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Y Mr. Andrew Smith - 3 - . 11 August 2003 <br /> 10. The Work Plan does not propose monitoring of the ORCO injection after 12 weeks. <br /> H&H Marina needs to propose monitoring until the concentrations of parameters <br /> monitored return to baseline concentrations. <br /> 11. The Work Plan does not discuss the potential effects of ORO® on the site soils, which are <br /> high in organic content (i.e., peat soils). H&H Marina needs to include this information. <br /> Regional Board staff concurs with the abandonment and replacement of monitoring well MW-1, <br /> but not with the injection of ORC® as an interim remedial measure. <br /> The QMR shows that concentrations in EW-1 are increasing and MTBE is at a historical high in <br /> monitoring wells MW-3 and MW-4 and surface water sample IDCW. Total petroleum <br /> hydrocarbons as gasoline (TPHg) is also at a historical high in MW-3. Based on the elevated <br /> concentrations of MTBE and TPHg and the proximity of surface waters that have detections of <br /> petroleum hydrocarbon pollutants, H&H Marina needs to implement an interim remedial <br /> measure to remove polluted groundwater and prevent further migration of pollution into nearby <br /> surface waters. <br /> Based on the information in the Report, groundwater extraction may not be the best alternative <br /> for full-scale remediation, but it will work to prevent further migration of pollution and prevent <br /> further concentration increases. Therefore,by 15 September 2003,please submit a response to <br /> the above comments and a work plan to begin groundwater extraction as an interim remedial <br /> alternative with schedule for implementation. By 15 October 2003, submit a feasibility study <br /> work plan(FSWP) outlining full-scale remedial alternatives,which should include proposal for <br /> ORC®with the information requested above. The FSWP needs to outline all potentially feasible <br /> remedial alternatives for petroleum pollution in soil and groundwater that H&H Marina will <br /> evaluate. Based on Regional Board staff concurrence with the FSWP, we will request a <br /> feasibility study that should be prepared in accordance with the attached Items To Be Included In <br /> A Feasibility Study. If you have any questions, you may contact me at (916) 255-3119 or by <br /> email at lewisdaa rb5s.swrcb.ca.gov. <br /> Lvj_ �_4 � <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> Attachment <br /> cc: Mr. James Barton, UST Unit, Regional Water Quality Control Board, Sacramento <br /> Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Daniel Kalmbach, Advanced GeoEnvironmental, Inc., Stockton <br />