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j4 <br /> 08 June 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: EHD Comments on Annual Five-Year Review Various Sites <br /> The San Joaquin County Environmental Health Department (EHD) has received and reviewed <br /> your draft 5-year review updates on numerous sites and is providing comments on the following <br /> sites: <br /> • 517 W. Fremont Street, Stockton <br /> • 23569 S. Santa Fe Road, Escalon, <br /> • 2315 N. California St, Stockton; <br /> • 15 E. Grant Line Rd., Tracy <br /> EHD comments on other sites may be issued at a later time; the EHD comments on your draft <br /> reviews for the above listed sites are as follows: <br /> 517 W. Fremont Street - In your draft letter you note that last year's recommendation was to <br /> initiate groundwater remediation; this year you recommend site closure although no remediation <br /> has been conducted. The EHD had directed implementation of groundwater remediation and <br /> has set several dates, to no avail as of yet. The EHD had reduced the quarterly monitoring for <br /> all but three wells to biennial sampling and kept three wells on quarterly sampling; the EHD will <br /> direct further reduction of sampling of the three wells to semi-annual. <br /> The plume of impacted groundwater on the site is delineated, but the EHD believes the <br /> contaminant concentration in well MW-3 to be too high for closure consideration without <br /> remediation. Your letter cites the latest high TPHg and benzene concentrations on the site at <br /> 1,100 micrograms per Liter (Ng/L) and 280 pg/L, actually, benzene was present in MW-1 at <br /> 6,200 pg/L, and TPHg was present at 40,000 pg/L during the November 2008 monitoring event. <br /> The EHD would appreciate your reconsideration of the closure recommendation and will attempt <br /> to get the site into remediation this year and will further reduce the groundwater sampling <br /> requirements. <br /> 23569 S. Santa Fe Road — Your draft letter recommends site closure consideration. During the <br /> last monitoring event (September 2008), the TPHg and benzene concentrations in monitoring <br /> 5-Year Review Comment Letter 0609.doc <br />