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3. In an attempt to be both cost effective and efficient, staff from PHS-EHD Site Mitigation <br />Unit during our August 15, 1995 meeting requested that Unocal employ techniques which <br />would accelerate the assessment of this site reducing construction delays by including <br />push point technologies in conjunction with an on site mobile laboratory. This workplan <br />fails to utilize the most cost effective approach to site assessment as indicated in current <br />regulation. The workplan proposes a 24 hour and 5 day turn around for laboratory <br />analysis which are not cost effective alternatives to mobile laboratories. Telephone <br />communications with Jim Munch on August 21, 1995 representing the State Clean Up <br />Fund confirm PHS-EHD staff recommendations to be reasonable and cost effective with <br />regard to on-site laboratory applications. PHS-Ethereby requests an amendment <br />to the workplan to include the employment of an on-site mobile laboratory. <br />4. The workplan fails to include analytical detection limits for soil samples and water <br />samples. Following the State of California Tri -Regional Board Staff Recommendations <br />for Preliminary Evaluation and Investigation of Underground Tank Sites detection limits <br />shall be 0.005 mg/Kg (ppm) for BTEX and 1.0 mg/Kg for TPH gasoline or diesel (TPH <br />g and d) in soil matrices. Water analysis detection limits shall be 50 ppb TPHg and d, and <br />0.5 ppb BTEX. <br />5. In accordance with PHS-EHD Well Standards, destruction of soil borings is limited to a <br />5 percent by weight maximum for bentonite in cement mixtures. <br />6. All composite sampling shall be no greater than 2 samples per 50 yards of soil. All <br />compositing to be performed by a State certified lab. <br />7. A public notification process is required for all remediation and assessment projects which <br />utilize excavation techniques. PHS-EHD may expedite this process by canvassing the <br />immediate area as well as posting the site. Please provide an executive summary <br />describing the site findings to date and work proposed for public comment. <br />Provide an amendment which addresses the above by <br />