Econo Energy Consultants, Inc.

2138 Harmony Lakes Circle

Lithonia, Ga.30058

August 8, 2005

Ms. Pamela Scully

United States EPA Projects Manager

61 Forsythe Street, SW

Atlanta, Georgia 30303

Re: OU-3 Field Sampling Plan

Dear Ms. Scully:

Please find enclosed the review comments from Econo Energy Consultants, Inc. (EEC) on the above referenced document under the Consent Decree (CD) Technical Advisor Grant (TAG).

EEC’s review comments are organized with the General Comments presented first. The General Comments discuss the overall adequacy of the document, noting any extension repetition and deficiencies that reoccur throughout the review document.

The Specific Comments, on the other hand, follows the General Comments and discuss specific deficiencies in the order of appearance in the reviewed document.

If you have any question on EEC’s review, please contact Mr. Bertrand Thomas at (256-237-8748)

Sincerely,

Econo Energy Consultants, Inc.

Bertrand Thomas, PG

Principal

GENERAL COMMENTS:

  1. The text in the OU-3 document states that the Plant Facility was designated as OU-3 , however, there is no discussion for sampling the Plant Storm Water Drainage System in the work plan. If this document is the RI for OU-3, which includes the investigation of all pathways, there should be a section in this document on the investigation of the Storm Water Drainage System for OU-3 or, the test should give a reason as to why the Storm Water Drainage System was not a part of this investigation.

2. We recommend as a QA/QC measure, to send some duplicate samples to a separate laboratory for analysis then comparing the results to those of the mentioned laboratory for consistency and accuracy purposes.

OU-3 Field Sampling Plan Comments

  1. Section 2.5.2.1. Page 11 First Paragraph.

There is no mention of who will be responsible for logging of visitors.

  1. Section 2.5.3 Page 14 Last paragraph

States that data files will be stored for a minimum of 10 years. What is the exact or approximate length of time the data will be stored since data for a project of this magnitude could be needed 20 or more years later.

  1. Section 3.1 page 16 3rd paragraph.

There is no reference to any air monitoring data or explanation of the air monitoring program. How was the conclusion that there is no additional air monitoring data needed and that the facility is not a discrete source of PCBs reached?

  1. Section 3.1.2.1 Page 20 1st paragraph

How effective is the OLSBI recovery system. Is there any monitoring being done to assess the effectiveness of the recovery system?

  1. Section 3.2.2.1 Page 27 1st paragraph

States that, “Groundwater from the two temporary wells will be analyzed for cobalt, PCBs, parathion and PNP”. Why not all the COPCs.?

6.Section 3.2.1 Page 25

States that the PCB (log) vs Z-score is a more accurate representation of a normal distribution graph.

Concern: This graph is linear and does not depict a normal distribution.