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y 7. Figure 4-1, Decision Tree For Small Excavation Sites <br /> The term "cleanup goal" in one of the decision boxes should <br /> be changed to "cleanup standard" since the ROD identifies cleanup standards, <br /> not goals. Also, this figure indicates a site is "No Further Action" if: <br /> a) soil cleanup goals (standards) have not been achieved; b) a critical site <br /> structure will be compromised; and c) the DI WET sample results do not <br /> exceed groundwater cleanup criteria. EPA does not agree with this <br /> assertion. If a site has not achieved the ROD-based soil cleanup standard <br /> for a COC, even though a DI WET sample indicates no impact to groundwater, <br /> the soil standard still has not been met. As a result, an Explanation of <br /> Significant Differences (ESD) to the ROD will be needed. Table 4-1, and <br /> applicable text, should be revised to reflect this understanding. <br /> 8. Section 4.12.3.1, Storage of Excavated Material, page 4-11 <br /> In the fourth paragraph of page 4-11, the text indicates <br /> that the "bottom" of the UST at SWMU 20 is considered the "probable minimum <br /> depth of contamination. " This implies that anything above this depth will <br /> be considered uncontaminated overburden. Unless DDJC-Tracy can substantiate <br /> why a leak from the top or middle of this tank is not possible, EPA <br /> considers only the cover which is on TOP of this tank to be overburden <br /> material. Please revise the text accordingly. <br /> Sampling and Analysis Plan <br /> 9. General <br /> Some of EPA's comments on the Remedial Action Work Plan, <br /> above, may apply to the Sampling and Analysis Plan. Please check the <br /> Remedial Action Work Plan and the Sampling and Analysis Plan for <br /> consistency. <br /> 10. Section 2.2, Problem Definition, page 2-3; and Section 2.3, Project <br /> Goals, page 2-3 <br /> These sections identify "cleanup goals. " "Cleanup <br /> standards" is the correct term since the ROD identifies enforceable cleanup <br /> standards, not goals. Please revise the text accordingly. <br /> 11. Section 3.1.1, Soil Cleanup Standards and Regulatory Limits (Tables <br /> 3-1 through 3-3) , pages 3-1 and 3-2 <br /> 3 <br />