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Antonia Vorster -2- 25 August 1989 <br /> Response to 17 January 1989 agency comments and Draft Sample Plan <br /> In March 1989, USATHMA submitted a Response to the comments supplied in the <br /> Agencies' 17 January 1989 letter. In June 1989, USATHMA submitted a work plan <br /> titled "Draft Sample Plan" which was presumably meant to fulfill the "Work Plan <br /> for Remaining RI/FS Work" requirement in the IAG. The Draft Sample Plan, as well <br /> as all of the USATHMA documents mentioned above, were prepared by Hunter/ESE, <br /> consultants to USATHMA. <br /> The submitted Work Plan ("Sample Plan") contains a lengthy discussion of "solid <br /> waste management units" (SWMUs) , targeted as potential areas of concern by EPA <br /> and proposes soil and ground water sampling to investigate the SWMUs; a storm <br /> and sanitary system investigation consisting of a records search, video taping <br /> line interiors , and soil/soil gas sampling; air monitoring for volatile organics; <br /> and arsenic sampling consisting solely of collecting off-site samples for <br /> background comparisons. These tasks have been requested over the past years <br /> numerous times. Some understandably very general , non-specific proposals of <br /> numerical modelling, endangerment assessment, remedial action alternatives <br /> analysis, and the RI/FS and ROD were also included. Our request that <br /> investigation of underground storage tanks be integrated into the RI/FS program <br /> was not clearly addressed. USATHMA simply states that a completely separate <br /> contractor and scope of work will be utilized. <br /> General Comments <br /> As is typical with Hunter/ESE submittals on this project, much of the presented <br /> material is incomplete and/or of poor accuracy. More importantly, the work plan <br /> lacks adequate responses to the Agencies' comments and legitimate justification <br /> for proposed actions or inaction. Only one page of the over 200 page document <br /> is devoted to discussing additional monitoring wells to complete definition of <br /> the contamination plumes. I have assumed that USATHMA' s March 1989 Response to <br /> Comments should be used as support regarding monitoring wells, although no such <br /> reference is made in the Work Plan. Even using both documents together, the two <br /> submittals are unacceptable and are inadequate to complete all necessary RI work. <br /> This is surprising given the Agencies' 17 January 1089 zone by zone, plume by <br /> plume analysis of the extent of ground water contamination data which identified <br /> the specific data needs to complete plume definition. <br /> Specific Comments <br /> My specific comments on the Work Plan which includes review of the March 1989 <br /> Response to the Agencies' Comments are as follows: <br /> 1. Proposed well locations are shown on four separate maps in the work plan (and <br /> four different maps in the Response to Comments). The maps do not show <br /> existing monitoring well locations, contamination sources, or plume contours <br /> to evaluate the proposed locations. The exact locations of the proposed <br /> wells are unclear since the maps do not use the grid system developed by <br />