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San Joaquin County Environmental Health Department 600 East Main Street Stockton, California 95202-3029 Website: WWW.Sjgov.org/ehd Phone: (209) 468-3420 Fax: (209)464=0138 12 June 2009 Messrs. Robert Trommer, CHG, and Kirk Larson, PG State Water Resources Control Board Division of Financial Assistance 1001 1 Street Sacramento CA 95814 Subject: EHD Comments on Annual Five -Year Review Various Sites DIRECTOR Donna Heran. REHS ASSISTANT DIRECTOR Laurie Cotulla, REHS PROGRAM COORDINATORS Mike Huggins, REHS, RDI Margaret Lagorio, REHS Robert McClellon, REHS JefF Carruesco, REHS, RDI Kasey Foley, REHS The San Joaquin County Environmental Health Department (EHD) has received and reviewed your draft 5 -year review updates on numerous sites and is providing comments on the following sites: • 1201 S. Center Street, Stockton • 300 S. California Street, Stockton, • 1250 N. Wilson Way, Stockton, • 2662 N. Wilson Way, Stockton; • 2151 Country Club Boulevard, Stockton EHD comments on other sites may be issued at a later time; the EHD comments on the above listed sites are as follows: 1201 S. Center Street - In your draft letter you recommend that the EHD direct the responsible Party (RP) to reduce monitoring and focus remaining resources on remediation. The EHD agrees with these recommendations; a directive letter is in preparation significantly reducing the sampling/analytical requirements. The responsible party and his consultant state that the delay n reimbursements from the State Board Cleanup Fund (CUF) is impeding their ability to start remediation. SVE wells have been installed, but trenching is needed to plumb them to an SVE unit. The EHD s scheduling a meeting with the RP to set timetables for bringing his site into remediation. 300 S. California Street —Your draft letter recommends the EHD direct the RP to assess groundwater remedial technologies to more rapidly achieve water quality goals (WQOs). The EHD has met with the RP and their consultant; both claim economic hardship due to the delay n reimbursements from the CUF, which is impeding their ability to maintain the current system. The groundwater extraction rate has been maximized, but further increase in the rate will exceed the RP's disposal permit and significantly increase disposal costs. 1250 S. Wilson Way —Your draft letter continues to recommend the EHD to direct the RP to assess remedial groundwater technologies and implement active remediation to achieve WQOs 5 -Year Review Comment Letter B 0609.doc