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Upgradient Environmental Cc.-;sultants June 20,2003 Mr.Michael Infurna PHS/EHD P.O.Box 2009 �� 200912 Stockton,CA 95201 Subject: Report Transmittal and Request for Closure Kwikee Food Mart nr 2081 Country Club Boulevard Dear Mr. Infurna: c_ r._ We are pleased to forward herewith the monitoring report for the second quarter of 2003 for Kwikee Food Mart.Monitoring was performed on May 22,and four wells were sampled, in accordance with your letter of si February 27. -We hope you have now had the opportunity to review our Site Conceptual Model and Fourth Quarter 2002 Report(December 2002)as well as the Conceptual Site Model report(May 2003)prepared by SECOR, Inc. N + for the former Chevron site located at 2103 Country Club Boulevard. These two reports present contrasting interpretations of the origin of groundwater contamination at Kwikee Foods,although both agree that a substantial release of gasoline at the former Chevron site led to the formation of a large contaminant plume beneath that site. We believe that the evidence strongly supports the interpretation that the Chevron plume has spread in a general eastward direction over a period of at least 20 years,contaminating groundwater beneath Kwikee Foods.If groundwater beneath the Kwikee site had been contaminated by a release at Kwikee,one would expect both significant contamination in the unsaturated zone and widespread groundwater contamination downgradient of the Kwikee storage tanks,along the eastern side of the Kwikee site.Instead,several years of drilling and monitoring have shown that the magnitude of both soil and groundwater contamination is minor to the east of the Kwikee storage tanks,but increases westward toward the Chevron storage tanks.We hope that you will agree that it is illogical to postulate eastward contaminant migration from the Chevron site concurrent with westward migration from the Kwikee site,as required by the commingled plume model advanced by SECOR.Therefore,we urge you to reject that interpretation and concur with the model presented in our December 2002 report. We submitted a Site Closure Report at the end of 2001 and requested that the case be closed at that time.In light of the conceptual models presented in the above-mentioned reports,we again ask on behalf of Mr. William Peters that the San Joaquin County Environmental Health Department forward the case to the Central Valley Regional Water Quality Control Board for a No Further Action declaration. In accordance with Appendix B of the Tri-Regional Board Staff Recommendations for Preliminary Investigation and Evaluation of Underground Tank Sites,we have enclosed a completed Checklist of Required Data for No Further Action Requests at Underground Tank Sites as an appendix to the enclosed report. We look forward to your concurrence with this request in the near future. Si rely J .' Victor Cherven,Ph.D. President cc: William Peters Jim Barton,RG,RWQCB Robert Trommer, State UST Cleanup Fund Stockton: P.O. Box 8002, Stockton, CA 95208 (209) 772-3620 Cameron Park: 3369 Kimberly Road, Cameron Park, CA 95682 (530) 677 3055