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& _ November 30, 1995 Page 3 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 are certainly relevant for this site PHSEEHD 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 ` works, the residual plume water quality is not better than that required to protected 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 Oboundary"' Resolution 68-16 Statement ofpohcy with Respected to Maintaining High Quah(y - Waters fn 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 occurling constituents of groundwater in this area, background is considered to be non-detectabje Prior to the i `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 PACIFIC agrees with your continent that benzene, toluene, ethylbenzene, and xylenes are volatile organics Additionally, your explanations regarding the application of Resolutions 68-16 and 94-117 are noted and accepted 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 I I ` Water qualityprotection 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. r� 3201337BICAPRESP