SITE INFORMATION AND CORRESPONDENCE

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a Mr. Verrill Norwood -2- 5 November 1996 Table 1, Laboratory Analysis Results for Hydropunch Samples The groundwater analyses for HP-1 and HP-8 shown in Table 1 appear to be reversed. The laboratory data show that groundwater from HP-1 had 2,330 1..tg/1 chloroform and <250 µg/1 carbon tetrachloride and groundwater from HP-8 had <2.0 µg/1 chloroform and <1.0 µg/1 carbon tetrachloride. Table 1 has these reversed. Figure 1, Chloroform Concentrations in Soil and Water Samples Figure 1 is identical to Figure 2, Carbon Tetrachloride Concentrations in Soil and Water Samples. Both figures show carbon tetrachloride, not chloroform, concentrations in soil and groundwater. BACKGROUND We do not agree that the groundwater elevation data since March 1995, while the facility was both operating and idle, indicate that groundwater flow beneath the All Pure facility is not impacted by facility operations such as groundwater pumping or operation of the surface impoundments. When Polly Lowry of our staff visited the site in January 1996, the two wastewater ponds were full of water even though the facility was not operating. There also was a significant volume of water in Fire Pond 1 and in the stormwater pond. All of these ponds were also full during March 1996. In addition, we received a complaint during September 1995 that the wastewater ponds had regularly overflowed during the winter of 1995. Thus, it is likely that any mounding effect due to water in the ponds is a year round phenomenon. COLLECTION OF SOIL AND WATER SAMPLES Laboratory Analyses Groundwater Samples The report states that chloroform detected in the six out of eight groundwater samples did not correspond to those locations where chloroform was detected in soil. This statement is incorrect. With the corrections to be made in Table 1 for groundwater samples in HP-1 and HP-8 (see discussion above), chloroform detected in each groundwater sample is associated with chloroform in corresponding soil samples. CONCLUSIONS AND RECOMMENDATIONS We do not completely agree with the statement that there is no strong correlation between soil and groundwater concentrations collected at the same location or between locations. With Table 2 corrected for hydropunch samples HP-1 and HP-8, chloroform was detected in each soil sample in which chloroform was also detected in the corresponding groundwater sample. Although the soil concentrations do not precisely indicate the concentrations in groundwater, for chloroform concentrations greater than 2,000 µg11 in groundwater, chloroform concentrations in soil increased with increasing chloroform concentrations in groundwater.