CORRESPONDENCE_2017 - Laserfiche WebLink

Home Browse Search

• On 05 December 2014, nine soil borings (AB8 through AB16) were advanced within an area of the property w[h]ere former glass debris and dust waste streams were historically managedltreated, stored and disposed on the surface. One soil boring was advanced at the eastern edge of the southern parcel near a depression which was depicted to have surface water discharged. Several borings were also advanced near the former surface sewer discharge areas, east of the glass storage area. Comment: Need some information on the reported surface water discharge. • On 08 December 2014, five soil borings (AB 17 through AB21) were advanced within an area of the property were [where] former glass debris and dust waste streams were historically managedltreated, stored and disposed on the surface. • Grab groundwater samples were collected from borings ABI, AB2, AB3, AB6, AB7,AB8, AB 10, AB 12, and AB 16 at depths between 15 and 20 feet bsg. Comment: not 6 to 10 feet as previously stated. The revised report included some updated quantities of soil and groundwater samples analyzed as follows: • Twenty-one (21) soil samples were analyzed from borings ABI through AB7 for the TPH-dlo constituents listed. • Fifteen (15)soil samples were analyzed from borings AB8 through AB21 for the TPH-gasoline, dlo constituents listed. • Fifteen soil samples were analyzed for CAM 17 metals. Comments ile this "revised" report provided some additional rationale and clarification of the locations and number of borings and samples analyzed, the previous comments to the earlier December 2014 PSA report also generally apply to this January 2015 PSA report. The revised report did not summarize analytical results, wording in the report suggests samples analyzed were "soil" only and not waste (based on nomenclature used), and the report indicated the same conclusions and recommendations which did not appear to be adequately substantiated. Based on this, the previous Ninyo & Moore comments also generally apply to this latter, revised report. NO—' N ..� The email stated that AGE obtained a soil boring permit from the EHD, for work performed at 500 East Louise and that the attached report documents the findings. AGE indicated that the potential buyer performed the work to evaluate the former AST spills on the property and use of the land for waste water disposal. AGE stated: "Now the closure of the landfill will become part of the scope of work. Please review the findings attached to evaluate the closure of the site." Comments: Although not entirely clear, if AGE was requesting the LEA to review the PSA report(s) with respect to "closure of the site" it appears that this was premature. (Please see previous Ninyo & Moore comments summarizing our opinion that the PSA reports were incomplete and did not provide the required information for the LEA to evaluate the adequacy of the site investigation, most specifically, the reports did not provide the required information to indicate that wastes were adequately characterized and delineated and it appears that based on information provided, and interpretation of what was presented, that this was not accomplished). Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 23