SITE INFORMATION AND CORRESPONDENCE

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Site-Wide Comprehensive ROD -2- 1 May 1997 DDRW Tracy for each "group". A separate section should be included to present and describe ARARs (see general comment 43). We suggest that DDRW Tracy review the organization and format presented in the Mather Air Force Base, Final Record of Decision for Soil Operable Unit Sites and Groundwater Operable Unit Plumes, dated 29 April 1996 (Table of Contents attached). 2. Missing Major ROD Components: The following major components of the ROD are missing or incomplete (see specific comments ): - Major components of each selected remedy listed as part of the Declaration - History of site activities which led to current problems - Main components of the treatment technologies - Type and volume of waste to be treated - Indication of whether treatability testing has been or will be conducted - Summary of relative performance of the alternatives evaluated - Presentation of cost-effectiveness is incomplete - List and description, including analyses, of ARARs and TBCs is incomplete To more completely and clearly satisfy the ROD objectives, these major components should be included in the revised version of the ROD. 3. Inadequate ARARs: The ROD does not include a complete list or analysis of State ARARs and TBCs. ARARs are discussed in Sections 7, 8, 9, and 10; however, these presentations are incomplete and leave the reader to sort and compile information in separate sections to identify which ARARs and TBCs are explicit to the constituents of concern detected in soil, sediments, surface water and ground water at particular sites at DDRW Tracy (see specific comments Section 10). The ROD presents incomplete state action-specific ARARs; state chemical-specific ARARs and TBCs should also be identified with respect to these media. The ROD should include a separate section to present and describe the categories of.ARARs and TBCs as was done for the Groundwater OU-1 ROD for DDRW Tracy. All Federal and State ARARs should be listed in a table with each substantive requirement identified as either applicable or relevant and appropriate. A description of the sources of each ARAR and TBC requirement and the regulatory authority agencies have to enforce these requirements should be presented. Each "description of alternatives" should include a subsection to describe how each ARAR or TBC applies to the CoCs and remedial actions, and the alternative remedies evaluated. The statutory determinations should detail how each selected remedy complies with each ARAR and TBC identified. We suggest that DDRW Tracy review the organization and format of ARARs and TBCs presented in the Mather Air Force Base, Final Record of Decision for Soil Operable Unit Sites and Groundwater Operable Unit Plumes, dated 29 April 1996. 4. NFA Justification. The ROD does not include adequate justification for no further action determinations. Text should clarify that contaminant levels allowed to remain in place at no further action sites pose no threat to water quality and it's beneficial uses. The basis for making these determinations should be described, including any determinations that it is not technically and economically feasible to remediate soil contaminants to levels which protect background levels in the underlying groundwater.