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6E -� <br /> r <br /> GENESIS ENGINEERING&REDEVELOPMENT <br /> Howard F. Hold, P.G. <br /> May 29, 2009 <br /> Page 2 <br /> institutional control will remove the need for a human health and ecological screening evaluation <br /> of the property. In addition, Mr. Lyle suggested, given the RWQCB's oversight role for the Site, <br /> that the current Voluntary Cleanup Agreement be terminated. <br /> A second issue of importance that was discussed in the meeting was what impact the Site's <br /> Closed, Abandoned, or Inactive ("CAI") status might have on closure requirements. Both you <br /> and Mr. Rosenbaum acknowledged in the meeting that the Site meets the definition of a CAI <br /> Unit. Title 27 gives some discretion to the regulator regarding strict adherence to Title 27 <br /> groundwater monitoring and corrective action requirements for CAI Units. Specifically, Mr. <br /> Rosenbaum indicated that the Site may be able to forego some of the financial assurance and <br /> post-closure monitoring requirements of Title 27 because of its CAI status. <br /> The following are comments on a number of items contained in the RWQCB's letter. <br /> RWQCB Comment: <br /> "Variations of chloride concentrations in groundwater beneath this site suggest that <br /> groundwater has been impacted by the presence of drilling mud... Additional <br /> comparisons of water quality data are impossible at this time because the laboratory <br /> reporting limits exceeded the water quality limits." <br /> We are addressing the second portion of this statement. Groundwater from the six on-Site <br /> monitoring wells has been monitored for four consecutive quarters,beginning in June 2008. <br /> Monitoring well samples have been analyzed for: <br /> • Volatile Organic Compounds <br /> • Total Petroleum Hydrocarbons as gasoline and diesel <br /> • Total oil and grease <br /> • Title 22 metals <br /> • Various non-metallic inorganic constituents <br /> The analytical results for these constituents are presented in Tables 19 through 22 of the Site <br /> Investigation Report(GE&R 2008) and in Tables 4 through 6 of the subsequent quarterly <br /> groundwater monitoring reports prepared by GE&R. In addition to the analytical results, these <br /> tables also contain the range of background concentrations in groundwater measured during the <br /> 2008 Site Investigation and the applicable water quality screening criteria found in A <br /> Compilation of Water Quality Goals (RWQCB,2007). Selection of the appropriate water <br />