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6633 Pacific Ave <br /> Page 4 <br /> The chlorinated hydrocarbon contamination associated with other releases is <br /> currently iri the process of being investigated, will require remediation, and is not <br /> related to water quality goals associated with this site's petroleum hydrocarbon <br /> release. <br /> The methods used to ascertain acceptable soil concentrations using The Designated <br /> Level Methodology for Waste Classification and Cleanup Level Determination are <br /> based on a compound's leachability and are not intended to suggest precise <br /> relationships between pollutant levels in soil and underlying groundwater. Also, to <br /> evaluate residual petroleum hydrocarbons, specialized testing methodologies must <br /> be used. <br /> The Antidegradation Policy requires water quality goals to be set between <br /> background and beneficial use protective levels when feasible. There is no reason <br /> to suggest that the implementation of groundwater remediation will not achieve these <br /> goals. <br /> 4.0 Remedial Action Requirement <br /> As indicated earlier, the residual soil contamination which has been evidenced and <br /> inferred continues to threaten and/or impact groundwater quality and requires <br /> remediation. PHS/EHD does not concur that soil contamination has been remediated <br /> or is at such levels as not to require remediation. The volume of residual soil <br /> contamination should be estimated and its threat evaluated. Since there is <br /> insufficient soil investigation data to estimate the volume, at this time, it is impossible <br /> to show that remediation is not necessary. <br /> Also, the definition of nuisance includes any contamination which threatens public <br /> health. Based on available information, the residual soil contamination and <br /> groundwater contamination continue to act as a nuisance to the people of San <br /> Joaquin County. Please also refer to San Joaquin County Development Title Chapter <br /> 9-1125, Water Quality Regulations and the State of California Water Code Division <br /> 7, Chapter 2 (m) for further information regarding nuisance. <br /> 5.0 Remediation <br /> Remedial Objectives <br /> Both groundwater and acceptable soil objectives have yet to be established. Also, <br /> there is no legal way to achieve your stated objective involving institutional controls <br /> "preventing the use of, or exposure to petroleum hydrocarbon affected groundwater <br /> until water quality goals are met". <br />