Comments on December 1999, RI/FS Work Plan

Jacksonville Ash Superfund Site

EPA ID: FLSFN0407002

GENERAL COMMENTS

EPA recommends that the soil sampling for the Site be separated into two tasks that can be performed during this phase of the RI/FS. The first task is to determine the extent of the ash contamination. The second task would characterize the ash contamination and vertical extent within the boundaries determined in the first phase.

Task 1 - EPA suggests that by visual observation and/or with XRF, samples be taken at the known boundaries of ash contamination, until two consecutive “clean” (free of ash or ash contaminated soil) samples are found. When using the XRF for screening (one per residential yard, if applicable), at least four intervals should be screened for lead at 0-6 inches, 6-12 inches, 12-18 inches (per FDEP request) and 18-24 inches (per FDEP request). The boring should be advanced to the watertable or native soil to verify that ash is not present. This can be achieved quickly and efficiently by using a direct push rig, mounted on a small maneuverable vehicle (to allow entry into backyards). After location of the second consecutive “clean” sample outside of the ash, a 5 or 6 point composite sample (from residential yards or comparable area in nonresidential areas) from 0-6 inches should be taken and analyzed for full TAL. In addition, 10% should be analyzed for TCL except VOCs and including dioxin/furans.

Task 2 - The characterization can precede along the lines of the proposed soil sampling. An adequate number of sampling locations should be determined for the ash contamination area. These areas should be broken into smaller areas where appropriate to insure that outlying areas (the area along McCoy Creek, residential areas, etc.) can be adequately characterized. At each sampling location at least 3 to 4 soil intervals should be collected. One at 0-6 inches, one at 12-24 inches, and one below the vertical extent of the contamination. If the ash contamination is deeper than five feet, an additional soil sample within the ash below five feet should be obtained. The XRF should be used to determine the intervals with the highest lead readings for sampling within the ash. Of the 3 or 4 soil samples obtained per sampling location, 20 to 30% should be analyzed for full TAL with half of those samples analyzed for “full” scan TCL (except VOCs)/TAL plus dioxin/furans.

Analyze all groundwater samples for full TAL/TCL including VOCs with 20% analyzed for dioxin/furan. The adequacy of the monitoring well locations will be determined after more data is available on groundwater flow direction and water quality. Because of the nature of the site material every effort should be made to decrease the turbidity of groundwater samples. Samples should not be collected until turbidity is 10 NTU or less.

It should be clearly stated in the workplan that surface water and sediment sampling will be proposed under an addendum to the workplan.

There should be an approval sheet with a declaration of the validity of the RI/FS Workplan signed and stamped by the project managers. Include this approval sheet into the revised workplan.

The background sampling is proposed for public areas and parks surrounding the sites. Past practices of using the incinerator ash as fill makes the analytical results of soil on public areas suspect. EPA doubts that a meaningful background is obtainable in this urban setting. Limited time and resources should be expended on this effort.

Preexisting sampling locations are given without giving the analytical results. Some of these are locations of only visual observation of ash. Give the analytical results associated with all sampling locations and include a listing of all chemicals analyzed for at each location. A spider diagram including the COPCs detected over cleanup levels and MCLs is recommended.

SPECIFIC COMMENTS

1. Section 1.3 - While formal enforcement was not undertaken, significant negotiations regarding the City entering into a consent order with the Florida Department of Environmental Protection were undertaken in 1994 and 1995 for the Forest Street and 5^th & Cleveland Sites, and therefore it is incorrect to suggest that no regulatory activity occurred prior to 1999.

2. Section 1.5.1 - Please note that the areal extent of the Forest Street Incinerator site is yet to be determined. We are not sure of the basis of the 10.5 acre approximation. Geotechnical boring data developed by the Florida Dept of Transportation found ash material in the embankment on the east side of I-95. Additionally, in a 6/10/96 letter to the DEP from the City’s consultant, it was reported that ash was found east of I-95, but not yet fully delineated.

3. Section 1.5.2 - Please note that the areal extent of the 5^th and Cleveland Incinerator site is yet to be determined. We are not sure of the basis of the 9 acre approximation. Excavation activities conducted by HUD in the Durkeeville project demonstrated that ash material extended beyond the boundary of the site. While the Durkeeville material has been addressed, ash material is likely to have been deposited in other directions as well.

4. Section 1.5.3 - As above, documentation that disposal activities were limited to the site has not been provided. Make it clear that these are approximations of the site areas.

5. Figure 2-1, 2-2, 2-3, 2-4, 2-5, 2-6, 2-7 and 2-8 - It is unclear how the term “Remediation Site” is being utilized in conjunction with the area outlined in red. The area of remediation is determined by the extent of all chemical of potential concern (COPC) above levels hazardous to human health and the environment. Referring to the sites as remediation sites is confusing.

6. Section 2.1.1.2 - This section states that “The 5^th & Cleveland Site consists of a 2.8-acre parcel...”. This contradicts the 9 acres stated in Section 1.5.2. Clarify this discrepancy.

7. Section 2.2.2 - Previous studies, Forest Street Incinerator Site, Page 2-14 - The 11^th line states that soil concentrations greater than 3 times background are considered elevated according to EPA protocols. The Region 4 Supplemental Guidance indicates that a constituent is considered elevated with respect to background when the maximum detected concentration is greater than 2 times the average background value. For naturally occurring organic chemicals, the risk assessor may compare the on-site maximum detected concentration to the 2 times average site-specific background concentration to determine whether the constituent is elevated at the site. The mention of 3 times background in the work plan also occurs at the bottom of Page 2-15.

8. Section 3.0 - Brown’s Dump is a separate Site. Jacksonville Ash Site is comprised of only three properties .

9. Section 3.1.2 - Lead was utilized as a convenient indicator in previous assessment activities, no determination was made by the FDEP that lead was the only or primary contaminant of concern.

10. Section 3.1.2.1- Not all organic COPC have been tested for in the groundwater.

11. Section 3.1.2.2 - Arsenic background has not been definitively established for the sites in question, it seems premature to suggest a background average has been developed.

12. Section 3.1.2.2 - Attempting to draw conclusions defining “source” and “non-source” areas is premature. Source areas are not defined as yet.

13. Section 3.1.3.4 - Summary of Ecological Effects, Page 3-7. Stressed vegetation is described as occurring in areas where ash is present at the soil surface. Additional information on the location and extent of stressed vegetation should be provided with a breakdown for each of the three ash sites. A revision to address this comment might be addressed in the ecological risk assessment.

14. Section 3.3.1.2 - It is stated that the ash disposal sites “ ...are not CERCLA sites...”. This statement is not true. The sites are CERCLA site, although they are not listed on the National Priority List. Correct this statement.

15. Section 3.4.1 - The second bullet should include what is the nature and extent of the contaminant release.

16. Section 3.4.2 - Advanced Assessment Decision, Phase II, needs to include analysis of the nature and extent of contamination. This phase should occur before the step called Advanced Assessment Decision, Phase I.

17. Section 3.5.1 - The tasks must include evaluating the nature and extent of the ash. Measure the concentration of all COPCs in surface soil, subsurface soil, and the groundwater. Delineation of the contamination cannot be limited to lead.

18. Section 3.5.1 - References to Level I, II, III, and IV protocols are extremely dated. These should be updated to the newest methodologies.

19. Section 3.5.1 - The documents state that systematic sampling will be used and that a grid will be placed over the site to obtain a realistic average. None of the figures in the Work Plans show a grid.

20. Section 3.5.1 - The documents state that the “number of samples to be collected is estimated to obtain an understanding of the site...and to obtain conservative upper confidence limits for the data set for comparison to decision-making limits”. These estimates and their dependent data must be included in the Work Plans.

21. Section 3.5.1.3 - It is recommended that for the purposes of the statistical evaluation of the data that the soils in drainage pathways be treated as sediments.

22. Section 3.5.1.4 - Surface water samples (and all other samples) must be collected as specified in the Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (http://www.epa.gov/region4/sesd/sesdpub_guidance.html).

23. Section 3.5.1.5 - The workplan states that groundwater wells will be sampled as described in the FSPs. FSPs were not included in the workplan, and therefor the proposed procedures cannot be evaluated to determine if the minimum standards described in the Environmental Investigations Standard Operating Procedures and Quality Assurance Manual are being met.

24. Section 3.5.2 - Ecological Risk Assessment Sampling Approach, Page 3-24 - This section should mention that biological sampling might be addressed by a future addendum to the work plan pending the results of the screening-level ecological risk assessment.

25. Sections 3.5.1.3 and 3.5.1.4 - These sections state that sediment and surface water sampling will be described in Section 10.0. However, Section 10.0 discusses sampling of soil and ash and ground water but not sediment or surface water. This section should clearly state that the surface water and sediment sampling will be in an addendum to the workplan.

26. Section 4.2.1 - Sampling intervals must be specified in feet and inches or feet and tenths of a foot. Well data must be recorded to the same accuracy, except water levels must be to 0.01feet.

27. Section 4.3.3 - The minimum required accuracy for the GPS unit is 1 meter.

28. Section 4.5 - Electronic format must include ArcView compatibility.

29. Section 5.2.1 - Due to historical confirmation that some areas of ash are characteristically hazardous for lead, the proposed extrapolation of RI analytical total concentrations is inadequate to determine if investigative derived solids are characteristically hazardous. TCLP analyzes will be necessary to meet RCRA requirements.

30. Section 6.0 - Data Evaluation and Risk Assessment Approach, Page 6-1 - Cite the current guidance on ecological risk assessment, specifically EPA’s (1997) Ecological Risk Assessment Guidance for Superfund.

31. Section 9.1.5 - Use the newest version of the Environmental Investigations Standard Operating Procedures and Quality Assurance Manual as specified above.

32. Section 10.1.1 - Regardless of the results of XRF, visually distinguishable ash should be noted and should be mapped as impacted areas. Evaluation of the extent of ash should be developed as a combination of multiple techniques, with confirmatory laboratory analysis for full metals and “full” scan TAL/TCL (without VOCs, with dioxins/furans), from samples outside the limits of the ash.

33. Section 10.1.1 - The XRF data and visual observations must be captured into the EDMS system.

34. Section 10.1.1 - The document states that XRF readings above 400 mg/kg will be considered elevated and this will determine the need for further soil/ash horizontal and vertical delineation. The accuracy of the field XRF is questionable, because of a lack of sample prep. The screening value should be set lower.

35. Section 10.1.2 - The document must specify how the XRF will be used as the basis in determining locations for laboratory samples.

36. Section 10.1.2 - There is not enough investigation into the characterization (nature) of the comtaminated soil and ash. Increase the number of samples and increase the percentage analyzed for “full” scan TAL/TCL (without VOCs, with dioxins/furans) including a few full scan TAL/TCL (with VOCs). Soil/sediment analysis for lead only is not appropriate. More full metals analyses are needed.

37. Section 10.1.2 - Do not use the highest XRF readings to pick which background samples are sent to the lab for analysis. This would bias the background results toward elevated concentrations.

38. Section 10.1.2 - Reference to “designated number of sample” must reference the table with that specifies the number or percentages.

39. Section 10.2.1 - Do not limit the groundwater investigation to the delineation of lead. Sample all existing and proposed monitoring wells and analyze for TAL/TCL with dioxin/furans.

40. Section 10.2.1 - If concerns exist over improper construction of previous wells leading to elevated turbidities, then prior to installation of any new wells, samples should be collected for sieve analysis to determine appropriate well construction and sandpack design.

41. Section 10.2.1 - The text should read that a deeper well “will be installed” , if any shallow groundwater result above the groundwater standard are found.

42. Section 10.2.2 - Sample all existing and proposed monitoring wells and analyze for TAL/TCL with dioxin/furans.

43. Section 11.0 - The proposed background sampling is actually control sampling.

44. Section 11.0 - Background Sampling Plan - The background sampling plan should include sampling of surface water and sediments. Indicate whether this will be in the addendum to the workplan.

45. Section 11.1 - Suggestions that PAHs and other organic contaminants detected are the result of other sources other than ash disposal activities are currently unverified.

46. Section 11.3 - The workplan should include references and an explanation showing how the equation was used to determine n. See comment on Section 12.4.3.2 for SW846 method for determining n.

47. Section 11.5 - Do not combine the background data for the sites. Brown’s Dump data is completely separate from the Jacksonville Ash Site data. The three properties that comprise the Jacksonville Ash Site, should have separate background data sets.

48. Section 11.5 - Need more “full” scans (TCL (except VOCs)/TAL with dioxins/furans) in “subsurface soils, groundwater, and surface water samples”. Even if chemicals are relatively immobile, ash is located in the subsurface.

49. Section 11.5.1 - It appears that all of the background soil samples are to be taken on public land; given the history of the City for using public land for disposal, we suggest that each proposed location be identified and evaluated for prior activities and its appropriateness for use as a background soil sample.

50. Section 11.5.1 - Need more “full” scans (TCL (except VOCs)/TAL with dioxins/furans) in background sampling in all media. This section contradicts Section 11.5.

51. Section 11.5.2 - Proposed background groundwater locations are contingent on data proving that they are upgradient of the sites.

52. Section 11.5.2 - Groundwater contamination investigation is not limited to lead above 15 µg/L.

53. Section 12.1 - It appears that the contaminated area generally known as Forest Street Incinerator is not adequately defined to suggest that the size of the impacted area is limited to approximately 10.5 acres.

54. Section 12.2 - The conceptual model does not take into account airborne transport of contaminants. While no information is provided, it is be noted that the shutdown of the incinerators was the result of a lack of air pollution control equipment. Based upon the operation of the incinerators, the height of the stacks, and the local meteorological conditions particulate releases would be deposited some distance from the release points. This could result in a “doughnut” of non-deposition of airborne contaminants near the release points and increasing contamination concentrations at some distance from the release points. The airborne contaminants would be unlikely to be visually distinguishable from surrounding soils.

55. Section 12.2.2 - Migration and Exposure Pathways, Page 12-3 - Include as an exposure pathway aquatic life exposure to sediments. The same goes for the list of receptors on Page 14-3 for Lonnie C. Miller Park.

56. Section 12.2.2 - It should not be assumed at this stage that lead is the primary contaminant with the potential to affect groundwater.

57. Section 12.3 - It is premature to suggest that lead is the primary contaminant of concern for soils. Insufficient data has been collected to make that generalization.

58. Section 12.4.1 - More soil samples are needed to characterize areas of known ash including additional TCL (except VOCs)/TAL with dioxin/furans analyses.

59. Section 12.4.2.1 - The 3^rd paragraph mentions resampling in the area of SB67 and if over 400 mg/kg of lead is found, the investigation will be expanded eastward. Concentrations above 400 mg/kg have already been established as has the presence of ash east of I-95 at Myrtle Avenue Park. The Dominion letter report from 1996 for Forrest Street indicates ash material extends (SB 67 contained 570 mg/kg) to I-95. The 1996 letter report and data developed by the Florida DOT also indicates ash material east of I-95 on both the eastern and western sides of Myrtle Avenue. The investigation should extend to known areas of ash disposal and possibly beyond depending upon the “extent” of contamination. Define the nature and extend east of I-95. Additional sampling is needed east of Margaret Street all the way to I-95.

60. Section 12.4.2.1 - The limited work to date has not defined the horizontal limits of ash material. Sampling beyond the boundaries of the existing school has been limited to right of ways only. Additional delineation sampling needs to be proposed, which should include sampling within non-City property boundaries. Soil sampling is needed in the residential areas south and west of the site.

61. Section 12.4.2.1 - Review of aerial photographs indicate that a passage may have existed between the south and north side of McCoys Creek. The sheet pilings on the north side of the creek and further west along the creek suggest that similar removal of native soil and deposition of ash may have occurred on the north side of the creek and west of the railroad tracks. Aerial photographs also show disposal activity in the industrial area north of the incinerator on the north side of McCoy Creek. Expand the investigation into these areas.

62. Section 12.4.2.1 - The December 1, 1997, Site Investigation report states that ash was encountered in a off site pile where sample SS-19 was obtained. It also states that ash was present on a vacant lot south of Lewis Street, approximately two blocks west of the site. Include these areas into the investigation.

63. Section 12.4.2.1 - Include a plan to investigate airborne contamination. Airborne contamination could result in a “doughnut” of non-deposition near the release points and increasing contamination concentrations at some distance from the release points. The investigation into the horizontal extent of dumped ash may not encounter airborne contamination.

64. Section 12.4.2.1 - A minimum of 18 borings is inadequate to evaluate the extent and nature of ash disposal areas. Additional characterization and delineation boring locations are needed. The soil investigation needs more TCL (except VOCs)/TAL with dioxin/furans analyses and TAL alone analyses. Do not analyze for lead only. In addition, due to the discontinuous nature of the ash and contaminant distribution additional samples should be collected beyond the “clean” samples. As mentioned above, ash material has been confirmed to exist beyond the areas indicated.

65. Section 12.4.2.1 - The last paragraph in this section indicates the extent of vertical investigation of groundwater will cease if groundwater in well DMW-12 has below detection levels of total lead. The vertical extent of contamination pertains to all contaminants (inorganic and organic) which may be a result of ash disposal/site activity. All groundwater samples need to be analyzed for the full scan TAL/TCL including VOCs .

66. Section 12.4.2.1 - Make it clear that surface water and sediment sampling will be included in an addendum to the RI/FS Workplan.

67. Section 12.4.3.1 - The extent of contamination (particularly groundwater contamination) is not limited to lead.

68. Section 12.4.3.1 - Some cluster wells are needed to determine if vertical gradients are present. Investigation into vertical gradients should take into account periods that City of Jacksonville municipal water wells, screened in the underlying Floridan Aquifer, are pumping.

69. Section 12.4.3.2 - Of the 54 soil samples planned, a maximum of 5 TCL (less VOCs)/TAL/dioxin & furan designated samples are planned for this 10+ acre site. Five total scan samples cannot adequately confirm and supplement the previously collected data and define nature and extent of the ash. Given the heterogeneous nature of the ash, a higher percentage of total scan samples are in order. Also, it should be made clear that sediment and surface water sampling will be included in an addendum to the RI/FS Workplan.

70. Section 12.4.3.2 - EPA generally uses the following (taken from SW846) to determine the appropriate number of samples:

Where:

is the square of the t statistic (is specified, usually 90 or 95%);

is the sample variance (based upon previous data); and:

is the result of the PRG of the analyte minus the mean concentration of the analyte (again, previous data) squared. I note that a lot of previous data is available, and this method could be applied to each decision unit for each analyte (lead, PAHs, etc.) to determine if the proposed plan will collect sufficient data.

71. Section 12.4.3.2 - The criteria to be used for determining whether or not sufficient data has been collected to determine if the risk/remediation decision can be made should be clearly stated.

72. Section 12.4.3.2 - Analysis all monitoring wells for full scan TAL/TCL including VOCs. It should be noted that pesticides were detected in MW-02 from a 1994 investigation.

73. Section 13.1 - The contaminated area at the 5^th & Cleveland Incinerator Site is not adequately defined to suggest that the size of the impacted area is limited to approximately 2.8 acres. This also contradicts that nine acres stated earlier on page 1.3.

74. Section 13.2 - It should be noted that the conceptual model does not appear to take into account airborne transport of contaminants. While no information is provided, it should be noted that the shutdown of the incinerators was the result of a lack of air pollution control equipment. Based upon the operation of the incinerators, the height of the stacks, and the local meteorological conditions particulate releases would be deposited some distance from the release points. This could result in a “doughnut” of non-deposition of airborne contaminants near the release points and increasing contamination concentrations at some distance from the release points. The airborne contaminants would be unlikely to be visually distinguishable from surrounding soils.

75. Section 13.2.2 - It should not be assumed at this stage that lead is the primary contaminant with the potential to affect groundwater.

76. Section 13.3 - It is premature to suggest that lead is the primary contaminant of concern for soils. Insufficient data has been collected to make that generalization.

77. Section 13.4.2.1 - More soil boring locations and additional “full” scans TCL (less VOCs)/TAL/dioxin & furan are needed to determine the extent and nature of the ash contamination. The remaining samples for lab analysis should be analyzed for TAL. Do not analysis for lead only.

78. Section 13.4.2.1 - The text states that “... an estimated total of 27 soil borings are proposed for this site”. Only 15 soil boring locations are shown on the site map Figure 13-2.

79. Section 13.4.2.1 - The extent is determined by the extent of all COPCs above levels hazardous to human health and the environment. Do not limit the definition of extent to lead.

80. Section 13.4.2.1 - The area north ( up to the school for exceptional children) and northeast (the picnic/playground area) of the Emmett Reed Community Center has very limited previous data. The City has placed sand under the playground equipment, but ash-like material is still visible at the surface. Additional samples designated for laboratory analyses should be collected from the picnic/playground area. Include the area of the former cemetery all the way to I-95, especially on the former drainage ditch that ran between the Emmett Reed Community Center and the picnic area turning east and running to I-95.

81. Section 13.4.2.1 - The City has detected ash in the yards of residents east of the former incinerator site. Include the residents east of the site into the sampling plan. Also, there is a nearby daycare center which should be targeted for soil sampling.

82. Section 13.4.2.1 - The 1996 Contamination Assessment Report (CAR) shows ash in the residential areas southwest and southeast of the site. Also recent soil borings by the Public Housing Authority presented in the 12/10/99 Ellis and Associates Report indicates that ash is present on the three lots examined between Eaverson and Payne Street and Grothe and Hart Street one block southeast of the site. More soil sampling locations are needed in the residential and light industry areas located southeast, south, southwest and west of the site.

83. Section 13.4.2.1 - The groundwater flow direction has not been determined for this site so additional monitoring wells may be necessary when flow direction is determined. Some cluster wells are needed to determine if vertical gradients are present. Investigation into vertical gradients should take into account periods that City of Jacksonville municipal water wells, screened in the underlying Floridan Aquifer, are pumping. The text states that six new monitoring wells will be installed. There are only four shown on Figure 13-2. The two “upgradient” wells are not shown on Figure 13-2. These “upgradient” wells should be closer to the property. One monitoring well is proposed for the middle of the baseball field. This well will had to be flush mounted or moved. One of the on-site monitoring wells should be installed at the location of the former incinerator building and include VOC analysis. The “downgradient” monitoring well east of the site near I-95 is too far away from known contamination. Move this well to the edge of the known contamination.

84. Section 13.4.2.1 - Do not limit the groundwater investigation to lead. Analyze all groundwater samples for all TAL/TCL including VOCs.

85. Section 13.4.2.1 - Clearly state that the surface water and sediment sampling will be in an addendum to the workplan.

86. Section 13.4.3.1 - Do not limit the groundwater investigation to lead.

87. Section 13.4.3.2 - More than five “full” scan TCL (except VOCs)/TAL and dioxins/furans are needed to determine the nature and extent of all COPC. The remainder of laboratory samples should be analyzed for TAL. Do not analyze any laboratory samples for lead only.

88. Section 13.4.3.2 - Analyze all groundwater samples for all TAL/TCL including VOCs.

89. Section 14.1 - Other sections of the report (Section 2.1.1.3) state the size of the Lonnie C. Miller, Sr. Park is approximately 100 acres. Correct this discrepancy.

90. Section 14.4.2.1 - The complicated history of waste disposal at this property requires a low cost method to determine areas that required more detailed soil sampling than the sparse sampling presently proposed. It is recommended that a geophysical survey of the property be performed and the analysis of that data used to determine additional sampling locations.

91. Section 14.4.2.1 - The western side of the property has been reported as the location of disposal of septic sludge. There are only four samples from the this side of the site with one estimated lead concentration of 380 mg/kg. This is a strong indication of the presence of ash on the church property on the southwest portion of the site. Investigate the western side of the property including the church property all the way to the intersection of Moncrief and Soutel Road to the wooded area northwest of the site that aerial photography indicates was not wooded in the past and was the site of possible disposal. Also, aerial photography and citizen accounts indicate that possible ash disposal occurred west of Soutel Road. Investigate for the presence of ash west of Soutel Road.

92. Section 14.4.2.1 - Aerial photography and citizen accounts indicate that ash disposal occurred south of Moncrief Road between Richardson Street and the Ribauld River. Disposal activity is visible on aerial photography on both the western and eastern bank of the Ribauld River south of Moncrief Road. Ash is known to have been deposited along the western bank of the Ribauld River north of Moncrief Road. Soil sampling is needed on the residential property on the eastern bank of the Ribauld River north of Moncrief Road. Include all of these areas into the investigation.

93. Section 14.4.2.1 - Determine if ash or contaminated soil is present in the residential areas north and south of the property.

94. Section 14.4.2.1 - A automobile junkyard was located in the southeast section on the property near Moncrief Road. There are citizen reports of buried automobiles in this area. Investigate this area including VOC analysis in the soil and groundwater samples.

95. Section 14.4.2.1 - A 400 foot by 400 foot grid is too large. This grid size would be more acceptable if backed up with a geophysical survey of the site with supplemental bias sampling in anomalies determined from the survey.

96. Section 14.4.2.1 - More than five “full” scan TCL (except VOCs)/TAL and dioxins/furans are needed to determine the nature and extent of all COPC. The remainder of laboratory samples should be analyzed for TAL. Do not analyze any laboratory samples for lead only.

97. Section 14.4.2.1 - Analyze all groundwater samples for all TAL/TCL including VOCs.

98. Section 14.4.2.1 - The groundwater flow direction has not been determined for this site so additional monitoring wells may be necessary when flow direction is determined. Some cluster wells are needed to determine if vertical gradients are present. Investigation into vertical gradients should take into account periods that City of Jacksonville municipal water wells, screened in the underlying Floridan Aquifer, are pumping. Assuming that groundwater flow direction is toward the Ribauld River, the two monitoring wells on the western side of the central drainage (a known ash deposit) need to be on the eastern side of the drainage ditch. The location of the “upgradient” monitoring well is not on Figure 14-2 and cannot be evaluated. Another monitoring well is needed in the western portion of the property to determine water quality and groundwater flow direction in the western side of the site.

99. Section 14.4.2.1 - Do not limit the groundwater investigation to lead.

100. Section 14.4.2.1 - The text states that six monitoring wells will be installed. Figure 14-2 only shows the location for five new wells. The need to install additional groundwater monitoring wells will be considered based on groundwater flow directions and extent of ash determined during the first phase of the investigation.

101. Section 14.4.2.1 - Clearly state that the surface water and sediment sampling will be in an addendum to the workplan. Include the on-site fish pond in the surface water and sediment sampling.

102. Section 14.4.3.1 - Do not limit the groundwater investigation to lead.

103. Section 14.4.3.2 - More than three “full” scan TCL (except VOCs)/TAL and dioxins/furans are needed to determine the nature and extent of all COPC. The remainder of laboratory samples should be analyzed for TAL. Do not analyze any laboratory samples for lead only.

104. Section 14.4.3.2 - Analyze all groundwater samples all TAL/TCL including VOCs.

105. Appendix B - Health and Safety Plan - The Dates of Site Work is incorrect. The Contaminants of Concern in Table 2.4 should include mercury, semivolatiles (PAHs), pesticides, PCBs and dioxin/furans.

106. Appendix D, p. D-3 - Materials blanks are required for well installation materials (water, sand, grout, and bentonite). Archiving is not sufficient.

107. Appendix D, p. D-6 - Water levels must be determined to 0.01 feet.

108. Appendix D, p. D-7 - Turbidity must also be measure during purging. Samples should not be collected until turbidity is 10 NTU or less. The well should be sampled immediately - 6 hours is too long to wait.

109. Appendix D, p. D-7 - Peristaltic pumps are recommended for sampling of all parameters when groundwater is shallow.

110. Appendix D, p. D-8 - When sampling for voc’s using a peristaltic pump, these analytes should be collected last.

111. Appendix D, p. D-12 - Note that the split spoons used for collecting soil samples designated for laboratory analyses should be stainless steel and large enough in diameter (usually 3") to obtain adequate sample volume.

112. Appendix D, p. D-16 - The paragraph on Design for Monitoring Wells mentions following the ECBSOPQAM “as closely as practical”. Any anticipated deviations from the ECBSOPQAM should be clearly listed.

113. Appendix D, p. D-17 - Include that to meet the minimum 2-inch annular space requirement, a minimum 6-inch diameter borehole is necessary to install a 2-inch monitoring well.

114. Appendix D, p. D-19 - State that no joint adhesive will be used in PVC well construction.

115. Appendix D, p. D-20 - The document describes wells as being screened within the ash waste. If wells are to be constructed in the ash material, standard sand will not work to keep materials from entering the well. The ash will have to be sieved to determine the proper grain sized for the sand.

116. Appendix D, p. D-23 - Soap is necessary for proper field decontamination.

117. Appendix D, p. D-23 - If it is planned to reuse Teflon^R tubing, please note Teflon^R tubing requires an alternate decontamination procedure. Also, PVC plastic materials that are decontaminated will not be rinsed with isopropanol, nor should PVC material be sprayed with steam.

118. Appendix D, p. D-25 - It is not necessary (and may be harmful) to rinse hoses and pumps with isopropanol.

119. Appendix D, p. D-25 - One meter accuracy is sufficient for locating samples and wells.

Appendix F, Section 2.4, p. 2-4 - The QAPP must specify the method proposed for the XRF instrument, including method detection limits, analytes and applicable QA/QC.

120. Appendix F - Quality Assurance Project Plan - Table 2-1 appears to indicate that soil samples will be preserved to a pH < 2. Soil samples should not be preserved with acid. Correct this table.

121. Appendix F - Section 2.4.3.10 and Table 2-1 - The workplan does not specify an analytical method to be used for XRF analysis. It is recommended that draft SW-846 method 6200 be used for XRF analysis.

122. Appendix F - Table 2-1 - The following omissions should be corrected.

a. In order to be complete, this table should include the extraction and clean-up methods used in preparation of the samples.

b. SW-846 analytical methodology is periodically updated. The table should cite the version of the method that will be used.

c. The table should specify the materials used for the sample container lids.

d. Dioxin/furan samples - Two (2) one-liter sample bottles should be collected in order that a reextraction could be performed if necessary. Two-liter sample bottles should not be used.

123. Appendix F - Section 2.4.3.1 - The workplan states that draft dioxin/furan screening method SW846/4425 produces data that can be used for risk assessment. In general, data produced from any screening method should not be used for risk assessment without confirmation of these data by analytical methods capable of producing definitive results. SW846 method 8290 or method 1613B are the only dioxin/furan analytical methods that will provide definitive results that meet the rigorous requirements of risk assessment.

124. Appendix F - Sections 2.5.1 and 2.5.2 - These sections do not adequately describe the acceptance criteria for field and lab QC samples. This omission should be corrected.

125. Appendix F - See the attached QAPP checklist for additional deficiencies. Correct these deficiencies.