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Mr. Jeff Werner October 5. 1990 Page 3 petroleum hydrocarbons(TPH)as will as benzene,ethylbenzene,toluene,and xylene(BETX) are non-detectable in the soil. As per the attached phone conversation on September 10, 1990 between Mr.Tom Peltier of the Board and Mr. Steve Misner of Brown and Caldwell (Attach- ment A),the stockpiled soil can be disposed of at a County Landfill, provided that appropriate approval is granted from the landfill_ At Geweke's request. Brown and Caldwell can coordinate soil disposal activities. However, to minimize costs, we recommend that Geweke contact a local Class C landfill and make arrangements for the soil to be disposed of at their earliest convenience. Quarterly Groundwater Monitoring Program Because the most recent efoundwater analvses indicate that the groundwater contamination M has migrated, a quarterly groundwater monitoring program is recommended. Quarterly groundwater monitoring will allow for an evaluation of seasonal fluctuations in groundwater levels as well as an evaluation of the dominant direction of movement. Quarterly data will be used to monitor: 1) groundwater flow direction and hydraulic gradient; 3) changes in the concentration of contaminants in groundwater,3)seasonal fluctuations and prin:ipal migration direction of the contaminants; and 4)effectiveness of a remedial action plan(once the interim treatment system is installed and operating). ,v Quarterly monitoring will consist of sampling and analysis of groundwater from the nine mon- itoring wells located on and adjar:ent to the subject property. Groundwater samples will be analyzed for TPH and BETX using EPA Method 5030/8015(modified). If additional monitor- ing wells are installed,(as recommended in this letter),these wells should also be incorporated into the monitoring program. Groundwater samples will be collected ir.accordance with gen- erally accepted geological and engineering practices in the environmental consulting industry and by the Board so as to insure that sample integrity is maintained. Analytical results will be summarized in quarterly reports, which will br submitted to Gewcke for review and then the Board. Design of an Initial Groundwater Treatment System As required by Order Number 90.702,a groundwater remedial action plan must be developed that will address the contaminated groundwater beneath the site. Brown and Caldwell recommends installation of a groundwater extraction and treatment system. This involves pumping of contaminated groundwater from wells and creating by appropriate methods. . No one remediation technique is effective for all types of compounds under 0.11 site conditions. Several different alternatives may be effectively employer,to remove the contaminant from the groundwater such as air stripping, carbon adsorption, advanced oxidation, and direct discharge. Brown and Caldwell Conswants I?t