SITE INFORMATION AND CORRESPONDENCE

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Mr. Peter T. Quinlan Page 2 February 2, 1989 resolved in a meeting between DHS and Hargis before well construction begins. DHS requires ten foot screen lengths where possible, and adherence to TEGD guidance documents. Screen lengths of greater than 20 feet are not acceptable. B. Closure Plan. 1. The Plan does not address the removal and disposal of trees, shrubs, bushes, and other plant life in the disposal area. This subject needs to be addressed in the Plan. 2 . The Plan calls for moving sludges and the top three inches of soil in the Pond 2 area into Pond I. This transfer of sludges and soil from Pond 2 to Pond 1 may be a problem when considering the amount of sludges/soil in Pond 2 and the small size of Pond 1. 3 . The Plan does not provide rationale for stabilizing the top three inches of soil. Rationale for selecting three inches, or any other depth is requested. 4 . The Closure Plan does not address closure of the 1, 1, 1-Trichloroethane area, nor does it identify the boundaries of the area to be capped. Past soil samples have not provided adequate data to define the area of contamination and cap boundaries. A grid distribution soil sampling plan needs to be written and implemented to determine the extent of soil contamination so that the boundaries of the cap can be determined. 5 . The Closure Plan does not adequately address the possible discharge area from the laboratory sink. There should be an attempt to identify and quantify these wastes and associated discharge areas. 6. The Closure Plan does not address the Title 22 requirement that a liquid monitoring and collection system should be incorporated into the sand/aggregate layer between the asphalt and synthetic membrane cap. 7 . The Closure Cost Estimate section of the Closure Plan needs to be redone to account for the deficiencies in the plan.