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A 4 <br /> � W <br /> UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> ;F <br /> pwE REGION IX <br /> 75 Hawthorne Street <br /> San Francisco, Ca. 94105-3901 <br /> March 6, 1992 MAR 0 9 1992 <br /> Abel W. Haines, P.E. , Chief Hi=ALTH <br /> Environmental Protection Office <br /> Bldg. 231, Tracy Location <br /> Defense Distribution Region West <br /> P.O. Box 960001 <br /> Stockton, CA 95296-0250 <br /> RE: Comments on the Draft Comprehensive RI/FS Work Plan <br /> DDRW-Tracy (JAN-92) <br /> Dear Mr. Haines, <br /> Attached are EPA's Comments on the Draft Comprehensive <br /> Remedial Investigation/Feasibility Study (RI/FS) Work Plan for <br /> Defense Distribution Region West, Tracy (DDRW-Tracy) , received in <br /> our offices on 1/6/92 , and amended by DDRW-Tracy with extensive <br /> revisions on 2/6/92 . Significant additional effort needs to be <br /> expended before this document can be approved by EPA. Our <br /> comments are provided in five attachments. <br /> Attachment I, provides comments on the RI portion of the <br /> Draft Work Plan. In general, DDRW-Tracy has been responsive to <br /> previous EPA comments (with the significant exception of the risk <br /> assessment portion of the Work Plan, see below) . However, <br /> significant revisions are requested. <br /> Attachment II, provides comments on the risk assessment <br /> portion of the Work Plan. As stated in our letter of 2/5/92 , <br /> (and which still is the case) , this portion of the work plan is <br /> too generic. There is an inadequate description as to how <br /> characterization data for each site will be used to provide an <br /> overall baseline risk assessment. This Work Plan states that a <br /> detailed Work Plan for risk assessment will be derived after the <br /> first phase of the RI is complete. This approach was not <br /> anticipated in the FFA schedule and is not acceptable to EPA. In <br /> short, EPA expects DDRW-Tracy to provide a detailed risk <br /> assessment work plan in the Draft Final Comprehensive RI/FS Work <br /> Plan. (DDRW-Tracy should attempt to provide this Work Plan <br /> earlier, if possible. ) As currently written, the Work Plan is <br /> incomplete. <br /> 1 <br /> Printed on Recycled Paper <br />