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Mr. Fernando Amador -5- 14 December 1995 <br /> 13. Page 4-12, Section 4.2.1.5, Borings Outside of Source Areas <br /> a. Northern Third <br /> The bulk of the contamination in other areas was found at approximately 25 feet bgs. <br /> However, the deepest sample from the former gas holder was taken only at about 13 feet bgs. <br /> On the other hand, MW-17 was sampled only at 100 feet bgs. The FS did not explain why <br /> B-5, MW-2, and SB-4 were not tested for TPHd/g. A sample should be taken in the storage <br /> building and at each of the former purifiers. If PG&E proposes not to sample these former <br /> facilities, the FS should provide the justification for not sampling. <br /> b. Middle Third <br /> The lateral contamination extent of SB-1-95, B-16, SB-1B, SB-21-95, B-14, and B-26 should <br /> be defined. Vertical definition is necessary at B-16, SB-IA, and B-14. A sample should be <br /> taken in the former lampblack separator and oil tank. The data for B-1 and MW-5 are not <br /> included in Table 4-6. The FS did not explain why SB-IA, SB-1B, unnamed boring location <br /> (28-33 feet bgs), MW-4, and B-2 were not tested for TPHd/g. <br /> c. Southern Third <br /> The FS should explain the rationale for the inconsistent sampling depths. For example, SB-5- <br /> 95 was sampled only at about five and 25 feet bgs, SB-6-95 was sampled only at four and 23 <br /> feet bgs, etc. Lateral definition is needed at B-7. The FS should explain why B-13, B-7, B-8, <br /> B-12, and B-10 were not tested for TPHd/g. The lateral and vertical extent of the <br /> contamination at B-7 should be defined. <br /> 14. Page 5-1, Section 5.1, Remedial Action Objectives <br /> The FS states that one of the objectives of the remedial action is to reduce the potential for <br /> migration of the constituents of potential concern (COPC) to ground water beneath the PG&E <br /> property. For clarification, the objective should state that the purpose of the remedial action is to <br /> reduce contaminant concentrations to levels which will not result in exceedance of water quality <br /> goals in ground water. <br /> 15. Page 5-1, Section 5.2.1, Federal and State Regulations and Guidelines for Soil <br /> The State Water Resources Control Board Resolution No. 92-49 should be included in this section. <br /> A copy of Resolution No. 92-49 (Attachment 2) is enclosed for your reference. <br /> 16. Page 5-2, Section 5.2.2, Remedial Action Goals for Soils <br /> The FS states that specific federal or state standards are not available for COPC in soil for the <br /> protection of human health and the environment. The beneficial-use protective numerical limits <br /> in ground water to protect municipal and domestic supply are presented in Attachment 3. PG&E <br /> should perform a water quality assessment using Dr. Jon Marshack's Designated Level <br />