SITE INFORMATION AND CORRESPONDENCE

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Mr. Verrill Norwood -2- 18 October 1996 As I discussed with Mr. Lerner, it is acceptable to collect only one discrete soil sample from the bottom of each pond to analyze for minerals. Sidewall soil samples are not now necessary for general mineral analyses. Laboratory Analysis EPA Method 8010 should be used to detect the presence of chlorinated VOCs, rather than the proposed EPA Method 8020. The proposed detection limits of 0.5 µg/l for chloroform and carbon tetrachloride are acceptable. These detection limits also should be achieved for all other constituents reported by EPA Method 8010. Nitrates should be included in the mineral analyses for soil samples since nitrates are known to be present in the ground water. Although the source of nitrates in ground water at All Pure is likely the surrounding croplands, nitrate analysis of the soils is necessary to determine if the All Pure facility is an additional source of nitrates. Task 5 - Report In addition to the items listed to be included in the report of soil sampling results, the report also shall include photographs of the wastewater pond liners, the disposal or remediation method for contaminated soils, proposed cleanup levels, an estimate of the volume of soils to be excavated, removed, or remediated, a grading plan, and proposals for confirmation sampling. We also need more details on the source of the clean compacted native soil such as the exact source area of the fill material and verification of its being uncontaminated. ADDITIONAL CONCERNS Additional concerns which must be addressed include stormwater discharges, the continued discharge of water softener to the stormwater pond, and the proposed schedule. Kate Gaffney of our staff will be contacting you regarding submittal of a notice of intent for an industrial stormwater permit. Under a stormwater permit, discharges of anything other than stormwater are prohibited. All Pure states efforts are continuing to find alternatives for disposal of discharges from the water softener with an alternative disposal method expected by 31 December 1996. All Pure must file a report of waste discharge (RWD) for this discharge and obtain waste discharge requirements (WDRs) until an alternative disposal method is actually in place. A blank RWD and filing fee schedule are enclosed for your use. There are some inconsistencies in the proposed schedule related to soil sampling in and closure of Fire Pond 1. Since this pond cannot be emptied, sampled, and closed until after closure of Fire Pond 2, the schedule must incorporate this. All Pure must submit a revised schedule which addresses the following comments. Emptying of ponds and removal of liners Fire Ponds All Pure should estimate when Fire Pond 1 will be empty. Discharges to this pond are proposed to cease by 1 December 1996 when the aboveground storage tank (AST) is installed. As noted below, installation of the AST at Fire Pond 2 will not be possible until after submittal of the closure report for the two wastewater ponds, the former small wastewater pond, and Fire Pond 2. This closure