WORK PLANS - Laserfiche WebLink

Home Browse Search

Review Comments for Revised Site Investigation Work Plan-lune 2015 Former Helena Chemical Facility Page 4 exceed the MCLS, cleanup levels cannot be set higher than the MCLS. Cleanup levels can be addressed further in a feasibility study. This section has been included in the work plan. 2. Furthermore, if constituents of concern in soil are detected above DTSC-SLs or RSLs, data should be further evaluated based on site specific conditions to determine if there is a risk to human health and/or threat to groundwater(i.e. leaching concerns), and whether further action is required.Threats to groundwater should be addressed through DI-WET testing and/or modeling. This section has been included in the work plan. 3. Section 3.0, Fourth Paragraph: The Work Plan states that "The data quality objective arts not met by the BC Laboratories EPA Method 504.1 detection limit for the analyte 1,2,3- trichloropropane. If laboratory data indicate non detect for 1,1,3-trichloropropane, then the results for otherfrnrigant pesticides may be used to evahrate whether that analyte may be present at a loner concentration and if additional sampling and/or analysis is needed. BSK Laboratories is capable of meeting the data quality objective for 1,1,3-trichloropropane using a California Department of Health Services method. However, the CVRYVQCB letter dated February 6, 2015 directed the ase of EPA Method 504.1 or an equivalent Method. SYVRCB tvebpage guidance indicates that the notification level is the same as the detection limit using Method 504.1, but Condor was unable to evaluate whether BSK methods would be equivalent or justified". Please use the following analytical methods(or equivalent method): a. Analytical methods developed by the California Department of Health (DHS) that are capable of quantification of 1,2,3-TCP at the notification level/detection limit for purposes of reporting (DLR) of 0.005 ug/L are acceptable. The selected laboratory may perform analysis for 1,2,3-TCP using one of the DHS gas chromatography/mass spectrometry (GC/MS) methods - Purge and Trap GUMS or Liquid-Liquid Extraction GUMS. This section has been included in the work plan. b. EPA Method 504.1 is also acceptable if the selected laboratory can demonstrate that the method is capable of achieving the DLR of 0.005 ug/L without method modification. See discussion above. 4. Section 6.0,First Sentence:The Work Plan states that fifty soil and groundwater samples will be analyzed for TKN, ammonia, and nitrate.However,the numeric value shown in parenthesis is 51 rather than 50.Please revise the Work Plan to correct this typographical error. The correction was made. 5. Sections 7.0 and 8.1: Section 7.0 of the Work Plan states that soil samples will be collected at approximately 15 feet below ground surface from the three proposed groundwater monitoring wells, and that one of the samples will be tested to determine permeability (hydraulic conductivity)of the soil.The Work Plan does not however, state what the other two collected soil samples will be used for or tested for. Additionally, Section 8.1 states that soil samples will be collected from the monitoring well borings for laboratory analyses based on field observations and planned collection depth but does not specify which analyses would be performed on these samples. The Work Plan should be revised to specify the analysis planned/anticipated for all soil samples collected from the monitoring wells borings. A lkkw- ILA CONDOR