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Y ', d • • <br /> Page 6,Item 20-The CRWQCB states that MTBE plume is migrating vertically while <br /> being transported in the down gradient groundwater direction. <br /> This statement is false. See Item 6 listed above. <br /> Page 6,Item 21 —The CRWQCB states that to date,the dischargers have failed to <br /> demonstrate the release has been stopped. <br /> ht January,2006,the Site conducted a$26,000.00 tracer test which showed the entire fuel <br /> dispensing system was free of leaks <br /> Page 6, Item 22—The CRWQCB states that to date, the dischargers have not evaluated <br /> threats from vapor intrusion to nearby buildings. In December 2005, results from well <br /> EW-4 (210,000 ug/L) exceeded the Region 2 Environmental shallow Soil Screening <br /> Levels for MTBE for Commercial Groundwater Vapor Emissions to Indoor Air(80,000 <br /> ug/L) <br /> Since June 29, 2006,groundwater concentrations for MTBE at well EW-4 have been well <br /> below the screening level listed above. Therefore this item is no longer valid and should <br /> be removed from the final version. <br /> Page 9,Item 33—The Water Board will, on a case by case basis, adopt numerical <br /> limitations in orders which will implement the narrative objectives. <br /> The site requests that it be held to the same Water Quality Objectives as Flag City <br /> Chevron site,which is closer to the CSA 31-2 well(540 feet)than the Site(900 feet). <br /> Apex is aware that the Flag City Chevron site is currently going through closure activities <br /> with 110 ug/L of MTBE remaining in groundwater. <br /> Page 12,Item 3—Already completed. Please read the background section, Items 3 <br /> through 13 in this draft. <br /> Page 12,Item 5 -The CRWQCB requires evidence to prove the USTs and associated <br /> system arc tight and free of leaks <br /> Already completed. Praxair Services, Inc performed an enhanced leak detection test in <br /> January, 2006. <br /> Page 12,Item 6—The CRWQCB states a subsurface investigation to define soil and <br /> groundwater MTBE contamination and a soil vapor survey should be conducted on 5-foot <br /> centers. <br />