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San Joaquin County <br /> �P.Q• �!.• <br /> DIRECTOR <br /> Environmental Environmental Health Department <br /> Donna Heran,RENS <br /> 1868 East Hazelton Avenue <br /> N { Stockton, California 95205-6232 PROGRAM COORDINATORS <br /> rN. Robert McClellon,RENS <br /> Jeff Carruesco,REHS,RDI <br /> C•' �� Website: www.s ov.or eLinsey Foley,REHS <br /> � 4 L l r p•R� �g / hd g Linda Turkatte,REHS <br /> k Phone: (209)468-3420 Rodney Estrada,REHS <br /> Fax: (209)464-0138 Adrienne Ellsaesser,REHS <br /> i <br /> May 21, 2013 <br /> Mr. Stephen Valentine <br /> Steve & Genes Service <br /> 6232 Hemet Avenue <br /> Stockton, CA 95207 <br /> Subject: Steve & Genes Service <br /> 2315 N. EI Dorado St. <br /> f <br /> Stockton, CA 95204 <br /> The San Joaquin County Environmental Health Department (EHD) has received and reviewed <br /> Second Semi-annual Groundwater Monitoring and Remedial Effectiveness (report), dated <br /> 30 October 2012, and Groundwater Plume Length Evaluation (PLE) dated 27 December 2012, <br /> both prepared by Geological Technics, Inc. (GTI, which is now Ground Zero Analysis, Inc. - <br /> GZA), your consultant for this site. <br /> The report presents the results of the groundwater monitoring event conducted 28 September <br /> 2012, a request for closure evaluation under the Low-threat Closure Policy (LTCP) recently <br /> adopted by the California State Water Resources Board (SWRCB), and included GTI's <br /> evaluation of the LTCP criteria for the site. The PLE was provided in response to an EHD email <br /> request dated 18 December 2012 to demonstrate that the length of the plume of impacted <br /> groundwater was less than 250 feet. Plume lengths in excess of 250 feet are limited to benzene <br /> concentrations equal to or less than 1000 micrograms per liter(erg/1) for closure under the LTCP. <br /> The EHD concurs with GTI's evaluation of the LTCP criteria with some minor exceptions: <br /> C Site fits the general criteria with the possible exception of criterion 'f' which requires that <br /> the secondary source be removed to the extent practicable; however as onsite dissolved <br /> plume concentrations have been declining the current state of remediation may be <br /> adequate. <br /> 0 Groundwater-specific case criterion (3) that the plume has been stable or decreasing for <br /> a minimum of 5 years may not be met in monitoring well MW-108, which has had a slow, <br /> steady increase, with some minor fluctuations, of total petroleum hydrocarbons <br /> quantified as gasoline (TPHg) and benzene concentrations from August 2004 to March <br /> 2012 (not sampled in September 2012); this suggests that some portion of the plume is <br /> still migrating. The EHD has evaluated the trend and the on-site concentration trends <br /> that could be expected to influence the down-gradient MWA 08 concentrations with time, <br /> and has concluded that the declining on-site mass is unlikely to maintain an increasing <br /> concentration trend in MW-108 and an expanding plume from that monitoring point. <br /> C Groundwater-specific case criteria (2) that the contaminant plume that exceeds water <br /> quality objectives is less than 250 feet in length. The groundwater data collected down- <br /> Comment Letter 0513 <br />