SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

CLEARWATER " : G .0 U' P, I N "C. Points raised in your letter,are re-iterated below: Paragraph-three states that Cummings letter.dated July 15, 1993.documents.that he intended to apply for an aeration permit for the soil that had been transported ` A)o . to 1111 North Union Street., You stated"that no .documentation of aeration was. provided.. The SJCAPCD issued- a permit to aerate to Mr.'Clark on September 30, ` 1993. Your letter also acknowledges ,that.,John; Cummings claims to- have witnessed the aeration of the soil. • Paragraph four states that PHS/EHD'staff estimated quantities 'of soil present at 729 South Commerce Street prior to transport-to"1111 North Union Street, and at the Union Street,site on'September-9;-1993. PHS/EHD staff estimated a difference _ in, soil.-pile :volume -:equel- to 30G-400 cubic=-yards -t our-recent,_,.tel`epnone. ,- conversation you stated,that-you were the PHS/EHI)t staff member who .recorded these observations. The inspection reports .referenced in your letter were not provided. . . • Paragraph five addresses' the. description' .of soil "contamination levels i n .materials excavated during tank removal as "low" (Cummings, letter, March .8, 1994). .You take issue with this`characterization. No objective criteria".is provided UO to. quantify this difference in opinion.- F ' Paragraph ,,eight requests additional stock ile sampling and - anal sis: '. You rtt- indicate fi that the EPA Methods for Evaluating Solid Waste should be,used as a guide in developing the sampling plan. ' You also indicate- that the PHS/EHD,, requests discrete sampling of stockpiles at'a.ratio of one sample per 25,cubic"yards, . or one sample per 20 lineal feet in cases "of excavation or piping, sampling for underground storage tank investigations". Finally,.you statedthat recent rainfall established the need for the sampling of native soil beneath the existing soil pile. " Paragraph nine indicates that soil samples 'are to be analyzed for concentrations of metals, TPH-gasoline; TPH-diesel, BTEX, and chlorinated solvents . It should be noted that no mention is made of the PHS/EHD opinion of the t l fad/ sampling 'conducted. by Cummings :following the aeration .of:the pile at' 1111 � y North Union Street In our January telephone- •conversation you 'indicated that your main concern centered around your estimation of,soil stockpile volume at 729'South Commerce Street and- 1111 North `Union Street (and 'the'.estimated difference 'between, the' volume:of the two piles): You .stated that you felt that the estimated difference in the volume of the soil piles may have been.associated,with the addition of soil that originated- at ' another' off-site source.` The request' -for additional , stockpile characterization was based on'this concern. . ' Clearwater.has .reviewed' the stockpile characterization options you listed in your letter. Results' of our- analysis, and.a ,recommended.'plan of.action,,. are presented below: : ,