Final Remedial Action Completion Report for the ... - Rvaap.org

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Cmt.# A-46 Page # Line # 27, 31, 33 and 34 Section 3.2.3, line 18 New Page or Sheet Comment wells are not already existing. Would “baseline” or “existing” be a better word choice? • Line 31. Remove “-“ after the word “one”. • Line 33. Revise “redevelopment were accomplished…” A-47 General Was the “Ravenna full suite”, including pesticides and herbicides, analyzed for 10% of samples? Even if the results are in appendix, please address in the report text as well. A-48 A-49 Section 3.2.8, lines 22-23 Section 3.2.8 Line 23- 24 Recommendation Response • Line 31: “-“ will be removed after the word “one” in line 31. • Line 33: This sentence will be revised to state”…redevelopment were completed as required….” • Line 34: reference to section 4.3.3.3.11.1 in the Facility-Wide Sampling Plan is correct. Line 34. Reference to section 4.3.2.3.11.1 is made. Please verify that this is correct. Change “form” to “from”. “form” will be changed to “from”. Understand the sentence, but it seems awkward. Would the text read better if it stated that “..the purpose of the initial groundwater sampling activities was to identify presence of contaminants in groundwater prior to initiation of Shaw construction activities…”? It would be helpful of the MCLs and secondary standards Shaw Environmental, Inc. 35 of 39 Section 3.2.5 Field Quality Control Sampling Procedures states “Duplicate samples were collected at a frequency of 10% of the field sample collected”. This sentence will be revised to state “Duplicate samples for the full suite including pesticides and herbicides were collected at a frequency 10% of the field samples collected.” Shaw will revise this sentence to state the following: “The purpose of the initial groundwater sampling activities was to identify presence of contaminants in groundwater prior to initiation of Shaw construction activities.” The MCLs, secondary standards, Region 9 PRGs and RVAAP
Cmt.# A-50 A-51 A-52 Page # Line # Section 3.2.8, page 3-5, line 15 Section 3.3.4 Section 3.3.6, line 31 and Section New Page or Sheet Comment were identified in the baseline groundwater data table in Appendix B. Should “taken” be “sampled”? Check comma and semicolon usage. States that a NOT will not be submitted until all areas are stabilized and vegetation is established. Is Shaw not proposing to skip vegetation of those areas which are likely to be disturbed by the BRAC contractor during slab removal? Shaw may have to reassess timing of NOT submittal, particularly if seeding is delayed until after slab removals are complete. Recommendation Report text change is not needed. Regardless of who completes seeding, the NOT submittal should not occur until after final stabilization is complete. Response background concentrations have been included in the groundwater tables for comparison purposes. This section has been revised extensively to discuss results in comparison to the RVAAP criteria per comments by Rick Hockett. Shaw will issue text for review prior to issuing the Draft report. The NOI only covers activities performed by Shaw as part of the remediation action for the soils and dry sediments and does not address impacts to soils disturbed by others. It was originally Shaw’s intention to restore all areas disturbed during remediation activities; however, Shaw does not consider itself to be responsible for excavation areas that were backfilled and reseeded and then disturbed by the BRAC contractor performing slab removal. Shaw intends to return to the outstanding areas requiring seeding at the beginning of May 2008 in order to take advantage of the growing season. Once vegetation begins to establish itself, Shaw will submit for the NOT for those areas recently seeded and incorporate language in the NOT that other areas are considered complete by Shaw and since there has been subsequent follow on work by the Army. Delete “-“ after “on”. “-“ after “on” will be deleted on this line. Shaw Environmental, Inc. 36 of 39
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