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ry <br /> d San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> ? ' •--_• ' 9 Donna Heran, REHS <br /> Q % 1868 East Hazelton Avenue <br /> Stockton , California 95205-6232 PROGRAM COORDINATORS <br /> Robert McClellan, REHS <br /> - Jeff Carrueseo, REHS, RDI <br /> c• . . �._• . . 'p Kasey Foley, REHS <br /> q<ikoR�� Website: www.sjgov.Org/ehd <br /> Linda Turkatte, REHS <br /> Phone: (209) 468-3420 Rodney Estrada, REHS <br /> Fax: (209) 464-0138 Adrienne Ellsaesser, REHS <br /> October 14, 2013 <br /> Ms. Marion Canepa <br /> Canepa's Car Wash <br /> 1536 North Hunter <br /> Stockton, California 95204-5915 <br /> Subject: Canepa's Car Wash <br /> 6230 Pacific Avenue <br /> Stockton, California 95207-3712 <br /> Dear Ms. Canepa: <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Feasibility <br /> Study Report (report) dated 13 August 2013, prepared and submitted by your consulting firm , <br /> Advanced GeoEnvironmental Inc. (AGE) , on your behalf for the above-referenced site. In the <br /> report, AGE compared two remedial alternatives, groundwater extraction and treatment; and in- <br /> situ chemical oxidation with in-situ bioremediation . As a result, AGE has recommended that a <br /> work plan be submitted to conduct an in-situ chemical oxidation pilot test to determine the <br /> effects of a chemical oxidant on the subsurface contaminants of concern and the formation of <br /> harmful bi-products such as hexavalent chromium . <br /> Concerns the EHD has about the implementation of in-situ chemical oxidation include: <br /> • The proposed cost estimates to submit a pilot study work plan, procure permits and <br /> conduct the pilot study fieldwork injections of chemical oxidants ranged between <br /> $50, 000 and $60, 000; <br /> • The proposed cost estimates to submit a remedial action work plan and apply the in-situ <br /> chemical oxidant, RegenOxTM or equivalent media, followed by "enhanced <br /> bioremediation applications" of ORC-ATm, ranged between $150, 000 and $200, 000; and <br /> • The annual groundwater sampling program to monitor the effects of RegenOxTM and <br /> ORC-ATm quarterly was estimated at between $ 16, 000 and $20, 000, bringing the total <br /> estimated cost between $216, 000 and $280, 000 for implementation of in-situ chemical <br /> oxidation and one year of monitoring; and <br /> • The lack of technical justification , based on site characteristics and contaminant <br /> distribution, which favors the proposed in-situ chemical oxidation/bioremediation method <br /> over other remedial technologies. <br />