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w <br /> Kristi Shelton <br /> Page 2 <br /> November 1,2007 <br /> The following remediation measures are currently being implemented. <br /> • Monitored natural attenuation(MNA). The naturally occurring nondestructive and <br /> destructive processes in the subsurface(1)limit the downgradient migration of <br /> hydrocarbon constituents in groundwater and(2)reduce the mass of residual <br /> hydrocarbon residuals in the vadose and groundwater zones,both in the former <br /> pipeline release"source area' and the areas downgradient of the source area. MNA was <br /> implemented with a 3-year pilot study that began in 2004 with shutdown of the active <br /> remediation systems(SVETS,GWETS). The pilot study concluded in 2007 with <br /> collection of the first quarter 2007 groundwater monitoring event. The aboveground <br /> portions of the SVETS and GWETS were removed from the site as approved by the <br /> RWQCB based on the positive results of the pilot study. The results of the pilot study <br /> are documented in the 3-Year Bioremediation Pilot Study Evaluation Report submitted to <br /> the RWQCB(CH2M HILL,2007a). <br /> • Phytoremediation. The maturing root system from the tree system planted in 2005 and <br /> 2006 in the"source area" will enhance the naturally occurring process described above. <br /> This will limit the downgradient migration of hydrocarbon constituents in groundwater <br /> and reduce the mass of hydrocarbon residuals in the vadose and groundwater zones. <br /> The phytoremediation system was constructed and is currently maintained as described <br /> in the Cleanup Plan Using Phytoremediation for the Source Area(CH2M HILL,2004). <br /> Construction of the phytoremediation system is documented in the following as-built <br /> reports submitted to the RWQCB: Phytoremediation As-Built Report(CH2M HILL,2005a) <br /> and Phytoremediation As-Built Report, Construction Season 2 (CH2M HILL,2007b). <br /> The recently submitted Second Semiannual and 2007 Annual Groundwater Monitoring Report <br /> documents current groundwater conditions at the Site(CH2M HILL,2007c). This report <br /> was submitted to the RWQCB on October 31,2007. Attached Figures 3,4,and 5 from this <br /> report present contour maps of the groundwater table elevation,total petroleum <br /> hydrocarbons,gasoline-range organics (TPH-g)concentrations,and benzene concentrations <br /> in groundwater for third quarter 2007 monitoring data,respectively. <br /> The current remediation activities(MNA,phytoremediation)and recommendations for <br /> future site management activities were discussed with the RWQCB at two meetings held on <br /> July 12,2007,and September 21,2007. As agreed at the September 21,2007,meeting,the <br /> RWQCB will provide a draft M&RP that will revise current M&RP No. R5-2004-0803 to <br /> incorporate the recommendations in the 3-Year Bioremediation Pilot Study Evaluation Report, <br /> after the RWQCB receives the Second Semiannual and 2007 Annual Groundwater Monitoring <br /> Report(CH2M HILL,2007c)and a work plan(this work plan)to destroy the select <br /> groundwater monitoring and extraction wells as recommended in the 3-Year Bioremediation <br /> Pilot Study Evaluation Report. As noted above,the Second Semiannual and 2007 Annual <br /> Groundwater Monitoring Report was submitted to the RWQCB on October 31,2007. <br /> ES102007015SCO/HOLT-WORK-PLAN-LETTER-WL369.DOC/073050005 <br /> COPYRIGHT 2007 BY CH2M HILL,INC.•COMPANY CONFIDENTIAL <br />