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Sharpe Army Depot <br /> Page 2 <br /> August 21, 1989 <br /> comments. Additionally, the revised Sample Plan should include <br /> sufficient narrative and graphics to detail the plume locations <br /> and justify the proposed well locations. <br /> 4) Section 3 .2 - Industrial Waste/Stormwater Sewers The <br /> Department is concerned about the adequacy of the pr posed <br /> investigation of the industrial/stormwater sewer. The first <br /> paragraph of this Section should indicate how the industrial <br /> wastewater is currently handled and the disposal methods for the <br /> industrial waste and stormwater. The investigation of historical <br /> activities and buildings should not be limited to those which <br /> used solvents and should attempt to characterize the waste <br /> composition (Page 3-43 , first bullet) . A copy of the industrial/ <br /> stormwater sewer videotape is to be provided to the Department, <br /> upon completion of the television survey. <br /> A detailed rationale should be provided on how the 1110 worst <br /> leaks" will be selected. Will a large break in the pipeline, in <br /> an area of low flow and few sources, be selected over a small <br /> crack in an area of steady flow and numerous sources? Specific <br /> guidance should be provided on the selection criteria. <br /> Considering the possibility of a very large number of pipeline <br /> breaks, the Sample Plan should be revised to specify that, at a <br /> minimum, soil gas surveys will be conducted at 10 locations. <br /> Additional locations may need to be investigated, dependinc upon <br /> the number of sewer leaks, past investigations, and the solh gas <br /> survey results. <br /> Considering that positive results could be detected at each of <br /> the 10 proposed sites, the last bullet on Page 3-44 should be <br /> revised. If all sites surveyed generate positive results will <br /> soil borings be collected at five additional locations, for a <br /> total of 15 borings? <br /> 5) Section 3 .4 - Air - The Department will direct our comments <br /> on the air monitoring section to the addendum that was tel faxed <br /> to us on 9 August 1989. <br /> The objectives of the air monitoring program should be c early <br /> defined in the Sample Plan. Is the purpose of the study to <br /> assess potential exposure to the on-site workers, to the off-site <br /> residents, or both? Also it is not clear whether the purpose of <br /> the study is to quantity the emissions from the air stripper, <br /> from areas of contaminated soil, or both. Additionally , the <br /> Sample Plan should explain why the 14 volatile organic com ounds <br /> (VOCs) that will be monitored were selected. Finally, the 3ample <br /> Plan should explain why sampling will be conducted every third <br /> day? <br />