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Review Comments for Revised Site investigation Work Plan June 2015 <br /> Former Helena Chemical Facility <br /> Page 6 <br /> 8. Appendix C, Table Listing Constituents of Concern, Screening Levels, and Proposed <br /> Laboratory Reporting Limits for Soil; Please address the following comments: <br /> a. The proposed RLs and MDLs for fumigant and organo-phosphorous pesticides are not <br /> included in the table. Also, the RLs and MDLs for two of the organochlorine pesticides <br /> listed (endosulfan I and endosulfan 11) are not included in the table. The Work Plan <br /> should be revised to include the proposed RLs and MDLs for these pesticides. <br /> Analysis for fumigant Pesticides in soil was not proposed in the previous work plans.The <br /> CVRWOCB letter dated February 6, 2015, Comment 7 requested analysis be added for <br /> fumigant and organo-phosphorous pesticides for the groundwater samples.The additional <br /> endosulfan RLs have been added. <br /> b. The proposed laboratory RLs and MDLs for some chemical constituents listed in the <br /> table (e.g. benzene, cadmium, TPH-kerosene, TPH-diesel, delta-BHC, dieldrin, and <br /> toxaphane) are above their regulatory screening levels (i.e. DTSC-SLs or RSLs). Please <br /> ensure that the selected laboratory can perform analyses using the lowest commercially <br /> available and achievable RLs, to provide quantification of constituents for evaluation <br /> with respect to the regulatory screening levels. <br /> Please refer to the response above for General Comments 2. <br /> c. Region 2 ESLs are not applicable for the Site and should be deleted from the table. <br /> References to Region 2 ESLs have been removed. <br /> 9. Appendix C,Table—Sampling and Analysis Plan Summary Table: The Work Plan proposes <br /> to collect a water sample from the stormwater retention basin located at the southeast portion of <br /> the Site, for analysis of total Kjeldahl nitrogen, ammonia, nitrates, organochlorine pesticides, <br /> organo-phosphorus pesticides, fumigant pesticides,and heavy metals.However,depending on the <br /> time of year that the sampling will be conducted, the stormwater retention basin may or may not <br /> contain stormwater. Therefore, the Work Plan should be revised to include provision to collect a <br /> soil sample from the stormwater retention basin for analysis of the same constituents as proposed <br /> for the stormwater sample, in the event that there is no stormwater available in the retention <br /> basin. <br /> Clarification has been made. <br /> I you have any questions regarding the responses in this letter, you can contact Bill Cook or Alex Dewitt <br /> at(209)234-0518,or by email at bcook(n,,condorearth.com or adewittna,condorearth.com. <br /> Respectfully submitted, <br /> CONDOR EARTH TECHNOLOG AL (� <br /> keg F0 <br /> O BILL A. COOK III 2 <br /> No.7802 yr <br /> Bill A.Cook III,PG,C.E.G. �9Alex .Dewitt,PG <br /> Senior Geologist ��` ���� Vice President,Environmental Services <br /> OF L\F� <br /> XAPrcjecr6000_pd 6847 Raymond investments-He '.Reports-Work Plan revision 2•L 20151222 CRWQCB response to review <br /> commems.docx <br /> A %t <br /> ILA CONDO <br />