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approximately 130° Fahrenheit before it will flow. (See Appendix A for specifics on #6 fuel <br /> properties.) To reach groundwater at this site, this sticky, tar-like #6 fuel would have to <br /> migrate vertically downward through over 17 feet of extremely dense, fine-grained silts and <br /> clays. That is a very unlikely scenario. (See Figure 1 for a cross-sectional diagram of the #6 <br /> fuel tank area.) It is possible, however, that dissolved constituents from the #6 fuel could <br /> reach groundwater. These dissolved constituents (Petroleum Hydrocarbons, Polynuclear <br /> Aromatics) are what AEMC's proposed groundwater monitoring program is designed to <br /> detect. <br /> A small leak in the #6 fuel tank, because of the sticky, tar-like nature of #6 fuel, would <br /> quickly congeal and seal itself. A large leak, although not a direct threat to groundwater, <br /> would be obvious, and corrective action would immediately follow. <br /> In your 29 August 1989 correspondence to Gold Bond Building Products, you suggested that if <br /> an appropriate vadose zone monitoring system could be implemented, then perhaps a variance <br /> would not be required. You also stated that because groundwater at the site is not as shallow <br /> as previously anticipated, it may now be possible to directly monitor the vadose zone. This is a <br /> definite misunderstanding. <br /> AEMC's Underground Tank Monitoring Plan for Gold Bond Building Products of <br /> 3 December 1986, revised 22 August 1988, and presented to the Central Valley Regional <br /> Water Quality Control Board states on page 3 that, "#6 fuel oil exhibits a high boiling point <br /> and low vapor pressure, rendering vadose zone or vapor wells ineffective for leak detection." <br /> You also stated this in the opening paragraph of your 29 August 1989 correspondence. <br /> It was never AEMC's contention that vadose zone monitoring would not be implemented due <br /> to shallow groundwater. Rather, AEMC contended that shallow groundwater would merely <br /> expedite the detection of a leak into the vadose zone. <br /> »�> Page 2 <br />