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The LLNL Reggrt on "Recommendations to improve the Cleanup Process_for <br /> California's Leaking Underground Fuel Tanks (LUFTs)" <br /> Ile LLNL conducted an 18-month review of the regulatory framework and cleanup process <br /> currently applied to California's LUST sites. LLNL issued the report in October 1995 with <br /> the following recommendations: <br /> 1. Utilize passive bioremediation as a remediation alternative whenever possible; <br /> 2. Immediately modify the American Society for Testing and Materials (ASTM) Risk- <br /> Based <br /> iskBased Corrective Action (RBCA) framework based on California's historical LUST <br /> case data; <br /> 3. Apply a modified ASTM RBCA framework as soon as possible to LUST cases where <br /> fuel hydrocarbons (petroleum) have affected soil but do not threaten groundwater; <br /> 4. Modify the LUST regulatory framework to allow the consideration of risk-based <br /> Cleanup goals higher than MCLs; and <br /> 5. Identify a series of LUST demonstration sites and form a pilot LUST closure <br /> committee. <br /> U.S. EPA Position on LLNL Report, RBCA. and Natural Attenuation <br /> EPA believes that a state LUST program which includes leak prevention, leak detection, risk- <br /> based corrective action, and strong enforcement for non-compliance is required to adequately <br /> protect human health and the environment from the risks associated with petroleum releases. <br /> Streamlining corrective action is a national and regional priority for EPA. There are far <br /> greater numbers of LUST sites to clean up than there are resources.available. EPA supports <br /> the review of accumulated historic data in an effort to understand trends, and to make better <br /> program decisions. <br /> EPA's position on the specific LLNL report recommendations are as follows: <br /> Recommendation 1: Utilize passive bioremediation as a remediation alternative whenever <br /> possible <br /> In the LUST Program, EPA does not advocate one cleanup technology over another; rather <br /> the focus is on determining the appropriate technology to use, taking into consideration both <br /> the conditions of the site and the nature and the extent of the release. In general, these <br /> 3 <br />