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James L. Tjosvold, P.E. <br /> August 19, 1996 <br /> Page 12 <br /> The sampling program is inconsistent in sampling depths and types of analyses performed. <br /> Following are the sample locations and their sampling intervals:MW-9:2.6-40.5 feet bgs; <br /> MW-19:50 and 100 feet bgs; SB-2-95 and SB-3B:3-8 feet bgs; SB-3-95:11.5-12 feet bgs; SB- <br /> 4-95: 10.5-20 feet bgs; and SB-23-95:7.5-24 feet bgs. At MW-9, soil samples were analyzed <br /> for total PNAs and total petroleum hydrocarbons as diesel (TPHd) at the first sampling <br /> depth of 2.6-3.0 feet bgs. At the next sampling depth of 3.0-3.5 feet bgs, the sample was <br /> tested far total volatile organic compounds (VOCs) and TPH as gasoline. This alternating <br /> sampling procedure was used throughout the sampling depth. <br /> As a result, the vertical extent of contamination has not been identified. For example, at <br /> 24.0-24.5 feet bgs, total PNAs and TPHd were detected at 1,875 and 5,425 mg/kg, <br /> respectively. The next available data for total PNAs (1.28 mg/kg) and TPHd (9.68 mg/kg) <br /> were taken from the interval at 35.0-35.5 feet bgs . Thus, there are more than 10 feet of <br /> undefined soil layer beyond the point where the highest concentrations of total PNAs and <br /> TPHd were detected. If remediation is proposed to go down to about 35 feet bgs, at least in <br /> this particular spot,fitrther characterization will not be necessary since remediation will <br /> address the interval which lacks data. MW-19 was not tested for total VOCs. SB-3B was not <br /> tested for TPHd/g. <br /> Table 4-1 lists 'Total VOCs' as one of the column headings. The table should define 'VOCs'. <br /> The term is typically associated with solvents such as carbon tetrachloride, <br /> tetrachloroethylene, trichloroethylene, etc. If the table is referring to aromatic compounds <br /> associated with petroleum hydrocarbons, the term 'BTEY is more appropriate and should <br /> be used. <br /> The lateral and vertical extent of soil contamination in S1 has not been defined except to the <br /> east of 5-23-95. To the west, MW-12 may define S1's lateral and vertical extent. However, I <br /> could not find the soil sample results for MW-12 in Appendix B which contains the soil <br /> data for the site. To the north is MW-9. As stated above, MW-9 is highly contaminated at <br /> about 25 feet, lacks data for 10 feet beyond this depth and is still contaminated at 35 feet. <br /> Lateral and vertical definition of this contamination to the north is necessary. To the south, <br /> SB-3B and SB-3-95 were sampled at maximum depths of only eight and 12 feet bgs, <br /> respectively. Laterally, the definition of the extent of contamination is acceptable. However, <br /> the data are limited to make a determination of the vertical extent. <br /> Response: <br /> 9. Source area 1 (Sl) is the location of a former gas holder and two former <br /> underground fuel storage tanks. The lateral and vertical extent of Source Area 1 <br /> was determined by data from the following seven borings: MW-9, MW-19, SB-3B, <br /> SB-2-95, SB-3-95, SB-4-95, and SB-23-95. As discussed in the general comments <br /> above, analytical data, in conjunction with boring logs, visual observations during <br />