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EPA Comments on the Draft Remedial Action Report for Institutional Controls at South Balloon Area January 2002 SPECIFIC COMMENTS 1. Section 1.4.7, Page 1-2: The text states that the Department of Defense (DOD) ...will ensure that the documents transferring real property out of federal control reflect the land use restrictions and enforcement mechanisms specified in the remedial decision document." The DDJC Sharpe Site is a post-ROD site and the Remedial Action Report (RAR) for Institutional Controls is a post-ROD document. The reference to "remedial decision document' would be more clear if it pluralized the term "document' (i.e., documents) and specifically identified the January 2002 Remedial Action Report for Institutional Controls (ICs). Please revise Section 1.4.7 of the RAR to pluralize the word "document" in the above referenced passage and to specifically reference the January 2002 Remedial Action Report for Institutional Controls. 2. Section 3.2.1.3, Page 3-2: The text states that "the DDJC-FA Environmental Project Manager shall notify the signatory parties to the FFA at least 90 days before the commencement of any demolition or construction activities that could expose contaminated soil." As stated in Section ES.2 of the Executive Summary,the intent of the ICs required by the California Department of Toxic Substance Control (DTSC) is "...to ensure that the proper precautions are taken during future disturbances of the surface soils and/or further remediation in the event land use is ever changed." The language provided in Section 3.2.1.3 is not sufficiently specific in regard to how a determination will be made whether the proposed activities will expose contaminated soil. Section 3.2.1.3 should be revised to provide more information on the references and procedures that will be used to determine whether"contaminated soil" will be disturbed by proposed activities. Section 4.2.1 of the Addendum to the Installation Master Plan should also be revised, accordingly. 3. Section 3.4.3, Page 3-3: The text describes the Five-Year Review Report that will be prepared to assess the ICs at the South Balloon Area. This section does not provide a provision for sending a copy of the Five-Year Review Report to the signatories of the FFA. The previous section of the Report, Section 3.4.2, Annual Inspection Report, does commit to providing copies of the Annual Inspection Report to the signatories of the FFA so it appears that the absence of similar language for the distribution of the Five-Year Review Report may be an oversight. Please revise Section 3.4.3 of the RAR to describe