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Bennett Properties <br /> Page 3 <br /> A plan dated July 21, 1989 , was apparently acceptable to <br /> SJLHD. It called for sampling at six areas previously <br /> excavated. Samples were collected at six inches, one foot, <br /> and two feet below the existing (excavated) surfaces. SJLHD <br /> staff observed the sampling activities. It appears that <br /> splits were taken by SJLHD, but not analyzed. <br /> In addition to TPH, the samples were analyzed for BTX, PCB, <br /> metals (WET test for soluble species) , and Purgeable <br /> Halocarbons. The analyses showed that none of these analytes <br /> were present in the six-inch depth samples with the exception <br /> of TPH at three of the six sample sites (at concentrations of <br /> 160, 34 , and 21 mg/kg) . Subsequent analyses of these three <br /> sample sites at the two-foot depth showed no detectable TPH. <br /> Bennett Properties then proceeded to remove another fifty <br /> cubic yards of soil from the three sites showing measurable <br /> TPH. (There is no documentation to show what depth this <br /> corresponds to) . All the excavated soils were manifested and <br /> trucked to PWI. <br /> OBSERVATIONS <br /> 1. The characterization and clean-up efforts undertaken by <br /> Bennett Properties do not address the entire site. Only <br /> the near-surface soils in the vicinity of the metal <br /> building have been investigated with any detail . The <br /> areas formerly occupied by the auto repair shop and the <br /> highway striping company appear to have received only a <br /> cursory visual inspection. (I could not locate these <br /> with any certainty on the submitted plot plans) . The <br /> septic tank and leach field area were likewise not <br /> investigated. <br /> 2 . All sanpling was carried out on an authoritative basis <br /> dictated by the presence of visual surface contamination. <br /> Complete characterization of the site or any defined <br /> portion thereof must include the selection of sampling <br /> points in a random manner and the collection of a large <br /> enough number of discrete samples to be statistically <br /> valid. <br /> 3 . The sampling does not meet DHS quality assurance criteria <br /> in that no replicate samples were taken. At least one <br /> colocated replicate sample should have been analyzed. <br /> Also, no background samples were collected. <br /> 4 . However, the submitted data strongly suggests that the <br /> oily contamination which was investigated was confined to <br /> near-surface soil strata and was completely attenuated <br /> within the first few feet of the soil column. <br />