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r <br /> !Ms <br /> ENVIRONMENTAL HEALTH 11EPARTMENT <br /> pe ts, SAN JOAQUIN COUNT <br /> 2 <br /> Program Coordinators <br /> Donna K.Reran R.E.H.S. � <br /> < 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. <br /> Director <br /> Laurie A. Catalla,R.E.H.S. Stockton,California 95202-2708 Mike Huggins,R.E:H.S.,R.D.I. <br /> ::- '� Assistant Director Telephone:(209)468-3420 Margaret Lagorio,R.E,H.S. <br /> �£rF'o�*"' Robert McClellon,RX.H.S. <br /> Fax; (209)464-0138 Jeff Carrueseo, R.E.H.S. <br /> Website www.sjgov.org/ehd/ Kasey Foley,R.E.H.S. <br /> KASHMIR SINGH & DALWINDER DHOOT UAN Q 4x',60 <br /> 15600 S HARLAN ROAD <br /> LATHROP CA 95330 <br /> RE: Joe's Place SITE CODE: 231585 <br /> 15600 Harlan Road <br /> Lathrop, Ca <br /> San Joaquin County Environmental Health Department (EHD) has reviewed the "Interim <br /> Remedial Action Plan" (TRAP)dated November 26, 2006, prepared by Environmental <br /> Remediation Group (ERG)for the above referenced site. EHD provides the following <br /> comments on the TRAP. <br /> EHD supports the use of groundwater extraction to control the migration of the MTBE <br /> groundwater contamination. However, in a letter dated March 16, 2005, EHD did not <br /> approve an IRAP dated February 2, 2005, prepared by Stratus Environmental Inc. that <br /> proposed extracting groundwater from MW2, MW3 and MWO-1X because the <br /> estimated cost for installation and operation of the groundwater extraction system for <br /> one year was $120,000 and justification for the continuous groundwater extraction <br /> system was not provided. SECOR performed step-draw down and constant-discharge <br /> pumping tests in December 2005 and concluded that groundwater extraction was not <br /> cost-effective. The IRAP prepared by ERG does not provide cost estimates for the work <br /> proposed so cost-effectiveness still has to be evaluated. <br /> The TRAP prepared by ERG states that applicable clean-up goals for this site haven't <br /> been established and discusses guidance levels established by regulatory agencies. It <br /> discusses the Environmental Screening Level established by the San Francisco Bay <br /> Regional Water Quality Control Board for MTBE in shallow or deep soil where <br /> groundwater is not>a current or potential source of drinking water and the United <br /> States Environmental Protection Agency's Preliminary Remediation Goal for MTBE in <br /> tap water. All groundwater in San Joaquin County is designated to have current or <br /> potential beneficial use. The;California Code of Regulations, Title 23, Division 3, <br /> Chapter 16, Section 2725(g)(1) requires cleanup levels for groundwater with current or <br /> potential beneficial use to achieve numerical objectives designated in the water quality <br /> control plans. The water quality objective for all ground waters of the San Joaquin River <br /> Basin is to restore groundwater to background (no detection of MTBE at appropriate <br /> detection limit) or at a minimum that it not contain MTBE in excess of the maximum <br /> contaminant level (5 parts per billion). <br /> The [RAP prepared by ERG proposes to extract groundwater from MWO-1X and MW3 <br /> at a pump rate of`5 gallons per minute (14,400 gallons per day), store it in a 5000-gallon <br /> tank, treat the extracted water with carbon and discharge it to the City of Lathrop storm <br /> drain. The Central Valley Regional Water Quality Control Board (CVRWQCB) has <br /> informed END that the City of Lathrop has an Industrial Storm Water permit, so disposal <br /> to the City of Lathrop storm drain will require approval from the City of Lathrop and <br />