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ATTACHMENT 2 <br /> EPA COMMENTS ON <br /> DEFENSE DISTRIBUTION REGION WEST - TRACY, CALIFORNIA <br /> DRAFT SOW FOR <br /> COMPREHENSIVE RDFS WORK PLAN AMENDMENT <br /> (DATED JAN. 21, 1994) <br /> 1. Title: Contrary to the title, this SOW covers more than just the Comprehensive RI/FS, <br /> Phase II, Work Plan Amendment. The text states that this SOW also covers the <br /> development and submission of the Comprehensive RDFS, the Proposed Plan and the <br /> ROD (refer to SOW Sections 3.6 and 3.7). <br /> 2. Section 1.3: It is not understood why the tela indicates that the delivery order "will <br /> complete the Site-Wide Comprehensive RI/FS, Phase II work needed to support the <br /> Baseline Risk Assessment." Isn't the purpose of the delivery order to support the <br /> development and finalization of the RDFS (which contains the BRA), the Proposed <br /> Plan, the Proposed Plan Fact Sheet, and the ROD? [Note: The draft RI would be <br /> incomplete without the BRA.] <br /> 3. It is unclear how the tasks in this SOW relate to the BRA work plan. Although the <br /> SOW is written to implement Phase II investigations and to develop CERCLA <br /> documentation from the Comprehensive RI through to the ROD, the SOW is silent on <br /> how the BRA (developed under separate contract?) will be incorporated into the draft <br /> RI. Separate contracts may increase the chance of discontinuity. Additionally, it is <br /> unclear how the data quality objectives and data needs to be identified in the BRA <br /> work plan -- a work plan which appears to be tasked under a separate contract -- <br /> will be met in this SOW which is stated to be the mechanism by which all remaining <br /> sampling will occur. It would be unfortunate if the BRA work plan identified <br /> additional sampling (e.g., as part of the ecological evaluation) and DLA had no <br /> mechanism by which the BRA sampling could be tasked. <br /> 4. Section 2.0: The objective is stated in part to perform the work detailed in the <br /> Comprehensive Site Characterization Report (Phase 1?), 18 Dec. 1993. However, <br /> wouldn't it be more accurate to state that the intent is to perform the tasks which will <br /> be described in greater detail in the Phase 2 work plan amendment, yet to be <br /> submitted? <br /> 5. Section 3.0: It is good that the SOW lists guidance under references. Please augment <br /> the references with the following: (1) Compendium of Superfund Program <br /> Publications (EPA/540/8-91/014) published annually, (2) past EPA comments on the <br /> Comprehensive RI/FS work plan and work plan amendments, and (3) the Federal <br /> Facility Agreement for DDRW-Tracy. <br /> EPA110M94 1/3 <br />