SITE INFORMATION AND CORRESPONDENCE

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Mr. Gregory Torlai, Jr. • -4 - • 3 August 2009 H&H Marina • H & H is free to add any analytes to its quarterly monitoring program. However, the data do not support a mandatory requirement to sample for 1,2-DCA or ethylene dibromide (EDB). • Resolution 2009-0042 is applicable only to sites eligible for funding from the Underground Storage Tank Cleanup Fund (USTCF). H & H does not receive funding from the USTCF, so the requirement to monitor quarterly where directed by the MRP remains applicable. • The extensive record of quarterly sampling results would normally constitute an adequate record of contaminant trends in the vicinity of MW-2, MW-4, and MW-5. However, we do not concur with H & H's recommendation to reduce sampling in MW-4 and MW-5 to a semi-annual basis due to recommendations in the Assessment Report to install groundwater extraction wells in the vicinity of these monitoring wells. Quarterly monitoring must continue in MW-2 to track the rapidly decreasing concentrations. • We concur with H & H's recommendation to sample MW-14 semi-annually. • We will require H & H to comply with the requirement to monitor groundwater levels on a quarterly basis in all wells except MW-13. • Contrary to H&H's interpretation, MRP No. R5-2004-0828 does not contain a provision to discontinue sampling for TPHg. Additionally, we do not concur with the recommendation to discontinue annual sampling in deep zone wells MW-8 and MW-11 or in shallow wells MW-10 and MW-12 because these are compliance wells located at the edge of the property. However, in accordance with footnote 6, data in the First QMR show that sampling for TBA, MTBE, di- isopropyl ether, ethyl tertiary butyl ether, and TAME may be discontinued in wells MW-3 and MW-6 through MW-12 due to two quarters of NDs. • Sampling for TAME in MW-3 and MTBE in MW-4 and MW-5 may not be discontinued since the requirements described in footnote 6 have not been fulfilled. • Treatment system sampling from EW-1, DDN, and DDS will be performed quarterly independent of the operational status. • We concur that there is no direct connection to surface water points IDCW and IDCE therefore monitoring requirements for these locations will be indefinitely suspended. Where applicable, H & H's comments are incorporated into the new MRP. We will send you a copy of the new MRP as soon as it is signed by the Executive Officer. In the meantime, the requirements of MRP No. R5-2004-0828 must continue.