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4 <br /> receptors. The work plan also described Chevron's subsequent plans to evaluate the necessity of remedial <br /> feasibility studies upon its review of the data collected during work plan implementation. <br /> The work plan addendum(10/17/96) submitted by Pacific proposed relocating the originally proposed <br /> monitoring well such that downgradient contaminant plume definition would be accomplished. The work <br /> plan addendum also proposed a soil boring that would obtain soil samples for the purpose of better <br /> characterizing exposure pathways beneath the subject site. The work plan addendum described the scope <br /> of work as being part of a phased, cost-effective approach toward corrective action that is based on actual <br /> risk. The work plan addendum again,emphasized that Chevron would evaluate the feasibility of remedial <br /> alternatives as soon as the associated risks were characterized and the appropriate level of remedial action <br /> was determined. <br /> Submit a map indicating proposed well/boring locations,work plan amendment including feasibility <br /> study,and permit applications/fees and encroachment permits. <br /> Chevron's consultant,Pacific Environmental Group,Inc.,will submit a revised site map to your agency <br /> on April 28, 1997. The revised map will indicate the new locations of the proposed monitoring well and <br /> soil boring. On that day Pacific will also submit the necessary well/boring permit applications and <br /> associated fees. The encroachment permit application for the proposed monitoring well is still being <br /> reviewed by Caltrans. A copy of this permit will be submitted to your agency as soon as it is received. The <br /> City of Stockton has deferred all encroachment/permitting issues relating to the proposed monitoring well <br /> to Caltrans. However, the City of Stockton will be notified of the proposed well location and of the <br /> planned drilling schedule. <br /> As discussed above, Chevron feels that it would be premature at this time to perform any feasibility testing <br /> of remedial alternatives. As such, there are no plans to amend the existing work plan to include remedial <br /> alternative feasibility testing. However, Chevron is committed to performing a feasibility evaluation of <br /> remedial alternatives. As results from the proposed scope of work are known and associated risks are <br /> characterized, a corrective action plan will be developed which will include a feasibility study of <br /> appropriate remedial alternatives. <br /> Chevron requests for groundwater monitoring program changes are denied. <br /> Prior to making the recommendation to modify the groundwater monitoring program at the subject site, <br /> Chevron reviewed the historic site data to answer the following questions.Have all contaminants of <br /> concern been identified?Has the extent of contamination in groundwater been adequately defined?Does <br /> the groundwater investigation data provide enough information to determine the most cost-effective plan <br /> of remedial action?The answers to these questions are provided below. <br /> Knowledge about the primary source of contamination combined with seven years of soil and groundwater <br /> investigation at the subject site have provided Chevron a thorough understanding about the contaminants <br /> of concern. <br /> The adequacy of groundwater contaminant plume definition at the subject site should be evaluated in <br /> terms of understanding the transport and migrational tendencies of the contaminant with respect to <br /> potential receptor locations and health risk. This comes down to knowing the direction,velocity,and <br /> distance the contaminant will migrate and knowing where any potential receptors are. The direction of <br /> groundwater(contaminant)flow at the subject site has been toward the southeast. This flow direction has <br /> been consistent throughout six hydrologic cycles. As such, the migrational direction of the contaminant <br /> plume is well understood by Chevron. Considering the soil types within the water bearing zone beneath <br /> the subject site, it would be reasonable to estimate a groundwater flow velocity of no more than three feet <br /> per year. However at this time, Chevron has little knowledge about the location of sensitive receptors in <br /> the vicinity of the subject site. <br />