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•f. SDMS Document H a r d i n g L a w s o n A s s o c i a t e s 1 1 5 5 8 0 April 12, 199G 29872 12.4 Ms. Slierrel Taylor-Domville United States Environmental Protection Agency Section II Emergency and Remedial Response Division 290 Broadway New York, New York 10007-1866 Proposed SiiK Activitios Phase II Reinedial Investigation Work Plan Island Chemical Company, St. Croix, U.S. Virgin Islands Dear Ms. Taylor-Domville: Harding Lawson Associates (HLA) is s\ibmitling this letter, on behalf of Island Chemical Company (ICC), to summarize our understanding of the items agreed to dining our March 1.5, 1996 meeting. It is HLA's understanding that the \LVA will issue an interim response to HLA's I'ebruary 23, 1996 Response to Comments letter associated vvitli the Draft Phase II Remedial Investigation Work Plan (RIWP) for the subject site to pei'irn't the installation of continuous water level recorders and the review of the data generated thereby belore FPA connnent.s on the rest of the RIWP. Since ICC or HLA has not yet received tins letlei-. we would [irofjose that IJiPA's interim response likewise permit some additional work lo fui-th(ii' I'aciiilale ihe pi-ogiiiss of the pi'ojecl. MLA reconnnends that the following pi"eiiminarv site activities he initiated innnediatelv: • HLA recommends that contirnious watei' level data be collected to document the pi'evailing direction of gi'oundwater llow under static conditions. HLA proposes to install two additional contiruious water level I'ecordei's in tlie two remaining onsite wells. Installation of these recorders, in addition to tlie two recoi-dei's ciu'rently functioning onsite, will provide continuous data across the majoi'ily of the site, 'f'hese recorders will provide data regai'ding the percentage of time that groundwalei' llows in any given direction. Once i:lu-; data generai(:;(i fi-om tile at)ove aciiviiies an: evaluated, additional mterim site activities are recommended to be im[)lemenle(i, including: • A soil sam[)ling pi'Ogram will be conducted lo invesligale tlie extent of impact in the AS'1\ The sui'ficial extent of impact in Ania H will be evaluated by collecting and analyzing 12 surface soil samples. Surface .soil samfiles will be collected using decontaminated shovels and stainless steel trowels. Samples will be collected from the 18- to 24-inch interval below ground surface. • The vertical extent of impact in Area B will be evaluated by collecting and analyzing selected soil samples from foiu' to six soil borings. Contiinios split spoon samples will be collected from the surface lo the watei' table at eacli localion. Samples will be [ilaced directly into laboratory-pre|)ar(!d sam])le containers. Additional sample volume will he collected into resealable plaslic bags and screened in liie field using a i;)hotoionization detector (PID) accoi'ding to |)roceduies desiiribed in llie r''SP. Piocedures foi'sample handling, management, and sin'pping are described in the l''SP and QAI'P. Selecl(^d sampliis will be analyzed and additional borings mav be installed liascid on tlie Pit) lesnlls. Soil samples will lie analyzed for VOCs. Engineering and Washington Park, 14 Washingion Road. Princeton Junction NJ 03550 609/936-0700 Fax 609/936-1020 Environmental Services ,,i .s,.,;,,;.;/„n ..fiLiniiif. .-IA..- I./,VA . 0;ii,;:. .\.iii,.mri.i,. 305304 Harding Lawson Associates Ms. Sherrel Tayloi'-Dornville USEPA April 12, 1996 Page 2. With EPA approval, planned monitoring well MW-2 was not completed during the January 1995 field program. As discu,s,sed with EPA, an area of low permeability was encountered above the water table in SBCl. The possibility that well installation might provide a conduit for contaminants to reach groundwater was a concern at the time. However, analytical results of soil samples collected from SBCl indicated that soils above the water table in this area were not contaminated. Thei'efore, MW-2 will be installed in Area C, as specified in the Phase I Work Plan, This well will be used to evaluate groundwater at the center of the site and to provide additional wafer level control data. The well will be installed and developed as described in the FSP. Development water will be placed in ,5,5-gallon drums and sitiged onsite pending disposal. Groundwater samples collected from the proposed nionit oriu" wet (MW-2) will be analyzed for TCL VOCs, TCL SVOCs, TCL Pesticides, TCL PCBs. and TAL Inoi'gtinics (total and dissolved). Once the data developed through tlie foregoing activities lias been analyzed and submitted to EPA, HLA's RIWP will be I'e-evaluated in context. HLA requests approval to perform the preliminary site activities delineated above. If a response is not received from EPA by April 22, 1996, HLA assumes that EPA authorizes implementation of these activities. Please call either of llu.; undersigned it you liave any (]ueslions. Yoiirs very truly HARDING LAW :SS90CIATES Jas,bn M. Schindler, P.G. A^isociate C^logist ' EdwarcTA. Nemecek. R.G., CI'G Principal Hydrogeologist Resional Geosciences Mana''er EAN\)MS\]sv\js\ml \WORK\29872\0l\epallr.doc '77775 document was prepared for the sole use oj the ICC and the regulatory agencies involved with the project, the only intended beneficiaries of our work. No other parties should rely on the information contained herein without the prior written consent of HI A. 305305