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CERCLA Section 120 requirements. Please modify the text to more accurately reflect the assumptions in the RD/RA schedule. C. Both the RD Technical Summary and the RD Work Plan repeatedly refer to various stages of design (e.g., 10%, 30%, 60% 95% and 100%) and to associated meetings and document reviews at each stage (see also Table 2-1 of the Remedial Design Work Plan). A number of these documents/reviews are not named in the FFA RD/RA schedule for OU-1. EPA believes that such an intensive level of document preparation/review may be unnecessary given that this remedial action is based on the most commonly selected technology for groundwater treatment. [Note that the text is silent on the regulatory review periods for these additional documents. In the absence of concurrence on review periods, time lines outlined in the FFA apply.] EPA is very interested in streamlining the number of reviews for this RD/RA if such action would enable DDRW-Tracy to expedite the remedial action schedule. DETAELED COMMENTS 3. Section 2.2.1.2 suggests that due to potential property access problems, the RD/RA schedule may need to be revised. However, since the submission of these documents, EPA has learned that DDRW-Tracy has successfully purchased, and currently owns, the Raspo property. Therefore, EPA assumes that there will not be a need to revise the RD/RA schedule. Please revise this text accordingly. 4. Table 2-1: The FFA OU-1 RD/RA schedule describes one primary design document. Table 2-1 describes the 30 percent design document as a draft primary document. This table also appears to describe the 60 percent design document as the subsequent draft final primary document. It would appear that DDRW-Tracy considers these two documents in Table 2-1 as the one primary document referred to in the FFA OU-1 RD/RA schedule. However, DDRW-Tracy should be aware that should the 60 percent design document contain significant new information (not included in the 30 percent design document as identified in Table 2-1) the regulatory agencies may consider it to be a first-time submission under the terms of the FFA. Please clarify the relationship between the FFA schedule for RD/RA documents and Table 2-1. [Note: EPA reiterates out desire to streamline the number of RD/RA documents for OU-1. Such action may help to eliminate some of this confusion regarding Table 2-1.] 5. Table 2-1 needs to include a date for the finalization of remedial design (per EPA OSWER Directive 9355.5-01, Section 4.2.2). EPA111 JAN94 2/4