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California Regional Water Quality Control Board <br /> vCentral Valley Region <br /> Terry Tamminen Robert Schneider,Chair <br /> Secreta for Arnold ScLwarzenegger <br /> Secretary Sacramento Main Office Governor <br /> Environmental Internet Address: http://wwwswrcb.ca.gov/rwgcb5 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-4797 (� r <br /> 30 December 2003 Rp <br /> �AN o 2 boa <br /> Andrew <br /> Herman Helen's s Marina ENVIR M��SER�jCESN <br /> 15135 Eight Mile Road PER <br /> Stockton CA 95219 <br /> REVIEW OF REPORTS, HERMAN & HELEN'S MARINA, 15135 EIGHT MILE ROAD, SAN <br /> JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)has reviewed the <br /> following submittals provided by Advanced GeoEnviromnental, Inc. on behalf of Herman &Helen's <br /> Marina(H&H Marina) at 15135 Eight Mile Road in Stockton(site): <br /> • 2 October 2003 Response to Comments (Letter); <br /> • 30 October 2003 Quarterly Report— Third Quarter 2003 (Report); and <br /> • 3 December 2003 Feasibility Studies Work Plan (Work Plan). <br /> The Letter responds to comments in Regional Board staff's 11 August 2003 letter regarding the <br /> 24 July 2003 Ground Water Extraction Feasibility Test Report and the 31 July 2003 Bioremediation <br /> Feasibility Study Work Plan. The Report discusses the groundwater monitoring activities conducted in <br /> September. The Work Plan proposes to evaluate soil excavation with groundwater extraction, dual <br /> phase extraction, and oxygen releasing compound injections as remedial alternatives for the site. <br /> Staff of the Regional Board's Underground Storage Tank Section has also reviewed the reports listed <br /> above, and those comments are included in this letter. <br /> 1. The Work Plan states that based on experience, groundwater extraction typically requires much <br /> more time than calculated. As stated in Regional Board staff's 11 August 2003 letter, H&H- <br /> Marina should use groundwater extraction as an interim remedial measure until a full scale <br /> remedial measure is implemented and shown to be effective. <br /> 2. The Work Plan states that groundwater extraction will commence pending the issuance of <br /> National Pollutant Discharge Elimination System and Waste Discharge Requirements permits. <br /> On 25 September 2003, Regional Board staff sent H&H Marina Waste Discharge Requirements <br /> for General Order for Discharge to Surface Waters of Groundwater Cleanup of Petroleum Fuel <br /> Pollution, General Order for Land Disposal of Groundwater or Surface Water from Cleanup of <br /> Petroleum Pollution;Form 200 Report of Waste Discharge; and Section 2200 Annual Fee <br /> Schedules. Although more than three months have passed, we have not received the completed <br /> California Environmental Protection Agency <br /> r o Recycled Paper <br />