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t <br /> �,Zeos.rFs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> A I Region 9 <br /> ` W 75 Hawthorne Street MOVED <br /> W D <br /> t >A7 San Francisco CA 94105-3901 Ifl] V v t� <br /> May 17, 2002 MAY 2 3 2002 <br /> ENVIRONMENT HEALTH <br /> Mr. Marshall Cloud PERMIT/SERVICES <br /> Defense Distribution Depot San Joaquin California, Tracy Site <br /> DDJC-FA, Attn: Environmental Management <br /> P.O. Box 960001 <br /> Stockton,CA 95296 <br /> RE: Draft Final Remedial Action Report for SWMUs 2,3,and 33 for DDJC-Tracy, <br /> April 2002 <br /> Dear Marshall, <br /> Thank you for the opportunity to review the "Draft Final Remedial Action Report for SWAIUs 2, <br /> 3, and 33 for DDJC-Tracy, "April 2002. Our comments are attached. <br /> The Remedial Action Report(RAR) provides only a cursory discussion related to the rationale <br /> for the explanation of significant differences(ESD). In general,the discussion does not clearly reflect <br /> that the remedy is still protective of human health and the environment. Some of the statements made <br /> raise questions about the assumptions used to revise ecological clean up levels, and the appropriateness <br /> of the revised assumptions would only be understood if one were to review of the original ecological risk <br /> assessment.The revisions presented in the responses to comments do not adequately document why it is <br /> appropriate for a chemical of concern, used in decision making for the original record of decision (ROD), <br /> to be deleted from the remedy. For example,the RAR does not discuss that a review of more site-specific <br /> considerations was conducted, and that the risk managers agreed to accept less conservative risk <br /> assumptions. The RAR should be clarified to document the actual rationale for why it was deemed <br /> appropriate to eliminate a chemical that was previously determined to be of concern. <br /> Please feel free to contact me at 415-972-3024 if you have any questions or comments. <br /> Sincerely,P /1l(j( f <br /> 4-e <br /> Michael Work <br /> Federal Facilities Cleanup Branch <br /> Superfund Division(SFD-8-3) <br /> cc: (See Distribution List) <br /> Attachment <br />