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t <br /> San Joaquin County DIRECTOR <br /> Donna Heran,REHS <br /> Environmental Health Department ASSISTANT DIRECTOR <br /> 600 East Main Street Laurie cotuna,REHS <br /> U): r Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> +' * Carl Borgman,REHS <br /> Website: Www S" ov"ot hd Mike Huggins,REHS,RDI <br /> 1 �eMargaretLagorlo,REHS <br /> Phone (209)46$-3420 Robert McClellon,REHS <br /> Fax: (209)464-0138 Jeff Carruesco,REHS,RDI <br /> Kasey Foley,REHS <br /> August 19, 2008 <br /> Dalwinder Dhoot Kashmir Singh Dhoot <br /> 15600 S. Harlan Road 5300 Penny Lane <br /> Lathrop, CA 95330 Pleasanton, CA 94588 <br /> Subject: Joe's Place Site Cade: 231585 <br /> 15500 Harlan Road <br /> Lathrop, CA <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed the letter <br /> regarding "SWRCB's Recommendation for Regulatory Case Closure" dated July 3, 2008, <br /> prepared by Stratus Environmental, Inc. (your consultant) for the above subject site and <br /> provides the following comments. <br /> The EHD received the "Preliminary 5-Year Review Summary Report" prepared by the State <br /> Water Resources Control Board Cleanup Fund (SiNRCB-CUF) staff on April 29, 2008 and <br /> responded to the SWRCB-CUF by electronic mail on May 1, 2008. The EHD response <br /> included corrections to the case information on the number, size and contents of underground <br /> storage tanks (UST's)that had been removed from the site in 1998, number, size and contents <br /> of active UST's at the site and stated that there were also active=above ground storage tanks at <br /> the site. The response also pointed out that the groundwater flow at the site was initially <br /> predominantly northeast and that it had recently changed to the northwest, that the groundwater <br /> Contamination had spread over the entire 3.77 acre Storage Pro property to the north of the <br /> site, that water samples from newly installed monitoring wells placed northwest and north of the <br /> site had contamination in them, that the newly installed monitoring wells to the northwest could <br /> no longer be found, that the plume of contaminated groundwater was undefined to the <br /> northwest and vertically and that because of these facts the plume was not considered to be <br /> shrinking or immobile: <br /> The SWRCB-CUF letter recommends the site be considered for regulatory closure. The EHD <br /> does not believe that sufficient data and information has been provided to justify a <br /> determination of "no further action is required" (closure) for this site. It must be demonstrated <br /> that the contaminant plume is defined, stable and contaminant concentrations are declining. <br /> The groundwater flow direction changed from predominantly to the northeast to the northwest. <br /> Contaminant concentrations increased in water samples from MW 13AB, began being detected <br /> in water samples from MWt03 and have been detected in water samples from MW15A. This <br /> demonstrates that the contaminant plume is mobile and undefined. <br />