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i <br /> Mr. Troung Mai <br /> Arcady Dump Site <br /> Holt, California - 2 - 1 December 2000 <br /> 3. Section 3-1 ERM anticipates that.a There is no justification for only drilling six <br /> 1 maximum of six borings will be borings or a description of how the spatial <br /> installed with three soil distribution was selected for such a large <br /> samples collected from each site. Expand this information and provide <br /> boring below the drilling mud. labels on Figure 5 for each location. <br /> 4. Section 3-1 Soils Investigation Approach: With historical detections of toluene, ethyl <br /> Page 3 The analysis will include benzene and xylene, there is evidence to <br /> #2 evaluation of the length of the suggest that gasoline range hydrocarbons are <br /> hydrocarbon chain to assess present. Therefore, analysis for TPH as <br /> mobility characteristics. gasoline, BTEX,PAHs VOCs, SVOCs, and <br /> Oil and Grease should be added to the <br /> sampling program. <br /> 6. Section 3-1 Additional samples will also be As stated in the 19 April 2000 letter, the <br /> Page 3 collected to confirm that Regional Board required the STLC analysis <br /> #3 extractable concentrations of to be run using deionized water. <br /> constituents of concern are Furthermore, DTSC has their own <br /> below MCLs or other requirements for the waste extraction tests, <br /> applicable water quality which require a citric acid solution. <br /> criteria. Therefore, enough sample should be <br /> collected to satisfy both data quality <br /> objectives. <br /> 7. Page 3-3 Drilling Mud:For both total During the initial ERM site investigation, <br /> Table and soluble metal Analysis only selenium did not exceed a specified <br /> Total Ba, Cr, Cr VI, Hg and Pb water quality goal. Again, MCLs and PRGs <br /> are not the only regulatory limit in which the <br /> Regional Board is responsible for reviewing. <br /> All beneficial uses in the Basin Plan must be <br /> evaluated when selecting the water quality <br /> goal. Therefore, all Title 22 metals and <br /> Hexavalent Chromium, TPH as gasoline, <br /> BTEX,PAHs VOCs, SVOCs, Alkalinity, <br /> Calcium, Chloride,pH, Sodium, Potassium, <br /> Sulfate and Sulfide should be added to this <br /> sampling program. <br />