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DRAFT <br /> sulfate concentrations are about 70 ppm and 170 ppm respectively while concentrations <br /> of these constituents at the core of the plume are "non detect" and in down-gradient <br /> groundwater nitrate concentrations are "non detect" while sulfate concentrations are only <br /> 10 to 20 ppm. Thus, available data provide evidence that the dissolved phase <br /> hydrocarbon plume in site groundwater is attenuating and biodegrading via iron, sulfate <br /> and nitrate reduction. <br /> In considering possible impacts to current and future beneficial uses of <br /> groundwater, three factors are relevant: 1) according to Department of Water Resources <br /> (DWR) Bulletin 146 (1967) and petitioner's March 1998 sample analyses, shallow <br /> groundwater in the vicinity of the site is of"inferior quality," 2) the groundwaters <br /> monitored by site wells are not in direct hydraulic communication with deeper <br /> groundwater aquifers or local supply-yells, and 3) as discussed above, the plume is stable <br /> and concentrations are decreasing as a consequence of natural attenuation. A review of <br /> DWR Well Drillers' Reports for water supply wells located in the vicinity of the site <br /> show that these wells are constructed with sanitary seals which extend to depths of 150 to <br /> 200 feet below ground surface. The purpose of this method of well construction is to <br /> exclude poor quality shallow groundwater(which generally contains elevated <br /> concentrations of nitrate, chloride, and TDS). The presence of this water in the Victor <br /> Formation is a consequence of the easterly intrusion of poor quality water underlying the <br /> Delta and the Stockton Deep Water Ship Channel over the past 50 years or so. An <br /> analysis of water level elevation data for site wells also shows an absence of the seasonal <br /> fluctuations one would expect if the groundwater monitored was in direct hydraulic <br /> communication with local production wells. Hence, the localized volume of affected <br /> water is not currently being used and, due to its inferior quality, is not likely to be used in <br /> the future. Furthermore, historic groundwater monitoring data, in addition to showing <br /> plume stability and decreasing constituent concentrations, shows that the poor quality of <br /> the shallow groundwater enhances the on-going bioremediation, consequently reducing <br /> the residual petroleum hydrocarbon mass in the subsurface. Because constituent <br /> concentrations will continue to decline as the mass of residual petroleum hydrocarbons <br /> to <br />