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73. Section 7.3.2.2 The text mistakenly includes OSHA requirements as ARARs for this remedial action. While OSHA requirements are to be met, they are not ARARs for this action. Corrective Action: Delete the mention of OSHA safety standards as ARARs. 74. Section 7.3.2.3 The text indicates that cost-effectiveness is reevaluated at the 5 year review. However, the intent of the 5 year review is to evaluate the protectiveness of the remedial action. Corrective Action: Please cite the source of the assertion that the 5 year review is an opportunity to reevaluate the cost-effectiveness of the remedy, or delete the statement. 75. Section 7.3.2.3 Modifications to the system to assure that it meets the intent of the remedy can be made at any time with concurrence of all parties to the FFA, and not only at the 5 year review, as is suggested in the current text. Corrective Action: Revise the text to reflect that modifications to the system can be performed as necessary to meet the intent of the remedy. 76. Section 7.3.2.3 While it is reassuring to state that effluent standards will be maintained that will not cause degradation of the aquifer, the ROD must explain how monitoring of the influent will be performed to assure that should other chemicals of concern be detected at levels which might cause degradation of the aquifer, it may be necessary to establish additional effluent standards. Corrective Action: Add to the text a commitment to monitor influent for all potential contamination and to establish additional effluent standards as necessary. 77. Section 7.3.2.3 The FS included a discussion concerning possible cross-contamination in wells screened in both the upper and middle horizons, however, this concern is not presented in the ROD. Corrective Action: Add the discussion regarding potential cross-contamination and include a statement which explains the actions DDRW-Tracy will take to address this concern. EPA/R9 June 7, 1993 18/40