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3. The Annual Monitoring Report as a primary document requires responses to comments, <br /> but in last year's report (2000 Annual Monitoring Report), the responses to regulatory <br /> comments were not included in the Final version. Please include a table of regulatory <br /> comments and responses in the Final version of the 2001 Report. <br /> SPECIFIC COMMENTS <br /> 1. Section 4.2.4.2, Page 4-3: The Report states that phthalates were detected in five wells <br /> during the 2001 sampling event (Solid Waste Management Unit [SWMU] 2, SWMU 3, <br /> SWMU 7, SWMU 8, and SWMU 20), but the last sentence of this section implies that the <br /> detections were due to laboratory contamination. While phthalates may be attributable to <br /> laboratory or field contamination at some sites, they are common contaminants at <br /> disposal sites (landfills, bum pits), and the Record of Decision (ROD) for the Tracy site <br /> set soil cleanup standards for the burn pits at Solid Waste Management Unit (SWMU) 7 <br /> and SWMU 8, and the sewage lagoon at SWMU 2. In addition, the ROD set 10 ug/L as a <br /> Groundwater Concentration Requiring Evaluation for bis(2-ethylhexyl) phthalate (DEHP) <br /> at SWMU 7, SWMU 8, SWMU 2, and SWMU 3. DEHP was reported as high as 53 ug/L <br /> at SWMU 7, well above the ROD-specified concentration. Please replace the statement <br /> about common laboratory contaminants with a statement naming the SWMUs as the <br /> likely source of phthalates. <br /> 2. Table 4.1-2, Page 4-15: The table presents only primary MCLS and implies that no <br /> secondary MCLS have been established for the listed chemicals. Many of the metals such <br /> as iron and zinc have secondary MCLS. Please revise the footnote to define MCL as the <br /> primary maximum contaminant level. <br /> 3. Table 4.1-2, Page 4-15: The table lists the MCL for arsenic as 0.050 milligrams per liter <br /> (mg/L). On October 31, 2001, EPA decided to implement a revised MCL for arsenic of <br /> 0.010 mg/L. Although arsenic is not a chemical of potential concern in groundwater at <br /> the Tracy site, the water quality standard used for comparison of monitoring results <br /> should be the latest MCL. Please revise the MCL for arsenic to 0.010 mg/L. <br /> 4. Table 4.1-2, Page 4-15: The table lists the MCL for lead as not established. As we <br /> pointed out on last year's report, lead has an established MCL of 0.015 mg/L. Please <br /> revise the table to include the lead MCL of 0.015 mg/L. This comment also affects Table <br /> 4.1-3. <br /> 5. Section 7.3.2, Page 7-2: The text recommends evaluation of air-to-water ratios in the <br /> GWTP2 air strippers, using the same wording as last year's report (Section 6.3.1, page <br /> 6-2). However, Table 5.2-1 indicates that the air flow problem at GWTP2 was addressed <br /> in November 2001. Please revise this section in the next version of the Report to discuss <br /> the results of the repairs made at GWTP2. In particular, present an evaluation of whether <br /> 2 <br />