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The ROD for OU-1 was finalized on August 12, 1993. The draft RD/RA Schedule <br /> indicates that the RD/RA Work Plans will be final on July 1, 1995, which is <br /> approximately 22.5 months later. The draft schedule indicates that enhancement to the <br /> existing IRM system will be complete by November 12, 1994, resulting in 30-40 <br /> percent of the rate of treatment of the planned remedial action. However, the draft <br /> schedule is silent on when 100 percent remedial activity can be expected to occur (i.e., <br /> the point at which the remedial system will be performing at its planned capacity). <br /> The DDRW-Sharpe schedule of April 7, 1993, included this date. Moreover, the <br /> definition of RD/RA includes the completion of construction [NCP 300.435 (a) states <br /> "The remedial design/remedial action (RD/RA) stage includes the development of the <br /> actual design of the selected remedy and implementation of the remedy through <br /> construction."] <br /> OU-1 Deliverable/Action ROD Finalization Draft RD/RA Duration in <br /> Schedule Months <br /> 30%Draft Design 12 AUG 93 17 AUG 94 12 <br /> Continuous 35% On-Site Activity 12 NOV 94 15 <br /> Final 95%RD/RA Work Plans 1 JUL 95 22.5 <br /> Continuous 100% Remedial Activity 7 7 <br /> Corrective Action: Include the date that continuous 100 percent remedial activity will <br /> occur. <br /> 4. Proposed Time Frames for Review and Finalization <br /> It is not clear to EPA how DDRW-Tracy calculated the time frames between <br /> submission of the 30 percent draft RD/RA Work Plan and the submission of the 30 <br /> percent draft final RD/RA Work Plan. Per the terms of the FFA one would expect <br /> 120 days (two periods of 60 days each) whereas the draft schedule plans for 129 days. <br /> Corrective Action: Please either revise the time frame or explain why it is necessary <br /> to include additional days. <br /> 5. 95 Percent Design Documents <br /> The schedule is not clear whether there is a document associated with 95 percent <br /> design stage. The schedule describes a "95% Remedial Design Review" but it is not <br /> clear what is being reviewed since no document is referenced. <br /> EPA September 20, 1993 3/4 <br />