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.1 <br /> no gasoline hydrocarbons have migrated vertically through the <br /> soil beneath a depth of 30 at the property. " is not true. As <br /> shown above, TFH-G was detected in 3 of the soil borings at 30 , <br /> 35 & 40 ' bgl . It is true that gasoline was not measured in any <br /> of the other borings, but it was present below 350 ' . <br /> The statement made in paragraph I on page 21 -. . "gasoline <br /> hydrocarbons detected in the groundwater are not a result of <br /> release from the gasoline tank at Morita Phos. , but is a result <br /> of migration from an offsite source which has been confined <br /> within this water zone, " may be partly true, but the results of <br /> the lab analysis of the soil borings indicates that contamination <br /> from the leaking tanks on the property most likely has also <br /> impacted the groundwater beneath the site. <br /> In paragraph 2, page 22, a statement is made that the source of <br /> the gasoline hydrocarbons found in the groundwater may be the <br /> result of an offs1to source. That idea is supported by saying <br /> that there is confining zone above the groundwater, and " . . . 30 <br /> feet of vertical separation between the deepest known known <br /> impacted soil at the site and groundwater. " Groundwater was <br /> • measured in the three monitoring wells on the property at about <br /> 54 'bg 1 ; TFH--G was found at 40 'bg 1 in the soil bor-i ngs, and <br /> Benzene & Toluene were detected as deep as 50'bgl . Erased on <br /> County maps, the water table was at 35 'bgl in 1986. Therefore, <br /> the statement made in the report is not true. <br /> During the placement of the monitoring wells, it was reported <br /> that soil samples were collected at 5 foot intervals from 5 'bgl <br /> to total depth , and preserved for laboratory analysis. A FID <br /> meter was used to screen each sample, and according to the logs <br /> included in the report, all readings were below instrument <br /> measurement levels. Only the samples at 55 ' & 65 ' bgl were taKen <br /> to the lab for analysis. The disposition of the other preserves <br /> samples is not noted. It is assumed that because the HID meter <br /> did not measure any hydrocarbons, the person on site decided that <br /> none of the samples were contaminated. Tnerefore, none of the <br /> samples above 55 ' were analyzed. <br /> Even when FID meters are accurately calibrated, the readings are <br /> not reliable or accurate enough to be used for determining <br /> whether or not a sample is contaminated. FID and other indirect <br /> methods of measurement are not accepted by environmental health <br /> agencies as evidence of lack of contamination - laboratory <br /> analysis must be used for confirmation. Therefore, it is not <br /> possible to state that the soil samples taken during placement of <br /> the monitoring wells were clean. <br /> i <br /> 3 <br />