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Background TPHg in soil and groundwater extended at least 17 that HLA review the report to assess the validity feet but not more than 28 feet under the shop of the data and whether additional work was (RAH, 1995b) necessary PHS/EHD reviewed the two RAH reports (RAH, HLA INVESTIGATIONS 1995a and 1995b)and requested that TVG submit a Corrective Action Plan by July 24, 1995 On HLA performed the review and submitted to .lune 19, 1995 TVG forwarded a copy of a PHS/EHD a report entitled Analysis of SECOR proposed remedial approach from SECOR Investigation and Recommendations for Additional International to PHS/EHD for review and Work Tri Valley Growers Plant T, 26200 Nowell comment Road, Thornton, California on August 5, 1997 (HLA, 1997a) The report included the following In September 1995, representatives of PHS/EHD, TVG,and SECOR met to address PHS/EHD A review of the SECOR methods and results, concerns about the approach TVG submitted a • A conclusion that the grab samples from open work plan(TVG, 1995)to address the Issues boreholes did not provide the required depth raised by PHS/EHD The scope of work consisted specific concentration data to calculate the of the following remaining dissolved hydrocarbon mass m the groundwater, • Advance three geoprobe-style borings in the • A summary of the site investigation and area between SB-1 and SB-7 to depths of 20 regulatory history, feet bgs • A review of previous investigations, • Collect soil samples at minimum 5-foot • A summary of the existing site conditions intervals in each boring based on the review, and • Collect two Hydropunch-style groundwater • Recommendations for collection of additional samples from each boring, data to complete site characterization and to • One at the beginning of saturated soils demonstrate compliance with RWQCB criteria (6-10 feet bgs),and for classification as a low-risk groundwater r • One at hole termination of 20 feet bgs site • Analyze samples for TPHg with EPA method 8015M and BTEX with EPA Method 8020 In addition, HLA recommended sampling of all • site monitoring wells in support of the low-risk Test selected representative samples for soil classification physical and chemical characteristics which relate to movement of water and contaminants On August 7, 1999, HLA sampled all six wells through the soil and submitted a report entitled Results of PHS/EHD reviewed the TVG work plan, and Monitoring Well Sampling, Third Quarter 1997, commented(PHS/EHD, 1995)that the borings Tri Valley Growers Plant T, 26200 Nowell Road, may need to be deeper and requested an additional Thornton, California to PHS/EHD on September boring between SBI and HA3 11, 1997 Monitoring well MW-4 was the only site well to consistently show detectable concentrations of hydrocarbons The results of the SECOR INVESTIGATION sampling provided recent groundwater quality data TVG contracted SECOR to perform the approved in support of a low-risk groundwater site scope of work The work was performed in April classification 1996 However, hollow stem auger rather than Geoprobe techniques were used and open borehole supplemental Site Investigation — Phase grab samples rather than depth-specific One Hydropunch samples were collected After review of the draft report(SECOR, 1997),TVG requested PHS/EHD reviewed the above two HLA reports (HLA, 1997a and 1997b) and in November 19, L000001387371WP138737Ni9 Harding Lawson Associates 4