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` N• 1 <br /> STATE OF CALIFORNIA-Environmental,, JZOW Agency `,.� PETE WILSON Govem <br /> rALIFORNIA REGIONAL WATER QUALITY CONTROL BOA L, t��r� <br /> CENTRAL VALLEY REGION rlvt r,_, 3`4TAL HEA! Th <br /> 3443 Routier Road,Suite A p F�f°�"',t i F i- <br /> V tt1E <br /> Sacramento,CA 95827-3098 <br /> PHONE:(91 6)255,3000 95 JAN 20 pM 1: 58 � -- <br /> FAX:(916)255-3015 J v y� <br /> 17 January 1995 <br /> Mr. Harry Crockett <br /> Real Estate Asset Specialist <br /> 555 Capitol Mall, Suite 647 <br /> Sacramento, CA 95814 <br /> MONITORING AND REPORTING PROGRAM NO. 95-802, TOWER PARK MARINA, <br /> SAN JOAQUIN COUNTY <br /> We have reviewed SECOR International, Inc.'s (SECOR) 18 November 1994 Work Plan for <br /> Subsequent Site Activities at Tower Park Marina in Lodi. In addition to proposed activities at <br /> Tower Park, the work plan also included comments on the draft monitoring and reporting <br /> program(MRP) we sent you in September 1994. Our comments on the work plan are presented <br /> below. <br /> Based on the June 1994 ground water sample results which showed nondetectable levels of total <br /> petroleum hydrocarbons as diesel and gasoline (TPHd/g), and benzene, toluene, ethylbenzene, <br /> and xylenes (BTEX) in all monitoring wells (MWs), except MW 3 which has free product, <br /> SECOR recommends continued monitoring of the wells, reviewing monitoring data annually to <br /> assess the need for additional investigation and/or remediation, and providing recommendations <br /> in each annual review. We concur with SECOR's recommendations. <br /> Enclosed is MRP No. 95-802 which requires quarterly measurement of ground water elevations <br /> referenced from the mean sea level and quarterly analysis for TPHd/g, BTEX, and dissolved <br /> lead. We discussed all your comments with SECOR on 5 and 6 January 1995. We understand <br /> your concern regarding sampling and testing costs, specifically testing for TPHg when it was not <br /> detected during the June 1993 and June 1994 sampling events. Since Tower Park does not have <br /> sufficient monitoring data to confirm the absence or presence of fuel constituents, we included <br /> TPHg in the MRP. Furthermore, the two sets of data currently available were obtained during <br /> the same time of the year. Based on our experience with similar sites, short-term diurnal <br /> changes in ground water elevations due to tidal effects and long-term changes due to seasonal <br /> variations can have significant effects on whether or not a monitoring well shows contamination. <br /> Thus, at a minimum, Tower Park should have at least four consecutive quarters of monitoring <br /> data at each MW. <br />