DERR-2025-003236

Responses to DERR Review Comments
Lelis Transmissions, VCP Site 128
General Comments
1. Once the Site Characterization Report has been revised and accepted, please draft a Remedial
Action Plan (RAP) for DERR to review.
RESPONSE: Agreed.
2. The DERR has developed a Fact Sheet to assist customers developing cleanup plans under the VCP,
as well as tips for building demolition. Please see the included links as a resource.
RESPONSE: Agreed.
3. The DERR is not opposed to the use of silica gel as a component of TPH/TRPH analysis for any
future sampling. For Comparability purposes, the sampling procedures and analysis should be
consistent between sampling events.
RESPONSE: Agreed.
Technical Comments
1. Page 9, Discussion, Paragraph 2: Lab results for fractionation analysis for MW-6 seems to suggest a
higher fraction of longer chain aliphatics (see Technical Comment #4). Please ensure that the
conclusions in this paragraph are consistent with the table corrections noted below.
RESPONSE: The conclusions in this paragraph remain consistent with the table corrections.
Additionally, a footnote is added for clarification regarding the non-detect PAH constituents.
2. Page 9, Discussion, Paragraph 3: Please clarify if “targeted removal of subsurface contaminant
source structures” includes the Oil Water Separator, sumps, drains, hydraulic lifts, and other relevant
features.RESPONSE:These items are included; a footnote is added for clarification.
3. Page 9, Discussion, Paragraph 3: Please clarify if “other management controls to be detailed in a
Site Management Plan” would include groundwater monitoring.
RESPONSE:Groundwater monitoring is included; text adjusted accordingly.
4. Table 2: Please check this table against the lab results, particularly for MW-6. A value has been
incorrectly entered for C11-C13 Alkyl Naphthalenes that has shifted subsequent values for C13-C16,
C17-C21, and C22-C35 Aliphatic Hydrocarbons into the wrong rows. The lab results on page 35 of the
report indicate a concentration of 4,190 ug/L for C22-C35 Aliphatic Hydrocarbons.
RESPONSE: Table has been corrected.
5. Page 20, Site-Specific Cleanup Level Table: aliphatic fractionation data has been attributed to MW-4
instead of MW-6 on some rows. Please revise.
RESPONSE: Table has been corrected.