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rr' Memo to Antonia Vorster -2- 12 December 1985 4. Wells No. 7 and No. 9 have not been sampled. They were drilled in their current location to provide vital information about the quality of the ground water moving off-site. Samples must be obtained in these locations. If wells No. 7 and No. 9 will not yield samples, then new wells must be drilled. 5. The WET extraction is performed using citric acid to simulate the condi- tions in a landfill. Since no pH data has been submitted, no conclusions can be drawn as to the applicability of this test. Arcady should determine the pH of the material in the impoundment. If the pH is near 7, then representative samples from borings containing barium, chromium, cobalt, lead, and nickel should be extracted with distilled water and analyzed for those metals. I understand these samples are currently in storage. Once this relationship is established between citric acid extraction and distilled water extraction, a determination can be made as to further required work. 6. No geologic cross-sections were submitted. 7. If Arcady plans to close the facility, they must comply with Article 8 of Subchapter 15. 8. Table No. 1, the soils analysis results for metals, is an unsigned, handwritten worksheet from Anlab. We must have final , signed lab reports. 9. On Page 8 of the report, the claim is made that "the only problem is at the southern extremity of the site near soil sample location No. 11. " The report makes no mention that there are 'designated' levels of other metals throughout the site, and ' hazardous ' levels of barium in boring No. 10. There are no ground water samples from wells No. 7 and No. 9. Before such a claim can be made, these critical areas must be evaluated. 10. The report proposes that Arcady do additional sampling near boring No. 11. I agree that this is critical . The proposal is for one boring 20 feet north and one boring 20 feet south of No. 11, and additional borings "if required". I would suggest, that if a drilling rig is to be hired, then numerous samples should be taken. These should be stored and then analyzed in a sequential manner, based upon previous analyses. My comments on the project, in general , are as follows; 1. Ground water elevations were submitted to this office. Elevation data for four dates were given as "from the bottom of the hole" . In order to interpret these data, mean sea level elevations must be provided (with an accuracy of 0.01 feet) . 2. The work plan approved by this office committed Arcady to use an 8" hollow stem auger to drill monitoring wells. This would allow adequate sand/gravel pack to be placed around the 4" well . The well logs submitted on 24 May 1984 state that a 6 Auger was used. This would allow only 1" of packing in the annulus between screen and hole.