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Sharpe Army Depot <br /> Page 4 <br /> August 21, 1989 <br /> SECONDARY COMMENTS <br /> 1) Section 3 . 1 - Solid Waste Management Units - The Depa tment <br /> will defer comments regarding the investigation of the RCRA Solid <br /> Waste Management Units (SWMUs) to the EPA. It should be noted <br /> that the Department is, specifically, interested in the <br /> Industrial Wastewater Treatment Plant (IWTP) . Additionally, the <br /> lead contaminated soil near the Hazardous Waste Storage Facility <br /> (Building 605) should be evaluated as a part of the SWMU <br /> investigation. According to the Department's Facility permitting <br /> Unit (Keith Riley) , the oil water separator near Building 199 <br /> (A#28) has shown contamination by Total Petroleum Hydrocarbons <br /> (TPH) . The TPH contamination should be evaluated before <br /> dismissing this site from any additional investigations. <br /> 2) Section 3. 3 - Underground Storage Tanks (UST) Program - The <br /> UST workplan, Quality Assurance Project Plan, and Health and <br /> Safety Plan are to be submitted to the Department upon <br /> availability. <br /> 3) Section 3.5 - Arsenic - The locations of the off-site soil <br /> samples should be detailed further or shown on a site map. <br /> 4) Section 4 . 0 - Request for Analysis - This Section indicates <br /> that five certified methods for water samples and six certified <br /> methods for soil samples will be used at Sharpe Army Depot and <br /> are detailed in subsequent paragraphs. Sections 4. 1 and 4.2 <br /> detail only four methods for water and five methods for soils, <br /> respectively. This should be clarified. <br /> 5) Page 5-5 - Monitoring Well Construction - The Sample Plan <br /> states that a grout composed by weight of 20 parts cement, p to <br /> one part bentonite, and no more than eight gallons of water per <br /> 94 pound bag of cement will be pumped into the annular spa--e of <br /> the wells. The Department recommends a bentonite-cement grout <br /> with the percentage of Americal Petroleum Institute approved <br /> bentonite (non-beneficiated/non-polymerized) to cement be in the <br /> two to three percentage range (2-3 pounds bentonite/sack of <br /> cement) . Furthermore, for this amount of bentonite, the <br /> Department also recommends that the amount of water t mix <br /> ingredients be as low as possible to obtain a workable sl rry. <br /> This should be between 8. 5 to 10 gallons of water per sack of <br /> cement. The bentonite needs to be weighed and water metered <br /> on-site prior to mixing with the cement. <br /> 6) Page 5-15 - Soil Gas Sampling - The Department questions <br /> whether the proposed 20 foot spacing interval for the soil gas <br /> sampling locations is appropriate. The 20 feet spacing may <br />