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cleanup standards (and include the fact that there is also a cleanup standard for <br /> DCE set by the state MCL). <br /> 89. Section 7.4.2.2.1 <br /> This section erroneously implies that the OSHA requirements are ARARs. <br /> Corrective Action: Delete the OSHA requirements (as ARARs). <br /> 90. Section 7.4.2.3 <br /> The text indicates that cost-effectiveness is reevaluated at the 5 year review. <br /> However, the intent of the 5 year review is to evaluate the protectiveness of the <br /> remedial action. <br /> Corrective Action: Please cite the source of the assertion that the 5 year review is an <br /> opportunity to reevaluate the cost-effectiveness of the remedy, or delete the <br /> statement. <br /> 91. Section 7.4.2.3 <br /> While it is reassuring to state that effluent standards will be maintained that will not <br /> cause degradation of the aquifer, the ROD must explain how monitoring of the <br /> influent will be performed to assure that should other chemicals of concern be <br /> detected at levels which might cause degradation of the aquifer, it may be necessary <br /> to establish additional effluent standards. <br /> Corrective Action: Add to the text a commitment to monitor influent for all <br /> potential contamination and to establish additional effluent standards as necessary. <br /> 92. Section 7.4.2.3.2 <br /> The FS included a discussion concerning possible cross-contamination in wells <br /> screened in both the upper and middle horizons, however, this concern is not <br /> presented in the ROD. <br /> Corrective Action: Add the discussion regarding potential cross-contamination and <br /> include a statement which explains the actions DDRW-Tracy will take to address this <br /> concern. <br /> 93. Section 7.4.2.3.3 <br /> It is not correct to state that at the end of remediation there will be "no risk.", <br /> Corrective Action: Modify the text to state that at the end of remediation risks will <br /> be reduced to acceptable levels (i.e., to the range stated in the NCP, 1x10-* to 1x10-8). <br /> EPA/R9 June 7, 1993 21/40 <br />