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resolve the conflict. The technical and economic <br /> analysis appears to be flawed in that it does not <br /> clearly demonstrate the economic differences in <br /> achieving either cleanup goal. Additionally, the <br /> proposed institutional controls will do nothing to <br /> meet F/S cleanup numbers. DDRW Tracy must re-evaluate <br /> their position with these proposals or develop a new <br /> alternative to resolve the conflict between removal <br /> action design documents and soil cleanup numbers in <br /> the Comprehensive F/S for these sites. Otherwise DTSC <br /> can not at this time consider this to be a final <br /> comprehensive ROD. <br /> The Draft ROD must also address the fact that these <br /> removal actions have not yet been undertaken. This is <br /> a major concern of DTSC's and the primary reason we <br /> may not consider this a final ROD for DDRW Tracy. <br /> Without a mechanism to resolve the conflict between <br /> the differing clean up numbers, we have to assume that <br /> an additional ROD will have to be developed after the <br /> removal actions are completed <br /> 2 . The Draft ROD, Section 9, is in conflict with soil <br /> cleanup levels presented in Table 8-13 of the <br /> Comprehensive F/S for sites other then those <br /> previously discussed. Other remedial sites include <br /> Solid Waste Management Unit (SWMU) 7 , the Drum Storage <br /> Area, and Building 30. The Draft ROD should be <br /> revised to reflect the cleanup levels in the F/S. <br /> 3 . Technical discussions have lead DTSC to believe <br /> that DDRW Tracy has suspended their plans to develop a <br /> waste management cell on site. If this is indeed the <br /> case, the Draft ROD must be modified to reflect this <br /> and all references to the management cell should be <br /> stricken or it should be noted that it is no longer a <br /> viable option. The ROD must also be clear as to the <br /> fate of soil that would have been contained at the <br /> management cell. <br /> 4 . The proposed action for the storm drain lagoon <br /> does not meet the F/S cleanup numbers or the remedial <br /> action objectives of the Draft ROD. DDRW Tracy should <br /> resolve this conflict in the Draft ROD or propose an <br /> alternative cleanup action other then a one time <br /> scrape of three inches at the site. <br /> 3) The Draft ROD is lacking complete development of the <br /> following required sections: <br /> 1. The ROD must consistently re-affirm or re-evaluate <br /> previous decisions made for the installation <br /> restoration program at DDRW Tracy, specifically OU-1 <br /> and the explanation of significant difference (ESD) . <br /> JP.bdi <br /> m:\smp-omf\hong\pinasco\JP33W.077 <br />