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d'ARR ASSOCIATES <br /> Randall A. Hays, Esq. <br /> August 21, 1997 <br /> Page 2 <br /> and that a groundwater monitoring well be installed in the immediate downgradient vicinity of <br /> the empty drum&hazardous material storage area to further evaluate groundwater quality. <br /> 3. The Workplan specifies that four soil vapor points are to be located along South <br /> Sacramento Street adjacent to the subsurface sewer system. <br /> Farr Associates recommends that soil vapor points along South Sacramento Street be located <br /> adjacent to every Holz sewer lateral connection to the municipal sewer and storm water,vstem. <br /> 4. The Workplan does not specify actual decontamination procedures for field equipment <br /> Farr Associates recommends that in order to reduce the potential for cross-contamination, the <br /> downhole sampling equipment should be pressure-washed with a steam cleanerlhot pressure <br /> washer prior to beginning drilling and between borings Equipment rinseate generated during <br /> the investigation should be contained in SS-gallon U.S. Department of Transportation(DOT) <br /> approved drums, then labeled mid stored on-sire pending receipt of laboratory analytical results <br /> for evaluation ofdisposal alternatives. <br /> 5. The Workplan proposed soil gas sampling procedurcz as EMc,va i C. <br /> Farr Associates is concerned that the soil gas sampling methodology proposed may not result in <br /> data ofsufficient quality to allow for the assessment ofthe potential threat to human health and <br /> the environment. 1f Holz Rubber elects to use the soil gas sampling methodology proposed Farr <br /> Associates requests that detailed field notes be taken and provided with the summai-reportfor <br /> the City ofLodi's review. <br /> Additional Comments: <br /> Farr Associates recommends that additional soil vapor and soil samples be collected from the <br /> following areas: <br /> • Building No. 7, where PCE use has been previously tdendfied; <br /> • In the vicinity of the spray booth where MIBrs, MEK, TGE and toluene have been <br /> historically used, <br /> • In the vicinity of the chemical dip tanks and holding tanks and product storage area; <br /> • In file vicinity of the empty drum A haZardaas materials storage area; <br /> RUG-25-1997 6B:13 9163519357 P.03 <br />