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Sent by: CQAA/SJOA EPU 209 468 9794; 11/16199 1 :12PM;kjrAx #345;Page 6/19 <br /> underground tank site corrective actions,the statewide impliegions would be enorTnous,well I <br /> I <br /> agree. But first of all,we do not consider that 130,000 parts per billion of TPH gasoline and <br /> 9,700 pasts per billion of ben2ene in ground water that's 50 to 60 feet deep is trace amounts. <br /> Secondly, this site has already been shown to be amenable to soil vapor extraction: A vapor <br /> extraction system was operated on this site for less than l year and our understanding,is it was ' <br /> taken out of service because they were exceeding the air pollution control standards as far as <br /> emissions from this site,but that it wasn't working effectively at the time. We wonder or we <br /> question why excavation is the only corrective action that's mentioned in the staff report and <br /> while we're discussing soil excavation that's.been a contention a contentious issue,we note that <br /> the supporting facts mentioned considerable contaminated soil bas already been removed,any <br /> debate regarding;the exact quantity of soil removed aside,the staff report mentioned.several <br /> times that the highest levels of soil contamination were located in the area of the dispenser <br /> islands,since no over excavation occurred in this area,it seems logical to conclude that the soils <br /> with the highest contaminant levels were not excavated and therefaore remained a source. Our <br /> agency has repeatedly requested complete characterization of the site,preparation of a feasibility i <br /> study to evaluate the options for remediation and closure as you will know,those can include <br /> natural attenuation do nothing, those types of actions or inaction. And apparently it was <br /> considered more feasible to petition a board than it was to comply with our actions. Mr. Anton's <br /> already mentioned the MTB C. that is sort of contentious with us but it's not an issue that we're <br /> going to discuss Dere today. With regard the overall impact of undergTound'tank clean-ups in our <br /> particular area,we have IS7 ground water contamination site$from underground tanks in the <br /> City of Stockton that we're working on currently that our staff's involved in, 13 of these sites <br />