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r Mr. Randy Fischback - 2 - 21 April 2003 3. The EA does not include a discussion of facility operations, such as how the manufactured product is transferred to the warehouse or shipping yard and the potential for releases from transferring the product. Dow should provide this information. 4. The EA states motor and hydraulic oil were stored on site, but does not include information showing that petroleum was analyzed for the soil or groundwater samples. Dow must include analytical results showing that petroleum constituents have not been 1eleased at the site. 5. On 6 May 2002, Regional Board staff sent a letter stating that diethylene glycol could possibly be a concern,but the EA does not include analytical results for it. The May 2002 letter also suggested vapor phase samples for volatile organic compounds (VOCs). Dow needs to collect additional samples to analyze for glycols and soil vapor samples for VOCs to determine whether there have been releases at the site. 6. The EA includes the June 2001 Phase II Environmental Site Assessment(Phase II Report) submitted by O'Brien& Gere Engineers, Inc. but not the November 2000 Phase I Environmental Site Assessment(Phase I Report) submitted by Environmental Resources Management Company. The Phase I Report would have been helpful to determine what materials have been manufactured at the facility because Section 1 of the EA states that the facility manufactured rigid insulation board, Section 3.2.1 states an aqueous waste stream and a combustible cleaning solvent were generated at the facility, and the Phase H Report states it is a foam manufacturing facility. It is also unclear what the facility manufactures and how the waste streams generated relate to the production of insulation board or foam. Furthermore, there is no discussion of where these hazardous materials were generated or stored on site to determine whether sampling locations performed to date are appropriate. 7. The EA includes logs of drilling activities but does not include organic vapor meter readings. Boring logs need to include these readings to help assess whether pollution is in the vapor phase and for workers safety. 8. The EA discusses the development of the four monitoring wells but does not include well development logs. The water sampling logs state the water is moderately turbid to murky brown, which shows that the wells may not have been properly developed. Regional Board staff understands that the monitoring wells were not producing sufficient water to fully develop the monitoring wells, and therefore, Dow needs to attempt to develop the wells again when there is a sufficient amount of water in the wells. 9. Appendix D of the EA states that a data diskette is included. Regional Board staff did not receive the data diskette and requests Dow provide the data diskette if it contains additional information not already included in the EA. 10. Based on the conepenetrometer testing (CPT) logs in Appendix D, it does not appear that the bottom of the gravelly-sand zone was found in CPT-01 or CPT-03. Dow needs to