FIELD DOCUMENTS AND WORK PLANS 1988

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ATTACHMENT A 1. Ref: page 1 of Attachment B: Because recent data indicates arsenic and copper have migrated to depths greater than originally thought, the Department has concluded that the statement- "Other wood treating constituents have been shown to be geochemically immobile and will not leach into the groundwater" . is not respesentative of site conditions. . The Marley Cooling Tower Company (MCTC) is therefore The to include the "Potential leaching of contaminants into groundwater" as one of the data gap items. The Department further advises MCTC that per Section 264 . 98 (a) (2) , Title 40, Code of Federal Regulations (40CFR) , the mobility, stability and persistence of all waste constituents (and any reaction products) in the unsaturated zone must be determined and monitored. 2 . Ref: .page 2 of Attachment B: (Re: page 4-1, Section 4 . 1. 1 of the Workplan) All samples collected from locations N-5, N-6, N-7 and N-9 must be analyzed for total chromium, hexavalent chromium, copper and arsenic. Moisture content shall also be determined at the time of analysis. 3 . Ref: page 4 and 5 0£ Attachment B: (Re: first paragraph, page 4-8 of the Workplan) The Department agrees with the intent of the remedial investigation as stated, however, all monitoring wells &hould be capable of monitoring groundwater conditions and should not be limited to monitoring "the effectiveness of implemented actions" . Our comment to add - "and monitor" to the first sentence of paragraph one is therefore reiterated. 4 . Ref: page 5 and 6 of Attachment B: (Re: second paragraph, page 4-8 of the Workplan) J6s agreed to during our August 19, 1988 meeting, MCTC will- utilize illutilize both continuous coring and geophysical logging :procedures. The number of borings which will be continuously cored will depend on the adequacy of the initial logging effort. It was also agreed that the ;Department ' s representative will be on site during the