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k" KLEINFELDEK <br /> May 2, 1989 Dlv � O <br /> File: 24-211 -00 ,. <br /> t <br /> [JAY 41969 <br /> Ms. Barbara D. Marcotte CN PERMITMENTAL I SERVICES HEALTH <br /> Department of Health Services <br /> Technical Services Unit <br /> 714/744 P Street <br /> Sacramento, CA 95814 <br /> SUBJECT: Southern Pacific Railroad Parcels C and D <br /> Work Plan for Health Risk Assessment <br /> Dear Ms. Marcotte: <br /> Following please find responses to your comments dated March 16, 1989, for subject work <br /> plan (Attachment 1) for Health Risk Assessment (HRA). These responses are meant to <br /> constitute amendments to finalize the work plan for the HRA dated November 16, 1988, <br /> and to satisfy DHS requirements for approval and implementation of the work plan. The <br /> original DHS comments appear first and are followed by Kleinfelder responses addressing <br /> the comments. <br /> Comment on pg. 1, para. 3. <br /> Please identify the cause for "secondary" public health concern regarding the nearby Segura <br /> Trucking Company. <br /> Response to comment on Section 1, pg. 1, para. 3: <br /> The "secondary" health concern regarding the nearby Segura Trucking site was <br /> preliminary information contained in San Joaquin Local Health District (SJLHD) <br /> files indicating disposal of waste oil and removal of underground tanks had taken <br /> place at the Segura site. Subsequent information obtained from SJLHD files ` <br /> (Attachment 2) indicates the following: <br /> 1) The waste oil contaminated soil at the Segura site was documented on <br /> June 4, 1985, by SJLHD staff as being cleaned up. Note Number 2 from <br /> SJLHD staff field activity log (page 2, Attachment 2) states: "A field visit <br /> made on this date verified that the contaminated soil has been removed." <br /> 2) The soil samples taken during the removal of four underground tanks, which <br /> were analyzed for benzene, toluene, ethylbenzene, xylene, ethylene <br /> dibromide, lead, and TPH, indicated that all compounds appear to be at <br /> levels well below the levels constituting hazardous waste or analysis detection <br /> limits. (The only detectable results were: one sample result of 6.6 mg/kg of <br /> lead and one sample result of 89 TPH for differing tank locations). <br /> Therefore, the Segura Trucking site is not considered a hazardous waste site subject to <br /> border zone determination for the SPR property and subject HRA. <br /> KLEINFELDER 9795 Business Park Drive, Sacramento, CA 95827 (916) 366-1701 <br />