WARZYN 0 0 0 0 0 9

& ScientistsEnvironmental Services

Wasre ManagementWater Resources

Site DevelopmentSpecial Structures

Georecnnical Analysis

July 25, 198913452.99 ^

Mr. Jack DowdenProject Coordinator - Hagen Farm RI/FSWaste Management of Wisconsin, Inc.2 Park Plaza10850 West Park Place, Suite 1200Milwaukee, WI 53224

Re: Response to Comments - Tech Memo 1

Dear Mr. Dowden:

Enclosed are our responses to U.S. EPA comments on Tech Memo 1. Theseresponses have been'prepared at the request of U.S. EPA in order to completethe public record prior to the public meeting scheduled for July 27, 1989.

We trust these responses are satisfactory and look forward to the expeditiousconclusion of the Hagen Farm RI/FS.

Sincerely,

WARZYN ENGINEERING INC.

<cfGregory E. AsburyProject Manager

cc: Jae Lee, U.S. EPATheresa Evanson, WDNRGary Parker, Jacobs

GEA/ckb[ckb-600-59]

Warzyn Engine:'"̂ <•••:One Scie-K* £:.-•:

University Hesejrin ?.'••.PC Be. 5-;35

M,i3ison. Wisconsin 537,'5(6061 2 73-•:-:-

The following responses were prepared by Warzyn Engineering Inc. for technicalreview comments on Technical Memorandum Number 1, Hagen Farm Site RI/FS. Thecomments were provided by Jacobs Engineering Group Inc. (Jacobs). Referencesto specific section numbers, tables and text in responses are based on theTechnical Memorandum Number 1 (Tech Memo 1) format; the reference may changeor not apply when eventually incorporated into the Remedial Investigation (RI)report.

1.0 Introduction

Acceptable as is, no comment.

2.0 Summary of Work Performed

In general, this section adequately summarizes field activities for the firstphase of the remedial investigation. However, certain details (e.g., timeperiod for the specific activity) have not been presented in the text.Specific comments are presented below.

2.1.1 Geophysical Investigation

The text does not specify the time period during which the EM and magnetometersurveys were performed. Figure 1 likewise does not present the time periodfor this (or any) of the field activities. Specific information should beprovided, both in the text, and in a PERC chart as a new figure.

Response: The EM survey was performed from July 12 to July 15 and July 18 toJuly 21, 1988. The Magnetometer survey was performed from July 19to July 22, 1988. This Information will be presented in the RIreport. The requested activity schedule (PERC or PERT chart) willnot be included in the RI report. The PRPs are providing near-termactivity schedules with the monthly status reports. Long-termscheduling may be evaluated relative to the schedule submitted withthe approved Work Plan. Given the uncertainty in forecasting long-term scheduling for projects of this type, the PRPs do not intend toupdate the Work Plan schedule on an interim basis.

WARZYN

July 25, 1989 -2- 13452.99

2.1.2 Soil Gas Survey

The text does not specify the dates when this activity was performed, nor theatmospheric conditions such as temperature. Also, the text does not presentthe method detection limit for the soil gas survey. The text should berevised to present this information. This activity should also be presentedon the requested PERC chart. The last paragraph of this section contains anapparent typographical error: "method detection jevel," should read "methoddetection limit."

Response: The soil gas survey was performed on August 31, September 2 andSeptember 7, 1988. This information will be presented in the RIreport. Details on atmospheric conditions will be presented in theRI report. The method detection limit for this activity is 1000ug/L, as stated in Appendix B of Technical Memorandum - Number 1(Tech Memo 1) and will be referenced in the RI report. Thetypographical error will be corrected in the RI report. Refer tothe response to comment 2.1.1 for discussion of the requested PERCchart.

2.1.3 Refuse Borings/Leachate Head Wells

The text does not specify when the nine refuse borings and three extra soilborings for Area A were done (first paragraph of this section). Similarly,the text (last paragraph on p. 6) does not specify when ESB-3/LH-1 wasinstalled. The text does not specify, or reference a table which specifies,locations where HNu readings were above background or where refuse was visible(paragraph 2 on p. 6). The text should be revised to present thisinformation. These activities should also be presented on the requested PERCchart.

Response: The Tech Memo 1 text is in error regarding the number of borings:six refuse borings and three extra soils borings were performed onSeptember 9 and September 12 through September 14, 1989. Specificdates are presented on the boring logs (Appendix C, Tech Memo 1).Leacnate Headwell LH-1 was installed on September 14, 1988. This

WARZYN

July 25, 1989 -3- 13452.99

information will be presented in the RI report. A table whichsummarizes the refuse borings will be presented in the RI report,which includes details on refuse thickness and HNu readings. Referto the response to comment 2.1.1 for discussion of the requestedPERC chart.

2.1.4 Vapor Sampling of Leachate Headwell LH-1

The text does not specify when this activity was performed. Furthermore, noindication is given in the text that ambient air sampling was also performedto establish a basis of comparison. The text should be revised to presentthis information, referencing section 2.3.1 Air Quality Evaluation. Thisactivity should also be presented on the requested PERC chart.

Response: Leachate headspace sampling was performed on January 3, 1988. Thisinformation will be presented in the RI report. The RI report textwill include information on ambient air sampling as a basis forcomparison, referencing section 2.3.1 Air Quality Evaluation. Referto the response to comment 2.1.1 for discussion of the requestedPERC chart.

2.1.5 Additional Groundwater Monitoring Wells

The text does not specify when the three groundwater and five sourcecharacterization wells were installed. No reference is made to the technicaldiscussions with EPA via conference call regarding the concurrence andapproval of these activities as an alteration of the approved work plan forthe site. The text should be revised to address these points. Theinstallation of these wells should also be presented on the requested PERCchart.

Response: The three additional groundwater wells were installed from September20 to September 22, 1988. The five source characterization wellswere installed from November 21 to November 23, 1988. Specificdates are presented on the Boring Logs (Appendix C, Tech Memo No.

WARZYN

July 25, 1989 -4- 13452.99

1). This information will be presented in the RI report. Verbalapprovalof these activities by ERA, as an alteration of theapproved Work Plan for the site, will be referenced in the RIreport. Relevant correspondence, including the above referenced,will be presented in an appendix in the RI report. Refer to theresponse to comment 2.1.1 for discussion of the requested PERCchart.

2.1.6 Groundwater/Leachate Sampling at Source Characterization and LeachateWells

The text does not specify the date of this sampling event. A typographicalerror exists in the second paragraph of this section: "ENECO/RMAL" shouldread "Enseco/RMAL." The text should be revised to address these points. Thisactivity should also be presented on the requested PERC chart.

Response: This sampling was performed on December 13, 1988. This informationwill be specified in the RI report text. The typographical errornoted above will be corrected in the RI report. Refer to theresponse to comment 2.1.1 for discussion of the requested PERCchart.

2.1.7 Test Pits

The text does not specify when this activity was performed. The text should^ be revised to present this information. This activity should also be

presented on the requested PERC chart.

Response: The test pits were performed on September 15 and September 19, 1988.The RI text will include this information. Refer to the response tocomment 2.1.1 for discussion of the requested PERC chart. Note thatthe test pit logs (Appendix E, Tech Memo 1) should show that TP10through TP16 were completed on September 19, 1988 rather thatSeptember 15, 1988.

WARZYN

July 25, 1989 -5- 13452.99

2.2 Migration Pathway Assessment

Acceptable as is, no comment.

2.2.1 Meteorological Investigation

Acceptable as is, no comment.

2.2.2 Soil Characterization

The text does not specify when the eighteen soil borings were performed.Paragraph 3 on p. 12 does not reference Table 4 which presents the results ofEP toxicity and flammability testing of the composited cuttings; it likewisegives no mention of how they were disposed (i.e., as hazardous waste, specialwaste, or non-hazardous waste), or where they were disposed of. Manifests orbills of lading as appropriate should be presented in the appendices. Thetext should be revised to address these points.

Response: The soil borings be performed between July 26, 1988 and September 71988. Specific dates are presented on the boring logs (Appendix C,Tech Memo 1). This information will be presented in the RI report.Refer to the response to comment 2.1.1 for discussion of therequested PERC chart. EP toxicity results (Table 4) will bereferenced in this section of the RI text. Information regardingthe disposal of cuttings will be provided in the RI report. Thecuttings have not been disposed of to date, and remain on-site in55-gal drums or in the on-site lugger box. Since the cuttings havebeen found to be nonhazardous, they will be stored on site until thefinal remedy is implemented.

2.2.3 Hydrogeological Investigation

Acceptable as is.

2.2.3.1 Groundwater Sampling while Drilling

WARZYN

July 25, 1989 -6- 13452.99

Acceptable as is.

2.2.3.2 Monitoring Well Installation

The text does not specify when the monitoring wells were installed, nor whenthey were developed. The text should be revised to present this information.These activities should also be presented in the requested PERC chart.

Response: The wells (including the three additional groundwater monitoringwells and the five source characterization wells) were installedbetween July 27 and September 7, September 20 and 22, and November21 and 23, 1988. Specific dates are presented in Appendix D of theTech Memo. The wells were developed between September 9 andSeptember 23, 1988 and on December 9, 1988. Specific dates arepresented in Table 6 of the Tech Memo. The RI report text willinclude this information. Refer to the response to comment 2.1.1for discussion of the requested PERC chart.

*

2.2.3.3 Survey

An apparent typographical error exists: text uses both "Kapur" and "Kopur" forthe surveyor. The text should be revised using the correct spelling of thesurveying firm.

Response: The RI text will use the correct spelling (Kapur).2.2.3.4 Groundwater Level Measurements

The text indicates that measurements were made on December 8, 1988, whileTable 6 indicates that Source Characterization Wells SCW-1,2,3,4, and 5 weredeveloped December 9, 1988. Measurements of groundwater levels in these wellsprior to development of these wells result in data of questionable validity.Since Drawing 13452-F6 is based on December 8 data, this water table map'svalidity is questionable in regards to groundwater levels at SCW-1,2,3,4 and5.

WARZYN

July 25, 1989 -7- 13452.99

Response: The December 8, 1988 water level measurements at these wells appearto be consistent with subsequent water level measurements at thesewells. Therefore the December 8 data is not considered to be ofquestionable validity. This subsequent data will be presented inthe RI report, along with a new water table map which incorporatesthe proposed Phase 2 wells.

2.2.3.5 In-Situ Hydraulic Conductivity Testing

The text does not specify when the rising head single well in-situ hydraulicconductivity tests were performed for the 13 newly installed groundwaterobservation wells. The text should be revised to present this information.This activity should also be presented on the requested PERC chart.

Response: The in-situ hydraulic conductivity tests were performed on October 5and 6, 1988. This information will be presented in the RI report.Refer to .the response to comment 2.1.1 for discussion of therequested PERC chart.

2.3 Contaminant Characterization

Acceptable as is.

2.3.1 Air Quality Evaluation

O The text does not specify when the ambient air sampling was performed, doesnot indicate what other activities where being performed on-site during thissampling activity, and does not summarize the weather and atmosphericconditions during this sampling. The text should be revised to present thisinformation. This activity should also be presented on the requested PERCchart.

Response: Ambient air sampling was performed on November 21, 1988. Sourcecharacterization wells SCW1 and SCW5 were completed on this date,hich involved drilling in the waste disposal area. Atmospheric

WARZYN

July 25, 1989 -8- 13452.99

conditions are summarized in Appendix F of Tech Memo 1. This datawill also be presented in the RI report text. Refer to the responseto comment 2.1.1 for discussion of the requested PERC chart.

3.1.1 Geophysical Survey

Acceptable as is.

3.1.2 Soil Gas Survey

The text needs to be revised to present discussion of method detection limitfor the soil gas survey. Also, the text refers to three Areas A-C, while thereferenced Table 1-3 refer to Sites A-C. The tables should be revised tocorrespond to the text labelling them as Areas.

Response: Refer to response to comment 2.1.2. The detection limit will alsobe presented in this section of the text. Tables 1-3 will bemodified to refer to Areas A-C.

3.1.3 Refuse Borings

The text indicates that both EP toxicity and flashpoint tests were done oncomposited cuttings. While the text states that the cuttings (spoils) do notindicate EP toxicity (as indicated in Table 4), no mention is made that thespoils display the characteristic of flammability due to a flashpoint of lessthat 200°F as indicated in Table 4, making them a hazardous waste bycharacteristic of flammability.

Response: A typographical error exists in Table 4. The flashpoint resultshould be ">200" rather than "<200H (°F). Materials which display aflashpoint of less than 140"F (not less than 200°F) are deemedhazardous due to the characteristic of flammability (s. NR181.15(2), Wis. Adm. Code).

WARZYN

July 25, 1989 -9- 13452.99

3.1.4 Test Pits

The text of the second paragraph should be revised to clarify the statement"many test pits did not establish a lower waste boundary" in the context ofthe methodology cited in 2.1.7, namely, that excavations were terminated ifgreater than 3 1/2 feet of waste was uncovered.

Response: This paragraph will be revised to include information in thissection regarding the termination of test pits as cited in section2,1.7.

3.1.5 Groundwater/Leachate Sampling Results

The text should be revised to indicate that the five additional groundwatermonitoring wells were installed with EPA's concurrence after only one of thefive refuse borings intended to be used as leachate head wells encounteredleachate.

Response: The text will be revised to specify that leachate was encountered inonly one of the five refuse borings. Details regarding approval ofthis activity will be presented as discussed in the response tocomment 2.1.5

3.1.5.1 Volatile Organic Compounds

Acceptable as is.

3.1.5.2 Semi-Volatile Organic Compounds

Acceptable as is.

3.1.5.3 Pesticides/PCBs

Acceptable as is.

WARZYN

July 25, 1989 -10- 13452.99

3.1.5.4 Inorganics and Indicator Parameters

Paragraph two on page 23 should be revised to clarify that the leachate samplewas not filtered in the field prior to preserving with acid.

Response: The RI text will clarify that the leachate sample was not filteredprior to preserving with acid.

3.1.6 Integrated Results of Site Characterization

Paragraph two on page 24 contains several typographic errors: 2-butanone istyped as 2-butonone and 2-butonne; manganese is typed as monganese.

Response: These typographical errors will be corrected in the RI report.

3.2.1 Meteorological InvestigationV

Acceptable as is.

3.2.2.1 Regional Geology

A map of the regional glacial geology should be included in this section sothat it may be referenced by the reader. Appropriate citations for data usedin the map should be included.

Response: A map of regional glacial geology and appropriate citations will beincluded in the RI report similar to Figure 13114-B2 of the SiteEvaluation Report (SER).

3.2.2.2 Site Specific Geology

The 18 feet of lean silt clay at MW-19 is different from the silt encounteredin the upper portions of the other surrounding soil borings. Since no sampleswere obtained from USGS soil borings, correlation with these borings is risky.

WARZYN

July 25, 1989 -11- 13452.99

In addition, the text states that silty clay was not observed at B-17B,however, this location is well within the inferred lateral extent of the"clay" unit on the Water Table Map, Drawing 13452-F6.

The actual extent of the clay unit could be much smaller than the areaoutlined in the Water Table Map. Based on the soil borings conducted duringthe Phase I investigation, and on the Surficial Soils Map, provided in theSite Evaluation Report (Warzyn, 1988), the lateral extent of the clay unitprobably approximates the 860 ft contour in the Southeast portion of the site.Note, however, that the clay unit at MW-19 was not observed at MW-18. TheWater Table map should be revised to reflect this approximate boundary.Likewise, the Section A-A geologic cross-section, Drawing 13452-F8, should berevised to pinch out the clay unit between MW-19 and P8A.8B. Also on the samecross section, the water level as drawn for MW-22 is incorrect with respect toP8A,8B. The illustration of the water level for MW-22 should be corrected.

Response: The clay omit shown on Drawing 13452-F6 is approximate only and isintended to provide a conceptual explanation for the position of thewater table contours and the steepening of the horizontal gradientadjacent to the clay unit. Boring B-17B is in a disturbed area(previous location of Hagen residence) and this may explain why theclay unit wasn't encountered at this location. Also, USGS datasuggests that clay is present, although this data is not definitive,because soil samples were not obtained during these borings. Theextent of the clay unit will be modified in the vicinity of P8A andMW18, and may also be modified based on additional information fromthe proposed Phase 2 borings. Cross section A-A1 will be madeconsistent with the revised clay unit extent as will be presented inthe RI report. Also, the water table will be corrected near MW-22on^the cross-section.

3.2.2.1 Groundwater Sampling While Drilling

Hypothesize the presence of acetone in the water sample from location B-16B.A "weird" odor was noted during installation of MW-16.

WARZYN

July 25, 1989 -12- 13452.99

Response: Acetone was only detected in the deepest groundwater sample at thislocation (63-71 ft). Other compounds present at the source ingreater concentrations were not observed at MW-16, although benzenewas reported at BMDL. Since acetone is miscible in water and has aspecific gravity of 0.791, it is unlikely that it would be presentonly in the bedrock aquifer. The sample from 58 to 65 ft, alsopartially in the bedrock, did not exhibit any detections althoughthe deeper sample exhibited 1430 ug/L of acetone. Because thecasing could only be driven to 63 ft (approximate top of bedrock)for the deepest sample, the two water sample depths overlap to somedegree. Because acetone was not detected in both samples suggeststhat the acetone detection may be a result of sampling or laboratorycontamination. This subject will be addressed more fully in the RIreport, in conjunction with additional data obtained at proposedwell locations during Phase 2.

3.2.3.2 Horizontal Groundwater Flow

Paragraph three on page 28 makes reference to a drainage ditch east of thedisposal areas and a pond at Sundby south of the site that are potentialgroundwater recharge points, and therefore potential surface water directcontact pathways. However, these features are neither called out in any ofthe drawings, nor are they emphasized with due importance in the discussion ofmigration pathway. Discussion of groundwater levels and groundwater flowdirections, particularly in the disposal areas, should be reevaluated in lightof the questionable validity of groundwater level readings taken on December8, 1988 at SCW-1,2,3,4 and 5 prior to their development on December 9, 1988.An apparent typographic error appears in paragraph one on page 2: "thisSeptember (1989)" should read "during September 1988" for clarity andfactuality.

Response: Potential migration pathways, including the drainage ditch east ofthe site and Sundby's pond will be discussed in more detail in theRI report, based on data obtained during Phase 2 of the SiteInvestigation. The discussion of groundwater flow directions willbe reevaluated in the RI report based on subsequent data collected

\A0\RZYN

July 25, 1989 -13- 13452.99

after December 8, 1988 at both the existing and proposed wells.However, 'as discussed in response to comment 2.2.3.4, the December 8data are considered representative of the groundwater levels at thefive source characterizafion wells. Regarding the typographicerror, September 1988 is the correct date and will be referred to inthe RI report.

3.2.3.3 Vertical Groundwater Flow

Discussion of the groundwater levels, particularly in the disposal areas,should be evaluated in light of the questionable validity of groundwater levelreadings taken on December 8, 1988 at SCW-1,2,3,4 and 5 prior to theirdevelopment on December 9, 1988.

Response: As previously stated in response to comment 2.2.3.4, groundwaterlevel readings taken on December 8, 1988 are considered to berepresentative of the groundwater levels. This discussion will berevised in the RI report to include subsequent data collected afterDecember 8 at both the existing and proposed wells.

3.2.3.4 Hydraulic Conductivities

Hypothesize why conductivities determined for previously tested wells weresubstantially higher than when they were tested by Warzyn in 1982.Conductivity calculations to verify PRPs calculations have not been performedby the reviewer.

Response: Differences in hydraulic conductivity values may be due in part todifferences between the methods used during data acquisition andanalysis in 1982 and 1988. A more detailed analysis of the data andthe discrepancy between the conductivities will be presented in theRI report.

WARZYN

July 25, 1989 -14- 13452.99

3.2.3.5 Groundwater Flow Rates

When estimating travel times for groundwater moving from the waste area to thesouthern property boundary, extraneous significant figures should be excluded(i.e., 1741 years). The average hydraulic conductivity of 3x10-3 used in thecalculations may be a poor assumption resulting in increased travel times.The Sundby wash plant well showed tetrahydrofuran (THF) contamination in 1986,24 years after waste disposal began (SER, Warzyn 1988). It may be moreappropriate to back calculate a minimum average hydraulic conductivity basedon the maximum length of time for contamination to migrate to the Sundby well.Also, waste disposal was initiated at the site in 1962, not 1967 as stated inthe text.

Response: Extraneous significant figures will be eliminated in revisions ofTables 23 and 24 and the RI report text. Because the unconsolidateddeposits at the Hagen Farm Site are generally interstratified siltysand and.sand and gravel, the average hydraulic conductivity may notbe representative of the conductivities of the layers. The higherconductivities may be more representative for calculating minimumtravel times, as presented in section 3.2.3.5 of Tech Memo 1. Thealternate approach outlined in the above comment will be discussedin the RI report. However, one problem with this approach is thathorizontal hydraulic gradients may have been different during 1986in the vicinity of the Sundby wells due to possible pumping of thewells. These issues will be considered and developed more fully inthe RI report.

3.2.4 Surface Water/Sediment Investigation

Paragraph ontf on page 32 indicates a drainage ditch to the west of the site,while drawings and previous text in 3.2.3.2 (paragraph 3 on p. 28) show adrainage ditch to the east of the site. The text should be revised asappropriate to remedy this discrepancy.

WARZYN

July 25, 1989 -15- 13452.99

Response: The RI report will consistently refer to the correct location of thedrainage swale east of the site (more specifically south east ofDisposal Area A.)

3.2.5.1 Air

No comment.

3.2.5.2 Soils

The presence of waste at or near the surface in some locations results in theneed for some surficial soil sampling at those locations with CLP TCL analysesto evaluate direct contact pathway for the endangerment assessment portion ofthe Remedial Investigation report. If the material is debris rather thanwaste, the report should so specify, in which case surficial soil sampling isnot necessary.

Response: Tires, rolled plastic and scrap metal were observed at the surfaceat some locations in the fill area. This material is not consideredto constitute hazardous waste and therefore soil sampling is notconsidered necessary. This will be clarified in the RI report.

3.2.5.3 Groundwater

Text should be revised to present further discussion of the presence ofcontaminants at or near the surface of the bedrock interface—that is theimplied presence of contaminants with a specific gravity greater than water("sinkers").

Response: It^is not clear based on limited data whether the presence ofcontamination at near the bedrock surface at P17B is related to thespecific gravity of contaminants or groundwater flow paths based onhorizontal and vertical gradients. This subject will be discussedin the RI report along with additional data obtained during Phase 2.

WARZYN

July 25, 1989 -16- 13452.99

3.2.5.4 Surface Water

Text in this section should be revised to incorporate reference to thedrainage ditch east of the site as another pathway for contaminant migration,as previously presented in 3.2.3.2 (paragraph 3 on p. 28).

Response: Based on groundwater flow directions inferred from water levelmeasurements, the drainage ditch is not considered to represent apotential groundwater discharge point. However, data obtained fromthe Phase 2 investigation will help confirm whether this is thecase. Additional discussion will be presented in the RI report.

3.3.1 Air Quality Evaluation

The second paragraph of this section on page 33 discusses the groundwatermigration pathway, and thus is not appropriate for this section. Thatparagraph should be moved to the discussion presented in 3.2.5.3 at the top ofthe same page.

Response: The second paragraph of this section will be moved to section3.2.5.3 in the RI report.

4.0 Conceptual Site Model

The first paragraph should be revised to indicate a silty zone to thesoutheast of the waste area and a zone of clayey material in the extremesoutheastern portion of the site (near MW-19). A discussion of the drainageditch east of the site should be included.

Response: The conceptual site model will be modified based on additional dataobtained during the Phase 2 investigation. This section will berevised if necessary to include additional information relevant tothe drainage ditch as a potential migration pathway, as discussed inresponse to comment 3.2.5.4.

WARZYN

July 25, 1989 -17- 13452.99

5.0 Recommendations for Phase II Site Investigation

No comment.

5.1 Observation Well Installation

A typographic error exists in the first line of the first paragraph of thissection: "Drawing 13452-9" should read "Drawing 13452-F9."

Response: The text will be made consistent with the drawing number in the RIreport.

5.2 Groundwater Sampling

The last line of the first paragraph of this section contains an apparenttypographic error: "(Drawing 13452-B6)" should read "Drawing 13452-F6)." Thetext is vague with.regards to which parameters will be analyzed for specificwells, especially in regards to semi-volatiles analyses. The first sentenceof the second paragraph of this section states that semi-volatiles will beanalyzed for at selected locations, but does not specify what those selectedlocations are, nor the basis of selection. The third paragraph of thissection indicates that pesticides/PCBs and metals will not be analyzed becausethey were "generally not detected, or detected at or near the required methoddetection limit." However, this directly contradicts previous informationwith regards to metals, specifically barium (1570 ug/1 at SCW-4) and mercury(6.5 ug/1 SCW-1) which the text at 3.1.5.4 (p. 23, paragraph 2) indicatesexceed the primary drinking water standards. The existing Maximum ContaminantLevel (MCL) for barium is 1,000 ug/1 with a proposed MCL of 5,000 ug/1. Theexisting MCL for mercury if 2 ug/1. The exceedance of the MCLs for thesemetals is sufficient to require that analyses of at least these CLP TCL metalscontinue during the next round of groundwater sampling. A listing of wells tobe sampled with analytical parameters, metals, volatiles and semivolatilesplus tetrahydrofuran, necessary sample bottles (type and number), necessarypreservatives, and allowable holding times would clarify the intended sampling

WARZYN

July 25, 1989 -18- 13452.99

(i.e., revised QAPP Table 2 for data usage, Table 3 for sample types andestimated sample numbers, Table 4 for sample quantities, containers,preservatives and packaging, and Table 5 for data quality objectives; andrevised Sampling Plan Table 1, Summary of Proposed Wells).

Response: The text will be made consistent with the drawing number in the RIreport. The purpose of this section is to propose Phase 2 samplingand therefore will not appear in this form in the draft RI. Thiscomment was addressed during the April 13, 1989 meeting betweenWMWI, U.S. EPA, Jacobs and Warzyn. The addition of barium, lead andmercury to the analyte list and the selection of semi-volatileanalyses locations was agreed upon during that meeting. Additionalclarification regarding sampling will be presented in the Work PlanAddendum which includes Phase 2 investigation activities.

Tables 1-3*

These tables reference Site A, B and C, whereas text and drawings refer toArea A(B, and C. Labelling of the tables should be revised to be consistentwith the text.

Response: These table will be revised to refer to Areas A,B and C.

Table 4

Flashpoint is presented erroneously as "(F)" rather than "(°F)." Also, nomaximum or standard is presented in the appropriate column. As materialswhich display a flashpoint of less than 200°F are deemed hazardous due tocharacteristic of flammability, this composite sample which displays aflashpoint of <200°F is a hazardous waste.

Response: Table 4 will be modified to display degrees Fahrenheit as "°F" andwill include a maximum of <140*F for the flashpoint in theapproximate column. Materials which display a flashpoint less than

WARZYN

July 25, 1989 -19- 13452.99

140°F are deemed hazardous (s. NR 181.15(2), Wis. Adm. Code). Theflashpoint result is a typographical error; the result should be>200 (°F). The composite sample is not considered a hazardous wasteby this determination.

Table 5

No comment. The reviewer has not recalculated total volumes to verify thosepresented.

Tables 6-10

No comments.

Table 11

Title is misleading; table presents both groundwater elevations and surfacewater elevations (at staff gauges STG-1,2 and 3). Readings of 12/08/88 forSCW-1,2,3,4 and 5 should be annotated to indicate questionable validity due tomeasurement prior to well development. Incomplete entries are recorded forwells 8411, 8412 and QW-3.

Response: The title will be modified to include surface water elevations.Readings for source characterization wells for September 8, 1989will be annotated. Entrees for Wells 8411, 8412 and QW-3 willindicate that data were not obtained on September 8, as indicatedfor other dates.

Table 12-13

No comments.Table 14

Table does not specify unit; revise to specify actual unit (presumably ug/1).

WARZYN

July 25, 1989 ' -20- 13452.99

Response: Table 14 will specify unit (ug/1).

Tables 15-19

No comments.

Table 20

No comment. The reviewer has not recalculated vertical gradients to verifythose presented.

Table 21

The annotations to this table are incomplete; that designated by an asterisk(*) should also list 9-14-88, 10-21-88, and 12-8-88 as being performed byWarzyn.

f

Response: Table 21 will be modified to indicate that Warzyn performed thegroundwater level measurements on the 1988 dates, also.

Table 22

No comment. The reviewer has not recalculated velocities to verify thosepresented.

Table 23

This table (and the text) contains extraneous significant figures for traveltimes.

Response: Extraneous significant figures will be eliminated for travel timesin this table and in the RI report text.

Figure 1

No comment

WMRZYN

July 25, 1989 -21- 13452.99

Drawings

Not specifically reviewed except as pertains to text of document; thosecomments are presented in the corresponding review comments on the text.

Summary

Overall, this technical memorandum adequately summarizes the first phase ofremedial investigation field activities. Noted deficiencies are primarilyomission of dates of specific activities and a timeline (PERC chart) for thoseactivities.

Other deficiencies relate to: 1) lack of specifics in regards to what on-siteactivities were underway during the ambient air monitoring on November 21-22,1988, such that no judgement can be made as to whether these measurements meetthe intended data usage/objective; 2) questionable validity of groundwaterlevel measurements.of SCW-1,2,3,4 and 5 and resulting water table maps due tomeasurements made December 8, 1988 prior to development on December 9, 1988;3) questionable inferred lateral extent of the clay unit on the east side ofthe site; and 4) calculated contaminant travel times were not checked againstthe actual THF contaminant travel time to the Sundby well.

Proposed second phase activities are inadequate due to: 1) not specifying TCLmetals for analysis even though first phase analyses of groundwater show thatmeasurements for barium and mercury exceed the MCLs; 2) not specifying whichwells will be sampled and what parameters will be analyzed for each sample;and 3) not proposing surface soil sampling to evaluate the potential directcontact migration pathway.

These deficiencies, however, can be addressed with relatively little revisionsto the document.

Response: Revisions to this document proposed by Jacob's will be provided inthe Draft RI report.

PFJ/bcn/GEA/DWH[ckb-600-59]

WARZYN