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Review of Response to Specific Comment 3 (Section 2.1.2, paragraph 2.1.2.1, page 2-1) <br /> Investigation Scope: Since groundwater contamination and associated risks (i.e., vapor <br /> intrusion) are to be addressed under the operable unit(OU) 1 remedial action,the SAP is exempt <br /> from requiring information pertaining to current and future groundwater use, quality or hydraulic <br /> connectivity. Consequently,the response appears to adequately address this comment. <br /> Review of Response to Specific Comment 4 (Figure 4, page 2-7) Conceptual Exposure <br /> Model: The response appears to partially address the comment. While the response indicates <br /> that surface water present in OU 2 is not likely to be impacted by site contaminants via transport <br /> pathways such as runoff, the comment does not address whether any sampling has been <br /> conducted specifically on the percolation ponds. That is, the rationale underpinning the <br /> aforementioned prediction regarding surface water present within OU 2 appears to be based on <br /> site documentation. However, it is not clear whether site documentation entails any empirical <br /> data. Without the support of empirical data, there is concern that a potential exposure pathway <br /> for receptors, such as an on-site worker, recreational adult/child or trespasser youth may be <br /> eliminated from further evaluation. Please provide specification as to the basis for possibly <br /> eliminating surface water impacted by site activities from the conceptual exposure model. <br /> Review of Response to Specific Comment 5 (Section 2.3.7.2, page 2-26) Waste Disposal: <br /> The response indicates that the SAP will contain revised text pertaining to waste management <br /> practices. Although the response is suggested to be adequate, complete evaluation of the text <br /> revisions can only be attained with review of the next version of the SAP. <br /> Review of Response to Minor Comment 1: The response indicates that the text has been <br /> revised to clarify the"P" designation in Appendix C. While the response to this comment <br /> appears adequate, complete evaluation of this response will be conducted when the modified text <br /> in Appendix C has been provided for EPA review. <br />