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remedial design" (Section 4.2.0.2), it may be cost effective to perform this <br /> monitoring during pre-design pumping tests. <br /> DETAELED COMMENTS <br /> 3. Section 1.2.0.2 states that groundwater is to be returned to the aquifer "using injection <br /> wells and/or surface impoundments". However, the ROD states that this will be <br /> accomplished via "injection and surface impoundments." <br /> To be consistent with the ROD, please correct this tent, and all similarly <br /> inaccurate instances of this text throughout the document. <br /> 4. Section 1.2.0.3 erroneously indicates that it is necessary to increase treatment to 350 <br /> gpm by November 1994 to meet EPA requirements. Whereas the text in the RD/RA <br /> schedule for OU-1 states that this action is judged to meet CERCLA Section 120 <br /> requirements. <br /> Please modify the text to more accurately reflect the assumptions in the RD/RA <br /> schedule. <br /> 5. Section 1.3.2.3 suggests that the IRM was constructed after the OU-1 RDFS of <br /> 1991/1992. Whereas it is EPA understanding that the IRM was built prior to the draft <br /> RDFS. Subsequent to the completion of the OU-1 RDFS, the IRM was modified to <br /> correct design flaws. <br /> Please clarify the history in the text. <br /> 6. Section 2.1.1.3 states that remediation is to occur for the "Upper Tulare Formation." <br /> However, the ROD for OU-1 requires remediation of the 'contaminate plume." All <br /> OU-1 design documents should use text which is consistent with the OU-1 ROD. <br /> Please modify this text accordingly in this and all future OU-1 design <br /> documents. <br /> 7. Section 2.1.1.4 and 2.1.1.5: The tent in these sections refers to a potential inability to <br /> achieve the aquifer cleanup standards and to the NCP section regarding waivers of <br /> ARARs. This concept is not included in the ROD for OU-1 and, therefore, is out-of- <br /> place in the OU-1 design. EPA is not considering an ARAR waiver for OU-1. OU-1 <br /> must be designed to meet the standards set forth in the ROD. Further, the text <br /> suggests that the purpose of the five-year review is, at least in part, to assess the <br /> success of the remedial system in achieving the MCLS. This would be more <br /> appropriately described as a performance evaluation. Whereas, the purpose of the <br /> five-year review is to "assure that human health and the environment are being <br /> protected by the remedial action being implemented" which is a broader concept. <br /> EPA/11JAN94 2/6 <br />