Laserfiche WebLink
Site-Wide Comprehensive ROD -13- 1 May 1997 <br /> DDRW Tracy <br /> be based on completing the characterization of soil contamination conducted as part of the removal <br /> actions. Therefore, unless the planned removal actions are completed prior to completing the ROD, <br /> the selected remedies for SWMUs 2, 3, & 33 presented in the ROD should consist of conducting <br /> excavation and disposal to meet the final cleanup levels. The statutory determinations presented in <br /> Section 10.0 of the ROD should also be modified according to these selected remedies. <br /> As we emphazised during the 17 March 1997 meeting, we do not necessarily consider funding <br /> limitations for the planned removal actions to be an acceptable part of any future technical and <br /> economic feasibility analysis for these sites. Once an acceptable technical and economic feasibility <br /> analysis is presented and approved by the agencies, after the site-characterization has been completed, <br /> the ROD may be revised. In addition, the ROD may need to be modified to include construction of <br /> an on-site soils management cell at the present location of the industrial waste lagoons to dispose <br /> of stockpiled soils removed if construction is completed as part of the proposed removal action <br /> alternative for SWMUs 2 and 3. An ESD to revise the ROD may be necessary. <br /> For SWMU 33, Section 9.6.2.1 states that "All VOC contamination associated with SB 108 (Area 1/ <br /> B 10) and SB431 (SWMUs 20/23) will be addressed through the remedy for the Group A sites." <br /> This conflicts with text in Section 9.5.5.2 which indicates this contamination will be addressed by soil <br /> vapor extraction conducted as part of the selected remedy for SWMUs 20/23. Section 9.6.2.1 <br /> should be modified to refer to the remedy for SWMUs 20/23. Language should be added to clarify <br /> that cleanup levels for VOCs remediated in areas of SWMU 33 (the IWPL) will be specified as part <br /> of the selected remedy for SWMUs 20/23. <br /> We are available to discuss our comments as soon as possible. We strongly suggest that DDRW Tracy <br /> schedule a scoping meeting to focus on re-organizing the ROD and responding to our comments. We <br /> believe the ROD process will benefit greatly by re-submitting a draft version of the ROD rather than <br /> proceeding with a Draft Final. If you have any questions, please contact me at (916) 255-3065. <br /> 01 <br /> Karen Bessette <br /> Project Engineer <br /> KAB:kb <br />