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,•�°mow t CALIFORNIA REGION®WATER QUALITY CONTROL BOARD Cal/EPA CENTRAL VALLEY REGION 1 3443 Routier Road,Suite A I )/ .,1 v Sacramento, CA 95827-3003 J l�I '7 Phone(916)255-3000 ) yam FAX(916)255-3052 �/ "' Pete Wilson,Governor 26 January 1998 Ms. Hortensia Muniz Department of Toxic Substances Control 10151 Croydon Way, Suite 3 Sacramento, CA 95827-2106 DRAFT FINAL SITE-WIDE COMPREHENSIVE RECORD OF DECISION, DEFENSE DISTRIBUTIONSAN JOAQUIN(DDJC) TRACY, SAN JOAQUIN COUNTY We have reviewed the Draft Final Site-Wide Comprehensive Record of Decision(ROD) for DDJC Tracy, submitted 15 December 1997. We find the ROD to be thorough and well presented. We commend the Defense Logistics Agency,particularly the Project Manager, Mr. Marshall Cloud, for dilligence, reasonableness and responsiveness during the development of the ROD and during the previous Remedial Investigation/Feasibility Study phases for DDJC Tracy. We appreciate Radian's extensive work to prepare and revise this complex decision document. In general, we concur with the ROD; however, some changes are necessary prior to deeming the ROD final. Our remaining concerns are presented as general comments below,followed by specific comments which pertain to modifying the text of particular sections to clarify points or correct errors noted. We believe that the project managers have basic agreement on responses to our comments;therefore,they should be easily addressed by DDJC Tracy. As agreed during the conference call held on 9 January 1998 to discuss ROD issues, we expect to receive slip pages which modify the DDJC Tracy ROD to address these comments as soon as possible. We are available to discuss or clarify any of our comments to facilitate a quick turn around time on the revised final document. General Comments 1. Water Quality Objectives. The ROD clarifies that groundwater monitoring will be continued on a regular basis as part of each selected remedy to evaluate any impacts to water quality and to assess the effectiveness of each remedial action. The ROD states that evaluations of all groundwater results and trends that exceed background concentrations will be included in the Annual Well Monitoring Report of the Tracy Well Monitoring Program. For clarity, we request that this section of the ROD include a table showing background ground water concentrations for each constituent of concern at DDJC Tracy. The ROD further states that DDJC Tracy will evaluate the appropriateness of the selected remedy in cases where site-specific water quality objectives are exceeded. As we discussed during the 9 January 1998 conference call, the water quality objectives identified in the ROD should be updated based on the latest published numerical limits necessary to protect the beneficial uses of ground water at DDJC Tracy. We request that the beneficial use protective limits presented in the attached table (Attachment 1)be included in each selected remedy for the constituents requiring ground water evaluation at the particular site. In cases where the constituent of concern(CoC)has not impacted ground water at a site or where Recycled Paper Our mission is to preserve and enhance the quality of California's water resources,and ensure their proper allocation and efficient useJor the benefit of present and future generations.