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JUNITED STATES ENVIRONMENTAL PROTECTION AGEN%RINE 11 f-,� <br /> REGION IX 1,� v E <br /> 75 Hawthorne Street <br /> P San Francisco, CA 94105 JUN 3 0 2004 <br /> *i ; 2004 ENYor)�"RENT HEALTH <br /> F <br /> /SERVICES <br /> Colonel <br /> Colonel Edward R. Visker, U.S. Army <br /> Commander, Defense Distribution Depot San Joaquin California (DDJC) <br /> U.S. Department of Defense, Defense Logistics Agency <br /> DDJC-D, Building 100 <br /> P.O. BOX 960001 <br /> Stockton, CA 95296 <br /> Re: Final Amendment to the Sitewide Comprehensive Record of Decision, <br /> Defense Distribution Depot San Joaquin (DDJC), Tracy Site, Tracy, <br /> California, December 2003 <br /> Dear Colonel Visker: <br /> The U.S. Environmental Protection Agency (EPA) Region 9 has received the Final <br /> Amendment to the Sitewide Comprehensive Record of Decision (ROD), Defense Distribution <br /> Depot San Joaquin (DDJC), Tracy Site, California, dated December 2003. The purpose of this <br /> ROD Amendment is to modify significantly the remedies for Solid Waste Management Unit <br /> (SWMU) 4 and for groundwater(designated as Operable Unit 1) originally specified in the <br /> DDJC-Tracy Sitewide Comprehensive ROD. This amendment also addresses the Defense Site <br /> Environmental Reporting and Tracking System (DSERTS) 72 site, which was discovered after <br /> the ROD was signed. <br /> Regarding the groundwater, the ROD Amendment proposes to dispose of effluent from the <br /> groundwater treatment system via overland flow as a backup method of recharging the aquifer <br /> when re-injecting the effluent per the existing ROD is not feasible. The 1998 Sitewide <br /> Comprehensive ROD does not include RCRA Land Disposal Restrictions as ARARs because the <br /> remedy did not initially include disposal of effluent to land. However, the effluent is already <br /> subject to Waste Discharge Requirements (WDRs) specified in the ROD. <br /> The WDRs specified in the ROD are more stringent than the RCRA Land Disposal <br /> Restrictions. Therefore, in order to comply with the substantive requirements of RCRA and <br /> avoid triggering RCRA ARARs, the DLA should ensure that chemical concentrations in the <br /> treatment system effluent continue to fall below the WDRs. <br />