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Wendy L. Cohen -3- 26 July 1995 COMMENTS ON WORK PLAN Soil An additional Geoprobe boring should be placed between Areas 4 and 7 to ensure adequate representation of the site along the pipeline. Geoprobe sampling should be performed using a four-foot sampling tube inside the rod in order to obtain continuous cores for logging purposes. A deep Geoprobe boring should be installed in Area 4 to evaluate the extent of petroleum hydrocarbons in the soil below the water table. Where petroleum hydrocarbons are indicated, all geoprobe samples should be analyzed for total purgeable petroleum hydrocarbons (TPPH) by EPA Method 8015 modified, and total recoverable petroleum hydrocarbons (TRPH) by EPA Method 418.1, in addition to the tests proposed. The sampling protocol should also be revised to include using EPA Method 8270 for analyzing PNAs where it appears that EPA Method 8310 may not be giving accurate results. The soil boring to be converted to a monitoring well closest to Area 4 should be continuously cored. Coring and sampling should extend below the water table to the bottom of the boring, as with the deep Geoprobe boring in Area 4. At least one petroleum-affected sample from Area 4 and a background sample from the upgradient monitoring well should be analyzed for total and soluble metals using the waste extraction test using deionized water as the extractant. Ground Water Piezometers should be installed in the Geoprobe borings to estimate the ground water level and gradient for placement of the monitoring wells. At least two wells should be downgradient of the pipeline. An interim report of the Geoprobe investigation, including gradient information, should be submitted for approval prior to installing the monitoring well borings to confirm their locations. All samples should be analyzed according to the sampling protocol, as modified above. JDMJsb