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Corrective Action: Revise the text to describe more accurately the scope of the <br /> report. <br /> 18. Section 2.3 <br /> Section 2.3.1 (the section entitled "History of CERCLA Enforcement Activities"), is <br /> appropriately relevant to the subject of the heading. However, the subsequent seven <br /> paragraphs contain information which is less relevant to CERCLA enforcement <br /> history at DDRW-Tracy. Further, the last sentence of section 2.3.7 discussion the <br /> "state-wide prohibition of land disposal" is not pertinent to this ROD and should be <br /> deleted. Also, the text mentions "primary documents" but includes no explanation. <br /> Corrective Action: The non-relevant text should be either moved to a more <br /> appropriate section of the ROD, after necessary modification, or deleted. Define <br /> primary documents for the reader. <br /> 19. Section 2.3.4 <br /> The text erroneously states that ARARs are "applicable apd relevant and appropriate <br /> requirements." <br /> Corrective Action: Change "and" to "or." <br /> 20. Section 2.3.5 <br /> The text implies that local laws are ARARs. However, local laws are not ARARs <br /> unless they implement a state requirement. In such cases the state requirement is the <br /> ARAR and the local implementing mechanism is cited in the text. <br /> Corrective Action: Delete the reference to "local" ARARs here and in all subsequent <br /> references (e.g., Section 2.3.7). <br /> 21. Section 2.3.7 <br /> In section 2.3.7 the discussion of ARARs should include the requirement that a <br /> proposed State ARAR must be consistently applied (in addition to promulgated, more <br /> stringent, timely identified, etc.). <br /> Corrective Action: Modify the text to include the requested discussion. <br /> 22. Section 2.3.8 <br /> The last sentence states "a summary of ARARs evaluated for OU #1 is provided in <br /> Tables 10.1-1 and 10.1-2." However, an "evaluation" will not suffice. The purpose of <br /> a ROD, in part, is to make a definite determination of the ARARs for the selected <br /> remedial action. Further, the text misstates chemical-specific as "contaminant- <br /> specific." <br /> EPA/R9 Jme 7, 1993 5/40 <br />