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Mr. Abel W. Haines <br /> Page 2 <br /> August 21, 1989 <br /> 4) Industrial Waste/Stormwater Sewers - The Department is <br /> concerned about the adequacy of the proposed investigation of the <br /> industrial/stormwater sewer. A rationale should be provided on <br /> how the 1110 worst leaks" will be selected. Specific guidance <br /> should be provided on the selection criteria. Due to the <br /> possiblity of detecting an excessive number of leaks in the <br /> industrial/stormwater sewer, the Department is concerned that the <br /> proposed effort will be insufficient to adequately characterize <br /> the sewer system. <br /> 5) Air Monitoring - The objectives of the air monioring <br /> program should be clearly defined in the Sample Plan. <br /> Additionally, the Sample Plan should explain why the 14 volatile <br /> organic compounds (VOCs) that will be monitored were selected. <br /> The AAL and Human Health-based Risk concentrations, that, were <br /> previously provided to USATHAMA staff, are not promu gated <br /> regulatory standards and, therefore, are not enforceable by law. <br /> They are, however, guidelines that should be used in evaluating <br /> the risk to the public health and welfare and the environme t. <br /> 6) Schedule and Project Management - A schedule for the <br /> implementation and completion of the Sample Plan should be <br /> included in the revised document. Additionally, a Section hould <br /> be included to delineate the responsibilities of Sharpe Army <br /> Depot, USATHAMA, and Hunter/ESE. This Project Management section <br /> should also identify the key persons and their responsibilities. <br /> The Department's comments contained within this letter a d the <br /> enclosed memo are to be addressed in the revised Sampling Plan, <br /> which is to be submitted within 60 days of the date f the <br /> agencies' comments. <br /> If you should have any questions or comments regarding this <br /> matter, please contact Tracie Billington at (916) 924-1239. <br /> Sincerely, <br /> ,:�all� AL� <br /> David Wang, P.E. <br /> Senior Waste Management <br /> Engineer <br /> Enclosure <br /> cc: See next page <br />