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Agency Draft Comments to the San Joaquin Cogeneration Sampling Plans <br />Agencies Involved: R9 EPA, Water Board, San Joaquin <br />Figure 1: SJ Cogen Site Plan Trenching Locations and Narrative <br />Dimensions of trench Excavate all trench depths to 7’ <br />Sampling per trench How many samples will be taken in the trench? <br />At what depths will samples be taken? <br />Will there be expert consult to examine the trenches and judge <br />if additional sampling is needed in certain trenches? <br />Locations of trench Since there are found waste cells along the west perimeter, <br />why was the south-east perimeter not considered for <br />trenching? <br />Additional actions in response <br />to Figure 1 and Narrative <br />Stockpiles <br />How will stockpiles be managed on site? <br />How will the stockpiled soils be disposed of, if PCBs <br />are found in the trench? <br />How will AGI characterize concentrations in <br />stockpile? <br />Please refer to 761.65(c)(9) guidance to store <br />stockpiles on in-situ <br />EPA prefer that stockpile concentrations are <br />characterized with as-found samples. There are other <br />manners in which a stockpile can be characterized. <br />Consider the time restrictions for contaminated <br />stockpiles to remain on site and how it will effect the <br />order of which trench work is done on site. <br />Other comments