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Quality Assurance Plan, Operation and Maintenance Plan, Groundwater <br /> Monitoring Plan (as well as identify the locations of the extraction, <br /> injection and performance monitoring wells; estimated extraction and <br /> injection rates)." <br /> b. Footnote No. 2: <br /> Footnote No. 2 should not attempt to state how CERCLA Section 120 is satisfied by <br /> this schedule. As was discussed between EPA and COE staff, should DDRW-Tracy's <br /> compliance with CERCLA statute be challenged, interpretation of this statute will be <br /> accomplished judicially. DDRW-Tracy may state DLA's interpretation. Please revise <br /> this footnote to read, for example: <br /> "The Interim Remedial Measure (IRM) is anticipated to operate at 35 percent <br /> of the OU-1 design capacity by 12 Nov 1994. The Defense Logistics Agency <br /> believes that this satisfies CERCLA Section 120(e)(2)." <br /> C. Footnote No. 3: <br /> Footnote No. 3 states that the draft and draft final remedial action work plans <br /> represent the 30 and 60 percent "technical specification development stage" <br /> (presumably to differentiate the subsequent secondary document of 15 Mar 95 from <br /> the draft final remedial design of 15 Dec 94). However, FFA Appendix B speaks only <br /> of a "final remedial design." In order to minimize the potential for misunderstandings, <br /> please modify footnote No. 3 to read: <br /> "The Final Design and Remedial Action Work Plan represents 100 percent <br /> design when final (less the construction specifications and drawings). These <br /> deliverables will meet the primary document requirements specified in the <br /> Federal Facility Agreement. Additional time is required following the draft <br /> final documents to further develop the technical specifications and cost <br /> requirements for contracting action." <br /> 4. Per EPA's suggestions, the number of total deliverables has been reduced in the <br /> revised proposed schedule. However, it is not clear whether this action has resulted in <br /> an expedited schedule. Please clarify for EPA how the time frame has been shortened <br /> given the number of documents/reviews which have been eliminated. <br /> EPA October 12, 1993 2/2 <br />