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1.. <br /> San Joaquin County DIRECTOR <br /> Environmental Health Department <br /> Donna Heran, REHS <br /> Z 2� 600 East Main Street ASSISTANT DIRECTOR <br /> Laurie Cotulla, REHS <br /> �X Stockton, California 95202-3029 <br /> • �•.•'� PROGRAM COORDINATORS <br /> c' P Mike Huggins, REHS, RDI <br /> <iFo'Ra� Website: www.sjgov.org/ehd Margaret Lagorio, REHS <br /> Phone: (209)468-3420 Robert McClellon,REHS <br /> Jeff Carruesco, REHS, RDI <br /> Fax: (209) 464-0138 Kasey Foley,REHS <br /> 15 April 2009 <br /> Messrs. Robert Trommer, CHG, and Kirk Larson, PG <br /> State Water Resources Control Board <br /> Division of Financial Assistance <br /> 1001 1 Street <br /> Sacramento CA 95814 <br /> Subject: Annual Five-Year Review Update Letters <br /> San Joaquin County Environmental Health Department (EHD) has received and reviewed the <br /> following six Second review five-year review letters, each with your request to convey the <br /> agreement or disagreement of the EHD with the site-specific recommendations. The EHD <br /> comments for those sites are provided herein. The following comments pertain only to the <br /> recommendations; other information in the annual five-year review update letters that is <br /> incorrect or incomplete is noted only insofar as that information directly affects the <br /> recommendations. <br /> 5491 F Street, Banta, CA. <br /> The State Water Resources Control Board Cleanup Fund Five Year Review Committee <br /> (CUF) repeated recommendation in the Revised 5-Year Review Summary Report, dated <br /> 09 March 2009 was to consider the site for closure. The EHD does have the site under <br /> such consideration; however an issue related to detection of TPH-mo in a grab <br /> groundwater sample collected from off-site CPT-2 at 80 feet bsg near a property <br /> dependent on a domestic well has not been addressed as has been directed by EHD <br /> letter dated April 11, 2007; the EHD letters dated May 23, 2007 and March 10, 2008 <br /> commented on inadequate work plans to resolve this issue. The EHD will issue a new <br /> directive letter to try to clear up this point and to get a technical justification for site <br /> closure with benzene exceeding Region 2 ESLs for soil gas in one soil gas sample. <br /> 814 Charter Way, E., Stockton, CA. <br /> In the Revised 5-Year Review Summary Report, dated 03 March 2009, the CUF <br /> recommended closure consideration for this site. The EHD is moving toward this <br /> consideration, but has been dealing with increasing TPHg concentrations in monitoring <br /> well MW-208 and increasing MTBE concentrations in MW-109. Careful analysis of site <br /> data indicates that the TPHg is probably originating from the LOP site at 749 E. Charter <br /> Way and the MTBE is originating from the former UST system on the subject site. The <br /> MTBE concentrations have been steadily increasing, but at small increments. The EHD <br /> interpretation of the site data leads it to believe that the MTBE concentrations will soon <br /> level off and start to decline; to test this model the EHD needs a few more quarters of <br /> Annual 5-Year Review Comment Letter 041509.doc <br />