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<br /> <br />Letter to Scott Hoover 2 December 22, 1998 <br />treatment and/or disposal plan for any contaminated media designated for on-site disposal. (Note <br />that this item #2 is a point of clarification rather than an issue to be addressed to gain approval of <br />the SAP; B and B need only register their concurrence or present any arguments against this item at <br />this time). <br />3. The SAP designates l00 percent of the bag house dust for off-site disposal. B and B must provide <br />the DMG with documentation that the bag house dust has been disposed of in permitted hazardous <br />waste landfill. Documentation of proper off-site disposal must be provided for all contaminated <br />media that may eventually be designated for off-site disposal. <br />4. The SAP, in Appendix D, states that sampling equipment will be decontaminated between each <br />sampling location. The SAP further states, on page 23, that only a small amount of <br />decontamination wash water will be generated because none of the heavy equipment will be steam <br />cleaned during the sampling activities. Please thoroughly describe how the samples will be <br />collected such that cross-contamination will be prevented that may be caused by the by the <br />backhoe or loader buckets. <br />It is stated on page 9 of the SAP that2he preliminary site assessment included the establishment of <br />"transects azound the perimeters" of the''/z inch and'/a inch road base piles with ATH screening <br />samples collected at 20-foot intervals. This description is not adequate for DMG to visualize the <br />locations of the screening sample collection locations. Please provide a sketch showing the <br />locations or a more complete description. Include information on the approximate depth below the <br />surface of the piles from which the samples were collected. <br />6. The lined temporazy storage cell described in the SAP is specified to be constructed with a <br />minimum 10-mil thickness geosynthetic liner. It has been the DMG's experience that <br />geosynthetics thinner than 30 mil are easily damaged and difficult to repair. DMG recommends <br />that a minimum 30-mil thick geosynthetic liner be specified. <br />A rationale is provided in the SAP for not investigating the wash plant sediments for herbicide <br />contamination. The DMG agrees with the rationale assuming that high levels of contamination <br />will not be found in the remaining''/z inch road base stockpile or in the soils underlying the former <br />location of the minus'/a inch feedstock pile. If high levels of contamination are found in either of <br />these locations through the SAP investigations, this would be an indication that high levels may <br />still exist in the wash plant sediments, and a plan to characterize the wash plant sediments may be <br />required at that time. In order to verify that leaving potentially contaminated wash plant sediments <br />in place will not result in surface or ground water contamination, the DMG will require sampling <br />of the storm water retention basin following rain events on a minimum of one occasion over the <br />next year. Please provide a sampling plan for DMG review that will implement this requirement. <br />8. The SAP provides for contaminant level characterization of the pit floor under the former location <br />of the minus ;/a inch feedstock pile. This chazacterization is intended to determine whether any of <br />