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Mr. Jon Weiss -2- <br /> the criteria for no further action sites and low risk sites. Appendix B states in part that, "Site <br /> characterization is required to determine the extent of contamination, risk to human health and <br /> the environment, and the impact on existing and probable future beneficial uses of water <br /> resources. Site monitoring must show that the remedial measure(s) applied by the Discharger <br /> is reducing or removing the petroleum hydrocarbons at the rate and in the time schedule <br /> projected." One of the criteria for low risk groundwater is, "The total pollutant mass <br /> remaining in the groundwater is decreasing at predicted rates and neither creates,nor <br /> threatens to create, a risk to human health and safety or future beneficial use(s) of the <br /> aquifer." LOF has not defined the extent of contamination, LOF has not applied a remedial <br /> measure, and has not shown that the total pollutant mass in groundwater is decreasing. <br /> As stated in my 23 October 1995 letter(Attachment 2), in June 1994, Board staff requested <br /> LOF to install additional monitoring wells to define the extent of groundwater contamination. <br /> In response, LOF requested that definition of the contamination be postponed until after <br /> completion of four quarters of monitoring. In response to my October 1995 letter, LOF <br /> requested additional groundwater monitoring including monitoring the discharge from the <br /> french drains. To date, the extent of groundwater contamination remains undefined. <br /> Therefore,by 19 March 1997,you are required to submit a work plan to define the extent of <br /> groundwater contamination. <br /> If you have any questions,you may call me at(916) 255-3049. <br /> PHIL S. ISORENA <br /> Associate Engineer <br /> PSI:psi/lsb <br /> Attachments <br /> cc(w/Attachment 2): <br /> Mr. Ron Rowe, San Joaquin County Public Health Services, Stockton <br /> Mr. Robert Job, Condor Earth Technologies, Turlock <br />