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Michael Work <br /> Page 3 <br /> January 23 , 1998 <br /> As a general comment with respect to the Northern Depot Area, the selected remedy does <br /> not appear to be adequately supported. Risk is not sufficiently addressed. According to Table <br /> 5-23, risk at the Northern Depot Area is attributable to manganese and arsenic; at SMWU 7 and <br /> Area 1, Building 237, however, the risks for manganese and arsenic are considered "biased high" <br /> because the amounts are within normal ranges for the Western United States. The document <br /> should explain why this is not the case for the Northern Depot Area. Also, no receptors other <br /> than grader operators are identified as at risk. It therefore seems that institutional controls would <br /> be sufficient to mitigate the threat to grader operators. <br /> 20. re Northern Depot Area: Table 8-2: revise "high" rating for treatment category to "low" <br /> (see ¶8.12.5). <br /> 21. re SWMU 33: ¶9.8.2.5: please expand the explanation regarding why contaminants will <br /> remain above cleanup levels (i.e., contaminants generally below buildings or under paved areas, <br /> low threat of migration to g/w; grouting IWPL will further reduce threat) see DDRW-Tracy <br /> response to ORC comment#59 dated October 15, 1997. <br /> 22. re ARARs: 17.2.6.7: "On-site Treatment" is a confusing heading. Suggest incorporate this <br /> text into beginning of next section. <br /> 23. re ARARs: ¶7.2.6: should include all statutes and regulations in Tables 10-2 and 10-3. <br /> 24. re ARARs: Table 10-2: ARARs for OUI should not deviate from the Final OU1 ROD. For <br /> example, ARARs #1-8, 10, 12-20, 22-23, 28-33, and 37-43 were not included as ARARs in the <br /> Final OU 1 ROD. Please revise Table 10-2 to be consistent with tables from Final OU 1 ROD. <br /> 25. re ARARs: Table 10-3: break out "not applicable" standards and compile a separate table. <br /> These tables should contain only standards that are applicable or relevant and appropriate (see <br /> comment #63, ORC Comments dated October 15, 1997). <br /> 26. re ARARs: Table 10-3: references to TBCs should now be to Performance Standards (see <br /> comment #63, ORC Comments dated October 15, 1997). <br /> 27. re ARARs: Table 10-3, ARARs 1-4: unclear why these standards are included. They appear <br /> to be general authorities, not standards. <br /> 28. re ARARs: Table 10-3, ARARs #14-27: unclear why Title 27 is Applicable or included as <br /> an AR-AR. <br /> B-3 <br />