SITE INFORMATION AND CORRESPONDENCE

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STATE OF CALIFORNIA - Environmental Prote tion Agency PETE WILSON, Governor CALIFORNIA REGIONAL WATER Q0VTY CONTROL BOARD , CENTRAL VALLEY REGION 3443 Routier Road, Suite A Sacramento, CA 95827-3098 PHONE: (916) 255-3000 DOD FAX: (916) 255-3052 12 August 1994 Mr. Jim Pinasco Department of Toxic Substances Control 10151 Croyden Way, Suite 3 Sacramento, CA 95827-2106 DRAFT COMPREHENSIVE REMEDIAL INVESTIGATION/FEASIBILITY STUDY - PHASE II WORK PLAN, DEFENSE DISTRIBUTION REGION WEST (DDRW), TRACY, SAN JOAQUIN COUNTY We have reviewed the Draft Comprehensive Remedial Investigation/Feasibility Study (RI/FS) - Phase II Work Plan (Draft Phase II Work Plan) for DDRW, Tracy submitted 13 June 1994. Most of our concerns with the Draft Phase II Work Plan were resolved during the Project Manager's Meeting held on 19 July 1994 to discuss Phase II field activities, and the followup teleconferences of 27 and 28 July 1994 held to discuss the need for further investigation of specific solid waste management units (SWMUs). We appreciate receiving a copy of the draft correspondence, letter to Mr. Steve Light of the Army Corps of Engineers from Ms. Jamie Atwood of Montgomery Watson, dated 25 July 1994. This letter is a complilation of the general and site-specific modifications to be made to the Draft Phase II Work Plan as agreed upon by all parties attending the 19 July 1994 meeting. We have also received copies of the letters from Ms. Atwood to Mr. Light, dated 27 and 28 July 1994, which summarize the action items tentatively agreed upon during the teleconferences held on those dates. The Draft Phase II Work Plan is acceptable once modified in accordance with the general and site- specific items presented in the foregoing mentioned letters. In addition, we have the following remaining comments which must be addressed in the revised version of the Draft Phase II Work Plan. GENERAL COMMENTS Waste Extraction Test Procedure Using Deionized Water (DI-WET): It is our understanding that the site-specific DI-WET analyses specified in Ms. Atwood's 25 and 28 July 1994 letters to Mr. Light, are to be conducted in addition to the DI-WET analyses proposed in the Draft Phase II Work Plan. Each DI-WET analysis should be conducted on the sample with the highest concentration of the constituent of concern, based on the analytical data obtained from all soil samples collected from a site prior to implementing the DI-WET procedure. At sites where the required analytes include Polychlorinated Biphenyls (PCBs), pesticides, and metals, the