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San Joaquin County DIRECTOR <br /> Environmental Health Department Donna Heran, REHS <br /> �� OG <br /> 600 East Main Street ASSISTANT DIRECTOR <br /> Laurie Cotulla. REHS <br /> Stockton, California 95202-3029 <br /> _ PROGRAM COORDINATORS <br /> _ - Margaret Lagorio, REHS <br /> %1 Rx4vP Website: www.sjgov.org/ehd Robert McClellon, REHS <br /> Phone: (209) 468-3420 .teff Carruesco, RENS. RDI <br /> Fax: (209) 464-0138 Kasey Foley, REHS <br /> 15 September 2009 <br /> Mr. Dan Silva <br /> Ms. Tina Mayhew <br /> West Clay Properties <br /> Post Office Box 6152 <br /> Stockton., California 95206 <br /> Subject: West Clay Properties <br /> 639 West Clay Street <br /> Stockton, California 9520 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed your letter <br /> dated 17 August 2009, Subject: West Clay Property, prepared and submitted by your consultant <br /> Advanced GeoEnvironmental, Inc. (AGE) regarding the above-referenced site. In your letter, <br /> AGE raises several issues regarding your site progress that are herein addressed, although not <br /> necessarily in the order presented in your letter. <br /> Toward the close of the letter AGE notes that Resolution 2009-0042, recently adopted by the <br /> State Water Quality Control Board (SWQCB) requires the regulatory agencies overseeing sites <br /> like yours to: <br /> • "...review all cases for closure prior (to issuing) new directives for corrective action", and <br /> • ...determine "specific environmental benefits from any additional work...performed at the <br /> site." <br /> Regarding the first bulleted point, the EHD completed its closure review of all the San Joaquin <br /> County Local Oversight Program sites on 18 August 2009, and can issue appropriate directives <br /> under the recently adopted Resolution. The EHD directive letter of 19 May 2009 was issued the <br /> same day as the Resolution was adopted and was not really a new directive, but a reiteration of <br /> the general directive to delineate the vertical and lateral extents of impacted media issued by <br /> EHD by letters dated 04 February 1999, 01 August 2001 and 16 February 2005. The <br /> outstanding directives for additional work on your site include completing the dissolved plume <br /> assessments and evaluating remedial technologies to address impacted soil and groundwater <br /> on your site; both have environmental benefits. <br /> Completion of the plume assessment is required for site closure consideration and to properly <br /> manage the plumes and the risk or hazards they present. The groundwater is considered to be <br /> of beneficial use and must be restored to its natural state prior to use. Selecting and <br /> implementing an appropriate, cost-effective groundwater remediation technology will return the <br /> Comment Letter 0909 <br />