indicate that the analytical data will be validated in accordance with EPA Region III, Innovative Approaches to Data Validation (June 1995). This document contains several

validation levels which were designed to be appropriate for various data uses. Therefore, the

plan should specify the validation level for organics and inorganics appropriate for this project. We request that data of this type be validated at a minimum level of M-2 for organics and IM- 1 for inorganics.

Response:

The following sentence will be added to the end of the first paragraph in Section VII to reference

the requested validation levels:

“Organic compounds will be validated at level M-2 and inorganic compounds at level TM-i.”Comment 2:

Dioxin/Furan analysis -Table 4, Analytical Methods, Sample Containers, and Preservation

Requirements, lists SW-846 Method 8280A as the analytical method to be used for the analysis of dioxins and furans. We request that the more sensitive SW-846 Method 8290 or EPA Office

of Water Method 1613 be used, since the data from this analysis will be used in a risk

assessment.

Response:

The analytical method listed for dioxins and furans on both Table 4 and Table 10 will be

changed to the more sensitive SW-846 Method 8290 as requested.Comment 3:

TCLP analysis -On page lofthe S/A Plan, in the next to last paragraph, the plan states, “Note that organics that are not detected in the total analyses do not need to be analyzed in the TCLP

and multiple pH extracts.”

We request that the organic constituents listed under 40 CFR §261.24 be analyzed in the TCLP

leachate, even ifthey are not detected above the reporting limit in the total analysis. In the EPA Delisting Program Guidance Manualfor the Petitioner, March 23, 2000, Exhibit 2 (Analyses for Constituents of Concern and Hazardous Waste Characteristics), the next to last bullet in this

table includes total constituent and TCLP analyses for the organic constituents listed under 40

CFR §261.24.
the paragraph in question are shown below in bold font:

“The TCLP extractions and the multiple pH extractions will be analyzed for all

constituents, except total sulfide, total oil and grease, and the Resource Conservation and

Recovery Act (RCRA) characteristics of ignitability and corrosivity. Note that the

extracts will not be analyzed for pesticides and herbicides, which are excluded based

on waste process knowledge. Also note that organics that are not detected in the total

analyses, except those listed under 40 CFR §261.24, do not need to be analyzed in the

TCLP and multiple pH extracts. In Phase 1, however, organics listed under 40 §CFR

261.24 (except pesticides and herbicides) will be analyzed in the TCLP and multiple

pH extractions, even if they are not detected in the total analyses.”

Other Changes to the Text and Tables

During the process ofrevising the Sampling and Analysis Plan (SAP) and preparing for

the upcoming sampling event, additional changes were made to the plan to clarify

ambiguities or correct minor inconsistencies in the draft version ofthe plan. These

changes are noted below:

I. The FEP sludge is a two-phase material and the SAP did not specify whether the

samples would be treated as a solid or liquid matrix for sample preparation and analysis.While this question is not at issue for the TCLP or multiple p1- extraction tests, there is

ambiguity concerning the preparation ofsamples for analysis of total chemical

concentration. In order to clarify this point, the text on page 1 and footnotes on Tables 1

and 4 have been modified to indicate that the samples for total concentration analysis will

be prepared and analyzed as a solid matrix. This selection was made as a practical

matter, as the large sample volumes necessary to prepare and analyze the samples as a

liquid matrix would make it impractical to complete the Phase I field event using the

proposed sampling technique, given the wide range of chemical constituents selected for

analysis. Accordingly, the detection limits listed in the “Solid” column of Tables 5, 7, 8,

9 and 10 will apply to the analyses for total chemical concentration.

2. The SAP identified two alternate extraction solutions for the multiple pH extraction

tests. In order to remove any ambiguity about the exact pH ofthe second extract fluid,

the alkaline solution of sodium hydroxide between pH 10 and 12 has been replaced with

a sodium bicarbonate and sodium carbonate solution with a pH of 10. The sodium

bicarbonate/carbonate solution is identified in current EPA delisting guidance as an
Tables 1 and 4 to remedy this inconsistency.

4. Page 2 of the text stated that “Each pond will be divided into four approximately equal

surface areas, and the center of each area will be sampled.” Based on earlier in-situ

measurements of the FEP sludge depths in 1993, it is clear that there are areas within

both ponds where the sludge layer is so shallow that sampling those areas would not be

productive. Therefore, the text in this section has been modified to state that (changes inbold font) “Each pond will be divided into four approximately equal surface areas, and

the approximate center of each area will be sampled. Sample locations somewhat off

the center of a subsection may be selected to improve the efficiency of samplecollection by avoiding areas where the sludge is less than 2 feet deep.”

5. The units for detection limits and reporting limits for metals on Table 5 were

incorrectly listed as ig/L for water or TCLP extracts and jig/kg for solids. The units arecorrectly listed on the revised table as mg/L for water or TCLP extracts and mg/kg for

solids.