SITE INFORMATION AND CORRESPONDENCE

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`..� *../ CYNTHIA C ADKISSON Page 3 time frame nor was the WDR issued within the 120 day period. Based on these failures to act, the discharge may be initiated as planned. With regard to the documents missing from the CVRWQCB files, courtesy copies should be mailed to the CVRWQCB for all reports submitted to PHS-EHD. Historical data relative to the UST removal are filed in the PHS-EHD office. Removal reports are not routinely submitted to the CVRWQCB. EBMUD has had several consultants over the years since the tank removal; however, the documents have been submitted to PHS-EHD and duplicates can be provided to the CVRWQCB should that be necessary. Ultimately, at the time of closure certification, the final prepared document will be an all-inclusive document containing all the historical data. In the January 24, 1994 letter, PHS-EHD stated that quarterly monitoring of Monitoring Wells #1, #8, and #9 would continue effective April 1994, thereby granting EBMUD's request for a reduction in the number of wells sampled; the CVRWQCB was courtesy copied. Gradient variances were adequately investigated in the "Addendum No.1 to the Additional Site Assessment and Remedial Options Report" dated September 1994. Furthermore, the " Quarterly Groundwater Monitoring Program and Tidal Study-Second Quarter 1992" prepared by Weston and dated August 26, 1992 was re-explored, at PHS-EHD's request, by BVWSI; the results are stated in the aforementioned September 1994 report. The conclusions of both consultants were that no influences from the tides are observed in the on-site EBMUD wells. PHS-EHD is now concerned that the proposed in-situ bioremediation system may not be appropriate based upon the original feasibility study of December 1993. As the lead regulatory agency for the investigation and cleanup of the UST site, PHS-EHD recommends re-evaluating the proposed bioremediation treatment system to determine whether it is still appropriately suited to address the site's problem, and you should consider implementing an action that would preclude CVRWQCB Waste Discharge Unit input to facilitate timely implementation of the chosen remediation system.