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ATTACHMENT B <br /> MEMO <br /> To: Michael Work <br /> From: Kara Christenson <br /> Subject: Tracy Draft Final ROD Comments (except for ARARs) <br /> Date: January 21, 1998 <br /> General: Text should clarify that contaminants that impact groundwater or pose a threat to <br /> groundwater do not necessarily pose a threat to human health. It is difficult to reconcile <br /> statements that contaminants have impacted groundwater, see e.g., paragraphs 5.4, 5.5, 5.6, with <br /> statements that no action alternatives are protective of human health,=L". , 8.5.2, 8.6.2. DDJC <br /> should provide explanation. <br /> General: Tables 5-1, 5-3, 5-7, 5-11, 5-17, 5-19, 5-26, 6-5; ¶¶5.4, 6.5.8, 6.5.10, 6.5.11., 6.5.12: <br /> The text still needs work to address the bias issue. The meaning of"one category high" is still <br /> unclear. It now appears that SWMU 7 is also affected by this "bias" issue (5gee ¶6.5.8). <br /> According to DDJC-Tracy, the issue was discussed in the BRA and/or the RI/FS; therefore, the <br /> ROD should refer directly to these documents (egg 16.5.13, 1st sentence). Without these <br /> references, DDJC-Tracy appears to be making this determination in the ROD, which is <br /> inappropriate. See also,¶¶8.9.2, 8.10.2, 8.13.2., 8.14.2. <br /> 1. ¶5.2.8: insert parentheses around"the sewage and industrial waste lagoons" <br /> 2. ¶5.5.3.1: was this site evaluated in the FS because of risk to construction worker (which is <br /> identified in Table 5-11)? <br /> 3. ¶6.5.7: 2nd sentence: delete "totally"; change "attributable" to "attributed". 3rd sentence: <br /> "The surface and near surface soil exposure scenario . . ." <br /> 4. Table 6-1: does not appear to include Northern Depot Area. Please clarify that it is included <br /> or include. <br /> 5. ¶6.5.9: bullet regarding SWMU 24 seems to be missing words after"presents" <br /> 6. 16.5.11: this paragraph deals only with chlordane, whereas Table 5-26 also attributes risk to <br /> DDX; therefore, conclusions re bias do not appear to be fully supported. <br /> 7. 16.5.11 and ¶6.5.12: according to DDJC-Tracy, these explanations of over-conservative <br /> assumptions are in the BRA. Please make this point clear(see 16.5.13). <br /> B-1 <br />