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,e <br /> From:Tuan A.Bacigalupi To: o ert Whritenour Date:219196 Time:09:39:41 <br /> Page 4 of 9 <br /> system, should be accurate to within 1 percent. If one meter reads high by 1 percent, and one reads <br /> low by 1 percent,then a total of 2 percent of the flow could go unnoticed. This variability is <br /> unacceptable. If an undetected leak in the CS-1 0 plume occurs,the leak could result in more than <br /> 140,000 gallons of contaminated water per day being dumped into the ground fairly close to the <br /> surface. Until a massive puddle fon-ns,no one may know about the leak. By then, a new plume may <br /> have developed. <br /> III. Hot Spots <br /> The Plume Response Plan, developed by the Plume Action Team,said that hot spot <br /> remediation was critical for the acceptance of the plan and for the lowering of substantial pollutants <br /> within the flow stream.'In the massive documents provided by the 6o percent design phase,hots of <br /> . . F �P P <br /> remediation or treatment is totally absent. <br /> a. Recognizing that the final remedial action under CERCLA may be the same as the <br /> interim containment action now being implemented,we request that the National Guard <br /> Bureau and regulators reaffurm the importance of identifying,delineating and treating <br /> ""hot spots" (areas of high contamination)as outlined in the Plume Response Plan. Hot span <br /> treatment at the time of plume containment will make eventual plume and groundwater <br /> remediation easier and more effective. <br /> b. Given no evidence that the contaminants in the"old"CS-1 0 hot spot are degrading <br /> significantly by themselves, we cannot accept the argument that the high contamination has <br /> simply disappeared. we request that the Installation Restoration Program direct the drilling <br /> of more test wells and direct the resampling of existing wells to find and sharply define the <br /> hot spot,which has likely moved downstream from its fust point of discovery. <br /> c. we request that the Installation Restoration Program direct the drilling of more test <br /> wells to find and delineate the new area of high contamination discovered near Ashumet <br /> Pond and the high-contamination areas of FS-12. <br /> The team feels that whenever QPTECH or the National Guard Bureau identifies a hot spot, <br /> they should insert extraction wells into the core of the pollution and that they should treat water as <br /> soon as possible. After all the work and expense that went into the Plume Response Plan,we should <br /> not ignore its recommendations and the National Guard Bureau should proceed with mitigation of the <br /> hot spots within the plumes. <br /> IV., Groundwater Modeling. <br /> Although the groundwater model used to predict draw downs used only average conditions, <br /> the predicted average groundwater draw downs and mounding raised concerns about potential- <br /> impacts. <br /> otentialimpacts. Of even greater concern was the statement, in the discussion section(page 5-1)of the ` <br /> groundwater modeling report,that"As recharge is not consistent throughout the year, draw down and <br /> mounding in excess of the predicted values will occur." Any groundwater model used to design the <br /> plume containment system must take into the account the natural seasonal rhythm and the lona term <br /> 3 <br />