SITE INFORMATION AND CORRESPONDENCE FILE 2

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Page 2 of 4 relevant data for remaining fuel impacts to soil and groundwater, then computing the averages, 95%upper confidence limit(UCL)values and maximums. These concentrations will then be evaluated against established ESLs for direct exposure, vapor intrusion into a building, and nuisance conditions. The ESL Surfer has two categorizations for land use and two for soil type. Entering the health risk analysis step of work we will see if the site data passes the more conservative criteria of each; i.e., residential (vs commercial/industrial) and permeable (vs limited permeability). This is desired to avoid restrictive conditions being placed on the no further action required(NEAR) designation we are all hoping to achieve. Based on the outcome of the ESL analyses, we wilt prepare the health hazard assessment write- up,which at this juncture is envisioned to be part of the next quarterly monitoring report, but could be a stand-alone technical document. Within the bounds of what is reasonable and justifiable, the write-up will be an advocate for NFAR. For example, site soils may not classify as clearly `low permeability' but they don't have high permeability either, so a mid-point ESL may be most appropriate. Also, it is often overly conservative to use maximum concentrations when those reflect only a very limited spot in the overall site area. Citing precedents where higher concentrations were acceptable at other fuel leak sites may also be helpful in the cause. Once the Cox clan gives us the ok to incur the expense we will get to work reviewing the old data and making our case. In the end if more testing and delineation is required then hey that's the way it is and my bravado will end up as egg on my face. Won't be the first time or the last0. John -----Original Message----- From: Mike Infurna [EH] [mailto:MInfurna@sjcehd.com] Sent: Tuesday, August 22, 2006 1:29 PM To: John F. Lynch Subject: RE: Mr. Ed's Muffler/Cox and Cox-UPDATE-Project Information-595 E. 11th St. Site Code 1933 good work John.. way to follow up on the pre-reqs I can't seem to find your email that refers to 1,2-DCA and EDB. These two constituents were noted in my June 27 letter and I'm SURE you've got it handled, that is, included in the next sampling events. I don't want to rain on your parade, but constituents aside, I would think your Vapor Intrusion (VI) investigation may pose a significant schedule- buster to your NFAR scheduling. With so many mobile homes so close, this site qualifies as a concern to residential occupants. but then again, the air space under each is a help too. In my experience with Tier 1 soil evaluations, most sites with any residual contamination left fail. Going to models to support your case is timely and uses the soil data you already have. It's been a while since any lateral soil investigation has been done at this site and only the old MW installation soil 8/23/2006