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P 05 <br /> r <br /> Paragraph 4, (page 22, ) recommends excavation & surface bioreme- <br /> diation of the impacted soil , "This should alleviate any <br /> possible sourLw of hydrocarbons at the Morita Brost. site which <br /> may migrate toward groundwater. " i have the following comments on <br /> that recomau-ridat i on a <br /> (1) The extent of plume has not yet, been determined. <br /> (2) Thera is insufficient room on site to allow excavation to 50 <br /> feet. <br /> (3) Remadiation car- disposal costs would be prohibitive. <br /> CONCLUSIONS: <br /> 1,. The high levels of TPH-G found in the groundwater beneath the 1 <br /> property strongly suggests a major offsite source to the west or <br /> northwest, but does not preclude some contribution from detected 's <br /> contamination onsite. STEX and TPH-G were measured in soil <br /> samples below highest recent water, and within 5-10' of the <br /> present water table. <br /> 2. Insufficient analysis of soil samples from the 3 monitoring <br /> wells does not permit either verification of an offsite source <br /> for the contamination found in the groundwater, or the dstermi - <br /> nation of the lateral extent of the plume. <br /> 3. The Environmental Fate worksheets show that the levels of <br /> Benzene_, roivana, Ethylbenzene, and Xylane -found in the samples <br /> from the soil borings all exceed the limits allowed for leaving <br /> ill place. }`p, <br /> 4. Although the removal and remediation/disposal of the surface } <br /> soils that had high levels of BTEX & TPH-G to prevent further <br /> downward migration may be advisable, such action along will not <br /> allow sit closure. <br /> 0XI Hunter J <br /> att <br /> CC: i ke Collins, EHD � � ([ S) <br /> t - <br /> 4 <br /> it � � <br />