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i <br /> <br />Letter to Scott Hoover 3 December 22. 1998 <br />the weed killer dumped on the feedstock pile Flowed through to the base of the pile and into the <br />ground. In addition to the characterization provided for in the SAP, the DMG will require that <br />ground water down gradient of the feedstock pile be sampled and that the Eagle River be sampled <br />up and downstream of the site. The reasons for these requirements are: <br />Diesel fuel, 2,4-D, and bromacil limit the uses of surface and ground water when present in <br />very low concentrations. <br />Investigation of the upper 36 inches of the pit floor at the weed killer release location may not <br />provide a definitive demonstration that ground and surface water contamination has not <br />occurred. This is because the contaminants may have leached out of or been degraded out of <br />the near surface soils, but may still be present in the ground water. <br />The primary environmental concern related to the release of the weed killer at the Montgomery <br />Pit is the potential for contamination to enter ground or surface water. Therefore, it is prudent <br />to make a direct investigation of these media. <br />Please provide a plan for DMG review to implement this requirement. <br />9. It is stated on page 14 of the SAP that based on a literature review "dioxin would not be formed as <br />a thermal degradation product of 2,4-D." It is the position of the DMG that a sample of bag house <br />dust must be analyzed for dioxin to verify this conclusion. Please provide a plan for DMG review <br />to implement this requirement. <br />Once the items listed above are addressed to the satisfaction of the DMG, corrective action number t <br />from the November 16, 1998 inspection report will be deemed completed. Corrective actions <br />numbered 2 through 4 from the inspection report would remain to be addressed. Please be reminded <br />that the asphalt plant at the Montgomery Pit may not be operated until the DMG is satisfied that the <br />weed killer in the plant feedstock has been isolated and that contamination in the hot plant components <br />has been removed. <br />If you have any questions, please contact me. <br />Sincerely, '' <br />Allen C. Sorenson <br />Reclamation Specialist <br />cc: Greg Lewicki (via FAX) <br />c:\wi ndaws\personal\montgomery. doc <br />