841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Albert C. Gray Hi. D, P.E. Si»i -1 2JACA Corporation550 Pinetown RoadFort Washington, PA 19034

Dear Dr. Gray:

Contained in this letter are consents which I have thus far exam-piled concerning the JACA SAP for the Cryochem RI/FS. This letter alsoconstitutes approval of the Health and Safety Plan as submitted.

Be advised that I have not as of yet received input from our lab-oratory on the CftPP portion of the SAP. I am expecting to receive theLabs contents on the QAPP shortly. In the meantime however, the enclosedcomments need to be addressed by JACA, and resolved to the satisfactionof EPA. Of course, comments which may be forthcoming from the Lab willhave to be communicated to, and addressed by JACA. I will forward thesecomments upon availability.

As we discussed in our June 28, 1988 conversation, in order toaccomtndate the phased nature of this RI/FS project, once the commentsto the JACA SAP have been addressed and resolved, EPA will provide writ-ten approval for the project on a phase by phase basis. With respectto Phase I, satisfactory resolution of the Ehase I comments willresult in EPA's approval of Phase I RI/FS activities. With respectto Phases II, since the Scope of Work (SCW) and the SAP contemplatesample locations and other RI/FS activities contingent upon Phase Iresults, Phase II can not be approved until EPA has reviewed the datagathered during Phase I as well as the Hiase II plans which are basedon this Phase I data. Likewise, Phase III can not be approved prior tothe availability of Phase II data. Tasks to be completed during thethree phases of this RI/FS, are those contained in the approved SCW.

Submittal of data collected during the- three phases of the projectcan be made via the monthly progress reports required under the ConsentOrder. For the immediate future, I plan on being on site monthlyand will pick up the progress reports for review during those visits.

I am in receipt of your first progress report for the RI/FS dated6/28/88. In accordance with par raph VIII (E) of the Consent Order,please be sure that all progress reports include at a minimum?

1) a description of the actions that have been taken toward achievingcompliance with the Consent Order; 2) all results of sampling and testsanalyitical data and interpretations of all other information receivedby the Respondents; 3) a description of all data anticipated and acti-vities scheduled for the next month; and 4) a description of any prob-lems encountered.

Presently, the schedule of activities for the RI/FS is containedin the SCW. The JACA SAP also contains a schedule, although it doesnot match the schedule contained in the scope of work. In revising theSAP, please provide a schedule which is specific for the sampling eventsto occur during this RI/FS. I intend to have my oversight contractorpresent during these sampling events and require sufficient lead timefor scheduling purposes. Once approved, the SAP schedule will supercedethe SOW schedule.

Please resufcmit the SAP within 30 days of your reciept of thisletter. If you have any questions, I can be contacted at (215)597-3169.

Sincerely,

Christorffer B. PillaEnvironmental Scientist

cc: T. Sheenan, PAOERB. NishitaniH. ZiaM. Johnson, PRC

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1.0 GENERAL COMMENTS

Conversion of REM II SAP to JACA'S SAP

The SAP prepared by JACA was primarily based on the SAPpreviously prepared by Roy F. Weston, Inc. under the REM IIcontract. In the consent order between EPA and the PRPsf thePRPs agreed to conduct all work according to the tasks con-tained in Weston's work plan. However, JACA's plan refers toresources available through the REM II contract but generallynot available to the PRPs and their contractors. Theseincorrect statements are primarily in Sections 4 and 5 of theSAP. For example, JACA states that bottles will be obtainedfrom the sample management office (SMO) and that JACA is theREM II prime contractor. The SAP needs to clearly demonstratethat JACA understands its responsibilities as opposed to thoseof others when EPA's contractor is conducing the work. In ad-dition, JACA must discuss how it will report field observationsand deviations from the SAP during the field activities.Additional statements that are not correct or have not beenchanged from the REM II SAP are identified in Section 5.0 ofthis report.

in addition, the SAP refers to the REM II Quality AssuranceProject Plan (QAPP) and the REM II Site Investigation ProceduresManual (SIPM) for many of the procedures outlined in the SAPQuality Assurance Project Plan (Section 5.0 of SAP). Referencingspecific sections or standard operating procedures in these docu-ments is acceptable if the documents are avilable for referenceand use during field activities. PRC recommends that the appro-priate sections from these two documents be included in theappendices of S/- .

* V

Schedule

Another general comment concerns the difference between theproject schedule in the SAP and that given, in the revised Scopeof Work (SOW) submitted to EPA on April 4, 1988. The schedulefor field activities in the SOW is realistic, although general.Providing a more specific project schedule in the SAP for eachtask to be conducted under Phases 1 and 2 is necessary in orderto understand how JACA anticipates completing these tasks.Instead, the proposed schedule is a cirect copy of Weston'soriginal project schedule. JACA needs to update the schedule andincorporate the changes made to the SOW. The revised schedulemust also include time requirements for evaluating and reportingdata to EPA.

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Sample Locations

The SAP identifies the number of samples to be collectedfor each media but does not identify the sampling locations.The SAP prepared under REM II contained a figure identifying thetentative sampling locations. JACA did not include this figure,thus making the sampling plan more vague than the initial plan.The quality of the sample analytical results depends on thesampling locations. If the locations are currently not known,the SAP must setforth the criteria that will be used in the fieldto alter the sample locations or identify additional locations.

Determining Background Site Conditions

The SAP does not address how background concentrations forthe various media will be determined. The SAP should clearlyidentify which samples will be considered background and discusstheir proximity to the site. In addition to considering thelocations of the background samples with regard to site conditions,background samples should not be in areas near potential off-sitecontaminant sources (the SAP states that eight off-site areas willbe investigated as possible contributors).

In addition. The SAP should identify what analyses will beconducted on the background samples. EPA recommends that thebackground samples be analyzed for all parameters on the EPATarget Compound LIST (TCL)> Knowing what parameters are present,or more important, not present, would be useful in confirming thecontaminants of concern at the site.

Soil Gas Investigation

Based on the discussion inthe SAP, it appears that thepurpose of the soil gas investigation is to identify monitoringwell locations and screen soils for contamination. The SAP doesnot clearly explain how the data from the investigation will beused to determine the monitoring well locations, nor does theSAP identify what additional data will be used to locate the wells.Several of the spceific comments in Section 4,0 of this reportaddress the soil gas procedures.

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2.0 INCONSISTENCIES BETWEEN CONSENT ORDER AND SAP

Many of the items agreed to in the Consent Order betweenEPA and the PRPs are not addressed inthe SAP. These items in-clude technical changes to the REM II SAP, notification andrecordkeeping requirements, and QA/QC audits.

Two of the technical thats were agreed to in the ConsentOrder are not correctly addressed inthe SAP. The first itemconcerns the parameters that will be analyzed during the firstand second sampling rounds of ground-water monitoring andresidential wells. JACA twice (Sections, pages 6 and 20)indicates that metals and pesticides will not be analyzed inthe second sampling round if they are not detected in thefirst round of sampling. However, the Consent Order statesthat PCBs and pesticides will not be analyzed in the secondround if they are not detected inthe first round of sampling.The second item not addressed inthe SAP is the borehole geo-physical logging methods that would be substituted for thecoring methods proposed inthe REM II SAP. The Consent Orderclearly indictes that the following three methods must be usedas a substitute to coring the bedrock wells:

o Temperature logs.

o Caliper logs.

o At least one of the following:

gamma-gamma logs.

resistivity logs.

conductivity logs.

acoustic televiewer logs.

JACA must discuss the methods that it will use to log thebedrock boreholes.

JACA also did not address several notification and recordretention requirements agreed to in the Consent Order. JACA isrequired to notify EPA of the identity of each subcontractor atleast 14 days before field work is to begin and to notify EPA at

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least 5 days in advance of field activities that will requiresplit sampling. The SAP does not address these requirements.JACA should also state that it retain all records and reportsgenerated during the RI for a period of not less than 6 years,as required. The Consent Order also requires that JACA submita progress report every 30 days. The SAP does not addressthis requirement. The report should contain the followinginformation at a minimum:

o A description of the actions that were takentoward achieving compliance with the Consent Order.

o All results of sampling and tests, analytical data,and interpretations.

o A description of all data anticipated and activitiesscheduled for the next month.

o A description of any problems encountered.

The third item that JACA did not addrss in the SAP is re-quired field and laboratory audits. JACA has not described howand when it will audit its subcontractor laboratory nor how itwill conduct its field audit. JACA should also state that itwill document that its subcontractor laboratory has analyzedperformance evaluation samples with the past 6 months.

3.0 DIFFERENCES BETWEEN JACA'S SAP AND THE REM II SAP

JACA's SAP closely parallels the SAP developed by Roy F.Weston, Inc., under the REM II contract; however, EPA has severalcomments concerning differences between the two plans. Althoughmany of the comments are primarily specific comments requiringadditional clarification, EPA noted one major change in JACA'sfield investigation approach. JACA stated throughout its SAPthat it will choose sampling location in the field, but does notclearly state the criteria that it will use to choose its samp-ling locations or how it will interface with EPA when selectingapproved sampling locations. Weston, on the other hand, includeda figure (Figure 3-2) in its SAP that located tentative surfacewater, sediment, and groundwater monitoring well locations.Tentative sampling locations (including soil gas and surfacesoil sampling locations) the rational for the tenative samplinglocations, and the sampling approach must be included in the SAP.In order for EPA to evaluate and approve JACA's technical approachbefore RI field activities begin.

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Specific comments regarding the differences between the twodocuments are given below.

Section Paqe CommentThe previous SAP stated that the pumpts toto be used for sampling ground water willhave disposable tubing and dedicated safetyropes. JACA has not discussed this issue.

5 JACA should clarify whether samplescollected for full HSL parameters are in-cluded in the total (partial and full HSL)number of samples given in Table 3-2. Forsome medial *such as surface, sediment, andground water) JACA appears to have includedthe full HSL samples in the total numberof samples to be collected, but in othermedia (surface soil and borehole soil) JACAdoes not include the full HSL samples inthe total number of samples to be collected

5 Weston's SAP indicated that TOC andalkalinity analyses will be conducted onresidential and ground-water monitoringwells. JACA has excluded these parametersin its SAP. These exclusions should beexplained.

8 JACA's residential well survey is not ascomplete as the residential well survey inWeston's SAP. JACA's survey is missing thefollowing information:

- Ground surface elevation- Length and type of screen (if present)- Casing material- Depthxta ground water- Type of home plumbing- Operating hours per day- Whether water has been tested before

(location, nature of sampling, dateof sampling

16 Weston's SAP clearly states that 20 sur-face water samples will be collected on-site and 2 samples will be collected off-site. JACXA should indicate whether itwill collect the same number of on-siteand off-site samples.

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Section Page ___________Comment_________________3 20 TOC and alkalinity should be considered

for inclusing in the list of parametersto be analyzed.

3 22 JACA states that their method of disposaldisposal for the purge water is to re-turn it to the well. Weston's SAP didnot include this disposal method. Groundwater is to be containerized untilground-water sample results have been re-viewed. After review of the sample data,a disposal method will be selected.

1 6 The SAP refers to "existing maps" thatshow a fault or displacement behind thefabrication building. Include a copyof the map showing the fault.

1 7 Including ground-water elevations pre-viously recorded for the existing wellsin the SAP would provide the readerwith additional understanding of the site.

1 7 Has JACA investigated the possibility ofusing surface geophysics to aid inmapping the Leithsville/Hardystonecontact on site.

1 9 State whether the contaminants identifiedas contaminants of concern were the onlycontaminants analyzed for or if all HSLparameters were analyzed for in theprevious studies.

1 10 Include a discussion on why metals andmethylene chloride are contaminants ofconcern. (A discussion has been includedfor the other.contaminants of concern.

1 11 The summay table of contaminants does notagree with the values included in Exhibit1 of the Consent Order. The maximum DCEand DCA values in the summary table areless than in Exhibit 1 of the Consent Order.

1 11 Explain why chlorobenzene, which was de-tected at the production well, was notincluded as a contaminant of concern.

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Section Page ____________Comments__________________Table 1-1 needs to include the sources ofthe data.

Explain what is meant by "eight possiblecontributors". Who they are, why theyare suspected, etc.

Phase I RI, Add detailed field mappinggeologic out crop on and off site toidentify information contact and toidentify stike, dip, etc. of the strata.This may be revised upon the informationgathered from the well cutting and cores.

JACA should explain what additional in-formation will be collected during Phase1 and whether the data include existingpumping data from the on-site productionwell.

JACA should describe the procedures it willuse to analyze aerial photographs. TheREM II work plan indicates that a sub-contractor will conduct fracture traceanalysis on aerial photographs to helpdetermine the final locations of monitoringwells.

Include details on the type of informationto be collected by the field biologist andthe procedures for collecting that infor-mation. Will this include a wetlandsdelineation?

Phase II RI. The bore hole geophysics raustbe conducted during this phase and priorto completion*of the well since somegeophysical techniques cannot be used incased holes. The borehole geophysics willalso be used to help select the screenedinterval if screens are necessary. Thesuite of borehole techniques to be usedmust be discussed and finalized.

The eighth bullet implies that a dye testor a smoke test may be conducted. How-ever, Section 3 implies that both willbe conducted. Clarify whether one orboth will be conducted.

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Section____Page_________________Comment

General information on the productionwell's construcvtion and use should becollected during Phase I of the RI.Detailed information on its use shouldbe collected during the sampling periodsof Phase II.

JACA may want to consider collectinginformation on other production wells ifany are in the area.

JACA should explain how and when the"confirmation" sampling round during Phase3. Explain how these two "confirmation"rounds are related.

The introduction needs to clearly explainwhich parameters will be analyzed forduring the RI. The introduction statesthat a percentage of the samples will beanalyzed for a full set of HSL parameters.Issues that need clarification includeexact meaning of full set of HSLwhat the other samples will be analyzed for;in general, the percentage of the samplesthat will be analyzed for the full HSL; andwhether cyanide is included in the metalanalysis or the full HSL analysis.

The decontamination procedures in Table3-1 are inconsistent and do not conformto standard decontamination proceduresoutlined in the Compendium of SuperfundField Operation (U.S. EPA, 1987)or theRCRA Ground Water Monitoring TechnicalEnforcement, Guidance Document (U.S. EPA,1986).

JACA should state the frequency of de-contamination. For example, JACA shouldindicate whether drill rigs will be de-contaminated each day or after completingeach borehole. EPA recommends that thedrill rig be decontaminated between bore-holes.

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Section Page ____________Comment___________________3 2 It is unclear whether JACA intends to steam

clean every split spoon before sampling.

3 2 Soil gas probes may also require steamcleaning. The contractor should visuallyinspect the holes and interior of the probeto determine if high pressure steam isnecessary to remove soil from the probe.

3 3 Table 3-1 states that bottles will becleaned by JACA personnel; however, page 45states that bottles will be provided by thesample management office (SMO). Thisissue needs to be clarified. If JACA orits laboratory is proving the bottles(and they re not being purchased pre-cleaned from a firm that specialized inthe area), the cleaning procedures must bediscussed.

3 3 No final rinse is listed for the soil probe,soil sampling "trowels," or the bailers.In addition, explain what type of "clearwater" rinse will be used for the testpumps.

3 3 "Travels" should read "trowels." Inaddition, "etc." should be defined.

3 3 JACA proposes to clean stainless steeltrowels with nitric acid. Nitric acidmay not adequately remove solvents fromstainless steel. The commonly accepteddecontamination procedure for removingsolvents from sampling equipment is torinse with another solvent (such as acetone)(U.S. EPA, 1987, A Compendium of SuperfundField Operations).

3 3 The table states that after completing thewells, all drill cuttings and water will bestored on-site in clearly labelled con-tainers. Explain what type of containerswill be used, how they will be labelled,and where they will be stored on-site.

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Section Page Comment

4 JACA should specify what it considers as"significant" contamination of waste gen-erated during RI activities. Certain sol-vent wastes from CERCLA activities will berestricted from land disposal afterNovember 8, 1988 (40 CFR 268.30). There-fore, wastes that do not meet the treat-ment standards for land disposal must betreated or disposed of off-site. JACA hasnot discussed how wastes will be treated ordisposed of off-site. Treatment standardsare given in 40 CFR 268.

5 JACA should clarify whether the projectednumber of samples includes samples takento characterize the background conditionsat the site.

5 The reviewer does not understand thephrase "I full HSL scan and analysis of asecond sample for HSL parameters foundpresent." JACA should define "full HSLscan." EPA's understanding is that afull HSL scan consists of VOA, SNA,pesticides, PCBs, metals, and cyanideanalyses.

5 and 6 It is unclear as to whether the "Pro-jected Number of Samples" column inTable 3-2 includes the samples for the"full HSL scans." For example, thiscolumn lists six sediment samples to becollected. It is not clear whether sixsamples will be collected for VOA,pesticides, PCBs, and metals, plus twosamples listed in the table. In addition,clarify this issue for the ground-watersamples. EPA assumes samples will becollected for three "full HSL scans" and11 "partial" during each sampling round.

5 Additional analyses to be conducted on soilsamples (such as organic carbon content)and surface water samples (such asneed to be described in the narrativeportion of Section 3. Clearly state whethel

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Section Page Comment

these will be conducted in the field or inthe laboratory, the methodology needs to beincluded in Appendix A. If the analyses areto be conducted in the laboratory, themethods need to be identified and discussedin the Section 3 narrative.

Something is missing under the second head-ing, "SOIL." Does JACA mean to includeshallow soil borehole samples.

Soil gas is not included in Table 3-2.

The procedures for collecting the 22 soilsamples for particle size and other physicalcharacteristics and the 2 clay mineralogysamples are not discussed in the Section3 narrative.

Weston's SAP stated that ground-water samplesfrom the residential and monitoring wellswould be analyzed for TOC and alkalinity.However, these parameters are not includedin JACA's SAP. JACA must include TOC al-kalinity in their sampling program.

The Consent Order states that PCBs andpesticides will not be analyzed in thesecond round if not identified in thefirst round of sampling. JACA statesthat pesticides and metals will not beanalyzed in the first round of sampling,

JACA should identify the exact number andtypes of QA/QC samples to be collectedduring the RI.

JACA states that its subcontractor labora-tory will analyze solid wastes using the;Toxicity Characteristic Leaching Procedure.Since this analytical method is relativelynew and not commonly in use, many labora-tories currently do not have the equipment :needed to perform this test. JACA mustdocument the laboratory's ability toconduct this test when conducting itslaboratory audit.

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Section Page Comment

7 JACA must discuss the process it will useto select the residential wells that willbe sampled. Once the wells are selected,JACA must submit the list to EPA forapproval. The list should discuss therationale for selecting the wells (forexample, to define the boundaries of theoff-site contributors, to confirm previoussampling results, and so on.)

7 Section 3.1 should describe the proceduresfor collecting the blank and duplicationsamples for the residential wells. (Forexample, state whether JACA anticipatescollecting duplicates from clean of con-taminated locations.) This comment appliesto all other sampled media.

7 Explain why residential wells are beingsampled for total metals, while monitoringwells are being sampled for both total andsoluble metals.

7 Table 3-2 states that samples will beanalyzed for pH and specific conductancein the field and laboratory; Page 7 liststhe field only. This needs to be clarified,If conductance is to be measured in thelaboratory.

8 The residential well survey should indicatewell uses )drinking, bathing, not in use,etc.) and whether the residents arecurrently using bottled water exclusively.

9 In addition to allowing residential tapwater to run for 20 minutes, EPA suggeststhat pH, specific conductance, and temper-ature be measured every 5 minutes duringthe purging efforts to ensure constantwater quality from the aquifer.

11 JACA does not discuss a sampling strategyor the criteria for selecting samplingpoints. If JACA intends to use gridpattern, JACA should indicate the criteria

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Section Page ______________Comment__________________

for selecting sampling points. inaddition, JACA should specify the criteriait will use to determine when samplingis completed.

3 11 The soil gas analytical method describedwill be of limited use and will serve asonly a rough estimate of the ground-watercontamination (depending on the depth ofground water and its degree of contamination)and may serve as a more accurate estimateof near surface soil contamination.Previous investigative reports indicatethat ground water is over 35 feet belowland surface in some areas of the site.The method for monitoring wells due to thedepth of the ground water and the observedlow levels of VOCs in the ground water. Inaddition, because the source of contaminationmay be surface spills, JACA needs to explainhow the distinction will be made betweensoil gas readings due to contaminatedsurface soil and those due to ground-watercontamination.

3 12 Provide a reference for the"slam bar"methodology of soil gas sampling.

3 12 JACA should specify the number of samplesand method that will be used to determine \the background air quality.

3 12 The soil gas sampling method does notindicate any type of gas purging techniqueprior to sampling. The purge volume andpurge rate need to be determined and statedin the SAP. The purge rate should beconsistent with the unsaturated intrinsicpermeability of the media intended to besampled.

3 13 Explain hou the soil gas sample will bedocumented and the results reported. EPAnotes that Table 3-5 does not contain asampling code for the soil gas samples.

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Section Page Comment

13 Specify whether the number of samples tobe collected includes duplicates, matrixspike duplicates, trip blanks, equipmentblanks, or any other type of samples.

13 JACA states that VOC sanlysis will beperformed using "a modified EPA method 8010"The term modified needs to be clarified.It is unclear whether EPA or JACA's lab-oratory has modified the method. Referencesfor the modified method are needed. TestMethods for Evaluating Solid Waste (EPA1986) lists the compounds that may beanalyzed by Method 8010. JACA needs tospecify which of these compounds will beanalyzed for .

14 and 15 As stated earlier, JACA needs to moreclearly explain which samples will beanalyzed for what parameters.

15 JACA should reference the surface soilprocedures that it will use to collectsamples.

15 The purpose of step 3 — head spaceanalysis — needs to be explained. Itis unclear as to whether the analysis isa screening used to determine if samplesshould be sent to a laboratory for analysisor whether the analysis is to collect VOCdata on the samples. It is not clear whatwill happen if the head space analysis isnegative — will the sample be sent for"partial" or "full" HSL analysis, or willno sample be s ent?

15 The procedure should clearly state tha thesample used for head space analysis shouldnot be the sample, that is submitted to thelaboratory for analysis.

15 The date, time, and sampler's name shouldalso be recorded in the field logbook.

16 The surface water locations need to bebetter defined. Identify how many sampleswill be from streams, ponds, and seeps.addition, identify which two locationsbe sampled for the "full HSL scan" andprovide the rationale for how these locationswere or will be selected. ftRSQQ

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Section Page Comment

16 Section 3.4.2 does not identify the same1parameters for analysis that are identifiedin Table 3-2 (hardness, dissolved oxygen, andothers).

17 The surface water sampling needs more detail,such as how the bottles will be filled(immersing bottle in the stream or trans-ferring the sample to the bottle with abreaker), at what depth below the surfacesamples will be collected, and at whatdistance from the shore.

17 JACA should state that samples will befiltered for dissolved metal analysis. inaddition the SAP should reference Section3.12 andTable 3-3 for field filtering andpreservation methods.

17 JACA should indicate how the sampling pointwill be staked and located if it is in themiddle of the stream (the sampling pointcould be surveyed in relation to a perma-nent object).

18 As stated for previous sections, the sampling,locations and type of analyses need to bedescribed in more detail. In addition, thecriteria for selecting locations need to bedescribed. Section 3.5.2 states that off-site sediment samples will correspond to theoff-site surface water samples; explain howthe on-site sediment samples correspond tothe on-site surface water samples.

18 Identify how many sediment samples will bestreams, ponds, or other areas.

18 Section 3.5.2 indicates that two of thesurface water sampling locations will beoff-site; however, this is not explained inthe surface water section.

18 The first sentence of the second paragraphof Section 3.5.2 should read "Two sampleswill be analyzed ..."

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Section Page ______________Comment________________

3 18 The SAP should state that downstreamsediment samples will be collected firstand sampling will continue upstream. TheSAP should also state that at locationswhere both sediment and surface watersamples are to be collected, surfacewater samples will be collected first.

3 19 Provide more detail on the sampling pro-cedure in step 2, such as whether sampleswill be composited in a pan or placeddirectly into sample bottles. In addition,minimal excess water should be includedwith the sample so that enough sedimentsample is available for analyses.

3 19 JACA should also record the date, sampler,color, and consistency of the sample.

3 20 State that ground-water samples will becollected during two rounds. Identifythe length of time between rounds.

3 20 See comment on Section 3, page 6, re-garding the parameters to be analyzedduring the first and second rounds ofsampling.

3 20 For Section 3.6.3, explain what criteriawill be used in the field to determinethe sampling order.

3 21 In step 5, calculate the volume of waterin the well, not the well volume.

3 21 It is not cleaV as to why the lengthdifference between the top of the protectivecasing and the riser pipe is being recorded.

3 21 Identify how the depth to ground water willbe determined (electric tape, chalked steeltape, plunker). To what level of accuracywill the ground-water level be measured?

3 21 Section 3.6.3 states that purge water willbe retruned to the well. See earliercomment on purged water.

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Section Page ______________Comment________________

3 22 In step 8, specify the order of all para-meters including pesticides, PCBs, andmetals. This step is somewhat misleadingbecause it appears that samples for semi-volatiles are to be regularly collected,but based on earlier information, semi-volatiles fractions will be collected for3 of the 14 samples.

3 24 Explain how soil samples will be selectedfor chemical analysis if the 5-foot con-tinuous sampler is used.

3 24 Explain the purpose of the head spaceanalysis. (Is it to collect contam-ination data or to select samples foranalysis? If it is the latter, explainin more detail what criteria JACA willuse in the field to select samples forchemical analys is.)

3 24 The scope states that soil samples willbe selected for analysis at least 2locations (0-5 BLS interval and just abovebedrock refusal); explain how other samplelocations will be selected based on theresults of the head space screening.

3 24 Explin how the outer surface casing will beemplaced into the bedrock; identify whichgrouting procedure will be used.

3 24 The first full paragraph on page 24 statesthat if a substantial area of soil contam-ination is revealed, five additional soilborings will be drilled and sampled every5 feet. Expalin-the criteria that willbe used to locate the additional borings.Define substantial. Explain what analysesthese additional samples wil undergo.

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Section Page Comment

27 Many of the comments made for Figure 3-2apply to Figure 3-3. in addition, thisfigure does not show that a concrete sur-face seal will be emplaced to guard againstfrost heaving. As discussed in the previouscomment, PVC is not EPA's material of choicewhen organic ground-water contamination isbeing monitored (U.S. EPA, RCRA GroundWater Monitoring Technical EnforcementGuidance Document). The screen length andscreen setting are not consistent; de-pending on the depth to bedrock and eleva-tion of the water table, screen lengthscould substantially exceed 10 feet.

29 JACA states that the gravel pack and ben-tonite seal will be added to the wellannulus using downhole placement methods.The SAP should describe the downholeplacement methods. In addition, JACA should"state how dep the tremie pipe will beplaced. The specified grout mixture is"1-2 mix of sodium bentonite powder andPortland cement." JACA should indicatewhether this mix is computed by volume orweight and howmuch water will be addedto the dry mix.

29 The method of well development is notclear. JACA should indicate that the wellwill be surged with (air, water, surge block,or swab). The well completion figures showthat water day*be added to the well. JACAshould explain the amount of water itanticipates adding to a well and the volumeof water that will be purged if this methodis used.

30 Bedrock monitoring well installation. Atminimum, one core shall be collected fromeach of the two bedrock geologic formationson-site (Leithsville and Hardystone). Thisis necessary for calibration and correla-tion with the borehole-geophysics study.

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Section Page ______________Comment_________________

3 30 JACA states that it will drill each bed-rock borehole to the "first zone ofsufficient yield of water," JACA shouldindicate how this zone will be determined.In addition, the method of placing a 4-inch casing 5 feet into bedrock and drillingto a depth of 100 feet below land surfacemay result in a large monitored zone thatwill not allow for depth-discrete sampling.

3 33 Section 3.9.1.2 states that slug testingwill be conducted on selected wells. Statethe nimber of wells that will be testedand explain the criteria for selectingthese wells.

3 33 indicate whether the air in the well willbe screened for volatile organic prior toslug testing. Also specify how the downhole equipment will be decontaminated be-tween wells. A steel slug is preferredto slugs made of PVC. Indicate how longthe slug will be and what method of dataanalysis will be used.

3 37 The SAP proposed to core only one bedrockwell. How will JACA determine if packertests areneeded for holes that have notbeen cored?

3 39 How will it be possible to get a repre-sentative ground-water sample for vola-tile organic compounds from the pumpingwell?

3 40 The SAP must indicate that the decisionconcerning the disposition of the dis-charge water, will be after analysis andconsultation with EPA.

A R 3 Q Q 1 5 U

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Section Paqe Comment

41 The scope of the continuous water levelmonitoring and sampling is unclear.State the number of wells to be monitoredand how they will be selected. Explainhow long the monitoring will continue.The production well will be sampledmonthly for VOAs — explain the rationalefor this sampling. (Will the resultseffect further or additional sampling?)

41 Indicate where the stream levels will bemeasured and how the stream elevation willbe measured.

42 JACA needs to provide more details con-cerning the shop drain system testing.The SAP should reference standard pro-cedures and calculations for determiningthe leakage rate.

3 In Figure 5-1, Organizational Chart, A.Gray is identified as both the ProjectDirector and the Quality AssuranceDirector. EPA believes that having thesame person in both positions can presenta conflict of interest.

11 EPA notes that it is JACA's responsi-bility to document that its subcontractorlaboratory has analyzed performance eval-uation samples within the past six months.The SAP must state that JACA will submitthis documentation before field activitiesbeg i n.

12 The SAP needs to identify what agency orfirm will complete the data reduction andvalidation.

13 JACA does not address the need for analyz-ing an equipment blan. Equipment blanksare collected by passing high performanceliquid chromatography (HPLC) water througha decontaminated piece of field equipment,such as a pump or bailer. The purpose ofthis blank is to evaluate if cross-contam-ination is occurring due to improperly de-contaminated equipment.

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Section Page ______________Comment_________________

3 45 Section 3.12.3 states that the SMO willprepare the bottles. This is not con-sistent with previous statements in theSAP.

3 46 The SAP should note that the sequence ofsample collection given in procedure 4 isfor full HSL scans, and that partial HSLscans will follow the same general sequence.In addition, procedure 4 is missing oneline from the Weston SAP. The procedureshould also specify the containers nec-essary for each soil analysis.

3 47 Table 3-3 should indicate which containersare for each analysis. The table alsostates that sample containers holding soilVOA samples will be filled to 75-90%capacity. These samples should be filledto the maximum extent possible.

3 49 Explain how soil gas samples will becoded.

3 50 All ice chests and coolers should be packedwith ice and vermiculite.

3 52 PRP contractors do not generally use EPAthrough CLP traffic reports and chain-of-custody

54 forms. The contractors generally usedocumentation provided by the subcontractorlaboratory.

3 55 Step 18 states that the SMO will be notifiedimmediately following all shipments. Thisis not necessary when samples are not beingsubmitted through the Contract LaboratoryProgram (CLP).

3 57 Step 19 states that traffic reports andsample shipment logs will be submittedto the SMO.

4 3 The tentative project schedule does notagree with the project schedule proposedin JACA's Scope of Work (April 4, 1988).The project schedule should also givethe anticipated duration of each fieldactivity.

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Section Page Comment

14 Section 5.11 states that "audits will beperformed in accordance with establishedprocedures." The SAP needs to referencethese established procedures.

17 Table 5-4, Equipment Maintenance Schedule,lists a radiation meter. If this is tobe used during the investigations, itneeds to be discussed in Section 3.

2 The standard operating procedures forspecific conductivity measurements statethat three readings should be collectedfor each sample. This is an importantQA/QC issue and should be included in theappropriate protocols in Section 3. Thisissue applies to other parameters measuredin the field.

4 Step 5 for calibrating the pH meter statesthat only one buffer solution is used forcalibration. Two buffers are generallyused in calibration.

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