SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Response to SJ EHD's 8-19-08 Letter Joe's Travel Plaza 15600 S. Harlan Road Excerpts from SJCEHD's August 19,2008 letter to Mr.Dhoot are provided below in bold font;Mr. Dhoot's numbered responses and general information regarding each subject fallow in regular font. The San Joaquin County Environmental Health Department (EHD) has reviewed the letter regarding "SWRCB's Recommendation for Regulatory Case Closure" dated July 3, 2008, prepared by Stratus Environmental,Inc. (your consultant) for the above subject site and provides the following comments. The EBD received the "Preliminary 5-Year Review Summary Report" prepared by the State Water Resources Control Board Cleanup Fund (SWR!CB-CUF) staff on April29. 2008 and responded to the SWRCB-CUF by electronic mail on May 1, 2008. The EHD response included corrections to the case information on the number, size and contents of UST's that had been removed from the site in 1998, number, size and contents of active USTs at the site and stated that there were also active aboveground storage tanks at the site. The response also pointed out that the groundwater flow at the site was initially predominantly northeast and that it had recently changed to the northwest, that the groundwater contamination had spread over the entire 3.77 acre Storage Pro property to the north of the site,' that water samples from newly installed monitoring wells placed northwest and north of the site had contamination in them,that the newly installed monitoring wells to the northwest could no longer be found, that the plume of contaminated groundwater was undefined to the northwest and vertically and that because of these facts, the plume was not considered to be shrinking or immobile.¢ ' There is no evidence that contamination has spread over the entire 3.77 acre Storage Pro property to the north of the site. It is assumed throughout this response that EHD's reference to "contamination" is in reference to MTBE only. At most, contamination from Joe's Travel Plaza has spread over only the southern portion of the Storage Pro property. Analytical results from well MWO-1 (located in the northeast;portion of the 3.77 acre Storage Pro parcel) indicate the MTBE plume does not reach this portion of the parcel. At most,,the MTBE plume (in excess of the secondary MCL of 5.0 �tglL) covers approximately 60% of this parcel(based on September 2008 analytical data). 2 These wells have now been found and sampled and the results reported in the Quarterly Groundwater Monitoring;Report, 3rd Quarter 2008. 3 There is no evidence to support the contention that the plume has not been vertically defined. The deepest groundwater zone in which contaminants have been detected at the site is Zone C. CPT and , grab groundwater samples collected at depths 5-10 feet beneath the C-Zone indicated no concentrations of petroleum hydrocarbons. Further, wells MW-12C and MW-13C are adjacent to the Zone A & B wells with the highest contaminant concentrations, which is where elevated contaminant levels in all of the zones would be expected to occur, thus there is nothing to suggest that Zone C contaminants are likely to have higher concentrations elsewhere at the site. Considering MTBE is on-detect in both C I