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Corrective Action: Explain in the text that no determination of wetlands or <br /> endangered species has been made yet. Explain in the text that DDRW-Tracy will <br /> assure that the remedial action will not adversely impact wetlands or endangered <br /> species habitat should they exist. <br /> 130. Section 10.6.2 <br /> The text states that the state action level for dieldrin (0.05 ppb) "is proposed as the <br /> effluent treatment standard for OU #1. However, the ROD needs to make a definite <br /> determination for the treatment standard and not merely "propose." Further, the <br /> concentration of 0.05 ppb is inconsistent with the 0.10 µg/l stated in Section 4. <br /> Corrective Action: Delete the words "proposed as." Also, decide which concentration <br /> is the effluent treatment standard for dieldrin. <br /> 131. Section 10.6.3 <br /> The text states that OSHA requirements are "not considered to be ARARs by EPA." <br /> However, this is an oversimplification. The reason that OSHA industrial hygiene <br /> requirements are not considered to be ARAR is due to the fact that the OSHA <br /> requirements are not environmental requirements. It should be noted that by <br /> discussing OSHA requirements under this section which is entitled TBCs for this <br /> remedial action, DDRW-Tracy is committing to OSHA requirements as part of this <br /> remedial action. <br /> Corrective Action: Provide the additional explanation in the text. <br /> 132. Table 10.2.1, Federal ARARs <br /> Note: Since California is an authorized state under the RCRA program, California <br /> RCRA provisions should be cited as federal ARARs. This revision should be made <br /> throughout the federal ARARs Table. This can be done by replacing the federal <br /> section with the equivalent state section, unless, as noted by EPA comments, the <br /> initial proposed federal criteria are incorrect. <br /> a. The sub-heading "Contaminant Specific" should be revised to read: "Chemical <br /> Specific." <br /> b. National Secondary Drinking Water Standards, 40 CFR Part 143 <br /> This is not an ARAR. As acknowledged in the description section of the <br /> table, no SMCLs have been established for the chemicals of concern. <br /> Moreover, section 143.1 of Part 143 states that these regulations are not <br /> federally enforceable . Reference to this citation should be deleted. <br /> EPA/R9 June 7, 1993 29/40 <br />