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June 30, 1995 `'' •.� <br /> Page 8 <br /> 6. The chlorinated plume has been documented from other sources at <br /> the Lincob7 Center. <br /> No comment. <br /> 2.5 Remediation <br /> 1. Tank removal and replacement is not a remedial action. Post reme- <br /> dial monitoring is not a valid approach for the site. <br /> Although removal of the former USTs in itself is not a remedial action, <br /> removal of the hydrocarbon-affected pea gravel surrounding the <br /> -former tank complex is a remedial action. Further, given the low <br /> degree of hydrocarbon impact beneath the site and the likelihood that <br /> hydrocarbon impact may have originated from product delivery opera- <br /> tions, it is possible that these soils were the primary source of hydro- <br /> carbon impact. <br /> 2. Residual soil contamination continues to threaten andlor impact <br /> groundwater quality and requires remediation via implementation of <br /> an approved corrective action plan. <br /> Data collected to date does not indicate that significant hydrocarbons <br /> exist in vadose zone soil beneath the site, as previously discussed. An <br /> additional three soil borings in the area of the former product piping <br /> are proposed to further support this conclusion. A corrective action to <br /> address remediation of vadose soils at this time is not warranted. <br /> 3.0 ENVIRONMENTAL, PUBLIC HEALTH, AND SAFETY GOALS <br /> 1. The list of beneficial uses in the CAP were incomplete. <br /> The list of beneficial uses, while incomplete, included the relevant uses <br /> and the most stringent uses from a water quality goal perspective. <br /> 2. The 1986 LUST manual includes detection limits for benzene and <br /> toluene that are less than the concentrations listed in the CAP. <br /> The detection limits listed in the CAP were denoted as reasonable <br /> detection limits. These detection limits are practical quantitation limits <br /> determined to be an industry standard by state certified laboratories. <br /> 32013570CAPLET.DOC.doc <br />