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ii <br /> M San Joaquin County DIRECTOR <br /> Environmental Health Department Donna Heran, REHS <br /> ASSISTANT DIRECTOR <br /> e: 600 East Main Street Laurie Cotulla, REHS <br /> N: Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> - .-- Carl Borgman, REHS <br /> Website: wwW. OV. Or ebd Mike Huggins, REHS, RDI <br /> S <br /> gtik6wi J J9 Margaret Lagorio, REHS <br /> Phone: (209) 468-3420 Robert McClellan, REHS <br /> i Fax: (209) 464=0138 Jeff Carruesco, REHS, RDI <br /> 30 June 2008 Kasey Foley, REHS <br /> l <br /> Messrs . Robert Trommer, CHG , and Kirk Larson , PG <br /> State Water Resources Control Board <br /> Division of Financial Assistance <br /> 1001 1 Street <br /> Sacramento CA 95814 <br /> Subject: Preliminary Five-Year Review Letters <br /> San Joaquin County Environmental Health Department ( EHD) has received and <br /> reviewed numerous preliminary five-year review letters each with your request to convey <br /> the EHD's agreement or disagreement with the site-specific recommendations . The EHD <br /> comments for a selection of those sites are provided herein, sites not noted in this letter <br /> will be addressed in the near future. Due to the high volume of preliminary five-year <br /> review letters and the ongoing workload and commitments of the EHD , the following <br /> comments pertain only to the recommendations; other information in the five-year letters <br /> that is incorrect or incomplete is noted only insofar as that information directly affects the <br /> recommendations . <br /> 1901 EI Dorado Street, S. <br /> • The State Water Resources Control Board Cleanup Fund Five Year Review <br /> Committee (CUF) recommends that the EHD direct the Responsible Party (RP) <br /> to implement soil vapor extraction (SVE) and assess the efficacy of (insitu) air <br /> sparging ( IAS) to achieve Water Quality Objectives (WQOs) more rapidly. The <br /> EHD partially agrees with this recommendation ; a significant clay interval in the <br /> area of the water table may impede effective recovery of air and stripped <br /> hydrocarbons from IAS. The consultant has concluded that the site is not suitable <br /> for groundwater extraction (GWE) , but has recommended dual phase extraction <br /> (DPE). The EHD has directed submittal of a work plan for a DPE pilot test by 07 <br /> July 2008. <br /> 2404 Pacific Avenue <br /> • The CUF recommends that the EHD direct the RP to assess the efficacy of the <br /> current groundwater treatment system and modify it as necessary to achieve <br /> WQOs in a timely manner. The SVE/IAS operation was terminated in November <br /> 2006 by the consultant; dissolved contaminant concentrations rebounded after <br /> five months of non-operation . The EHD directed rebound testing , the consultant <br /> disagreed with rebound testing and proposed reinitiating SVE/IAS operation and <br /> installation of additional SVE wells; the EHD is not satisfied with the technical <br /> 5-Year Review Comment Letter 063008.doc <br />