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partially addresses EPA's comment by indicating that monitoring <br /> would continue at individual SWMUs until it can be demonstrated <br /> that no further threat to water quality remains . However, it is <br /> not clear how this would be demonstrated at sites where: 1) <br /> waste remains in place, AND 2) such waste has the potential to <br /> impact groundwater but has not yet done so. This concern would <br /> apply to the Institutional Control sites, and some active remedy <br /> sites where the remedy is not designed to clean up all in-place <br /> contaminants . Specifically, this would apply to: <br /> * SWMU 1/Area 2 (SVE is the selected remedy, but this would <br /> not remediate PCBs in soil) <br /> * SWMU 7 (Institutional Controls are the selected remedy, but <br /> VOCs, TPH, SVOCs, and pesticides/herbicides would remain in <br /> soil) <br /> * SWMU 24 (bioventing is the selected remedy, but this would <br /> not remediate PCBs and only partially remediate SVOCs and <br /> pesticides in soil) <br /> * SWMU 33 (the excavation performed during the Removal Action <br /> has not cleanup all SVOCS, pesticides, and TPH in soil to <br /> soil clean levels, per Section 9. 8 .2 . 5) <br /> * Drum Storage Area/Building 30 (Institutional Controls are <br /> the selected remedy, but VOCs, SVOCs and <br /> pesticides/herbicides would remain in soil) <br /> Section 9. 1.2 attempts to address these concerns by stating <br /> "Furthermore, if wastes remain in place (e.g. , under <br /> institutional controls) , the site will be monitored until cleanup <br /> standards are met or until it can be demonstrated that no further <br /> threat to water quality remains (22 CCR, Section 20400) . " <br /> Although soil cleanup standards have been included for the <br /> Institutional Control sites (SWMU 7 and Drum Storage <br /> Area/Building 30, per Sections 9.7 .3 .2 and 9.7. 8 .2, <br /> respectively) , these standards may never be achieved since there <br /> is no active remediation. Thus, DDJC-Tracy will presumably rely <br /> upon the second part of this requirement (i .e. , "it can be <br /> demonstrated that no further threat to water quality remains") as <br /> the basis for discontinuing performance monitoring. However, the <br /> ROD does not explain HOW no further threat to groundwater can be <br /> demonstrated for these five sites. Although Section 9. 1.2 states <br /> "sites recommended for further action in this ROD . . .will be <br /> monitored for the analytes. . . for no less than three years after <br /> A-5 <br />