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STATE OF CALIFORNIA-Environmental Prote*Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CEN RAL `ALLEY REGION <br /> 344;„_kotier Road, Suite A i <br /> UN,Sacr.+nento, CA 95827-3098PHONE: (916) 255-3000 <br /> DOD FAX: (916) 255-3052 <br /> 12 November 1992 �( <br /> R NOV t 8 1492 <br /> Mr. Abel Haines <br /> Environmental Protection Office ENVIRUivlwt+vim, <br /> Bldg. 231, Tracy Location PER MIT/SF.RVICtrr <br /> Defense Distribution Region West <br /> P. 0. Box 960001 <br /> Stockton, CA 95296-0250 <br /> DRAFT FINAL FEASIBILITY STUDY (FS) REPORT AND PROPOSED PLAN FOR OPERABLE UNIT <br /> NO. 1, DEFENSE DISTRIBUTION REGION WEST (DDRW), TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Final FS Report and Proposed Plan for Operable Unit <br /> No. 1 (OU-1) at DDRW, Tracy submitted on 13 October 1992. It appears that <br /> these documents have been revised to reflect the Board's comments on the draft <br /> versions of these reports. We have some outstanding concerns and comments <br /> which are briefly listed below and are discussed in more detail in the <br /> enclosed memorandum. However, in spite of these concerns, we approve of the <br /> Draft Final FS Report and Proposed Plan due to the good faith effort and <br /> cooperation shown by DDRW, Tracy in the past. <br /> 1 . The response to our request to analyze the costs associated with cleanup <br /> to different aquifer cleanup levels was unsatisfactory. Because DDRW, <br /> Tracy has retracted the originally proposed aquifer cleanup levels, <br /> compliance with our applicable or relevant and appropriate requirements <br /> (ARARs) cannot be assured. We question DDRW, Tracy's rationale for <br /> accepting DDRW, Sharpe's proposed aquifer cleanup level for <br /> tetrachloroethylene (PCE) of 0.5 micrograms per liter (µg/1 ) . This <br /> concentration is not based on the 10-6 cancer risk estimate. We believe <br /> that the aquifer cleanup level for PCE should be based on a valid water <br /> quality criteria. <br /> 2. Aquifer cleanup levels for dieldrin, carbon tetrachloride and chloroform <br /> should not be established for OU-1. We do not concur with the proposed <br /> effluent treatment standards for most of the volatile organic constituents <br /> (VOCs) of concern listed in Table 2.2-6 and believe that there is still <br /> confusion between the treatment standards and the aquifer cleanup levels. <br /> Best available technology (BAT) should be used for the effluent treatment <br /> standards for VOCs. <br /> 3. We do not concur with the identification of some of the ARARs in Tables <br /> 2.2-3 and 2.2-4. We have provided comments on these Tables. <br /> 4. The evaluation of disposal alternatives was not thorough. We maintain <br /> that other disposal options, including ponding, irrigation and surface <br />