Final Remedial Action Completion Report for the ... - Rvaap.org

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Cmt.# A-1 PRELIMINARY DRAFT INTERIM ACTION COMPLETION REPORT FOR THE REMEDIATION OF SOILS (RVAAP 08-11) AT THE RAVENNA ARMY AMMUNITION PLANT, RAVENNA, OHIO COMMENT RESPONSE TABLE APRIL 18, 2008 Page # Line # Section 3.5.4, Pg 3-11 A-2 Section 2.0, Pg 2-1 New Page or Sheet Added sections 3.5.4.1 – 3.5.4.3 (Pgs 3-14 to 3-17) Pg 2-1 to 2-2, added Section 2.1.1 for RAOs Comment Field screening results were not provided. What were the COCs and the associated clean-up goals? Recommendation USACE (Kathy Krantz, Rec’d 27 Mar 2008) Shaw Environmental, Inc. 1 of 39 The screening results and the establishment of a correlation with confirmatory samples should be provided in an Appendix. Response Shaw will revise the first sentence in Section 3.5.4 to state the following: “On-site field screening was performed for metals, PCBs and the explosives TNT and RDX prior to collecting the multi-increment samples for off-site confirmatory analysis. In general, the results of the field screen analyses for metals and explosives compared well with the confirmatory laboratory results with the exception of…..”. Shaw will revise Section 3.5.4 to include further discussion of the correlation between field screen and laboratory results for PCBs, explosives and metals. Since metals represented the majority of the COCs at LLs 1-4, a table showing the XRF correlation results for the pre-construction samples will be added to this section. Shaw will provide the text for review prior to issue of the Draft report. Include in section. Section 2.1.1 will be inserted into Section 2.0 and will state the following: “Clean-up goals are the maximum allowable concentrations which are protective of human health and the environment. Cleanup goals for surface and subsurface soils and dry sediment at LLs 1-4
Cmt.# A-3 Page # Line # Section 3.6.1, Pg 3-12 New Page or Sheet Pg 3-17, Section 3.6.1, Line 18- 20 Comment The intent of multi-incremental sampling is to send in the entire sample collected. Was sending a maximum of 1 kilogram specified in the Work Plan and how often was it necessary to reduce the size of the MI sample? Shaw Environmental, Inc. 2 of 39 Recommendation Response were determined based on risk-based and site-specific considerations, including background concentrations, duration of reasonable maximum human exposures, and reasonably anticipated future land use (National Guard mounted training, no digging). Attainment of the RAO addressed potential risks to human and ecological receptors identified in the risk assessment through removal of surface and subsurface soil and dry sediment with concentrations of COCs exceeding clean-up goals (Shaw 2007a). The clean-up goals implemented for the remediation of soils and dry sediment at LLs 1-4 as presented in the Interim ROD are included in Table 2-1.” Table 2-1 will include a list of the COCs and associated cleanup goals. Clarify. The original intent in the Work Plan was to submit the entire multiincremental sample to the laboratory for processing; however, discussions with Test America during the procurement process indicated that typically only 1 kg of soil is sent for processing including samples submitted in the past by USACE. After collecting the required sample volume and homogenizing it in the field, Shaw reduced the size of the MI sample as best possible so that approximately only 1 kg of soil was collected for each MI area. Shaw will include a sentence at the end of the 1 st paragraph in section
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