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'ter <br /> John Weber <br /> Page 2 <br /> Furthermore,the Water Quality Goals dated May 1993 and prepared by the Central Valley Regional <br /> Water Quality Control Board (CVRWQCB) states that "Ground waters shall not contain chemical <br /> constituents in concentrations that adversely affect beneficial uses." and that "Ground waters shall not <br /> contain taste- or odor producing substances in concentrations that cause nuisance or adversely affect <br /> beneficial uses." The beneficial uses outlined in the CVRWQCB Basin Plan include uses other than <br /> drinking water. <br /> Finally, the SWRCB adopted Resolution 92-49,Policies and Procedures for Investigation and Clean! and <br /> Abatement of Dischar es under Water Code Section 13304 outlines the procedures and policies applicable <br /> to investigations, cleanup, and abatement activities. The groundwater extraction which occurred over a <br /> period of 11 months and discharged approximately 3,488,163 gallons of groundwater is not considered as a <br /> sufficient attempt to restore the groundwater quality beneath the site to background levels,since <br /> concentrations of contaminants exceeding background levels continues to be evidenced. <br /> Vapor Extraction and Treatment <br /> Vapor extraction was re-started on June 23, 1993 and operated continuously for 3 months until September <br /> 21, 1993 when granulated activated carbon (GAC) canister breakthrough occurred. The system was not in <br /> operation for approximately 1.5 months. The system then operated continuously from November 4, 1993 <br /> for approximately 2.5 months until January 27, 1994 when breakthrough again occurred. PHS/EHD is <br /> concerned that the treatment system may not be adequately sized to remediate the concentrations of <br /> contaminants that are being removed from the subsurface environment. It is obvious that the system is <br /> continuing to remove petroleum hydrocarbon. <br /> The performance of the remediation system in use should be evaluated quarterly and the estimated time <br /> until completion should be included in quarterly reports. <br /> If you have any questions, comments or wish to schedule a site inspection, please contact Mary Meays, <br /> Senior REHS, of my staff at (209) 468-0337. <br /> Ernest Fujimoto, M.D., M.P.H. <br /> Acting Health Officer <br /> Diane M. Hinson, Supervising REHS <br /> Environmental Health Division <br /> DMH/MM <br /> C, Elizabeth Thayer, CVRWQCB <br /> c: Dan Kirk, Shell Oil <br /> C. Jeanne Zolezzi, Neumiller and Beardslee <br /> c: Paul Graff, Aegis Environmental <br />