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REVIEW OF THE DRAFT <br /> SITE-WIDE COMPREHENSIVE RECORD OF DECISION (ROD) , <br /> DEFENSE DISTRIBUTION REGION WEST (DDRW) , TRACY SITE <br /> Overall the Draft ROD has a number of deficiencies that <br /> need to be addressed prior to being approved for signature. <br /> Our comments identify those deficiencies in terms of their <br /> conflict with previous documents produced for DDRW Tracy's <br /> environmental program or their insufficient compliance with <br /> State or Federal Statues. <br /> General Comments <br /> 1) Development of the analysis for ARARs: <br /> Presentation of potential ARARs in the Draft ROD was <br /> both sparse and confusing. In general we recommend <br /> that DDRW Tracy re-evaluate it's ARARs analysis. <br /> Specific concerns with the ARARs analysis are: <br /> 1. ARARs presented in previous remedial documents, <br /> specifically the Final ROD for Operable Unit 1 (OU-1) <br /> and the Comprehensive Feasibility Study (F/S) , were <br /> provided in a more clear and concise manner. DTSC <br /> would recommend that DDRW Tracy present their proposed <br /> ARARs in a table format similar to that in the fore <br /> mentioned documents. This would allow presentation of <br /> the remedial action and citation of the ARARs to be <br /> displayed in one section for easy review. <br /> 2 . DTSC also questions how potential ARARs for the <br /> Draft ROD were selected. The specific ARARs presented <br /> in Comprehensive F/S appear to be more numerous. We <br /> request that DDRW Tracy address the apparent <br /> difference in the ARARs presented in the Comprehensive <br /> F/S and the Draft ROD. <br /> 2) Conflicts in cleanup levels between the Comprehensive <br /> F/S and the Draft ROD with respect to removal actions, <br /> remedial actions, and potential changes to planned <br /> remedial activities: <br /> 1. Soil cleanup numbers developed in removal action <br /> design documents and soil cleanup numbers in the <br /> Comprehensive F/S are in conflict. Removal actions of <br /> concern are the lined ponds, the industrial pipeline, <br /> and the sewage lagoons. The removal action documents <br /> propose cleanup numbers not as stringent as those in <br /> the F/S. The conflict between the two documents needs <br /> to resolved. <br /> The Draft ROD uses a combination of technical and <br /> economic analyses and institutional controls to <br /> JP.bdi <br /> m:\smp-omf\bong\pinasco\JP33W.011 <br />