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2 <br /> 2 . Application of bench-test data to site <br /> The bench testing results cannot be applied to the site <br /> because the methods used bear little resemblance to <br /> subsurface conditions at the site. The issue of scale <br /> factor in applying laboratory results to field operations <br /> must also be addressed. <br /> 3 . Consistency of in-situ treatment proposals with SARA. <br /> SARA (Superfund Amendments and Reauthorization Act of 1986) <br /> requires that, to the maximum extent possible, remedial <br /> actions achieve a permanent and significant decrease in the <br /> toxicity, mobility, or volume of a contaminant. EPA' s <br /> concurrence with the in-situ treatment concept will be <br /> needed particularly for the following points. <br /> o Does converting Cr+ to Cr+3 and leaving the Cr+3 <br /> in the soil conform to the intent of SARA? <br /> o Ths bench-scale testing indicated hat the reduced <br /> Cr 3 in the samples oxidized to Cr 6 when <br /> additional leaching with de-ionized water was <br /> performed. The in-situ treatment method proposed <br /> must be able to demonstrate permanent achievement <br /> of the treatment objective. <br /> 4 . Further Work <br /> The Pyrih report recommends further laboratory and field <br /> testing to evaluate soil treatment. Was any additional work <br /> performed? <br />