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t ENVIRONMENTAL HEALT"EPARTMENT <br /> Ppu�H <br /> SAN JOAQUIN COUNTY Unit Supervisors <br /> F ;a Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Third Floor g <br /> N c Carl Bor man,R.E.H.S. <br /> Director Mike Huggins,R.E.H.S.,R.D.I. <br /> •' ;,Y _ Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> eq:Cr �P Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> FOR Laurie A.Cotulla,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Mark Barcellos,R.E.H.S. <br /> MAY 0 3 2005 <br /> KEN HILLIARD KENDALL YOUNG <br /> 7—ELEVEN INC YLY LLC <br /> PO BOX 711 720 YORK STREET <br /> DALLAS TX 75221-0711 SAN FRANCISCO CA 94110 <br /> RE: 7-Eleven Store #32262 SITE CODE: 1505 <br /> 2360 Grant Line Road <br /> Tracy CA 95376 <br /> San Joaquin County, Environmental Health Department (SJC/EHD) has reviewed "Work <br /> Plan for Additional Site Assessment and Interim Remediation Addendum"(Addendum) <br /> dated March 31, 2005 prepared on your behalf by Secor International Incorporated <br /> (SECOR) and has the following comments. <br /> In correspondence dated February 14, 2005, SJC/EHD requested submittal of the <br /> following: <br /> 1. A work plan to continue the investigation of the vertical and lateral extent of the <br /> documented groundwater contamination at your site. <br /> 2. A work plan addendum to conduct an extended groundwater extraction test. <br /> SJC/EHD recommended that the test be designed to demonstrate and <br /> compensate for the earth tidal effects SECOR reported as being a factor in the <br /> previously conducted 24-hour extraction test. <br /> 3. A copy of the chromatogram from the analysis of the groundwater sample <br /> collected at 60 feet below surface grade (bsg) in CPT-1, along with an explanation <br /> as to why SECOR considered pipe dope to be the source of the contamination <br /> detected in this sample. <br /> 4. Further explanation and justification of the test method used for the oxygen <br /> infusion test conducted on June 21, 2004; SJC/EHD recommended the test be <br /> conducted as originally proposed and approved. <br /> SECOR declined to submit a work plan to continue investigation of the vertical and lateral <br /> extent of the site contamination, stating that the low concentrations of methyl tertiary butyl <br /> ether (MtBE) reported in groundwater samples from the Valero branded station located <br /> down the street from the subject site define the western limits of the 7-Eleven plume, and <br /> that MtBE concentrations onsite and offsite are declining. However, verification to <br /> SJC/EHD has not been made that 7-Eleven has taken possession of the Valero <br /> monitoring well that SECOR claims defines one margin of your plume, nor have they <br /> included data from this well in the quarterly reports. The groundwater monitoring event <br /> that SECOR references in the Addendum as demonstrating a decline in the MtBE <br /> concentrations in both on and offsite monitoring wells had not been reported to SJC/EHD <br />