Laserfiche WebLink
cannot be shown to be an impenetrable barrier to feeding <br /> birds, reference to a 3-inch excavation should be eliminated <br /> from the text, except perhaps, in the cost estimate <br /> assumptions Please revise the ROD to resolve this issue. <br /> (Per the January 9, 1998 conference call to discuss agency <br /> comments on the ROD, DDJC-Tracy has agreed to remove the <br /> geofabric from the remedy and to cleanup sediment to the <br /> ROD-based cleanup levels. Thus, the remedy could involve <br /> removal of more than 3 inches of sediment . Please reflect <br /> this understanding in the Final ROD. ) <br /> b. Section 9.7 .1 .15 discusses the CERCLA five-year site review <br /> process relative to SWMU 4 . The text explains that sediment <br /> sampling will continue and a determination will be made on <br /> whether to remove future deposits of contaminated sediment <br /> which may accumulate in the pond. However, the text does <br /> not present the threshold criteria for making this <br /> determination. Without such criteria, how is one able to <br /> determine if the remedy has been effective, or if further <br /> remediation is warranted? Does DDJC-Tracy plan to apply the <br /> same risk-based cleanup criteria, as presented in this ROD, <br /> for making a determination for additional cleanup at the <br /> five-year review stage? Please clarify. (This concern was <br /> discussed at the January 9, 1998 conference call . ) <br /> Per EPA Counsel Comment No. 23 on Section 7 . 5 . 1.2, EPA was <br /> concerned that the remedy at SWMU 4 does not establish <br /> periodic removal of contaminated sediment following <br /> remediation. M. Work suggested that the 5 year review could <br /> determine if this is the case. S. Glover (COE) explained <br /> this was an ongoing operational problem that is not CERCLA <br /> related. Thus, this issue seems unresolved as the CERCLA <br /> remedy would appear to not be protective in the long-term. <br /> C. Section 9.7 .1. 13 states "Sediment samples will be collected <br /> for analysis during the remedial action to ensure that <br /> sediment across the bottom of the lagoon does not exceed the <br /> risk-based concentrations for DDD, DDE, DDT, and selenium <br /> that are protective of ecological resources . " Following <br /> this statement, this paragraph should reiterate that risk- <br /> based concentrations have yet to be finalized and will be <br /> based on additional site-specific data to be collected post- <br /> ROD, rather than the preliminary cleanup standards listed in <br /> this ROD. It should also mention that an ESD will likely be <br /> A-2 <br />