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108. Section 9.1.1.3.1 <br /> The text states that disposal of treated groundwater will occur through "injection <br /> into the aquifer or in combination with discharge to surface impoundments." <br /> However, disposal will occur via both injection and discharge to surface <br /> impoundments. <br /> Corrective Action: Modify the text to state definitely that both disposal methods are <br /> included in this alternative. <br /> 109. Section 9.1.2.2.1 <br /> The text states that "effluent treatment standards will be set by the RWQCB . . :'. <br /> However, this ROD is the mechanism by which these treatment standards will be set. <br /> If not set in this ROD, the treatment standards may not be legally binding. <br /> Corrective Action: Revise the text accordingly and refer the reader to the <br /> appropriate section of the ARARs tables where the effluent treatment standards are <br /> stated. <br /> 110. Section 9.1.2.2.2 <br /> The text states that RCRA groundwater treatment unit requirements are ARARs. <br /> However, it is not clear to EPA what part of the remedy triggers these requirements. <br /> Corrective Action: Explain in the text what part of the selected alternative triggers <br /> these requirements or delete this text. <br /> 111. This section erroneously implies that the OSHA requirements are ARARs. <br /> Corrective Action: Delete the OSHA requirements (as ARARs). <br /> 112. Section 9.1.2.3.1 <br /> The text indicates that at the 5 year review modifications to the design can be made. <br /> However, the intent of the 5 year review is to evaluate the protectiveness of the <br /> remedial action. Modifications to the design to meet the intent of the ROD can be <br /> made prior to the five year review. <br /> Corrective Action: Revise the text accordingly. <br /> 113. Section 9.1.2.3.1 <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 /> EPR/R9 June 7, 1993 25/40 <br />