Laserfiche WebLink
Donna Heran, REHS <br /> RE: Site Code 2226 <br /> April 24, 1992 <br /> Page 2 <br /> categories of low, medium, or high leaching potential. Sites are categorized using a weighted <br /> scoring system based upon specific site features. <br /> The leaching potential analysis prepared by SJCPHS categorizes the subject site as having a high <br /> leaching potential, based upon a score of 38. Consequently, the maximum allowable TPHG <br /> levels which can be left in place are 10 ppm. The maximum level of TPHG detected in soils <br /> samples collected beneath the former tank was 4.1 ppm ('fable 1), indicating that residual soil <br /> contamination remaining beneath the location of the former tank can be left in place with no <br /> significant threat to groundwater. No BTEX levels are presented for the most sensitive sites. <br /> Thus, the leaching potential analysis for sensitive sites relies exclusively on TPH values (LUFT <br /> Field Manual, Section II. C. b., revised March, 1989.). <br /> In addition, RESNA Industries feels the subject site was inappropriately categorized as having <br /> a high leaching potential. The site's score of 38 was due, in part, to the presence of a septic <br /> system on the site which could potentially increase vertical migration of contaminants. Although <br /> it is true that the subject property does have a septic system, the relative location of the septic <br /> system to the tank pit suggests that the septic system would not be a pathway for vertical <br /> migration of contaminants associated with the former tank. Septic systems are located <br /> approximately 100 feet north and south of the former tank. Regional groundwater flow is to the <br /> northeast. Moreover, borings logs from a nearby site indicate that soils beneath the site are <br /> generally fine-grained silts and clays to a depth of approximately 72 feet below grade, and <br /> groundwater currently exists at approximately 70 feet below grade (Attachment 3). Septic <br /> system leachfields generally extend to a maximum depth of only 10-12 feet. <br /> In summary, RESNA Industries respectfully requests that the SJCPHS reassess the site's leaching <br /> potential. Further investigation at this site is not warranted, based upon the leaching potential <br /> analysis, and would put unnecessary financial burden on Economy Fence. We respectfully <br /> request the SJCPHS to review the results of the leaching potential analysis and grant immediate <br /> site closure. <br /> 1041592.ktt <br />