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Mr. Sheldon Heckman - 3 - 12/27/01 <br /> Mr. Richard Calone,`Esq., <br /> Richard Calone, Inc. <br /> Specific Comments: <br /> 1. Section 2.1, Site Description: The text states that Figure 2 is a site plan view showing all adjacent <br /> streets, buildings and open work spaces (concrete and asphalt). Figure 2 covers just the immediate <br /> investigation area at one corner of the warehouse/truck bays building. Please include a figure <br /> showing the entire site, as described in the text. <br /> 2. Section 2.4, Previous Site Assessment, page 6, Bullet 5: The text states that TPH-D detected in <br /> groundwater at 110 µg/L"is not of great concern". Please remove this statement from all future <br /> reports, and review the attached Board memo Beneficial Use-Protective Water Quality Limits for <br /> Components of Petroleum-Based Fuels (Attachment A), which states that the water quality objective <br /> for TPH-D is 100 µg/L(taste and odor threshold). <br /> 3. Section 1.0 Introduction, Section 3.2, Groundwater Monitoring Well And Soil Vapor Extraction <br /> Well Installation And Scope; and Figure 2: These two sections and the figure conflict with each <br /> other on the total number of SVE wells proposed in the Work Plan. Section 1.0 says five new SVE <br /> wells will be installed. Section 3.2 states (and Figure 2 shows the locations for) four new SVE wells <br /> will be installed. Please clarify the number of proposed SVE wells, and the location of the fifth SVE <br /> well,if applicable. <br /> 4. Section 3.1 Permitting And Pre-Field Work Activities: The Text does not discuss the need for, or the <br /> agencies requiring, permits for well construction and SVE testing. Please provide a discussion of the <br /> permits required and permitting agencies. <br /> 5. Section 3.2 Ground Water Monitoring Well And Soil Vapor Extraction Well Installation Scope: The <br /> text states that the two SVE observation monitoring (test) wells are actually SVE/groundwater <br /> recovery wells. See comment 2 for an explanation on why these wells should not serve a dual <br /> purpose of extracting groundwater and monitoring the SVE test. Please clarify the purpose for these <br /> wells, and explain how these SVE test wells will be designed to ensure discrete sampling of soil gas <br /> and groundwater will be possible, with one screened interval intersected by the water table. <br /> 6. Section 3.3, Drilling, Soil Sampling, And Well Completion, and Section 4.1, Soil Pilot Borings <br /> Advancement And Sampling, conflict with each other on which soil sleeve will be sampled and <br /> analyzed. Section 3.3 says the lead (first) sleeve will be chosen. Section 4.1 says that the second <br /> sleeve will be chosen at the depths specified in Table 5, although the text continues by adding that an <br /> organic vapor meter equipped with a photo ionization detector(PID) will also be used to determine <br /> which sleeve will be chosen. Please clarify which sample sleeve (first, second, etc.) will be sampled, <br /> and whether the PID screening will be used to override the standard selection (first, second sleeve, <br /> etc.). We would prefer that the PID would be used first to screen all of the sleeves (regardless of <br /> depth), and then the sleeve with the highest PID reading be chosen for analysis. If the purpose is to <br /> fill in data gaps from previous investigations, then targeting that missing depth profile would be <br /> applicable. <br /> 7. Section 3.7 Ground Water Sample Collection And Analysis and Table 1: The analytical results of <br /> previous investigations show a wide range of method detection limits (MDLs) for individual <br />