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` M • ENVIRONMENTAL HEALTH DEPARTMENT SAN JOAQUIN COUNTY Unit Supervisors G Donna K Heran,R E H S 304 East Weber Avenue, Third Floor Cart Borgman,R E H S Director Mike Huggins,R E H S,R D i • Al Olsen,R E H S Stockton, California 95202-2708 Douglas W Wilson,R.E H S �P Program Manager Telephone (209)468-3420 Margaret Lagono,R E H S Laurie A Cotulla,R E H S Robert McClellon,R E N S Program Manages FaX (209) 464-0138 Mark Barcellos,R E H S KEN HILLIARD SES 2 2 2003n FE�(C-9 7�Tr 7r% , 7-ELEVEN INC U PO BOX 711 C2 G � L 3 0 3 DALLAS TX 75221-0711 RE 7-Eleven Store#32262 SITE CODE 1505 2360 West Grant tine Road Tracy CA 55376 San Joaquin County Environmental Health Department (SJCIEHD) has received and reviewed "Addendum to Soil and Groundwater Assessment Work Plan" dated September 10, 2003, prepared and submitted on your behalf by SECOR International Inc (SECOR) and provides the following comments Analysis of groundwater samples collected from two wells, T-1 and T-2, built into the tank . pit backfill at this site yielded results of 110,000 and 510,000 parts per billion (ppb) of methyl tertiary butyl ether(MtBE), 350 and 1,500 ppb tertiary amyl methyl ether and 23,000 and 79,000 ppb tertiary butanol, respectively Depth to water in these wells at the time of sampling was recorded at 11 67 and 11 17 feet below surface grade (bsg), respectively The high concentrations of contamination in combination with the relatively shallow depth to groundwater of the area make this a high priority site SJCIEHD requested an addendum to the previously submitted "Soil and Groundwater Assessment Work Plan", dated August 12, 2003, which had failed to include a proposal for a vertical investigation of your site as directed by SJCIEHD correspondence dated August 22, 2003 in response, SECOR ventured the "professional opinion that installation of a deep depth discrete well in the initial phase of assessment of the shallow groundwater conditions should be deferred until the distribution of the dissolved plume, flow direction, and gradient in the shallow groundwater at the site have been determined " SECOR proposes to submit a work plan to define the vertical extent of dissolved gasoline range petroleum hydrocarbons after two or three quarters of monitoring This is not acceptable and fails to comply with the clear and justified directives of SJCIEHD Please note that SJCIEHD did not direct the installation of deep, depth discrete monitoring wells as implied by the September 10, 2003 addendum SJCIEHD had directed, per the California Code of Regulations Title 23, Division 3, Chapter 16, Article 14 Section 2725, an investigation of the vertical and lateral extent of the documented contamination at your site SECOR provided no basis In scientific principles or site conditions that justifies their professional opinion SJCIEHD is not aware of any research that demonstrates any relationship between the shallow ground water conditions that SECOR is willing to . investigate and determination of a need for vertical delineation of a dissolved ME plume As a high priority ME site there is no luxury of time that allows for two or three quarters of monitoring that can provide no foreseeable basis to decide that vertical delineation should be investigated, an investigation objective already required by state regulations