SITE INFORMATION AND CORRESPONDENCE_FILE 1

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San Joaquin County Environmental Health Department DIRECTOR �0`fit cp Donna Heran, REHS 600 East Main Street a. 1 �a -� PROGRAM COORDINATORS W :< Stockton, California 95202-3029 Margaret Lagorio,REHS .. Robert McClellon,REHS Jeff Carruesco,REHS,RDI OgCFOR��P Website: www.sjgov.org/ehd Kasey Foley,REHS Phone: (209)468-3420 Fax: (209) 464-0138 October 8, 2009 Mr. Wesley Parkinson Parkinson's 1-5 ARCO Service Station 3250 West Hammer Lane Stockton, California 95209 Subject: Parkinson's 1-5 ARCO Service Station 3250 West Hammer Lane Stockton, California 95209 By letter dated July 27, 2009, Stratus Environmental, Inc. (Stratus) responded to the San Joaquin County Environmental Health Department (EHD) letter dated February 27, 2009, recommending that you request access to collect groundwater samples for metal analysis from monitoring wells screened in the same depth interval as the ozone injection wells and down gradient of the injection well(s) at the adjacent ConocoPhillips 76 (former BP) Service Station No. 11193 (BP/CP) at 3202 West Hammer Lane, Stockton; and compare hydrogeological characteristics between the BP/CP and your site. In the correspondence, Stratus included boring logs and cross sections to support the position that hydrogeologic similarities exist between the adjoining BP/CP and the above-referenced site; however, instead of complying with the recommendation by the EHD to request access to collect groundwater samples at the BP/CP site to demonstrate that groundwater quality had not been adversely affected by ozone injection (and possibly avoid implementing the EHD- approved ozone bench-scale study), Stratus responded with the following comments: • Ozone has been injected at the BP/CP site for more than four years; however, the responsible parties, large petrochemical companies with vast resources, have not been required to collect and analyze groundwater for adverse affects to water quality. In contrast, Mr. Parkinson, responsible party for the above-referenced site and a small business owner with limited resources, is being asked to meet a more stringent regulatory standard than BP/CP. • Considering the length of time that ozone injection has taken place at the BP/CP site, Stratus is concerned that collecting a representative background groundwater sample may be problematic. • If analytical results demonstrate that water quality has been adversely affected by ozone injection, it is best that BP/CP address the adverse effects, if any, and provide this information to Mr. Parkinson.