SITE INFORMATION AND CORRESPONDENCE

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Mr. Robert. 0. Godwin 8 February 1988 2. High Explosives (HE) Process Area a. EIQ-3, page 16 - This section suggests that the HE compound RDX in Well W-817-01 might have been " inadvertently introduced during the drilling and construction of the well . " This seems unlikely since RDX is not used in drilling fluid or present in any other drilling equipment or materials. Also, if such was the case, the RDX levels should decrease over time, which they have not. b. EIQ-2, page 21 , and EIQ-3, page 16 - Both reports discuss boreholes drilled in lagoon 827E and refer to low levels of HE found. However, in borehole 827-EI the HE compound HMX ranged in concentration from 1 . 12 to 6.24 ppm, the high value of which is almost two times the calculated designated level for HE of 3.5 ppm (see my letter to you dated 26 October 1987) . Even higher levels of HMX were found in borehole 827-E2 with 390 ppm, more than an order of magnitude greater than the highest value previously reported for any lagoon (29.3 ppm) and 100 times the designated level . This is a large amount, not. "small amount" as stated on page 16 of EIQ-3. Some soil removal will likely be required to protect ground water quality in this area. We will await the Remedial Investigation Report on all the old HE lagoons , due in February 1988, before determining what specific actions will be required. C. EIQ-3, pages 16 - 17 - Here the authors consistently refer to Soluble Threshold Limit Concentrations (STLCs ) as "recommended levels" for metals in soil ; this is a serious misconception. STLCs are the hazardous waste limits and are by no means recommended limits for allowable levels of metals in soil . Much lower levels would be required for any necessary soil cleanup. I understand more complete data on metals concentrations in the old HE lagoons will be available in the upcoming report mentioned above. d. EIQ-2, page 20 - The location of building B814 should be added to Figure 11. Also, is Well W-806-6A in the same aquifer as Wells W817-1 through W817-4? e. EIQ-3, page B-2 - Well W-814-1 should be listed with the other well in this table showing the history of HE occurrence in all the HE Process Area wells. 3. HE Burn Pit - Table B-8 in EIQ 3 lists the units for HE compounds as ug/l , but the text (page 17) refers to ug/g, implying total metals, not soluble, were analyzed in these samples. Also, ug/i is parts per billion while ug/g is parts per million. Which units are correct and was the Waste Extraction Test run? Also, TCE was found slightly above the state action level of 5 ppb in Well W-829-8, the only monitoring well at the burn pit. This could be a new location for TCE ground water contamination. An investigation of TCE in ground water at the burn pit facility should be added to the Environmental Restoration Work Plan.