From: Thomas Price <This email address is being protected from spambots. You need JavaScript enabled to view it.> at 1:54 PM 2/20/2017
Re: Subject: Proposed Plan of Remedial Action for the Former Avon Products Site located at 2100 Ogleton Road, Newark dated January 17, 2017
Stephanie Gordon (in care of Ms. Stacy Jones), Project Officer
Timothy Ratsep, Administrator, Site Investigation and Restoration Section
Department of Natural Resources and Environmental Control
State of Delaware
391 Lukens Drive
New Castle, Delaware 19720
Dear Ms. Gordon and Mr. Ratsep:
Electronic Review for the Environment, Inc. has reviewed the document and has the following comments:
1) I had difficulty delivering comments since no email was provided with the Public Notice. Also, since the period ended on a holiday, I was unable to post a letter via the postal service by the last day of the comment period due date of February 20. So I have sent this to Stephanie Gordon in care of Ms. Stacy.Jones at the email address of This email address is being protected from spambots. You need JavaScript enabled to view it. which was the only email address I could find on a listing of comment periods (on an electronic newsletter) for your organization. I would like to request that for future public comment periods by the Department of Natural Resources and Environmental Control (DNREC), that you include your email addresses so that providing comments is more convenient.
2) Page 3 – At the bottom of the page the descriptions of the contaminants are inconsistent. For example the detections of beno(a)pyrene at OU-1 above screening levels indicates that it is a contaminant of concern (COC). However the next sentence stated that it was not; perhaps it should be changed to indicate the risk assessment demonstrated that the concentrations were below levels of concern (based on averaging or future planned usage, I wasn’t sure). Similarly the wording descriptions of contaminants at OU-2 appears to need the same type of clarification.
3) Page 4 paragraph 2 –
a. The discussion indicates that contaminants may leach to groundwater as not being a concern because there are no complete exposure pathways. Isn’t there a local anti-degradation policy for groundwater which would prohibit degradation of the groundwater resources?
b. The paragraph discussed that the levels of contaminants would not be a concern for ecological receptors if it migrated to the creek; since some ecological screening criteria are more stringent that human health screening levels, this statement appears to be potentially inaccurate. Have the groundwater contaminant concentrations been compared to ecological screening criteria?
4) I attempted to view additional site documents by going to the navigation system of databases however under the Avon site, no documents came up; I was unsure if the documents were really available for viewing or if the problem was on my end. Please let me know if the documents are really available for viewing on the link you provided.
5) I would like to request an extension of the public comment period so that I may view additional site documents which I was unable to view on the link provided. And please address the comments above in a revised document.
Sincerely yours,
ELECTRONIC REVIEW FOR THE ENVIRONMENT, INC.
By: Tom Price, Director
P.O. Box 2756
Berkeley, CA 94702