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Draft OU-1 ROD Memorandum -5- 4 June 1993 DDRW, Tracy State Board Resolution No. 91-33; Inland Surface Water Plan. The Inland Surface Water Plan does not need to be listed as an ARAR because DDRW, Tracy does not plan to discharge the treated ground water from OU-1 to surface water. Table 10-2.2 (page 5) should be revised to delete Plan. 6. Remedial Design (RD) . The Draft ROD does not acknowledge whether or not numerical modeling will be used as a predictive tool to aid in the RD. We believe that the ROD should have qualifying statements regarding the conceptual plans for the extraction, treatment and disposal systems that may be revised from that presented in the ROD. This qualifying statement should include reference to the use of modeling, the need for additional field work or other methods that will be used by DDRW, Tracy in the RD. With these statements the ROD will more accurately present the current and future plans for the ground water remedial action. As previously stated, we do not support a conceptual extraction system in which all of the extraction wells are placed at the leading edge of the plume rather than placing some of the wells in the "hot spot" areas within the plume. MINOR COMMENTS Section 1.4.2 (Page 1-3). This section states that approximately 1700 people work at DDRW, Tracy. This figure should be revised downward as beginning in Autumn 1992, there have been significant staff reductions at the DDRW, Tracy site. Section 1.5.1 (Page 1-3). The Upper Tulare and Lower Tulare is referred to as a "Zone". This designation should be changed to Members of the Tulare Formation. Section 1.5.4 (Page 1-4) . This section references Well No. 4 as a main supply well for the base. This well is scheduled to be abandoned. New wells Nos. 8 and 9, in addition to Well No. 7 are the supply wells for the site. This section should be modified to incorporate this information. This section also indicates that private off-site wells are used for agricultural and domestic purposes. This section should be revised to state that nearby off-site wells are also used for industrial purposes. Section 2.2.2.1 (Page 2-2) . The 1980 technical report prepared by the U. S. Army Environmental Hygiene Agency (AEHA) , is not based out of Fort Meade, Maryland, as referenced in this section, but is out of Aberdeen Proving Ground, Maryland. This section should be revised to reflect this. Section 2.3 (Page 2-5) . This section is designated as the "History of CERCLA Enforcement Activities". The title of this section should be changed from "enforcement" to "regulatory" as there have been little to no enforcement actions taken at this site. Section 2.3.2 (Page 2-5). The well monitoring program is being performed by Montgomery Watson. The text of this section should be revised from J. M. Montgomery to reflect the recent change in the company's name.