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Mr. John Kiel -3- 27 August 1992 <br /> poses an unnecessary safety risk, and the excavation serves as an open <br /> conduit to ground water. <br /> As stated in Item 3 above, contaminated soils that can be removed, <br /> should be removed, and free product, if present, should be recovered <br /> prior to backfilling. Warning signs and barriers could be placed while <br /> contaminated soil is removed and free product is recovered. It is <br /> unclear why the existing excavation is a safety risk and a conduit to <br /> ground water while the proposed excavation for backfill material would <br /> not be. <br /> 6. The letter states six soil samples were composited into two soil <br /> samples and analyzed for total extractable petroleum hydrocarbons <br /> (TEPH) ; benzene, toluene, ethylbenzene, and xylene (BTEX) ; total <br /> threshold limit concentrations (TTLC) ; and soluble threshold limit <br /> concentrations (STLC) . The test methods or constituents tested are <br /> appropriate. However, compositing soil samples and testing for BTEX, <br /> which are volatile compounds is inappropriate. Furthermore, the <br /> sampling frequency is not specified. We recommend that one grab sample <br /> per 50 cubic yards be taken for testing of the constituents specified <br /> above. <br /> By 9 September 1992, please respond to the comments in this letter and provide <br /> a submittal date for a complete site assessment report. Also, we request that <br /> you inform us at least 48 hours prior to any sampling event so that we may be <br /> present to observe procedures or take split samples. <br /> If you have any questions, please call me at (916) 361-5650. <br /> PHIL I, S. ISORENA��✓ <br /> Sanitary Engineering Associate <br /> PSI : ldj <br /> cc: Ms. Diane Hinson, San Joaquin County Public Health Services <br /> Mr. John Weiss, Libbey-Owens-Ford Company, Lathrop <br /> Condor Earth Technologies, Turlock <br />