SITE INFORMATION AND CORRESPONDENCE

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ATTACHMENT EPA Comments on Comprehensive Remedial Investigation/Feasibility Study - Phase I Site Characterization Report/Analytical Data Report (Dated December 1993) Defense Depot Region West - Tracy (DDRW-Tracy) GENERAL COMMENTS 1. Written Response to Comments Please be aware that Section 7.7 (e) of the FFA states "On a draft secondary document DDRW-Tracy shall, within sixty (60) days of the close of the comment period, transmit to EPA, DHS and RWQCB its written response to the comments received." 2. Phase II field sampling details While the Site Characterization Report identifies data gaps, field sampling details are not provided for sites recommended for Phase 2 investigation (i.e., SWMUs 1, 2 (South Pond), 4, 10, 10A, 11, 14, 20, 23, 24, and 27, and Areas 1 and 2). Eventually, more detailed information will be needed on the number and location of borings and wells, intervals for sampling, and well screening. It is EPA's understanding that this information, along with the rationale to support the proposed features, will be presented in the work plan that is currently due for submittal on May 24, 1994. 3. Phase 11 Recommendations Consistent with one of the report's stated objectives, the report provides recommendations for Phase II investigations. Section 8 recommendations relate to further characterization of the currently identified SWMUs. What is not clear, however, is the planned mechanism or work plan in which DLA will task RI investigative efforts which may fall outside of Phase H work, as it is currently defined in this report.' For example, pending review of the risk assessment work plan, newly collected data, and existing data, follow-up field work and/or data analysis may be identified (e.g., sampling to address risk assessment /ecological assessment data gaps, 1 Note that it appears that the draft SOW for Phase 11, received by EPA on February 4, 1994, similarly lacks the flexibility to add additional RI tasks. EPA 14FEB94 1/10