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Stantec , <br /> Addendum Remedial Action Plan — Former Tosco Bulk Terminal No. 10013 <br /> July 21, 2010 <br /> estimate of the TDS levels beneath the site can be derived (Freeze, R.A., and J. A. Cherry. 1979. <br /> Groundwater). During the first quarter monitoring and sampling event completed at the site, the <br /> average specific conductance (final reading prior to sampling) from all sampled wells was <br /> approximately 2,350 pmhos/cm, and when that average is multiplied by the conversion factor of 0.65 an <br /> estimated TDS of 1,525 mg/I is yielded. Applicable California drinking water standards list 500 mg/I <br /> TDS as a recommended value, 1,000 mg/I TDS as the upper limit, and 1,500 mg/I TDS as the short- <br /> term limit. This comparison suggests that groundwater at the site is largely non-potable. <br /> Due to these factors, basing the remedial objectives/site clean-up goals on California primary or <br /> secondary maximum contaminant levels is believed to be questionable. Stantec proposes to complete <br /> risk based modeling (ASTM E2081) to determine the appropriate site specific remedial <br /> objectives/clean-up goals. If approved by the CRWQCB-CVR, Stantec will perform the required risk <br /> modeling and present the results prior to the proposed end date of the ongoing oxygen injection <br /> activities in December 2010. <br /> Present background concentrations on which the proposed remedial objectives are based. <br /> If deemed warranted by the CRWQCB-CVR, Stantec proposes to collect groundwater samples from <br /> monitoring wells MW-6 and MW-10 to determine if results are deemed appropriate for use as <br /> background constituent of concern concentrations. If groundwater sampling results show non- <br /> detectable concentrations for the site related COCs, Stantec will perform additional sampling of MW-6 <br /> and MW-10 to assess select drinking water quality constituents and parameters including TDS, salinity, <br /> total coliforms, bromate, chlorite, chlorine, antimony, arsenic, barium, total chromium, lead, mercury, <br /> nitrate, nitrite, sulfate, iron, and selenium. If groundwater beneath the site is deemed not suitable for <br /> drinking water quality based on State of California criteria, Stantec proposes to move forward with case <br /> closure protocols based on a low risk criteria. <br /> Define the magnitude of the rebound that would tripper the contingency measures. <br /> Contingency measures are proposed to be implemented if the dissolved concentrations of the site <br /> related constituents of concerns (CDCs), including total purgeable hydrocarbons as gasoline (TPHg), <br /> total purgeable hydrocarbons as diesel (TPHd), benzene, methyl tertiary butyl ether (MtBE), or tert- <br /> butyl alcohol (TBA), rebound to concentrations five times greater than the site-specific risk-based clean- <br /> up goals for groundwater (to be determined through proposed risk modeling). <br /> Present a contingency plan should constituents of concern (COCs) rebound once the injections <br /> are discontinued. <br /> Following the conclusion of oxygen injection activities at the close of 2010, dissolved petroleum related <br /> concentrations will be tracked for rebound analysis along with monitored natural attenuation. If <br /> dissolved concentrations for TPHg, TPHd, benzene, MtBE, and TBA rebound to concentrations five <br /> times greater than the site specific risk based clean-up goals, bi-weekly oxygen injections will be <br /> reinitiated for six-months. After six months of oxygen injection activities, the dissolved concentrations <br /> will be reevaluated to determine whether continuation of remedial activities is necessary. <br /> 2 <br />