REMEDIAL ACTION WORK PLAN OPERABLE UNIT 2, LANDFILL ...

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Attachment A
Responseto Commentsfrom
CaliforniaIntegratedWaste Management Board
Review of the Remedial Action Work Plan, April 3, 1996
REMEDIAL ACTION WORK PLAN
OPERABLE UNIT 2 LANDFILL CLOSURE
FORT ORD, CALIFORNIA
TOTAL ENVIRONMENTAL RESTORATION CONTRACT
DACW05-95-D-0001
DELlVERY ORDER NO. 0003
General Response to Comments:
The USACE, through the TERC contract, is constructing the landfill cap in accordance with
approved documents including the Record of Decision (ROD) and approved Harding Lawson
Associates (HLA) designs. The Remedial Action Work Plan (RAWP) is the primary deliverable,
not the HLA design. However the design remains the same. International Technology
- Corporation (IT) is incorporating constructibility improvements to the HLA design in the
Remedial Action Work Plan (RAWP). These improvements enhance the overall design approved
by the Base Cleanup Team (BCT) and are meant to define those areas which deviate from the
approved design. BCT approval is requested to adapt these improvements to the approved
design.
None of these improvements are changes to the basic design concepts and performance
specifications approved in the HLA design documents. Therefore, no Explanation of Significant
Differences (ESD) amendments are required to the ROD based on these constructibility
improvements. The only ESD required to the ROD is currently under review by the EPA, state
and Regional Water Quality Control Board (RWQCB) which adds cleanup criteria to the areas to
be consolidated.
Language will be added to clearly reference the HLA design docurnents.except as they are
needed by the improvements as shown in the wwp and specifically detailed in Table 6.1,
Constructibility Improvements. Table 6.1 verbage will be enhanced to say that these
improvements are incorporated in the RAWP.
Again, no design changes impact the record of decision. In our opinion, there are no “sweeping
design changes” being proposed. The design, in our opinion, is frozen as capped landfill areas
within a low permeable liner and vegetative cover.
SJ/4-23-96/SACTERC/FTORDOU2/CIWMB
A-1