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18 . Page 2-34, Section 2 .3.2.2, second paragraph <br /> Address the sites that were thought, in the Environmental <br /> Monitoring Systems Laboratory (EMSL) report, to be drum <br /> storage areas. State if these areas were storing hazardous <br /> wastes or products with hazardous constituents. <br /> Historic drainage into, and out of the storm drain lagoon <br /> (SWMU No. 4) was also listed in EPA's review as having <br /> potentially contaminated soils. Propose appropriate <br /> sampling. <br /> 19. Page 2-38, Section 2.3.4.14 <br /> State if there have been any violations of the air permits <br /> at the fumigation chambers. <br /> 20. Page 2-43, Section 2 .4.6. 1 <br /> State at what depth these soil samples were taken. Also, <br /> some contaminants may be leached down into the shallow <br /> groundwater via rainstorms. Explain how DDRW-Tracy will <br /> investigate this possibility. <br /> 21. Page 2-43 and 2-44, Section 2 .4.7. 1 <br /> It is possible that the pipeline has leaked into the soil <br /> and groundwater. Soils sampling and analyses must <br /> necessarily become a part of this overall effort prior to <br /> completion of the RI. Propose appropriate investigation <br /> work/tasks. <br /> 22 . Page 2-48, Section 2 .5.5 <br /> The Subpart S of 40 CFR 264 is a TBC for soils, air and <br /> groundwater. Subpart S provides contaminant-specific risk- <br /> based levels for many contaminants of concern in all media. <br /> (See also General Comment No. 10. ) Include a discussion of <br /> Subpart S. <br /> 23 . Page 2-57, Section 2 . 6. 0, second sentence <br /> The sentence should read "The objective of the Baseline Risk <br /> Assessment . . . . " <br /> Explain the OSWER Directive 9355. 0-030 in more detail. <br /> 24 . Page 2-57, Section 2. 6. 1, second sentence <br /> The sentence should read "Only . . .can be used to <br /> characterize current or potential exposure pathways. . . " . <br /> 25. Page 3-2, Section, 3. 1. 0.2 <br /> This paragraph states 32 of the 33 USTs were removed as part <br /> of the three-phase effort. One UST was abandoned in place, <br /> phase I removed 17, phase II removed 12 , and phase III <br /> removed 1. Added together (1+17+12+1) they equal 31 not 32 <br /> as stated. This might explain the discrepancy in the <br /> volumes of waste oil noted in General Comment No. 24 . <br /> I-11 <br />