SITE INFORMATION AND CORRESPONDENCE

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4. Section 3.3, Aggregate Base(AB) Cover, Pages 3-1 to 3-2: The last sentence of the first paragraph states the aggregate base(AB)cover"may be upgraded to an asphalt cap as was recommended in the ROD"if future increased industrial use of the Northern Depot Soils Area is proposed. There is, however,no institutional control referenced for tracking the potential cap upgrade. This information should be readily available and apparent to any DDJC-Tracy personnel or organization that proposes to increase activity on the cap area or effect a change in land use, including construction activities that disturb the cap, while the property is controlled by the Defense Logistics Agency. Also, an institutional control should be in place that performs the same function upon release of the DDJC for public use. Please discuss the institutional controls(e.g.,Addendum to the Master Plan, DDJC land use restriction, deed restriction on file with San Joaquin County, etc.) that will inform future users of the Northern Depot Soils Area of the potential need to upgrade the aggregate base cover to an asphalt cap. 5. Section 5.0, Completion of ROD Requireipents, Page 5-1: This section recommends "No Further Remedial Action" forlihe Northern Depot Soils Area, but EPA considers institutional controls to be a remedy. The EPA ROD Guidance("A Guide to Preparing Superfund Proposed Plans,Records of Decision, and Other Remedy Selection Documents", EPA 540-R-98-031,July 1999) states that no action means"no treatment, engineering controls, or institutional controls" (page 8-1). The Remedial Action Report proposes leaving concentrations of manganese that are orders of magnitude higher than the cleanup standard without building the cover specified in the ROD, so a no action alternative does not appear to be appropriate. Please revise the recommendation to include institutional controls as the remedy for the Northern Depot Soils Area. 6. Section 6.0, Post-Construction Activities, Page 6-1: Section 6.0 recommends several institutional controls,but it is unclear which DDJC organization(s)will be responsible for their development, management, implementation, and enforcement. In addition, due to the organization of the text in Section 6.0, it is not clear that the recommended institutional controls address all of the ESD requirements, or even the ROD requirements. Such discussions belong in Section VI, Final Inspection and Certifications, as described in the Guidance. Please revise the next version of this Remedial Action Report to clearly identify the organization(s)that will be responsible for the development, management, implementation, and enforcement of all of these institutional controls. 7. Section 7.0, Summary of Project Costs, Page 7-1: Section 7.0 states that the construction cost of the remedial action at DSERTS 67 was approximately$147,000. This value, however, does not appear to address the total costs associated with the selection and implementation of a recommended remedial alternative. As indicated by the technical memoranda presented in Appendix B, which supported the ESD process, the initial recommended alternative was apatite mineralization,but pilot testing proved that it 2