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1997 Annual Report 5 - 10 February 1998 Sharpe Facility 8) The Annual Report acknowledges the North and South Balloon discharge exceeded the NPDES pH discharge limits and the Central Area discharge also exceeded the pH discharge limits. These excursions are violations of Sharpe's permit. In 1996 Sharpe conducted a Scale Study to address extraction and treatment system scale problems. This study recommended adding pH control to the outlet of the air stripping towers for each of the three plants to control scale formation. To date, Sharpe has not implemented the recommendation from the Scale Study Report. The revised Annual Report must provide specific actions, with a time schedule for implementation, to achieve compliance. 9) Current designations of the monitoring well aquifer zones are incorrect and may lead to inaccurate interpretations of contaminant movement. It appears appropriate to re-designate wells for more accurate interpretation of future data. For example MW521C does not actually extend into the C zone sand nor does MW445C as seen in cross section B and D (Figures 2.5-3 and 2.5- 5). A footnote could indicate the previous designation for correlation of past data. 10) Page 3-2 in Section 3.2.8, the statement"MW 421C is located at the downgradient edge of the C zone" is incorrect. This well is at the upgradient edge of the C zone. 11) Page 4-4, Section 4.2.2.6 States that"Surface scrape soil samples collected in the North Balloon in February 1997 did not indicate any results greater than the action levels specified in the OU 2 ROD for lead and chromium". This statement is incorrect and should be modified. 12) In the 1Q97, 209 results of VOC analysis by SW8020 were rejected by Radian based on the lack of QA for the data, and in 3Q97, 239 sample results were rejected. Samples collected during all four quarters for total petroleum hydrocarbons contained a contaminant in the blank resulting in 27 sample results as being qualified as non-detect. Finally, forty results in the 3Q97 analyzed for pesticides/PCBs by Method SW8081 were qualified, and therefore are less reliable because the samples were analyzed at the incorrect dilution factor. These seem to be excessively poor QA/QC results. What actions is Sharpe taking to improve data collection to avoid these problems in the future? 13) Concentrations of diesel are noted in MW 421A and MW470A in both 1996 and 1997 Annual Reports. These impacts were caused by underground storage tanks and a response action has been described in the UST Program Work Plan, submitted October 6, 1997. These actions should be referenced in the Annual Report in response to the diesel degradation. Page 5-5, Section 5.4.2.4 notes that petroleum hydrocarbons are also detected in the Central Area effluent. Is there a correlation with the petroleum contamination found in the groundwater at MW 421A and MW470A noted above? 14) The last two sentences in Section ES 1.14 contradict each other. Please clarify and correct. 15) The following comments pertain specifically to the Proposed Groundwater Monitoring Plan.