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ATTACHMENT REVIEW COMMENTS ON 30 MAY 1989 HARGIS CLOSURE PLAN Page 16: Water levels in SMW-2 are reported to be inconsistent and not representative of ground water elevations in the project area. Figure 6 (ground water level contour map) has a questionable elevation for SMW-1 and not SMW-2. It is unclear whether the inconsistent ground water levels in SMW-2 are representative of the entire historical pattern or whether the inconsistency has occurred since recovery from being dry in November 1988. Page 25: Pumpage reccrds are to be collected monthly for the production wells within a mile of the site. The pumpage records should be reported and correlated, if possible, to the ground water flow direction. This may be depicted by displaying each well pumpage as a percentage of the total using a pie chart for the well point on the water level contour maps. Page 29: The list of Canonie soils borings did not include T-7. T-7 was not included on Figure 10 or elsewhere in the Closure Plan. This boring was installed immediately west of Pond 1 near the dry well during the same period as when T-6 was installed. The analytical results from T-6 and T-7 were reported in the 5 February and 6 February 1987 letters from Canonie Environmental . Page 31: The original analytical data and boring logs from SB-8 and SB-9 could not be located in any of the records at the Regional Board. These boring logs should be submitted to the Regional Board. Page 33: Hargis should consider analyzing for Cation-exchange capacity, particularly for those soil samples taken where acidic wastes were disposed. Page 33: The selected trace metals for soils analyses include barium, beryllium, copper, lead, mercury, silver and zinc. The constituents which exceed the maximum background or the statistical background concentrations also include cadmium, cyanide, iron and molybdenum (but did not include beryllium) . The rational for not including cadmium, cyanide or molybdenum as the selected trace metals for soils analyses was not presented. In addition, it appears that the metals were selected based on constituents present in the waste streams (pg.34). Silver cyanide is used in the manufacturing process (pg.7) . Because Figure 13 depicts cyanide as present in shallow soils in Pond 2S, cyanide should be included as an analyte for soil samples collected in the Pond 2 area. Page 34: The rationale for final sample depth in the deep soil borings was not presented. Two deep borings are to be installed to 40 feet. However, if previously collected data indicates that contamination has not extended to this depth, then the total depth for the deep borings may be reduced. COPY