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EPA Comments
<br /> DD-Tracy Comprehensive
<br /> Draft Remedial Design Work Plan (JUL98)
<br /> General Comments and Major Concerns
<br /> 1. Potential Changes to ROD-based Soil Cleanup Standards and Monitoring
<br /> Requirements
<br /> Laboratory leachability tests on soil samples are proposed for eight
<br /> sites. The purpose of these tests is to reevaluate, and potentially
<br /> revise, the cleanup standards and monitoring requirements established in
<br /> the Final Site-Wide Comprehensive ROD. The following sites and
<br /> contaminants are affected:
<br /> * SWMU 6, Building 28 Sump - dieldrin, endrin, heptachlor, lindane,
<br /> dicamba, 2,4,5-T, as listed in Table 4-13;
<br /> * SWMU 7, Burn Pit No. 1 - dieldrin, linuron, 2,4-D, simazine and
<br /> TPH-diesel, as listed in Table 6-3;
<br /> * SWMU 8, Burn Pit No. 2 - bis(2-ethylhexyl)phthalate,
<br /> diethylphthalate, 2,4,-dinitrotoluene, naphthalene, PCBs, dieldrin,
<br /> DDD, DDT, lindane, chlordane, linuron, 2,4-D, MCPA, simazine, TPH-
<br /> gasoline, TPH-diesel and TPH-motor oil, as listed in Table 4-10;
<br /> * SWMU 20/SB204, Aboveground Solvent Tank and Area 1 Building 10 and
<br /> SB204 - pesticides (of concern are dieldrin, methiocarb, MCPA,
<br /> linuron, as listed in Table 4-15) , PCBs and TPH-diesel, as listed
<br /> in Table 4-17;
<br /> * SWMU 24, Bioventing - PCBs (Aroclor 1260) , carbofuran, lindane,
<br /> phorate, ronnel and TPH-diesel, as listed in Table 7-4;
<br /> * SWMU 27, Building 206 Roundhouse Sump/Area 1 Building 206 - 2,4-D,
<br /> MCPA, 2,4,5-T and TPH-motor oil, as listed in Table 4-20;
<br /> * SWMU 33, Industrial Waste Pipeline - di-n-butylphthalate,
<br /> diethylphthalate, dieldrin, aldrin, carbaryl and methiocarb, as
<br /> listed in Table 6-6; and
<br /> * Building 30, Drum Storage Area - benzyl alcohol, bis (2-
<br /> ethylhexyl)phthalate, diethyl phthalate and di-n-butylphthalate,
<br /> as listed in Table 6-9.
<br /> For each of these sites, the text includes the following statements:
<br /> "If laboratory results indicate that cleanup standards are
<br /> inappropriate, review of the cleanup standards and proposed groundwater
<br /> monitoring under the Well Monitoring Program may be warranted. Any
<br /> revisions will be documented in an ESD or PDTS. " EPA is concerned about
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