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,Ar. David Johnson - 3 - 22 December 2010 <br /> Herman and Helen's Marina <br /> Our comments are presented below. <br /> 1. While we concur that the distinctly lower water levels observed in the deep-zone wells <br /> coincide with the timing of Stockton's dewatering operation, options for investigating any <br /> potential influence on the H&H plume are presently limited since (1) the City of Stockton <br /> has abandoned its wells, and (2) the NOA does not require monitoring for petroleum <br /> hydrocarbons. The Annual Report shows that H&H's downgradient wells, MW-8, MW-9, <br /> and MW-10, did not contain any COCs during July 2010. Followup investigation of potential <br /> off-site migration may be conducted by performing groundwater monitoring in MW-8, MW- <br /> 9, and MW-10 at an increased frequency over what is required by MRP No. R5-2009-0833, <br /> but Central Valley Water Board staff will not require H&H to do so. <br /> 2. If an access agreement to inject the oxidants has not been obtained from the Reclamation <br /> District by the end of December, please include an update on H&H's efforts to obtain the <br /> agreement and provide a tentative schedule to perform pre-injection groundwater <br /> monitoring described in the Work Plan in the fourth quarter report, which is due by ., <br /> 1 February 2011. <br /> If you have any questions regarding this letter, you may contact me at (916)464-4811 or at <br /> betaylor@waterboards gov. <br /> BRIAN E. TPS LOR, R.G. <br /> Engineering Geologist <br /> cc: Ms. Adrienne Ellsaesser, San Joaquin Environmental Health. Department, Stockton <br /> Mr. Gregory.Torlai, Jr, Bustez Enterprises, Inc., Stockton <br /> Mr. Arthur Deicke, Advanced GeoEnvironmental, Inc., Stockton <br /> Mr. George V. Hartmann, Esq, Hartmann Law Firm, Stockton <br /> Ms. Pamela Neuvert, H&H Marina Properties, LLC, Stockton <br /> Ms. Nicole Gleason, Downey Brand Attorneys LLP, Sacramento <br />