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EPA Review of the <br /> Responses to Comments on the "Well Monitoring Program, <br /> Draft 1999 Annual Monitoring Report" dated April 15, 2000 for <br /> Tracy Defense Depot <br /> The Army's responses often involved statements such as "the text was modified <br /> in the final report". However, the actual text was not provided as part of the <br /> responses. Therefore, it is in some cases not possible to evaluate whether the <br /> EPA comment was adequately addressed. In such cases EPA concurrence has to be <br /> postponed until the final report has been issued and the modified text can be <br /> reviewed. Following are a list of the responses to comments (RTCs) that could <br /> not be evaluated: <br /> 1. The RTC to EPA's General Comment 2 states that " (A) Text has been added <br /> addressing the impact of reporting limits that exceeded the cleanup <br /> standards. TPH-D concentrations are acknowledged. Sampling of <br /> groundwater for TPH will continue." However, without reading the <br /> modified text, it is unclear whether the EPA comment has been adequately <br /> addressed. <br /> 2. The RTC to EPA's General Comment 4, which states that "The contours have <br /> been revised and text has been added to address the anomaly of the mound <br /> at an extraction well." However, since the rational for groundwater <br /> mounding at EW034AU was not provided, further evaluation of this <br /> phenomenon and potential remedy for this mounding could not be <br /> evaluated. <br /> 3. The RTC to EPA's General Comment 5 states that "Text has been added to <br /> the final report to explain how plume capture percentages were <br /> estimated". Since the text was not provided, it is impossible to <br /> evaluate and comment on the methodology of plume capture estimation. <br /> Therefore, additional clarification and/or revision to the final report <br /> may be warranted. <br /> 4. Further RTCs that did not provide sufficient information include RTCs to <br /> Specific Comments 1, 2, 3, 4, 6, 7, 10, and 14 . <br /> Item 1. General: The Response to Comment (RTC) states that " (N) The removal <br /> action was not intended to cleanup dieldrin or other contaminants that were <br /> already in groundwater and migrating away from SWMUs 2 and 3. The remedy for <br /> dieldrin in groundwater, addressed in the Site -Wide Comprehensive Record of <br /> Decision (ROD) , was the installation of new extraction wells and operation of <br /> pre-existing wells with well head treatment. The new wells have not begun <br /> extracting and treating groundwater." <br /> 1 <br />