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Theresa Lanctot � <br />2651 S. Airport Way, StocTcron, California <br />Page 4 of 5 <br />Preparation and implementation of a work plan to complete the vertical assessment of <br />impacted groundwater; assess soil in the immediate area of contaminant release(s); <br />confirm effective remediation of vadose zone soil; and collect sufficient data to develop <br />an adequate hydrogeological model for the site — EHD suggests a CPT investigation to <br />develop the hydrogeological data and assess the vertical extent of impacted ground <br />water; <br />Inclusion of 1,2 -DCA and EDB in the analytical regime for samples collected during <br />future soil and groundwater sampling events; and <br />Collection of groundwater samples from the irrigation well for laboratory analysis for <br />the chemicals of concern to demonstrate that the well has not been impacted or is <br />influencing the plume of impacted groundwater. <br />The plume of impacted groundwater must be fully delineated in all directions. 1,2 -DCA should <br />be reported at 0.5 micrograms per liter, if possible. <br />Ideally, the work plan for the next phase of work should be presented in the context of an SCM. <br />Simply stated, the purposes for such a model are to demonstrate where the contaminants came <br />from, where they are at the present time, how they move through the subsurface, how they will <br />respond to changes in the groundwater flow characteristics or to potential remediation efforts, <br />what the contaminants' ultimate environmental fate will be, and to help evaluate the risk posed by <br />the contaminants to groundwater supplies and sensitive receptors. To be sure that the SCM will <br />adequately address the assessment, remediation and, ultimately, final closure requirements for <br />this site, please include the following items, as appropriate, in the SCM: <br />• Local and regional plan view maps with sources, boring and monitoring well locations, <br />lines of cross section, extent of contaminants in each media, direction and rate of <br />groundwater flow, and receptor locations, including water supply wells within 2,000 feet <br />of the site. <br />• Cross sections showing subsurface geological features, depth to groundwater, man-made <br />conduits, monitoring well construction and an interpretative drawing of the vertical extent <br />of soil and groundwater contamination. <br />• Cross -plots of key chemical concentrations verses time for representative wells that <br />demonstrate significant contaminant concentration trends. <br />• Summary tables of contaminant concentrations in the different media. <br />• Well and boring logs. <br />• A narrative description of the SCM that describes controls on contaminant distribution; <br />contaminant migration mechanisms, pathways, and rates; plume disposition over time; <br />and sorbed and dissolved contaminant masses. <br />While not necessarily showing all data in diagrams and drawings, an adequate SCM can be <br />utilized to account for most of the known data and to illustrate additional assessment needs. All <br />analytical data should be included in tables. Methods and calculations of contaminant masses <br />should be included in the SCM, and may be submitted as an appendix. The SCM should be <br />updated each time new data are acquired that causes a change of interpretation or expands the <br />model until model modifications are not needed to explain subsequently acquired data. As the <br />SCM becomes complete, it can be utilized to reasonably predict additional investigation results <br />and plume response to various remedial technologies or to changes in groundwater flow regime. <br />