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(\� Department of Toxic Substances Control = <br /> Edwin F. Lowry, Director <br /> Terry Tamminen 8800 Cal Center Drive Arnold Schwarzenegger <br /> Agency Secretary Sacramento, California 95826-3200 Governor <br /> Cal/EPA <br /> December 22, 2003 <br /> DECENED <br /> DEC 3 1 2003 <br /> ENVIRONMENT HEALTH <br /> Mr. Marshall Cloud PERMIT/SERVICES <br /> Remedial Project Manager <br /> Environmental Office <br /> Defense Distribution Depot-Tracy Site <br /> Post Office Box 960001 <br /> Stockton, California 95296 <br /> COMMENTS ON REVISED DRAFT 2003 EXPLANATION OF SIGNIFICANT <br /> DIFFERENCES (ESD) TO THE SITE-WIDE COMPREHENSIVE RECORD OF <br /> DECISION FOR DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN CALIFORNIA <br /> (DDJC), DATED OCTOBER 9, 2003, STOCKTON, CALIFORNIA <br /> Dear Mr. Cloud: <br /> The Department of Toxic Substances Control (DTSC) received the above-mentioned <br /> report on October 13, 2003. DTSC has reviewed the ESD and has the-following <br /> comments: <br /> Comments: <br /> 1.) DTSC's new applicable or relevant and appropriate requirement (ARAR) in the <br /> Title 22, Division 4.5, Chapter 39, section 67391.1 of the California Code of <br /> Regulations requires that any site using a Land Use Controls (LUC) needs to <br /> have an enforcement and implementation plan (E&I) to facilitate the LUC. <br /> Specifically, the E&I plan should list who is responsible for conducting the <br /> inspections, what types of things are going to be observed, how often the <br /> inspections will be conducted, etc. DDJC-Tracy plans to include the Addendum <br /> to the Installation Master Plan (IMP) as an Appendix to the ESD as indicated in <br /> the response to comments for the Tracy-DDJC Amendment to the Record of <br /> Decision. The updated IMP Addendum attached to the ESD would eliminate the <br /> need for a separate E&I plan for sites with current LUCs. If in the future, land is <br /> transferred to a non-federal entity then Land Use Covenants would be required <br /> to implement deed restrictions on the property until it is cleaned up to <br /> unrestricted use. Please include a copy of the Addendum to the Installation <br /> e Printed on Recycled Paper <br />