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ATTACHMENT III <br /> EPA COMMENTS ON THE DRAFT COMPREHENSIVE FS <br /> WORK PLAN (JAN-92) <br /> FOR DDRW-TRACY <br /> GENERAL COMMENT <br /> This Feasibility Study (FS) Work Plan is generic; contrary to the <br /> intent of a work plan, it provides little information as to how <br /> specific tasks will be accomplished. Significant additional <br /> planning needs to occur. Toward this end, EPA is including in <br /> this attachment a copy of OSWER Directive 9355. 3-01FS3 which, <br /> though intended as FS report guidance, describes the information <br /> requirements which this work plan should be trying to address. <br /> SPECIFIC COMMENTS <br /> 1 . Page 5-1, Section 5. 0. 1, 4th bullet: <br /> Nowhere in the plan is the matter of how abandoned wells <br /> will be evaluated and/or potentially remedied discussed. <br /> The other five types of "sites" are at least generically <br /> touched upon, but not the special problem of wells acting as <br /> conduits to contaminate deeper aquifers. <br /> 2 . Page 5-2, Sections 5. 1. 1.2 and 5.1.2 : <br /> The plan indicates that the FS for Underground Storage Tanks <br /> (USTs) will be based upon the Tri-Regional Board Guidance. <br /> This guidance is considered quite stringent in protection of <br /> groundwater, and, from a pragmatic point of view, should be <br /> adequate to protect human health and the environment. <br /> However, normally the FS process requires screening <br /> technologies, development of alternatives, detailed analysis <br /> of alternatives, etc. Looking at the bullets in Section <br /> 5. 1. 2 . 1, it appears that this narrowing down process will <br /> not be done and the FS report will begin with the proposed <br /> remedial action. This bypassing of the usual process might <br /> be accepted for an emergency interim OU action, but usually <br /> not for an FS to select a final remedial action. <br /> 3 . Page 5-3, Section 5. 1.3. 1: <br /> This section for UST sites requiring both soil and <br /> groundwater remediation takes a more commonly seen FS <br /> approach in that a large number of remedial alternatives are <br /> screened. Listed are such soil remedial actions as <br /> excavation, soil aeration, landfilling, venting, <br /> incineration, etc. It is difficult to understand why it is <br /> III-1 <br />