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Jim Tjosvold, P.E. <br /> Page 2 <br /> September 21 , 1987 <br /> of hydrazines and nitrosoamines, from using the GC/FID method, <br /> has been submitted to the State. Unless equivalency testing <br /> can be shown for these methods, past data will need to be <br /> audited by the HML to determine adequacy. <br /> Comment 24 <br /> The State has requested that EPA Method 8040 be used to <br /> analyze all chlorophenol species. The revised Workplan has <br /> not listed that tetrachlorophenols will be analyzed. Because <br /> they are a breakdown product and a by-product of <br /> pentachlorophenol and are an environmental concern, the <br /> analysis list should be amended. <br /> Comment 45 <br /> McCormick and Baxter has submitted an acceptable method for <br /> purging the monitoring wells. However, the procedure for <br /> collection of water samples for volatile components must be <br /> corrected. The proposed method is to reduce the flow from the <br /> submersible pump to collect samples. Although this method is <br /> not ideal because of sample agitation and introduction of air, <br /> this collection system can be used for samples to be analyzed <br /> for semi-volatiles and metal analyses. This type of pump <br /> action does purge volatiles out of the water and should not be <br /> used. Volatile samples should be collected with a teflon <br /> lined or stainless steel bailer or a bladder pump. <br /> McCormick and Baxter did not submit their sampling procedure <br /> until it was requested by the State (July 3 , 1987) . Pumps <br /> were installed and samples were collected before the State <br /> could comment on McCormick and Baxter's amended workplan. In <br /> order to clarify data from samples collected using this <br /> incorrect procedure, the report must state that a submersible <br /> pump was used to collect the samples. Data will be suspect in <br /> interpretation by the State. Due to cost considerations, <br /> wells within the plume with high levels of contamination may <br /> continue to use the current method of sample collection. <br /> However, this sampling procedure will not be allowed for <br /> monitoring wells installed at the plume boundary. Sampling <br /> procedures will need to be modified for all wells with results <br /> near or below detection limits. <br /> Comment 60 <br /> Task 11 (Dioxin Assessment) stazt and completion dates have <br /> been moved up on the schedule by 12 weeks. There are <br /> additional tasks, which are associated with Task 11, such as <br /> final PHERA (Task 13) , Soil and Stormwater OUFS (Task 17) and <br /> Plant Process OUFS (Task 20) which can also be moved up as <br /> indicated by our July 3, 1987 comments. The State has not <br /> received justification for not moving up these tasks. The <br />