SITE INFORMATION AND CORRESPONDENCE

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Mr. Gregory Torlai, Jr. 0 -2 - is 24 May 2010 H&H Marina Central Valley Water Board staff also reviewed the 7 April 2010 Comments.to Draft Cleanup and Abatement Order, H&H Marina, 15135 Eight Mile Road, Stockton, San Joaquin County (HHM Letter) prepared by Downey Brand Attorneys LLP on behalf of Herman and Helen's Marina, Inc, the former owner of the marina, in response to the 11 March 2010 draft CAO. The HHM Letter states that under the sale agreement between Bustez and Herman and Helen's Marina, Inc., Bustez assumed all obligations and liabilities related to contamination at the Site. Staff reviewed H&H's 9 April 2010 Quarterly Report-First Quarter 2010, H&H Marina, 15135 Eight Mile Road, Stockton California (First QMR). Groundwater monitoring at the Site is conducted in accordance with Monitoring and Reporting Program (MRP) No. R5-2009-0833. Based on groundwater monitoring conducted during January 2010, the First QMR shows that concentrations of total petroleum hydrocarbons as gasoline (TPHg) and methyl tertiary butyl ether (MTBE) are noticeably lower in two monitoring wells, MW-2 and MW-4, which historically have been characterized by elevated and/or recalcitrant levels of petroleum hydrocarbons. TPHg and MTBE concentrations in MW-2 were 860 micrograms per liter (Ng/L) and 100 pg/L, respectively. The MTBE concentration in MW-4 was 42 pg/L. The First QMR concludes that MTBE and TPHg concentrations are declining at the Site and recommends continuing to monitor in accordance with the MRP No. R5-2009-0833. On 12 April 2010, through written correspondence, H&H offered to prepare a work plan to conduct an oxygen release compound (ORC) pilot study in lieu of continuing to operate the pump and treat system. Prior to the 18 May meeting, we reviewed the 5 May 2010 ORC Advanced TM Pilot Study Work Plan (Work Plan) prepared by AGE on behalf of H&H Marina. The Work Plan proposes to implement an ORC pilot study in the vicinity of MW-4. As additional correspondence regarding a meeting was exchanged with H&H, Central Valley Water Board staff delayed issuing written comments on the Work Plan until it could be discussed during the meeting. During the meeting, Mr. Johnson, the owner of Delta Transport, Inc., stated that he is leasing the H&H Marina property with the option to purchase it by 1 October 2010. Mr. Johnson changed the name of the facility to Delta Transport, Inc. dba Herman and Helen's Marina. The terms of the sale agreement set a cap on Mr. Johnson's financial liability for environmental investigation and cleanup. If the cap is exceeded, H&H Marina must resume paying for the cleanup activity, even if Delta Transport, Inc. has already purchased the property. The Work Plan proposes to submit a notice of intent (NO[) to enroll in Order No. R5-2008-0149, General Order for In-Situ Groundwater Remediation, to inject ORC Advanced TM at the Site into six boreholes at two locations, near MW-4 and historical boring B-16. Both locations are in the vicinity of the pre-2007 spill and about 40 feet upgradient of the September 2007 release area, which is monitored by MW-2. An advance copy of the laboratory analytical results for groundwater sampling performed on 15 April 2010 showed that TPHg concentrations in MW-2 and MW-4 were 5,900 pg/L and 1,400 pg/L, respectively. MTBE was also present in MW-2 and MW-4 at 36 pg/L and 19 pg/L, respectively. Prior to the injections, H&H proposes to collect a groundwater sample from MW-4 and a grab groundwater sample from proposed boring B-30A, which will then be sealed. Groundwater levels will be collected from MW-2, MW-4 and MW-6. Laboratory analysis will be performed to characterize baseline ambient groundwater parameters and petroleum hydrocarbon concentrations. ORC Advanced TM slurry will be prepared on site and injected at discrete