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Mr. Fernando Amador -2- 6 April 1995 <br /> Section 4.4.1, Conceptual Model of the Ground Water Flow, of the RDFS stated that on 2S August <br /> 1992, the Zone A ground water flow direction was southeast to southwest. A southwest flow <br /> direction would explain contamination southwest of the site. <br /> The source of the regional gradient should be cited. Based on a southeast gradient, monitoring well <br /> (MW) 16 is cross-gradient of the site (Area I) and not upgradient. <br /> 4. Section 3.2.4, Aquifer Test Design <br /> Appendix C stated that the purpose of the pumping test (in MW 19)was to evaluate hydraulic <br /> conditions of the underlying aquifers and to determine if ground water pumping and treating is a <br /> viable remedial alternative for the site. The memo did not explain why MW 19 was selected as the <br /> pumping well and whether or not pump-and-treat is a viable remedial alternative. <br /> 5. Section 3.3, Analytical Results <br /> The memo stated that a QA/QC review showed that most QA/QC parameters were within control <br /> limits. The memo should explain which parameters were outside the control limits and whether the <br /> results for these parameters are invalid since they are outside the control limits. The memo should <br /> also include measures taken or planned to meet data quality objectives in the future. <br /> 6. Section 3.3.1, Soil Analytical Results <br /> Table 3-9 does not include sample results for total petroleum hydrocarbons as diesel or gasoline <br /> (TPHd/g) for MWs 17 and 18 as stated in the memo. Isocentration maps of soil contamination in <br /> Zones A, B, and C should be included in the memo to clearly identify data gaps, if any. <br /> 7. Section 3.3.2, Hydropunch Sampling Results <br /> The memo stated that Hydropunch samples were taken from MWs 14-17 in Zones A and B, and that <br /> Zone C MWs 14-16 are upgradient and cross-gradient of the site, suggesting that there may be <br /> upgradient sources. <br /> The memo should explain why samples were not taken in M-1R and MWs 18 and 19 which are Zone <br /> A wells. Since the gradients at the site have not been fully established, it is premature to say which <br /> direction is upgradient or downgradient. Potential offsite sources should be identified to determine if <br /> they are contributing to the contamination onsite. <br /> 8. Section 3.3.3, Ground Water Analytical Results <br /> The memo stated that in Zone A, the PNA plume has not been defined in the downgradient direction. <br /> Figure 3-8, 3-9, and 3-10 show that the extent of PNA contamination has not been defined in all <br /> directions in Zones A, B, and C. Figures 3-16 and 3-17 show that the benzene contamination in <br /> Zones B and C have not been defined. Table 3-13 shows that MW 17 in Zone B and MWs 13 and <br /> 16 in Zone C were not tested for TPHd/g and BTEX. The memo should explain this inconsistency <br /> in the sampling program. In Figure 3-15, Benzene Isoconcentration Plot, Zone A, the notation next <br />