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EPA Comments on the <br /> Memorandum,DDJC-Recommendation for <br /> Modifications to Monitoring Requirements to the <br /> DDJC-Tracy WDR [Waste Discharge Requirements] Permit, <br /> Order Number 98-053 (DACA87-02-D-0004/TO0007-003) <br /> Defense Distribution Depot San Joaquin (DDJC) <br /> Tracy Site, Tracy, California <br /> July 2003 <br /> BACKGROUND <br /> DDJC submitted a memorandum to the Central Valley Regional Water Quality Control <br /> Board (RWQCB), entitled DDJC-Recommendation for Modifications to Monitoring <br /> Requirements to the DDJC-Tracy WDR Permit, Order Number 98-053 (DACA87-02-D- <br /> 0004/TO0007-003), dated July 3, 2003 (the WDR Memorandum). At the request of the <br /> RWQCB, the recommendations contained in the WDR Memorandum were reviewed for their <br /> potential impacts on the DDJC-Tracy Well Monitoring Program and compliance with the DDJC- <br /> Tracy Record of Decision (ROD). These comments address the extraction wells but do not <br /> address the background monitoring wells, which are required to be monitored by the WDR <br /> Permit. <br /> GENERAL COMMENTS <br /> 1. Based on review of the WDR Memorandum, we concur with the proposed deletion of <br /> analysis of all extraction well groundwater samples for carbamate-urea (CU) pesticides by <br /> EPA Method SW8321A and the proposed deletion of analysis of pre-2002 extraction well <br /> groundwater samples for total petroleum hydrocarbons as gasoline (TPH-G) by Modified <br /> EPA Method SW8015. The rationale presented in the WDR Memorandum presents a clear <br /> justification for deletion of these analyses based on lack of detections over time. We do not <br /> concur with the proposed timing of the change in the analytical suite for extraction well <br /> groundwater samples because deleting the analyses beginning in the third quarter 2003 <br /> contradicts previous recommendations developed and published by the DDJC-Tracy <br /> facility and approved by the Regulatory Agencies. Proposed sampling frequencies and <br /> analytical suites for calendar year 2003 were presented in the Final Well Monitoring <br /> Program 2002 Annual Monitoring Report dated May 2003 and the 2003 Well Monitoring <br /> 1 <br />