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19133 East Liberty Road - 2 - 13 March 2023 <br />Clements, CA <br /> <br />analyzed for chemicals of concern and soil samples of stockpiled material from the <br />excavations were collected for analysis. An additional eight potholes were advanced <br />around the Site to establish the approximate contact of the undisturbed portion of the <br />Site with the debris. <br /> <br />An EHD inspection report dated 12 November 2021 states the majority of the debris has <br />been delineated except for a portion along the west side of the property. <br /> <br />Laboratory analytical results from the Phase II investigation indicated minor <br />concentrations of TPH as diesel and motor oil, SVOCs and heavy metals. No VOCs <br />were detected with the PID during the site characterization activities. Asbestos was not <br />detected in any of the soil samples analyzed. The laboratory data indicated that minor <br />amounts of contamination found in Site soil surrounding the debris do not pose a <br />significant environmental health risk or hazard. The well sample analytical results did <br />not indicate any chemical constituents exceeding California drinking water standards, <br />Title 22 of the California Code of Regulations (CCR) maximum contaminant levels <br />(MCLs). <br /> <br />Proposed Work <br /> <br />The Work Plan proposes to remove trash and debris from the site by excavator in three <br />areas of the site based on previously collected data. Verification soil sampling will be <br />performed to confirm removal of impacted soil. Analyses of soil samples will include <br />heavy metals, PCBs, SVOCs, asbestos and TPH. Department of Toxic Substance <br />Control Human and Ecological Risk Office (HERO) Human Health Risk Assessment <br />(HHRA) Note 3 screening levels and residential screening levels established by USEPA <br />Region IX will be used as for verification as the property’s future land use will be <br />residential. <br /> <br />Comments <br /> <br />1. The Work Plan does not indicate at what frequency verification soil sampling will <br />be conducted, nor does it include frequency of sampling for stockpiled soil that <br />will be used for reuse. The Work Plan should be revised or an addendum should <br />be supplied that includes appropriate sampling frequencies for these activities. <br /> <br />2. The Work Plan includes the following statement: “Soil will be loaded or <br />stockpiled, profiled as needed, transported for off-site use or on-site as fill <br />material.” Potential off-site use scenarios should be discussed and soil sampling <br />protocols and notification protocols should be included to ensure that any <br />impacted soils removed to off-site locations that are not disposal sites are <br />appropriately disclosed to accepting parties. <br />