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i EPA COMMENTS ON <br /> DRAFT REMEDIAL DESIGN/REMEDIAL ACTION SCHEDULE <br /> SUBMITTED ON SEPTEMBER 3, 1993 FOR <br /> DDRW-TRACY OPERABLE UNIT NO. 1 <br /> 1. General Comment: <br /> Section 8.3 of the DDRW-Tracy FFA states "Within twenty-one (21) days of issuance <br /> of the Record of Decision for any operable unit or for the final remedy, DDRW-Tracy <br /> shall propose deadlines for completion of the draft primary documents found in <br /> Appendix B" to the FFA. Appendix B lists, in part, the following as primary <br /> documents: <br /> RD/RA Work Plans, <br /> Preliminary Remedial Designs, <br /> Final Remedial Designs, <br /> Construction QA Plans, <br /> Construction QC Plans, and <br /> Project Closeout Plans <br /> EPA believes that all parties to the DDRW-Tracy FFA are interested in expediting the <br /> final remedial design and remedial action work plan. Therefore, the list of primary <br /> documents provided in Appendix B should serve as a point of departure in the <br /> identification of primary documents; not all documents listed in Appendix B need be <br /> primary in this case. However, the draft schedule of September 3, 1993 identifies only <br /> one primary document, the Draft Remedial Design Document at the 30 percent design <br /> stage. The text does not clarify why the only primary document is proposed to be at <br /> the 30 percent design stage. It would appear that this schedlule does not propose any <br /> primary document at any stage for the remedial action work plan. Nor does the text <br /> explain the status of the remaining documents listed in the schedule. Is DDRW-Tracy <br /> proposing that the listed documents not identified as "primary" are "secondary?" If so, <br /> normally the secondary documents are feeder documents to a more final primary <br /> document.' Hence, EPA believes that either the 95 percent design and RA work plan <br /> or the final design and RA work plan should be primary. <br /> Corrective Action: The Schedule should explain how the proposed schedule satisfies <br /> DDRW-Tracy FFA Section 7.2(b) regarding the role of secondary documents, states <br /> "secondary documents include those reports that are discrete portions of the primary <br /> documents and are typically input or feeder documents. Secondary documents are issued by <br /> DDRW-Tracy in draft subject to review and comment by EPA, DHS [now DTSC] and <br /> RWQCB. Although DDRW-Tracy will respond to comments received, the draft secondary <br /> documents may be finalized in the context of the corresponding primary documents." <br /> EPA September 20, 1993 1/4 <br />