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ATTACIUWENT 1 <br /> EPA COMMENTS ON <br /> DEFENSE DISTRIBUTION REGION WEST - TRACY, CALIFORNIA <br /> DRAFT SOW FOR WELL EVALUATION AND ABANDONMENT <br /> (DATED TAN. 31, 1994) <br /> 1. General Comment: It is assumed that regulatory agencies will be included in any <br /> decision-making regarding well abandonment and/or relocation. <br /> 2. Objectives: One option not stated in the SOW objectives (when reconstruction is not <br /> possible) should be to locate a new well adjacent to the original location of any well <br /> being abandoned. <br /> 3. Sample Analysis: It is not clear why the text states that the AE perform 'chemical <br /> analysis as needed to determine the presence of OU41 Record of Decision chemicals <br /> of concern." The list of analytes should not be limited as stated. Chemicals of <br /> concern continue to be identified, e.g., chlordane. [Note: Table 1 does not appear to <br /> place such a limitation on the number of analytes. Therefore, it appears that this text <br /> could be revised.] Can it be assumed that the methodologies in Table 1 are the same <br /> as those in the approved Comprehensive RDFS work plan? <br /> 4. Detection Limits: It would appear that DLA intends for this data to be of RI quality. <br /> Towards this objective, it may be useful to state that detection limits will be the same <br /> as those set forth in the approved Comprehensive RI/FS Work Plan and amendments. <br /> 5. Data Reporting and Data Quality: The text indicates that the COE will utilize E-Data <br /> Data Validation software. [Note: This software is currently being evaluated by EPA.] <br /> EPA concurrence should be obtained for modifications (i.e., fine tuning) made to the <br /> software. Data submitted to EPA should be in the same electronic format as sent by <br /> the AE to COE. [Please also note that EPA will "check" the data validation, DLA or <br /> its representative willen dorm the data validation.] <br /> EPA/10M94 1/1 <br />