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125. Section 10.3.3 <br /> The text erroneously states that the groundwater or sludge (?) contaminants of <br /> concern will be managed as RCRA California-regulated wastes. <br /> Corrective Action: Either explain why this RCRA requirement is triggered by this <br /> remedial action or delete this section. <br /> 126. Section 10.4.1 <br /> The text states that CWA drinking water criteria are relevant and appropriate, but <br /> then states the RWQCB will "utilize their criteria" to set WDRs. This text seems to be <br /> confusing separate parts of the remedy (i.e., cleanup standards for the aquifer and <br /> treatment standards for the effluent). <br /> Corrective Action: Explain in the text which requirements are ARARs for which <br /> part of the remedial action. Further, the text should include the numerical <br /> standards for both parts of the remedy. <br /> 127. Section 10.4.2 <br /> Again, it is not clear how the RCRA storage requirements would be triggered by this <br /> remedial action. It may be that the RCRA regulation implied in this text is not an <br /> ARAR for this CERCLA action. <br /> Corrective Action: Either revise the text to explain why this requirement is <br /> triggered under this CERCLA remedial action or delete the text. <br /> 128. Section 10.4.7 <br /> Normally county/local requirements are not ARARs unless they are developed as <br /> part of a state program (e.g., local Air Pollution Control District regulations which <br /> are developed to implement the California Clean Air Act). In such a case, the state <br /> requirement is the cited ARAR and the local requirement is named and described in <br /> the text. <br /> Corrective Action: Either explain how the county groundwater well protection <br /> standards implement/satisfy a cited state requirement or move this text to a section <br /> for TBCs. <br /> 129. Section 10.5.1 <br /> In the absence of a determination that wetlands and endangered species do not exist <br /> at DDRW-Tracy, it must be assumed that they are present. DDRW-Tracy must <br /> provide assurances that should wetlands and/or endangered species habitat be <br /> present, they will not be adversely impacted by this remedial action. <br /> EPA/R9 Jw 7, 1993 28/40 <br />