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RE-MANUFACTURING MEETING -2- 10 May 1991 Mr. Vaughn also stated that sufficient data must be obtained for soluble lead (using the citrate Waste Extraction Test) to correlate with the total lead results. He stated that we cannot approve closure of the impoundment as a class III landfill with hazardous waste left in place. This not only includes total lead concentrations above the TTLC, but also soluble lead above the Soluble Threshold Limit Concentration (STLC) of 5 mg/l . Mr. Moore stated that he fully intends to meet the 1 June 1991 deadline. We received the sampling plan by FAX at 3:30 pm on 2 May 1991, and samples were collected the following morning. Therefore, there was little time for review. The plan appeared to contain some deficiencies. For instance, there were no borings proposed that stepped away from the impoundment as was discussed at the meeting. We are concerned that if at five feet (the greatest sampling depth proposed in the plan) i the side'-wall samples' contain- hazardous levels of lead or levels higher than the surrounding area, there won't be enough time to collect additional samples to complete ' the closure plan and HAR. Samples collected outside of the impoundment could also help prove Mr. Moore's claim that the entire area contains high levels of lead. As discussed at the meeting, we can't approve closure by removal if we don't know the volume of soil that needs to be excavated or the levels of contaminants that will remain in place. Therefore, we recommended taking samples further away from the I impoundment to avoid a trial and error approach. I mentioned our concern that the plan did not propose samples outside of the impoundment to Ms. Kataoka and Mr. Moore in the field on the 28th. Mr. Moore stated that he will excavate whatever is necessary to close the impoundment. However, the limits of the excavation must be defined through sampling. Lack of sufficient sampling at this point is risky. The samples collected j may be sufficient, if the results come out as Mr. Moore expects. If not, it could be very costly since 1 June 1991 is rapidly approaching. Another concern was that the plan only proposed analyzing three of the twenty-six samples for soluble lead, using the citrate Waste Extraction Test (WET) . At the meeting they had proposed to analyze 25 percent of the samples for soluble lead. I discussed the need for a good correlation between total lead and soluble lead in the field with Ms. Kataoka. She stated that additional samples would be analyzed, using the citrate WET. JEM:jm I