SITE INFORMATION AND CORRESPONDENCE_FILE 1

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"• JAN-09-1996 1;.02 RWOCB - SF BAY PLANNING 5102860928 P.04 "Interim Guidan,ie on Low-Risk P6e11111 Hydrocarban ifeanups& (cont.) January 11, 19911 Q Can existing active remediation systema at low tisk sites Q If a responsible party wants to ptusuc a more aggressive be turned off evzn though established remedial gnats remedial strategy than stated in the State Board letter, have 110[been:cached? will the Cleanup Fund pay for the additional Yes. If the site is evaluated using the new guidance and mmedlatfon? active remediation is not indicated,then active treatment A The Cleanup Fund manager has indicated that the Fund will onlytelmbursc costs for these activities that are at the site should vi terminated.yhydraulic If the of the plume system required b regulatory a unties. For low risk cases, is nc¢:vsary ro provide hydmvlic wntrol of the plume g Y nc ry g' which prevents contaminants from rcaebiag a sensitive regulatory'agencies should not adeqappuate lusove work plans for receptor,then continued pumping may be warranted. active remediation unless adequate justification is provided. Article 11,section 2727E of the ltndergtound n Storage Tank When can adjacent site data be used in lieu of site Regulations requires that responsible g - specific data? partes propose the most cnst_cffective corrective action. Local hydrogeologic data can often be infected From data lhis will be monitoring,without attire remediation, is j-1 collce[etl at adjacent situs. Depth to groundwater, depth many casts. to regional aquifer; groundwater gradient,soil types that What public notification is required when implementing may be present,and chemical concentrations may all be P of value.in directing an invcatigaucin. A conceptual this gmdance? model of the site may be formed using eves adjacent A site data. Data ceilccted during a site investigation The implementation of the LLNL recommendations igatian suggested by the Slate Board letter dots not change the should clarify the conceptual model and help to guide Public notification requirements already stated in the any further work al the site. USC regulations in Chapter 11, Section 2728. That section requires that the public must be informed of the If a site is only monitoring and no active remediation is proposed activities contained in a sitc'a corrective action anticipated,can the site be dosed? plan. If a site's corrective action plan is modified to the A Regulatory agencies have broad discretion to determine extent that it is essentially a new corrective action plan, whether or not regulatory action is necessary and then it may be appropriate for the public to be notified appropriate at a given site. Under current policies, the of the new plan. monitoring period could be many years depending upon Will tine an impacted proper tea[rjc[cd by the magnitude of the release, remedial actions taken,and biodesradation fates at the site. Closure of low risk UST implementation of State Boards' recommendations? No change in current practice is expected. Generally, sites would be appropriate as soon as enough data A sites are a in c rred m cachet is expect. raiRi nr supported the conclusion that the source had been commercial/industrial requirements based on current and removed, the plume had stabilized, and bioremediation was expected to achieve water quality objectives (e.g. projected future land uses. if a site is cleaned up to MCI s)in a reasonable time. commercialAndusnial standards and the land use changes to residential, then further risk assessment and possibly The State Board has indicated that policies regarding miligation or remediation may be required. petroleum cleanup standards will be reviewed in 1996 pursuant m SB1764 requirements, Changes in closure 'Rhe current UST"g further action" if a c requiresin that the im Icmendn agency be notified if a change in land polity regarding low risk groundwater rases may be a c g g ry n:sult of that review. use occurs. QHow does this guldancc H[with casting and future What action should be taken if a responsible parry Q policy? tefim'a to take any action at a site and cites this From the December S, 1995 letter, "what I propose to guidance a the reason for inaction? A Policies or A you is not in any way inconsistent with ac mea Responsible parties are required di comply with all Y regulations. However,it does represent a major regulatory requirements If tory disagree with a directive departure from how we have viewed the threat fi'nm leak or think it is in violation Of current regulatory practice, USTs" Under the roqui have vie e t 1764 the they have the opportunity to appeal that directive legislature expects the State Water Resources Control. through the proper channels. Responsible parries may Board to propose and snake further permanem changes face enforcement actions if they disregard regulatory to the interim guidance, perhaps as early P this s ri11x' requirements and do not appeal using the appropriate Meanwhile,the Regional Board and the Inuibmtaliog procedures, agencies will be implementing the interim guidance- For further information or questions, please contafurther general information and direct your ct the Regional Board. Initial contact should be Wit Bruhn&,the Regional Board's Ombudsman at be notedthat moaefuel cleanup syesyou in the Bay Area are regulated by local agencies.questions to the appropriate staff persons. h TOTAL P.04