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Response to Comments in December 22, 1998 Letter <br />' The items discussed below are specific responses to the items raised in your (DMG) letter to Scott <br />Hoover of December 22, 1998. <br />' Item I) We agree to sample the soils under the original minus 3/4 inch road base stockpile for testing <br />of 2,4-D, Bromacil, Dicamba and Diesel. We also agree to sample the surface and groundwater <br />around the area of concern as described in Item 8. If any sampling of the waters or the subsoil under <br />the original 3/4 road base pile show significant contamination , B&B commits to sampling the soils <br />under the following piles: a) %: inch road base pile, b) 1/4 inch road base pile and c) 3/4 inch rock <br />pile. <br />Item 2) we understand that the ]0 mg/Kg RCRA land disposal restriction level for 2,4-D does not <br />' necessarily mean that concentrations below this level can be ignored. However, to our knowledge, <br />there is no state or federal specified soil concentration of 2,4-D that determines treatment vs. no <br />treatment. As you pointed out in your inspection report of the site on November 19, 1998, the <br />Colorado Water Quality Control Division has established a ground water quality standard of 70 <br />micrograms per liter. This level is a lone term standazd for human consumption and we feel that we <br />' should not be held to this standard for a temporary spill. We believe that the water analyses should be <br />interpreted with the Division once it is received. <br />' Based upon the soil sample analysis, we propose the following plan regazding 2,4-D contamination <br />levels in soil media: <br />1) Any soils at any location on the site which contain between 0.1 to 10.0 mg/Kg 2,4-D will be taken <br />to the Eagle County Landfill for permanent disposal. It is felt that the small amount of material which <br />is potentially contaminated is so small (< 100 cubic yards) that this is the best solution. This site is a <br />' certified RCRA hazardous waste disposal facility and is fully capable of storing this material. B&B <br />trucks would be used to haul the material to the facility which is located approximately 10 miles <br />north of Wolcott on State Highway 131. All certified paperwork regarding the disposal will be <br />' submitted to the Division in the final report after remediation of the site. Since the facility is capable <br />of handling very high concentrations of TPH, it is felt that the low concentrations of TPH from the <br />Montgomery Pit should present no problem for the disposal facility. <br />' Z) Although initial testing indicates the unlikelihood of soils existing on site which contain 2,4-D <br />above 10 mg/Kg, a contingency plan is needed in case any soils of this type are encountered. The <br />only pile that registered any contamination in the preliminary testing was the minus'h inch product <br />pile and the total volume of this pile is probably less than 200 cubic yazds. Testing was done at 20 <br />' feet intervals along the pile and only one sample showed any 2,4-D. This sample registered 1. I <br />mg/Kg. Although it is possible that some higher 2,4-D levels could be encountered deeper in the pile, <br />