SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Mr. Gregory Torlai, Jr. ' -2 - 11 March 2010 H&H Marina 5. Response to Comment No. 5— The Water Quality Control Plan for the Sacramento and San Joaquin River Basins, 4th Edition (Basin Plan) establishes narrative water quality objectives (WQOs) for groundwater in the Central Valley Region. The Basin Plan assigns drinking water as a potential beneficial use (BU) of all groundwater underlying the Central Valley. As such, cleanup standards must be derived pursuant to drinking water standards. The Basin Plan states that groundwater shall not contain taste- or odor-producing substances in concentrations that cause nuisance or adversely affect BUs. The Central Valley Water Board's July 2008 A Compilation of Water Quality Goals may be used to assign numerical values that implement the narrative objectives. The 5 pg/L for gasoline is listed on page 8a of this document, but due to limits imposed by the laboratory detection limits, the default is 50 pg/L. Furthermore, the data in Table 3 of the 25 January 2010 Quarterly Report— Second Quarter 2009 show that TPHg concentrations in EW-1, the extraction well for the treatment system, decreased from 9,800 pg/L in 2002 to non detect (< 50 pg/L) in 2007. The data indicate that the treatment system has the capacity to achieve the WQO locally, and if adequately optimized, may achieve the WQO site-wide. 6. Response to Comment No. 6— The compliance dates in the draft CAO were draft dates, intended to change after receiving H&H's comments. The purpose of issuing the CAO in draft was to provide an opportunity for H&H to participate in the decision-making process to determine an appropriate schedule for the overall site cleanup. H&H's coverage under the new NPDES General Order R5-2008-0085 was terminated effective November 2009 for failure to re-enroll by 30 June 2009. 7. Response to Comment No. 7— Because third and fourth quarter 2009 groundwater monitoring events were not conducted, we concur that monitoring reports cannot be submitted. However, H&H must resume monitoring as required in MRP No. R5-2009-0833. Legal Provision 10 of the MRP states that failure to submit the required reports could result in the imposition of up to $1,000 in administrative civil liability for each day the violation. Failure to comply with the MRP could result in staff recommending an administrative civil liability. 8. Responses to Comment Nos. 8 and 9 — The Central Valley Water Board's 29 April 2009 letter directed H&H to submit a work plan by 27 July 2009 to complete the borings, well installations, and remediation system upgrades as proposed in H&H's 13 February 2009 Additional Site Assessment Report. H&H failed to submit the work plan as directed. The final CAO will include a due date for submittal of this work plan. 9. Responses to Comment Nos. 10 and 11 — H&H Marina's 27 January 2010 Quarterly Interim Remediation Report and previous quarterly reports conclude that "The current groundwater remediation system exerts some measure of hydraulic control on plume migration." Central Valley Water Board staff concurs with this conclusion, and our 29 April 2009 letter agreed with H&H's recommendations to optimize the existing extraction system to bring it to full-scale operation. Site remediation will not require the completion of additional feasibility studies. Water Quality Control Plan for the Sacramento River and San Joaquin River Basins, 4'" Edition, revised September 2009