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b. The first paragraph also explains that confirmation samples will be <br /> collected "from just above (1 foot) the capillary fringe or groundwater zone <br /> of influence/fluctuation. " As discussed during the March 3 technical <br /> meeting, in some cases the highest known contaminant concentrations were <br /> observed at shallower depths. As a result, DDJC-Tracy agreed to modify <br /> sample collection depths to correspond to the highest known contaminant <br /> concentrations for the site or portion of the site. This understanding <br /> should be reflected in Section 4 .10 as well as other applicable sections of <br /> the Remedial Action Documents. <br /> 5. Table 4-2, Soil Cleanup Standard Small Excavation Sites, page 4-8 <br /> As discussed during the March 3 technical meeting, the text <br /> of this section does not explain why soil samples will not be analyzed for <br /> VOCs at SWMU 20, even though the ROD identifies soil cleanup standards for <br /> VOCs. The text should be revised to explain that DDJC-Tracy will sample and <br /> analyze for VOCs in both soil and soil gas, following completion of soil <br /> vapor extracting (SVE) at SWMU 20, to ensure the site has achieved ROD-based <br /> cleanup standards for VOCs. <br /> 6. Section 4 . 10, Confirmation Sampling; and Table 4-2, Soil Cleanup <br /> Standard Small Excavation Sites, page 4-8 <br /> As discussed during the March 3 technical meeting, <br /> DDJC-Tracy indicated it was planning to report the analytical results of <br /> only the site-specific COCs listed in Table 4-2. However, based on further <br /> discussion, DDJC-Tracy (M. Cloud) agreed that a complete listing of <br /> analytical results for each method will be included in an appendix of the <br /> Remedial Action Report (s) , which presents the results of confirmation <br /> sampling. The Remedial Action Work Plan should be revised to reflect this <br /> understanding. <br /> 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 /> 2 <br />