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GOALS <br /> California Administrative Code Title 23, Chapter 3, Subchapter 16, Article 4, Section 2641, <br /> "Applicability," part (b) states that, "the objectives of the monitoring program for existing <br /> underground storage tanks are: to detect unauthorized releases before groundwater is <br /> affected. Groundwater monitoring may be utilized as a primary means of monitoring when <br /> the groundwater does not have actual or potential beneficial uses" <br /> Shallow groundwater beneath the 5,500-barrel #6 fuel tank for which we are currently seeking <br /> the variance has no known beneficial uses at this time. No known domestic or agricultural <br /> wells in the vicinity of the #6 fuel tank are using this uppermost water-bearing unit. <br /> Initial field analyses of groundwater at the site revealed specific conductivity (EC) values from <br /> 1800 µohms/cm to 2,100 µohms/cm. The Central Valley Regional Water Quality Control <br /> Board's "Water Quality Goals," June 1989, sets lower specific conductivity values for either <br /> agricultural or drinking water (1). The specific conductivity standard (TDS) for drinking water <br /> is 900 µohms/cm with an upper level of 1,600 µohms/cm and a short term level of <br /> 2,200µohms/cm. For agricultural use, a value of 700µohms/cm is recommended. <br /> The specific conductivity values in groundwater at the subject site make it highly unlikely that <br /> this shallow groundwater will be put to current or future beneficial use. <br /> v <br /> In this case, California Administrative Code Title 23, Chapter 3, Subchapter 16, Article 4, <br /> Section 2641, "Monitoring Alternatives," #4 should be applicable. If this alternative is not <br /> suitable for this site, please explain why. Monitoring alternative #4 would eliminate the need <br /> for a site-specific variance to alternative #2. <br /> If it is the CVRWQCB's contention that eventually this shallow groundwater will be put to <br /> beneficial use, then the #6 fuel would still have to be able to physically reach the groundwater. <br /> #6 fuel is a sticky, tar-like substance at normal ambient temperatures. It must be heated to <br /> „ �.,� Page 1 <br />