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,low <br /> 139 South Center <br /> Page 2 <br /> migrating. Chevron's most recent correspondence dated April 28, 1997 stated that there is insufficient <br /> information regarding the transport mechanisms and the downgradient extent of the groundwater plume, <br /> and yet Chevron is able to make certain inferences about plume migration rate(3 feet per year)and <br /> dimensions. <br /> PHS/EHD understands that the station has been in operation since 1969 and that the leaking tanks were <br /> removed in 1990. During the investigation, contamination had migrated to MWS, located approximately <br /> 200 feet from the former tank pit. PHS/EHD questions how the plume migration rate was calculated <br /> given the plume size currently known and the dates of operation. Generally, groundwater velocities are <br /> determined after hydrologic studies have been completed. If aquifer testing has been performed at this <br /> site,the results should be submitted immediately. <br /> Please note that the map that PHS/EHD received,with permits, included the location of the boring, <br /> SB 10,that Chevron has requested. The"Addendum to Work Plan for Well Installation"dated October <br /> 17, 1996, indicated that selected soil samples would be analyzed for water content, bulk density, <br /> porosity, and fractional organic carbon content. The location of this proposed upgradient soil boring is <br /> approximately 25 feet southeast of SB3 and 15 feet northeast of SB4. SB3 and SB4 were drilled and <br /> sampled at the direction of PHS/EHD to determine the extent of soil contamination associated with the <br /> former underground storage tanks. Soil contamination of 2.0 ppm TPH-gas and 0.18 ppm benzene was <br /> detected only in soil samples collected from S133 at 40 feet below ground surface(bgs). However, <br /> significant contamination of up to 15,000 ppm TPH-gas and 160 ppm benzene was evidenced in the soil <br /> sample collected from S134 at 43 feet bgs. At the time that S133 and S134 were drilled,May 13, 1994,the <br /> depth to water was approximately 42 feet bgs. The vertical extent of soil contamination in the former <br /> tank pit area is unknown. <br /> PHS/EHD suggests that if contamination is detected during the installation of SB 10 that there be careful <br /> evaluation of total organic carbon results and that TCLP analysis is performed. Given that groundwater <br /> was most recently reported at 25 feet bgs and that all of the on site wells are screened between 35 and 60 <br /> feet bgs and have submerged screened intervals, and that PHS/EHD has requested the installation of <br /> wells to evaluate the feasibility of remedial alternatives,PHS/EHD hereby directs you to convert this <br /> proposed soil boring into a monitoring/remedial testing well and that PHS/EHD be contacted following <br /> the completion of drilling activities to discuss the soil samples that will undergo analysis. Additional <br /> remedial testing wells will be necessary,but it would not be cost effective to drill and grout a soil boring <br /> given the site conditions. <br /> Intrinsic Bioremediation Parameters and Groundwater Monitoring Requirements <br /> The groundwater samples that were collected on February 27, 1997 were analyzed for ferrous iron(Iron <br /> II), nitrate,phosphate, sulfate and sulfite. Anaerobic biodegradation can be indicated by changes in the <br /> concentrations of Iron II that indicates anaerobic biodegradation and by concentrations of nitrate and <br /> sulfate, that act as an electron acceptors for anaerobic respiration. <br /> These initial analytical results were not included in the summary table. When PHS/EHD tabulated the <br /> results in terms of contaminated verses uncontaminated wells, no clear correlation could be made <br /> regarding the biogradation potential at the site. It is unlikely that another single sampling and analysis <br /> event will provide adequate information to evaluate the biogradation potential at the site. <br />