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y URS AN INTERNATIONAL PROFESSIONAL SERVICES ORGANIZATION URS CONSULTANTS, INC. ATLANT OSTON 282 DELAWARE AVENUE BUFFALO BUFFALO,NEW YORK 14202-1805 CLEVELAND O September 21, 1995 (716)856-5636 DEENVER US FAX:(716)856-2545 NEW YORK PARAMUS.NJ NEW ORLEANS SAN FRANCISCO SAN MATEO Mr. Brent Hudson SEATTLE VIRGINIA BEACH Corporate Environmental Services Manager WASHINGTON D.0 Rich Products Corporation 1150 Niagara Street Buffalo, New York 14213 RE: COMMENTS ON WHF, INC. REPORT OF THE ESCALON, CA SITE Dear Brent: We have reviewed the WHF, Inc. (WHF) report on the Rich Products Fruit Pak facility at Escalon, CA. The report is entitled, Underground Tank Investigation, Phase I Report of Findings," and dated September 12, 1995. The report covers an investigation by WHF in the vicinity of 4 former USTs that were removed properly from the property in 1987 and obtained clean closure by San Joaquin County Public Health Department on February 3, 1994. Our comments are as follows: 1. Contamination at boring B-l: There appears to be some diesel contamination at soil boring B-1 between 10 ft. and 30 ft. BGS. The contamination did not extend to any of the other borings proximate to B-I (B-2, -3, -4, and -5). B-5 was approximately 15 ft. from B-1, while B-3 and B-2 were approximately 20 ft. from B-1. It should be noted that surficial or near surficial soils contaminated by diesel may have fallen into boring B-1 during sampling (see Comment 3). 2. Site geology evaluated by D. Lenhardt, PhD, CPG, URS Sr. Geologist: The site geology is consistent and uniform across the area investigated by WHF to a depth of 60 ft. BGS. From the logs of all the WHF borings, the very dense silt found at approximately 35 ft. and clay at approximately 40 ft. will be an effective barrier to prevent the migration of the diesel contamination to the water table at 57.5 ft. This is evident by the fact that no contamination at soil boring B-1 was found below 30 ft. 3. Slight contamination at soil boring B-3, 55 ft.: The slight contamination found at soil boring B-3 at 55 ft. is unrelated to the diesel contamination at B-1, because of the following: • No contamination was found at 50 ft. of B-3 boring, below the silt and clay barriers at 35 ft. for the reasons mentioned in Comment 2. • WHF used a solid stem auger to bore holes for sampling. As a solid stem auger passes through a contaminated area, it could drag contamination downward as the boring continues. The drilling and sampling methods used by WHF also could have introduced soils from above 55 ft. into the sample. The solid stem auger, used by WHF, must be withdrawn before split spoon sampling can occur. Loose soils above the 55 ft. level, even from the surface, could have been introduced into the boring before the split spoon sampler could collect a sample at the 55 ft. depth. URS recommends the use of hollow stem augering to avoid this potential source of contamination. j:1353971wp\cor\9-20-95.bb