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Page I of 2 <br />BRIAN WOODY <br />From: "Teresa J Bennett" <Tjbennet@smtpgate.dphe.state.co.us> <br />To: "Brian Woody" <brianwoody1234@msn.com>; <teresa.bennett@state.co.us> <br />Cc: "WALTER Avramenko" <wavramen@cdphe.state.co.us>; "'Sergius Hanson<serge@e- <br />21engineering.com>; Steven Artman<sartman@geocon.net>; "'Vinod Jayaram"' <br /><vjayaram@geocon.net>; "'PC Norm Higley "' <normhigley@nwhlaw.com>; "Teresa J Bennett" <br /><Tjbennet@smtpgate.dphe.state.co.us>; "'Chris Morley -- Vertex"' <cmorley@vertexeng.com>; <br />Don D'Amato - Vertex<ddamato@vertexeng.com>; "'Warren Maierhofer -- Vertex <br /><wmaierhofer@vertexeng.com> <br />Sent: Tuesday, February 06, 2007 4:49 PM <br />Subject: Re: Bayshore ICSP Addendum - waste mgt plan west of break <br />Brian, <br />I have taken a quick look at this. Just a few comments for the west <br />(presumed nonhazardous) trench excavation: <br />1. It does not sound like you will excavate below the water table. If <br />you were to get into saturated soils while excavating, then any <br />groundwater that may be contaminated above State groundwater standards <br />would need to be contained and not allowed to run and drain onto the <br />ground surface. <br />2. Please increase the confirmation soil sampling following excavation <br />to a frequency of every 50 feet along each of the sidewalls, and every <br />50 feet along the bottom of the excavation for BTEX analysis, along with <br />the ones from each end of the excavation. Since these soil samples will <br />be used to potentially get a no further action determination on the soil <br />here, I need a few more samples. <br />3. I concur with PID screening as you excavate, as there may be pockets <br />of "hotter" material encountered, especially as you near the release <br />point. I also concur with then sampling this "hotter" material if you <br />encounter it. You state that you will sample any material showing PID <br />results over 200 ppm and less than 1000 ppm. But what is your intent if <br />the PID results are greater than 1000 ppm (i.e, why the cap)? <br />4. Just be aware that if you run into "hot" soils and take the BTEX <br />sample (1-2 hour verbal results), and then excavate/dispose as solid <br />waste prior to receiving the TCLP results, if the TCLP results fail, <br />then you run the risk of not having made a proper haz waste <br />determination and illegal disposal. You may want to hold these "hot" <br />soils in a lined roll-off until the TC results come back. <br />Otherwise, good to go on this portion. I agree with removing these <br />materials as further assurance that no source material is being left <br />behind that could further impact groundwater. Please contact me if any <br />questions at 303-692-3376. I won't be in tomorrow, but will <br />check/return messages periodically. <br />Thanks, Terry <br />>>> "Brian Woody" <brianwoodyl234@msn.com> 02/06/07 1:43 PM >>> <br />Teresa, <br />I have attached the waste management plan to haul non-hazardous <br />impacted <br />6/9/2007