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San Joaquin County <br />Environmental Health Department <br />600 East Main Street <br />Stockton, California 95202-3029 <br />DIRECTOR <br />Donna Heran, REHS <br />ASSISTANT DIRECTOR <br />Laurie Cotulla, REHS <br />PROGRAM COORDINATORS <br />Carl Borgman, REHS <br />Mike Huggins, REHS, RDI <br />Margaret Lagorio, REHS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Kasey Foley, REHS <br />Website: www.sjgov.org/ehd <br />Phone: (209) 468-3420 <br />Fax: (209) 464-0138 <br />25 November 2008 <br /> <br />Gurpal S. Sidhu <br />5410 Staples Way <br />Linden CA 95236-9556 <br />RE: Waterloo Food & Fuel <br />3032 E. Waterloo Rd <br />Stockton, CA 95205 <br />The San Joaquin County Environmental Health Department (EHD) has received <br />information that you and/or your consultant, Advanced GeoEnvironmental, Inc. <br />(AGEI) has applied to suspend or terminate your permit to discharge treated <br />groundwater to the City of Stockton sewerage system. This implies that you and/or <br />your consultant intend to terminate operation of the groundwater extraction (GWE) <br />system currently utilized to reduce the mass of fuel hydrocarbons and additives <br />impacting groundwater on your site and to exert some hydraulic control on the <br />vertical and lateral migration of the impacted groundwater. Neither you nor AGEI <br />have recommended to the EHD termination of the GWE system operation, nor has a <br />suitable alternative interim remediation technology been proposed. While this letter <br />was in preparation, the EHD received confirmation that your GWE system is not in <br />operation. <br />AGEI reports that as of June 2008, your groundwater extraction system had <br />recovered an estimated 10,534 pounds of total petroleum hydrocarbons quantified <br />as gasoline (TPHg), 583 pounds of benzene and 1,132 pounds of methyl tert-butyl <br />ether (MTBE); the soil vapor extraction (SVE) system, in operation for a much <br />shorter period of time, had extracted an estimated 23,650 pounds of TPHg. To the <br />best of the knowledge of the EHD, no other GWE system in this county has matched <br />this performance, yet the contaminant concentrations in impacted groundwater <br />remain extremely high. Your plume of impacted groundwater has migrated off-site, <br />and is believed to extend at least 500 feet down-gradient from your UST area to the <br />3012 E. Waterloo Road site, and may extend nearly 1,000 feet down-gradient to the <br />Western Farm Service well (MW-20) in Gilchrist Avenue. Approximately 1,000 feet <br />further down-gradient from the Western Farm Service monitoring well is a municipal <br />water supply well; given the extremely large mass of contaminants known to be in <br />groundwater on your site and the possibility that your plume of impacted groundwater <br />already extends nearly 1000 feet in the down-gradient direction, the EHD cannot <br />dismiss the potential for your plume to impact the municipal well and cannot permit <br />Directive Letter 1108