ACAT FOIA Repository 32

.1i;~N111 W. 16th Avenue, Suite 302Anchorage, Alaska 99501·510999501-5109907-743-9399 Phone907-743-9398 Fax56016-007November 30, 2005USAED Alaska DistrictNorthern Area OfficeU.S. Army Corps of EngineersP.O. Box 35066Fairbanks, AK 99703-0066Attention: Mr. Paul Schneider, P.E.Correct BCS Responses to USACE Comments on Rev 0 Planning DocumentsW911KB-05-P-OI03W91lKB-05-P-OI03 Gambell FUDS Remedial ActionGambell, AlaskaDear Mr. Schneider:The purpose of this letter is to provide Bristol Construction Services, LLC's (BCS's) correctresponses to the U.S AnnyArmy Corps of Engineers' comments on the Rev 0 planning documents forthe Gambell FUDS Remedial Action project. We initially transmitted our responses to youunder our serialized letter 56001-006 dated November 11, 2005. Unfortunately, the responsesattached to letter 56001-006 were not complete. Please discard them and replce them with thoseattached to this letter.We suggest we hold a Comment resolution Conference in the near future to discuss and developa mutual understanding of the modifications we will make to the Rev 0 planning documents.Because of leave time scheduled by BCS project staff, we suggest meeting either during theweek of December 5, 2005, or after January 2, 2006. We look forward to meeting with you todiscuss our responses.If you have questions or wish to discuss our responses, please call me at (907) 743-9322.Sincerely,Bristol Construction Services, LLC>~-{;,[ji~~C;'i!i~~Steven A. Johnson, P.E.Project ManagerAttachment: Corrected BCS ResponsesA subsidiary of Bristol Bay Native Corporation200-H• FlOAK069601_07.01_0001_aF10AK069601_07.01_0001_a200-HF10AK069603_07.01_0001_aREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 1COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental ResponseWork Plan1.Sec 3.2.2/p. 12Reference to Table 4-1 should be Table 3-1AReference will changed in Work Plan.2.Sec 3.4.1/p. 12The Waste Accumulation Point is not apparent on my copyof Figure 3. If it's there, please highlight it in the final copyAFigures will be edited to clarify WasteAccumulation Point.3.Sec 3.6/p. 14Using 26 mg/Kg as the cleanup level for chromium may beimpractical with the XRF.Given the unlikelihood ofhexavalent chromium, we should reconsider this in ourreview session.AThis will be discussed during the commentreview conference.4.Sec 4.0/p. 19The Project Schedule dates need to be updatedAThe project schedule will be updated in thefinal Work Plan.Sampling and Analysis Plan1.Paragraph 3.4As stated in the scope of work: -all viable wells, minimumof 5 of the 8 known wells, are to be sampled. The SAPstates a maximum of 5 are to be sampled. This isincorrect.WCarey Cossaboom - This was changedduring negotiations. Maximum of 5, withOptions to sample up to two more.2.Paragraph 4.2.3State under what conditions, the sampler will decide toTypically, we want the wellcollect a well sample.parameters, pH, temp, DO, conductivity, etc. to stabilize.That sometimes takes more than 3 well volumes. Taking asample immediately after 3 well volumes regardless of theparameter readings may result in a poor sample that doesnot reflect contaminant levels in the aquifer.AItem 6 has been changed as follows:Page 1"Collect the following field measurementsform the groundwater (down the well) orpurge water. The well should be purgeduntil these parameters have been stabilizedso that the variance between subsequentmeasurements are no greater than thoselisted below.Temperature - OSCSpecific conductance - 3%Conductivity - 3%Salinity - 3%Dissolved oxygen - 10%pH - 0.5 unitsOxidation-reduction potential - 10mVTurbidity - 10% or 3 readings below 10NTUs."IUSACEResponseREVIEWCOMMENTSDATE:LocationItemNo.1I3.Paragraph 4.2.3PROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer ICOMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:IIReviewConferenceExplain how the purge water will be containerized. Statingthat it will be put into a bucket is insufficient as a bucket isnot an appropriate storage device for potentiallycontaminated water. Also explain how the water will bestored while you await analytical results for the water andhow it will be stored if it must be stored over the winter.AIBristol Environmental ResponseThe following text will be added to item 5:"Basedhistoricaluponknowledge,purgewater will be disposed on by spillingon-site."4.GeneralPQLs:PQLs do not meet the DoD000 QSMPQls: some of the listed PQls000 QSMrequirements. Ensure the lab will comply with DoDrequirements and is current in its NELAP accreditation forthe methods to be used.ASGS (our project laboratory), will complywith DOD QSM requirements and verify that000 QSM control limits are met.DoD5.Table 5-3Preparation method for total metals analysis in soils is3050B.ATable 5-3 has been corrected.AThe following text will be added to theWaste Management Plan:Waste Management Plan1.GeneralIf placarding will be required for any wastes, the contractormust meet DOT security requirements; 49 CFR 172.704;172.800. The new manifest with preprinted manifestnumbers will be required by September 5, 2006."DOT security requirements specified under49 CFR 172.704 -172.800 will be followed ifPreprintedplacarding is required.manifests will be used for wastes shipped5, 2006."after September 5,2006."Environmental Protection Plan1.GeneralIf removal of Marston matting will disturb more than 1 acreof land, then the NPDES permit requirements may apply.AThe following text will be added to theEnvironmental Protection Plan:"If Marston matting removal disturbs morethan 1 acre of land, requirements from theNPDES General Permit for StormwaterLarge and SmallDischarges from largeConstruction Activities will be followed."Page 2USACEI ResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 1COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReviewIBristol Environmental ResponseSite Safety and Health Plan1.Table 6-1Trail repairs and stream crossings are not applicable to theanticipated work in Gambell.AReferences to trail repairs and streamcrossings have been removed from Table6-1.2.Page 63Include phone number for the Gambell Health Clinic.AThe phone number for the Gambell HealthClinic has been added to Section 11.7.3.Figure 3Please correct typos.AAll figures will be reviewed and typoscorrected.Page 3IUSACEResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 2COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental ResponseIWork Plan1.2.p. 9, Line 11p. 16, Line 23The cleanup level of 11 mg/kg is a site-specific backgroundlevel approved by the ADEC as a cleanup level. It is not apromulgated ADEC cleanup levelAThis paragraph may be clarified by inserting text whichstates ... constructed using five foot sections of 2 inch ...AThe text has been edited to the following:"The wooden timbers were treated witharsenic resulting in soil contamination in thisarea in excess of the site-specificbackground level of 11 mglkg approved bythe Alaska Department of EnvironmentalConservation (ADEC)."The text has been edited to the following:'Then the temporary well point will beconstructed using five-foot section of twoinch inside diameter stainless steel drivescreen and black iron riser pipe."3.All figuresNo scale bars included. Should be determined for futurereference, or at least in Remedial Action Report figures.AAll figures will be reviewed and scale barsincluded where possible.4.Figure 3Please correct typos in Source text: investigationAAll figures will be reviewed and typoscorrected.5.Figure 4Please correct typos in Source text: NAlEMP, Excavation.The border depicting Site 7 is not distinguishable fromother solid black lines on the figure which indicatebuildings, other areas of concern not related to this project,etc. Site boundaries could be deleted.AAll figures will be reviewed and typoscorrected. Drawings will be reviewed toeliminate confusion.6.Figure 5Consider labeling trails as such.AThe trails will be labeled.7.Figure 6MW16 is no longer present and should not be included onthe figure.AMW16 will be removed from all drawings.Alaboratory control limits will be reviewed toconfirm that they meet DOD QSMrequirements.Sampling and Analysis Plan1.Page 4GeneralMethod QC requirements (PQls, control limits, etc.) mustmeet DoD QSM limits.USACEResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCAnON: St. Lawrence Island, AlaskaREVIEWER: Reviewer 2COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental Response2.Table 3-6 andparagraph 3.9.1You cannot mix wastes from different sites that havedifferent contaminants. Waste with arsenic contaminationcannot be mixed with the wastes that have chromium andother metal contamination. This is a RCRA requirement.Mixing soil from the two sites would be considered dilutionunder RCRA.AAgreed.mixed.3.Paragraph 4.2.3Well parameters must be stable prior to sampling, simplypulling out three well volumes may not be sufficient.AItem 6 has been changed as follows:The waste streams will not be"Collect the following field measurementsform the groundwater (down the well) orpurge water. The well should be purgeduntil these parameters have been stabilizedso that the variance between subsequentmeasurements are no greater than thoselisted below.Temperature - 0.5°CSpecific conductance - 3%Conductivity - 3%Salinity - 3%Dissolved oxygen - 10%pH - 0.5 unitsOxidation-reduction potential - 10mVTurbidity - 10% or 3 readings below 10NTUs."4.GeneralQA laboratory will be assigned by the District ChemistAThe District Chemist has assigned STL,Seattle as the QA laboratory.5.Table 5-3Preparatory method for metals analysis in soils is SW3050.ATable 5-3 has been corrected.Waste Management Plan1.Page 7, Line 13The waste accumulation point is not shown on Figure 3.AThe waste accumulation point was added toFigure 3.2.Figure 3Please correct typos.AAll figures will be reviewed and typoscorrected.Page 5USACEI ResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionS1. Lawrence Island, AlaskaLOCATION: St.REVIEWER: Reviewer 2COMMENTSIDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:I ConferenceReview IBristol Environmental ResponseIEnvironmental Protection Plan1.P. 7, lines 9-10Alaska Natives are not exempt from the Act. The Actallows Alaska Natives to take marine mammals subject tocertain restrictions.AText will be edited to clarify that AlaskaNatives are not exempt from the Act.2.P. 15, Section 4.Identifying a list of permits and laws is useless withoutdetermining which apply to the proposed action. Identifyand coordinationspecific knownpermit,legal,requirements as a starting point for contractor compliance.AAgreed. Only project-specific permits andlaws will be identified.3.P. 20, line 25.Wording related to NHPA is ambiguous. Reworks so it isclear that workers will not disturb or remove artifacts orremains from the work sites or from anywhere else whilethey are employed on the island.AText will be edited to make it clear thatworkers will not disturb or remove artifactsor remains from any site while they areemployed on the island.4.P. 21, line 1The affected sites are not on Federal land. ARPA of 1979does not apply.AText will be edited to reflect comment thatsites are not on federal land.5.GeneralThroughout the document, Gambell is referred to as thevillage of Gambell or the Village of Gambell. Gambell islisted as a second class city the State of Alaska. TheNative Village of Gambell is the village corporation thatowns surface rights to much of the lands in andsurrounding Gambell. The City includes everyone inGambell. The village corporation includes only members"tribe," and specifically excludes other Natives andof that "tribe,"races. Texts should be edited to maker it plain whether itrefers to the a group of Natives comprising part of theGambell population or the community. We generally use"community" for more general references to avoidambiguity and to avoid the appearance that we areignoring other population segments.AText will be edited to clarify whether thevillage corporation (Village of Gambell) orthe community (City of Gambell) is beingreferenced.Page 6USACEResDonseResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 3COMMENTSIDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:I ConferenceReview IBristol Environmental ResponseIWork Plan1.GeneralPlease note DEC review and concurrence on this work planis to ensure that the work is done in accordance with Stateof Alaska environmental conservation laws and regulations.While DEC may comment on other state and federal lawsand regulation, our concurrence on the plan does notrelieve responsible person from the need to comply withother applicable laws and regulations, for example theDOT&PF restriction involving work near the airstrip.AAcknowledgedSampling and Analysis Plan1.Table 3-3Ingestionllnhalation cleanup levels should apply for theentire Gambell site.ATable 3-3 has been corrected to reflectingestion & inhalation pathway cleanuplevels.2.Page 13, Line 7Clarify that five foot section of 2 inch screen and pipe will beused.AThe text has been edited to the following:"The temporary well point will beconstructed using five-foot sections of 2inch inside diameter stainless steel drivescreen and black iron riser pipe."3.Section 3.4More details should be provided regarding the anticipatedgroundwater sampling timeframes. Low/high water leveldata or pumping rates should be included from the AlaskaVillage Safe Water or other sources. Provide reasoning forproposed sampling dates.ABCS will obtain data on groundwater levelsfrom VSW and determine the appropriatesampling schedule. Our rationale for theproposed sampling times will be presentedat the Comment Resolution Conferenceand then included in the final document.4.Page 18,13Tank scrap is not anticipated in Gambell.AText has been edited to the following:"Compatibility field screening (discussed inSection 4.1.3) will be conducted to aid in theconsolidation and bulking of potentialpetroleum, oil, and lubricant-contaminatedwater, other liquids, sludges, residues,sediments, and containerized hazard andtoxic waste (Con-HTW) if discovered onPage 7USACEResponseREVIEWCOMMENTSDATE:LocationItemNo.IIPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 3COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental ResponseIsite."5.All FiguresPlease correct typosAAll figures will be reviewed and typoscorrected.6.AppendixChange sample log location to Gambell sites.ASample sites, analyses, etc. have beenchanged to those appropriate for theGambell FUDS project.7.AppendixInclude laboratory sheets for SGSAPlease note that CT&E and SGS are thefonns havesame company, however SGS formsbeen included in the Appendix.The correct phone number for the USACE Archaeologist,Ms. Margan Grover, is 753-5670.AThe text has been changed to:Please correct typos.AEnvironmental Protection Plan1.2.Page 8Page 21, Line 8Figure 3"The OARQAR will notify Ms. Margan Grover,the USACE Archaeologist at (907 753-5670and will forward the photographs and notesto her. Ms. Grover will consult with thePreservationOfficeStateHistoricalregarding findings."All figures will be reviewed and typoscorrected.USACEResponseREVIEWCOMMENTSDATE:LocationItemNo.TIPROJECT: Gambell FUDS Remedial ActionSt. Lawrence Island, AlaskaLOCATION: S1.REVIEWER: Reviewer 4COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:IIConferenceReview IBristol Environmental ResponseWork Plan1.Paragraph 3.8As stated in the scope of work: all viable wells, minimum of 5of the 8 known wells, are to be sampled.WCarey Cossaboom - This was changedduring negotiations. Maximum of 5, withOptions to sample up to two more.Sampling and Analysis Plan1.Sec. 3.1I think some additional detail is needed to make sure we'vethought through the best way to remove the As-contaminatedsoil. For starters, the surveyed corners should be locatedand squared to approximate the actual slab location. Next,the top 8" of soil (gravel) should be scraped away to removethe backfill. Excavate a 2-3 foot wide swath along thecenterline of the framing timbers which should have lines theBias theoutside edges of the former concrete pad.excavation towards ay stained or timber-remnant soils. Biasexcavation to corners where high As soils were collected.Hand tools may not cut it.ABCS agrees that additional detail isappropriate and wishes to discuss thistheCommentResolutionduringConference.2.Sec. 3-2Four-six inches may not be deep enough. I would think thatwe might concentrate the dig upon one or two "hot spots"and dig down a foot or two. Hand tools may not cut it.APer the SAP, 4-6 inches will be excavatedand the site field screened for furthercontamination. However, we would like toduringCommentdiscussthistheResolution Conference.3.Pg. 16, Table 3-7Parameter (sp.)ATable 3-7 will be reviewed and typoscorrected.Page 9IUSACEResponseREVIEWCOMMENTSDATE:LocationItemNo.I4.I 4.2.3, number 5PROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 4COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:IYou should not be sampling until these parameters havestabilized such that variance from previous well volume is notgreater than as follows:IConferenceReview IAI Sec. 4.2.3What will you do if the well purges dry?Item 6 has been changed as follows:"Collect the following field measurementsform the groundwater (down the well) orpurge water. The well should be purgeduntil these parameters have been stabilizedso that the variance between subsequentmeasurements are no greater than thoselisted below.Temperature - 0.5°CSpecific conductance - 3%Conductivity - 3%Salinity - 3%Dissolved oxygen - 10%pH - 0.5 unitsOxidation-reduction potential - 10mVTurbidity - 10% or 3 readings below 10NTUs."Temp. -.1 degree CCondo -3%0.0.-10%pH-0.1 unitORP -10 mVTurb. -10%, or 3 readings below 10 NTUsIf parameters don't stabilize after an hour of purging, well canbe sampled.5.Bristol Environmental ResponseAAAn additional item (item 6) has been addedstating:"If the well purges dry, this will be assumedto be one well volume. The well will beallowed to recover and be purged again fora total of 3 well volumes or purged dry atotal of 3 times."Page 10USACEI ResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: S1. Lawrence Island, AlaskaREVIEWER: Reviewer 5COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental ResponseIWork Plan1.Sec. 3.2.2Subs are in Table 3-1AReference to the subcontractor list will becorrected.2.Sec. 3.3Supply additional detail to demonstrate that a sufficient effortwith be made to consolidate existing survey information andsite basemaps to create a fully geo-referenced, ESRIArcGIS 9ArcView 9.x) compatible basemap with applicablelayers for the Gambell site per the SOw. This task requiresa definite plan to assure proper location of specific featuresat Site 7 and 12.ABCS's GIS specialist will attend theCommentResolutionConference toparticipate in this discussion. The results ofthis discussion will be presented on a tsakby-task basis in the final plans.3.Sec. 3.4.1Update accordinglyASection 3.4.1 will be updated to reflect thatequipment will not be shipped from NECape.4.Sec. 3.4.1, p 12,line 25Where on Figure 3 is the WAP?AFigures will be edited to clarify WasteAccumulation Point.5.Sec. 3.4.1,13, line 11Where on Figure 3 is the barge loading area?AFigures will be edited to clarify bargeloading area.6.Sec. 3.4.1, pg 13,line 6Update accordinglyAReference to Table 3-2 will be corrected.'7.Sec. 3.5, pg. 14,line 6 & 7"shown on Figure 4 as the Former Concrete Slab."AText for Sec. 3.5 has been edited to:Sec 3.5I think some additional detail is needed to make sure we'vethought through the best way to remove the Ascontaminated soil. For starters, the surveyed corners shouldbe located and squared to approximate the actual slablocation. Next, the top 8" of soil (gravel) should be scrapedaway to remove the backfill. Excavate a 2-3 foot wide swathalonQ the centerline of the framing timbers which should8.Page 11pg."BCS will excavate up to four tons ofarsenic-contaminated soil at Site 7 in thearea shown on Figure 4 as the FormerConcrete Slab."ABEESC agrees that additional detail isappropriate and wishes to discuss thisduring the comment resolution conference.USACEResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 5COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental Responsehave lined the outside edges of the former concrete pad.Bias the excavation towards any stained or timber-remnantsoils. Bias excavation to comers where high As soils werecollected. Hand tools may not cut it.9.Sec. 3.6, pg. 14,line 20Figure 5 does not show the historical sampling points.AThe historical sampling points will beadded to Figure 5.10.Sec. 3.6Four-six inches may not be deep enough. I would think thatwe might concentrate the dig upon one or two "hot spots"and dig down a foot or two. Hand tools may not cut it.APer the SAP, 4-6 inches will be excavatedand the site field screened for furthercontamination. However, we would like todiscuss this during the comment resolutionconference.11.Sec. 3.8Please include that all eight wells will be fitted with newlocking caps or new locks for the protective casing. Refer tophoto log from August 2005 (USACE) to assess lockrequirements.AThe following text has been added to Sec.3.8:ABCS will obtain data on groundwater levelsfrom VSW and determine the appropriatesampling schedule.A rational for theproposed sampling times will be included inthe final document.ASec. 3.9 has been corrected.12.Sec. 3.8, line 13Based on discussion with Village Safewater, the seasonallow water period is in the ApriVMay timeframe. I am seekingactual information from the Native Village of Gambell. Thisperiod would be important to sample as the TAPP advisorhas suggest the groundwater gradient could be overcome bypumping demands, thereby drawing contaminates from thevillage proper. I would think this would be doable. Then oneround mid summer.13.Sec. 3.9, line 231st word = The (Then.)st"All wells will be fitted with locking caps ornew locks for the protective casing."Sampling and Analysis Plan1.2.Page 12Sec. 2.5/p. 4Sec. 2.6.2/p. 5The SAP should explicitly state here that the environmentalsamplers will be on the ADEC Qualified Persons list, inaccordance with the SOW and regulations.It should be stated that the analytical laboratory will not sub-USACEResDonseI ResponseThe following text has been added to Sec.2.5:"In accordance with the SOW, allenvironmental samplers will be on theADEC Qualified Persons list."The following text has been added to Sec.REVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: St. Lawrence Island, AlaskaREVIEWER: Reviewer 5COMMENTSIDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:I ConferenceReview Icontract any work without the approval of the USACE projectchemist.Page 13Bristol Environmental ResponseI2.6.2:uSGS will not subcontract any work withoutthe approval of the USACE projectchemist."USACEResponseREVIEWCOMMENTSDATE:LocationItemNo.IPROJECT: Gambell FUDS Remedial ActionLOCATION: S1. Lawrence Island, AlaskaREVIEWER: Reviewer 6COMMENTSDOCUMENT: Groundwater Sampling for Gambell FUDS Remedial ActionPHONE:II ConferenceReview IBristol Environmental ResponseIIWork Plan1.Page 15Insure that here or in the safety plan that there is anindividual identified with responsibility for NOTAM notificationto FAA and a contact number at FAAAThe individual responsible for filing theNOTAM and the FAA contact name andnumber will be added to the WP and theSAP.2.GeneralSee general comment about "village" in the EnvironmentalProtection Plan comments.AText will be edited to clarify whether thevillage corporation (Village of Gambell) orthe community (City of Gambell) is beingreferenced.AText has been added to sections 3.1, 3.2,3.3, and 3.4 saying the following:Sampling and Analysis Plan1.Sections 3.3-3.6Reference Table 3.5, which specifies the analytes to betested."The number of samples and parametersare specified in Table 3-5. "2.Section 3.9.1If a single sample is used to characterize a soil waste streamit should be composited from several discrete locations.ASection 3.9 will be modified to includecomposite sampling of the soil wastestreams.3.Section 3.9.2If there is no odor or sheen associated with the purge water,please discharge to the ground surface at Site 5. The site ishistorically clean with the exception of one sample that wasat the Table C cleanup level. If a granulated carbon filter isavailable the purge water can be run through that just to beconservative.AThe following text will be added to item 5:Please note I don't need to see the instrument users manualif you want to decrease the size of the documents.A4.Page 14Appendix Buponhistoricalknowledge,"Basedpurgewater will be disposed on by spillingon-site."Agreed. User's manuals will be deletedfrom the SAP.USACEResponse