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) 11 <br /> 3.2 Compliance Contingency Plan <br /> Use of a compliance contingency plan for migration is proposed as part of designating a <br /> WQLZ The contingency plan has two primary components, a trigger methodology, and tng- <br /> ger activation response strategy Figure 10 shows the steps to be followed under the trigger <br /> activation response strategy As a first step in developing the compliance contingency plan, <br /> the compliance boundary is defined <br /> 3.2.1 Compliance Boundary <br /> The compliance boundary is a conceptual boundary at which dissolved hydrocarbon concen- <br /> trations are monitored for the purpose of identifying trends which indicate hydrocarbon <br /> impact migration is occurring The proposed site compliance boundary is shown on <br /> Figure 11 The downgradient compliance boundary monitoring system will be comprised of <br /> proposed Wells MW-15, MW-16, MW-17, and MW-18 An upgradient set of wells will be <br /> used to monitor the groundwater quality entering the proposed WQLZ The upgradnent well <br /> set will consist of existing Wells MW-2R and MW-10, and proposed Wells MW-19 and <br /> MW-20 <br /> 3.2.2 Ongoing and Future Groundwater Monitoring <br /> Monitoring of the site groundwater monitoring wells will continue in accordance with the <br /> existing schedule The purpose of the monitoring program will be to monitor groundwater <br /> quality and to continue to evaluate plume stability and degradation The monitoring schedule <br /> will be reviewed periodically, proposed changes to the schedule will be submitted for review <br /> and approval <br /> 3.2.3 Trigger Methodology <br /> The purpose of the trigger methodology is to provide a procedure for initiating action in the <br /> event it appears migration of dissolved hydrocarbons threatens groundwater quality outside <br /> the compliance boundary A process is outlined to evaluate groundwater monitoring data <br /> with the purpose of defining groundwater quality trends Trigger activation will be based on <br /> trend observations <br /> 3.2.4 Data Analysis <br /> Data analysis will be performed using historical and current groundwater monitoring data and <br /> the results will be used to identify a trigger condition The analysis method is outlined below <br /> Linear regression techniques will be used to develop the relationship between dissolved <br /> hydrocarbon concentrations and time (in most cases an exponential decay of dissolved hydro- <br /> 3201337B/1918REV 13 August 31, 1995 <br /> i <br />