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ATTACHMENT <br /> EPA COMMENTS ON THE <br /> DRAFT FINAL RECORD OF DECISION (ROD) OF JULY 1993 FOR <br /> OPERABLE UNIT NO. 1 (OU $1) FOR <br /> DDRW-TRACY <br /> 1. Declaration, Description of the Remedy <br /> The text which describes the selected disposal mechanisms for disposal <br /> of the treated groundwater states this groundwater will be "through <br /> injection and/or surface impoundments." However, it has been EPA's <br /> understanding throughout the drafting of this ROD that DDRW-Tracy wished <br /> to select both injection and surface impoundments as discharge <br /> mechanisms. The current IRM is constructed to use both injection wells <br /> and surface impoundment. It was not EPA's understanding that this ROD <br /> was to leave open the choice of either mechanism. The indefinite <br /> "and/or" text is used throughout the ROD. <br /> Corrective Action: EPA requests clarification in this matter prior to <br /> the finalization of this ROD. If DDRW-tracy has reason to maintain a <br /> level of uncertainty with regard to the disposal mechanism(s) , the <br /> justification needs to be provided in this ROD. Further, the criteria <br /> to be used in the final decision on disposal mechanisms (or combination <br /> thereof) will need to be identified in the ROD. <br /> 2. Section 2.3 <br /> The name of this section has been changed from "History of CERCLA <br /> Enforcement Activities" to "History of CERCLA Enforcement Activities. " <br /> However, EPA guidance (OSWER Directive 9335.3-06) which provides the <br /> outline for the sections and subsections of a ROD describes this section <br /> as properly title "History of CERCLA Enforcement Activities. " There is <br /> no requirement to summarize the history of regulatory activities. <br /> Corrective Action: Please restore the original title of this section. <br /> 3. Section 4.2.2 <br /> As EPA previously stated in our comments of June 7, 1993, this section <br /> implies that only a subset of the chemicals of concern will be evaluated <br /> in the Comprehensive RI/FS. Whereas all chemicals of concern will be <br /> re-evaluated in the Comprehensive RI/FS risk assessment. Although <br /> modifications have been made to the text, this section continues to <br /> suggest that not all constituents (i.e. , TCE, PCE and DCE appear to have <br /> been excluded) will be re-evaluated. The Comprehensive RI/FS risk <br /> assessment will, by definition, need to asses risks posed by all <br /> pathways. <br /> Corrective Action: Revise the text to state that all chemicals of <br /> concern and all pathways will be re-evaluated in the Comprehensive <br /> RI/FS. <br /> 4. Table 4.2-3 <br /> Total VOC constituents has been added as an effluent treatment standard. <br /> However, the text does not provide an explanation a to why the addition <br /> of this standards is necessary. <br /> Corrective Action: Please provide an explanation in the ROD as to the <br /> purpose of an effluent treatment standard for total VOCs and the basis <br /> 1/7 <br /> EPA/R9 July 28, 1993 <br />