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1I SECOR � m �a V%fAFAW EQrcle,2 Floor S E C O R INTERNATIONAL Lafayette,CA 94549 INCORPORATED 925-299-9300 TEL 925-299-9302 FAX June 18, 2003 Mr. Mike Infuma San Joaquin County Environmental Health Department 304 East Weber Avenue, Third Floor Stockton, California 95202-2708 RE: Work Plan for Groundwater Monitoring Well Abandonment Tower Park Marina 14900 West Highway 12, Lodi, California Dear Mr. Infurna: On behalf of Westrec Marinas, SECOR International Inc. (SECOR) is submitting this Work Plan for Groundwater Monitoring Well Abandonment(Work Plan) describing the proposed destruction of five groundwater monitoring wells at Tower Park Marina, located at 14900 West Highway 12 near Lodi, California. The abandonment of the groundwater monitoring wells was requested by the California Regional Water Quality Control Board (RWQCB), Central Valley Region, in their letter dated March 21, 2003. The methods outlined in this proposal are consistent with the currently-accepted practices and procedures as understood by SECOR. This Work Plan provides for the destruction of the five groundwater monitoring wells, the disposal of all wastes generated during well destruction, and preparation of a summary report describing monitoring well abandonment activities. SITE BACKGROUND The site is an operating marina located at 14900 West Highway 12 near Lodi, California (see Figure 1). The marina is situated on a levee adjacent to Potato Slough, a tributary of the Mokelumne River. The site has utilized aboveground storage tanks (ASTs) for refueling automobiles and boats, and a past release of petroleum hydrocarbons to the subsurface was observed during conveyance piping upgrade activities in 1991. Subsequent investigation activities identified the presence of free-phase petroleum hydrocarbons within the levee, and five groundwater monitoring wells were installed in 1993 (see Figure 2). Periodic groundwater monitoring and sampling was initiated at this time. i Historically, the highest concentrations of petroleum hydrocarbons and related constituents have been reported in wells MW-3 and MW-4 in the vicinity of the former gasoline dispenser and underground conveyance piping. In correspondence dated March 21, 2003, RWQCB staff noted that although concentrations of petroleum hydrocarbons exceed applicable water quality objectives (WQOs), the remaining groundwater impacts are limited, and WQOs are expected to be achieved in a reasonable amount of time. Therefore, the RWQCB authorized the permitted abandonment of the groundwater monitoring wells at the site. Following receipt of confirmation from the San Joaquin County Environmental Health Department that the wells were properly destroyed, the RWQCB will issue a 'No Further Action' letter for Tower Park Marina. Well Destruction WP