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San Joaquin County DIRECTOR <br /> V'" Donna Heran, RENS <br /> Environmental Health Department <br /> OG M ASSISTANT DIRECTOR <br /> 2. t •2 sOO East Main Street Laurie Cotulla,REHS <br /> { Stockton, California 95202-3029 <br /> PROGRAM COORDINATORS <br /> • Carl Borgman,REHS <br /> 6 p Mike Huggins,REHS, RDI <br /> o:Rd� Website: www.Sjgov.org/ehd Margaret Lagorio,REHS <br /> Phone: (209)468-3420 Robert McClellon, REHS <br /> Fax: (209)464-0138 Jeff Carruesco, REHS,RDI <br /> Kasey Foley,REHS <br /> 7-ELEVEN INC JAN 0 4 <br /> KEN HILLIARD <br /> PO BOX 711 <br /> DALLAS TX 75221-0711 <br /> .RE: 7-Eleven Store#14117 Site Code:1073 <br /> 2725 Country Club Blvd. LOP-RO#:013 <br /> Stockton, CA.95204 Global ID#: T0607700458 <br /> The San Joaquin County Environmental Health Department(EHD)has reviewed Corrective Action <br /> Plan(CAP) prepared by Secor International for the above referenced site and offers the following <br /> comments. The CAP calls for the injection of pressurized oxygen gas into the shallow ground water <br /> beneath the site through four additional injection wells. This remedial alternative proposal received its <br /> final approval by the EHD on June 15, 2007 after the Central Valley Regional Water Quality Control <br /> Board(CVRWQCB)stated that the waste discharge requirements(WDR)were not required. <br /> Although the plume of petroleum contamination has been reducing in size as noted in the CAP, it is <br /> still centered on the underground storage tank (UST)area/pit and the contaminant concentrations are <br /> too high to be left in place; therefore some active remediation would be appropriate. <br /> The CAP is not adequate as submitted. [H&S Code 25296.10(c)(3)]. The four proposed oxygen <br /> injection well installations are shown as being placed to the southwest, the south, and to the east of <br /> the UST area. No injection wells are proposed in the center of the plume, the UST pit,where two <br /> conductor casings were placed during the UST installation in 1998. The purpose of these conductor <br /> casings was to provide safe drilling locations between the USTs for future remediation wells and/or <br /> confirmation soil borings. By not targeting the center of the petroleum plume, the EHD considers the <br /> CAP inadequate. The EHD will require at least one oxygen injection well to be installed in the core <br /> area of the plume, unless you can demonstrate that the remediation system as designed will <br /> effectively address the core of the.plume. <br /> Please submit a revised CAP that addresses the items of concern noted in this correspondence. <br /> Thank you for your patience and cooperation during this process. You may contact Michael Infurna at <br /> (209)468-3454 if you have any questions. <br /> z <br /> Donna Heran, REHS, Director <br /> Environmental <br /> Health Department <br /> Michael Infurna, REHS Nuel C. Henderson Jr., PG <br /> LOP-Unit IV Engineering Geologist <br /> LOP/Site Mitigation Unit IV <br /> cc: CVRWQCB-James Barton, Sacramento. <br /> Secor-Damon Brown, 3017 Kilgore Rd.,#100 Rancho Cordova 95670 <br /> SWRCB-Clean Up Fund-Mark Owens, Sacramento. <br />