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' Jerry Lile <br /> ' December 10, 2003 <br /> Page 4 <br /> data sheets for metals in crude oil and oil sludge samples from the Southern San <br /> 1 Joaquin Valley area. <br /> c. The area impacted by leakage of petroleum product from the pipelines is <br /> 1 considerable, covering several residential lots. In addition, the APL pipeline was in <br /> service for 70 years transporting crude oil or heavy fractions of petroleum. Based on <br /> the extended use of the pipelines and size of the area impacted by leakage of <br /> ' petroleum product from the pipelines on the Surland Homes property, HERD <br /> recommends sampling and analysis for metals from soil and groundwater in petroleum <br /> impacted areas. <br /> -6. Soil , _ <br /> a. HERD disagrees with the conclusion that the site is sufficiently characterized for <br /> ' screening-level human health risk assessment purposes. <br /> b. Shallow soils were not investigated. The soil data used in the screening health <br /> ' risk assessment were all obtained from 6 to 9 ft below ground surface (bgs). HERD <br /> recommends soil depths of up to 10 to 12 feet be considered for future residential <br /> scenarios due to the possibility of redistribution of soils during development,of the <br /> A land; however we understand that the shallow water table begins at 5 to 7 bgs. <br /> ' c. HERD disagrees with the conclusion that the petroleum-affected soil vertical <br /> extents are constrained, because there are no data to support this statement. <br /> ' Boring GB-2 was only advanced to 10 ft bgs, and the associated boring log <br /> demonstrates odor and oil staining, as well as color perturbation, beginning at <br /> approximately 5.5 ft bgs and extending to the bottom of the boring. Furthermore, <br /> some constituents were present in higher concentrations at 9 ft than 7 ft bgs. In <br /> addition, for GB-3 the soil boring log indicated soil color change and odor were <br /> noted beginning at 5 ft bgs, however the boring was only advanced to 7 ft bgs; the <br /> soil sample collected from 7 ft bgs had the maximum soil concentrations for each the <br /> tvarious contaminants detected at the site. <br /> 7. GW <br /> ' a. HERD disagrees with the conclusion that groundwater is sufficiently <br /> characterized for screening-level human health risk assessment purposes. <br /> ' b. For human health risk assessment purposes, groundwater analytical chemistry <br /> data are needed from unfiltered samples. Monitoring well TW-2, which was <br /> destroyed prior to development of the area into a residence, had sheen on the <br /> ' groundwater. Furthermore, grab sample GPI was contaminated with TPH, toluene, <br /> ethylbenzene, xylenes, and polynuclear aromatic hydrocarbons (PAHs). These <br /> 1 <br /> t <br />