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4 Septemberzuuo <br /> • 2 ' <br /> Mc Gregory Torlai, Jr <br /> H&H Marina petroleum hydrocarbons, <br /> /L in monitoring well MW-2• Concentrations trends of other p showed that BTEX also <br /> 190,000 Ng xylene collectively BTEX), tion of a <br /> IL, respectively. With the o exception <br /> ion o <br /> including benzene, to 3,500, 19 900, 5,600, and 27,400 predominantly ND since Sep <br /> increased from ND to 3,500, ounds had been p butyl ether <br /> 2004. <br /> few low level detections, these <br /> rese P for gasoline oxygenates including methyl tertiary Y <br /> Notable increases were also p l ether (TAME). <br /> (MTBE) and tertiary alcohol <br /> me <br /> AGE returned to the Site on 22 September anodorous soid observed l in thea vicinity of a blroken fence es of non-aqueous <br /> quantity of gasoline reportedly occurred as the <br /> phase liquid (NAPE) in MW-2 and discolored, Environmental <br /> surrounding the AGTs. The release of an unknown q tY OES). An <br /> e San Joaquin Co <br /> and the Governor's Office of Emergency Services <br /> result of a theft from the AGTs. The release is record edteen 22 Scy Services <br /> embe and 5 November 2007. <br /> Health Department (SJCEHD) date — Fourth Quarter 2007 <br /> aggregate 12 inches of NAPE were observed e MW-2 il and Clean-up Update <br /> completed in <br /> The 29 January 2.008 Above Ground Tank Theft, SP roundwater cleanup <br /> (Update), submitted by AGE, summarized soil and g activity was <br /> response to the Septembewas <br /> r 2007 discharge. We understand that this phase of the ae p activit letter, <br /> this finding. In an 11 January <br /> wholly funded by your insurance carrier. In the Update, H&H concluded that the cleanup <br /> tete, and Regional Water Board staff concurred with Ian by 29 February 2008 to investigate <br /> incomplete requested submittal of a work p September 2007 plumes. <br /> Regional Water Board staff <br /> and complete the cleanup of the entire commingled pre-2007 and <br /> 2008 Additional Site <br /> ro Marina <br /> s site-wide grab groundwater sampling to delineate the <br /> In response to this requirement, H&H Marina submitted the 22 February to add two <br /> Assessment Work Plan (Work Plan) ember 2007 discharge, the Work Plan proposed <br /> pre 2007 plume. To address the Sep which consists of the 2-inch diameter <br /> roundwater extraction syastem, backfilled sump that has been left <br /> extraction points to the existing 9 nd in the shored, p Y <br /> monitoring well MW-2 and a sump-p p <br /> open since the contaminated soil was excavated during the funded spill cleanup. <br /> rovided comments on the Work Plan. The esecondar of <br /> On 3 April 2008, Regional Water Board staff provided <br /> proposed system modifications app <br /> expressed our concern that the p p groundwater pollution. <br /> our four comments exp the September 2007 spill instead rn site wide <br /> intended to address only re-2007 releases, is present in <br /> Evidence of site-wide pollution, that most likely resulted from the p concentrations in MW-4 have <br /> MW-4 located across the site in the vicinity of the former USed sin TPHgal <br /> been about 3,000 pglL since 2006and\hfh the Work PI <br /> tn under heconditionltha ourecommentsaff <br /> concurred with H&H's plan to proceed <br /> from the 3 April letter were incorporated into the investigation. <br /> culminated in the 14 August 2008 meeting. Themeeting <br /> eeting a cke of When this proposed investig ion was not conducted, Regional WaterBoarstaff initiated a series o <br /> telephone calls to H&H, which <br /> by Mr. Pat McCarty and Mr. Chuck Spurlock of H&H Marina, er. o y ary to continue the mandated <br /> AGE, and that <br /> self and Ms. Wendy Cohen of the Regional Water Board. H&H informed Regional Water <br /> de the funds necess <br /> Board staff that its insurance carrier \jvould not k because the Regional Water Board staff had stated that the plume <br /> investigative and cleanup were unable to continue with the proposed cleanup because i <br /> was commingled. H&H stated that they <br /> does not have adequate financial resources. plume,, however, has degraded the <br /> H&H did not cause the September 2007 discharge. The resulting p <br /> and BTEX, at <br /> groundwater in the vicinity of MW-2 with petroleum hydrocarbons, including TPHg <br />