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California Regional Water -Quality ,Control Board <br /> Central N;�ajley, Region <br /> Winston H. Hicko\: Steven T. Butler; C'hlir .''4r <br /> 1j7 nr <br /> Grav Davis <br /> pec.erarl jor Sacrament6 Main Office Governor <br /> Environmental <br /> Prlzctin Intemet Address: htrp:'4v����.s�rrh.ca.eov!—nvgcb5 <br /> =443 Rouder Road.Suite A.Sacramento,Califomia 9=S27-3003, <br /> \, t� Phone 1916)255-=000•F_Al(9I6)255-3,015 <br /> 28 April 2000 <br /> Mr. James A/fills <br /> Westrec Marinas <br /> 14900 West Highway 12 <br /> Lodi, CA 95242 <br /> DRAFT REVISED MONITORING AND REPORTING PROGRAM No. 95-802, TOWER PARK <br /> MARINA, SAN JOAQUIN COUNTY <br /> I have reviewed the Tower Park Marina Fourth Quarter 1999 Groundwater 11Nlonitoring Report and <br /> 1999 Annual Review (Report) dated 28 January 2000, which included recommendations for revisions to <br /> the Monitoring and Reporting Program (MRP) No. 95-802. My comments on this report are provided in <br /> a separate letter. Following review of this Report and a discussion with Susan Gahry of SECOR <br /> International Inc. (SECOR), I have prepared the enclosed as the Draft Revised MRP No. 95-802 for your <br /> review and comment. <br /> In summary, the Report provided several recommendations for firture monitoring at the site, including <br /> continued weekly free product/groundwater purging of MW-3, continued groundwater monitoring, <br /> reduction of analysis frequency for benzene, toluene, ethylbenzene, and xylenes (BTEX), elimination of <br /> total petroleum hydrocarbons as gasoline (TPHg) analyses, and elimination of monitoring in wells MW- <br /> 1, MW-2, and MW-5. Based on the data presented in the Report, we concur with a reduction of the <br /> sampling frequency for selected constituents in selected wells and removal of MW-5 from the MRP. <br /> However, elimination of wells MW-1 and MW-2 from the MRP is premature. Wells MW-1 and MW-2 <br /> are in approximate downgradient locations from the source areas and serve as sentry wells for detection <br /> of any further migration of source area contaminants. The draft revised MRP includes a reduction in the <br /> groundwater monitoring frequency for total petroleum hydrocarbons as diesel (TPHd) and for BTEX <br /> compounds in wells MW-1 and MW-2. I removed TPHg from the MRP for wells MW-1, MW-2 and <br /> MW-4, since it has not been detected in these wells since the initiation of groundwater monitoring at the <br /> Site. MW-4 consistently contains TPHd; therefore, no reduction in the frequency of TPHd analysis in <br /> MW-4 is warranted at this time. No dissolved phase monitoring is necessary in MW-3 when free-phase <br /> product is present. If free-phase product is not present in MW-3, monitoring for TPHg, TPHd, and <br /> BTEX shall be performed on a quarterly basis. <br /> California Environmental Protection Agestcy <br /> :w. 2ect-cled Paper <br />