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1 <br /> Messrs. Shareghi and Teed-Bose - 2 - 21 July 2008 <br /> or where it would be stored, if it would be exposed to stormwater, if it would be stored <br /> in containers or on bare ground, or if any measures would be implemented to protect <br /> groundwater quality. Considering the O&M Manual anticipates only 2.5 cubic yards of <br /> sludge will be generated per day, it is likely the reservoir sludge will overwhelm any <br /> storage facility provided for such a small sludge generation rate. Please describe how <br /> and where the reservoir sludge will be stored, how it will be protected from stormwater <br /> (direct fall and stormwater surface flow), when it will be removed, and where it will be <br /> disposed. <br /> 5. Section 4.1 states soil samples collected in Reclamation Area 1 may be used as <br /> background to compare with samples collected from beneath the wastewater pond <br /> liners. Use of soil samples in areas where wastewater has already been applied may <br /> not be an appropriate method of evaluation. Please describe why that procedure <br /> would provide representative background samples. Furthermore, the workplan lacks a <br /> description of a method to evaluate the data that will be collected. How will the data be <br /> used? <br /> 6. Within Reclamation Area 1, the soil sample locations presented on Figure 3 show three <br /> sample locations close to the Old River levee. That may be an area of groundwater <br /> discharge (through evaporation) which could result in more saline soil conditions. You <br /> may want to reconsider those sampling locations or add more locations farther away <br /> from Old River. <br /> 7. Section 4.2.1 describes submittal of an Effluent Storage Reservoir Closure Plan that <br /> will be submitted in the future. Please submit that plan with the amended workplan. <br /> 8. Section 4.2.2 discusses removal of the free liquids in the wastewater ponds and states, <br /> "Reservoir 2 and Reservoir 1 B contain stormwater that is not in contact with significant <br /> amounts of residual sludge." Please note that stormwater that falls on wastewater <br /> sludge must be handled consistent with requirements for wastewater. In addition, the <br /> statement about sludge in Reservoir 2 is not consistent with several references in the <br /> workplan that indicate Reservoir 2 was never used to store wastewater (Sections 2.2 <br /> and 2.3). Please clarify the references. <br /> 9. Section 4.2.3 states solids in Reservoir 1 B will be added to the fill materials to be used <br /> in grading the site. Because wastewater was historically discharged to Reservoir 1 B, <br /> solids from that reservoir shall be handled and disposed of as sludge. Use of the <br /> material for fill when the future development of the area is not determined is <br /> inappropriate due to potential for pathogens to be present in the material. <br /> 10. Please remove qualifying remarks about sampling from the Fieldwork and Laboratory <br /> Analysis section of the report. In Section 4.3.2, rather than state "Condor will collect up <br /> to 12 samples..." clearly state how many samples will be collected. In addition, Figure <br /> 3, which presents the soil sampling locations, includes sample locations in Reclamation <br /> Areas 2 and 3. Section 2.3 of the workplan states wastewater was never applied to <br /> Reclamation Areas 2 or 3 and therefore, no samples would be collected there. Please <br /> remove ambiguous information presented in the workplan. <br /> 11. Section 4.3.2 states sludge analytical results will be used to determine the "potential to <br /> contaminate underlying soil." Will the data be evaluated and changes to the underlying <br /> W\SICff\Ounen1SB JonquinVounmin Nou \Shvcghi I I July 09 doc <br />