.H.S. <br /> 1 <br /> Laurie A. Cotulla, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S.,R.D.I. <br /> • F o%/ Assistant Director Telephone: (209)468-3420 Margaret Lagorio, R.E.H.S. <br /> Robert McClellon, R.E.H.S. <br /> Fax: (209)464-0138 Jeff Carruesco, R.E.H.S. <br /> Website:www.sjgov.org/ehd/ Kasey Foley, R.E.H.S. <br /> THRIFTY OIL COMPANY OCT 0 5 2006 <br /> LARRY HIGINBOTHAM <br /> 13116 IMPERIAL HIGHWAY <br /> SANTA FE SPRINGS CA 90670 <br /> RE- Thrifty Station #172 Site Code: 1227 <br /> 7647 Pacific Avenue RO#: 0557 <br /> Stockton, CA 95207 CUF #: 002156 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Addendum Work Plan for Remediation (the Plan), dated 08 May 2006, prepared <br /> by GeoHydrologic Consultants, Inc. (GHCI), and has the following comments. <br /> Soil vapor extraction (SVE) and ground water extraction (GWE) has been <br /> conducted at the above referenced underground storage tank (UST) site under a <br /> remedial action plan (RAP) approved by the EHD. Recent changes to the City of <br /> Stockton water discharge permit requirements have caused a suspension of the <br /> GWE remedial action as the required discharge concentration limits cannot be <br /> achieved by the ground water treatment system currently installed onsite. The <br /> EHD directed preparation of the addendum to the RAP to discuss and evaluate <br /> other potential remedial alternatives to continue the cleanup of the remaining <br /> ground water with elevated concentrations of petroleum hydrocarbons. <br /> The Plan included a feasibility evaluation and cost comparison of four remedial <br /> alternatives and GHCI concluded that SVE in conjunction with ozone sparing was <br /> the most cost effective and feasible remedial option. Remedial option four in the <br /> Plan (section 6.4.4, page 11) included soil vapor extraction and ozone sparging, <br /> but no discussion of SVE with the ozone injection was included in Section 6.5 <br /> (Evaluation of Remedial Action). The EHD is uncertain whether or not Thrifty Oil <br /> Company (TOC) plans on continuing to utilize SVE if ozone injection is approved <br /> for use. Please clarify this point. <br /> Through phone and electronic mail communications with TOC, EHD has learned <br /> that TOC has had success with ozone injection into ground water in southern <br /> California and was planning on using the technique at this site. EHD requested a <br /> technical justification for concluding that this remedial option would be effective <br /> for cleaning up the site. In the Plan, GHCI presented site-specific characteristics <br /> that fit the profile of sites suitable for ozone injection as detailed by the United <br /> States Environmental Protection Agency (USEPA) in Guidance Document UST <br />