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Wendy L. Cohen -2- 16 February 1994 <br /> Comments <br /> RESNA's proposed cleanup level/.bioremediation goal is-80 mg/kg TPH as oil.and grease <br /> (TPHOG). This value was a health-based cleanup level established for the City of Tracy, Schulte <br /> Road Extension project, by the Department of Tonic Substances Control. In that investigation, a <br /> case was made that impacted soils with those concentrations were not a threat to ground water due <br /> to various site-specific factors. The same evaluation of a tlmmt to ground water needs to be done <br /> for the Belconte North Subdivision, before a cleanup level = beset. The proposal also calls for <br /> analyses using the standard 5520 E/F method for TPHOG which is not appropriate. The preferred <br /> method for TPH is EPA Modified 8015. Another round o ground water gauging also should be <br /> done with a longer wait following any purging to obtain a inore accurate gradient direction. <br /> It has been over a year since this work plan was submitted, and it has not been implemented. <br /> J1VIW:jmw/ldj <br />