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ATTACHMENT 2 <br /> EPA COMMENTS ON <br /> DEFENSE DISTRIBUTION REGION WEST - TRACY, CALIFORNIA <br /> REMEDIAL DESIGN WORK PLAN FOR OU-1 <br /> November 1993 <br /> GENERAL COMMENTS <br /> 1. The draft remedial design work plan for OU-1 is incomplete as submitted. Significant <br /> portions not included are: <br /> Health and Safety Plan', <br /> Field Sampling Plan', <br /> Chemical Data Acquisition Plan', <br /> Surface Impoundment Percolation Pond Study (App. F), <br /> Foundation Study (App. G), <br /> Proposed Pump Tests (App. H), <br /> Pesticide/Groundwater Turbidity Correlation Study (App. 1), <br /> While the document successfully describes the data gaps, the absence of the above <br /> sections results in a lack of identified tasks to eliminate the data gaps. The text states <br /> that these portions will be provided with the final RD work plan. However, it is <br /> unclear how DDRW-Tracy plans on obtaining regulatory concurrence. Since there is <br /> no established time period for the regulatory agencies to review these sections, it can <br /> be assumed that the FFA-stipulated review period for first-time draft submissions <br /> applies. Please let EPA know if this is not the intent. <br /> 2. Since much of the initial text of the remedial design work plan is identical to the text <br /> of the Pre-design Technical Summary, many of EPA's comments need to be reiterated. <br /> a. The text frequently states that groundwater is to be returned to the aquifer <br /> "using injection wells and/or surface impoundments". However, the ROD <br /> states that this will be accomplished via "injection and surface impoundments." <br /> Please correct this text, and all similarly inaccurate instances of this text <br /> throughout the document, to be consistent with the ROD. <br /> b. Section 1.2.0.3 erroneously indicates that it is necessary to increase treatment to <br /> 350 gpm by November 1994 to meet EPA requirements. Whereas the text in <br /> the DR/RA schedule for OU-1 states that this action is judged to meet <br /> 1 Outlines provided in draft document. <br /> EPA/11JAN94 1/4 <br />