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Project No. 014-13157 <br />Page No. 2 <br />Joaquin County Environmental Health Department (SJCEHD) inspection of a Fish & Game <br />facility located at 4001 N. Wilson Way indicates that lab staff stated that formalin was disposed <br />down the sink and into the septic system, and it is unknown how long this practice may have been <br />in place prior to the use of the existing formalin neutralization system. Additionally, a utility sink <br />with minor staining was observed in the northwestern portion of the Fish & Game shop, a facility <br />which has historically been utilized for servicing boat engines. Consequently, given the apparent <br />historical discharge of lab waste to the on-site septic system, coupled with the reported presence <br />of boat servicing/maintenance operations on site and the use of hazardous materials commonly <br />associated with boat servicing and maintenance operations, the potential exists that waste <br />materials historically disposed within the on-site sinks have entered the on-site septic system and <br />thereby have potentially impacted the subsurface of the subject site proximate to the 4001 N. <br />Wilson Way building septic system. <br />Additionally, a septic tank historically associated with the 3931 and 3975 N. Wilson Way <br />buildings located in the southeastern portion of the subject site (adjacent to the south of the <br />General Trailer portable office building) was abandoned in place in approximately 2008 and two <br />replacement septic tanks were installed in different locations. According to a representative of <br />the company which services the on-site septic systems, abandonment of the previous septic tank <br />entailed empting the tank, filling the tank with sand/soil and compacting the soil. The <br />representative indicated that no odors or visual evidence of environmental contamination were <br />noted at the time of abandonment; however, no samples were collected for analysis of potential <br />environmental contaminants. The 3931 N. Wilson Way building has been occupied by <br />businesses that conduct vehicle repair operations and use hazardous materials since at least 1980 <br />and the 3975 N. Wilson Way building was occupied by such businesses from at least 1980 until <br />approximately 2000. Based on the presence of sinks and toilets proximate to shop areas in both <br />of these buildings and the rationale discussed previously, the potential exists that waste materials <br />historically disposed within the on-site sinks/toilets may have entered the former on-site septic <br />system and have thus potentially impacted the subsurface of the subject site proximate to the <br />septic tank which previously serviced the 3931 and 3975 N. Wilson Way buildings. <br />Consequently, given the above-referenced considerations and site use factors, coupled with the <br />environmental persistence of some of the materials potentially utilized on site such as chlorinated <br />degreasing solvents, the condition of the subsurface of the subject site in the vicinity of the two <br />above-referenced septic systems is unknown. <br />As discussed previously, a sump associated with the Fish & Game lab sinks, which is reportedly <br />constructed of concrete, is located adjacent to the south of the eastern portion of the 4001 N. <br />Wilson Way building. The interior of the sump could not be inspected at the time of Krazan's <br />site reconnaissance; however, even with a visual inspection of such features, it is typically <br />difficult to assess the structural integrity of a sump and its plumbing connections due to the <br />presence of sediments and liquids in the sump. It is presumed that the sump has only been used <br />in conjunction with the discharge of neutralized formalin from the on-site labs as discussed <br />previously. However, this could not be substantiated definitively through interview of available <br />Fish & Game personnel, nor could the length of time that the sump has been in operation be <br />specified. Given the unknown structural integrity of the sump and its plumbing connections and <br />the potential that un-neutralized formalin was historically discharged to the sump, the condition <br />of the subsurface of the subject site in the vicinity of the sump relative to a potential impact from <br />formalin is unknown. <br />During Krazan's February 20, 2013 site reconnaissance, several mounds of soil and concrete <br />debris were observed in the northwestern portion of the subject site. No hazardous materials were <br />observed within the visible portions of the soil/debris mounds and no odors, surface staining, or <br />other evidence of a release of hazardous materials/waste was observed in association with the <br />KRAZAN & ASSOCIATES, INC. <br />With Offices Serving the Western United States <br />014-13157-Wilson Property Workplan FINAL