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CAP Addendum:Former Fue Station, 7500 West Eleventh Street, Tracy, C)1-W Page I <br /> 1.0 PURPOSE <br /> This document is an addendum to the Corrective Action Plan for the Oak Walk <br /> Redevelopment Site (The San Joaquin Company Inc. 2007). It has been prepared in <br /> response to a directive issued in a letter dated August 2, 2007 by the San Joaquin County <br /> Environmental Health Department (SJCEHD) (San Joaquin County Environmental <br /> Health Department 2007). This addendum addresses technical comments in the SJCEHD <br /> letter regarding the Corrective Action Plan. A copy of the SJCEHD letter is included as <br /> Appendix A of this document. <br /> 2.0 RESPONSE TO TECHNICAL COMMENTS <br /> Technical comments for which responses were requested by the SJCEHD in its letter are <br /> addressed below. <br /> 2.1 Recoverable Volume of LNAPL <br /> In December 2003, SJC estimated the extractable volume of light non-aqueous phase <br /> liquid (LNAPL) present in the subsurface beneath the 7500 West Eleventh Street Site <br /> due to the discharge of gasoline and diesel fuels to be on the order of 1,000 - 8000 gals. <br /> Since that estimate was made, additional groundwater-quality monitoring wells have <br /> been installed and the groundwater-quality monitoring program being conducted at the <br /> site has generated additional data regarding the distribution and thickness of LNAPL. <br /> 2.1.1 Apparent Thickness of LNAPL <br /> Table 1 shows the thickness of floating product (LNAPL) measured in eight wells, the <br /> locations of which are shown on Figure 1. No floating product has been detected in any <br /> well other than Monitoring Well MW-7. In that well, the apparent thickness of floating <br /> product over the period of April 2002 through November 2003 ranged from 0.13 to 0.58 <br /> ft. However, those apparent thicknesses have reduced following the periodic purging of <br /> LNAPL from that well that was initiated in November 2003. Over the 16-month period <br /> from March 29, 2006 through July 30, 2007, which period included the last four semi- 'r <br /> annual measurements of floating product thickness, the maximum apparent thickness <br /> measured was 0.05 ft. That value will be used in making a new estimate in the total <br /> extractable volume of LNAPL in the subsurface. <br /> 2.1.2 Thickness of LNAPL in Formation <br /> As was described in the Corrective Action Plan (CAP), the thickness of floating product <br /> measured in a well is greater than the actual thickness of LNAPL in the surrounding <br /> formation. Numerous methods are available to estimate the actual thickness of floating <br /> product in the formation compared to the thickness measured in the monitoring well. <br /> However, all of the methods have serious limitations and frequently provide highly <br /> inaccurate results. In addition, they frequently break down when small measured <br /> thicknesses of LNAPL are.considered. For example, the method developed by Hall, et al <br />