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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Steven T.Butler,Chair 0Winston H. Hickox Grav Davis <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/--rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 CO <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 19 June 2000 - - <br /> c� <br /> J <br /> z" <br /> Mr. James Mills © - <br /> Westrec Marinas c n J <br /> 14900 West Highway 12 <br /> Lodi, California 95242 <br /> FINAL REVISED MONITORING AND REPORTING PROGRAM, TOWER PARK MARINA, <br /> SAN JOAQUIN COUNTY <br /> Staff has reviewed the 18 May 2000 letter from Ms. Susan Gahry of SECOR submitted on behalf of <br /> Westrec Marinas for the Tower Park Marina at 14900 West Highway 12 in Lodi. The letter provided <br /> comments on the draft revised monitoring and reporting program (MRP) No. 95-802 and responded to <br /> our request for an evaluation of remedial alternatives to expedite removal of contaminants from the <br /> subsurface. We have incorporated all substantive comments from SECOR in the enclosed final MRP <br /> No. 5-00-824, which has been issued for this facility. <br /> SECOR's letter also provides comments on the requested evaluation of remedial alternatives. The letter <br /> states, "SECOR does not agree that an evaluation of remedial alternatives is warranted." As stated in <br /> our 28 April 2000 letter, an evaluation of remedial alternatives is necessary to address contamination <br /> remaining in site wells, in particular MW-3. This well consistently contains free product with <br /> thicknesses ranging from 0.4 feet to a sheen. According to the Fourth Quarter 1999 Groundwater <br /> Monitoring Report and 1999 Annual Review (report), from October 1996 to December 1999, weekly <br /> purging of MW-3 by Marina personnel has removed a total of only 0.71 gallons of free product from <br /> MW-3. These data show that although purging has removed some contaminants from the subsurface, <br /> this activity has not significantly expedited clean up of the contaminated groundwater. <br /> The letter also states: <br /> Well MW-3 will be sampled in the Second Quarter 2000 monitoring event to assess <br /> groundwater concentrations and verify that concentrations have been reduced from <br /> historical levels. None of the other wells contain substantive amount of <br /> contamination; the most recent TPHd[total petroleum hydrocarbons as diesel] <br /> concentrations in wells MW-1, MW-2, and MW-4 were 150 pg/l, 110 pg/l, and 130 <br /> ,ug/l, respectively. On this basis, the benefits of alternative remedial methods (such <br /> as soil vapor extraction) would not be cost effective. <br /> The report shows that based on the most recent analyses, well MW-3 contained TPHd at 400,000 µg/1 <br /> (December 1998) and 420,000 µg/1 (April 1999), which'are significantly higher than concentrations <br /> previously detected. Also, the free product thickness measurements have been less than 0.1 foot since <br /> California Environmental Protection Agency <br /> prd Rec sled Paper <br />