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+aE°s*vFm UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> Region 9 <br /> ` 75 Hawthorne Street <br /> P San Francisco CA 94105-3901 <br /> November 3, 1998 <br /> Marshall Cloud <br /> Environmental Protection Office <br /> DD-Tracy <br /> P.O. Box. 960001 <br /> Stockton, CA 95296-0250 <br /> RE: Monthly Status Report Narrative, DD-Tracy <br /> Dear Marshall, <br /> Thank you for the Monthly Status Report Narrative for DD-Tracy. EPA's <br /> comments follow. <br /> 1. EE/CA for Lagoons and Industrial Waste. Pipeline, DDJC-Tracy, Delivery <br /> Order 0004 <br /> The project schedule for DO 4 identifies a "Closure Report" and a <br /> "Bioremediation Report. " What is the scope of both documents and are <br /> they scheduled for agency review? From the schedule provided, it does <br /> not appear that either report is scheduled for agency review. <br /> Additionally, EPA noticed that the removal action at SWMUs 2/3 continues <br /> to be referred to as an EE/CA. An EE/CA is a study prepared prior to <br /> performing a Removal Action, and is somewhat analogous to an FS report <br /> being prepared prior to performing a Remedial Design/Remedial Action. <br /> Thus, continuing to refer to the completed removal action at SWMUs 2/3 <br /> as an EE/CA is very misleading and may be confusing to anyone not <br /> intimately familiar with the DDJC-Tracy site. Thus, in the future, <br /> please use the term `Removal Action for Lagoons and Industrial Waste <br /> Pipeline. " <br /> 2. Record of Decision Remedial Design (DDJC-Tracy) , Delivery Order 0030 <br /> This section provides a monthly update of remedial design activities, <br /> and includes a schedule of work, including reports which are to be <br /> reviewed by the regulatory agencies. EPA compared the list of remedial <br /> design deliverables presented in the schedule with those listed in Table <br /> 1-2 of the recent Draft July 1998 Remedial Design Work Plan. Table 1-2 <br /> indicates that one of the design documents is the Design Analysis Report . <br /> (DAR) . However, in the DO 30 schedule, the DAR is not mentioned. <br /> Instead, the schedule identifies the Remedial Design Analysis (RDA) . Is <br /> the RDA the same as the DAR? If so, to avoid confusion, only one term <br /> should be used to describe this report. If not, the schedule should be <br /> revised to include the DAR. Also, in EPA's September 22, 1998 comments <br /> on the Draft Remedial Design Work Plan, Detailed Comment No. 8, EPA <br />