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Chevron Pipeline Co.,Dividend Property -4- 7 March 1996 <br /> and Chevron did not feel that they could convince me of their position on this case. The following <br /> comments respond to these issues: <br /> a) My review of this case does not relying solely on taste and odor thresholds to determine <br /> beneficial use impacts and threats. I compared both taste and odor thresholds and "available <br /> toxicologic criteria from the literature with measured concentrations of pollutants in ground <br /> water before reaching my conclusion that pollution of ground water exists at this site. These <br /> procedures are clearly consistent with our Basin Plan water quality objectives for toxicity <br /> and taste and odor(copies attached), which are designed to protect beneficial uses of ground <br /> waters. Ground waters beneath this site, including shallow zones, having either existing or . <br /> potential beneficial uses of municipal and domestic supply, agricultural supply, and industrial <br /> supply, as stated in our Basin Plan. Both toxicity and organoleptic effects can render water <br /> unusable'for municipal and domestic supply. <br /> b) This case,is not a soil-only case, as discussed above. It very well may be a low-risk case. To <br /> demonstrate low-risk, we need to be confident that pollutant concentrations will be reduced <br /> to below water quality objectives before the water is likely to be beneficially used. To <br /> clearly demonstrate that this is the case and that closure is appropriate for the site (e.g., no <br /> additional active remediation nor monitoring), sufficient documentation is needed. The <br /> documentation that we have requested is no more or less than that requested of dischargers <br /> responsible for leaking underground petroleum tanks in this Region, as contained in the Tri- <br /> Regional Recommendations, Appendix B. Our position is consistent with that expressed by <br /> USEPA, Region 9 in their Fact Sheet on the Lawrence Livermore report on California's <br /> le,â–ºking underground storage tank program, a report that has neither been formally accepted <br /> nor publicly debated by the members of the State Water Resources Control Board. <br /> Attachments (2) <br /> i <br />