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I <br /> Ms. Laurie Cotulla .1 <br /> fi September 23, 1992 <br /> Page 3 <br /> The presence of dissolved hydrocarbons in the groundwater is well documented at this site <br /> and the groundwater extraction system in place is effectively halting the migration of the <br /> hydrocarbons. <br /> Items 5 and 6 <br /> The results of the soil sampling beneath the former product recovery tank and the new waste <br /> oil tank indicate that hydrocarbons are present in the soil in these locations. These areas are <br /> within the characterized area of the site. ARCO has revised the number of vapor extraction <br /> wells proposed for the site and these areas will be remediated with the currently proposed <br /> vapor extraction system. Figure 1 presents the revised number and locations of soil vapor <br /> extraction wells proposed for this site. <br /> Item 7 <br /> This statement by the County is unclear. Since the groundwater table has dropped <br /> significantly since monitoring wells E-2 through E-12 were installed in 1984, it would be <br /> impossible to define the dissolved hydrocarbon plume at 1984 water levels. ARCO has <br /> graphically shown the estimated extent of dissolved hydrocarbons in the groundwater in each <br /> of the first two quarterly reports for 1992. <br /> Item 8 <br /> The EMCON borehole logs of wells E-1 (no longer exists) through E-12 do indeed indicate <br /> the presence of hydrocarbon odor in some of the boreholes. However, odors were not noted <br /> in wells E-7, E-8, E-10, or E-12. Hydrocarbon odors were noted only at the groundwater <br /> surface in wells E-3 (faint), E-4, E-5, E-9, and E-11. The other wells (E-1, E-2, and E-6) are <br /> well within the proposed remediation area. <br /> As stated in item 6, ARCO is proposing a number of soil vapor extraction wells in addition <br /> to the five wells presented in BCC's April 29, 1992, Final Remediation Plan (FRP). This <br /> proposed system should effectively remediate the hydrocarbon-affected soil at this site. <br /> Confirmation sampling will be conducted when the system has operated for a period of time. <br /> The County has accepted the FRP for both soil and groundwater as they are written. ARCO <br /> is proposing a soil vapor extraction system that is above and beyond the system proposed in <br /> the FRP. <br /> Based on the information contained in this letter, it is not necessary to conduct further <br /> characterization investigation, and further work at the site should be remediation—not further <br /> characterization. We request that the County rescind the request for a work plan for soil <br /> characterization. If this is not acceptable to the County, ARCO is requesting that a meeting <br /> be scheduled immediately among you, ARCO, BCC, and Gordon Boggs of the California <br /> Regional Water Quality Control Board, Central Valley Region, to discuss these issues. <br /> Brown and Caldwell 6746\C0RRESP6746-08.1_3 <br /> Consultants <br />