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EPA Comments on the <br /> "Draft DDJC-Sharpe/Tracy Comprehensive Field Work Plan" <br /> Version 3.0, Volumes 1 and 2 <br /> GENERAL CObMNTS ON VOLUME 1 (FIELD SAMPLING PLAN) <br /> 1. In general, the Draft DDJC-Sharpe/Tracy Comprehensive Field Work Plan <br /> (FWP) is a thorough and well-written presentation of general <br /> requirements for field work. DLA intends the document to be general in <br /> nature and intends to supplement it with project-specific work plans as <br /> needed for specific projects. To make it clear to field personnel that <br /> the FWP is not a stand-alone document that can be used to make design <br /> decisions, please clarify that the field staff will not make design <br /> decisions, e.g. , selecting the location and number of piezometers to be <br /> installed, which wells to select for pumping tests, and which wells to <br /> select for bioventing tests, in the field. The rationale and detail <br /> (e.g., how many piezometers to install and where, where the screened <br /> interval will be located) for these activities should be documented in <br /> site-specific or action-specific work plans. <br /> 2. The FWP states that it is intended as general guidance on all field <br /> projects at DDJC-Sharpe and DDJC-Tracy; however, the FWP includes <br /> sections that appear to reference specific sites. For example, Section <br /> 7.3.5.2 states that the bioventing test system will be located on the <br /> existing concrete pad. It is not clear to what existing concrete pad <br /> the text is referring. In addition, Section 8.2.1 states that <br /> agricultural wells will be prepared for abandonment after geophysical <br /> logging and groundwater sampling. Agricultural wells are not discussed <br /> in the FWP, and it is not clear why agricultural wells are designated <br /> for abandonment. For clarity, please provide a description of the <br /> concrete pad and the agricultural wells. Alternatively, since the FWP <br /> is intended as a general guidance document, please remove references to <br /> specific sites or wells. <br /> SPECIFIC COMMENTS ON VOLUME 1 <br /> 1. Section 1.1 Document outline, Page 1-1: Paragraph 1. 1.2 states that the <br /> FWP will be used as a general guidance on all field projects at DDJC- <br /> Sharpe and DDJC-Tracy and that specific details related to sampling, <br /> analysis, and health and safety will be provided in project or site- <br /> specific work plans. However, since the FWP does not include <br /> information about well numbers or locations, numbers and locations of <br /> samples, groundwater monitoring and soil vapor extraction well design <br /> (e.g. , screen intervals) , and aquifer test design; please revise this <br /> section to clarify that project- and site-specific work plans will <br /> include this information as well. <br /> 1 <br />