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Rantec Work Plan for Amended Bioremediation Pilot Study BP Terminal 40T November 10, 2008 In the event that concentration levels of sulfate exceed the baseline levels by more than 20% at the point of compliance, AR/MW-1 A, the following steps will be taken: • Sulfate injections will be put on hold; • AR/MW-1A will be re-sampled and analyzed to verify the concentration levels; • If levels still exceed the concentrations limits, a monthly monitoring program will be introduced; • If the trend is stable at a concentration above background or increasing after three months the use of injection will be reevaluated; and • The wells will be monitored bi-weekly until the levels fall below the concentration limits, at which time the groundwater treatment system will be stopped. Transport Evaluation Stantec proposes adding a tracer compound, such as bromide, to the injection solution in order to evaluate the rate of transport at the site. This information will be used to determine the injection well design for a full scale system. All A-zone wells will be sampled for the tracer compound monthly in order to determine the rate of transport. Baseline Parameters The objective of the sulfate injection plan is to elevate the level of these compounds in the impacted zone. URS submitted revised baseline levels during their pilot study. These levels are proposed for use during this expanded pilot study. If the baseline levels shown below are exceeded by 20%, the corrective actions indicated above will be implemented. Compound Proposed Baseline Level m /L Calcium 70.9 Sulfate as SO4 27 Total Suspended Solids 680 Total suspended solids concentrations will be determined based on background evaluations that are currently scheduled to be collected during the first week of November. A status letter will be submitted with the results confirming what BP requests as Baseline Levels. Reporting Performance evaluation reports will be prepared and submitted on a quarterly basis during the pilot study. A summary report for will be prepared and submitted to the RWQCB upon completion of the pilot study. The report will document field activities, present field and analytical data, and provide conclusions and recommendations. Waste Discharge Requirements Upon RWQCB approval of this work plan and concurrence with Baseline Levels, BP will file a Notice of Intent to Order No. R5-2008-0149 Waste Discharge Requirements General Order for In-situ Groundwater Remediation at Sites with Volatile Organic Compounds, Nitrogen Compounds, Perchlorate, Pesticides, Semi-volatile Compounds, Hexavalent Chromium and/or Petroleum Hydrocarbons within 45 days. 40T Work Plan for Amended Bioremediation Pilot Study.doc 8