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referenced. Please provide the reference where this decision was documented and <br /> approved, as was done for the two changes discussed in the previous bullets. <br /> 2. Section 2.4.2,Page 2-3,fourth bullet: The text states that the potential limits of <br /> excavation might include, "the discovery of a much greater extent or volume of fill or <br /> impacted soil than postulated in the remedy selection process," and includes a reference <br /> to the ROD, but no such statement could be found in the ROD. A statement regarding the <br /> water table as the limit of excavation was found in Section 9.7.4.5 of the ROD, and this <br /> section of the ROD also states that the limits of the disposal area are well defined. Please <br /> delete the statement about greater extent, provide a proper reference for the statement, or <br /> explain where in the ROD this statement can be found. <br /> 3. Section 3.2.7.3,Page 3-9: The text appears to be using the lack of funds as a <br /> justification for backfilling the excavation, but the final total cost was less than the total <br /> cost estimated in the ROD. A phased approach for excavation was presented in a <br /> Technical Memorandum dated April 26, 2001 to help avoid funding shortages. In <br /> addition, based on the meeting minutes from the RPM meeting held on November 19, <br /> 2002, funding issues were never raised as a problem, and further sampling and excavation <br /> were to continue. Please remove all references from the text that the excavation was <br /> backfilled because the budget had been expended. <br /> 4. Section 3.2.7.3, Page 3-9, second bullet: The text states that one of the factors for <br /> "ceasing further overexcavation" was that, based on review of the analytical results, final <br /> vadose zone samples would comply with primary cleanup standards. Although <br /> statements were made at the time that preliminary analytical results were below cleanup <br /> standards, the final results turned out to be above ROD-specified primary cleanup <br /> standards for dieldrin and DDT. Contamination was left in place at concentrations <br /> greater than ROD cleanup standards, which were the cleanup standards in place at the <br /> time analytical results from the final confirmation samples would have been reviewed. <br /> An Explanation of Significant Differences (ESD) was then issued to provide evidence <br /> that raising the cleanup levels would still be protective of human health and the <br /> environment, thereby showing that the contamination left in place would not pose a risk. <br /> Please remove the statement that the preliminary analytical results were less than primary <br /> cleanup standards from the list of factors contributing to ceasing overexcavation, or <br /> qualify the statement to explain why it was thought the final results would not exceed <br /> primary cleanup standards when, in fact, they did. <br /> 5. Table 4-1: The table shows that on November 19, 2002 the RPM team verbally <br /> approved cessation of the excavation. This is inaccurate. EPA's approval to backfill <br /> anything more than the portion of the excavation deeper than 14 feet bgs was never given. <br /> Please remove this statement from the table or qualify it in accordance with the minutes <br /> of the November 2002 RPM Meeting. <br /> 2 <br />