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October 30, 1997 <br /> Page 5 <br /> • •• drilling of multiple soil borings to evaluate remaining contamination in the <br /> VES treatment area, <br /> • installation of air sparge wells to address any soil contamination in the - <br /> saturated zone and remaining groundwater,contanunation, and <br /> • continued groundwater monitoring ` <br /> In a letter dated September 12, 1997, Tosco stated their position that a single soil boring <br /> and replacement of one downgradient perimeter monitoring was sufficient to meet <br /> PHS/EHD's requirements A work plan dated September 12, 1997, was prepared by <br /> GeoStrategies and subrrutted to PHS/EHD In the September 12, 1997 letter, Tosco <br /> further concluded that the dissolved hydrocarbon plume appeared stable, and based on <br /> groundwater monitoring data, the site should be considered for low-risk closure In a <br /> letter dated September 26, 1997, PHS/EHD responded that they could not agree the <br /> dissolved hydrocarbon plume was stable and reconfirmed that additional assessment <br /> work would be necessary A work plan addendum was required by October 15, 1997 <br /> In a site meeting on October 10, 1997, Ms Mary Meays of PHSIEHD reconfirmed the <br /> request that Tosco replace all abandoned perimeter wells and drill multiple soil borings in <br /> the VES area Ms Meays indicated that the PHS/EHD uses risk assessments only for <br /> case prioritization and not for consideration of case closure Tosco requested that <br /> PACIFIC review the case and make recommendations regarding further assessment of <br /> the site In a letter dated October 14, 1997, PACIFIC confirmed that the site met the <br /> criteria for low-risk groundwater case closure . <br /> EVALUATION OF SITE FOR CLOSURE (1.G.) <br /> PACIFIC requests that the Fund Manager consider the following current site conditions <br /> when evaluating the site's eligibility for closure <br /> • The leak has been stopped Facility tanks were upgraded in 1988 with <br /> the installation of double-wall USTs Dispensers and associated piping <br /> were upgraded in 1994 <br /> • Impacted soils have been remediated to the degree practical Initial <br /> excavations in 1988 removed approximately 1600 cubic yards of <br /> hydrocarbon-impacted soils to depths of 18 to 22 feet bgs In 1994, <br /> an additional 150 cubic yards of impacted soil were removed from . <br /> dispenser and piping areas A VES subsequently removed a large <br /> amount of remaining mass of TPH-g and benzene from soils beneath <br /> 3111657A\CL.6981 DOC <br />