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T <br /> California Regional Water Quality } ard : <br /> FIEAI-1N <br /> Central Valley Region SERVICE <br /> Robert Schneider,Chair <br /> Winston H. Hickox .Z� 34 Gray Davis <br /> Secreraryfor Sacramento Main Office Governor <br /> Environmental Internet Address: htip://www.swrcb.ca.gov/mgcb5 <br /> Proteclion 3443 Roulier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 16 July 2003 <br /> Mr. Andrew Smith <br /> Herman &Helen's Manna <br /> 15135 Eight Mile Road <br /> Stockton CA 95219 <br /> REVIEW OF ADDITIONAL SITE ASSESSMENT WORK PLAN, HERMAN & HELEN'S <br /> MARINA, VENICE ISLAND FERRY, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board) have <br /> reviewed the 19 June 2003 Additional Site Assessment Work Plan (Work Plan) submitted by <br /> Advanced GeoEnvironmental, Inc. on behalf of Herman & Helen's Manna (H&H Marina) at <br /> 15135 Eight Mile Road in Stockton (site). The Work Plan proposes four borings to collect soil <br /> and grab groundwater samples to evaluate the source of pollution near MW-6. The Underground <br /> Storage Tank Section of the Regional Board has also reviewed the Work Plan and its comments <br /> are included in this letter. <br /> 1. The Work Plan was submitted in response to Regional Board staff's 21 April 2003 letter, <br /> which requested a work plan to "delineate the lateral and vertical extent of pollution and <br /> to determine the source of pollution near MW-6 as well as the source for the elevated <br /> methyl tertiary butyl ether concentrations on site." The Work Plan does not propose <br /> sampling to delineate the lateral or vertical extent of pollution or the source of elevated <br /> methyl tertiary butyl ether (MTBE) concentrations. Therefore, the Work Plan is <br /> incomplete. <br /> 2. The Work Plan does not discuss the reasoning for the locations of the four borings. <br /> Based on the cross section figures provided in the 11 April 2003 Additional Soil and <br /> Ground Water Investigation Report (Report), none of the four proposed locations will <br /> add further definition to the estimated contours for soil and groundwater pollution. H&H <br /> Marina needs to provide a discussion of the rationale for the proposed locations, whether <br /> these locations will further define the extent of pollution in soil and/or groundwater, and <br /> how these proposed locations will determine the source of pollution observed in <br /> monitoring well MW-6. <br /> 3. The Report shows elevated concentrations in monitoring wells MW-6, which is west of <br /> the aboveground storage tanks (ASTs), and monitoring well MW-7, which is east of the <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />