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EPA Comments on the <br /> "Draft No Further Action for Defense Site Environmental Reporting and Tracking <br /> System 72 (DSERTS 72) " <br /> Tracy Defense Depot <br /> GENERAL COMMENTS <br /> 1. It is unclear how the "Draft No Further Action for Defense Site <br /> Environmental Reporting and Tracking System 72 (DSERTS 72) " (the Report) <br /> fits into the Comprehensive Environmental Response, Compensation and <br /> Liability Act (CERCLA) process. It appears that DDJC-Tracy bases the <br /> No-Further-Action determination for DSERTS72 on the findings presented <br /> in the Report; however, the Report does not follow the format of a <br /> Record of Decision (ROD) , a ROD Amendment, an Explanation of Significant. <br /> Difference (ESD) or an Action Memorandum. In addition, DSERTS 72 was <br /> discovered after the Site-Wide ROD was signed and, therefore, is not <br /> included in the ROD. For clarity, please explain how the Report fits <br /> into the CERCLA process and how this action will be documented in the <br /> required CERCLA decision document. <br /> 2 . Appendix B shows that DDE was detected at 0.4 ug/l, DDT at 0.7 ug/1, and <br /> dieldrin at 0.1 ug/l in the groundwater sample collected from <br /> SB1084GWOOIDS. However, the Report does not discuss these <br /> concentrations with respect to cleanup goals and human health risks with <br /> respect to groundwater (the California State Action Level for dieldrin <br /> is 0.05 ug/l; the tap water PRGs for DDX range between 0.20 ug/l and <br /> 0.28 ug/1) . For clarity, please revise the Report to indicate what the <br /> cleanup goals for groundwater are. In addition, if contaminated <br /> groundwater is being addressed by groundwater remediation at SWMUs 2 and <br /> 3, please indicate this in the Report. <br /> 3 . In Appendix A, cleanup goals are listed for some chemical compounds. <br /> For example, the cleanup goal for dieldrin in soil is listed as 0.37 <br /> mg/kg (Page 3) . However, the industrial Preliminary Remediation Goal <br /> (PRG) for dieldrin is 0.15 mg/kg. For clarity, please indicate how the <br /> compounds of concern were selected and how cleanup goals for DSERTS 72 <br /> were developed for all the compounds of concern. <br /> 4. In Appendix A, the October 1999 data for selenium show that the <br /> reporting limits sometimes exceed the "cleanup goal" of 0.616 mg/kg. <br /> Although the cleanup goal is much lower than the PRG for selenium, the <br /> reporting limits did not appear to have reached the data quality <br /> 1 <br />