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January S 1998 ' I'age 5 • on the following scope of work installation of thi ee groundwater monitoring wells to 40 feet and three groundwater monitoring wells to 70 feet (these shallow and deeper nested wells would be placed at three locations oil and off site) to further assess the ertical delineation of hydrocarbons in soil and groundwater, installation of three exploratory borings to further delineate the tate]al and vertical extent of hydrocarbon impact to soil, installation of one air sparge well and one observation well to depths of 40 feet, performance of a 1 month air sparge/soil vapor extraction pilot feasibility study, and preparation of a corrective action plan which would include the evaluation of three remedial alternatives As stated above, it is PEG's opinion the activities rewired by the PHS/EHD are not required for protection of human health and groundwater resources Furthermore, the cost of the required actions is not commensurate with the very limited utility of the data that would be generated (6) The SpeCl fic action by the .Mate Bow d which the j)elmollel l equests On behalf of LJNTOCAL, PEG requests that the requirement for additional soil borings and monitoring wells, performance of soil vent/sparging testing and evaluation of remedial alternatives be overturned Additionally, PEG requests that the PHS/EHD be' directed to approve the October 9, 1997 work plan and not require additional work until . the proposed scope of work has been completed (7) A %(alenient of the j)olwl crud awhoi me% In %llj)j)oll of legal 1%VIC°� 1611%ed in the JVW70ll - Both the Legislature and the SWRCB have expressed concern over unnecessary expenditure of money and effort to remediate residual petroleum resulting from releases from USTs in situations where the remaining materials do not pose any significant risk to health or the environment In 1994, the Legislature passed SB 1764, which required the S\'VRCB to convene a panel of experts to explore appropriate cleanup standards for releases from USTs This resulted in the report issued by Lawrence Livermore National Laboratories (LLNL) This report found that the impacts from leaking USTs were not as great as once thought, and that passive bioremediation should be considered as a primary remediation tool in most cases once the source had been removed In December, 1995, Walt Petit, Executive Director of the SWRCB, issued a memorandum to all agencies implementing the UST law endorsing the LLNL report The memo recommended that in cases involving "low risk" groundwater, defined in the memo as shallow groundwater with no drinking water wells screened in the groundwater zone within 250 feet, active remediation be replaced with monitoring to determine if the plume is stable As demonstrated above, this case presents exactly the kind of"low risk" situation • addressed in Walt Petit's memo The GSI work plan submitted by UNOCAL is j 1111 i07Al0187RMEIV