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STATE OF CALIFORNIA-Environmental Protection AOency PETE WILSON Govemor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road,Suite A _ <br /> Sacramento,CA 95827-3098 a - <br /> PHONE:(918)255-3000 y . . <br /> FAX:(916)2553015 <br /> n..m <br /> 1 May 1997 <br /> Mr. Jim Pinasco <br /> Department of Toxic Substances Control <br /> 10151 Croyden Way, Suite 3 <br /> Sacramento, CA 95827-2106 <br /> DRAFT SITE-WIDE COMPREHENSIVE RECORD OF DECISION, DEFENSE DISTRIBUTION <br /> REGION WEST(DDRW) TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the Draft Site-Wide Comprehensive Record of Decision (ROD) for DDRW Tracy, <br /> submitted 3 February 1997. We find the ROD to be incomplete, poorly organized, and too complex with <br /> respect to satisfying the objectives for clearly presenting the final comprehensive remedial action plan for <br /> DDRW Tracy. A number of important major components of the ROD are either incomplete or are not <br /> addressed. We believe the ROD should be re-organized to include the missing components in a more <br /> concise focused format that will reduce the present confusion and numerous redundancies. Our major <br /> concerns are presented as general comments, followed by specific comments which pertain to particular <br /> sections of the ROD and site-specific comments. Based on the overall inadequacy of this Draft ROD, <br /> we request that DDRW Tracy re-submit the revised version as a Draft ROD rather than proceeding with <br /> a Draft Final ROD. <br /> General Comments <br /> 1. Re-organize ROD: For clarity, we suggest that DDRW Tracy re-organize the ROD. In addition to <br /> the general declaration, including signatures, separate main sections should be included to present a <br /> declaration and decision summary for each group of sites identified in the Comprehensive RI/FS <br /> Report-- i.e., a separate section for each of the following groups: <br /> 1. No Further Action Sites; <br /> 2. Group A Sites Selected For Remedial Action; <br /> 3. Group B Sites Selected For Remedial Action; <br /> 4. Group C Sites Selected For Remedial Action; <br /> 5. Operable Unit-1 Ground Water. <br /> This organization will simplify the presentation by "grouping" the ROD information and focusing on <br /> the logical step-by-step process behind similar decisions made. This will help the reader to "follow" <br /> the process conducted rather than requiring the reader to "compile" complex information presented in <br /> different sections. Each section should include tables which identify the sites (SWMUs) showing <br /> associated soil and ground water contaminants of concern, the selected remedies, and cleanup levels <br />