SITE INFORMATION AND CORRESPONDENCE

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Mr. Gregory Torlai, Jr -3- 4 September 2008 H&H"Marina • • concentrations that greatly exceed.the concentrations observed prior to September 2007. The IRM was successful in reducing TPHg concentrations almost to baseline conditions. However, quarterly groundwater monitoring data from MW-2 during December 2007, and Marchand June 2008 show that the TPHg concentration has increased to about 200,000 pg/L, higher than it ever has been historically. As shown in the time-concentration graph below, the September 2007 spill has reversed the groundwater cleanup of the pre-2007 spill in the area of MW-2. MW-2 TPHg 2002-2007 - Post-September 2007 Discharge y 250 000 x 200 000 - -- C 150000 p� 100,000 a 50000 It" date In an email dated 27 August 2007, AGE informed Regional Water Board staff that operation of an IRM designed to specifically address the September 2007 release, which consisted of pumping directly from the sump, had to be discontinued due to dewatering of the sump. Funding of cleanup of the September 2007 gasoline discharge must be resumed forthwith. If insurance funding is needed to complete remediation of the September 2007 discharge, then the insurance carrier should resume funding. As evidenced by the groundwater data, groundwater quality in the vicinity of MW-2 was close to baseline conditions prior to September 2007. Therefore, although the plume is commingled in other areas of the Site, such as MW-4, the vast majority of the pollution in the vicinity of MW-2 is from the September 2007 spill, and groundwater extraction and treatment in the vicinity of MW-2 is necessary to restore groundwater quality to pre-September 2007 conditions. The September 2007 spill resulted in pollution of both soil and groundwater. The insurance carriers funded the soil cleanup, and now the groundwater cleanup in the arekmust also be conducted. By 27 October 2008, H&H must implement the 22 February 2008 Additional Site Assessment Work Plan (Work Plan) as modified by our 3 April 2008 comments. The groundwater degradation in the vicinity of MW-2 caused by the September 2007 spill is well-defined. Therefore, the insurance carriers and H&H should be able to devise a strategy to separate the costs of cleaning up September 2007 spill from the pre-2007 pollution. If you have any questions regarding this letter, you may contact me at (916) 464-4811 or at betaylor@waterboards.ca.gov. BRIAN E. TAYLOR, R.G. Engineering Geologist cc: Ms. Margaret Lagorio, San Joaquin Environmental Health Department, Stockton Mr. Chuck Spurlock, H & H Marina, Stockton Mr. Arthur Deicke, Advanced GeoEnvironmental, Inc., Stockton