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• Excavation is not logistically feasible due to the deep soil impacts(as deep as 50 fbg). <br /> In addition, proximity to overhead utilities,existing structures, and fuel dispensing <br /> equipment present additional logistical challenges due to potential impacts <br /> excavation may have to their integrity. <br /> • Monitored natural attenuation (MNA) is an effective means of remediating TPHg <br /> and benzene, which are the primary COCs at this site. Typically, MNA is very cost <br /> effective since it allows hydrocarbons to degrade naturally and does not require <br /> active remediation. CRA stated in the December 9, 2009 CAP that natural <br /> attenuation would not be effective at this site because COC concentrations were not <br /> decreasing. However, the above analysis of COC trends shows that hydrocarbons <br /> concentrations in groundwater are now decreasing in all wells with two noted <br /> exceptions(MW-14 and VEW-4). <br /> 5.0 DISCUSSION <br /> Since the release was discovered at this site, the release has been stopped, free product <br /> has been removed, secondary source material has been remediated to the extent <br /> practicable, the hydrocarbon plume shows declining concentration trends and appears <br /> to be retracting. Sensitive receptors have been assessed in the vicinity of the site and <br /> there are no receptors threatened by the hydrocarbon plume. The plume is located <br /> primarily beneath the subject site and may also extend beneath part of Pacific Avenue. <br /> Hydrocarbon concentration trends in well VEW-4, which is screened in the C-zone, <br /> indicates a declining trend for TPHg,but a fairly stable trend for benzene. VEW-4 is the <br /> most downgradient well in the C-zone,but is also located in the source area (the former <br /> UST area). Recent data collected from soil borings (SB-7 through SB-10) drilled in the <br /> southeastern portion of the site indicates that elevated hydrocarbon levels are located in <br /> the C-zone in the southeastern portion of the site. Since the extent of hydrocarbons in <br /> the C-zone has not been delineated downgradient of VEW-4, CRA believes additional <br /> assessment is warranted. We expect this assessment will provide repeatable data to <br /> demonstrate the downgradient extent of hydrocarbons in the C-zone and over time will <br /> show declining concentration trends in the C-zone. <br /> 6.0 RECOMMENDATIONS <br /> Because the hydrocarbon plume beneath this site appears to be a stable or shrinking <br /> plume and no receptors are threatened by the plume, further active remediation of the <br /> plume is not warranted. CRA believes MNA is an appropriate remedial option for this <br /> 5 CONESTOGA-ROVERS&ASSOCIATES <br /> 240959(29) <br />