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SECOR %Vwwsecorcom <br /> INTERNATIONAL 3017 Kilgore Road 5ulie 100 <br /> S E C 0 R INCORPORATED Rancho Cordova CA 96670 <br /> 916 881 0400 TEL <br /> 916-661-D430 FAx <br /> July 22, 2004 <br /> Mr James Barton <br /> Central Valley Regional Water Quality Control RWQCB <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, CA 95670-6114 <br /> RE Field Test Program for Evaluation of Oxidation Capacity of Groundwater <br /> 7-Eleven Store#14117 <br /> 2725 Country Club Boulevard <br /> Stockton, California 95204-3937 <br /> SECOR Project No 77EL 14117 04 0104 <br /> Dear Mr Barton <br /> This field test program, prepared by SECOR lnternational Incorporated (SECOR) on behalf <br /> of 7-Eleven Inc , proposes evaluating the oxidation capacity of the groundwater resource at <br /> 7-Eleven Store #14117 (Figures 1 and 2) Mr Michael Infurna of the San Joaquin County <br /> Environmental Health Department (SJCEHD) responded to SECOR's submittal of a Work <br /> Plan for Interim Remediation and Oxygen Infection Feasrbrhty Test, commenting that the <br /> Central Valley Regional Water Quality Control RWQCB (RWQCB) has recently advised that <br /> a Waste Discharge evaluation may be required to inject oxygen into groundwater <br /> Furthermore, SECOR understands that the RWQCB is considering bench scale testing as a <br /> means to evaluate potential Impacts to groundwater quality from oxygen injection <br /> SECOR proposes the installation of one oxygen injection test well and injecting oxygen to <br /> evaluate potential impacts to groundwater quality resulting from (1) reactions between the <br /> injected oxygen and the groundwater, and (2) reactions between the injected oxygen and <br /> the subsurface lithologies Such a program will effectively address concerns of the <br /> RWQCB regarding potential impacts to groundwater quality from oxygen injection and <br /> results will be more applicable and representative compared to bench scale testing <br /> GENERAL PROJECT APPROACH <br /> Oxygen injection is utilized as a remedial method to enhance biodegradation of dissolved <br /> petroleum hydrocarbons However, there is concern that injection of oxygen into <br /> groundwater may promote oxidation of dissolved constituents and/or oxidation of the <br /> aquifer lithologies and impact water quality through production of oxidized species, e g , <br /> Cr207 z or Cr04 Z, both forms of Cris stable 1n aqueous environments and which are <br /> considered a health hazard In addition, oxidation of dissolved constituents may promote <br /> formation of insoluble precipitates, e g , Fe00H, that impair aquifer characteristics and foul <br /> well screens <br /> Reaction of groundwater and aquifer lithologies with injected oxygen is minor due to the <br /> capacity of the dissolved oxygen to remain at high concentrations and the limited radius of <br /> influence as it migrates outward from the injection well through the aquifer The aquifer <br /> would also tend to buffer the oxidation reactions such that reaction products would be <br /> 117-Eleven%7-11 Storesk14117\Workplans <br />