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CET <br /> CONDOR EARTH TECHNOLOGIES INC. <br /> 1125 N. Golden State Blvd. 188 Frank West Circle <br /> May 7,2001 Suite G Suite I <br /> Turlock, CA 95381 Stockton, CA 95206 <br /> (209) 668-9256 (209) 234-0518 <br /> FAX (209) 668-9257 FAX (209) 234-0538 <br /> Ms. Devra Lewis <br /> CRWQCB <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3098 <br /> Re: Comments to Draft Monitoring and Reporting Program, Herman & Helen's Marina, 15135 Eight <br /> Mile Road,Stockton,San Joaquin County,CA <br /> Dear Ms.Lewis, <br /> Condor has reviewed the draft monitoring and reporting program(MRP)for the above referenced facility and <br /> your letter dated April 30, 2001 to Mr. Andrew Smith of Herman & Helen's Marina regarding the request to <br /> abandon site monitor well MW-l. The April 30, 2001 letter indicated that the request to abandon MW-1 was <br /> denied. The request to abandon MW-1 was made by Condor on behalf of Herman & Helen's Marina as part <br /> of a package of supporting data presented to the CRWQCB on April 23,2001. Condor, on behalf of Herman <br /> and Helen's Marina, has one general comment regarding the denied request to abandon MW-1 and one <br /> specific comment regarding the draft MRP. <br /> Regarding the proposed abandonment of MW-1: <br /> Condor respectfully requests reconsideration of the denial to abandon site monitor well MW-1, based on the <br /> following discussion. Condor understands that the original intent of MW-1 was to monitor the up-gradient <br /> portion of the Underground Storage Tank (UST) site based on the results of the soil and groundwater <br /> samples collected from the Hydropunch borings installed in 1995. However, based upon written and verbal <br /> comments by the CRWQCB related to the closing the UST portion of the site, the CRWQCB has indicated <br /> that the contaminant of concern at the site is MTBE (and potentially other gasoline oxygenates). The <br /> CRWQCB has also indicated that the suspected source of the MTBE is the site Above Ground Storage Tanks <br /> (ASTs)to the east of site monitor well MW-4(down-gradient of MW-4). <br /> Condor believes that site monitor well MW-4 effectively monitors the up-gradient extent of MTBE <br /> contaminant plume potentially resulting from the site ASTs and that monitoring of MW-1 is therefore <br /> redundant. Historical data clearly indicates that the location of MW-4 is up-gradient of the ASTs. Historical <br /> MTBE results in groundwater samples from MW-4 indicate either very low concentrations or no detection at <br /> or above the laboratory reported detection limits. This strongly suggests that MW-4 is located at the up- <br /> gradient extent of MTBE contamination from the ASTs. <br /> MW-4 sits at the base of a very steep levy slope while MW-I is located on top of the levy. Both the <br /> topographical and hydraulic slope between the two wells is very substantial. The large increase in hydraulic <br /> head that begins just a few feet to the west of MW4 (at the toe of the levy slope) indicates that lateral <br /> movement of MTBE up-gradient of MW-4 (in the direction of MWA) is not likely. Therefore, it is a very <br /> high probability that MW-4 is well situated to monitor the west (up-gradient) extent of potential MTBE <br /> contamination from the ASTs. <br /> ENVIRONMENTAL GEOLOGICAL ENGINEERING GEOTECHNICAL <br /> http://www.condorearth.com <br />