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Y <br /> t <br /> Review of the EPA Comments on the <br /> Pond Design Evaluation Field Investigation Work Plan, <br /> Sharpe Site,January 2003 <br /> GENERAL COMMENTS <br /> 1. The Pond Design Evaluation Field Investigation Work Plan (the Work Plan) does not <br /> discuss the compatibility of the proposed disposal of treated groundwater with the Record <br /> of Decision (ROD)for the DDJC-Sharpe facility. It appears that evaporation/infiltration <br /> ponds were among the disposal alternatives discussed in the ROD, Section 7.3, Page 50 <br /> (ES&E, 1993). Please add a brief statement describing the compatibility of the proposed <br /> pond disposal option with the DDJC-Sharpe ROD. <br /> 2. The Work Plan does not provide sufficient background information on the chemical <br /> make-up of the treated groundwater to be managed in the ponds. This information is <br /> necessary to evaluate the proposed management of the groundwater within the ponds. <br /> Please provide information on pH, suspended solids, total solids, inorganics/metals <br /> (specifically arsenic), and organic compounds in the treated groundwater. <br /> 3. Appendix C provides a cost benefit analysis of alternatives for the discharge of treated <br /> groundwater. However, there was no indication that the impact to the environment was <br /> assessed as part of the options. Please discuss the environmental impact of the selected <br /> option. <br /> 4. This Work Plan does not clearly address several areas that are normally contained in a <br /> work plan, including project management and a Sampling and Analysis Plan (SAP). A <br /> project management plan would include sections that address key elements such as <br /> project objectives, project organization, project personnel, project communications and <br /> reporting, project deliverable, subcontract management (if necessary) and management of <br /> field operations. The SAP would address any samples that are taken. The Work Plan <br /> does not specify if sampling will be conducted of the treated groundwater during the test, <br /> however, this procedure is recommended. Please discuss or reference where project <br /> management and the SAP will be addressed. <br /> 1 <br />