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411% <br /> %%owl ;: <br /> SECOIX <br /> "cl;r J SERVICE <br /> Iralc'rrllrilloln;llitccopol38 <br /> zitcc/ {. , <br /> ;+ <br /> Y; y4 <br /> August 14. 1996 <br /> al <br /> Gail Wiggett i ; <br /> California Regional Water Quality Control Board , <br /> Central Valley Region <br /> 3443 Routier Road, Suite A tv , <br /> Sacramento.California 95827-3098 <br /> b <br /> RESPONSE TO COMMENTS BASED ON REVIEW OF FIRST QUARTER 1996 GROUNDWATER <br /> MONITORING REPORT, TOWER PARK MARINA, 14900 WEST HIGHWAY 12, LODI, <br /> arc <br /> CALIFORNIA <br /> Dear Ms. Wiggett: <br /> SECOR International Incorporated(.S' COR),on behalf of Westrec Properties(Westrec), is providing response <br /> to your .July 1 1. 1996 letter prepared on behalf of the California Regional Water Quality Control Boards. <br /> (RWQCB). Your letter provided review comments on the First Quarter 1996 Groundwater Monitoring Report {iy4y <br /> for Tower Park Marina located at 14900 West Highway 12 in Lodi, California (the Site). <br /> .SEC'OR agrees with the RWQCB that the increase in petroleum-hydrocarbon concentrations at the Site likely ,. <br /> resulted from rising groundwater levels that desorbed residual hydrocarbons from the previously unsaturated <br /> vidose zone. <br /> �f <br /> Field Protocol Regarding Wells Containing ORC Filter Socks <br /> _ x <br /> The Geld procedures for sounding and sampling monitoring wells MW-2. MW-3. and MW-4 containing ORC <br /> Filter Socks are as follows: (1)measure del)th-to-grOLUldwater with the URC Filter Socks in the well and calculate <br /> the purge Volwrne based on this measurement and total depth of the well, (2) remove the ORC Filter Socks from S. <br /> the well and Vvrap them in clean plastic sheeting,(3) purge a nllnimL1111 of three casing volumes of groundwater, <br /> allow the water level to recover to 801X,of the original depth-to-groundwater measurement, and sample the well, <br /> and (4) place the ORC Filter Socks back into the Nell. These field procedures are outlined in the attached < <br /> Quarterly Groundwater Monitoring Report, Second Quarter 1996. <br /> 17h'('01l agrees that the above method of sounding and sampling With the ORC Filter Socks leads to purging a <br /> grcatcr volume of groundwater. However,the ORC Filter Socks do not inhibit the flow of groundwater through <br /> the well and should not affect groundwater level fluctuations. A review of historic groundwater elevation data <br /> and contour Maps indicate that the ORC Filter Socks do not appear to affect the movement of groundwater at the <br /> Site. <br /> Addition of MTBE to Site Monitoring <br /> S' "COR understands that methyl tertiary-butyl ether (MTBE) is a fuel oxygenate that is added to unleaded <br /> gasoline. Groundwater samples collected from the Site since June 1993 have not indicated the presence of <br /> gasoline in groundwater: reported concentrations of total petroleum hydrocarbons as gasoline (TPHg) in <br /> Monitoring well MW-3 samples have not resembled a gasoline pattern and have been attributed to the presence <br /> of diesel fuel. SkC'OR requested Superior Analytical Laboratoi}, (Superior) to review and evaluate <br /> n r ��r:w�:.i<rsr is ru <br />