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July 14, 1997 <br /> . CI <br /> aC I/EPA Mr. Marshall Cloud <br /> Activity Service Center West, Tracy Site <br /> Environmental Protection Branch, ASCW-BE <br /> Department of Building 5-108, Sharpe Location Pete Wilson <br /> Toxic Substances P.O: Box 960001 Governor <br /> Control Stockton, California 95296-0250 <br /> PelerM.Rooney <br /> 10151 Croydon Way REVIEW OF THE DRAFT SITE—WIDE COMPREHENSIVE RECORD OF Acting <br /> Sramete 3 SecretDECISION, DEFENSE DISTRIBUTION REGION WEST, TRACY SITE Environmental Sacramento, CA Environmental <br /> 95827-2106 Protection <br /> Dear Mr. Cloud: <br /> The Department of Toxic Substances Control and the <br /> California Regional Water Quality Control Board, Central <br /> Valley Region (collectively, the State) , have reviewed the <br /> following document: <br /> "Defense Distribution Region West (DDRW) , Tracy, <br /> California, Site-Wide Comprehensive Record of <br /> Decision, Draft", submitted on February 23 , 1997, by <br /> Radian International on behalf of the U.S. Army Corps <br /> of Engineers, Huntsville Division. <br /> For your records, we present our review (see the <br /> attached memoranda with comments) . We have found the Draft <br /> Record of Decision (ROD) to have the following major <br /> deficiencies: <br /> 1) The Draft ROD provides incomplete submissions <br /> regarding Applicable or Relevant and Appropriate <br /> Requirements (ARAB) , comparison of alternatives, and <br /> presentation of the selected remedial actions. <br /> 2) The Draft ROD, as written, does not resolve conflicts <br /> for differing cleanup levels proposed by DDRW Tracy, <br /> in separate documents, for the same sites. <br /> 3) The discussions regarding decisions made outside the <br /> specific scope of this ROD are limited and lack depth. <br /> These deficiencies leave the reviewers with the <br /> concern that this ROD is not comprehensive or final. To <br /> insure that all the State's concerns are met, we recommend <br /> that the draft ROD be revised to address our comments and <br /> be re-submitted for regulatory review prior to the document <br /> proceeding to the draft final stage. The State is <br /> interested in resolving our concerns with DDRW Tracy and <br /> helping to develop a final ROD that satisfies all State and <br /> Federal criteria. <br /> JP. 7m:\smp-omf\ftp ng\pinasco\J P33W.070'!'/ <br /> A rRecyH Pep <br />