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During the April 7, 1999 meeting at the Sharpe Depot, ICF Kaiser (Nels <br /> Johnson, now of the IT Group) expressed a concern that RI sampling <br /> results at the Northern Deport Soils Area may be composite samples from <br /> multiple boring locations, and thus, the usability of this RI data was <br /> in question. Although it may be inappropriate to respond to this <br /> concern within this ESD, please inform EPA if the RI results were indeed <br /> composite samples, and how such a finding may effect the selected remedy <br /> or the remedial design. <br /> 15. Section 5.0, New SWMUs <br /> This section is limited to the following note: "This section is <br /> reserved for the potential addition of soil or groundwater SWMU sites at <br /> DDJC-Tracy. " It is not clear which sites are being referenced. Does it <br /> include the new site identified at the April 15, 1999 RPM meeting which <br /> is adjacent (or associated with) SWMUs 2/3? At that meeting, there was <br /> discussion of combing this new site with SWMUs 2/3 instead of making it <br /> a separate site (although this issue was not resolved) . Thus, Section 5 <br /> needs further clarification. In any event, this EDS cannot be finalized <br /> until any issues related to new sites are resolved, or unless such sites <br /> are omitted from the scope of this ESD. <br /> 16. Section 6.0, Institutional Controls <br /> An introduction to this section is needed to clarify why Institutional <br /> Controls (ICs) are being described in this ESD, since, except for the <br /> Northern Depot Soils Area, ICs are already identified as the selected <br /> remedy for these sites. Additionally, the text should be restructured <br /> to clearly distinguish: 1) which remedy components are already <br /> identified in the ROD; 2) which remedy components simply provide more <br /> detail than what is presented in the ROD and are not considered <br /> "significantly different"; and 3) which remedy components are actually <br /> considered "significantly different. " Without this distinction and <br /> clarification, this section is confusing. <br /> Please also consider moving section 6. 6, Northern Depot Soils Area, to a <br /> subsection of Section 4, Northern Depot Soils Area, so that the remedy <br /> components for this site are not split between two major sections. <br /> 5 <br />