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. 4) Groundwater contamination at the site fluctuates in response to changes in the water depth <br /> When GT-1 and GT-2 were first drilled in late 1994, the water depth was at 75 feet, below <br /> the zone of contaminated soil, yet diesel was detected in the water samples This was <br /> probably due to contamination during drilling, causing impacted soil higher in the boring to <br /> slough into the saturated zone and contaminate the water temporarily Within a few months, <br /> the water depth began to rise and groundwater concentrations dropped below the detection <br /> limit When the water depth later rose above 63 feet and came in contact with the zone of <br /> residual soil contamination, concentrations spiked 'sharply, even though the water level was <br /> above the screened interval This situation had previously been predicted during our initial <br /> investigation in 1994, when we recognized that soil contamination was significant between <br /> 40 and 60 feet Since 1999, the water depth has increased again by more than 10 feet, and <br /> diesel concentrations in the groundwater have declined by more than 90% in all wells <br /> except GT-6 Even in GT-10, concentrations declined from 190,000 ppb in early 1999 to <br /> between 20,000 and 30,000 ppb in early 2000, a decrease of at least 85% Concentrations <br /> have since spiked and declined again, but in the most recent sample the concentration of <br /> 37,000 ppb still represents a decrease of over 80% from the 1999 peak This decline has <br /> occurred even though the water depth is presently at 58 feet,which is only 6 inches above a <br /> soil sample collected in 1999 that had a TPH-d concentration of 19,000 ppm Although it is <br /> conceivable that the groundwater concentration will rise again'in the near fixture, it is a <br /> virtual certainty that the concentration would decline greatly should the water level fall to <br /> its pre-1998 level, when drought conditions and agricultural use of groundwater resulted in <br /> regional lowering of the water table Hence, by and large, groundwater contamination at <br /> this site is a problem primarily when the water depth is above 60 feet <br /> 5) Active remediation of groundwater at this site would be difficult to implement, because <br /> contaminant concentrations are high only within the Modesto channel, which has a very <br /> limited volume of groundwater In recent years, this channel has been completely devoid of <br /> groundwater, and treatment would be impossible because the impacted water has been <br /> contained within the low-permeability aquitard that underlies the channel Wells that are <br /> completed within the Riverbank Formation yield water to wells much more readily, but <br /> contaminant concentrations are too low in this formation to warrant the difficulty and <br /> expense of treatment <br /> 6) The hydrogeology at this site was well understood as early as October 1996 Subsequent <br /> drilling in 1999 added some additional information regarding the vertical extent of <br /> contamination beneath the former UST facility, but for the most part this phase of drilling <br /> merely confirmed the hydrogeological interpretation that had been developed in 1996 <br /> Groundwater monitoring since that time has further confirmed the relationship between the <br /> water depth and changes in contaminant concentration, but has otherwise added little new <br /> information Continued monitoring is therefore unlikely to produce significant new insights <br /> in the future Further, it is difficult to imagine what public health benefits could be derived <br /> from additional attempts to locate the precise limit of soil or groundwater contamination <br /> {"non-detect line") in selected locations (e g north of GT-8), especially in view of the fact <br /> that this margin probably undergoes slight changes continuously as the water depth changes <br /> 8 <br />