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Wendy L. Cohen -3- 14 February 1994 <br /> 2. Figure 3 in the work plan lacks the proposed location for'the new monitoring well (MW3). If <br /> a new well is installed, SPTCo should wait at least 48 hours after well developement before <br /> sampling to ensure representative samples. The three monitoring wells on the ATMCo site, in <br /> conjunction with the existing SPTco wells, MW1 and MW2, should be sufficient for <br /> determining the horizontal ground water gradient provided the screens are all completed within <br /> the same aquifer. The installation of a new well may be unwarranted if wells MW 1 and <br /> MW2 are downgradient of areas with high concentrations in the soil. Efforts should be <br /> concentrated towards excavating those soils with the highest concentrations. <br /> 3. SPTCo seems to spend its energy trying to get the highest possible cleanup levels when it <br /> could be moving dirt already. We need a schedule for excavation down to the proposed 241 <br /> mg/kg level now, and then discuss a lower level to protect water quality. This will facilitate <br /> sampling, too. <br /> 4. The work plan lacks a schedule for submittal of a report. <br /> 5. SPTCo should focus on addressing the threat to ground water from the contaminated soils as <br /> soon as possible. After reviewing the SPTCo Tracy Yard file history, I see the same <br /> insistence on SPTCo's part to hold off interim remediation until cleanup levels are established. <br /> 6. The proposed soil sampling should include analyses for those constituents which were found to <br /> be elevated in the 1992 report, including barium, cadmium, copper, mercury and zinc. <br />