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2 <br />Responses to the comments listed in the 10 March 2020 letter are provided below (Revised <br />Additional Site Assessment Work Plan). <br />1. <br /> AdvancedGeo, Inc (AGI) will add Arochlor 1268 to the list of congeners analyzed by EPA <br />Method 8082 for polychlorinated biphenyls (PCBs). <br /> AGI will confirm with the laboratory and have samples analyzed for PCBs using EPA SW-846 <br />Method 8082A. <br /> All soil samples analyzed for PCBs will be analyzed for percent (%) moisture in accordance <br />with ASTM D2216-05 and PCBs will be reported as dry-weight results. <br />2. <br />The letter directs that lead and dioxin/furan be added to the sampling plan because they were <br />detected above screening levels during the March 2019 investigation. <br /> Lead was only detected above the Regional Water Quality Control Board’s Environmental <br />Screening Level (ESL) in one (1) waste sample collected from Waste Cell No. 1 (18-SL). Lead <br />was not detected above the ESL in the remaining 33 samples analyzed for lead, including all <br />16 samples analyzed for lead in the former power plant area <br /> Dioxin/furan was only detected above the ESL in one (1) waste sample collected from Waste <br />Cell No. 2 (B36-6 Waste). Dioxin/furan was not detected above the ESL in the remaining 20 <br />samples analyzed for dioxin/furan. <br /> Lead and dioxin/furan were detected in only one (1) sample each and both were waste <br />samples. Additionally, dioxin/furan was only analyzed in waste samples and selected soil <br />samples collected at the waste/soil interface as approved by Regional Board staff during the <br />March 2019 investigation. <br />Based on lead and dioxin/furan results from the March 2019 investigation, AGI is unclear of the <br />directive to include these constituents in the sampling plan. We have already confirmed that elevated <br />levels of lead and dioxin/furan were detected in very limited waste samples (2 samples), and that soil <br />across the site and in the former power plant area does not contain lead and dioxin/furan above <br />ESLs. AGI requests clarification to the directive to include lead and the extremely expensive and <br />time-consuming dioxin/furan analysis to the sampling plan. <br />Thanks, <br /> Brian W. Millman, P.G. <br />Senior Geologist <br />CA Professional Geologist No. 8574 <br />OR Registered Geologist No. G2663 <br />CA QSP/QSD No. 26882 <br />AdvancedGeo, Inc. <br />Environmental • Compliance • Industrial Hygiene • Geotechnical <br />Phone: 800-511-9300 <br />Fax: 888-445-8786 <br />bmillman@advancedgeo.biz <br />www.advancedgeo.biz <br />“Working in Partnership with People, Business and the Environment” <br />This email/fax message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, <br />use, disclosure or distribution of this email/fax is prohibited. If you are not the intended recipient, please contact the sender by email/fax and destroy all <br />paper and electronic copies of the original message. <br />From: Palmer, Ann@Waterboards <Ann.Palmer@waterboards.ca.gov> <br />Sent: Tuesday, March 10, 2020 5:01 PM <br />To: Brian W. Millman <bmillman@advancedgeo.biz>; Barbara Guiltinan <guiltinan@beowulfenergy.com>