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1997 Annual Report - 2 - 10 February 1998 <br /> Sharpe Facility <br /> model should be referenced and briefly described in the Annual Report with respect to future <br /> actions to achieve full capture. <br /> b. Groundwater mounding caused by discharges to the percolation ponds continues to aggravate <br /> problems with the hydraulic capture in the Central and North Balloon Areas. A Comprehensive <br /> Water Management Plan has been discussed during Remedial Project Managers meetings and <br /> with the compliance section of the facility during meetings to discuss revisions to the <br /> wastewater/stormwater permit. This effort should also be described in the Annual Report, <br /> including how DDJC Sharpe will meet the goal of eliminating discharges to the percolation pond <br /> to remedy the mounding and spreading of the TCE plume to the west, away from the extraction <br /> wells. <br /> c. Discharges of treated groundwater from the North Balloon, Central Area and South Balloon <br /> all exceeded the discharge requirements for pH. A scale study initiated in 1996 recommended <br /> pH adjustment by CO2 injection to address the pH noncompliance. Improvements to address pH <br /> control(as recommended in the Scaling Study) of the treatment systems, including an <br /> implementation schedule, need to be specified in the Annual Report. <br /> 2. 01 J-2 Record of Decision- requires removal and disposal of soils containing elevated levels of <br /> lead and chromium, zone remediation of VOC contaminated soils by vacuum extraction, and <br /> evaluation of the impact or threat of impact to groundwater from residual lead and chromium in <br /> the vadose. <br /> a. The 100%Design document for excavation of lead and chromium contaminated soils was <br /> approved in August 1997. Since that time the regulators have asked for an implementation time <br /> schedule and Sharpe has not responded to that request. The schedule for completing this work <br /> should be included in a revised Annual Report. <br /> b. Likewise, the 100% Design document for soil vapor extraction systems was finalized in <br /> September 1997. Since that time the regulators have asked for an implementation time schedule <br /> and Sharpe has not responded to that request. The schedule for completing this work should be <br /> included in a revised Annual Report. <br /> c. The Post-ROD Site Investigations, extensively discussed during the 2 December 1997 Project <br /> Managers Meeting, is investigating sources of metals contamination in the South Balloon. <br /> Investigation activities to better define the nature and extent of metals contamination in the <br /> South Balloon will be carried out this year. These activities should be referenced in the Annual <br /> Report to address the increasing chromium concentrations found in the groundwater. <br /> 3). Our comment letters on the 1994, 1995 and 1996 Annual Reports, have all outlined the same <br /> problems particularly with respect to plume capture and the lack of recommendations regarding <br /> how to improve extraction system performance . In the past Sharpe has not revised the Annual <br /> Reports but has responded to Regional Board in the form of response to comments. Sharpe's <br /> activities have been inadequate to address Board's concerns resulting in continuing migration of <br />