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COMMENTS REGARDING THE DRAFT <br /> RECORD OF DECISION (ROD) <br /> OPERABLE UNIT (OU) NUMBER 1 <br /> DEFENSE DISTRIBUTION REGION WEST, TRACY <br /> GENERAL COMMENTS <br /> 1) The ROD should establish a consistent definition of the <br /> contaminants that are part of OU - 1. The ROD should further <br /> state the determinations that will be made regarding other <br /> contaminants found at DDRW, Tracy. <br /> 2) The Risk Assessment (RA) has two major constraints: 1) it <br /> considers ground water pathways only; and 2) volatile organic <br /> compounds are the only contaminants of concern. This should <br /> be strongly prefaced at the beginning of the RA section. How <br /> this document will interact with the future base-wide RA <br /> should also be well documented. <br /> 3) The discussion of the ground water extraction system does not <br /> portray the remediation concept agreed to by the regulatory <br /> agencies. The ground water extraction system portrayed in the <br /> Draft ROD provides for a fence line approach which will <br /> achieve plume containment. DDRW, Tracy has agreed with verbal <br /> regulatory comments to develop a total remediation concept <br /> incorporating both hot spot removals and plume containment. <br /> This approach should be reflected in the ROD. <br /> 4) The monitoring program outlined in the Draft ROD consists of <br /> two years of quarterly monitoring followed by bi-annual <br /> monitoring for 28 additional years. A rigid monitoring <br /> program that does not take into account the analysis of real <br /> data is unacceptable. The length and frequency of ground water <br /> monitoring should be based on the effectiveness of remedial <br /> measures as demonstrated by monitoring data. It is <br /> recommended that the monitoring program be re-written to <br /> reflect a more flexible approach. <br /> 5) To assure compliance with applicable or relevant and <br /> appropriate regulations (ARARs) , it is recommended that a <br /> conference call be set up with the appropriate legal counsels <br /> to discuss and agree on the specific ARARs for OU - 1. If <br /> this proves to infeasible to accomplish, another contingency <br /> to assure regulatory agencies' and facility satisfaction <br /> should be developed. <br /> -1- <br />