SITE INFORMATION AND CORRESPONDENCE

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u � 45 East Harding Page 2 3.1.1 Water Quality Protection Standards The parameter within the Basin Plan that was stated to be not relevant included volatile organics. Please note that benzene, toluene, ethylbenzene, and xylene are considered to be volatile organics and are certainly relevant for this site. PHS/EHD does not agree with the statements that "Where groundwater degradation has occurred, Resolution 68-16 may not strictly apply. This is because the existing water quality within the residual plume boundary does not warrant protection; in other words, the residual plume water quality is not better than that required to protect all other beneficial water uses. It seems reasonable to presume that protection, the primary objective of Resolution 68-16, pertains only to water outside the residual plume boundary". Resolution 68-16 Statement of Policy with Respect to Maintaining High Ouality of Waters in California states that existing high quality of water will be maintained and any activity which produces a degradation to existing high quality will be required to treat the discharge to assure that pollution or nuisance will not occur and that the highest water quality consistent with maximum benefit to the people of the State will be maintained. Since petroleum hydrocarbons are not naturally occurring constituents of groundwater in this area, background is considered to be non-detectable. Prior to the unauthorized discharge of petroleum hydrocarbons into the groundwater, background water quality was achieved. Note that the concept of alternative points of compliance proposed by San Francisco Bay Regional Water Quality Control Board was specifically disallowed by State Board Resolution 94- 117 which was adopted on December 13, 1994. Attached is a copy of this resolution for your information. 3.1.2 Water Quality Goals The plan included water quality goals without reference to where these goals were obtained. Specifically, PHS/EHD understands that you do not agree with the currently adopted taste and odor goal for TPH-gas; however, the value which was included seems equally arbitrary. Water quality protection standards and water quality goals should have been established to protect the waters of the State rather than the waters outside some hypothetical compliance boundary. 4.0 Remedial Action Requirement Groundwater and soil remediation are required. PHS/EHD does not have a mechanism to prevent a property owner or a nearby property owner for disallowing the rights to use groundwater from beneath their property for their own use. 5.1 Remediation PHS/EHD is unaware of any possible dissolved-hydrocarbon plume mixing with an off site source. MW13 was installed to investigate contamination which was evidenced in MW5 and MW6 that have been dry for some time. Also, please note that PHS/EHD observed significant soil contamination during the installation of MW13 at 60 feet. 5.2 Technology Identification and Screening Groundwater remediation will be necessary to achieve the remedial objectives.