SITE INFORMATION AND CORRESPONDENCE_FILE 1

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approach to reflect current technology and new approaches, such as risk based corrective action (RBCA), to cleaning up petroleum spills from LUSTS in California. The I.LNL report completed in October, 1995 was presented to the SB 1764 Technical Advisory Committee for their consideration in preparing recommendations to the SWRCB. The SWRCB may choose to implement recommendations from the Technical Advisory Committee through revisions to the SWRCB Resolution 92-49 in mid-1996, or through revised regulations in 1997. EPA will participate in these proceedings to ensure that changes to California's LUST cleanup requirements are consistent with national and regional policy and are protective of human health and the environment. There will also be additional opportunities for public and stakeholder input during this process. The I.LNL report recommends incorporating risk-based corrective action and natural attenuation principles into California's cleanup processes and requirements. The study was designed to focus on the geologic settings and petroleum release scenarios which would represent a large majority of the LUST sites in California. It is important to realize that petroleum compounds beyond benzene (e.g., Methyl-tertial-butyl-ether (MTBE), poly- aromatic hydrocarbons (PAHs)) were not evaluated; exposure pathways beyond ground water imparts (e.g., air, surface water, soil) were not reviewed in detail; the study did not review certain geological conditions (e.g., bedrock, fractures, karst);_ and, the number of fully characterized contaminant plumes in ground water included in the study was limited to 271 sites compared to over 10,000 LUST sites statewide that impact groundwater and a total of 28,000 LUST-sites. Some of these compounds, exposure pathways, geologic settings, and release scenarios not evaluated in this study may constitute higher risk sites. As a result, the recommendations made in the LLNL report should not be applied to sites or scenarios which differ dramatically from the parameters of the study. The authors recognized that the study had limitations and stated that only more predictable release scenarios were investigated. Unfortunately, news articles and other publications have incorrectly stated that this report and subsequent memoranda from the SWRCB were intended to halt cleanups. On the contrary, the LLNTL report and SWRCB actions are NOT an attempt to discontinue cleanup of petroleum releases in the state of California. This report IS part of the ongoing effort to update and streamline the process by which petroleum releases are cleaned up WrM_OUT compromising protection of human health, safety and the environment. This report IS part of an effort to bring good science to the management of petroleum releases, receive stakeholder input, and test the updated process.through a pilot project. 2