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San Joaquin County DIRECTOR <br /> Donna Heran,RENS <br /> o <br /> a°"'" Environmental Health Department I. ����'`' �' I� ASSISTANT DiRFcroR <br /> 600 East Main Street <br /> Laurie Cotulla,REHS <br /> zNX Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> • a Mike Huggins, REHS, RD! <br /> Website: www.S1gov.or 1 hd Margaret Lagorio, REHS <br /> g Robert McCleUon,REHS <br /> Phone: (209) 468-3420 .left Carruesco, REHS, RDI <br /> Fax: (209) 464-0138 Kasey Foley, REHS <br /> 12 June 2009 <br /> Messrs. Robert Trommer, CHG, and Kirk Larson, PG <br /> State Water Resources Contra[ Board <br /> Division of Financial Assistance <br /> 1001 1 Street <br /> Sacramento CA 95814 <br /> Subject: EHD Comments on Annual Five-Year Rteview Various Sites <br /> The San Joaquin County Environmental Health Depa ment (EHD) has received and reviewed <br /> your draft 5-year review updates on numerous sites an J is providing comments on the following <br /> sites: <br /> • 1301 W. Kettleman Lane, Lodi <br /> • 466 Moffat Boulevard, Manteca, <br /> 0 715 Hunter Street, Stockton, <br /> EHD comments on other sites may be issued at a later time; the EHD comments on the above <br /> listed sites are as follows: <br /> 1301 W. Kettleman Lane - In your draft letter you state that the current remediation techniques <br /> are no longer effective and recommend that the EHD direct the responsible Party (RP) to <br /> assess alternate remedial technologies and implem nt a cost effective approach that will <br /> achieve Water Quality Goals (WQOs) in a timely ma ner. The EHD does not agree with the <br /> evaluation or recommendation. SVE has been employed on the site since October 2006 and <br /> GWE since September 2008. The SVE and air stripper treatment system has recently been <br /> converted from a catalytic oxidize to granular activated carbon to reduce costs and increase <br /> efficiency. Since September 2008, the GWE system is calculated to have removed 97 pounds of <br /> MTBE, 37 pounds during the last quarter, While the returns are diminishing, the EHD believes <br /> that the removal rate is beneficial for the time being. The EHD notes that the concentrations of <br /> MTBE and TPHg in groundwater have declined an order of magnitude since the GWE went on <br /> line. <br /> The EHD will issue a directive letter to the RP to evaluate the need for continued SVE <br /> operation, although the consultant did recommend continued operation in the first quarterly <br /> report for 2009; the EHD will also reduce the groundwE ter sampling and analysis requirements <br /> and approve the consultants recommendation to complete the lateral assessment of impacted <br /> groundwater. <br /> 466 Moffat Boulevard — Your draft letter recommends he EHD consider the site for closure. By <br /> letter dated 27 May 2009, the EHD has requested a site closure summary report from the RP. <br /> 5-Year Review Comment Letter D 0609.doc <br />