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Review of Draft Final Project Closeout Plan (Remedial Action Report) Northern Depot Area (DSERTS 67) Cover Installation Defense Distribution Depot San Joaquin (DDJC) Tracy Site, Tracy, California January 2003 GENERAL COMMENTS 1. It is unclear why the DSERTS 67 Project Closeout Plan (Remedial Action Report, or RAR) is being used to change a remedy agreed to by all parties in the Record of Decision (ROD) and subsequent"Explanation of Significant Differences to Selected Remedies in the ROD for SWMUs 2, 3, 7, and 33,Building 30 Drum Storage Area, and the Northern Depot Soils Area", Revised,Final, dated July 2001 (ESD). There is a legal obligation to follow the remedy proposed in the ROD, and it is inappropriate to document changes in an RAR because it is not a decision document under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Please defer finalizing this RAR until the remedy as described in the ESD is implemented or an ESD or ROD Amendment is completed to document the change in the selected remedy and cavy it through the appropriate public participation process. 2. The format of the body of text of the draft version of the RAR was substantially revised in the draft final version. The change in format reflects the requirements presented in the current United States Environmental Protection Agency (EPA) guidance document, "Close Out Procedures for National Priorities List Sites,"EPA 540-R-98-016, January 2000 (Guidance), and as requested in EPA's comments on the Draft RAR. The draft final version of the DSERTS 67 RAR, however, does not follow the Guidance format requirements for appendices. A detailed Cost and Performance Summary was not referenced in Section 8.0 and provided as Appendix A. Please add Appendix A to the next version of the RAR or explain why it is not necessary. 3. According to Section 1.3 of the Final Draft RAR, a Design Data Collection Effort (DDCE) was conducted in January 1999 "to fill design data gaps prior to proceeding with remedial designs and/or implementation." The DDJC-Tracy Remedial Project Managers reportedly used the results of the DDCE to decide that the asphalt cover proposed in the ROD was overly conservative and, therefore,recommended the aggregate base (AB) cover in the ESD. Section 1.3 also states that, as a result of the DDCE, the limits of the area requiring the AB cover were reduced from the 138,000 square feet estimated in the ROD to approximately 63,500 square feet, but it is not clear who made this decision or when it was made. 1