2061601 Remedial Project Manager United States ...Wllco Corporation One American Lane Greenwich, CT 06831-2559 (203) 552-2000 (203) .552-2010 Fax-20 November 1 995 2061601 Mr. Eric

Wllco CorporationOne American LaneGreenwich, CT 06831-2559(203) 552-2000(203) .552-2010 Fax-

20 November 1 9952061601

Mr. Eric NewmanRemedial Project ManagerUnited States Environmental Protection AgencyDE/MD Remedial Section (3HW42) !841 Chestnut BuildingPhiladelphia, PA 19107

Re: Response Action PlanHalby Chemical Superfund SiteWilmington, DelawareAdministrative Order for Removal Response ActionResponse to EPA Comments on the Response Action Plan

Dear Mr. Newman:

Pursuant to paragraph 8.5 of the Unilateral Administrative Order (Order), the Respondent has eitherincorporated the EPA Comments dated 20 October 1995 on the revised Response Action Plan attachedto this letter, or herein provides explanation as to why any specific EPA Comments were notincorporated. For ease of reference, we have numbered the comments provided in the EPA letter, andretyped them herein. EPA comments are provided in bold type, and our responses follow.

The U.S. Environmental Protection Agency (EPA) and Delaware Department of Natural Resourcesand Environmental Control (DNREC) have reviewed the revised draft Response Action Plan (RAP)submitted on September 4,1995 by Langan Engineering and Environmental Services on behalf ofWitco Corporation (Witco). Although the RAP is in better shape than the first draft, the document,read in its entirety, does not give the impression of a focused plan of action (i.e., remedial optionsevaluation prior to development of action levels?, etc.). In the spirit of trying to move the projectalong, we have identified four items which need to be addressed at the site on an immediate basis.We have then offered comments on the proposed FSP, QAPjP, HASP and the anticipateddevelopment of action levels. Please do not mistake the level of detail included in our comments asa shift in priorities. Our common goal is to address the potential environmental problems identifiedin the Action Memorandum on an expedited basis, not production of perfect planning documents.The revised draft RAP submitted on September 4, 1995 is accepted conditioned upon Witco's

consideration of the government's comments and qualified by the acknowledgment that the RAP wasnot presented as a "final form" document (i.e., risk assessment and treatability study sections mustyet be developed). At a minimum, a revised Field Sampling Plan and schedule should be submittedto EPA prior to initiation of sampling activities. In accordance with Section 8.5 of the UnilateralAdministrative Order ("UAO" or "Order"), please incorporate our comments, as appropriate, in arevised RAP and submit to EPA. if Witco chooses to provide page revisions to the existing binder,it is acceptable to the government.

In reviewing Witco's responses to previous government comments and comparing the writtenresponses to actual modifications made by Witco to the RAP we note inconsistencies. On severaloccasions the response indicates that the comment is accepted, but no modification was made to theRAP; or, an adversarial response is provided by Witco, only to provide the modification requestedby EPA. We will not waste time on such unproductive discussion because the need for expeditedaction in the field at the Halby site supersedes such administrative matters.

Response: Based on EPA's conditional acceptance of the September 4, 1995 revised draftRAP, Witco will address implementation of the RAP in accordance with the Order.Witco has submitted a revised Field Sampling Plan and schedule for EPA's reviewprior to initiation of sampling activities. In addition, Witco has prepared a revisedRAP which incorporates EPAs comments.

We appreciate your focus on actually achieving the field work, and we agree withthe need to constructively resolve our differences. We apologize for any confusionbetween our comments and the RAP revisions. Witco has now incorporated all of

EPAs comments into the RAP. Comments that have been accepted were used tomodify the RAP. Responses which appeared adversarial were intended to preserveour different understanding or opinion on issues, even though we had agreed tocomply.

Immediate Actions

Comment 1: There are significant matters which must be addressed on an immediate basis and

the government supports expedited action taken by Witco to accomplish them.

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1) Institute security measures to prevent unauthorized access to contaminatedareas which do not already have access controls or access restrictions toprevent exposure to the Site's contamination. This means, at minimum,immediate construction of secure and suitably posted fencing around thecontaminated areas, including any exposed area of the former lagoon.

The 01 September RAP states that temporary fencing and appropriate hazardwarning flagging and placards have been posted. During a Site visit on 13October, there was no flagging or placarding. We note that the fence installedby Witco surrounding the ditch area containing the highest known concentrationsof contaminants is a solid fence which should dissuade prospective trespassers.Since existing data (e.g., Rl data) show that lagoon sediment is contaminated, andthere is no data to the contrary, better access restrictions are needed for thelagoon, especially the northern currently unrestricted portion. A fence iswarranted between the railroad tracks and lagoon. Tighter security and firecontrol would only be necessary during performance of intrusive activities at theSite.

Response: We do not believe that the contamination identified to date in the former lagoonarea warrants installation of a fence. There is no reason to protect human exposurebecause this is a remote area of the site and inaccessible to trespassers.Furthermore, the levels of contaminants are well below the developed screeningrisk levels. However, notwithstanding these objections to erecting a fence, Witcowill comply with your demand to put a fence in-place, as noted below, rather thanrisk sanctions for failure to comply, unless upon further consideration you decidea fence is not warranted.

The eastern portion of the fence constructed around the drainage ditch will becontinued to the north parallel to the drainage ditch to 1-495 to restrict access tothe lagoon. Construction of the fence will begin as soon as we obtain access from

the railroad and arrange for installation. It is anticipated that this could beaccomplished in two weeks.

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Comment2: 2) Conduct sampling and treatment, as needed, and dispose ofsoil/sediment/sludge which contributes to exposure or potential exposure tohazardous substances or potentially significant releases into air or waterways.Specifically, stockpiled soils and exposed contaminated soils should beremoved. Or, a cover and security suited to the long-term storage ofstockpiled and contaminated soil should be immediately provided. The pilescould also be moved to a secure fenced area.

This means that Witco needs to immediately commence disposal or handling ofstockpiled soil as stated during the transfer of the Site stabilization and cleanupfrom public to private management. In addition, any areas of soil exposed andcontributing to releases into air or water at levels of potential concern should beaddressed now.

At this time the soil piles remain as we left them and the temporary covers we

placed have deteriorated and ripped off. EPA would have stayed to complete thisportion of the job if we knew the piles would be left unattended. Thecontaminated soil is subject to the elements and its erosion will result in offsiterelease. Erosion of the pile is evident. Additionally, air releases from thecontaminated soil continue as is evident from the odor; the extent of exposure tohazardous substances is unknown. Since the area around the piles is frequentedby area business people, this action needs to commence immediately. If the soilpiles are not secured by November 3,1995 the government will take mitigativemeasures. We note that the soil piles were not addressed in the RAP.

Response: On 30 October 1995, Witco repaired/replaced the temporary covers of both thestockpiled soils and the soil erosion protection in response to the demand in yourletter. Photographs and a written discussion of this action are provided inAppendix F of the RAP. The cover and soil erosion protection is a temporarymeasure and will be maintained by Witco. Once the test pits within the fenced"area around the drainage ditch are completed, (i.e., approximately one week aftermobilization), the stockpiled soils will be placed within the fenced area andsecured for use in future field treatability testing.

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Comment 3: 3) Develop and implement erosion, sedimentation, and other controls to. - - =--. ;—~ - - - -,,-jj ft--. ;.

immediately minimize releases of hazardous substances from the Site into air,waterways and other offsite areas. This means, in part, to properly contro'land route storm water such that contaminated areas and offsite releases ofpotentially contaminated storm water are avoided. Uncovered andcontaminated soil is also able to become entrained in the air.

See our previous comment number 31. Although Witco's response indicated thatthe government comment had been addressed, no relevant modification to theRAP was noted.

At this time, our temporary water controls are relied upon to slow storm waterdischarge and stall tidal advance into the most contaminated area (ditch/sump).These controls were instituted on an emergency basis and can not be relied uponto do the job required. Initiate water controls to minimize offsite releases ofhazardous substances in the surface water. Storm water should be re-routedaround the contaminated areas.

Response: Stormwater controls consisting of berms and ditches will be initiated approximatelyone week after mobilization. This stormwater control will divert surface flow fromapproximately 2.5 acres of land, away from the drainage ditch within the fencedarea, into the lagoon downstream of the current fenced area.

The existing drainage ditch within the fenced area will remain. The temporarywater control for the existing drainage ditch (berm) constructed by EPA will becovered with high density polyethylene (HOPE) and additional soil to provide amore substantial surface water control. The surface water collected within thisarea will be allowed to evaporate and/or seep into the ground.

We will construct a dike at the upper end of the lagoon at the breached area alongI-495 at elevation +4 to minimize tidal flow onto and from the site.

These short term storm/surface water control actions will be modified uponimplementation of the removal/remedial action.

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•Comment 4: 4) Isolate water line and other utilities from hazardous substances and hazards ^ 1

posed by Halby's wastes to avoid potential exposure to unsuspecting and ^otherwise careless* or uninformed workers responsible for repairing,inspecting, maintaining, or otherwise contacting contaminated materials inrights-of-way, easements, or private property not controlled by Witco.

The RAP states that Witco has notified the utility companies, including UnitedWater, of identified contaminants which impact respective utilities. In addition,Witco has informally informed EPA of an agreement between Witco and theutilities (at least United Water) whereby, in the event of necessary maintenanceactivities the utility company will notify Witco. In turn, Witco will provide aqualified and OSHA trained contractor to perform the maintenance activities.We believe that this temporary "administrative control" is a very important firststep to avoiding unanticipated exposure of workers. Please provide a copy of allcorrespondence between Witco and the utility companies and any writtenagreements between Witco and the utility companies. Please provide the nameand standard qualifications package for the subcontractor Witco has retained toperform emergency maintenance activities on behalf of the utilities.

Notwithstanding the forgoing, EPA remains concerned about the presence ofcontaminants in the vicinity of the water main (especially from the base of pipeup to the surface) and awaits Witco's proposal for a more permanent solution.Witco's first sampling event conducted near the water main identifiedconcentrations of CSZ which are well below the free product-type concentrationspreviously identified in the adjacent ditch. However, until an appropriate "actionlevel" is developed and agreed upon it is impossible to determine the significanceof the findings. The analyses performed should give us an idea of the types ofcontamination in the vicinity of the water line. It would be a bit more convincingif the field team had followed the FSP and collected additional samples when fieldscreening techniques had indicated a potential hot spot. What is the depth to thewater main from the surface elevation?

Response: Copies of correspondence between Witco and the utility companies are providedin the RAP as described below:

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<<*^/ • access agreements - Appendix E of the RAP;

* standard operating procedures - Attachment C of the QAPP; and> other correspondence - Appendix C of the RAP. .r

.'" , - •' >,--.,.'-'•'- "• • -, ~;. • - . ' ' * , '- •: -

There is an agreement between Witco and United Water that if an emergency• repair for the water line is necessary, United Water will notify the respondent.; ' Final arrangements"'Wiin'regard to emergency repair and maintenance are pending

completion of the inspection of the water line, which will be performed when fieldwork resumes. United Water has a contract with a qualified and OSHA-trained

'' . " ;-"1'"":'* "'•--'•contractor. ""';' •-'->'-' - ••".-.-•- -. :'.'• ----- '-. ;--^,r-,;; -o*' -- .,-•-„. •-•, . •

•• - - * . ' . - « . " - •EPA has been provided the summarized data obtained from the initial sampling

; • " activities conducted by Witco. Full copies of laboratory data will be provided toEPA with the Response Action Report, field screening from the initial sampling didnot indicate any potential hot spots of soil. Health and Safety monitoring indicatedpuffs of CS2, {maximum level of 20 ppm), using a PID and Drager Tubes; however,the monitoring showed levels well below the OSHA 20 ppm TLV. If potential hotspots of soil were encountered, they would have been sampled. The developmentof action levels is discussed in the general comments on the RAP.

The depth of the water main Is reportedly 3'to 4'below surface elevations. Thisis also the approximate depth of water in the six test pits excavated parallel to the

. water line. You are correct to note that the test pits were dug parallel to the watermain. There was not enough room between the water line and drainage ditch todig perpendicular to the water line. Additional test pits are planned in the area todetermine the condition of the water line and the extent of contamination in itsvicinity. The details of these proposed additional test pits were summarized in aMemorandum to EPA dated 14 September 1995 and are incorporated into the FSP,as Water Main Investigation - Second Event.

Genera! Comments on RAP '_ , .

Comments: Our technical comments are difficult to convey due to the lack of detail includedin the draft RAP. Many of the key sections (i.e., treatability studies, risk

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*••• •assessment, etc.) are drafted with a level of detail appropriate for an outline or . ,scope of work rather than an action plan. Author of RAP should make an effortto present information consistently throughout the document For example, it isstated in the sections which address property access requirements that Witco hassecured all necessary access agreements, yet other locations within the documentutilize qualifiers reserving potential for delay while access agreements are soughtSuch inconsistencies lead to misunderstandings, however, we will not belaborsuch editorial points. . -.

Response: The lack of detail was due to the limited amount of time available. Details havebeen included in the final document, and any RAP inconsistencies were corrected.

Comment 6: The government's fundamental concerns regarding the Witco FSP include thefollowing: •-.

1) Insufficient number of proposed samples to meet stated objective. If the trueobjective is to "delineate the vertical and horizontal extent of contamination'1' Vythe number of samples is clearly insufficient To "delineate", one must haveenough samples placed close enough together that one can discern aboundary between "clean" and "dirty" soils, as dictated by an accepted"action level*. If instead Witco simply intends to supplement the existingdata, and this field sampling plan is not intended to be a true delineationeffort, the Agency is willing to accept the 17 locations proposed.

This Is also true of the other sampling locations; insufficient for delineationbut simply utilized for supplemental data, it is acceptable. The effortproposed in the FSP does not appear to delineate contamination with respectto depth. Further, an additional sampling objective should be to identify andevaluate remedial alternatives for the site.

Response: Witco believes that sufficient data does exist to fully delineate the sitecontaminants at the present; however, the described sampling investigation in the

'\*FSP is needed to further define the "clean" areas which do not require treatmentAfter the results of this proposed investigation are reviewed, Witco may propose

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additional appropriate investigation to determine the vertical and horizontal extentof contamination. A second objective of the FSP is to identify and evaluateremedial alternatives for the site.

. —M-g.. iV_i_ii;'j., . .

Comment 7: 2) It is unclear how the field team will systematically utilize the samplingflexibility written into the sampling plan. For example, Section 2.1 of the FSPstates that there will be six sampling locations near the water main and thata minimum of two and up to three samples would be collected. It is statedthat a sample would "be collected from the base of the water main, the areaabove the water main and if contamination is found, one additional samplefrom above the water table with the highest....field measurement..." Thiswork has been completed by Witco. Despite the stated intention of collectingadditional samples when field instrumentation indicated contaminants werepresent, Witco collected only the minimum, two samples from each location.Other examples of inconsistency are found when comparing the FSP, whichstates that test pits will be oriented perpendicular to the water line, and thepost-sampling excavation logs (Log of Test Pit 1 notes that test pit was dugparallel to water main). Then again with, "No excavation will be performed

within two feet of the water main in order to minimize potential damage tothe protective coating. The water main will be partially exposed to allow forvisual observation." ???

With this as background we note that in Section 2.2.1 of the FSP, Witco plansto take "up to 34 soil samples" from the proposed 17 locations in the vicinityof the south ditch. At one point the plan states that "a minimum of onesample per test pit and up to two soil samples" per test pit would be collected(no criteria for such determination in-the-field are offered). It goes on (samesection) to state that the pits would be excavated to a maximum of 10 feetand later that "[soil samples from each test pit will be collected from the 0 to2 foot interval and 2 to 4 foot interval above the water table." Whenpresented with such an inconsistent plan it is difficult provide concisetechnical comments.

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We propose that Witco provide a more structured FSP which includes asampling approach which correlates to its stated objectives. If flexibility isbuilt in, criteria to guide field decisions should be included. In all likelihood,significant prospective excavation activities will be-limited at depth due thepresence of the water table. The 10 foot below grade excavation proposedin the FSP seems reasonable, however, criteria for when a sample will becollected at depth should be included. Please review our detailed commentson the FSP and QAPjP which are offered constructively for yourconsideration at the end of the comment package.

Response: The original intention was to orient the water line investigatory test pits (TP-1through TP-6) perpendicular to the water line; however, because the security fencewas installed prior to this investigation, it prevented using the backhoe in a waythat would allow test pits to be excavated perpendicular to the water line.

The sample location and frequency described in the FSP has been modified toinclude flexibility in order to accomplish the sampling objectives.

To clarify any confusion or inconsistencies, our modified FSP generally calls forsoil samples to be collected, as follows:

• At least one soil sample will be collected from the 0 to 2 foot intervalabove the water table.

• At least one soil sample will be collected from an interval having thegreatest PID field measurement, carbon disulfide dra'ger tube concentrationor where visual observation indicates contamination.

• If these locations are the same, only one sample per test pit will becollected.

-11- •In the area of the water main:

• A soil sample will be collected from an interval at the base of the watermain.

• A soil sample will be collected from an interval above the water main ifcontamination is suspected by PID field measurement, carbon disulfidedrager tube concentration or where visual observation indicatescontamination.

• An additional soil sample will be collected, if deemed necessary, from aninterval having the greatest PID field measurement, carbon disulfide drager

tube concentration or where visual observation indicates contamination.

An investigation of the water main (second event) was proposed to USEPA in amemorandum. This proposal included exposure of the water main, and it is nowincorporated into the FSP and QAPP.

The sampling approach is described in the responses to the detailed comments onthe FSP and QAPP.

Comment 8:. The government understands that the field investigations proposed by Witco areintended to better estimate the volume of contaminated soils and sludges present.The volumes of contaminated materials will have a significant impact on the finalevaluation of clean-up options. However, based on existing analyses we nowknow that we have soils which contain levels of CS2 within a range of non-detectto 110,000 PPM, zinc from near zero to 80,000 PPM, arsenic from near zero to30,000 PPM, etc. Witco should be developing an analysis scheme to select andpropose concentrations of contaminates which would be protective to humanhealth and the environment. These action levels will be as important as the fieldinvestigation in determining the volume of soils to be addressed.

During a brief conference call between Witco and EPA on October 11,1995 wetouched upon the fact that the Region III Risk-Based Concentration Table does

not take cross media transfer into account in generation of screening levels. Thisbecomes significant when the compound is as volatile as carbon disulfide. Inaddition, some compounds, such as carbon disulfide, have different referencedoes for the ingestion and inhalation exposure pathways. In the case of carbondisulfide, adverse effects occur at lower levels for the inhalation pathway thanthe ingestion pathway.

For the past couple of years, EPA toxicologists at the national level have beenworking on a document entitled "Soil Screening Guidance" (see enclosure). Thedocument is still in draft form and does not yet represent "official" policy,however, it has undergone approximately 6 national peer reviews and does giveus someplace to start in developing action levels appropriate to the Halby site.The generic pathway-specific value for inhalation of carbon disulfide included inAppendix A of the draft Soil Screening Guidance is 11 mg/kg in soil. If Witcowere to use the same, or similar, approach to generating a site-specificconcentration it would lead to a higher concentration than 11 mg/kg for at leasttwo reasons. First, the "reference dose inhaled" has recently been revisedupward. I do not have the revised reference dose on hand but your toxicologistcan access the information from the HEAST database. Second, the exposurescenario utilized in the generic calculation in Appendix A was for a residentialland use. We encourage Witco to initiate the development of action levels forcarbon disulfide, and other compounds as appropriate, for the Halby site as soonas possible.

Current and Future Land Use - By letter dated October 11,1995 Mr. WilliamMercurio, Langan Environmental, provided a drawing titled Zoning and PropertyOwnership. The drawing documents that the entire 14 acres referred to as theHalby Chemical site is currently zoned for industrial use, as well as the adjacentparcels. This fact supports the premise that prospective exposure scenariosshould be calculated using industrial use assumptions. However, at least oneparcel (lot #10-002.30-77) within the 14 acre site currently supports multipleresidential trailers. These residences are approximately 300-400 feet from thehighly contaminated ditch area. Upon informal telephone inquiry with the localdepartment of planning I was informed that it is lawful for persons to maintain

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a residence within an industrial zone provided that the residential status pre-datesthe industrial zoning designation. These circumstances must be fully considered.

I am as yet unaware of any government policy or standard operating practicewhich would offer guidance on this matter.

Response: The Halby Chemical Site Review of Constituent Concern Toxicity (ERM,

November 1995) submitted to ERA, provides the requested action levels, which ofcourse, ERA will review. As noted therein, the only site soil areas with levels of

potential concern are in the ditch or the lagoon area. This area will be investigatedduring the RAP implementation.

Comment 9: Mr. Bob Schulte, DNREC chemist, has brought to our attention that the extremelyhigh concentrations of carbon disulfide in the soils at the Halby site may mask thepresence of other significant contaminants if we use the standard EPA analyticalmethod. Delaware DNREC recommends that we utilize the methanol fieldpreservation method commonly used by Delaware DNREC at HSCA (statesuperfund) sites. We offer a copy of the DNREC SOPs for your consideration(enclosed). The government will defer this decision to Witco.

Response: ' Envirotech Research, Inc. (the selected laboratory) will use the DNREC HSCA SOPfor the analysis of volatile organics. This procedure includes the use of a methanolpreservation technique.

Specific Comments

Comment 10: The following specific comments are offered for Witco's consideration.

Introductory Sections of the Response Action Plan

The SAP introductory information typically includes information on the sitehistory, chronology of past actions (both investigative and remedial), past andpresent disposal practices, the physical setting of the site, and a summary ofexisting analytical data. This information is lacking in this document and is onlyincorporated by reference.

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Response: This information is included in the Preliminary Site Assessment (PSA). A brief sitehistory was added to Subsection 1 .2 of the RAP, Subsection 1 .3 of the FSP, andSubsection 1 .3 of the HASP.

Field Sampling Plan

Comment 1 1 : Review consisted of comparing Witco's FSP to EPA's guidance Elements of a FieldSampling Plan in Guidance for Conducting a Remedial Investigation andFeasibility Shidy (OSWER Directive 9355.3-01) and to previous FSPs prepared forHalby and other sites.

Site Background

As per the guidance the analysis of existing data; a description of the site andsurrounding areas; and discussion of known and suspected contaminant sources,probable transport pathways, and data gaps are to be included in the FSP unlessthey are included in the work plan or QAPjP. They are not found in either theFSP or the QAPjP. Ideally these topics would be discussed in the introductorysections of the RAP and then incorporated into Section 1 .0, Introduction, of theFSP by reference.

Response: Probable transport pathways have been extensively discussed and studied by EPAfor the OU-1 and OU-2 RI/FSs. To the extent that these issues have been modifiedby recent findings, we will include additional evaluation in the risk assessment.All other background information is included in the PSA. It should be noted thatEPA comparison of the RAP to RI/FS guidance documents requires detail which isnot normally considered as applicable in the removal program; however, we arecomplying with EPA's request

Comment 1 2: Sample location and frequency. The locations and number of samples to be takenwere reviewed.

• The scope does not allow for additional test-pit excavation and sampling thatmay be needed if high levels of contamination are encountered. In each of

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the three areas the number of test pits is specified but no consideration isgiven to increase the number and extent if field observations indicate a needto do so. '

Response: The necessity for additional sampling will be evaluated based on EPA's andWitco's review of the data from the proposed field investigation. If deemednecessary, a third sampling event, consisting of test borings, will be proposed tofurther define the levels of contamination.

Comment 13: • Note: Ebasco reported on a sampling location SSS-16 east of the drainageditch and water main and west of the railroad tracks (see Figure 1 for anestimated location). Apparently the location was in the right-of-way of therailroad tracks and, therefore, probably within about 8 feet of the end of theties. The location was about midway between the upper end of the lagoonand the fence of the former process plant area. The actual location isuncertain but it appears to be outside of Witco's temporary fence. At thislocation at a depth of about 3 feet arsenic was detected at a concentrating of430 mg/kg and carbon disulfide was detected at a concentration of 320mg/kg. At this time we do not know if these are problematic concentrations.

Response: We are aware of the Ebasco data, and it is already plotted on the applicable PSAmaps. The concentrations referenced do not appear to be a concern in the contextof the Order.

Comment 1 4: The number of samples to be analyzed and the constituents to be analyzed for arepresented in tables 1 through 3. We have several comments that apply to all ofthe tables:

• A turnaround time is not defined for the soil-sample analyses.

Response: Turnaround times of 14 days were added to Tables 2 through 4 in the FSP andQAPP.

Comment 15: • The method for analysis for thiocyanate is listed as ASTM 04193-89; themethod is actually ASTM D-41 93-89. This method is for analysis of water

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samples; a method for extracting the water from the soil before analysis also vshould be defined.

Response: The typographical error was corrected to read ASTM'D-4193-89 on Tables 1through 4. The procedure for extracting the water from the sample prior to analysisby D-4193-89 is ASTM D3987-85 "Standard Test Method for Shake Extraction ofSolid Waste with Water." This procedure was referenced in Tables 1 through 4also.

Comment 16: • In tables 1 through 3 the analytical method for CLP organics is specified asSOW OLM01.8, whereas in the third paragraph on page 1 of 19 the methodis specified as SOW OLM03.1. The correct specification is SOW OLM03.1or the latest available version of OLM.

Response: Tables 2 through 4 in the FSP and QAPP were revised to show the method as SOWOLM 03.1. The exception to the use of OLM03.1 will be the use of the methanolfield preservation technique which is not included in the SOW for field samplesreceived by the laboratory.

Envirotech also updated their QA Manual and the most recent version is includedin the RAP, dated 20 November 1995.

Comment 17: • Note: The tables list various SW-846 analytical methods for TCLP analyses,whereas EPA's split samples will be by SOW OLM03.1 (or the latest availableversion for organics) and SOW ILM03.0 (inorganics). For ignitability, the EPAstandard practice specifies Method 1010 or 1020A, not 1020B. Forcorrosivity, the EPA standard practice specifies Method 9040A, not 9045C;Method 9045C could not be found in the current SW-846 procedures. Forcyanide and sulfide reactivity the EPA standard practice specifies sections7.3.3.2 and 7.3.4.2, respectively. We note these differences for yourinformation only. If Witco has deliberately specified these methods we arenot stating that they should be changed.

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Response: Please provide clarification of the first statement. SW-846 methods can not be run/i5by CLP. Does EPA mean that the extract from TCLP will be analyzed by the SOWMethods?

For ignitability, the most recent version is Method 1020 B; however, Envirotechwill use Method 1020A if EPA prefers.

Related to corrosivity, the following quotation has been taken from SW-846,Chapter 7.2.1 . "EPA has selected two properties upon which to base the definition

of a corrosive waste. These properties are pH and corrosivity toward Type SAE1 020 steel." The issue of the use of methods is complicated by the definition of acorrosive waste. The definition states that a solid waste is corrosive if it is aqueousand has a pH of <; 2 or * 12.5. Therefore in Section 7.2.2.1 of SW-846, only

method 9040 (aqueous) is referenced.

In seeking guidance from the EPA Office of Solid Waste, Methods InformationCommunication Exchange Service (MICE), Envirotech was told to follow themethod most appropriate for the matrix type. Therefore, Envirotech routinelyevaluates waste material for the property of corrosivity using the two methodsreferenced previously. The methods are selected based on the matrix type of thewaste being evaluated. A corrosive waste is then defined as having a pH of 2 or;> 12.5 by either Method 9040B or Method 9045C.

For reactivity, the full reference is as follows:

7.3.3.2 Test Method to Determine Hydrogen Cyanide Released from Wastes7.3.4.2 Test Method to Determine Hydrogen Sulfide Released from Wastes

These are part of SW-846 Chapter 7.3 (which was listed on Tables 1-3), but thespecific reference was incorporated into Tables 1 through 4 of the FSP and QAPP.

Comment 18: • The pH is not measured by SOW OLM01 .8, which is the outdated analyticalmethod for organics. The pH should be measured by SW-846 9045A.

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Response: Envirotech will determine the pH of the samples by the appropriate method asfollows: for soil/solid samples -- SW-846, Method 9045C and for aqueous/liquidsamples - SW-846, Method 9040B. Method 9045A is in an older version ofSW846.

Tables 2 through 4 of the FSP and QAPP were changed to reflect this revision.

Comment 19: • The analytical methods for TCLP pesticides and herbicides are reversed:Method 8150 is for herbicides and Method 8080 is for pesticides.

Response: The following method references were noted and corrected on Tables 1 through4 of the FSP and QAPP as follows:

TCLP Pesticides - SW-846, Method 8080ATCLP Herbicides ~ SW-846, Method 81508

Comment 20: « Air-sample analyses are listed in Table 1 but there is no discussion in the FSPon the objectives and procedures for collecting these samples. No qualitycontrol (QC) samples are specified for the air samples.

Response: The air monitoring program was included in the HASP. The following LaboratoryQuality Control Samples are proposed for the air sample analyses and wereincorporated in Tables 1 through 4 of the FSP and QAPP.

Reagent Blank Matrix Blank SpikeMatrix Blank Matrix Blank Spike DuplicateBlank Spike Laboratory Control Sample

Comment 21: • The purpose for collecting a laboratory duplicate is unclear; laboratoriestypically obtain their duplicates directly from the samples submitted.

Response: Envirotech is obtaining their duplicates directly from the samples submitted;however, additional volume is being collected to ensure sufficient volume forlaboratory analyses.

Comment 22: • Note: EPA plans to obtain splits for TCLP and other RCRA characteristics;these are not specified in tables 1 through 3.

Response: EPA has discretion as to which samples it intends to obtain splits from and whichanalyses it plans to run; however, Tables 1 through 4 of the FSP and QAPP wererevised to reflect splits for TCLP and other RCRA characteristics.

Comment 23: A trip blank should not simply be sent once per day but one in each coolercontaining samples for VOC analyses; more than one cooler may be sent per dayfor these analyses.

Response: All samples for volatile organic analyses will be placed in one cooler per day;therefore, only one trip blank will be necessary. Samples for other analyses do notrequire trip blanks and, therefore, will be placed in additional coolers, as required.In the event that a second cooler is needed for samples for volatile analyses, thena second trip blank will be included. This is highly unlikely since numerous 4ounce vials can fit into the large coolers.

Tables 1 through 4 of the FSP and QAPP were revised to incorporate the abovecomment.

Comment 24: Sample designation. The example sample number provided in Section 3.5 (page8 of 15) will presumably be "TP-1-003," not just "003." No guidance regardingdesignations for QC samples is provided.

Response: Sample designation for test pits will be TP-1 -003. QC samples are collected fromadditional volumes of regular samples; therefore, the designation is the same withthe addition of MS (Matrix Spike) or MSD (Matrix Spike Duplicate). The Chain ofCustody Record will also indicate the QC sample.

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Sampling Equipment and Procedures .HV'%

Comment 25: • Descriptions of procedures are' very brief and no standard operatingprocedures (SOPs) are provided. Such procedures should describe thepurpose and scope of each procedure, the equipment and materials(including the composition of the materials) required, and the procedures andguidelines to be followed. A list of key items to be checked is useful.

Response: Sampling procedures will be in accordance with the Compendium of SuperfundField Operations Methods (USEPA, 1987) as referenced in the FSP and QAPP.ASTM and Conrail SOPs were also added as Attachment C to the QAPP. TheseSOPs were incorporated by reference in the FSP.

Comment 26: • In Section 3.3, Soil Sampling Procedure, the statement is made to the effectthat QC samples will be field homogenized. This is not a proper procedurefor samples for VOC analysis because of the likely loss of VOCs from thesample. Soil samples for VOC analyses should not be homogenized.

Response: The QC samples will be field homogenized, with the exception of the volatileorganic portion. All references to homogenization were clarified to reflect this.AdditionaJ volumes of sample will be collected for QC samples. The laboratorygenerally provides extra bottles for QC samples and in order to ensurerepresentativeness, the QC samples will be field homogenized, with the abovenoted exception for VOCs.

If the laboratory can provide sample jars large enough, then field homogenizationwill not be necessary as the analytical method requires homogenization.

Comment 27: • It is not clear whether the MS/MSDs are additional volumes of a specificregular sample or separate samples in their own right.

Response: The MS and MSD are additional volumes of a regular sample. The specific samplewill be chosen by field personnel. This clarification was incorporated in Tables 1through 4 of the FSP and QAPP. Refer to the response to comments 21 and 26.

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,Sample Handling and Analysis

Comment 28: • The purpose of the laboratory duplicate is unclear; laboratories typicallyobtain their duplicates directly from the samples submitted.

Response: Refer to the response to comment 21.

Comment 29: • In Section 3.4, Field Quality Control Samples (on page 6 of 15 and on page8 of 15), the statement is made to the effect that QC samples will be fieldhomogenized. The reason not to homogenize the samples is described abovewith the discussion on sampling equipment and procedures.


Comment 30: • In Section 3.4 (page 8 of 15), it is stated that a trip blank will be sent on eachday of sampling. A trip blank should not simply be sent once per day but onein each cooler containing samples for VOC analyses; more than one cooler

may be sent per day for these analyses.


Comment 31: • It is recommended that ASTM Type 2 water be used for all QC blank samplesin lieu of HPLC water, the past standard.

Response: Envirotech does use ASTM Type 2 water and will provide this water for QC blanksamples. The FSP and QAPP did not state that HPLC water would be used for QCblank samples. However, the specification for ASTM Type 2 water was added toTables 1 through 4 of the FSP and QAPP.

Comment 32: • In Section 3.7, Packaging and Shipping, it is stated that "ice or an icesubstitute will be placed in the cooler such that the samples requiringrefrigeration are maintained at approximately 4°C." In fact, all samples forchemical analysis should be refrigerated.

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%.-22- , 4;Response: The intent of the statement was that aJI samples will be placed in the cooler with

ice or an ice substitute. This clarification has been made.

Comment 33: • The precautions to be observed in returning used sampling equipment to thelaboratory should be described.

Response: The first step is physical removal of any gross contamination on the samplingequipment. The equipment will then be bagged in plastic prior to returning theequipment to the laboratory. Subsection 3.10 of the FSP was revised toincorporate this procedure.

Comment 34: • The number of sample bottles for each type of analysis should be defined inTable 4. Containers for air samples are not defined in this table.

Response: Table 5 (formerly Table 4) was revised to incorporate the above referencedinformation.

Comment 35: • The "Analytical Methodology" for metals (except Hg) is defined in Table 4 asSOW ILM02.0 and in Tables 1 through 3 as SOW 1LM03.0; SOW ILM03.0 isthe correct SOW. The analytical methodology for organics should be SOWOLM03.1,notOLM01.8.

Response: Table 5 (formerly Table 4) was revised accordingly.

Comment 36: • The holding time for aqueous samples for VOC analysis without preservativeis only 7 days, not 10 days, as stated in Table 4. When preserved with HCLthe holding time is 14 days.

Response: According to SOW OLM 03.1 -Exhibit D (Analytical Methods for Volatiles), Section8.1.3, "Water samples are preserved to a pH of 2 at the time of collection."According to Section 8.3 (Contract Required Holding Times), "Analysis of waterand soil/sediment samples must be completed within 10 days of Validated Timeof Sample Receipt (VTSR)". Therefore, the method requires preservative and a 10-day holding time.

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Ouality Assurance Project Plan

Comment 37: Review consisted of comparing Witco's QAPjP to EPA's 16-page guidance QualityAssurance Project Plan Review and to QAPjPs previously prepared for Halby andother sites. Comments are provided below, organized by QAPjP section.

General

• The title page lacks appropriate approval lines at the bottom.

Response: The title page was revised to incorporate the approval lines.

Comment 38: • The QAPjP is not prepared in a document control format.

Response: Partial document control format was included in the QAPP; however, the QAPPwas revised to include the date and revision number on each page in the upperright hand, corner.

Comment 39: • The document lacks a distribution list.

Response: The distribution list for the entire RAP, including the FSP, QAPP, and HASP is listedon the cover letter; however, the distribution list was also added to the end of theTable of Contents of the QAPP.

Project Description

Comment 40: • There is no schedule of activities specifically in the QAPjP but it referencesthe one provided in Appendix D of the RAP.

Response: Witco made an effort not to duplicate information, but rather to incorporate byreference in accordance with past comments from EPA on previous Halbydocuments.

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Comment 41: • There is no overview of the scope of the project or a discussion of the specificobjectives of the sampling or the intended uses of the data, but these aredescribed in the FSP and referenced to Section 2.0 of the RAP.

Response: The overview of the scope of the project is discussed in Section 2.0 of the RAP.The specific objectives of the sampling and intended uses of the data are discussedin Sections 1.0 and 2.0 of the FSP. Section 2.0 of the QAPP was revised to includea reference to Sections 1.0 and 2.0 of the FSP. In accordance with "Elements ofa Quality Assurance Project Plan" in Guidance for Conducting RemedialInvestigations and Feasibility Studies Under CERCLA. these items may beincorporated by reference if included in the work plan.

Comment 42: • As described earlier, there is no adequate project description in any part ofthe RAP.

Response: Refer to the responses to comments 10 and 11.

Comment 43: • There is no description of the sampling network design and rationale butthese are discussed in the FSP.


Comment 44: • There is no specific discussion as to whether the data collected will addressthe specific objectives of the project, although this is touched on in Section2.0 of the FSP.

Response: The QAPP was revised to incorporate the above comment.

Project Organization and Responsibilities

Comment 45: • Key personnel are discussed in Section 2.0 but are not named and no phonenumbers or addresses are provided. However, the names, phone numbers,and addresses of the Witco Project Coordinator and the Langan ProjectDirector are provided in Subsection 5.1 (page 18 of 20) of the RAP.

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Response: Section 2.0 and Figure 1 of the QAPP was revised to include names. Additionalcontractors and subcontractors were also added. Subsection 5.1 of the RAP wasalso revised to include additional contractors and Subcontractors telephonenumbers and addresses.

Comment 46: • There is no discussion of who performs data processing, data-processing QC,and data review, although these responsibilities are included in theorganizational chart (Figure 1).

Response: Section 2.0 of the QAPP and Figure 1 were revised to include the above personneland their designated responsibilities.

Comment 47: • Personnel qualifications are not discussed.

Response: Personnel qualifications were not discussed because Langan's Statement ofQualification (SOQ), dated 24 July 1995, was previously forwarded to EPA. TheSOQ included resumes and project descriptions. These resumes have now beenadded to Attachment B of the QAPP.

Quality Assurance Objectives

Comment 48: • There is no statement of the intended usage of the data.

Response: Refer to the response to comments 41 and 44.

Comment 49: • Data quality levels and quantitative limits for precision are not provided.

Response: Table 7 was added to the QAPP in response to the above comment.

Comment 50: • QA objectives are not provided in a table format.

Response: QA objectives are summarized in Section 3.0 of the QAPP, although they are notin a table format.

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~26'Comment 51: • The interrelationships between study design, analytical procedures, internal $

QC, and data assessment are not specifically reflected in the DQOs. Inparticular, there should be a discussion of the rationale for the number andlocations of samples to demonstrate that sufficient data are being collectedat the proper locations.

Response: Refer to the response to comments 41 and 44.

Comment 52: • Although air sampling is proposed there are no objectives or detection limitsproposed for air samples.

Response: The air sampling objectives were summarized in the HASP. The QAPP was revisedto include a reference to the HASP. Table 6 (formerly Table 5) of the QAPP wasrevised to include the detection limits for air. The following laboratory detection

limits for the air sample analyses are listed below.

Hexavalent chromium - 1.0 ugTotal Chromium — 0.15 ugArsenic - 0.3 ugLead - 0.2 ug

Actual concentrations in air are determined based on the volume of air drawnthrough the sampling medium which in this case is a PVC filter used for hexavalentchromium and a mixed cellulose ester filter for the other three elements.

Sampling Procedures

Comment 53: Many of these comments are repeated from the above discussion on samplelocation and frequency in the FSP.

• The QAPjP does not provide specific guidance for all field work. The fieldwork is described in the FSP but no SOPs are provided.


-27' ' ,;Comment 54: • Because the QAPjP does not discuss the rationale for the sampling one cannot

ensure that the sampling is limited to that which is necessary and sufficient.


Comment 55: • The investigation objectives are not described in the QAPjP but are discussedin the FSP in Section 2.0, Proposed Scope of Work. Additional objectives arediscussed earlier with respect to the sampling objectives in the FSP.


Comment 56: • Site background and the analysis of existing data are not discussed.


Comment 57: • A map of proposed sampling locations is not provided in the QAPjP but isprovided in the FSP.

Response: The "Sampling Procedures" section of the QAPP references the FSP. Witco madean effort not to duplicate information, but rather to incorporate by reference inaccordance with past comments from EPA on previous Halby documents.

Comment 58: • Sample locations, frequencies, and sample collection methods are notdiscussed for air samples.

Response: The tables in the FSP and QAPP have been revised. Also, refer to the responses tocomments 20 and 52.

Comment 59: • The purpose of the laboratory duplicate is unclear; laboratories typicallyobtain their duplicates directly from the samples submitted.


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Comment 60: • In Table 4 it is stated that a trip blank will be sent on each day of sampling.A trip blank should not simply be sent once per day but one in each coolercontaining samples for VOC analyses; more than one cooler may be sent perday for these analyses.


Comment 61: • It is recommended that ASTM Type 2 water be used for all QC blank samplesin lieu of HPLC water, the past standard.


Comment 62: • The number of sample bottles for each type of analysis should be defined inTable 4. Containers for air samples are not defined in this table.


Comment 63: • The "Analytical Methodology" for metals (except Hg) is defined in Table 4 asSOW ILM02.0 and in Tables 1 through 3 as SOW 1LM03.0; SOW ILM03.0 isthe correct SOW. The analytical methodology for organics should be SOWOLM03.1, not OLM01.8.


Comment 64: • In Section 5.4, Sample Packaging and Shipment Procedures, it is stated that

"samples requiring refrigeration will be promptly chilled with ice or an icesubstitute to an approximate temperature of 4°C..." In fact, all samples forchemical analysis should be refrigerated.


Comment 65: • The holding time for aqueous samples for VOC analysis without preservativeis only 7 days, not 10 days, as stated in Table 4. When preserved with HCLthe holding time is 14 days.

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Sample Custody

Comment 66: • The QAPjP does not include examples of forms, labels, etc. but these areprovided in the FSP.

Response: These were incorporated by reference in order to avoid duplication.

Comment 67: « The sources of reagents and a laboratory custodian are not defined.

Response: Envirotech's laboratory custodian is Mr. Robert McGrady; this has been added toSubsection 5.5 of the QAPP. Envirotech provided a list of reagent sources, and it

is included in Section 7.0 of the QAPP.

Comment 68: • The QAPjP does not address final evidence files.

Response: Sections 8.3 and 14 of the QAPP does address final evidence files for Langan.Envirotech maintains final evidence files for 5 years, as required by New Jerseylaboratory certification. Section 14 of the QAPP was revised to include the abovestatement.

Calibration Procedures and Frequency

Comment 69: » The QAPjP does not include a discussion of calibration standards or reagentsto be used, their source, and traceability procedures. This sort of informationis typically supplied in an SOP.

Response: Maintenance and calibration of the field equipment will be in accordance with themanufacturers instructions. The field equipment manuals were added asAttachment D to the QAPP. These references were incorporated in Subsection 6.3of the QAPP.

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Comment 70: • Calibration procedures and frequency for the analytical laboratory areprovided in Attachment B, Quality Assurance Manual, Envirotech Research,Inc.

Response: Understood, no response.

Analytical Procedures

Comment 71: • Criteria for selection of analytical methods are not included.

Response: EPA informed Witco that it had no preference to the use of EPA versus DNRECanalytical methods. Witco selected CLP methods because these contain a welldefined set of procedures including the analytical and reporting requirements toachieve the highest level of data quality. This rationale was incorporated into

Section 7.0 of the QAPP.

Comment 72: « The method for analysis for thiocyanate is listed as ASTM 04193-89; themethod is actually ASTM D-4193-89. This method is for analysis of watersamples; a method for extracting the water from the soil before analysis alsoshould be defined.


Comment 73: « The tables list various SW-846 analytical methods for TCLP analyses, whereasEPA's split samples will be by SOW OLM03.1 (organics) and SOW ILM03.0(inorganics). For ignitability, the EPA will utilize Method 1010 or 1020A; not1020B. For corrosivity, EPA will specify Method 9040A, not 9045C; Method9045C could not be found in the current SW-846 procedures. For cyanideand sulfide reactivity EPA will specify sections 7.3.3.2 and 7.3.4.2,respectively.


AR30l*980

Comment 74: • The pH is not measured by SOW OLM01.8, which is the outdated analytical

method for organics. The pH should be measured by SW-846 9045C.


Comment 75: • The analytical methods for TCLP pesticides and herbicides are reversed:Method 8150 is for herbicides and Method 8080 is for pesticides.


Comment 76: • Air sample analyses are listed in Table 1 but there is no discussion in theQAPjP on the objectives and procedures for collecting these samples. No QCsamples are specified for the air samples.


Data Reduction, Validation, and Reporting

Comment 77: • No units are specified for air analyses.

Response: Air analyses units are reported in ug/filter. This was incorporated into the tablesin the QAPP.

Comment 78: • The types of records to be maintained are not described.

Response: Section 8.3 of the QAPP states, "All data and reports received from subcontractors,and all data and reports generated by the Contractor will be kept maintained in theproject file." Also, Section 3.0 of the RAP lists the types of records to bemaintained.

Comment 79: • Procedures are not included for transferring data to forms, reports, etc.;proofing; cross-calculating; and handling blank results.

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Response: Langan receives the data from Envirotech on a computer disk, and summary tablesare generated by adding appropriate titles and deleting non-detected values. Thisis stored in a separate computer file so that the original disk is not changed.Section 8.1 of the QAPP was revised to incorporate the above statement. Otherdata reduction, validation, and reporting procedures are described in Section 8.0of the QAPP. For the handling of blank results, refer to the response to comment80.

Comment 80: • Criteria used to accept or reject data are not described.

Response: A statement was included in Section 8.2 of the QAPP that data will be evaluatedaccording to Region Ill's Laboratory Data Validation Functional Guidelines forEvaluating Organic Analyses and Region Ill's Laboratory Data ValidationFunctional Guidelines for Evaluating Inorganic Analyses.

Comment 81: • The key individuals who will handle or report data are not identified.


Internal Quality Control Checks

Comment 82: « Acceptance or control limits are not specified for field and laboratory.

Response: Refer to the response to comment 49 for control limits for laboratory. The QAPPwas revised to include control limits for field. For data acceptance, refer to theresponse to comment 80.

Performance and Systems Audits

Comment 83: • No schedule of audits is included.

Response: QC audits for the laboratory are dictated by the frequency of the sample analysesas specified by the Method.

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-33- %.. ' 4CComment 84: • Audit protocol and acceptance criteria for field activities are not defined. '

Response: Audit protocol is defined in Section 10.1 of the QAPP.

Preventative Maintenance

Comment 85: • The QAPjP lacks a maintenance schedule, a spare-parts list, identification ofa source of spare parts, and a description of the source of repair.


Data Assessment Procedures

Comment 86: • The equations for calculating the relative percent difference or relative

standard deviation are not provided so that precision can be calculated.

Response: The equations to calculate relative percent difference and standard deviation areprovided in Section 9.0 of the QAPP.

Corrective Action

Comment 87: • The QAPjP does not include a scheme to trace defects to a particular source.

Response: Envirotech's QA manual (Attachment A, formerly Attachment B, of the QAPP) doescontain the above information in various SOPs:

• Preventive Maintenance and Calibration Procedures for all AnalyticalInstruments and Ancillary Equipment;

• Procedures for Sample Receipt, Log-In and Mitigation of LaboratoryContamination; and

• Procedure for Internal QA Inspection and Corrective Action.

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«— • -Response:

Comment 89:

Response:

(HASP) must meet the basic

McordinS.y are o

Hazard Assessment

The information on contaminants of concern was sketchy and may be erroneous.The listed chemicals are not the same ones listed in previous HASP for the samesite, and no information is given on the amounts found or likely to be found in thesoil. From our previous HASPs and the description of work, there appears to becyanide compounds at this site, but there is no mention of cyanide in the LanganHASP. The HASP contains a table (Table 3.3 found in Attachment A of AppendixE) to be used to describe the contaminants of concern, but the table is blank anda referral is made to a non-specific list of chemicals. More information is neededon the exact chemicals of concern and their maximum concentrations becausethe type of PPE to be worn is based on the kind and amount of contamination.

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Response: The HASP was developed to meet OSHA regulations 29CFR1910.120 and

included a discussion of chemical hazards with specific emphasis on carbondisulfide. Table 3.3 has been modified to include the contaminants of concern.

Site Control

Comment 91: • The Plan appears to include all the necessary information required in1910.120(d), which covers site control.


Air Monitoring Plans

Comment 92: The Plan appears to be in compliance with 1910.120(c) (6) and 1910.120(h),which covers initial and ongoing air monitoring.


Decontamination Plan

Comment 93: The Plan appears to meet the requirements of 1910.120(k), which coversdecontamination.


Contingency Plans

Comment 94: The HASP does not have all the necessary site-specific information needed (e.g.,names and roles of employees on the site and evacuation route(s)) as required in1910.120(1), which covers emergency response.

Response: Evacuation routes were to be determined on site depending on the location of theactivity. Because the schedule for implementation of the sampling activities hasnot as yet been confirmed, we can not be definite as to which personnel will be

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on site or what their role will be; however, key personnel who are anticipated tobe involved in the project activities were summarized in the HASP.

We trust we have satisfactorily responded to EPA's 20 October 1995 commehts with regard to the RAP.If you have any questions or require additional information, please give me a call.

Very truly yours,

Rajnikant VyasProject CoordinatorWitco Corporation

cc: Jane Biggs-Sanger - DNRECRobert Root - CH2M HillValeric Hahn - BCCJames Nortz - WitcoJack Phillips-PhillipsRichard Dulcey - ERMPaul Fahrenthold - FahrentholdWilliam Mercurio - Langan 206i6\commeni4.epji

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Documents

2061601 Remedial Project Manager United States ...Wllco Corporation One American Lane Greenwich, CT 06831-2559 (203) 552-2000 (203) .552-2010 Fax-20 November 1 995 2061601 Mr. Eric