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Paragraph Q, (page 22, ) recommends excavation & surface bioreme- <br /> diation <br /> ioreme- <br /> diation of the impacted soil . "This should alleviate any <br /> possible source of hydrocarbons at the Morita Bros. site which <br /> may migrate toward groundwater. " I have the following comments on <br /> that recommendation: <br /> ( 1 ) The extent of plume has not yet been determined. <br /> (2) There is insufficient roam on site to allow excavation to 50 <br /> feet. <br /> (Z) Remediation or disposal costs would be prohibitive. <br /> CONCLUSIONS: <br /> 1 . The high levels of TPH-G found in the groundwater beneath the <br /> property strongly suggests a major offsite source to the west or <br /> northwest, but does not preclude some contribution from detected <br /> contamination onsite. BTEX and TFH-G were measured in sail <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 = monitoring <br /> wells does not permit either verification of an offsite source <br /> for the contamination found in the groundwater, or the determi- <br /> nation of the lateral extent of the plume. <br /> 3. The Environmental Fate worksheets show that the levels of <br /> Benzene, Toluene, Ethylbenzene, and Xylene found in the samples <br /> from the soil borings all exceed the limits allowed for leaving <br /> in place. <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 alone will not <br /> allow sit closure. <br /> Pill Hunter <br /> att <br /> cc: ike Collins, EHE) <br /> 4 <br />