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SEC www.secor.com <br /> INTESTIONAL 3017 Kilgore Road;Suite 100 <br /> - INCORPORATED Rancho Cordova,CA 95670 <br /> E 916-861-0400 TEL <br /> MD I� (�` �,I I \��I C�� 916-861-0430 FAX <br /> IN March 19, 2008 MAR 2 4 1008 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Michael Infurna <br /> San Joaquin County Environmental Health Department <br /> 304 East Weber Avenue, Third Floor f/6,6 <br /> Stockton, CA 95202 <br /> RE: Corrective Action Plan-Addendum <br /> 7-Eleven Store #14117 <br /> 2725 Country Club Road <br /> Stockton, California <br /> SECOR Project No.: 77EL.14117.08.0537 <br /> Dear Mr. Infurna: <br /> SECOR International Incorporated (SECOR), on behalf of 7-Eleven, Inc. (7-Eleven), <br /> presents this Corrective Action Plan (CAP) addendum for 7-Eleven Store Number 14117, <br /> located at 2725 Country Club Boulevard in Stockton, California (Figures 1 and 2). The CAP <br /> addendum was requested by the San Joaquin County Environmental Health Department <br /> (SJCEHD) in a letter dated January 4, 2008 (Attachment A). <br /> The January 4, 2008 letter from the SJCEHD indicated that the submitted CAP was not <br /> adequate as "No injection wells are proposed in the center of the plume, the UST pit..." and <br /> the CAP is "not targeting the center of the petroleum plume..." The SJCEHD further <br /> indicated that "The EHD will require at least one oxygen injection well to be installed in the <br /> core area of the plume, unless you can demonstrate that the remediation system as <br /> designed will effectively address the core of the plume." <br /> While acknowledging that an additional oxygen injection well installed in the UST pit would <br /> directly target the center of the remaining TBA plume, SECOR respectfully requests <br /> approval of the submitted CAP based on the following: <br /> • As outlined in the submitted CAP, SECOR proposed installation of the additional <br /> oxygen injection wells to target a well-defined and continuous sand unit located <br /> throughout the site at approximately 20-25 feet bgs. This continuous sand unit <br /> provides particularly ideal conditions to disperse the injected oxygen over a broad <br /> area. Based on experience injecting oxygen at other sites with similar lithologies, <br /> SECOR expects the combined radius of influence (ROI) for the proposed injection <br /> wells (particularly proposed injection wells 1-2 and 1-3) will encompass the entire <br /> current UST pit. <br /> It is also the experience of SECOR that oxygen injection into groundwater results in <br /> temporary groundwater mounding that can cause accelerated plume movement <br /> down-gradient. Given that the plume is currently laterally defined and stable (as <br /> VW-Eleven\7-11 Stores\14117\Reports\14117 CAP Addendum 3-19-08.doc <br />