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NT <br /> ENTAL HEALTU �E <br /> ENVI, ONM LINTY <br />` .JpAQUIN CO Unit s.pervisors <br /> OUiN t SAN 11��I1A1�7 `.G <br /> Carl Borgman,R.E.H.S. <br /> ..� � Third Floor <br /> Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Mike Huggins,R.E.H.S.,R.D.I. <br /> cor <br /> Stockton, California5202 <br /> ia 2708Douglas W:Wilson,R.E. • " <br /> D[Ye <br /> Al Olsen,R.E. H.S. Margaret Lagorio,R.E.H.S. <br /> p program'Manager Tel (209) 458-342 Robert McClellon,R.EH.S. <br /> Laurie A.Cotulla,R.E.H.S. Fax': (209) 464-0138 Mark Barcellos,REES. <br /> Program Manager <br /> SEP 2 2 2003 <br /> KEN HILLIARD <br /> 7-ELEVEN INC <br /> Po BOX <br /> DALLAS TX 75221-0711 <br /> .':i SITE CODE: 1505 <br /> RE: 7-Eleven Store #32262 :. <br /> ' 2360 West Grant Line Road s <br /> Tracy CA 95376 <br /> - <br /> San Joaquin County Environmental Health Department (SJCIEHD) has received and <br /> reviewed "Addendum to Soil and Groundwater Assessment Work Plan" dated <br /> September 10,2003, prepared and submitted on your behalf by SECOR International Inc. <br /> (SECOR) and provides the following comments: <br /> is Analysis of groundwater samples collected from two wells, T-1 and T-2, built into the tank <br /> pit backfill at thi's site yielded results of 110,000 and 510,000 parts per billion (ppb) of <br /> methyl tertiary.butyl ether (MtBE), 350 and 1,500 ppb tertiary amyl methyl ether and <br /> 23,000 and 79,000 ppb tertiary butanol, respectively. Depth to water in these wells at the <br /> time of sampling was recorded at 11.67 and 11.17 feet below surface grade (bsg), <br /> respectively. The high concentrations of contamination in combination with the relatively <br /> shallow depth to groundwater of the area make this a high priority site. <br /> SJCIEHD requested an addendum to the previously submitted "Soil and Groundwater <br /> Assessment =Plan", dated August 12, 2003., which had failed toinclude a proposal <br /> for a vertical igation of your site as directed by SJCIEHD correspondence dated <br /> August 22, 2003. In response, SECOR ventured the "professional opinion that installation <br /> of a deep depth discrete well in the initial phase of assessment of the shallow <br /> groundwater conditions should be deferred until the distribution of the dissolved plume, <br /> flow direction,sbnd gradient in the shallow groundwater at the site have been determined." <br /> SECOR proposes to submit a work plan to define;the vertical extent of dissolved gasoline <br /> range petroleum hydrocarbons after two or three quarters of monitoring. This is not <br /> acceptable and fails to comply with the clear and justified directives of SJCIEHD. <br /> Please note that SJCIEHD did not direct the installation of deep, depth discrete monitoring <br /> wells as implied by the.September 10, 2003 addendum. SJCIEHD had directed, per the <br /> California Code of Regulations Title 23, Division 3, Chapter 16, Article 11 Section 2725, <br /> an investigation of the vertical and lateral extent of the documented contamination at your . <br /> site. SECOR,provided no basis in scientific principles or site conditions that justifies their <br /> professional opinion. SJCIEHD is not aware of-any research that demonstrates any <br /> relationship between the shallow ground water conditions that SECOR is willing to <br /> investigate and determination of a need for vertical delineation of a dissolved MtBE plume. <br /> As a high priority MtBE site there is no luxury of time that allows for two or three quarters <br /> of monitoring that can provide no foreseeable basis to decide that vertical delineation <br /> should be investigated, an investigation objective already required by state regulations.. <br />