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should reiterate the history of the metals issues <br /> 6. A review of Woodward-Clyde Consultants' (WCC' s) response to <br /> EPA' s comments of May 22 , 1991, on the previous Draft FS for <br /> DDRW-Tracy revealed that nine of the specific comments were <br /> not addressed completely in the revised report. <br /> Please respond to specific comments numbered 20, 34 , <br /> 38 , 44 , 45, 50, 56, 57 , and 66 and identify their <br /> location in the next revision of the FS for OU #1. <br /> 7 . Terminology: The RI has used the term "Chemicals of <br /> Concern" in describing contamination. Whereas the FS is <br /> using the term "Contaminants of Concern. " These two <br /> documents need to use consistent terminology. <br /> Modify the text throughout the FS to be consistent with <br /> the RI . <br /> SPECIFIC COMMENTS <br /> 1. List of Acronyms Used in the FS, Page xv <br /> According to the California Code of Regulations (CCR) , Title <br /> 22 , the definition of STLC is soluble threshold limit <br /> concentration. <br /> 2 . Section ES . 1. 1, Page ES-1, First Bullet <br /> As mentioned in the General Comments, remediation for only <br /> PCE and TCE is insufficient for OU #1; other VOCs and <br /> pesticides are included in OU #1. <br /> 3 . Section ES. 1. 2 , Page ES-2 <br /> The Interim Remedial Measure (IRM) system is the first area <br /> from which metals would migrate off-site. A pretreatment <br /> system for metals could be installed prior to restarting <br /> this system. <br /> • DLA should consider this option. <br /> 4 . Sections ES. 4 . 3 . 1 and ES . 4 . 3 . 2 <br /> The text in these sections appropriately states that ARARs <br /> will be met. EPA is not recommending any changes to these <br /> sections. However, the ARARs tables (Table 2 . 2-3 and Table <br /> 2 . 2-4) state that the applicability, relevancy and <br /> appropriateness are "to be determined" for many of the <br /> potential ARARs. <br /> 3 <br />