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MARCH AFBCALIFORNIA
ADMINISTRATIVE RECORDCOVER SHEET
AR File Number
544 0 File: 17AT.s.
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MARCH Am FORCE B1tsE
S OPERABLE UNIT #1
RECORD OF DECISION
544 3
- .rr\IILE OF CONTENTS
Section
1.0 Site1.11.21.31.41.51.61.71.81.91.10
3.0 Highlights of Community Participation
4.0 Scope & Role of Operable Unit
Page No.
1—1
1—1
1—1
1—1
1—1
1—1
1—1
1—1
1-31-31-5
2-12-42-42-5
3-1
4-1
5.0 Summary of Site Characteristics5.1 Geology and Aquifer Characteristics5.2 Groundwater Contamination
5.2.1 Organic Contaminants5.2.2 Inorganic Contaminants
5.3 Soil Contamination
.
6.0 Summary of Site Risks6.1 Chemicals of Potential Concern6.2 Exposure Assessment6.3 Toxicity Assessment6.4 Risk Characterization and Conclusions .6.5 Cleanup Standards and Goals
6.5.1 Groundwater Cleanup Standards and
6-16-16-16-26-26-9
Goals 6-96-106-106-216-26
7.0 Description of Alternatives7.1 Remedial Alternatives for Groundwater7.2 Remedial Alternatives for Soil
8.0 Summary of Comparative Analysis of Alternatives8.1 Comparative Analysis of Alternatives
8.1.1 Groundwater8.1.2 Soil
9.0 Selected Remedies9.1 Groundwater9.2 Soil
11
7-17-17-6
8-18-28-2
8-16
9-19-19-4
Name, Location, & DescriptionLocationPopulationLand UseClimateGeologySoilSurface Water and WetlandsHydrogeologyWater Use and Well InventoryThreat of Site
.
S
2.0 Site History & Enforcement Activities2.1 Sites With No Further Action Planned2.2 Sites Requiring Soil Remediation2.3 Sites Requiring Groundwater Remediation
5-15-15-15-45-45-5
6.5.2 Soil Cleanup Standards and Goals6.5.2.1 Surface Soil Cleanup Standards and Goals6.5.2.2 Subsurface Soil Cleanup Standards and Goals6.5.2.3 Summary of Soil Cleanup Standards and Goals
544 4
TABLE OF CONTENTS CONTINUED
10.0 Statutory Determinations 10-110.1 Groundwater 10-110.2 Soil 10-3
11.0 Documentation of Significant Changes 11-1
Appendix A Responsiveness SummaryAppendix B Administrative Record IndexAppendix C ARAR Tables
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111
1-1 Location of March AFB .
2-1 Areas to be Retained by March Air Force Base2-2 Location of Operable Unit I Sites2-3 Locations of Groundwater Contaminant4-1 OUs and IRP Sites5-1 Locations of Groundwater Contaminant6-1 Site 4 Surface Soil Contamination6-2 Site 10 Surface Soil Contamination6-3 Site 15 Surface Soil Contamination6-4 Site 31 Surface Soil Contamination6-5 Site 34 Surface Soil Contamination6-6 Site 18 Subsurface Soil Contamination6-7 Site 31 Subsurface Soil Contamination6-8 Site 34 Subsurface Soil Contamination6-9 Decision Tree for Vadose Zone Cleanup
Page No.
1-21-42-22-3
inOUl 2-64-2
inOUl 5-26-156-176-186-206-226-236-246-256-27
5-1 Groundwater Contaminants5-2 Surface Soil Contaminants Exceeding EPA Region IX PROs6-1 Summary of OU1 Risk6-2 Groundwater Cleanup Standards6-3 Concentrations of Surface Soil Contaminants Exceeding EPA Region IX PRGs6-4 Cleanup Goals for Chemicals in Soil that Require Remediation8-1 Comparative Ranking of Remedial Alternatives for Groundwater - Site4/OU 1 Groundwater
March Air Force Base8-2 Comparative Ranking of Remedial Alternatives for Soil - Site 4 March Air Force Base8-3 Comparative Ranicing of Remedial Alternatives for Surface Soil - Site 10 March Air Force
Base8-4 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 15 March Air8-5 Comparative Ranking of Remedial Alternatives for Groundwater - Site 18 March
Base8-6 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 18 March
Base8-7 Comparative Ranking of Remedial Alternatives for Groundwater - Site 31 March
Base8-8 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 31 March
Base8-9 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 31 March
Base8-10 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 34 March
Base8-11 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 34 March Air Force
Base 8-13
544 5
LIsT OF FIGuREs
1-2 Locations of Past or Existing Wells in Penis Valley near March AFB, California.
Plumes
Plumes
• TableLisT OF TA1wE5
Plume
Page No.
5-35-6
.6-46-116-136-28
8-38-4
8-58-6
8-7
8-8
8-9
8-10
8-11
8-12.
Force BaseAir Force
Air Force
Air Force
Air Force
Air Force
Air Force
iv
544 6
DECLARATION OF DECISION
Sum NAIstE AND LOCATION
Operable Unit 1March Air Force BaseRiverside County, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial actions for Operable Unit (OU) I at March AirForce Base (AFB), Riverside County. California. The Air Force developed this Record of Decision(ROD) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986(SARA), and to the extent practicable, the National Oil and Hazardous Substances Pollution ContingencyPlan (NCP). This decision is based on information contained in the Remedial Investigation/FeasibilityStudy (R1/FS) report dated July 1994 and the administrative record for March AFB and complies with40 Code of Federal Regulations (CFR), Part 300.
The U.S. Air Force (Air Force), has selected remedies in concurrence with the U.S. EnvironmentalProtection Agency (USEPA) Region IX, and the State of California.
SASSESSMENT OF THE SITES
The purpose of this ROD is to set forth the remedial actions to be conducted to remediate soil andgroundwater contaminated with polycyclic aromatic hydrocarbons (PAils) and volatile organic compounds(TCE, PCE) beneath OU1 and adjacent off-base areas.
Actual or threatened releases of hazardous substances from OU 1, if not addressed by implementing theresponse actions selected in this ROD, may present a current or potential threat to public health, welfare,or the environment.
DESCRIPTION OF THE SELECTED REMEDIES
The response actions address the documented principal public health and environmental threats from OU1.OU1 consists of 14 different sites with the potential for soil and groundwater contamination and a plumeof contaminated groundwater. Eight of the sites have no further action planned by the Air Force basedon the results of a risk assessment performed as part of the OU1 Remedial Investigation. No furtheraction is planned for Sites 5, 7, 9, 13, 14, 16, 29, and 38 by the Air Force and in concurrence with theUSEPA, and the State of California. The remaining six sites require cleanup of either soil, groundwater,or both. Complete site descriptions, including site history and waste types, are provided in Section 2.0of this ROD.
Due to differences in the nature of contaminants found at each site and variances in site conditions,various applicable cleanup methods were evaluated in the Feasibility Study (FS). Based on thisevaluation, the following cleanup methods have been selected:
V
SollCleanup544 7
• Site 4. A small volume of surface soil is contaminated with polycyclic aromatic hydrocarbons (PAHs),and subsurface landfill wastes are the apparent source of chlorinated hydrocarbons in groundwater. Thepreferred cleanup method for soils and solid wastes at Site 4 is closure of the landfill in accordance withCalifornia regulations (Title 23, Chapter 15, Article 8). This will include installation of a cap over thelandfill, protection of the cap from erosion, long-term maintenance of the cap, and groundwatermonitoring.
Site 10. A small volume of surface soils contaminated with polycyclic aromatic hydrocarbons (PAHs)at Site 10 require cleanup. The preferred method of cleanup for these soils is excavation and lowtemperature thermal desorption. -
Site 15. At Site 15 a small volume of surface soil is contaminated with PAHs and requires cleanup. Thepreferred method of cleanup for these soils is excavation and low temperature thermal desorption.
Site 18. The subsurface soils at Site 18 are contaminated with jet fuel and its components. The preferredmethod of cleanup for the soils is soil vapor extraction (SVE). Soil will be treated by extracting vaporsfrom the same wells used to extract contaminated groundwater (see Site 18 groundwater plume).Extracted vapors will be treated at the surface using the Purus PADRETh system.
Site 31. For PAH surface soil contamination at Site 31, the preferred method of cleanup is excavationand low temperature thermal desorption. The preferred method for cleanup of subsurface soilscontaminated with trichloroethene (TCE) at Site 31 is SVE with carbon adsorption. Soil vapors will bee'xiracted from the same wells used to extract contaminated groundwater (see Site 31 groundwater plume)• and brought to the ground surface for treatment by granular activated carbon (GAC).
Site 34. Surface soils at Site 34 are contaminated with PARs and the preferred method of cleanup isexcavation and low temperature thermal desorption. Subsurface soils at Site 34 are contaminated withfuels. The preferred method for cleanup of the soils is bioventing. Bioventing consists of injectingoxygen (air) into the soil to stimulate the growth of hydrocarbon degrading microbes. These microbesuse the hydrocarbons as an energy source and break them down into nothazardous compounds.
Groundwater
The occurrence of groundwater contaminants is discussed within the context of "plumes" of contaminantsthat share a common source area, geographic distribution, and composition. These plumes cross siteboundaries, so site-specific discussions are not practical. My remedial response actions undertaken willbe applied to each plume as an entity, without consideration for site boundaries. Four plumes have beenidentified: The OU1 groundwater plume, the Site 4 groundwater plume, the Site 18 groundwater plume,and the Site 31 groundwater plume.
OU1 Groundwater Plume. The OUI groundwater plume extends from the area of Site 31 to the southand east and offbase. The preferred method for cleanup of the plume is to withdraw groundwater usingextraction wells and treat the groundwater using liquid phase GAC adsorption to remove TCE and relatedcompounds. The groundwater extraction system will use existing extraction wells located along theeastern base perimeter, supplemented with additional wells to assure complete containment of that portionof the plume presently underlying the base. Groundwater from the OU 1 groundwater plume will be• combined with groundwater from Site 4 for treatment. Treated water will be discharged either to the basewastewater treatment plant, to the Heacock Storm Drain or reinjected into the aquifer. In accordancewith California Health and Safety Code Section 25230, deed restrictions will be implemented as an
vi
544 8
institutional control to prohibit the installation of wells to restrict groundwater use in onbase contaminatedareas, until groundwater cleanup standards have been achieved in onbase contaminated areas.
• Groundwater monitoring will be conducted to ensure that migration of the plume ofibase has stopped,that ofibase water supplies are not threatened, and that the concentrations of contaminants offbase aredecreasing. If contaminant concentrations in offbase portions of the plume do not decrease or migrationhas not stopped, the Air Force will take action to cleanup these portions of the plume, includinginstallation of offbase extraction wells as necessary. Groundwater monitoring will be conducted to ensurethat the onbase portion of the plume does not migrate offbase, to ensure that the maximum concentrationof ofibase contaminants continues to fall, and to ensure that the offbase plume does not threaten oftbasewater supplies.
Site 4 Groundwater Plume. The preferred method for cleanup is to withdraw water using extractionwells and treat the water using liquid phase GAC adsorption to remove tetrachloroethene (PCE), TCE,and other volatile organics. Groundwater from the Site 4 groundwater plume will be combined withgroundwater from the OU1 groundwater plume for treatment. Treated water will be discharged eitherto the base wastewater treatment plant, to the Heacock Storm Drain or reinjected into the aquifer. Inaddition, deed restrictions will be implemented to restrict groundwater use in onbase contaminated areas.Groundwater monitoring will be conducted to ensure that the plume does not threaten ofibase watersupplies.
Site 18 Groundwater Plume. The groundwater at Site 18 is contaminated with jet fuel and itscomponents. The preferred method of groundwater cleanup is total fluids recovery followed by oil/waterseparation. Groundwater and jet fuel will be removed using extraction wells and free-phase product willbe recovered for recycling. Contaminated groundwater will be treated by air stripping to remove volatilecontaminants, followed by liquid-phase carbon polishing to remove any remaining fuel components.• Treated water will be discharged either to the base wastewater treatment plant, or to the Heacock StormDrain.
Site 31 Groundwater Plume. Site 31 is a likely source for much of the TCE found in the groundwaterbeneath OU1. The preferred method for cleanup of groundwater at Site 31 is extraction and treatment.Groundwater will be extracted and treated at the surface using liquid phase GAC adsorption to removeTCE and related compounds. Treated water will be discharged to the base wastewater treatment plantor to the Heacock Storm Drain.
STATUTORY DETERMINATION/DECLARATION
The selected remedies for groundwater at the Site 4 plume, groundwater at the Site 18 plume,groundwater at the OU1 plume, groundwater at the Site 31 plume, and subsurface soils at Sites 18, 31and 34 are protective of human health and the environment, comply with Federal and state requirementsthat are legally applicable or relevant and appropriate to the remedial actions, and are cost-effective.These remedies utilize permanent solutions and alternative treatment (or resource recovery) technologiesto the maximum extent practicable and satisfy the statutory preference for remedies that employ treatmentthat reduces toxicity, mobility, or volume of contaminants as a principal element. For remedies that donot achieve numerical cleanup goals within five years, a review of implemented technologies will beconducted to ensure that the remedies continue to provide adequate protection of human health and theenvironment.
The selected surface soil remedies for Sites 10, 15, 31, and 34 are protective of human health and the• environment, comply with Federal and state requirements that are legally applicable or relevant and
appropriate to the remedial actions, and are cost-effective. These remedies utilize permanent solutionsand alternative treatment technologies to the maximum extent practicable and satisfy the statutorypreference for remedies that employ treatment that reduces toxicity, mobility, or volume of contaminants
vii
544 9
as a principal element. Since the selected remedies for these sites will result in permanent destructionof the contaminants, a five-year review will not be required.
The selected surface soil remedy for Site 4 is protective of human health and the environment, complieswith Federal and State requirements that are legally applicable or relevant and appropriate to the remedialaction, and is cost-effective. This remedy utilizes permanent solutions and alternative treatmenttechnologies to the maximum extent practicable. However, because treatment of the principal sitecontaminants was not found to be practicable, this remedy does not satisfy the statutory preference fortreatment as a principal element. Because this remedy will result in hazardous substances remainingonsite above health-based levels, a review will be conducted within five years after commencement ofthe remedial action, and at each five year period in the future to ensure that the remedy continues toprovide adequate protection of human health and the environment.
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viii
544 10.This Record of Decision (ROD) presents the selected remedial actions for Operable Unit 1 (OU1), MarchAir Force Base, California, developed in accordance with the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executedand delivered shall be deemed to be an original, but such counterparts shall together constitute one andthe same document.
Signature . DateGerard J. ibeault, Executive Officer, California RegionalWater Quality Control Board, Santa Ana Region
xii
544 1.1This Record of Decision (ROD) presents the selected remedialactions for Operable Unit 1(0(M). MarchAir Force Base,California, developed in accordance with the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act (SARA)..
This ROD may be executed and delivered in any number of counterparts, each of which when executedand delivered shall be deemed to be an original, but such counterparts shall together constitute one andthe same document.
lx
544 12This Record of Decision (ROD) presents the selected remedial actions for Operable Unit I (OU1), MarchAir Force Base, California, developed in accordance with the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executedand delivered shall be deemed to be an original, but such counterparts shall together constitute one andthe same document.
S—fl /S-ak( (9A0/V,Signature DateJulie Anderson, Director, Federal Facilities ComplianceBranch, USEPA, Region IX
x
544 13This Record of Decision (ROD) presents the selected remedial actions for Operable Unit I (OU1), MarchAir Force Base, California, developed in accordance with the Comprehensive Enviromnental Response,Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments andReauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executedand delivered shall be deemed to be an original, but such counterparts shall together constitute one andthe same docun,nt.
r Date
J/hn E. Scandura'thief of Operations/outhern California Office of Military FacilitiesDepartment of Toxic Substances Control
xi
544 141.0 SITE NMVW, LOCATION, & DESCRIPTION
S 1.1 LOCATION
March Air Force Base (AFB) is located in the northern end of the Penis Valley, east of the city of Riverside, inRiverside County, California. The base is approximately 60 miles east of Los Angeles and 90 miles north of SanDiego (Figure 1-1). The base lies in sections of Township 3 South, Range 4 West.
1.2 POPULATION
The population of Riverside County is 1,700,413 (U.S. Census, 1990) and consists primarily of english- andspanish-speaking citizens.
1.3 LAND USE
Current land use on March AFB is classified as residential and light industrial. Maintenance facilities, warehouses,and administrative centers support the mission.
The land surrounding March AFB includes areas of residences, light industry, and agriculture. Light industrialareas are located to the north. Agriculture is located to the east and south. Residential areas are located in alldirections around March AFB.
1.4 CLIMATE
The climate of the March AFB area is characterized as Mediterranean to semi-arid. The climate in the region variesaccording to elevation and distance from the Pacific Ocean. The weather generally consists of warm to hot, dry
5 summers and mild winters. -
1.5 GEOLOGY
The Main Base lies in the Penis Valley where alluvium is found at the surface. The Penis Valley is characterizedas a broad, nearly flat surface dotted with bedrock hills. The numerous bedrock hills that interrupt this flat surfaceare described as erosional renmants of the underlying crystalline basement rocks. Surficial alluvial deposits arecomposed of alternating layers of varying amounts of clay, silt, sand, and gravel. In general, the deposits consistof silty sand and sandy silt with varying amounts of clay. Based on drilling information to date, thickness of thealluvial deposits ranges from zero to over 150 feet.
1.6 SOIL
Two major soil associations exist in the March APE area: the Cieneba-Rockland-Fallbrook association and theMonserate-Arlington-Exeter association. The Cieneba-Rockland-Fallbrook association is derived from granitic rockand occurs on the western portion of the base. These soils are typically 1 to 3 feet thick, have a surface layer ofsandy loam to fine sandy loam, are well drained, are coarse- to medium-grained, and have slopes ranging from 2to 50 percent. The Monserate-Arlington-Exeter association is derived from granitic alluvium and occurs on theeastern portion of the base. These soils have a surface layer of sandy loam to loam, are well drained, are fme- tomedium-grained, and are gently sloping.
1.7 SURFACE WATER AND WETLANDS
With the exception of small surface water impoundments that are used for agricultural purposes, there are twopermanent surface water bodies within 3.5 miles of March AFB. Lake Penis, located 4 miles southeast of the base,provides approximately 130,000 acre feet of storage for State Project Water brought in by the California Aqueductwhich runs north and east of the base. An east-west portion of the Colorado River Aqueduct is locatedapproximately 3.5 miles south of the base. This aqueduct flows into Lake Matthews, which is located about 10
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San Diego90Miles
544 16miles west of March AFB. A very small recreation lake is located approximately 2 miles east of the Base. It ismaintained by the Moreno Valley Ranch homeowners association and is located just south of Iris Street and westof Lasselle Street in the City of Moreno Valley.
• A number of wetlands and riparian areas have been identified on and in the immediate area of thebase. Most arelocated on West March, outside OU1. The U.S. Army Corps of Engineers (USACE) has performed a delineationof jurisdictional wetlands associated with the Cactus and Heacock flood control channels (USACE, 1992). Althoughthese are artificial channels excavated in uplands, they act as ephemeral streams, support some scattered wetlandvegetation and are considered waters of the United States. The USACE determined that approximately 2.17 acresof jurisdictional wetlands exist in the Heacock Storm'Drain channel with 0.8 acres of wetlands adjacent to the Site4 landfill. The wetlands are not continuous but are localized patches of wetland vegetation that change position eachyear due to the high volume, high velocity storm water flow from the spring rains through these channels whichcauses scouring of the earthen bottom and sides.
1.8 IIYDROGEOLOGY
The Main Base is located in the Penis Valley where coarse-grained alluvial deposits form the main aquifer. Thesedeposits are highly permeable and capable of yielding large amounts of water under unconfined conditions. Basedon previous studies and the results of the Operable Unit (OU1) Remedial Investigation/Feasibility Study (RI/FS),the permeability of the alluvium varies both laterally and vertically. Boring logs indicate that the generalstratigraphy consists of silty sands and sandy silts from the surface to depths of approximately 50 feet below groundsurface (bgs). Below a depth of approximately 50 feet bgs, boring logs from OUt reveal highly permeable cleansands ranging in thickness from a few inches to tens of feet alternating with relatively impermeable clays, silts, andsilty sands of similar thickness. These clays and silts act as local leaky confining units.
Bedrock is found at depths ranging from zero to over 150 feet bgs. In some areas, competent rock is overlain bya mantle of fractured and weathered rock. Water-bearing properties of the weathered rock are highly variable,depending on the degree of fracturing and weathering. Underlying competent rock is considered non-water-bearing,except in localized fracture zones.
1.9 WATER UsE AND WELL INVENTORY
Many wells exist in the Penis Valley south, east, and north of March AFB. These wells have been used forindustrial, agricultural, and domestic water supplies. Figure 1-2 shows the locations of existing and abandonedwells for which data are available through the Eastern Municipal Water District and the California Department ofWater Resources. Several water wells are also located southwest of March AFB in Mead Valley. It is possiblethat low-yield, domestic wells are not on file with government agencies.
Four on-base (BPW-1 through BPW-4) and two off-base (BPW-5 and BPW-6) wells southeast of March AFB wereformerly used for the base water supply. BPW-2, which was located just north of BPW-3 in the middle of Building100, was abandoned in 1937, and no data are available.
BPW-1, BPW-3, and BPW-4 are located in the northeast portion of the base, near the intersection of Graeber Roadand Meyer Drive. Use of BPW-3 and BPW4 was discontinued in July 1978 because yields from these wells werenot sufficient to meet water supply demands. Although BPW- 1 has not been abandoned, it has not been used asa source of water since February 1984 due to trichloroethylene (TCE) contamination.
Two high-capacity wells, BPW-5 and BPW-6, are located on Markham street, southeast of the base. These wellswere drilled in areas of greater aquifer thickness and permeability than the on-base production wells. These wellsare located in the center of Penis Valley. Although both wells are operative, BPW-5 is not currently being used.BPW-6 is occasionally used for emergency water supplies. The base water supply is currently provided by theEastern Municipal Water District. The Final Installation Restoration Program, Remedial Investigation/FeasibilityStudy Report for Operable Unit 1, published in July 1994 provides detailed well characteristics for each of the wellsshown in Figure 1-2.S.
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1.10 THREATOFS1TE 544 18
Base operations have resulted in contamination of soil and groundwater at a number of sites within OU 1.• Contaminants include chlorinated solvents, fuels, and polycyclic aromatic hydrocarbons (PAils). The selectedremedy for each site addresses the principal threat from contaminants found at that site.
1-5
544 192.0 SuE HISTORY & ENFORCEMENT ACTIVITIES
March AFB is located on 7,123 acres in the northern end of the Penis Valley, east of the City of Riverside, andsouth of the City of Moreno Valley in Riverside County, California. The base is approximately 60 miles east ofLos Angeles and 90 miles north of San Diego (Figure 1-1).
March AFB was officially opened on March 1, 1918. The base, originally a 640-acre facility called the AlessandroAviation Field, was initially used to train"Jenny" pilots during World War I. Following World War I, the baseclosed for about four years, then reopened in 1927. By 1938, March AFB was considered to be the central locationfor West Coast bombing and gunnery training. In 1949, the Strategic Air Command took control of March AFB.Since that time, the base has hosted bombers, refuelers, and cargo aircraft. In June 1992, March AFB became anAir Mobility Command installation. Its primary mission is air refueling but reserve and guard units have cargo andfighter missions as well.
In September 1993, March AFB was designated by Congress to realign its forces. Active duty Air Force personneland aircraft will transfer to Travis AFB, California, by March 1996. Air Force Reserve and Air National Guardunits will remain at March, and the base will be redesignated "March Air Reserve Base." In addition, the base isexpected to decrease to about one-third of its present size. After the base realignment, property that is not retainedby the base will be available for transfer to the local community. Figure 2-1 shows the base as it is today, withareas to be retained by the Air Force and areas likely to be available for transfer.
The U.S. Air Force, due to its primary mission in national defense, has long been engaged in a wide variety ofoperations that involve the use, storage, and disposal of hazardous materials. In 1980, the Installation RestorationProgram (IRP) was developed by the Department of Defense (DoD) to locate and clean up hazardous waste sites.
At March AFB, aircraft maintenance, fuel storage operations, fire-training exercises, and base operations havegenerated a variety of hazardous wastes. Past waste disposal practices have resulted in contamination of soil andgroundwater at several areas onbase. The March AFB IRP process began in September of 1983. Six studies havebeen completed at March AFB in support of the IRP. The initial study consisted of employee interviews andreviewing aerial photographs and base records. The records search identified 30 potentially contaminated sites forfurther investigation. A second study, completed in March 1987, consisted of the collection of soil, water, and soilgas samples. This study indicated that further investigation was needed at 5of the 30 sites to determine the typeand extent of contamination in the soil and groundwater. In June 1987, further investigation was conducted. Thisinvestigation indicated that additional work was required to better define the extent of soil and groundwatercontamination and to research possible offbase migration of trichloroethene (TCE) in groundwater.
In November 1989, March AFB was listed on the USEPA's National Priorities List (NPL) primarily due to thepresence of contamination in groundwater beneath the base. The NPL is a list of sites that are considered by theUSEPA to be of special interest and require immediate attention. In September 1990, a Federal Facility Agreement(FFA) was signed by the Air Force, U.S. Environmental Protection Agency (USEPA), and the State of Californiato establish procedures for involving Federal and state regulatory agencies and the public in the March AFBenvironmental restoration process. Three separate OUs were created in order to facilitate the environmentalrestoration of March AFB. OUs were created based on geographic location of sites, similarity of contaminants,and location of groundwater contaminant plumes.
The subject of this ROD is OU1. OU1 sites include Sites 4,5, 7, 9, 10, 13, 14, 15, 16, 18, 29, 31, 34, and 38(Figure 2-2). OU1 sites originally included Sites 21 and 23, but these sites have been reassigned to 0U2. Thelatest investigation at OU1 was performed from November 1991 to November 1993. The overall objectives of theinvestigation were to collect additional data to confirm contaminant source areas, better define contaminationboundaries, assess potential risks to human health or the environment, and evaluate the feasibility of differentremedies at OU1 sites. Groundwater at Site 4, Site 18, Site 31 and within the OU1 groundwater plume and soilat Sites 4, 10, 15, 18, 31, and 34 require remedial action. Descriptions of the sites are presented below..
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March Air Force Base, California
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Areas to be Retainedby March Air Force Base
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Location of
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Base Boundary
2.1 SITEs WITH No FURTHER ACTION PLAFNED 544 22Based on currently existing data collected under previous studies, no unacceptable risk has been identified and• therefore, no further action is required at the following sites:
Site 5 (Landfill No. 3). This site covers approximately 5 acres and is located southeast of the present flightline.The landfill was reportedly operated from the late 1940s to approximately 1960. Landfill wastes consist primarilyof sanitary waste and construction rubble.
Site 7 (Fire Training Area No. 2). This site is located on the eastern part of the Base, north of the Alert Facility.Between 1954 and 1978, fire training exercises were conducted in unlined training pits. Three distinct burn pitswere identified in historic aerial photographs of the Base. A portion of this site may have been used for crashrescue training. Wastes used in training exercises reportedly included contaminated fuel, waste solids, and spentsolvents.
Site 9 (Main Oil/Water Separator). Site 9 is located north of Site 5 at the southeast end of the flightline apron.The facility was constructed in 1974 and serves the main storm drainage system for the flightline apron and theflightline shops. The storm drains have reportedly received waste oils, hydraulic fluids, diesel fuel, waste paints,
• spent solvents, paint strippers, paint thinners, and battery acids. The oil/water separator is of earthen constructionwith a large baffle that divides the separator into two compartments. The separated oil is picked up by a skimmerand pumped to a holding tank for off-base disposal. This facility drains into the Flightline Drainage Channel (Site10) and then to the Perris Valley Storm Drain Lateral A.
Site 13 (Tank Truck Spill Site). Site 13 is located along the eastern perimeter road of the Base, within the northernportion of Site 5. In 1973, approximately 5,000 gallons of JP-4 jet fuel spilled from a tank truck to the ground atthis location. The accidental discharge resulted from a mechanical malfunction. There was no reported spillcontainment or spill clean-up.
Site 14 (Liquid Fuel Pump Station Overflow). Site 14 is located southeast of the flightline apron and about 50 to• 100 feet west of the East March Sludge Drying Beds (Site 16). In 1973, approximately 1,000 gallons of JP-4 jet
fuel spilled onto the ground. The spill occurred due to an overflow of the liquid fuels pump station at Building1245. The spill was contained in the unpaved area south of the pump station and allowed to percolate into theground.
Site 16 (East March Sludge Drying Beds). Site 16 is located on the eastern part of the Base, at the south end ofthe flight line parking apron, and near the former East March Wastewater Treatment Plant. The treatment plantwas constructed in 1938 and provided secondary treatment for sanitary and industrial waste-water. Primary andsecondary sludges were digested anaerobically, dewatered on unlined sludge drying beds, and disposed of in an on-base landfill. The sludge may have contained heavy metals and organics resulting from discharges of industrialwastes to the sanitary sewer system. These drying beds operated from 1938 to 1977, when the plant was destroyedin place.
Site 29 (Fire Training Area No.1). Site 29 is located on the eastern part of the Base, north of Site 9. The areawas used as a fire training pit prior to 1951. Suspected contaminants at the site include contaminated fuel, wasteoil, and spent solvents.
Site 38 (PCB Contamination, Building 1311). Building 1311 is located at the southeast end of the taxiway,northwest of JRP Site 23. In 1984, soils from four areas contaminated with transformer oils were sampled. Soilsfrom two of the areas (Buildings 317 and 1305) were determined to be PCB-contaminated. The soils wereexcavated and removed from the Base. Records to verify the cleanup have not been located.
2.2 SITEs REQUItING Son. REMEDIATION
Site 4 (Landfill No. 6). This site covers approximately 8.5 acres and is located along the eastern boundary of the• base, south of the East Gate (Figure 2-2). The landfill operated from 1955 to 1969. The landfill is up to 25 feetdeep, containing primarily sanitary waste, construction rubble, and debris. Small amounts of medical wastes andempty fuel containers are also present. RI sampling data indicated the presence of very low concentrations of
2-4
544 23chlorinated solvents in soils and soil gas beneath the site. A groundwater monitoring well situated in the southeastcorner of the site has consistently contained elevated concentrations of tetrachloroethene (PCE) and TCE. Both PCEand TCE are found in solvents which were used to clean and degrease military equipment. In addition, vinylchloride also has been detected in Site 4 groundwater. Vinyl chloride is a breakdown product of TCE and PCE.The landfill is considered the source of contaminants detected in groundwater downgradient of the site.
Site 10 (Flightline Drainage Channel). This site is located southeast of the flightline aircraft maintenance areas(Figure 2-2). The drainage channel, which was installed prior to 1940,has reportedly received various waste oils,hydraulic fluids, diesel fuel, jet fuel, waste paints, paint strippers, paint thinners, battery acids and solvents(including TCE). The drainage channel is concrete lined (since the 19605) up to the eastern boundary of the basewhere it discharges to the Penis Valley Storm Drain. The Penis Valley Storm Drain flows east approximately 2miles, where it joins another drainage and flows south approximately 6 miles to the San Jacinto River. Prior to1974, wastes disposed of in the drainage channel may have been discharged directly to the Penis Valley StormDrain. Since 1974, the main oil/water separator (Site 9) has pretreated the runoff before its discharge ofibase.Primary contaminants of concern are PAHs, which were detected in drainage ditch sediments. PANs are a seriesof petroleum derivatives found in many fuel and asphalt compounds.
Site 15 (Fire Protection Training Area No. 3). This site is located southeast of the end of runway 12-30 andbetween Sites S and 7 (Figure 2-2). The area was developed in 1978 and was reportedly constructed by placingan underdrain system and gravel over a clay liner. Firefighting water, solutions of Aqueous Film Forming Foam(AFFF), and residual fuel used during training exercises were drained to a formerly unlined water holding pondlocated adjacent to Site 15. Approximately 6,000 gallons per year of contaminated JP-4 have been burned intraining exercises since the facility was constructed in 1978. This site is no longer being used as a fire trainingarea. The primal)' contaminant of concern is phenanthrene, a PAH.
Site 18 (Engine Test Cell). Site 18 is located on the flightline, south of Taxiway No. 2 (Figure 2-2). The test cellwas constructed in 1957 for the purpose of testing aircraft engines. The test cell has been inactive for several years.An oil/water separator was installed at the test cell in 1976. Water from the separator was discharged to the basewastewater treatment plant. Oil was collected by a contractor for offbase disposal. Prior to 1976, spills of oil,
• fuels, or solvents were drained to a nearby ditch. Fuel has been detected in four of the ten monitoring wellsinstalled to date. Potential source(s) of the fuel include overflow of tanker trucks and fuel tanks on aircraft thathave been parked on the site in the past.
Site 31 (UnconfIrmed Solvent Disposal). Site 31 is located off Graeber Street on the east side of Building 1211(Figure 2-2). The practice of discharging solvents on the ground reportedly occurred from about the mid- 1950sto the mid-1970s. In addition, floor drains from maintenance shops may have leaked solvents to the subsurface.Groundwater sampling at the site has indicated TCE concentrations which exceed Federal and State drinking waterstandards.
Site 34 (Pritchard Aircraft Fueling System). Site 34 is located next to Building 1245, at the southeast end ofTaxiway No. 1 (Figure 2-2). In 1962, six 50,000-gallon tanks were moved to this site from the Panero FuelingSystem. During a geological investigation (July 1988) for a construction project just south of the site, stained soilsand fuel odors were observed. In 1990, use of this system was discontinued, and in 1991, the tanks and systemwere removed.
2.3 SITEs REQUIRING GROUNDWATER REMEDIATION
The occurrence of groundwater contaminants is discussed within the context of "plumes" of contaminants that sharea common source area, geographic distribution, and composition. These plumes cross site boundaries, so site-specific discussions are not practical. Any remedial response actions undertaken will be applied to each plume asan entity, without consideration for site boundaries. Four plumes have been identified: OU1 groundwater plume,Site 4 groundwater plume, Site 18 groundwater plume, and Site 31 groundwater plume (Figure 2-3).
S2-5
March Air Force Base, CaJifornia
Locations of GroundwaterContaminant Plumes in OUI
9-95 Figure 2-3
544 24
North
S Out Groundwater Plume
.8 0 2000 4000 Feet
Scale2-6
544 25OU1 Groundwater Plume. The OUt groundwater plume is the most widespread plume at the base, extending fromSite 31 south and east through the area of Sites 34, 9, and 5, and extending to a maximum of approximately 1300feet to the east of the eastern base boundary and 1500 feet south of site 5 offbase (Figure 2-3). The most• widespread contaminant detected is TCE, detected at a maximum concentration of 1,400 pg/I in monitoring well31 -PWI at Site 31 on base and 42 pg/I in monitoring well 5-MWI 1 300 feet southeast of Site 5, off base. Thefollowing contaminants were also detected above cleanup standards: bis(2-ethylhexflphthalate (maximum l3Opg/l);1,1 -dichloroethene (maximum 260 pg/I); benzene (maximum 420 pg/I); carbon tetrachloride (maximum 3pg/I);cis- 1, 2-dichloroethene (maximum 30 pg/I); methylene chloride (maximum 45 pg/I); tetrachloroethene (PCEY,(maximum 1 9pg/l); 1 ,2-dichloroethane (maximum 25 pg/I) and total phenols (maximum 79 pg/I).
Site 4 Groundwater Plume. This plume is localized in the vicinity of Site 4 with the apparent source area nearthe southern end of Site 4 (Figure 2-3). The contaminants with the highest concentrations are PCE and TCE.
Site 18 Groundwater Plume. This plume is localized in the vicinity of Site 1$ with the apparent source area westof the engine test cell in the center of Site 18 (Figure 2-3). Fuel has been detected in four of the ten monitoringwells installed to date. Up to 10 feet of fuel has been identified in one well. Potential source(s) of the fuel includeoverflow of tanker trucks and fuel tanks on aircraft that have been parked on the site in the past.
Site 31 Groundwater Plume. Concentrations of contaminants at Site 31 (primarily TCE) are much higher thanthose in the rest of the OUI plume, and these high concentrations are confmed to a relatively small area. Theseconditions coupled with the history of Site 31 (reported solvent disposal) indicate that Site 31 is a likely source areafor much of the TCE found in OU1 groundwater. Therefore, even though the Site 31 plume has the samecontaminants and is contiguous with the OU 1 plume, it is appropriate to treat Site 31 separately from the remainderof the OU 1 plume, in order to eliminate the source of contamination.
S
S2-7
544 2t3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI IFS report and Proposed Plan for OU1 were released to the public on April 28, 1994. These two documentswere made available to the public in the Administrative Record, the information repositories at the Moreno Valleyand March AFB libraries, and at the Moreno Valley Chamber of Commerce. The notice of availability of thesedocuments was published in the Press-Enterprise on April 27, 1994. A fact sheet, condensed from the ProposedPlan, was sent to everyone on the March AFB mailing list, which includes Restoration Advisory Board (RAB)members. An OU 1 RI/FS subcommittee, formed by the RAB, provided oral comments to the RAB at its April 26,1994 meeting. The Final RI/FS Report was published in July 1994.
A public comment period was held from April 28 to May 28, 1994. In addition, a public meeting was held on May12, 1994 at 7 p.m. at the Best Western Image Suites in Moreno Valley. Representatives of the U.S. Air Force,USEPA, Department of Toxic Substances Control, and California Regional Water Quality Control Board, SantaAna, attended the public meeting to address any questions about the RI/FS and Proposed Plan.
A response to the comments received during the public comment period is included in the Responsiveness Summary,contained in this Record of Decision. This decision document presents the remedial actions for the OUI sites,located at March AFB, California, which were selected in accordance with Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), as amended by Superfund Amendments and Reauthorization Act(SARA), and the National Contingency Plan (NCP). The cleanup decisions for the OUI sites are based on theAdministrative Record. The Administrative Record Index is provided in Appendix B.
Public participation in the decision-making process for OU1 complies with the requirements of CERCLA§113(k)(2)(B)(i-v), 117, and the NCP §300.430(0(3).
S
S3-1
4.0 SCOPE & ROLE OF OPERABLE UNiT 544 27
OU 1 represents one component of the comprehensive environmental investigation and cleanup program presentlybeing performed at March AFB. The investigations are being performed to comply with CERCLA and the AirForce's IRP. As part of the comprehensive cleanup program, the Air Force is presently evaluating cleanupalternatives as related to these IRP sites. Plans are currently being developed for the proper cleanup and closureof all sources of soil and groundwater contamination that have been shown to pose unacceptable health orenvironmental risks.
At March AFB, aircraft maintenance, fuel storage operations, fire-training exercises, and base operations havegenerated a variety of hazardous wastes. Past waste disposal practices have resulted in contamination of soil andgroundwater at several areas on base. March AFB was added to USEPA's National Priorities List of hazardouswaste sites primarily due to the presence of TCE in groundwater beneath the base.
Three separate OUs were created in order to facilitate the environmental restoration of March AFB. OUs werecreated based on geographic location of sites, similarity of contaminants, and location of groundwater contaminantplumes (See Figure 4-1). Sites included in each OU are as follows:
QIL1. OUt encompasses Sites 4, 5, 7, 9, 10, 13, 14, 15, 16, 18, 29, 31, 34, and 38. Sites 21and 23 were initially included in OU1, but were transferred to 0U2. OU1 also includes the off-base plume area along the Eastern boundary of March AFB.
0U2. 0U2 includes the remaining sites not in Operable Units 1 or 3. It includes all of the areaknown as West March, the Hawes site, and the sites in the northern portion of the Main Base westof Riverside Drive: Sites 1,2, 3, 6, 8, 11, 12, 17, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 30,32, 35, 36, 37, 39, 40, 41, and 42.
QM. OU3 consists of IRP Site 33 (Panero Aircraft Fueling System). Soils and groundwaterin 0U3 have been contaminated by jet fuel.
OU 1 was created based on geographic location of sites, similarity of contaminants (primarily TCE) and comminglingof groundwater contaminant plumes migrating southeastward offbase. The scope of the operable unit includesgroundwater containing TCE and other compounds over the majority of OUl sites and ofibase, groundwatercontaining primarily PCE at Site 4, groundwater containing jet fuel at Site 18, and sources of these contaminantsin soils above the groundwater that have caused the plumes. The remedial investigation identified a possible sourcefor TCE contamination at Site 31 although other sites within the OU1 groundwater plume area may be contributingTCE to groundwater. The scope of the operable unit also includes soils containing PAHs at Sites 4, 10, 15, 31,and 34. By cleaning up the groundwater and soil, the operable unit will address the principal threats posed byenvironmental contamination at the base.
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5.0 SUMMARY OF SITE CHARACTERISTICS29
Elevated levels of solvents, fuel components, and metals were detected in soil and groundwater at several OU1 sites.OU1 geology, aquifer characteristics, and occurrences of groundwater and soil contamination for each site arediscussed below.
5.1 GEOLOGY MW AQUIFER CHARACTERISTICS
Beneath OU1 the lithology consists predominantly of alluvial deposits composed of alternating layers of silty sands,sandy silts, clay, sand and gravel. The alluvial deposits range in thickness from a few feet at site 18 to over 300feet in the southeast corner of OU1. Beneath the alluvial deposits granitic bedrock is present. A significant zoneof weathered bedrock overlies the competent bedrock. The weathered bedrock zone varies in thickness from a fewfeet to 70 feet at Site 29. Depth to competent bedrock varies from a few feet bgs at site 18 to greater than 300 feetbgs in the southeast corner of OU 1, and the bedrock surface is undulating.
Below a depth of approximately 50 feet bgs, highly permeable clean sands ranging in thickness from a few inchesto tens of feet are found alternating with relatively impermeable clays, silts and silty sands. This zone of verticallyand laterally discontinuous sands is capable of yielding large amounts of water, but the amount of water yielded ishighly variable based on the thickness and permeability of the sand zones. The weathered bedrock zone beneaththe alluvial deposits yields highly variable amounts of water which is controlled by the degree of weathering,fracturing, and thickness of the zone. The unweathered bedrock underlying the weathered bedrock is considerednon-water bearing, with the exception of groundwater occurring in joints or fracture zones.
The groundwater gradient gently slopes (approximately 0.003) southeast over the majority of OU 1. For a moredetailed discussion of the OU1 lithology and aquifer characteristics please refer to the March Air Force Base OUIRI/FS (The Earth Technology Corporation, July 1994).
5.2 GROUNDWATER CONTAMINATION
The occurrence of groundwater contaminants is discussed within the context of "plumes" of contaminants that sharea common source area, geographic distribution, and composition. Four plumes have been identified: OU1groundwater plume, Site 4 groundwater plume, Site 18 groundwater plume, and Site 31 groundwater plume (Figure5-i). Cleanup standards for groundwater are based on Federal and State Applicable or Relevant and AppropriateRequirements (ARARs). The rationale and approach used for establishing cleanup standards are presented in Section6.0. The compounds that most frequently exceed applicable standards in groundwater in OU 1 are chlorinatedhydrocarbons (TCE, PCE, and others) and aromatic hydrocarbons (benzene, toluene, ethylbenzene, and xylenes(BTEX) compounds) (Table 5-1). Each of the four groundwater contaminant plumes is described below:
• OUt Groundwater Plume. The OU 1 groundwater plume is the most widespread plume at thebase. It has been divided into the onbase OU1 groundwater plume, and the offbase OUIgroundwater plume. The onbase OU1 plume extends from Site 31 south and east through the areaof Sites 34, 9, and 5 and has TCE levels ranging from 1,400 tgfl at Site 31 to 76 pg/l at Site 5.The ofibase OU 1 groundwater plume extends south and east from the Site 5 boundary with TCElevels gradually decreasing to non-detect 2500 feet southeast of Site 5. The primary contaminantsare TCE and other chlorinated volatile hydrocarbons.
• Site 4 Groundwater Plume. This plume is localized in the vicinity of Site 4 with the apparentsource area near the southern end of the landfill (Figure 5-1). The primary contaminants are PCEand TCE.
.5-1
March Air Force Base, California
Locations of GroundwaterContaminant Plumes In OU1
S544 30
North
COCSF
IrisAy..
SOUI Gmundwater Plume
SI,65CSF
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0 2000 4000 Feet
Scale
5-29-95 Finitre S-I
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544 31
i'ABI.E 5—1GItouNnw,vIJJ CON'FA\IINANIS
.
Note:
Key: pg/IRWQCB
MCL
Maximum concentrations are from the basewjdegroundwater monitoring data as of Summer 1994.
= Micrograms per liter= California Regional Water Quality Control
Board, Santa Ana Region= Maximum Contaminant Level
5-3
Plume Contaminant
MaximumConcentration
(pg/i)
Site 4 Methylene ChlorideTetrachioroethene (PCE)Trichioroethene (TCE)Vinyl ChlorideBis(2-ethylliexyl)phthalatecis-1 ,2-Dichloroethene
9260858
29021
Site 18 BenzeneTolueneEthylbenzeneMethylene ChloridePhenols, TotalXylenes, Total
12,00011,0001,500
44073
7,700
Site 31 Bis(2-ethythexyl)phthalate1, 1-DichloroetheneTrichloroethene
63260
1,400
OU1 Bis(2-ethylhexyl)phthalateBenzeneCarbon TetrachlorideTrichioroethene (TCE)1,1 -Dichloroethenecis-1,2-DichloroetheneMethylene ChlorideTetrachioroethene (PCE)1 ,2-DichloroethanePhenols, Total
130420
31,400
2603045192579
544 32• Site 18 Groundwater Plume. This plume is localized in the vicinity of Site 18 with the apparent source
area to the west of the test engine cell in the center of Site 18 (Figure 5-1). Fuel has been detected in fourof the ten monitoring wells installed to date. Up to 10 feet of fuel has been identified in one well.Potential source(s) of the fuel include overflow of tanker trucks and fuel tanks on aircraft that have been5 parked on the site in the past.
• Site 31 Groundwater Plume. Concentrations of contaminants at Site 31 (primarily TCE) are much higherthan those in the rest of the OUl plume, and these high concentrations are confined to a relatively smallarea. These conditions coupled with the history of Site 31 (reported solvent disposal) indicate that Site 31is a likely source area for much of the TCE found in OU1 groundwater. Therefore, even though the Site31 plume has the same contaminants and is contiguous with the OU1 plume, it is appropriate to treat Site31 separately from the remainder of the OU 1 plume, in order to eliminate the source of contamination.
5.2.1 Organic Contaminants
For the Site 4 plume, a total of six organic contaminants were detected at concentrations exceeding applicable cleanupstandards. PCE was detected at a maximum concentration of 260 micrograms per liter (pg/I), exceeding the cleanup standardof 5 pg/I. TCE was detected at a concentration of 85 pg/I, exceeding the cleanup standard of 5 pg/I. Vinyl chloride wasdetected at a concentration of 8 pg/I, exceeding the cleanup standard of 0.5 pg/I. Methylene chloride was detected at aconcentration of 9 pg/l, exceeding the cleanup standard of 5 pg/I. Bis (2-ethylhexyflphthalate and cis-l,2dichloroethenewere also detected at concentrations exceeding the cleanup standards of 4 pg/I and 6 pg/I, respectively. The Site 4 plumeand OU1 plume overlap near the southern edge of the Site 4 plume.
For the Site 18 plume, organic contaminants exceeding applicable cleanup standards consisted primarily of jet fuelcomponents. Benzene (12,000 pg/I), toluene (11,000 pg/I), ethylbenzene (1,500 pg/I), and total xylenes (7,700 pg/I),exceeded the respective cleanup standards of 1 pg/I, 10 pg/I, 10 pg/l, and 10 pg/I. Total phenols (73 pg/I) exceed thecleanup standard of 40 pg/I. A methylene chloride concentration of 440 pg/I detected at site 18 was determined to be alaboratory contaminant. Methylene chloride was detected in associated blanks and has not been historically detected at site18.
For the OU1 groundwater plume, several organic contaminants exceeded applicable standards. The most widespread andconcentrated contaminant was TCE, detected at a maximum concentration of 1,400 pg/l. This sample was collected at Site31. Site 31 is a likely source area for TCE in the OU1 plume and therefore is treated separately. The maximumconcentrations of contaminants which exceed cleanup standards are provided in Table 5-1.
For the Site 31 groundwater plume, a total of three individual organic contaminants exceeded applicable cleanup standards.As previously discussed, the maximum concentration of TCE in the OU1 plume was at Site 31 with a concentration of 1,400pg/I. Bis(2-ethythexyl)phthalate and 1,1 -dichloroethene were also detected at maximum concentrations of 63 pg/I and 260pg/l, respectively.
5.2.2 Inorganic Contaminants
Several metals also exceeded State or Federal drinking water standards in the groundwater contaminant plumes. However,most of these metals occur naturally at elevated concentrations, as indicated by background sampling data. Therefore, mostof these metals do not require cleanup. Of these metals, thallium was the only metal detected above background levels, andwas only detected in the Site 18 plume. Thallium concentrations were determined by analytical method 5W6010 (InductivelyCoupled Plasma, ICP). This method often shows false positives because of interference from other analytes in the sample,mainly iron and aluminum. In addition, analytical precision is difficult to maintain so close to the detection limit (detectionlimit for thallium is reported as 0.100 mg/L). Therefore, the presence of thallium in the filtered samples but not in theassociated unfiltered samples suggests that the reported thallium values are an artifact of the analytical program, and thalliumwas determined not to require cleanup.
In addition to metals, other inorganic water quality criieria were exceeded. California Regional Water Quality Control Board(RWQCB), Santa Ana Region water quality objectives for hardness, chloride, sulfate, and total dissolved solids (TDS) were
S exceeded in all four groundwater plumes as well as in OU1 background samples. The water quality objective for surfactantswas exceeded in the Site 4 and OU1 plumes. TDS is the subject of an ongoing basewide groundwater study. Insufficientwater quality data are currently available to determine cleanup requirements. A basewide groundwater monitoring program
5-4
544 33is currently being conducted. The results of this program will be included in the basewide ROD. The Basewide ROD willaddress cleanup requirements of the water quality objectives for hardness, chloride, sulfate, and TDS.
S SoIL CONTAMINATION
Concentrations of analytes detected in the surface soil (0- to 2-foot) interval were compared to Region IX PreliminaryRemediation Goals (PROs). The PROs are based on the amount of contaminant that a person may ingest, inhale, or contact,and are designed to be protective of human health and the environment. Contaminants that exceed PROs warrant furtherevaluation. However, a contaminant concentration that exceeds a PRO does not necessarily indicate an unacceptable healthrisk. In determining the cleanup standards and goals for OU1, both the results of the PRO comparisons and the results ofthe risk assessment were considered. See Section 6.6 for a final site-specific list of contaminants that require remediation,based on the risk assessment.
For each analyte detected in the surface soil at a site, the maximum concentration was compared to the residential soil PROfor that analyte. The following contaminants do not have a PRO: calcium, iron, magnesium, mercury, potassium, sodium,benzo(g ,h,i)perylene, phenanthrene, 2-methylnaphthalene, alpha-chlordane, gamma-chiordane, endosulfan sulfate, and endrinaldehyde. For some of these contaminants, surrogates were applied. The PRO for anthracene, a noncarcinogenicpolynuclear aromatic hydrocarbon (PAH), was selected as a surrogate for benzo(g,h,i)perylene and phenanthrene, which arealso noncarcinogenic PAHs. The PRO for naphthalene was used for 2-methylnaphthalene. The PRO for chlordane was usedfor aipha-chlordane and gamma-chlordane. The PRO for endosulfan was selected as a surrogate for endosulfan sulfate andendrin was used for endS aldehyde.
EPA Region IX has calculated a PRG only for one dioxin, 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD), which isthe most toxic of the dioxin isomers. However, California EPA has determined Toxicity Equivalency Factors (TEFs) thatconsider the relative toxicity of each of the dioxin isomers. These TEFs were applied to the 2,3,7,8-TCDD PRG and themaximum concentration of each dioxin detected at a site was compared to the modified PRO.
Table 5-2 presents maximum surface soil concentrations of site contaminants, where the maximum concentrations exceedRegion IX PROs. The residential land use PRGs were used for all sites. The occurrence of soil analytes at each site are5 discussed below:
Site 4. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PRGs: aluminum (3,960.0-9,310.0 mg/kg), barium (73.4-117.0mg/kg), calcium (1,000.0-6,700.0 mg/kg), chromium, total (6.0-11.3 mg/kg), cobalt (3.7-5.4 mg/kg), copper (5.0-10.9mg/kg), iron (7,450.0-13,700.0 mg/kg), lead (ND-16.2 mg/kg), magnesium (2,160.0-5.320.0 mg/kg), manganese (149.0-367.0 mg/kg), nickel (ND-S .3mg/kg), potassium (2,240.0-4,090.0 mg/kg), sodium (ND-uS .0 mg/kg), vanadium (15.9-25.6mg/kg), zinc (24.7-46.5 mg/kg), fluoranthene (ND-17.0 mg/kg), phenanthrene (ND-3.5 mg/kg), pyrene (ND-8.9 mg/kg),DDE (ND-0.0046 mg/kg), and DDT (ND-0.0057 mg/kg).
Site 5. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PRGs: aluminum (5,450.0-7,290.0 mg/kg), barium (83.7-159.0mg/kg), calcium (2,160.0-3,220.0 mg/kg), chromium, total (8.7-9.9 mg/kg), cobalt (3.9-4.9 mg/kg), copper (6.9-10.0mg/kg), iron (8,570.0-10,800.0 mg/kg), lead (ND-18.1 mg/kg), magnesium (2,540.0-3,400.0mg/kg), manganese (203.0-221.0mg/kg), nickel (ND-4.7 mg/kg), potassium (2,570.0-3,010.0mg/kg), vanadium (17.2-20.8 mg/kg), zinc (27.0-41.8mg/kg), di-n-butyl phthalate (ND-0.56 mg/kg). fluoranthene (ND-O.41 mg/kg), DDE (ND-0.0088 mg/kg), and DDT (ND-0.0041 mg/kg).
Site 7. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (4,020.0-10,000.0 mg/kg), barium (35.5-214.0mg/kg), cadmium (ND-1.9 mg/kg), calcium (817.0-2,780.0 mg/kg), chromium, total (7.4-22.1 mg/kg), cobalt (2.4-8.1mg/kg), copper (4.3-56.9 mg/kg), iron (127.0-16,600.0 mg/kg), magnesium (1,490.0-4,760.0 mg/kg), nickel (ND-8.6mg/kg), potassium (1,540.0-5,000.0 mg/kg), silver (ND-35.7 mg/kg), sodium (ND-207.0 mg/kg), vanadium (10.5-33.1
S5-5
544 34
tuu.i: 5—2. SL.Rv:tcL Soil.CIrcrAMINANls ExCEEIUN.;EPA Rn;iuN IX PRGsS
S
.
Site Chemical
Maximum SiteConcentration (mgJlc
Region IXResidential
PRO(mg/kg)
4 Benzo(a)anthracene
Benzo(a)pyrene
Benzocb)fluoranthene
Benzo(g,h,i)perylene
Chrysene
Dibenz(a,h)anthracene
lndeno(l,2,3-c,d)pyrene
Beryllium
5.58.7
14.0
20.0
9.74.221.00.39
0.61
0.061
0.61
19°'
6.1°'
0.061
0.61
0.14
5 Beryllium 0.27 0.14
7 1 2,3,4,6,7,8-Heptachiorodibenzo-p-dioxin
Heptachiorinated dibenzo-p-dioxim, totalHexachiorinated dibenzo-p-dioxins, total
BerylliumLead
Manganese
0.00075
0.0013
0.0001
0.58
855.0
449.0
0.00038°'
0.00038°'
0.000038°'
0.14
130°'
380
9 Beryllium 0.42 0.1410 Benzo(a)anthracene
Benzo(a)pyrene .
Benzo(b)fluonnthene
Benzo(k)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-c,d)pyrene
3.23.53.71.8
0.963.9
0.61
0.061
0.61
0.61
0.061
0.61
13 Beryllium 0.27 0.14
IS Benzo(a)pyreneI ,2,3,4,6,7.8-Heptachlorodibenzo-p-dioxin
Heptachiorinated dibenzo-p-dioxins, total
Beryllium
0.340.00095
0.0016
0.33
0.061
0.00038°'
0.00038°'
0.14
16 Beryllium
Manganese
0.41
654.0
0.14
380
18 Beryllium 0.45 0.14
29 l,2,3,4.6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
BerylliumLead
Manganese
0.00079
0.0014
0.66
246.0
554.0
0.00038°'
0.00038°'
0.14
130°'
380
31 Benzo(a)antliracenc
Benzo(a)pyrene
Bcnzo(b)fluoranthene
lndeno(1,2,3-c,d)pyrene
BerylliumLead
Manganese
0.961.0
1.5
0.85
0.79
311.0
610.0
0.61
0.061
0.61
0.61
0.14
130°'
38034 Benzo(a)anthracene
Benzo(a)pyrene
BcnzoØ,)fluoranthene
5.83.24.9
0.61
0.061
0.61
5-6
544 3:
• iAItI.E 52. SURF:%UE Soil. ((1VF:flhi\ANl S EXCEEDINGEPA RECIUN IX PRGs
Site Chemical
Maximum SiteConcentration (mg/kg)
Region IXResidential
P1W(mg/kg)
34 lndeno(1,2,3-c,d)pyrene
Beryllium
2.2
0.28
0.61
0.14
38 Beryllium 0.29 0.14
A PRG was not available for this noncarcinogenic polynuclear aromatic hydrocarbon (PAH). The PRG foranthracene, which is the most conservative PRG for the noncarcinogenic PAHs, was used as a surrogate.
(2) The California EPA PRG was used for this chemical because it is more restrictive than the Region IX PRG.
2, 3, 7, S-TCDD is the only dioxin for which Region JX has calculated PRGs (3.SE-06 for residential soiland 2.4E-05 for industrial soil). Therefore, this PRG has been adjusted using a TEF (See Table 6-3 for alist of TEPs.)
Key: PRG Preliminary Remediation GoalTEF Toxicity Equivalency Factor
S
S5.7
544 3bmg/kg), zinc (22.1-87.6 mg/kg), 2,4-dimethylphenol (ND-2.3 mg/kg), 4-methylphenol (ND-3.9 mg/kg), trichloroethylene(ND-0.02 mg/kg), m,p-xylenes (ND-0.0063 mg/kg), xylenes, total (ND-O.01 15 mg/kg), DDE (ND-0.0067 mg/kg), DDT(ND-0.014 mg/kg), octachlorodibenzo-p-dioxin (ND-0.0037 mg/kg), and octachlorodibenzofuran (ND-0.00049).
Site 9. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (6,220.0-11,100.0 mg/kg), barium (97.6-129.0mg/kg), calcium (2,260.0-3,900.0 mg/kg), chromium, total (8.9-11.8 mg/kg), cobalt (5.0-6.3 mg/kg), copper (8.5-17.4mg/kg), iron (10,300.0-14,600.0mg/kg), lead (ND-11.9 mg/kg), magnesium (3,220.0-4,370.0mg/kg), manganese (230.0-300.0mg/kg), nickel (4.5-5.7 mg/kg), potassium (3,100.04200.0mg/kg), sodium (ND-i 17.0 mg/kg), vanadium (22.5-28.3mg/kg), zinc (30.0-44.7 mg/kg), and DDT (ND-0.0038 mg/kg).
Site 10. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (1 .610.0-1,790.0 mg/kg), barium (89.0-222.0mg/kg), cadmium (ND-0.52 mg/kg), calcium (1,830.0-2,940.0mg/kg), chromium, total (3.4-8.8 mg/kg), cobalt (1.8-2.2mg/kg), copper (4.0-4.8 mg/kg), iron (2660.0-2980.0 mg/kg), lead (14-37.4 mg/kg), magnesium (849.0-1,290.0 mg/kg),manganese (93.5-132.0 mg/kg), potassium (593.0-631.0 mg/kg), vanadium (5.6-6.7mg/kg), zinc (31.1-57.1mg/kg), bis(2-ethylhexyl) phthalate (ND-l .5mg/kg), benzo(g,h,i)perylene (3.1-3.6mg/kg). benzo(k)fluoranthene (1.5-1.8mg/kg), chrysene(2.9-4.5 mg/kg), fluoranthene (ND-8.8 mg/kg), phenanthrene (3.4-9.9 mg/kg), and pyrene (3.8-8.8 mg/kg).
Site 13. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (for the one sample collectedat this site) were detected at concentrations below the PROs: aluminum (7,290.0 mg/kg), barium (95.5 mg/kg), calcium(2,280.0 mg/kg), chromium, total (8.7 mg/kg), cobalt (4.9 mg/kg), copper (8.2 mg/kg), iron (10,600.0 mg/kg), magnesium(3,170.0mg/kg), manganese (221.0mg/kg), potassium (2,790.0 mg/kg), vanadium (20.8 mg/kg), and zinc (27.0 mg/kg).
Site 15. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (5,730.0-7,980.0 mg/kg), barium (29.7-108.0mg/kg), calcium (1,880.0-4,790.0 mg/kg), chromium, total (6.9-13.6 mg/kg), cobalt (3.7-5.8 mg/kg), copper (7.3-15.1mg/kg), iron (9,330.0-17,300.0mg/kg), lead (ND-10.0 mg/kg), magnesium (3,000.0-5,170.0mg/kg), manganese (160.0-372.0mg/kg), nickel (4.7-11.1 mg/kg), potassium (1,330.0-4,040.0mg/kg), sodium (ND-228.0 mg/kg), vanadium (18.5-• 27.5 mg/kg), zinc (26.8-40.1 mg/kg), benzo(b)fluoranthene (ND-0.54 mg/kg), benzo(g,h,i)petylene (ND-0.4 mg/kg),chrysene (ND-0.41 mg/kg), fluoranthene (ND-0.38 mg/kg), indeno(1 ,2,3-c,d)pyrene (ND-0.44 mg/kg), 2-methylnaphthalene(ND-5.8 mg/kg), naphthalene (ND-2.0 mg/kg), and phenanthrene (ND-2.1 mg/kg).
Site 16. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (5,550.0-10,500.0mg/kg), barium (106.0-172.0mg/kg), cadmium (ND-0.76 mg/kg), calcium (1,490.0-10,400.0mg/kg), chromium, total (6.2-27.6mg/kg), cobalt (3.6-7.7 /mg/kg), copper (6.9-18.7 mg/kg), iron (8,590.0-18,000.0 mg/kg), lead (ND-16.5 mg/kg), magnesium (2,390.0-5,990.0.mg/kg), mercury (ND-0.4 mg/kg), nickel (ND-8.5 mg/kg), potassium (2,090.0-5,320.0 mg/kg), silver (ND-17.3 mg/kg),sodium (ND-167.0 mg/kg), vanadium (17.3-38.8mg/kg), zinc (21.3- 88.8 mg/kg), alpha-chlordane (ND-0.003l mg/kg),gamma-chlordane (ND-0.0041 mg/kg), DDD (ND-0.016 mg/kg), DDE (ND-0.0042 mg/kg), and DDT (ND-0.0098m/kg),dieldrin (ND-0.0052 mg/kg). //Site 18. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (6,980.0-9,540.0mg/kg), barium (101.0-143.0mg/kg), calcium (2,810.0-10,500.0mg/kg), chromium, total (11.2-17.3mg/kg), cobalt (5.1-7.6 mg/kg), copper (10.7-14.0mg/kg), iron (9,960.0-13,500.0mg/kg), lead (6.9-38.8mg/kg), magnesium (3,410.0-5,480mg/kg), manganese (244.0-349.0mg/kg), mercury (ND-0.l4 mg/kg), nickel (5.3-9.2 mg/kg), potassium (3,060.0-4,530.0 mg/kg), vanadium (17.3-21.9mg/kg), zinc (31.6-45.5mg/kg), di-n-butyl phthalate (ND-0.56 mg/kg) alpha-chlordane (ND-0.01 1 mg/kg), gamma-chlordane(ND-0.0l2 mg/kg), and DDT (ND-0.0041 mg/kg).
Site 29. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (6,970.0-13,500.0 mg/kg), antimony (ND-i .6mg/kg), barium (84.8-200.0mg/kg), cadmium (ND-4.2 mg/kg), calcium (1,820.0-4,790.0 mg/kg), chromium, total (8.1-23.9mg/kg), chromium, hexavalent (ND-0.19 mg/kg), cobalt (5.0-10.4 mg/kg), copper (9.8-73.5 mg/kg), iron (11,200.0-• 20,000.0 mg/kg), magnesium (3,280.0-5,970.0 mg/kg), mercury (ND-0.78 mg/kg), nickel (ND-9.5 mg/kg), potassium(3,640.0-6,480.0 mg/kg), silver (ND-27.2 mg/kg), sodium (ND-441.0 mg/kg), vanadium (21.2-42.9 mg/kg), zinc (34.1-122.0mg/kg), benzo(b)fluoranthene (ND-0.37 mg/kg), fluoranthene (ND-O.68 mg/kg), alpha-chlordane (ND-O.0063 mg/kg),
5-8
544 37gamma-chlordane (ND-0.0062 mg/kg), DDD (ND-0.O11 mg/kg), DDE (ND-0.0097 mg/kg), and DDT (ND-0.028 mg/kg),and octachlorodibenzo-p-dioxin (ND-0.0029 mg/kg).
• Site 31. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PRGs: aluminum (6,440.0-18,000.0 mg/kg), antimony (ND-8.3mg/kg), barium (32.6-822.0 mg/kg), calcium (1,930.0-12,400.0 mg/kg), cadmium (ND-3.2 mg/kg), chromium, total (10.0-66.9 mg/kg), cobalt (4.2-10.2 mg/kg), copper (8.3-22.9 mg/kg), iron (11,000.0-23,200.0 mg/kg), magnesium (3,350.0-8,590.0 mg/kg), nickel (4.4-10.8 mg/kg), potassium (1,350.0-7,720.0 mg/kg), sodium (ND-446.0 mg/kg), vanadium (21.9-54.1 mg/kg), zinc (29.6-384.0 mg/kg), bis(2-ethylhexyl) phthalate (ND-0.5 mg/kg), benzo(g,h,i)perylene (ND-0.71),chiysene (ND- 1.3 mg/kg), fluoranthene (ND-2 .4 mg/kg), phenanthrene (ND-2.1 mg/kg), pyrene (ND-2 .3 mg/kg), DDT(ND-0.13 mg/kg), endosulfan sulfate (ND-0.046 mg/kg), and endrin aldehyde (ND-O.062 mg/kg).
Site 34. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (7,260.0-8,760.0 mg/kg), barium (87.5-139.0mg/kg), calcium (1,910.0-3,170.0 mg/kg), chromium, total (6.4-13.6 mg/kg), cobalt (4.7-6.5 mg/kg), copper (7.7-10.9mg/kg), iron (13,600.0-16,800.0 mg/kg) lead (5.7-37.8mg/kg), magnesium (3,140.0-4,430.0 mg/kg), manganese (249.0-315.0mg/kg), nickel (ND-4.2 mg/kg), potassium (3,790.0-4,880.0 mg/kg), sodium (128.0-274.0mg/kg), vanadium (21.5-30.2 mg/kg), zinc (38.4-71.4 mg/kg), anthracene (ND-3.8 mg/kg), benzo(g,h,i)perylene (ND-2.0 mg/kg), chrysene (ND-6.0mg/kg) fluoranthene (ND-13.0 mg/kg), phenanthrene( ND-10.0 mg/kg), pyrene (ND-10.0 mg/kg), and DDT (ND-0.045mg/kg).
Site 38. In addition to the analytes that exceed PROs listed in Table 5-2, the following analytes (and the ranges ofconcentrations) were detected at concentrations below the PROs: aluminum (6,860.0-9,900.0 mg/kg), barium (103.0-148.0mg/kg), calcium (1,950.0-2,200.0mg/kg), chromium, total (10.0-14.1 mg/kg), cobalt (12-7.0 mg/kg), copper (10.0-13.4mg/kg), iron (10,900.0-14,700.0mg/kg), lead (6.3-12.1 mg/kg), magnesium (3,300.0-4,410.0 mg/kg), manganese (214.0-295.0 mg/kg), nickel (ND-6.1 mg/kg), potassium (3,080-4,280 mg/kg), sodium (ND-118 mg/kg), vanadium (24.4-32.8mg/kg), zinc (33.2-83.8 mg/kg), DDD (ND-0.0077 mg/kg), DDE (0.025-0.036 mg/kg), DDT (0.018-0.046 mg/kg). anddieldrin (ND-0.017 mg/kg).
S
..5-9
544 386.0 SUMMARY OF SITE RISKS
A human health risk assessment was conducted for March AFB OU1 sites following USEPA Region IX and California EPAguidance. This baseline risk assessment produced estimates of the potential risks to public health from site contaminantsas if no cleanup would occur. Exposures to contaminated surface soil, groundwater, and alr were addressed by the riskassessment. Although groundwater is not currently used as a source of drinking water in the vicinity of March AFB, theState of California considers the groundwater a potential source of drinking water. Therefore, risk to potential futuregroundwater consumers (residents and industrial workers) was evaluated. Ecological risks for OU 1 sites were not addressedby the baseline risk assessment but will be addressed in an upcoming basewide RI/FS.
6.1 CHEMIcALS OF POTENTIAL CONCERN
Soil and groundwater analytical data were used to select chemicals of potential concern in soil, groundwater, and air for sitesor groundwater plumes. All organic analytes detected in one or more site samples were retained as chemicals of potentialconcern for that site. For naturally-occurring inorganic chemicals in the soil, the selection process included statisticalcomparisons of site inorganic concentrations to OU 1 background data. For inorganic chemicals in groundwater, totalinorganic concentrations were statistically compared with background data for total inorganics. Selection of a chemical asa potential chemical of concern does not in itself indicate a need for remediation. Chemicals of potential concern wereevaluated in the human health risk assessment, and the results of the risk assessment were used to detennine the need forremediation.
Soil gas data collected at Sites 4, 5, 18, and 31 were used to select volatile organic compounds (VOCs) of potential concernin air at these sites. All volatile chemicals of potential concern in soil that had a vapor pressure greater than 1 millimeterof mercury were also selected as VOCs of potential concern in alr.
The site arithmetic mean concentration and 95% upper confidence limit (UCL) of the arithmetic mean were calculated for• chemicals of potential concern in soil, groundwater, and air.
The following classes of chemicals were identified as chemicals of potential concern in either surface or subsurface soil:
• Inorganics: All sites.• PAHs: Sites 4, 5, 10, 15, 29, 31, and 34.• Organochiorine Pesticides: Sites 4, 5, 7, 9, 16, 18, 29, 31, 34, and 38.• Dioxins and Furans: Sites 7, 15, and 29.• Other SVOCs: Sites 4, 5, 7, 10, 18, 29, 31, and 34.• VOCs: Sites 4, 5, 7, 15, 18, and 31.
For groundwater the following classes of chemicals were identified as chemicals of potential concern:
• Inorganics: All plumes.• PAHs: OU1 Plume and Site 18 Plume.• Other SVOCs: All plumes.• VOCs: All plumes.
For air, VOCs were identified as chemicals of potential concern at the following sites: 4, 5, 7, 15, 18, 31, and 34.
For a complete listing of each chemical of potential concern identified at each site, see Volume I of the RemedialInvestigation/Feasibility Study Report for Operable Unit 1.
6.2 ExPosuRE ASSESSMENT
Current and future human receptors were identified by selecting receptors who are or may be exposed to contaminated media• (i.e., soil, groundwater, and air) at or migrating from OU1 sites. Human receptors could contact the following contaminated
media:
6-1
• Contaminated site surface soil. 5 44 3 9
• Contaminated site subsurface soil.
• Contaminated groundwater (i.e., the OU1 Plume, Site 4 Plume, and Site 18 Plume). Contaminatedgroundwater is not currently consumed by onbase or offbase receptors.
• Contaminated air (i.e., contaminated dust or airborne VOCs) at an OUt site or contaminated air that hasmigrated from an OU1 site to another area within OU1 or offbase.
The following human receptors who may contact contaminated site media were identified: current onsite base workers,current onbase/offsite adults, current offbase resident adults, current oftbase school children, current offbase workers, futureonsite resident children and adults, future onsite industrial workers, and future onsite construction workers.
Seven pathways were identified for receptors exposed to chemicals in soil, groundwater, or air. These exposure pathwaysare as follows:
• Dermal absorption of chemicals from the soil.• Incidental ingestion of chemicals in soil.• Ingestion of chemicals in drinking water.• Inhalation of volatilized organic compounds while showering.• Dermal absorption of chemicals in shower water.• Inhalation of contaminated fugitive dust.• Inhalation of volatile organic compounds.
Receptor intake estimates (i.e., exposure estimates) were calculated using receptor contaminant exposure concentrations andU.S. EPA acceptable intake models (i.e., formulas). Specific current receptor exposure information (i.e., receptor exposurefrequency and duration) was obtained through interviews of March AEB personnel and oftbase contacts. Where receptor-specific information was not available, applicable U.S. EPA and California EPA standard default exposure factors were used.Professional judgment was used for selection of other receptor-specific exposure factors.
6.3 ToxIcITy ASSESSMENT
A reference dose, or RfD, is the toxicity value most often used to evaluate non-carcinogenic effects resulting from exposureto contaminants. The U.S. EPA has developed RIDs for both the oral exposure route and reference concentrations (RfCs)for the inhalation exposure route. The first source for RIDs and RfCs (which were convened to inhalation RIDs) was theU.S. EPA's IRIS database. If RIDs or RfCs had not been published in IRIS, the U.S. EPA's Health Effects AssessmentSummary Tables (HEAST) was used as a second source. If values were not available from either IRIS or HEAST, AppliedAction Levels (AALs) developed by the State of California were used to calculate RIDs. In such cases, the AAL for airor water was assumed to be equivalent to a unit risk concentration and was converted to an inhalation or oral MD. OnlyAALs derived from non-carcinogenic endpoints for human receptors were used to convert to RIDs.
A slope factor is an upper 95th percent confidence limit of the probability of a carcinogenic response per unit intake of achemical over a lifetime. Slope factors were obtained from the U.S. EPA's IRIS as a first source. These slope factors havebeen verified by the U.S. EPA Carcinogen Risk Assessment Verification Endeavor (CRAVE) work group. If a slope factorcould not be retrieved from IRIS, the slope factor was obtained from the HEAST as a second source. Slope factor valuesdeveloped by the California EPA Standards and Criteria Work Group were used if more conservative than IRIS or HEASTvalues.
6.4 RISK CHARACTERIZATION AM) CONCLUSIONS
Risk is estimated by determining the amount of a chemical in a medium (soil, water, or air) that a person may ingest, inhale,or contact over a period of time (exposure) and comparing the exposure to a dose of the chemical known to cause harm.The risk potential is expressed in terms of the chance of a disease occurring. To calculate this chance, conservative• assumptions are made to protect public health.
Because cancer can result from exposure to chemicals at levels lower than that which cause other health problems, thegreatest concern is that exposure may result in cancer. Therefore, the exposure is compared to the probability of increasing
6-2
544 40the risk of cancer. A risk level of 1 in 1,000,000 means that one additional person out of 1 million people exposed coulddevelop cancer as a result of the exposure. To be considered protective of human health, the cancer risk from exposure toa chemical should be within or less than the range of 1 in 10,000 to I in 1,000,000. Non-cancer causing effects are• measured in terms of their hazard index, which is an index of the potential for adverse, non-cancer health effects. Theacceptable hazard index for protection of human health is less than or equal to 1. Risk from exposure to lead in theenvironment is expressed in terms of predicted blood-lead concentrations rather than increased risk of cancer.
Because March AFB is scheduled for realignment, portions of the base may become available for use by other governmentagencies or the public. Therefore, the risk assessment considered potential future land uses as well as current land uses inthe determination of risks posed by soil, air, and groundwater contaminants.
The populations potentially exposed to contaminants in OUI include workers currently at the base, current offbase residentsand school children, and potential future residents, industrial workers, or construction workers, if the base is redevelopedfor residential and/or industrial purposes. Table 6-I presents the increased risks to current workers and potential futureresidents, industrial workers, and construction workers as determined by the scenarios discussed below. The increased risks,as presented in Table 6-1, could result from the following:
• Current Risk for Workers, Ofibase Residents, and Ofmase School/Children from Exposure to -Contaminated Soils. A potential exists for current base workers to be adversely exposed to contaminantsthrough dernial contact with or ingestion/inhalation of contaminated soils. Additionally, offbase residentsand school children could be adversely exposed to soil contaminants through inhalation of contaminantsmigrating in air offbase. Current cancer risk was found to be elevated for base workers at Sites 15, 29,and 31. A summary of increased risks from exposure to contaminated soils is presented in Table 6-I.
• Future Risk for Residents from Exposure to Contaminated Soils. This setting assumes that there isunrestricted land use and that the base is redeveloped for residential housing. A potential exists for futureresidents to be adversely exposed through dermal contact with or ingestion/inhalation of contaminated soils.Increased cancer risk was found for exposure to contaminants in soils at Sites 4, 7, 9, 10, 15, 29, 31, and34. Table 6-1 presents increased risks for future residents. Increased noncancer risk was identified forexposure to contaminants in soils at Sites 10, 16, and 29.
• Future Risk for Industrial Workers from Exposure to Contaminated Soils. This setting assumes thatthe future use of the base is light industrial (such as continued use for aircraft repair). Future workerscould be exposed to site chemicals through contact with soil, or through soil ingestion/inhalation. Increasedcancer risk was found for exposure to contaminants in soils at Sites 4, 7, 9, 10, 15, 29, 31, and 34. Asummary of increased risks from exposure to contaminated soil is presented in Table 6-1.
• Future Risk for Construction Workers from Exposure to Contaminated Soils. Because it is assumedthat the base will be redeveloped in the future, construction activities, especially excavation, could causeconstruction workers to be adversely exposed through dermal contact with or ingestion/inhalation ofcontaminated soils. Increased cancer risk was found for exposure to contaminants in soil at Sites 4, 10,15, 31, and 34. A summary of increased risks from exposure to contaminated soils is presented in Table6-1.
• Future Risk for Residents and Industrial Workers from Drinking and Personal Use of ContaminatedGroundwater. The State of California considers groundwater beneath the base a potential source ofdrinking water. The risk related to drinking and using water (such as showering) from a plume wasassessed. A summary of increased risks from exposure to contaminated groundwater is presented in Table6-1.
Risk From Soils. The findings of the carcinogenic and noncarcinogenic risk assessment for receptor exposure to soilcontaminants for each site are discussed briefly below. Current onsite base workers and future onsite residents and industrialworkers have been assumed to be exposed to the 0- to 2-foot surface soil interval. Future construction workers have beenassumed to be exposed to the 0- to 12-foot subsurface soil interval..
6-3
C"
. .
. T
.•u;
i.i: 6
-1
—
SU
MM
.RY
OF
()U
1 R
isic
F S
ite
Haz
ard
Inde
x C
ance
r Ris
k S
ettin
g A
dult
Chi
ld
30-Y
ear R
esid
ent
I A
d tilt
. SO
IL
4 Fu
ture
Ind
ustr
ial
Wor
ker
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.00
2 0.
05
NA
N
A
NA
N
A
1 in
10
thou
sand
5
in 1
thou
sand
4 Fu
ture
Ons
ite R
esid
ent
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.00
5 0.
05
0.05
0.
3 1
in I
thou
sand
9
in I
thou
sand
N
A
NA
4 Fu
ture
Con
stru
ctio
n Wor
ker
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.02
0.
07
NA
N
A
NA
N
A
4 in
1 m
illio
n 3
in 1
00 th
ousa
nd
7 Fu
ture
Ons
ite R
esid
ent
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.03
0.
05
0.3
0,3
1 in
100
thou
sand
5
in 1
00 th
ousa
nd
NA
N
A
7 Fu
ture
Ind
ustr
ial W
orke
r D
irec
t Con
tact
with
Sur
face
Soi
l 0.
05
NA
N
A
2 in
100
tho
usan
d
9 Fu
ture
Ons
ite R
esid
ent
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.00
01
0.00
2 00
01
0.01
4
in I
mill
ion
5 in
100
thou
sand
N
A
NA
9 Fu
ture
Ind
ustr
ial W
orke
r D
irec
t Con
tact
with
Sur
face
Soi
l 0.
002
NA
N
A
2 in
100
thou
sand
10
Futu
re I
ndus
tria
l Wor
ker
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.01
0.
2 N
A
NA
N
A
NA
5
in 1
00 th
ousa
nd
tin I
thou
sand
10
Futu
re O
nsite
Res
iden
t In
gest
ion
of Su
rfac
e So
il D
irec
t Con
tact
with
Sur
face
Soi
l
0.05
0.
2 0.
5 1
4 rn
10
thou
sand
3
in 1
tho
usan
d N
A
NA
10
Futu
re C
onst
ruct
ion W
orke
r In
gest
ion
of Su
rfac
e So
il D
irec
t Con
tact
with
Sur
face
Soi
l
0.07
0.
3 N
A
NA
N
A
NA
2
in 1
00 th
ousa
nd
I in
10
thou
sand
IS
Futu
re I
ndus
tria
l Wor
ker
Inge
stio
n of
Sur
face
Soi
l D
irec
t C
onta
ct w
ith S
urfa
ce S
oil
0.01
00
4 N
A
NA
N
A
NA
4
in I
mill
ion
I in
10
thou
sand
6-4
Ui
. .
. rI
l%B
hI. 6
—I
SUM
M.%
RY
01'
OU
t
Con
tinue
d Si
te
Setti
ng
Haz
ard
lnde
* C
ance
r Ris
k A
dult
I C
hild
30
-Yea
r Res
iden
t A
dult
Sow
(CoN
TIN
uED
) IS
Fu
ture
Ons
ite R
esid
ent
Thg
estio
n of S
urfa
ce S
oil
Dir
ect
Con
tact
with
Sur
face
Soi
l 00
3 0.
04
0.3
0.2
4 in
I00
tho
usan
d 3
in 1
0 th
ousa
nd
NA
N
A
15
Fut
ure
Con
stru
ctio
n W
orke
r D
irect
Con
tact
with
Sur
face
Soi
l 0.
1 N
A
NA
tin
100
thnu
sand
15
C
urre
nt B
ase
Fire
Dep
artm
ent W
orke
r D
irect
Con
tact
with
Sur
face
Soi
l 0.
004
NA
N
A
I in
100
thou
sand
16
F
utur
e O
nsite
Res
iden
t In
gest
ion o
f Sur
face
Soi
l D
irect
Con
tact
with
Sur
face
Soi
l 0.
1 0.
7 1 4
tin 1
0 m
illio
n tin
10
mill
ion
NA
N
A
29
Fut
ure
Ons
ite R
esid
ent
Inge
stio
n of
Sur
face
Soi
l D
irect
Con
tact
with
Sur
face
Soi
l 0.
2 0.
6 I 4
tin 1
00 th
ousa
nd
1 in
10
thou
sand
N
A
NA
29
F
utur
e Thd
ustr
lal W
orke
r In
gest
ion
of Su
rfac
e S
oil
Dire
ct C
onta
ct w
ith S
urfa
ce S
oil
0.06
0.
6 N
A
NA
N
A
NA
2
in I
mill
ion
5 in
100
tho
usan
d 29
C
urre
nt W
orke
r at R
adar
Fac
ility
D
irect
Con
tact
with
Sur
face
Soi
l 0.
6 N
A
NA
S
in 1
00 t
hous
and
31
Fut
ure
Indu
stria
l Wor
ker
Inge
stio
n of
Sur
face
Soil
Dire
ct C
onta
ct w
ith S
urfa
ce S
oil
0.01
0.
1 N
A
NA
N
A
NA
4
in I
mill
ion
I in
10 t
hous
and
31
Futu
re
Ons
ite R
esid
ent
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.03
0.
1 0.
3 0.
7 4
in 10
0 th
ousa
nd
3 in
10
thou
sand
N
A
NA
31
Fu
ture
Con
stru
ctio
n Wor
ker
Dire
ct C
onta
ct w
ith S
urfa
ce S
oil
0.00
1 N
A
NA
tin
100 t
hous
and
31
Cur
rent
Site
Wor
ker
Inge
stio
n of S
urfa
ce S
oil
Dire
ct C
onta
ct w
ith S
urfa
ce S
oil
0.01
0.
t N
A
NA
N
A
NA
4
in 1
m
illio
n I i
n 10
thou
sand
6-5
6-6
S
. .
TA
BIJ
6—
I
——
S
nni..
un O
F O
H R
ISK
C
ontin
ued
Site
&
tting
Haz
ard
inde
x C
ance
r Ris
k
Adu
lt I
Chi
ld
30-Y
ear R
esid
ent
Adu
lt
SoiL
(CoN
TiN
UE
D)
34
Futu
re In
dust
rial
Wor
ker
Inge
stio
n of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.00
1 0.
02
NA
N
A
NA
N
A
4 in
100
thou
sand
2
in 1
thou
sand
34
Futu
re O
nsite
Res
iden
t In
gest
ion of
Surf
ace
Soil
Dir
ect C
onta
ct w
ith S
urfa
ce S
oil
0.00
2 0.
02
0.02
0.
1 4
in 1
0 th
ousa
nd
4 in
1 th
ousa
nd
NA
N
A
34
Futu
re C
onst
ruct
ion W
orke
r In
gest
ion
of Su
rfac
e So
il D
irec
t Con
tact
with
Sur
face
Soi
l 0.
0006
0.
tX)4
NA
N
A
NA
N
A
6 in
I m
illio
n 7
in 1
00 th
ousa
nd
GR
OU
ND
WA
TE
R
OU
I Pl
ume
Futu
re I
ndus
tria
l Wor
ker
Dir
ect C
onta
ct w
ith W
ater
Whi
le S
how
erin
g In
gest
ion
of G
roun
dwat
er
Inha
latio
n of
Vap
ors
Whi
le S
how
erin
g
0.09
0.
3 10
NA
N
A
NA
NA
N
A
NA
4 in
I m
illio
n 2
in 1
00 t
hous
and
9 in
10
thou
sand
OU
I Pl
ume
Futu
re O
nsite
Res
iden
t D
irec
t Con
tact
with
Wat
er W
hile
Sho
wer
ing
Inge
stio
n of
Gro
undw
ater
In
hala
tion
of V
apor
s W
hile
Sho
wer
ing
0.1
0.3
20
NA
.
NA
N
A
S in
1 m
illio
n 3
in 1
00 t
hous
and
2 in
1 th
ousa
nd
NA
N
A
NA
Site
4 P
lum
e Fu
ture
indu
stri
al W
orke
r D
irec
t Con
tact
with
Wat
er W
hile
Sho
wer
ing
Inge
stio
n of
Gro
undw
ater
In
hala
tion
of V
apor
s W
hile
Sho
wer
ing
0.1
0.3 20
NA
N
A
NA
NA
N
A
NA
3 in
100
thou
sand
tin
10
thou
sand
3
in 1
thou
sand
Site
4 P
lum
e Fu
ture
Ons
ite R
esid
ent
Dir
ect
Con
tact
with
Wat
er W
hile
Sho
wer
ing
Inge
stio
n of
Gro
undw
ater
In
hala
tion
of V
apor
s W
hile
Sho
wer
ing
0.3
0.5
20
NA
N
A
NA
6 in
100
thou
sand
2
in 1
0 th
ousa
nd
4 in
1 th
ousa
nd
NA
N
A
NA
Site
13
Plum
e Fu
ture
Indu
stri
al W
orke
r D
irec
t Con
tact
with
Wat
er W
hile
Sho
wer
ing
inge
stio
n of
Gro
undw
ater
In
hala
tion
of V
apor
s W
hile
Sho
wer
ing
4 80
200
NA
N
A
NA
NA
N
A
NA
2 in
I th
ousa
nd
7 in
I th
ousa
nd
S in
10
CA
)
. T
.uui
: 6-I
-
Sfli
M tR
Y O
F O
fl R
ISK
Con
tinue
d
Site
Se
tting
H
azar
d In
dex
Can
cer R
isk
Adu
lt I
child
30
-Yea
r Res
iden
t A
dult
GR
OU
ND
WA
TE
R (C
oNT
INuE
D)
Site
18
Plum
e Fu
ture
Ons
ite R
esid
ent
Dir
ect C
onta
ct w
ith W
ater
Whi
le S
how
erin
g In
gest
ion
of G
roun
dwat
er
Inha
latio
n of
Vapo
rs W
hile
Sho
wer
ing
5 N
A
100
NA
30
0 N
A
4 in
I th
ousa
nd
NA
I in
I hu
ndre
d N
A
9 in
10
NA
Key
: N
A
=
Not
App
licab
le
Not
e:
OnJ
y pa
thw
ays
whi
ch c
ontr
ibut
ed s
igni
fica
ntly
to ri
sk a
re in
clud
ed.
01
a.
a.
a. a
6-7
544 45• Site 4. No risk to current populations was identified for Site 4. As discussed above, the risk assessment
also considered hypothetical future residents, light industrial workers, and construction workers who mightlive or work on or near Site 4. For hypothetical future residents, industrial workers, and constructionworkers, an increased cancer risk was identified. The contaminants at Site 4 that most affected risk arePAl-Is.
• Site 5. No risk to current or future populations was identified for Site 5.
• Site 7. No risk to current populations was identified for Site 7. For hypothetical future residents andindustrial workers, an increased cancer risk was identified. The contaminants at Site 7 that most affectedrisk are beryllium and dioxins.
• Site 9. No risk to current populations was identified for Site 9. For hypothetical future residents andindustrial workers, an increased cancer risk was identified. The contaminant at Site 9 that most affectedrisk is beryllium.
• Site 10. No risk to current populations was identified for Site 10. For hypothetical future residents,industrial workers, and construction workers, an increased cancer risk was identified. The contaminantsat Site 10 that most affected cancer risk are PAHs and beryllium. For hypothetical future residents, anincreased noncancer risk was identified. The contaminant that most affected noncancer risk is manganese.
• Site 13. No risk to current or future populations was identified for Site 13.
• Site 15. A cancer risk was identified for current onsite base workers at Site 15. For hypothetical futureresidents, industrial workers, and construction workers, an increased cancer risk was identified. Thecontaminants at Site 15 that most affected risk are PAHs and dioxins.
• Site 16. No risk to current populations was identified for Site 16. For hypothetical future residents, anincreased noncancer risk was identified. The contaminant that most affected risk is manganese.
• Site 18. No risk to current or future populations are identified for Site 18 soils.
• Site 29. An increased cancer risk was identified for current onsite base workers at Site 29. Forhypothetical future residents and industrial workers, an increased cancer risk was also identified. Thecontaminants at Site 29 that most affected cancer risk are beryllium, PAHs and dioxins. For hypotheticalfuture residents, an increased noncancer risk was identified. The contaminant that most affected noncancerrisk is manganese.
• Site 31. An increased cancer risk was identified for current onsite workers at Site 31. For hypotheticalfuture residents, industrial workers, and construction workers, an increased cancer risk was also identified.The contaminants at Site 31 that most affected risk are PARs and beryllium.
• Site 34. No risk to current populations was identified for Site 34. For hypothetical future residents,industrial workers, and construction workers, an increased cancer risk was identified. The contaminantsat Site 34 that most affected risk were PANs.
• Site 38. No risk to current or future populations was identified for Site 38.
Predicted concentrations of lead in blood (Pb-B) for receptors show that Pb-B concentrations for the following receptorsexceed the Pb-B concentration of concern of 10 jzg/dL:
• Future Onsite Resident Children (ingestion rate of 200 mg/day).
- Site 31 (estimated Pb-B concentration of 10.5 g/dL for the 99th percentile).
These receptors are considered to have borderline risk through exposure to lead.
6-8
544 46Risk from Groundwater. Results of the carcinogenic and noncarcinogenic risk assessment for exposure to groundwatercontaminants within each plume are discussed briefly below:
S OUI Groundwater Plume. Throughout the area of the OU 1 groundwater plume, there are no current• users of groundwater. Therefore, no receptors are currently exposed to groundwater contaminants andthere is no increased risk of cancer. However, since the State of California considers all groundwater aspotential drinking water, the risk assessment considered the exposure of hypothetical future resident adultsand industrial workers who may occupy this area. For future receptors, an increased risk for both residentadults and industrial workers was identified using this assumption. This increased risk was due to exposureto groundwater contaminated with benzene, bromodichioromethane, bromoform, carbon tetrachloride,dibromochloromethane, 1 ,2-dichloroethane, 1,1 -dichloroethene, methylene chloride, tetrachioroethylene,
• and trichloroethylene. For future resident adults and industrial workers, an increased noncancer risk wasidentified for exposure to OU 1 plume water. The contaminants that most affected noncancer risk wereTCE and carbon tetrachioride.
• Site 4 Plume. There are no current users of groundwater from the Site 4 plume. Therefore, no receptorsare currently exposed to groundwater contaminants and there is no increased risk of cancer. However, forfuture receptors, increased risk was identified for both resident adults and industrial workers. Thisincreased risk was due to exposure to groundwater contaminated with tetrachloroethylene, trichloroethylene,benzene, bis(2-ethylhexyl)phthalate, 1 ,4-dichlorobenzene, 1 ,2-dichloropropane, cis-1 ,2-dichloroethene,methylene chloride, and vinyl chloride. For future resident adults and industrial workers, an increasednoncancer risk was identified for exposure to Site 4 plume water. The contaminants that most affectednoncancer risk were TCE, PCE, and cis-l,2-DCE.
• Site 18 Plume. There are no current users of groundwater from the Site 18 plume. Therefore, noreceptors are currently exposed to groundwater contaminants and there is no increased risk of cancer.However, for future receptors, increased risk was identified for both resident adults and industrial workers.This increased risk was due to exposure to groundwater contaminated with benzene, ethylbenzene,methylene chloride, thallium, toluene, trichloroethylene, and total xylenes. For future resident adults and• industrial workers, an increased noncancer risk was identified for exposure to Site 18 plume water. Thecontaminants that most affected noncancer risk were TCE, toluene, xylenes (total), ethylbenzene, andthallium.
• Site 31 Plume. For risk assessment purposes, the Site 31 plume was considered part of the OUt plume.
Conclusions. Actual or threatened releases of hazardous substances from OUt sites at March AFB, if not addressed by theresponse actions selected in this ROD, may present a current or potential threat to public health, welfare, or the environmentas discussed in Section 6.4.
6.5 Cleanup Standards and Gtals
Section 6.6.1 presents groundwater cleanup standards based on ARARs and Section 6.6.2 presents soil cleanup standards.Surface soil cleanup standards in are based on risk-based PRGs, and subsurface soil cleanup standards are based on protectionof groundwater from contaminant sources in subsurface soil.
6.5.1 Groundwater Cleanup Standards and Goals
ARARs are Applicable or Relevant and Appropriate Requirements. A requirement may be "applicable" or "relevant andappropriate". "Applicable" requirements are those promulgated Federal or state requirements that specifically address ahazardous waste site. "Relevant and appropriate" requirements are those promulgated Federal or state requirements that,while not legally applicable, are designed to apply to problems sufficiently similar to those encountered at CERCLA sitesthat their application is appropriate. Relevant and appropriate requirements are applied in the same manner as applicablerequirements.
• For those situations or chemicals where no ARAR exists, or where the ARAR is not protective of human health and theenvironment, to-be-considered (TBC) information is evaluated. There are a number of guidance documents andnon-promulgated standards that can be used in the development of "criteria" for remedial action. This step of the ARARs
6-9
544 47process involves review of advisory, guidance, and nonpromulgated standards documents to aid in the development of otherconsiderations for site remedial actions.
• There are three types of ARARs: chemical-specific, location-specific, and action-specific. In addition to thechemical-specific standards used as cleanup standards, CERCLA requires that site cleanups comply with otherlocation-specific and action-specific ARARs. Location-specific ARARs govern activities in certain environmentallysensitive areas, such as floodplains, wetlands, endangered species habitats, or historically significant resources.Action-specific ARARs are restrictions that define acceptable treatment and disposal procedures for hazardoussubstances. These ARARs generally set performance, design, or other similar action-specific controls or restrictionson particular kinds of activities related to management of hazardous substances or pollutants. These chemical-, location-,and action-specific ARARs are discussed in Chapter 8.0 and the accompanying tables.
Although there are no current users of groundwater in the immediate vicinity of March AFB, the State of California considersgroundwater beneath the base to be a source of drinking water. Therefore, Federal and State MCLS, which are chemical-specific ARARs and drinking water standards, are considered to be protective of human health, and appropriate as cleanupstandards. The Federal MCLs are established in 40 CFR 141.61(a) and the California MCLs are established in Title 22 CCR64444.5. Where the Federal and State MCLS for a contaminant are not the same, the more stringent of the two is used asa cleanup standard.
Table 6-2 presents maximum concentrations of groundwater contaminants in each plume identified and the associatedgroundwater cleanup standards.
6.5.2 Soil Cleanup Standards and Goals
The standard of soil cleanup is twofold: to protect human health by preventing exposure to contaminated soils, and toprevent further degradation of groundwater from contaminants migrating downward through the soil. Cleanup levelsnecessary to meet these two standards were determined by considering two soil zones: surface soil (0-2 feet below groundsurface) and subsurface (from the ground surface to groundwater level). For the surface soil interval, cleanup standards werebased on U.S. EPA Region IX risk-based PROs; for subsurface soil, the standards were based on results of computermodeling. Section 6.6.2.1 discusses cleanup for surface soil, and Section 6.6.2.2 discusses cleanup for subsurface soil.
6.5.2.1 Surface Soil Cleanup Standards and Goals
Surface soil cleanup standards at March AFB are based on U.S. EPA Region IX residential scenario PROs; residentialPROs were used because they are considered protective of human health. These PROs were determined to be appropriatefor all sites with the exception of Sites 7 and 29. At these sites, rather than basing remediation goals on unrestricted(residential) land use, the remediation goals were set for industrial land use. The reasons for using industrial land usescenario PRGs are discussed below.
The following is a discussion, by site, of the chemicals that exceed U.S. EPA Region LX PROs. Table 6-3 presentsconcentrations of chemicals that exceed Region IX PROs at each site. It also presents U.S. EPA Region IX residentialPROs for all sites as well as industrial PRGs for Sites 7 and 29. As discussed in Section 5.0, a contaminant does notnecessarily require remediation even though it may be detected at concentrations greater than the PRO. Contaminants thatrequire remediation were determined by considering chemicals that exceed PROs as well as by considering the results of therisk assessment (see Section 6.4 Risk Characterization and Conclusions) and other relevant site-specific information.
.6-10
.
= Micrograms per liter= California Regional Water Quality Control= Maximum Contaminant Level
544 48
S
40 Code of Federal Regulations (CFR) 141.12 and 141.61 Maximum Contaminant Levels for Organic Contaminants.2
Title 22, California Code of Regulations (CCR), Division 4, Chapter 15, Article 5.5, Section 64444.5, MaximumContaminant Levels for Organic Chemicals.Water Quality Control Plan, Santa Ma River Basin, 1984. Water Quality Objectives.NPDES Permit, CAG918001, 14 March 1995
6-Il
i'ABI.E 6-2GROL.NL)%AIER CI.EANLI' SIANI)ARDS
.
Plume Contaminant
MaximumConcentration
(pg/I)
Cleanup Standard(State or Federal MCL)
(pg/I)Site 4 Methylene Chloride
Tetrachloroethene (PCE)Trichloroethene (TCE)Vinyl ChlorideBis(2-ethylhexyl)phthalatecis-l,2-Dichloroethene
9260858
29021
5 (federalY5 (state and federal)'25 (state and federal)'2
0.5 (state)24 (state)26 (state)2
Site 18 BenzeneToluene
EthylbenzeneMethylene ChloridePhenols, TotalXylenes, Total
12,00011,0001,500
44073
7,700
1 (state)210 (federal)'10 (federal)4
5 (federal)40 (state RWQCB)'
10 (federal)'Site 31 Bis(2-ethylhexyl)phthalate
l,1-DichloroetheneTrichloroethene
63260
1,400
4 (state)26 (state)2
5 (state and 2
OU1 Bis(2-ethylhexyl)phthalateBenzeneCarbon TetrachlorideTrichloroethene (TCE)1,1 -Dichloroethenecis-1,2-DichloroetheneMethylene ChlorideTetrachjoroethene (PCE)I ,2-DichloroethanePhenols, Total
130420
314002603045192579
4 (state)21 (state)2
0.5 (state)25 (state and federal)12
6 (state)26 (state)2
5 (federal)15 (state and federal) 1.2
0.5 (state)240 (state RWQCB)3
Key: pg/lRWQCBMCL
Board, Santa Ana Region
544 49Site 4. Beryllium and several PAHs were detected in surface soil at concentrations greater than U.S. EPA Region IXresidential PROs (see Table 6-3). The results of the risk assessment indicate that beryllium at this site does not requireremediation. However, the risk assessment indicates that the following PAHs, which also exceed PROs, present a potential• health risk and, therefore, require remediation: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, chrysene,dibenz(a,h)anthracene, and indeno(1,2,3-c,d)pyrene. The estimated area requiring reinediation at Site 4 is 435,164 squarefeet. See Figure 6-1.
Site 5. Beryllium was detected at concentrations greater than the U.S. EPA Region IX PRO (see Table 6-3). The resultsof the risk assessment indicate that beryllium does not require remediation. Consequently, no contaminants at this siterequire remediation.
Site 7. Beryllium, lead, manganese, and several dioxins were detected at concentrations greater than U.S. EPA Region IXresidential PROs (see Table 6-3). For lead, a method developed by the California EPA, Department of Toxic SubstancesControl was used to estimate blood-lead concentrations, based on exposure to lead by multiple pathways. Results of thismethod indicate that lead does not require remediation. The results of the risk assessment indicate that manganese does notrequire remediation. U.S. EPA Region IX industrial PROs, rather than residential PRGs, were used to determine the needfor cleanup at Site 7 for the following reasons:
• Site 7 is located in an area to be retained by March Air Force Base, and to which the public does not haveaccess.
• It is unlikely that Site 7 will be used for residential purposes in the future.
• Cleanup of Site 7 is considered cost-prohibitive in light of the minor risk reduction that would be achieved.The combined cost for Site 7 and Site 29 (which has also been selected for remediation based on industrialPRGs) would be $22 million.
The Air Force will ensure that this site is used appropriately in the future by implementing deed restrictions prohibitingresidential land use. Based on U.S. EPA Region TX industrial land use PROs, beryllium and dioxins do not requireremediation at this site. Consequently, no contaminants at this site require remediation.
Site 9. Beryllium was detected at concentrations that exceed the U.S. EPA Region IX residential PRO (see Table 6-3); therisk assessment also indicates increased risk for beryllium at this site. The average surface soil (0-2 ft. bgs) concentrationsof beryllium (0.34 mg/kg) slightly exceeded the average background concentration (0.27 mg/kg). However, concentrationsof beryllium observed at Site 9 are considered naturally-occurring for the reasons outlined below, and do not requireremediation:
• There is no current or historical information indicating that beryllium was used, stored, or disposed of atSite 9.
• The range of beryllium concentrations observed at Site 9 falls within the range of backgroundconcentrations observed, i.e., the maximum site concentration (0.42 mg/kg) is less than the maximumbackground concentration (0.43 mg/kg).
• Background concentrations of beryllium exceed the U.S. EPA Region IX PRO for unrestricted land use,indicating naturally-elevated concentrations of beryllium at March AFB.
• The spatial distribution of beryllium concentrations at Site 9 is fairly uniform; there are no obvious "hotspots" or areas of elevated concentrations.
• Levels of beryllium found at Site 9 are within the acceptable range for cancer risk (1O to I0' cancer risk)for unrestricted land use. There are no other contaminants detected at Site 9 that would contribute tounacceptable risk.
Consequently, no contaminants at this site require remediation.
6-12
544 50T.rn.F. 6-3. C NUEVI R,VIIO'sS OF SLRF.U t SOIL. 'ONI .kMIN.tNTS
I:xi l. iui's; EPA Rn;u 'N IX PRGs
Site Chemical Range ofConcentration
at Site(n,plkp%
95% UpperCmifldence
Limit(mpIko
Region IXResidential
PRG°(mptkpl
Region IXIndustrial
PRG°'(mIka
4 Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluonnthene
Benzo(g.h.i)perylene
Chrysene
Dibenz(a,h)anthracene
lndeno(1,2,3-c,d)pyreneBeryllium
ND-5.5
ND-8.7
ND-14.0
NO-20.0
ND-9.7
ND-4.2
ND-21.0
ND-&39
5.58.714.0
20.09.74.2
21.0
0.39
0.610.061
0.61
196.P0.061
0.61
0.14
--
-----
5 Beryllium NO-0.27 0.27 0.14 -
7 I,2.3.4.6.7.8-Heptachlorodibenzo-p-dioxin
1-leptachlorinated dibenzo-p-dioxins. total}Iexachlorinated dibenzo-p-dioxins, total
BerylliumLead
Manganese
NO-0.00075
ND-0.0013
ND-0.0001
ND-0.58
ND-855.0
111.0-449.0
0.00075
0.0013
0.000089
0.38
80.6
256.7
00Q038t)
0.OO038°
000003$t)0.14
130°380
Q0024t4)
0.0024'0.00024°
1.1
1000
7800-
9 Beryllium 0.26.0.42 0.39 0.14 -
10 Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-c,d)pyrcne
2.0-3;2
2.9-3.5
3.3-3.7
1.5-1.8
ND-0.96
3.6-3.9
3.23.5
3.71.8
0.96
3.9
0.61
0.061
0.61
0.61
0.061
0.61
--
--
13 Beryllium 0.27' 0.27 0.14 -
IS Benzo(a)pyrene
l,2.3.4.6.7,8-Heptachlorodibenzc-p-dioxin
Heptachlorinated dibenzo-p-dioxins. total
Beryllium
ND-0.34
NO.0.00095
NO.0.0016
NO.0.33
0.34
0.00095
0.0016
0.3
0.061
0.00038'°
0.000380.14
---
-
16 Beryllium
Manganese
NO.0.41
186:0-654.0
0.41
450.!0.14
380
--
18 Beryllium 0.23-0.45 0.42 0.14 -
29 1,2,3.4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachiorinated dibenzo-p-dioxins, total
BerylliumLead
Manganese
ND-0.00079
NO.0.0014
017-0.665.3-246.0
250.0-554.0
0.00079
0.0014
0.45
82.9
351.5
o00038t4)
0.00038t4)
0.14
130°380
00024t)
00024t4)
1.1
1000
7800
31 Bcnzo(a)anthracene
Bcnzo(a)pyrene
Benzo(b)fluoranthene
Indeno(1,2,3.c.d)pyreneBeryllium
NO.0.96ND-1.0
NO-1.S
NO.0.85
NO.0.79
0.30
0.34
0.53
0.26
0.39
0.610.061
0.61
0.61
0.14
-----
31 Lead
Manganese
NO-311.0
188.0-610.0
121.0
307.!l30°380
.
34 Benzo(a)anthracene
Benzo(a)pyrene
Benzorb)fluoranthene
lndeno(l,2.3-c,d)pyrene
ND-5.8
ND-3.2
ND-4.9
ND-2.2
5.83.20
4.90
2.20
0.61
0.061
0.61
0.61
---
-
a
a
6-13
Range of 95% Upper Region IX Region DCConcentration Confidence Residential Industrial
at Site Limit ERG' PRG'(mo/kd (nia/ko (mpfka (nwIka
Region IX residential soil PROs were used for all sites except sites 7 and 29. At sites 7 and 29, industrial soil PROs wereused.
A PRO was not available for this noncarcinogenic polynuclear aromatic hydrocarbon (PAll). The PRO for anthracene,which is the most conservative PRO for the noncarcinogenic PAl-Is, was used as a surrogate.
The California EPA PRO was used for this chemical because it is more restrictive than the Region IX PRO.
(4) 2, 3, 7, 8-TCDD is the only dioxin for which Region DC has calculated PROs (3.8E-06 for residential soil and 2.4E-05 forindustrial soil). Therefore, this PRO has been adjusted using a TEF listed in the table below. This adjusted value wascompared to site concentrations.
Key: PRO = Preliminary Remediation GoalTEF = Toxicity Equivalency Factor ,-
Only one sample was collected at this site.
I544 51
Tutu-: 6—3. Cc 'xn-:Nri&vi itj7%S 01:S! grt -i-; Soil. Cosi:uirc:yisExnrriu'.a; EI'.-t ItFCU 'N IX PRCs
0.22-0.28
ND-0.29
0.27
0.29
0.14
0.14
)
1%
Toxicity Equivalency Factors for Dioxins
Congener TEF
1 ,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin 0.01
Heptachiorinated dibenzo-p-dioxins, total 0.01
Hexacblorinated dibenzo-p-dioxins, total 0.1
Octachlorodibenzo-p-dioxinOctachlorodibenzofuran 0.001
TEFs were obne4fvSup,Iernental Guidance for HumanHealth MultirnsjL kisx$essments of Hazardous Waste Sitesand Pennittedc6tiüFicfltate of Calif9rnia Environmental.,Pretection AgèfleDc$artment of Toxic Substàñdes Control,Office of the Science Advisor July 1992.
-
ft
(51
53
p.
.6-14
544 52
ExplanationSurface soil sample location
Inactive landfill area to be capped
800 Feet
6-15
slope of 20% of cover
space between cover and storm drain
Site 4 Boundary.L
S • 45L1March Air Force Base, California
Site 4 Surface SoilContamination
544 53Site 10. Several PAHs were detected in surface soil at concentrations that exceed U.S. EPA Region IX PROs (see Table6-3) and were also identified by the risk assessment as presenting a potential health risk. The PAHs that require remediationare: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenz(a,h)anthracene, andindeno(1,2,3-c,d)pyrene. The estimated volume of PAH contaminated soil is 76 cubic yards. See Figure 6-2.
In addition to the PAHs, manganese was detected at Site 10 at concentrations that indicate potential risk. However, themaximum concentration of manganese (132.0 mg/kg) is less than the U.S. EPA Region IX PRO for residential land use (380mg/kg). Furthermore, the concentrations of manganese at Site 10 are considered naturally-occurring for the reasons outlinedbelow, and do not require remediation:
There is no current or historical information indicating that manganese was used, stored, or disposed ofat Site 10.
• The range of manganese concentrations observed at Site 10 falls within the range of backgroundconcentrations observed, i.e., the maximum site concentration (132.0 mg/kg) is less than the maximumbackground concentration (402.0 mg/kg).
• The mean concentration at the site (112.8 mg/kg) is less than the mean background concentration (266.1mg/kg).
• The spatial distribution of manganese is fairly uniform, with no apparent patterns of elevatedconcentrations.
Site 13. Beryllium was detected at concentrations greater than the U.S. EPA Region IX PRO (see Table 6-3). The resultsof the risk assessment indicate that beryllium at this site does not require remediation. Consequently, no contaminants atthis site require remediation.
Site 15. Beryllium, benzo(a)pyrene, and two dioxins were detected at concentrations greater than U.S. EPA Region IXresidential PROs (see Table 6-3). The risk assessment indicates that beryllium does not require remediation at this site.Although dioxin concentrations exceed the U.S. EPA Region IX PRO for unrestricted land use, cancer risk from dioxinsis within the acceptable range for cancer risk (10 to 10 cancer risk) and therefore dioxins do not require remediation atSite 15. Other contaminants present at Site 15 (PAHs) will be remediated and will not contribute to excess cancer risk. Theestimated volume of PAN-contaminated soil is 15 cubic yards. See Figure 6-3.
Site 16. Beryllium and manganese were detected at concentrations that exceed U.S. EPA Region IX PRGs (see Table 6-3).The risk assessment indicates that beryllium does not require remediation at this site; manganese was detected atconcentrations that indicated potential risk. For manganese, the average surface soil concentration of 366.5 mg/kg slightlyexceeds the average background concentration of 266.1 mg/kg. However, concentrations of manganese detected at Site 16are considered naturally-occurring for the reasons outlined below, and do not require remediation:
• There is no current or historical information indicating that manganese was used, stored, or disposed ofat Site 16.
Of the 10 surface soil samples collected at Site 16, all but one fall within the range of backgroundconcentrations. The one sample that exceeds the range of background concentrations was 654.0 mg/kg,compared to the maximum background concentration of 402.0 mg/kg.
• The maximum background concentration (402.0 mg/kg) exceeds the U.S. EPA Region IX PRO forunrestricted land use, indicating naturally-elevated concentrations of manganese at March AFB.
• The spatial distribution of manganese is fairly uniform, with no apparent patterns of elevatedconcentrations.
The mean concentration of manganese (366.5 mg/kg) is less than the U.S. EPA Region IX PRO for• residential land use. The 95% UCL of the mean (450.1 mg/kg) only slightly exceeds the PRO. There areno other contaminants at Site 16 that would contribute to unacceptable risk.
6-16
SSITE 29
SITE 9
Flightline Drainage Channel
Perris Valley Storm DrainLateral A
Explanation
k:ass4 SOUrCe ama
ld:*i(M Area requiring excavation
Site 10 Surface SoilContamination320 Feet
6-17
Site 15 Boundary
Explanation
Area RequiringExcavation
6-18
Site 15 Surface SoilContamination
a200 Feet
Consequently. no contaminants at this site require remediation. 5 44 5 6
Site 18. Beryllium was detected at concentrations greater than the U.S. EPA Region IX PRG (see Table 6-3); however,the results of the risk assessment indicate that beryllium at this site does not require remediation. Consequently, no surfacesoil contaminants at this site require remediation.
Site 29. Beryllium, lead, manganese, and two dioxins were detected at concentrations that exceed U.S. EPA Region IXresidential land use PRGs (see Table 6-3). For lead, the method developed by the California EPA, Department of ToxicSubstances Control, was used to estimate blood-lead concentrations, based on exposure to lead by multiple pathways.Results indicate that lead does not require remediation.
U.S. EPA Region IX industrial PRGs, rather than residential PRGs, were used at Site 29 for the following reasons:
Site 29 is located in an area to be retained by March Air Force Base, and to which the public does not haveaccess.
• It is unlikely that Site 29 will be used for residential purposes in the future.
• Cleanup of Site 29 is considered cost-prohibitive in light of the minor risk reduction that would beachieved. The combined cost for Site 29 and Site 7 (which has also been selected for remediation basedon industrial PRGs) would be $22 million.)
The Air Force will ensure that this site is used appropriately in the future by implementing deed restrictions prohibitingresidential land use.
Based on U.S. EPA Region IX industrial land use PRGs, no chemicals at this site require remediation.
Site 31. Concentrations of beryllium, lead, manganese, and several PANs exceed U.S. EPA Region IX PROs (see Table6-3). For lead, the method developed by the California EPA, Department of Toxic Substances Control was used to estimateblood-lead concentrations. Results indicated that lead does not require remediation. The results of the risk assessmentindicate than manganese at this site does not require remediation.
Beryllium was detected at Site 31 in concentrations that exceed the U.S. EPA Region IX PRG for unrestricted land use.The average surface soil concentration of beryllium (0.35 mg/kg) slightly exceeds the average background concentration ofberyllium (0.27 mg/kg). However, concentrations of beryllium at the site are considered naturally-occurring for the reasonsoutlined below, and do not require remediation:
• There is no current or historical information indicating that beryllium was used, stored, or disposed of atSite 31. Site 31 is a solvent spill area. Chlorinated solvents were discharged to the ground through aleaking drain pipe and potentially through surface spillage. Soils data show no anomalous values forberyllium in the areas contaminated by chlorinated solvents, indicating that beryllium occurrences in Site31 soils are unrelated to past waste handling activities.
• Of the 58 surface soil samples collected at Site 31, the maximum concentration of beryllium (0.79 mgfkg)was only slightly higher than the maximum background concentration (0.43 mg/kg).
• Background concentrations of beryllium exceed the U.S. EPA Region IX PRO for unrestricted land use,indicating naturally-elevated levels of beryllium at March AEB.
• Concentrations of beryllium detected at Site 31 are within the acceptable range for cancer risk (10 to I0cancer risk) for unrestricted land use. Other contaminants at Site 31 that could contribute to cancer risk(chlorinated solvents and polynuclear aromatic hydrocarbons) will be remediated and will not contributeto unacceptable risk.
• The risk assessment indicates that the following PANs, which also exceed PROs, present a potential health risk andtherefore require remediation: benzo(a)anthracene, benzo(a)pyrene, benzo(b)tluoranthene, and indeno( 1,2, 3-c,d)pyrene.The estimated volume of surface soil requiring clean-up is 1,700 cubic yards. See Figure 6-4.
6-19
ILJ
Explanation
7A Area Requiring Excavation
400 FeetSite 31 Surface Soil
Contamination
SSite 31 Boundary
0
6-20
544 58Site 34. Beryllium and several PAHs were detected at concentrations that exceed U.S. EPA Region IX PROs (see Table6-3). The results of the risk assessment indicate that beryllium at this site does not require remediation. The followingPAHs, which also exceed PROs, present a potential health risk and, therefore, require remediation: benzo(a)anthracene,benzo(a)pyrene, benzo(b)fluoranthene, and indeno(1 ,2,3-c,d)pyrene. The estimated volume of soil requiring remediationat Site 34 is 440 cubic yards. See Figure 6-5.
Site 38. Beryllium was detected at concentrations that exceed the U.S. EPA Region IX PRO (see Table 6-3). However,the results of the risk assessment indicate that beryllium at this site does not require remediation. Consequently, nocontaminants at this site require remediation.
6.5.2.2 Subsurface Soil Cleanup Standards and Goals
For the protection of groundwater, the California Regional Water Quality Control Board, Santa Ana Region, requested thatthe Air Force develop and propose cleanup criteria for soils that would be protective of groundwater. Cleanup criteria forsubsurface soils were developed such that soil contaminants would not be expected to leach into groundwater atconcentrations greater than applicable groundwater standards (Federal and State MCLs).
Impacts of contaminant migration from soil to groundwater were assessed by modeling the entire soil column from theground surface to groundwater. Two models were used: VLEACH, a vadose zone contaminant transport model, andMJXCELL, a mixing cell model that calculates groundwater contaminant concentrations from contaminant fluxes suppliedby VLEAC}-I. Based on modeling results, Site 18 is the only site at which soil contaminants could be expected to leach intogroundwater at concentrations that exceed MCLs.
Subsurface soils at Sites 31 and 34 were also evaluated for potential contributions to groundwater contamination. Neithersite exceeded allowable limits predicted using the VLEACH/MIXCELL methodology. However, due to the existinggroundwater contamination at these sites and the potential for subsurface soil contaminants to provide a continuing sourceof groundwater contaminants, the California Regional Water Quality Control Board requested that these two sites be includedin subsurface soil remediation strategies.
Site 18. The primary subsurface soil contaminants of concern are jet fuel and its components. Since jet fuel has migratedto the water table and impacted groundwater with concentrations of contaminants above MCLs (i.e., benzene), the CaliforniaRegional Water Quality Control Board, Santa Ana Region requires soil remediation. Contaminants detected include volatilejet fuel components (BTEX compounds) as well as oil and grease, and semivolatiles (naphthalene, bis(2-ethylhexl) phtha!ate,and Di-n-butyl phthalate). The volatile components of jet fuel (BTEX compounds) are the most mobile in soil andgroundwater and are therefore of greatest concern. Maximum concentrations detected were 97 mg/kg for berrzene, 69 mg/kgfor toluene, 36 mg/kg for ethylbenzene, and 238 mg/kg for xylenes. Figure 6-6 presents subsurface soil contamination atSite 18 and an approximate area requiring remediation (337,500 square feet).
Site 31. TCE was detected in groundwater at Site 31 at concentrations exceeding the established ARARs and, therefore,is a contaminant of concern. The California Regional Water Quality Control Board, Santa Ma Region requires soil cleanupto prevent degradation of the groundwater through migration of contaminants from soil to groundwater. Since thegroundwater at Site 31 is currently being degraded, the Air Force has chosen to address the soil contamination at Site 31in order to prevent further groundwater degradation. See Figure 6-7 for the approximate area requiring remediation.
Site 34. Subsurface soil contaminants consisted primarily of benzene, ethylbenzene, and xylenes. Benzene was detectedin groundwater at Site 34 at concentrations exceeding the established ARARs and, therefore, is a contaminant of concern.The California Regional Water Quality Control Board, Santa Ana Region requires soil cleanup to prevent degradation of thegroundwater through migration of contaminants from soil to groundwater. Since the groundwater at Site 34 is currently beingdegraded, the Air Force has chosen to address the soil contamination at Site 34 in order to prevent further groundwaterdegradation. See Figure 6-8 for the approximate area requiring remediation.
Cleanup of contaminants in the vadose zone will be implemented at Sites 18, 31, and 34. The modeled subsurface soilcleanup criteria is based on controlling impacts to groundwater exposure pathways. Therefore, MCLs are used as indirectendpoints for estimating the likelihood that existing soil contaminant concentrations will result in an unacceptable, groundwater impact. However, predicting contaminant migration based on soils data alone has been found to underestimatecontaminant loading due to unaccounted for volatilization of contaminants during sampling and analysis. Therefore,additional soil gas sampling will be performed during the Remedial Action phase for use in the model.
6-21
544
r267
< Site 34Boundary
Site 34 Surface SoilContamination
12691242
I
of Former USTs
Site 14Boundary
\
SExplanation
v//AS
0
Proposed Excavation Area
120 Feet
6-22
Hot Cargo Pad
Taxiway
irfrdhff
ExplanationProposed Dual Phase Soil Vapor/Groundwater
Extraction Well
Site 18 Subsurface SoilContamination
Proposed Soil Vapor Extraction WellApproximate subsurface soilremediation area
. 300 Feet
6-23
Proposed dual phase soilvapor/9roundwaterextraction well
Proposed soil vaporextraction well
Approximate areal extent ofcontaminated soil
aSite 31 Boundary
0
Explanation
400 Feet Site 31 Subsurface SoilContamination
6-24
I-
1
r
—
Approximate subsurface soilremediatiori area
p544
12691242 n2671
62
North
-----c I
I Site 34Boundary
FormerPumpShelter
\\ //
of Former USTs
Site 14Boundary
\
Explanationa0
C 0 60 120 Feet
Scale
Site 34 Subsurface SoilContamination
6-25
544 63Vadose zone cleanup (SVE and bioventing) will be implemented in combination with contaminant transport modeling. Theprocess of cleanup and evaluation will be iterative so that cleanup effectiveness is maximized. Cleanup system operationwill be followed by model application to predict vadose zone contaminant migration potential. The results of model
0 application will be used to determine if cleanup should continue or if monitoring for contaminant rebound should begin.
This decision will be made using the Decision Tree for Vadose Zone Remediation (see Figure 6-9). The Decision Tree isa tool for directing operation of vadose zone cleanup systems. Vadose zone cleanup will be initiated and will operate untilSVE system influent concentrations drop to predetermined target concentrations. Soil gas (and other samples, as necessary)will then be collected. The results of this post-cleanup sampling will be used to calculate contaminant concentration inputto VLEACI{ and MJXCELL models (or similar, mutually agreed upon models). The models will be used to predictgroundwater contaminant concentrations for comparison with groundwater cleanup standards and will determine whether thevadose zone cleanup system will be restarted or rebound monitoring will be initiated.
Contaminant input to VLEACH will be based on total-phase concentrations. Total-phase concentrations include soil gas,adsorbed soil, and liquid phases. Soil gas results will be used to calculate total-phase concentrations, based on mutuallyagreed-upon equilibrium calculations, when other phase sampling results are not available. Implementation specifics (e.g.,the length of initial cleanup system operation and the length of time of monitor rebound) will be determined during theRemedial Action phase.
6.5.2.3 Summary of Soil Cleanup Standards and Goals
Table 6-4 lists chemicals in surface and subsurface soil that require remediation, and their cleanup goals. U.S. EPA RegionIX residential PRGs are used as cleanup goals for all sites listed in Table 6-4. As stated previously, based on U.S. EPARegion IX industrial PROs, remediation is not required at Sites 7 and 29.
S.
6-26
I3
544 64
I:
Stop and monitorvapor for rebound
S[G.W contamination is the predicted
concentration hi groundwater based on
VLEACH and MIXCELL applications.
March Air Force Base, California
Decision Tree forVadose Zone Cleanup
6-279-95 FigurO 6-9
544 65TAm.I: 6—4. Ci.i::s,i P Go%iS FOR Soil. CONTA%IIN.4NTS
RI•:Q IRIN( ; Iti•:SIEDI.viION
Site Chemical
Maximum SiteConcentration
(mg/kg)
Cleanup SlandaniRegion IX PRG'°
(mglkg)
4 Benzo(a)anthraceneBenzo(a)pyreneBcnzo(b)fluorantheneChryseneDibenz(a,h)anthraceneIndeno(1,2,3-c,d)pyrene
5.58.7
14.09.74.2
21.0
0.610.0610.616.1
- 0.0610.61
10 Benzo(a)anthraceneBenzo(a)pyreneBenzo(b)fluorantheneBenzo(k)fluorantheneDibenz(a,h)anthracenelndeno(l,2,3-c,d)pyrene
3.23.53.71.80.963.9
0.610.0610.610.610.0610.61
15 Benzo(a)pyrene 0.34 0.061
18 Benzene 97 6.8(2)
31 Benzo(a)anthraceneBenzo(a)pyreneBenzo(b)fluorantheneIndeno(1,2.3-c.d)pyrene
0.961.01.50.85
0.610.0610.610.61
34 Benzo(a)anthraceneBenzo(a)pyreneBenzotb)fluorantheneIndeno(1,2,3-c,d)pyrene
5.83.24.92.2
0.610.0610.610.6!
Residential soil PROs were used for all sites listed on this table.Target remediation concentrations were derived using VLEACH, a soil to groundwater partitioning model.
6-28
7.0 DEscRIPTIoN OF ALTERNATIVES 66
A Feasibility Study (FS) was conducted to develop and evaluate remedial alternatives for Operable Unit 1. The followingsections present summaries of cleanup alternatives evaluated for both groundwater and soil during the FS. The FS wasapproved by the USEPA on August 23, 1994.
7.1 REMEDIAL ALTERNATIVES FOR GROUNDWATER
In this section, potential cleanup technologies are identified for each groundwater plume in OU 1. A variety of treatmentmethods were evaluated, and are described below.
Alternative 1G - No Action. Every site must be evaluated for the no action alternative to provide a basis for comparisonof existing site conditions with other proposed alternatives. Under this alternative, no action would be taken to addressgroundwater contamination or to minimize further contaminant releases.
Alternative 2G - Limited Action. Under the limited action response, groundwater monitoring is implemented to checkwhether contaminants are migrating or increasing in concentration.
Alternative 3G - Direct Treatment with Liquid Phase Granular Activated Carbon Adsorption. Activated carbonadsorption is a proven technology for removing organic compounds from groundwater. Contaminated groundwater, onceextracted from a well, is passed through a carbon filter which traps the contaminants. The treated water is then dischargedto the base wastewater treatment system, the ground surface, or returned to the aquifer via injection wells. Once the carbonbecomes saturated with contaminants, the carbon is replaced. The organic compounds identified in OU1 groundwater canbe effectively removed by activated carbon adsorption.a Alternative 4G - Ultraviolet (LV) and Chemical Oxidation Treatment. UV and chemical oxidation uses a combinationof UV radiation, hydrogen peroxide, and ozone to destroy contaminants. Groundwater is introduced to the UV and chemicaloxidation unit, where hydrogen peroxide is injected. The groundwater then enters a reaction chamber. Ozone is bubbledthrough the water while it is exposed to UV light in the reaction chamber. The UV light increases the chemical reactionrate and thus reduces the time required for treatment. Contaminants are rendered harmless with no toxic residuals requiringtreatment. Treated wastewater is discharged to the base treatment plant, the ground surface, or returned to the aquifer viainjection wells.
Alternative SG - Total fluids Recovery. Total fluids recovery can be used in combination with other technologies to treatgroundwater contaminated with immiscible fluids, such as the jet fuel found at Site 18. The method includes the retrievalof groundwater and floating product simultaneously using recovery wells. Jet fuel would be separated from the groundwaterin an above-ground oil/water separator and disposed of offsite or recycled. The remaining contaminated groundwater wouldbe treated using a groundwater cleanup technology, such as air stripping.
Alternative 6G -Air Stripping with Carbon Adsorption. Air stripping is a proven technology for removal of VOCs fromgroundwater. Groundwater is sprayed into a tank filled with packing material. As the water flows downward by gravityit comes into contact with air blown upward into the tank from below. The packing material has a large surface area toincrease water/air contact. Contaminants are volatilized from the water and transferred to the air stream. Contaminant-ladenair is drawn out through the top of the tank and run through a carbon filter before being discharged to the atmosphere.Depending on contaminant concentrations remaining in the treated wastewater following air stripping, liquid phase granularactivated carbon (GAC) may be used to remove trace contaminants. Treated wastewater is then discharged to the basetreatment plant, the ground surface, or returned to the aquifer via injection wells.
Alternative 7G - Air Stripping with Catalytic Oxidation. Under this alternative air stripping would take place as describedin Alternative 6G. Contaminants that are volatilized from the groundwater enter the air stream and require further treatment.The catalytic oxidation process removes contaminants from the contaminated air stream. The contaminated air stream is
• preheated; then the hot air is passed over a catalyst. The contaminants adsorb to the surface of the catalyst where theyoxidize to form carbon dioxide and water. The treated air stream is then cooled and vented to the atmosphere.
7-1
544 67Alternative 8G - Air Stripping with Purus PADRE" System. Under this alternative air stripping would take place asdescribed in Alternative 60. Contaminants that are volatilized from the water enter the air stream and require furthertreatment. The PADRE"' System removes contaminants from the contaminated air stream by adsorption onto a proprietary• resin. The system is operated with two parallel resin beds. Contaminants are adsorbed onto one resin bed while the otherbed is regenerated. The beds are regenerated by heating the resin to desorb the contaminants back into a vapor. The vaporsare then condensed to a liquid, collected in storage containers, and recycled or disposed of offbase.
Alternative 9G - Ex-Situ Bioremediation. In this process, conventional biological wastewater treatment processes are usedto remove organic contaminants from groundwater. The groundwater is pumped to the surface where it is passed througha sedimentation basin to remove particulate matter. The groundwater then flows to biological reactors such as a tricklingfilter, rotating biological disk, or aeration basin where microbes biologically degrade the organic contaminants. The treatedwater then passes through another settling tank where the microbial mass is removed. The water may be disinfected withchlorine or ozone prior to discharge to surface water or reinjection into the aquifer.
A variety of remedial alternatives were evaluated for remediation of groundwater at Site 410U1 plume, Site 18 plume andthe Site 31 plume. The following sections summarize remedial technologies considered for each site. The implementationof the various technologies, including the estimated costs, is discussed below.
In order to compare costs of the alternatives, the alternatives were evaluated using present worth analysis. The present worthof each alternative represents the total project costs in present day dollars based on the capital costs and annual operatingcosts.
Site 4/OUt Groundwater Plume. An alternative for full-treatment of the entire groundwater plume was considered (outto the Sppb isopleth), however, the $12 million cost was so disproportionate, this alternative was not included in subsequentdrafts of the FS. Groundwater extracted from these two plumes will be combined for treatment to increase cost-effectiveness.Remedial alternatives considered have been limited to those that have been successfully implemented at sites with similarcontaminants and site conditions. The remedial alternatives evaluated were as follows:
• 10 - No Action• 20 - Limited Action30 - Direct Treatment with Liquid Phase GAC40 - UV and Chemical Oxidation Treatment
• 6G - Air Stripping with Carbon Adsorption
Alternative IG - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with other proposed remedial alternatives. No remedy is implemented under the no action alternative.The no action alternative must be considered in order to comply with the provisions of the National Contingency Plan (NCP).
The no action alternative does not provide protection of human health and the environment since no remedial action isimplemented. Further, compliance with ARARs is not required for a no-action decision and therefore applicable or relevantand appropriate chemical-, action-, and location-specific requirements are not summarized in Appendix C (Tables C-i andC-2).
Implementation of the no action alternative would result in a continuation of risk posed by the presence of TCE, vinylchloride, PCE, and other contaminants at concentrations greater than the cleanup standards for groundwater at these sites.This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved.
Cost: The no action alternative is by definition a no cost alternative.
Alternative 2G - Limited Action. The limited action alternative provides some protection to human health throughgroundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does notreduce contaminant concentrations and therefore does not comply with applicable or relevant and appropriate chemical-,action-, and location-specific requirements as summarized in Appendix C (Tables C-i and C-2). This alternative does notreduce the toxicity, mobility or volume of contamination since no treatment is involved..
7-2
Capital Cost: $ 209,415 544 68Total Project Cost/Present Worth: $1,148,000. Annual O&M Cost: $ 90,508
(30 years required)
• Alternative 3G - Direct Treatment with Liquid Phase GAC. Activated carbon adsorption is a proven technology forremoving VOCs from groundwater, and has been successfully implemented at March AFB. This technology is capable ofremoving greater than 99 percent of contaminants from groundwater and reducing the levels of contaminants to below cleanupstandards. The remedy will comply with all applicable or relevant and appropriate chemical-, action-, and location-specificrequirements as summarized in Appendix C (Tables C-i and C-2).
Capital Cost: $ 736,216Total Project Cost/Present Worth: $1,839,000. Annual O&M Cost: $ 106,348
(30 years required)
Alternative 4G - Ultraviolet and Chemical Oxidation Treatment. Oxidation of organics in groundwater using UV radiation,hydrogen peroxide and ozone is a proven technology. This technology is capable of removing 99 percent of contaminantsfrom groundwater, and reducing the levels of contaminants to below cleanup standards. The remedy will comply with allapplicable or relevant and appropriate chemical-, action-, and location-specific requirements as summarized in Appendix C(Tables C-I and C-2). Implementation may be somewhat limited due to the small number of vendors.
Capital Cost: $ 1,851,216Total Project Cost/Present Worth: $6,014,000. Annual O&M Costs: $ 401,506
(30 years required)
Alternative 6G - Air Stripping with Carbon Adsorption. Air stripping is a proven technology for removal of VOCs fromgroundwater. This technology is capable of removing greater than 99 percent of contaminants from groundwater and reducingthe levels of contaminants to below cleanup standards. Contaminant-laden air is run through carbon filters prior to dischargeto the atmosphere. The remedy will comply with all applicable or relevant and appropriate chemical-, action-, and location-specific requirements as summarized in Appendix C (Tables C-i and C-2).
Capital Cost: $ 769,716Total Project Cost/Present Worth: $2,494,000. Annual O&M Costs: $ 166,288
(30 years required)
Site 18 Groundwater Plume. Remedial alternatives considered for Site 18 have been limited to those that have beensuccessfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated are asfollows:
• 10 - No Action• 20 - Limited Action• 3G/SG - Direct treatment with Liquid Phase GAC/Total Fluids Recovery• 70/50 - Air Stripping with Catalytic OxidationlTotal Fluids Recovery• 8G/5G - Air Stripping with Puns PADRE" System/Total Fluids Recovery
Alternative JG - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with other proposed remedial alternatives. No remedy is implemented under the no action alternative.
The no action alternative does not protect human health and the environment since no remedial action is implemented.Further, compliance with ARARs is not required for a no-action decision, and therefore applicable or relevant andappropriate chemical-, action-, and location-specific requirements are not summarized in Appendix C (Tables C-3 and C-4).
Implementation of the no action alternative would result in a continuation of risk posed by the presence of jet fuelcontaminants (primarily BTEX compounds). This alternative does not reduce the toxicity, mobility or volume ofcontamination since no treatment is involved.
Cost: The no action alternative is by defmition a no cost alternative.
7-3
544 69Alternative 2G - Limited Action. The limited action alternative provides some protection to human health throughgroundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does notreduce contaminant concentrations, and therefore does not comply with applicable or relevant and appropriate chemical-,action-, and location-specific requirements as summarized in Appendix C (Tables C-3 and CA). This alternative does notreduce the toxicity, mobility or volume of contamination since no treatment is involved.
Capital Cost: $ 57,477Total Project CostfPresent Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
Alternative 3G!SG - Direct Treatment with Liquid Phase GAG/Total Fluids Recovery. Total fluids recovery will be usedto extract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminatedgroundwater will require further treatment. Activated carbon adsorption is a proven technology for removing organiccompounds from groundwater, and has been successfully implemented at March AFB. This technology is capable ofremoving greater than 99 percent of contaminants from Site 18 groundwater, and reducing the levels of contaminants tobelow cleanup standards. The remedy will comply with all applicable or relevant and appropriate chemical-, action-, andlocation-specific requirements as summarized in Appendix C (Tables C-3 and CA).
Capital Cost: $ 274,271Total Project CostfPresent Worth: $1,027,000. Annual O&M Costs: $ 72,608
(30 years required)
Alternative 7G/SG - Air Stripping with Gatalytic Oxidation/Total Fluids Recovery. Total fluids recovery will be used toextract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminatedgroundwater will require further treatment. Air stripping is a proven technology for removal of VOCs from groundwater.This technology is capable of removing greater than 99 percent of contaminants from Site 18 groundwater and reducing thelevels of contaminants to below cleanup standards. The catalytic oxidation process converts contaminants in the contaminatedair stream to nonhazardous compounds, carbon dioxide and water. The remedy will comply with all applicable or relevantand appropriate chemical-, action-, and location-specific requirements as summarized in Appendix C (Tables C-3 and C-4).
Capital Cost: $ 531,771Total Project CostIPresent Worth: $3,006,000. Annual O&M Costs: $ 238,604
(30 years required)
Alternative 8G/SG - Air Stripping with Purus PADRE11'System/Total Fluids Recovery. Total fluids recovery will be usedto extract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminatedgroundwater will require further treatment. Air stripping is a proven technology for removal of VOCs from groundwater.This technology is capable of removing greater than 99 percent of contaminants from Site 18 groundwater, and reducing thelevels of contaminants to below cleanup standards. The PADREm System removes contaminants from the contaminated airstream by adsorption onto a proprietary resin. Liquid wastes are later condensed and disposed of or recycled. The remedywill comply with all applicable or relevant and appropriate chemical-, action-, and location-specific requirements assummarized in Appendix C (Tables C-3 and CA). This system is proprietary and implementation is limited to one vendor.
Capital Cost: $ 504,036Total Project Cost/Present Worth: $1,288,000. Annual O&M Costs: $ 75,613
(30 years required)
Site 31 Groundwater Plume. Remedial alternatives considered for Site 31 have been limited to those that have beensuccessfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated are asfollows:
• 10 - No action• 20 - Limited Action• 30 - Direct Treatment with Liquid Phase GAC• •. 40 - Ultraviolet (UV) and Chemical Oxidation Treatment• 60 - Air Stripping with Carbon Adsorption
7-4
544 70Alternative IG - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with other proposed remedial alternatives. No remedial action is implemented under the no actionalternative.
The no action alternative does not protect human health and the environment since no remedy is implemented. Further,compliance with ARARS is not required for a no-action decision and therefore applicable or relevant and appropriatechemical-, action-, and location-specific requirements are not summarized in Appendix C (Tables C-S and C-6).
Implementation of the no action alternative would result in a continuation of risk posed by the presence of TCE atconcentrations greater than the MCLs for groundwater at Site 31. This alternative does not reduce the toxicity, mobility orvolume of contamination since no treatment is involved.
Cost: The no action alternative is by defmition a no cost alternative.
Alternative 2G - Limited Action. The limited action alternative provides some protection to human health throughgroundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does notreduce contaminant concentrations, and therefore does not comply with applicable or relevant and appropriate chemical-,action-, and location-specific requirements as summarized in Appendix C (Tables C-s and C-6). This alternative does notreduce the toxicity, mobility or volume of contamination since no treatment is involved.
Capital Cost: $ 57,477Total Project CostlPreseut Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
Alterizative 3G - Direct Treatment with Liquid Phase GAC. Activated carbon adsorption is a proven technology forremoving organic compounds from groundwater, and has been successfully implemented at March AFB. This technologyis capable of removing greater than 99 percent of contaminants from Site 31 groundwater and reducing the levels ofcontaminants to below cleanup standards. The remedy will comply with all applicable or relevant and appropriate chemical-,action-, and location-specific requirements as summarized in Appendix C (Tables C-s and C-6).
Capital Cost: $ 349,446Total Project Cost/Present Worth: $1,103,000. Annual O&M Costs: $ 72,664
(30 years required)
Alternative 4G - Ultraviolet (UV) and Chemical Oxidation Treatment. Oxidation of organics in groundwater using UVradiation, hydrogen peroxide and ozone is a proven technology. This technology is capable of removing 99 percent ofcontaminants from Site 31 groundwater, and reducing the levels of contaminants to below cleanup standards. The remedywill comply with all applicable or relevant and appropriate chemical-, action-, and location-specific requirements assummarized in Appendix C (Tables C-S and C-6). Implementation may be somewhat limited due to the small number ofvendors.
Capital Cost: $ 479,782Total Project Cost/Present Worth: $1,549,000. Annual O&M Costs: $ 103,124
(30 years required)
Alternative 6G - Air Stripping with Carbon Adsorption. Air stripping is a proven technology for removal of VOCs fromgroundwater. This technology is capable of removing greater than 99 percent of contaminants from Site 31 groundwater andreducing the levels of contaminants to below cleanup standards. Contaminant-laden alr is run through a carbon filters priorto discharge to the atmosphere. The remedy will comply with all applicable or relevant and appropriate chemical-, action-,and location-specific requirements as summarized in Appendix C (Tables C-S and C-6).
Capital Cost: $ 296,478Total Project Cost/Present Worth: $1,068,000. Annual O&M Costs: $ 74,403
(30 years required).7-5
7.2 REMEDIAL ALTERNATIVES FOR Som 544 7 1
In this section, potential cleanup technologies are identified for each site requiring soil cleanup. A variety of treatment• methods were evaluated and are described below.
Alternative IS - No Action. Every site must be evaluated for the no action alternative to provide a basis for comparisonof existing site conditions with other proposed alternatives. Under this alternative, no action would be taken to address soilcontamination or to minimize further contaminant releases.
Alternative 2S - Limited Action. Under the limited action response, mechanisms to prevent access to the site and directcontact with the contaminants are implemented such as fences and deed restrictions. Access to the site is controlled. Forsites with surface soil contamination, periodic monitoring of the soil contaminant concentrations is conducted. For sites withsubsurface soil contamination, periodic monitoring of groundwater is conducted to assess potential health impacts. Thisalternative reduces risk by limiting exposure to contaminants.
Alternative 35 - Resource Conservation and Recovery Act (RCRA) Capping. Capping protects human health and theenvironment by controlling exposure from ingestion, inhalation, and dermal contact with the contaminants. It also reducesmigration of contaminants from the site through air, surface water, and groundwater. This alternative includes installinga low-permeability cap over the existing wastes, protecting the cap from erosion, and long-term maintenance to ensure capintegrity.
Alternative 45 - Landfill Closure. This alternative implements final closure of the existing landfill at Site 4, in accordancewith the California Water Regulations (California Code of Regulations, Title 23, Waters, Division 3). Closure of the landfillincludes construction of a cover, installation of an impermeable barrier to isolate landfill materials from surface waterdrainage, water quality monitoring and response programs, closure maintenance activities, and post-closure maintenanceactivities.
Alternative SS - Excavation and Low Temperature Thermal Desorption. In a thermal desorption process, soils areexcavated and heated to volatilize and drive off contaminants. The volatilized contaminants are destroyed in an afterburner.Contaminated soils may be heated in a screw auger dryer, a rotary kiln, or a series of externally heated distillation chambers.
Alternative 6S -Soil Washingflon Exchange. Under this alternative, soil washing would be conducted as described abovefor Alternative SS. Metal contaminants washed from soil would be removed from the wash solution using ion exchange.Dissolved metals are removed from solution by exchanging the metal ions with an ion of the same charge, such as hydrogen,bound to a resin surface. The hydrogen ion goes into solution and the metal ion is bound to the resin. The resin isregenerated using a concentrated wash solution which releases the bound metal ions from the resin. The wash solutionrequires further treatment or disposal.
Alternative 7S - Excavation and Oufsite Treatment. This alternative involves the excavation of contaminated soil andtreatment/reuse at an offsite location. The contaminated soils are mixed with asphalt, which is then used as a sub-base forpavement. This is especially effective for PAH-contaminated soils which bond with the asphalt, thereby reducing migrationand minimizing risk.
Alternative 85 - Excavation and Onsite Consolidation. Under this alternative, excavated soils would be added to othersolid wastes and consolidated beneath a low-permeability cap. Before placement under the cap, the soils must pass the toxiccharacteristic leaching procedure (TCLP) and California leachate tests. Capping minimizes contaminant migration fromburied wastes by preventing water infiltration and controlling surface water runoff. This alternative involves installation ofa low-permeability cap, protection of the cap from erosion, and long-term maintenance to ensure cap integrity.
Alternative 9S - Excavation and Offsite Disposal. This alternative involves the excavation of contaminated soil andplacement of the soil in an approved offsite landfill.
Alternative lOS - Bioventing. Bioventing is an in-situ treatment technology for petroleum contaminated soils. It consistsof subsurface injection or withdrawal of air to stimulate biodegradation of non-halogenated organic contaminants by native• microbes. These microbes use the petroleum hydrocarbons as an energy source and break them down into carbon dioxideand water. Air flow through contaminated soils is controlled through the use of air injection or air extraction wells. Flowrates are maintained at low levels to minimize volatilization of contaminants.
7-6
544 72Alternative 115 - Ex-Situ Bioremediation. This treatment alternative is applicable to soils contaminated with non-halogenated organic compounds. Contaminated soils are excavated and aerated to stimulate biodegradation. Contaminantsare converted to carbon dioxide and water, as a result of biodegradation processes. Nutrient amendments and microbial• cultures may also be added to the soils to enhance biodegradation rates.
Alternative 12S - Soil Vapor Extraction with Catalytic Oxidation. Soil vapor extraction (SVE) is generally used toremove VOCs with vapor pressures greater than 1 millimeter of mercury from soil. Air flow is induced throughcontaminated soils by extracting air through wells installed in the soil column. Air flow may be enhanced by using airinjection wells in conjunction with extraction wells. VOCs are stripped from the soils into the air as the air flows throughthe soil column. The contaminated vapors are then brought to ground surface for treatment using catalytic oxidation. Thecontaminated air stream is preheated and the hot air is passed over a catalyst. Contaminants adsorb to the surface of thecatalyst where they are oxidized to carbon dioxide and water. The treated air stream is then cooled and vented to theatmosphere.
Alternative 135 - Soil Vapor Extraction with Pun's PADRE"' System. Under this alternative SVE would be performedas described above for alternative 12S. The contaminated vapors are then brought to ground surface for treatment by thePurus PADRE"' System. The PADRE"' System removes contaminants from the extracted vapor stream by adsorption ontoa proprietary resin. The system is operated with two resin beds. Contaminants are adsorbed onto one resin bed while theother bed is regenerated. The beds are regenerated by heating the resin to desorb the contaminants which are condensedto a liquid and collected in storage containers. The resulting liquid wastes require disposal or recycling.
Alternative 14S - Soil Vapor Extraction with Carbon Adsorption. Under this alternative SVE also would be performedas described in Alternative 12S. The contaminated vapors are then brought to ground surface for treatment by GAC. GACremoves contaminants from the extracted vapor stream by adsorption onto the carbon. The carbon may be regenerated onsiteor offsite using steam to desorb the contaminants.
A variety of remedial alternatives were evaluated for remediation of soils at Sites 4, 10, 15, 18, 31, and 34. The followingsections summarize remedial technologies for remediating soil at each site. The implementation of the various technologies,including the estimated costs, is discussed below.
S Site 4 Soil. Site 4 alternatives were identified based upon contaminant types and concentrations, and current plans for siterestructuring. The remedial alternatives evaluated were as follows:
• iS - No Action• 2S - Limited Action• 3S - RCRA Capping• 4S - Landfill Closure• 9S - Excavation and Offsite Disposal
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of otherproposed remedial alternatives. Under a no action alternative the landfill would be left in its current state. This alternativewould not reduce the potential for waste migration due to precipitation or surface drainage, and therefore provides no overallprotection of human health and the environment.
Compliance with ARARs is not required for a no-action decision, therefore, ARARs are not summarized in Appendix C(Table C-7). The potential for migration of contaminants to groundwater is not reduced and the potential for erosion oflandfill materials would remain. In addition, this alternative does not control contaminant migration to groundwater and doesnot provide a mechanism for monitoring contaminant migration.
Cost: The no action alternative is by definition a no cost alternative.
Alternative 25 - LimitedAction. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact and monitoring contaminant migration. The limited action alternative does not comply withARARs as summarized in Appendix C (Table C-7). This alternative does not reduce the toxicity, mobility or volume of• contamination since no treatment is involved.
Capital Cost: $ 209,415
7-7
544 73Total Project Cost/Present Worth: $1,148,000. Annual O&M Costs: $ 90,508
(30 years required)
Alterna five 3S - RCRA Capping. Capping protects human health and the environment by minimizing exposure fromingestion, iithalation, and dermal contact with the contaminants. It also reduces migration of contaminants from the sitethrough air, surface water, and groundwater. The remedy will comply with ARARs as summarized in Appendix C (TableC-7).
Capital Cost: $ 1,816,059Total Project Cost/Present Worth: $2,853,000. Annual O&M Costs: $ 100,008
(30 years required)
Alternative 4S -Lan4fill Closure. The closure alternative would involve closure of the landfill in accordance with CaliforniaWater Regulations (California Code of Regulations, Title 23, Waters, Division 3). Closure of the landfill would includeconstruction of a cover, isolation of landfill materials from surface water drainage, water quality monitoring and responseprograms, closure maintenance activities, post-closure maintenance activities. The remedy will comply with ARARs assummarized in Appendix C (Table C-i).
Capital Cost: $ 1,390,102Total Project Cost/Present Worth: $2,427,000. Annual O&M Costs: $ 100,008
(30 years required)
Alterna five 9S - Excavation and Offsite Disposal. This alternative involves the excavation of contaminated soil andplacement of the soil in an approved offsite landfill. The remedy will comply with ARARs as summarized in Appendix C(Table C-i). This alternative does not reduce the toxicity or volume of the contaminants.
Capital Cost: $ 96,712,000Total Project Cost/Present Worth: $96,712,000. Annual O&M Costs: $ 0
(not applicable)
Site 10 Surface Soil. Site 10 surface soil alternatives were identified based upon contaminant types and concentrations.The remedial alternatives evaluated were as follows:
• 15 - No action• 2S - Limited Action• 5S - Excavation and Low Temperature Thermal Desorption• iS - Excavation and Offsite Treatment• 85 - Excavation and Onsite Consolidation• uS - Ex-Situ Bioremediation
Alternative 15- No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of otherproposed remedial alternatives. Under this scenario, PAH-contaminated soils would remain in the drainage channel andcontinue to pose potential risk. Because the drainage channel leads oftbase, contaminants could eventually migrate oftbase.This alternative does not mechanism for reduction of toxicity, mobility or volume of contaminants. Compliance with ARARsis not required for a no-action decision, therefore, ARARS are not summarized in Appendix C (Table C-8).
Cost: The no action alternative is by definition a no cost alternative.
Alternative 25 - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations and doesnot control offsite migration. The limited action alternative complies with ARARs as summarized in Appendix C (Table C-8).
This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved..7-8
544 74Capital Cost: $ 51,004
Total Project Cost/Present Worth: $87,000. Annual O&M Costs: $ 3,480(30 years required)
Alternative 55 - Excavation and Low Temperature Ther,nal Desoqtion. Under this alternative, contaminated soils areexcavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroysthem in an afterburner. The remedy will comply with ARARs as summarized in Ap3endix C (Table C-8).
Capital Cost: $ 37,000Total Project Cost/Present Worth: $37,000. Annual O&M Costs: $ 0
(not required)
Alternative 75 - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated soil from thedrainage ditch for treatment/reuse at an offsite location. The offsite facility will mix contaminated soils with asphalt. Themixture is used as sub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby reducing migrationand minimizing risk. The remedy will comply with ARARs as summarized in Appendix C (Table C-8).
N. Capital Cost: $ 22,000Total Project Cost/Present Worth: $22,000. Annual O&M Costs: $ 0
(not required)
Alternative 85 - Excavation and Onsite Consolidation. Under this alternative, soils excavated from Site 10 would be addedto the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated soils wouldbe controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in Appendix C (TableC-8).
Capital Cost: $ 7,000Total Project Cost/Present Worth: $7,000. Annual O&M Costs: $ 0
(not required)
• Alternative uS - Ex-Situ Rioremediation. Under this alternative, contaminated surface soils are excavated and aerated tostimulate biodegradation. Nutrient amendments may also be required. Contaminants are converted to carbon dioxide andwater as a result of biodegradation processes. The remedy will comply with ARARs as summarized in Appendix C (TableC-8).
Capital Cost: $ 50,000Total Project Cost/Present Worth: $50,000. Annual O&M Costs: $ 0
(not required)
Site 15 Surface Soil. Site 15 surface soil alternatives were identified based upon contaminant types and concentrations.The remedial alternatives evaluated were as follows:
• 15 - No action• 2S - Limited Action• 5S - Excavation and Low Temperature Thermal Desorption• 75 - Excavation and Offsite Treatment• 8S - Excavation and Onsite Consolidation• 115 - Ex-Situ Bioremediation
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of otherproposed remedial alternatives. Under this scenario, PAR-contaminated soils would remain in place and continue to posepotential risk. This alternative provides no mechanism for reduction of toxicity, mobility or volume through treatment.Compliance with ARARs is not required for a no-action decision, therefore, ARARs are not summarized in Appendix C(Table C-9).
Cost: The no action alternative is by definition a no cost alternative.
7-9
544 75Alternative 2S - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. Thisalternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARs• apply for the limited action alternative as summarized in Appendix C (Table C-9).
Capital Cost: $ 32,348Total Project Cost/Present Worth: $68,000. Annual O&M Costs: $ 3,480
(30 years required)
Alternative .5S - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated soils areexcavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroysthem in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C-9).
Capital Cost: $ 26,000Total Project Cost/Present Worth: $26,000. Annual O&M Costs: $ 0
(not required)
Alternative 7S - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated soil fortreatment/reuse at an offsite location. The facility will mix contaminated soils with asphalt. The mixture is used as sub-basefor pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy will comply withAltARs as summarized in Appendix C (Table C-9).
Capital Cost: $ 7,000Total Project Cost/Present Worth: $7,000. Annual O&M Costs: $ 0
(not required)
Alternative 8S -Excavation and Onsite Consolidation. Under this alternative, soils excavated from Site 15 would be addedto the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated soils wouldbe controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in Appendix C (TableC-9).
Capital Cost: $ 4,000• Total Project Cost/Present Worth: $4,000. Annual O&M Costs: $ 0(not required)
Alternative US -Ex-Situ Bioremediation. Under this alternative, contaminated soils are excavated and aerated to stimulatebiodegradation. Contaminants are converted to carbon dioxide and water as a result of biodegradation processes. Theremedy will comply with ARARs as summarized in Appendix C (Table C-9).
Capital Cost: $ 43,000Total Project Cost/Present Worth: $43,000. Annual O&M Costs: $ 0
(not required)
Site 18 Subsurface Soil. Remedial alternatives evaluated for Site 18 subsurface soil have been limited to those that havebeen successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated wereas follows:
• 15 - No Action• 2S - Limited Action• 105 . Bioventing• 125 - Soil Vapor Extraction with Catalytic Oxidation• 13S - Soil Vapor Extraction with Purus PADRETh System
Alternative IS - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with proposed remedial alternatives. No remedy is implemented under the no action alternative.
The no action alternative does not protect human health and the environment since no remedial action is implemented.• Implementation of the no action alternative would result in a continuation of risk posed by the presence of fuel contaminants.This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. Compliancewith ARARs is not required for a no-action decision, therefore, ARARS are not summarized in Appendix C (Table C-b).
7-10
544 76Cost: There are no costs associated with the no action alternative.
• Alternative 2S - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact and monitoring contaminant concentrations. The limited action alternative provides noreduction in contaminant concentrations. This alternative does not reduce the toxicity, mobility or volume of contaminationsince no treatment is involved. No ARARs apply to the limited action alternative as summarized in Appendix C (Table C-10).
Capital Cost: $ 57,477Total Project Cost/Present Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
Alternative 105 - Bioventing. Bioventing is an in-situ treatment technology for hydrocarbon-contaminated soils includingpetroleum products. Bioventing is the process of accelerating the natural microbial biodegradation of hydrocarbons inunsaturated zone soils by providing sufficient air flow in these soils to maintain oxygenated conditions. Under aerobic (withoxygen) conditions, indigenous microorganisms that are already acclimatized to using the hydrocarbons as an energy sourcereduce contaminants to carbon dioxide and water. Either air injection or withdrawal can be used. However, air injectionoffers the additional benefit of no secondary residuals (i.e., vapor) to control. The remedy will comply with ARARs assummarized in Appendix C (Table C-b).
Capital Cost: $ 863,954Total Project Cost/Present Worth: $891,000. Annual O&M Costs: $ 26,740
1 year only: (project costs are incurred during1st year)
Alternative 125 - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 18 are primarily VOCs. SVE removesVOCs from unsaturated soils by mechanically drawing air through the soil pore spaces and transferring the contaminants to
• the vapor phase. The catalytic oxidation process converts contaminants in the contaminated air stream to carbon dioxide andwater. The remedy will comply with ARARs as summarized in Appendix C (Table C-b).
Capital Cost: $ 979,704Total Project Cost/Present Worth: $1,229,000. Annual O&M Costs: $ 130,000
1 year only: (project costs are incurred during1st year)
Alternative 13S - Soil Vapor Extraction with Purus PADRE"' System. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 18 are primarily VOCs. SVE removesVOCs from unsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to thevapor phase. The PADRE" System removes contaminants in the contaminated air stream by adsorption onto a proprietaryresin. The remedy will comply with ARARs as summarized in Appendix C (Table C-b).
Capital Cost: $ 1,014,469Total Project Cost/Present Worth: $1,215,000. Annual O&M Costs: $ 105,170
1 year only: (project costs are incurred during1st year)
Site 31 Surface Soils. Site 31 surface soil alternatives were identified based upon contaminant types and concentrations,and site conditions. The remedial alternatives evaluated were as follows:
• iS - No Action• 25 - Limited Action• 55 - Excavation and Low Temperature Thermal Desorption• • 7S - Excavation and Offsite Treatment• 8S - Excavation and Onsite Consolidation• 115 - Ex-Situ Bioremediation
7-il
544 77Alternative 15 - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of otherproposed remedial alternatives. Under this scenario, PAH-contaminated soils would remain in place and continue to pose• potential risk. This alternative provides no mechanism for reduction of toxicity, mobility or volume through treatment.Compliance with ARABs is not required for a no-action decision, therefore, ARARS are not summarized in Appendix C(Table C-ll).
Cost: There are no costs associated with the no action alternative.
Alternative 2S - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. Thisalternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARABsapply to the limited action alternative as summarized in Appendix C (Table C-Il).
Capital Cost: $ 29,085Total Project Cost/Present Worth: $65,000. Annual O&M Costs: $ 3,480
(required for 30 years)
Alternative 55 - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated surface soilsare excavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil anddestroys them in an afterburner. The remedy will comply with AltARs as summarized in Appendix C (Table C-I I).
Capital Cost: $ 372,000Total Project CostfPresent Worth: $372,000. Annual O&M Costs: $ 0
(not required)
Alternative 75 - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated surface soilsfor treatment/reuse at an offsite location. The offsite facility will mix contaminated soils with asphalt. The mixture is usedas sub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy willcomply with ARARs as summarized in Appendix C (Table C-Il).
Capital Cost: $ 374,000Total Project Cost/Present Worth: $374,000. Annual O&M Costs: $ 0
(not required)
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, surface soils excavated from Site 31 wouldbe added to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAll-contaminatedsoils would be controlled by emplacement beneath the cap. The remedy will comply with AltARs as summarized inAppendix C (Table C-li).
Capital Cost: $ 41,000Total Project Cost/Present Worth: $41,000. Annual O&M Costs: $ 0
(not required)
Alternative 115 - Ex-Situ Bioremediation. Under this alternative, contaminated surface soils are excavated and aerated tostimulate biodegradation. Nutrient amendments may also be required. Contaminants are convened to carbon dioxide andwater as a result of biodegradation processes. The remedy will comply with ARARs as summarized in Appendix C (TableC-Il).
Capital Cost: $ 81,000Total Project Cost/Present Worth: $81,000. Annual O&M Costs: $ 0
(not required)
Site 31 Subsurface Soils. Site 31 subsurface soil alternatives were identified based upon contaminant types andconcentrations, and site conditions. Remedial alternatives evaluated were as follows:.
7-12
544 78• 15 - No Action• 2S - Limited Action• 12S - Soil Vapor Extraction with Catalytic Oxidation• 135 - Soil Vapor Extraction with Purus PADRE System• 145 - Soil Vapor Extraction with Carbon Adsorption
Alternative IS - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with proposed remedial alternatives. No remedial action is implemented under the no actionalternative.
The no action alternative provides no protection of human health and the environment since no remedial action isimplemented. Implementation of the no action alternative would result in a continuation of risk posed by the sitecontaminants. This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment isinvolved. Compliance with ARARs is not required for a no-action decision, therefore, ARARS are not summarized inAppendix C (Table C- 12).
Cost: There are no costs associated with the no action alternative.
Alternative 25 - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. Thisalternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARsapply to the limited action alternative as summarized in Appendix C (Table C-12).
Capital Cost: $ 57,477Total Project Cost/Present Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
• Alternative 125 - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs fromunsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to the vapor phase.The catalytic oxidation process destroys contaminants in the contaminated air stream. The remedy will comply with ARAR5as summarized in Appendix C (Table C- 12).
Capital Cost: $ 481,457Total Project Cost/Present Worth: $612,000. Annual O&M Costs: $ 130,592
1 year only: (project costs are incurred during1st year)
Alternative 135 - Soil Vapor Extraction with Purus PADRE System. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs fromunsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to the vapor phase.The PADRE' System removes contaminants from the contaminated air stream by adsorption onto a proprietaiy resin. Theremedy will comply with ARARs as summarized in Appendix C (Table C- 12).
Capital Cost: $ 516,222Total Project Cost/Present Worth: $621,000. Annual O&M Costs: $ 55,579
1 year only: (project costs are incurred during1st year)
Alternative 14S - Soil Vapor Extraction with Carbon Adsorption. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs fromunsaturated soils by mechanically drawing alr through the soil pore spaces, transferring the contaminants to the vapor phase.Contaminants are removed from the vapor stream using GAC adsorption. The remedy will comply with ARARs assummarized in Appendix C (Table C-12).
7-13
544 79
Capital Cost: $ 361,457Total Project Cost/Present Worth: $417,000. Annual O&M Costs: $ 55,579• 1 year only: (project costs are incurred during
1st year)
Site 34 Surface Soils. Site 34 surface soil alternatives were identified based upon contaminant types and concentrations,and site conditions. The remedial alternatives evaluated were as follows:
• 15 - No Action• 2S - Limited Action• 5S - Excavation and Low Temperature Thermal Desorption• 7S - Excavation and Offsite Treatment• 8S - Excavation and Onsite Consolidation• 115 - Ex-Situ Bioremediation
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of otherproposed remedial alternatives. Under this scenario, PAR-contaminated soils would remain in place and continue to posepotential risk. This alternative provides no mechanism for reduction of toxicity, mobility or volume through treatment.Compliance with ARARs is not required for a no-action decision, therefore, ARARs are not summarized in Appendix C(Table C-13).
Cost: There are no costs associated with the no action alternative.
Alternative 25 - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. Thisalternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARsapply to the limited action alternative as summarized in Appendix C (Table C-i 3).
Capital Cost: $ 19,087Total Project Cost/Present Worth: $55,000. Annual O&M Costs: $ 3,480
(30 years required)
Alternative 55 - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated soils areexcavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroysthem in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C- 13).
capital Cost: $ 111,000Total Project Cost/Present Worth: $111,000. Annual O&M Costs: $ 0
(not required)
Alternative 7S - Excavation and Offtite Treatment. This alternative involves the excavation of contaminated surface soilsfor treatment/reuse at an offsite location. The facility will mix contaminated soils with asphalt. The mixture is used assub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy willcomply with ARARs as summarized in Appendix C (Table C-13).
Capital Cost: $ 101,000Total Project Cost/Present Worth: $101,000. Annual O&M Costs: $ 0
(not required)
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, surface soils excavated from Site 34 wouldbe added to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAR-contaminatedsoils would be controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized inAppendix C (Table C-13).
Capital Cost: $ 14,000• Total Project Cost/Present Worth: $14,000. Annual O&M Costs: $ 0(not required)
7-14
Alternative 115 - Ex-Situ Bioremediation. Under this alternative, contaminated surface are excavated and aerated tostimulate biodegradation. Nutrient amendments may be required. Contaminants are converted to carbon dioxide and water• as a result of biodegradation processes. The remedy wilt comply with ARARs as summarized in Appendix C (Table C-13).
Capital Cost: $ 52,000Total Project Cost/Present Worth: $54,000. Annual O&M Costs: $ 0
(not required)
Site 34 Subsurface Soils. Remedial alternatives evaluated for Site 34 subsurface soils have been limited to those that havebeen successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated wereas follows:
• iS - No Action• 2S - Limited Action• lOS - Bioventing• 125 - Soil Vapor Extraction with Catalytic Oxidation• 135 - Soil Vapor Extraction with Puns PADRETh System
Alternative IS - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison ofexisting site conditions with proposed remedial alternatives. No remedial action is implemented under the no actionalternative.
The no action alternative provides no protection of human health and the environment since no remedial action isimplemented. Implementation of the no action alternative would result in a continuation of risk posed by the presence offuel contaminants. This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment isinvolved. Compliance with ARARs is not required for a no-action decision, therefore ARARs are not summarized inAppendix C (Table C-14).
Cost: There are no cost associated with the no action alternative.
Alternative 25 - Limited Action. The limited action alternative provides some protection to human health by limiting thepotential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. Thisalternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARsapply to the limited action alternative as summarized in Appendix C (Table C-14).
Capital Cost: $ 55,419Total Project Cost/Present Worth: $992,878. Annual O&M Costs: $ 83,654
(30 years required)
Alternative 105 - Bioventing. Bioventing is an in-situ treatment technology for hydrocarbon-contaminated soils such aspetroleum products. The contaminants of concern in subsurface soils at Site 34 are petroleum components. Bioventing isthe process of accelerating the natural microbial biodegradation of hydrocarbons in unsaturated zone soils by providingsufficient air flow in these soils to maintain oxygenated conditions. Under aerobic (with oxygen) conditions, indigenousmicroorganisms that are already acclimatized to using the hydrocarbons as an energy source reduce contaminants to carbondioxide and water. Either air injection or withdrawal can be used. However, air injection offers the additional benefit ofno secondaiy residuals (i.e., vapor) to control. The remedy will comply with ARARs as summarized in Appendix C (TableC- 14).
Capital Cost: $ 58,717Total Project Cost/Present Worth: $89,000. Annual O&M Costs: $ 29,545
1 year only: (project costs are incurred during1st year)
Alternative 125 - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 34 are primarily VOCs. SVE removesVOCs from unsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to thevapor phase. The catalytic oxidation process destroys contaminants in the contaminated air stream. The remedy will complywith ARARs as summarized in Appendix C (Table C-14).
7-15
544 81Capital Cost: $ 159,386• Total Project Cost/Present Worth: $223,000. Annual O&M Costs: $ 63,9001 year only: (project costs are incurred during1st year)
Alternative 135 - Soil Vapor Extraction with Purus PADRE" System. SVE is a proven technology for treatment of soilscontaminated with VOCs. The contaminants of concern in subsurface soils at Site 34 are primarily VOCs. SVE removesVOCs from unsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to thevapor phase. The PADRETh System removes contaminants from the contaminated air stream by adsorption onto a proprietaryresin. The remedy will comply with ARARs as summarized in Appendix C (Table C-14).
Capital Cost: $ 151,540Total Project Cost/Present Worth: $204,000. Annual O&M Costs: $ 52,300
1 year only: (project costs are incurred during1st year)
.
.7-16
544 828.0 SUMMARY OF COMPARATIVE ANALYSIS OF
ALTERNATIVES
The nine criteria established by CERCLA and Superfund Amendments and Reauthorization Act (SARA) were used toevaluate the alternatives in detail. The nine criteria encompass statutory and practical factors that assist in gauging the overallfeasibility and acceptability of the cleanup alternatives. The nine criteria are summarized as follows:
1. Overall Protection of Human Health and the Environment. This factor addresses whether or not aremedy provides adequate protection of human health and the environment and describes how risks posedthrough each exposure route are eliminated, reduced, or controlled through treatment, engineering controls,or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements. This evaluation criterion isused to determine whether each remedy will meet all ARARs or provide grounds for invoking a waiverof the requirements. These include chemical-, location-, and action-specific ARARs. Appendix C providesa detailed analysis of compliance with ARARs for each site/media remedy.
3. Long-term Effectiveness and Pennanence. This criterion includes evaluation of the long-termeffectiveness of the remedy in maintaining protection of human health and the environment after theresponse action is complete.
4. Reduction of Toxicity, Mobility, or Volume through Treatment. This criterion addresses the anticipatedperformance of the specific treatment technologies that an alternative may employ.
5. Short-term Effectiveness. This criterion addresses the effectiveness of alternatives in protecting humanhealth and the environment during the construction and implementation of a remedy until the remedialaction is complete.
6. Implementability. This criterion addresses the technical and administrative feasibility of alternatives andthe availability of required goods and services.
7. Cost. This criterion addresses the capital and operations and maintenance (O&M) costs of each alternative.
• Capital Cost. Capital cost consists of direct (construction) and indirect (non-construction andoverhead) costs. Direct costs include materials, labor and equipment required to install a remedialsystem, equipment fpr the remedial system, land and site-development, buildings and associatedutility services. Indirect capital costs include engineering licenses or permit fees, start up costs, andcontingency allowances.
• O&M Cost. O&M costs are post-construction costs necessary to ensure the continued effectivenessof a remedial alternative. These costs include operating labor, maintenance, and materials, auxiliarymaterials and energy, disposal of residues, purchased services (i.e., analytical laboratory), andadministrative services.
• Total Project Cost. The total project cost represent the present worth of each of the alternativesincorporating the capital cost and the annual O&M costs. They project time periods may be variedfor the various alternatives and the present worth analysis allows them to be evaluated on an equalbasis.
8. State Acceptance. This criterion summarizes the technical and administrative concerns of the State ofCalifornia for each remedial alternative presented.
9. Community Acceptance. This criterion indicates whether community concerns are addressed by eachcleanup method and whether the community has indicated a preferred cleanup method.
8-1
8.1 COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives presented in Section 7.0 were evaluated against the criteria listed above. Alternatives were ranked againsteach criterion individually using a numerical system ranging from ito 5(1 being least desirable and 5 being most desirable).Compliance with criteria S and 9 were evaluated qualitatively by considering any objections, concerns, or preferences raisedby the community or the state. Tables 8-1 through 8-il presents the ranking for each site. A detailed ARARs analysisfor each site/media alternative is presented in the tables in Appendix C.
8.1.1 Groundwater
Site 4 Groundwater Plume/OUi Groundwater Plume. A comparative analysis was completed using the alternatives andcriteria previously identified. The alternatives are:
• 10- No Action• 20 - Limited Action• 30 - Direct Treatment with Liquid Phase GAC• 40 - Ultraviolet (UV) and Chemical Oxidation Treatment• 60 - Air Stripping with Carbon Adsorption
Overall Protection of Human Health and the Environment. With the exception of the no action and limited actionalternatives, all the potential remedial alternatives will provide overall protection of human health and the environment. Theno action and limited action alternatives will not reduce the long-term risk posed by the presence of TCE and PCE in thegroundwater, and therefore would result in an unacceptable risk to human health and the environment.
Compliance With ARARs. The no action and limited action alternatives will not comply with ARARs. All three treatmentalternatives are capable of treating effluent to below MCLs. However, aquifer restoration is limited by the rate at whichcontaminants can be extracted from the aquifer.
Long-term Effectiveness and Permanence. As stated previously, the no action and limited action alternatives provide noreduction in risk since contaminants are not removed. The limited action alternative does provide long-term monitoring ofthe site but provides no protection of human health and the environment. The three groundwater treatment alternatives willreduce the magnitude of risk, by cleanup of the groundwater through contaminant removal. The direct treatment with liquidphase GAC and air stripping with carbon adsorption alternatives require disposal or regeneration of spent or used GAC,whereas the UV and chemical oxidation treatment alternative does not generate a residual waste stream.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do notreduce the toxicity, mobility or volume of contaminants in the groundwater while the direct treatment with liquid phase GAC,air stripping with carbon adsorption and UV and chemical oxidation treatment alternatives provide for very similar levelsof groundwater withdrawal and contaminant removal efficiencies.
Short-term Effectiveness. The three active remedial action alternatives (30, 40, 60) include treatment of the groundwaterto remove contamination and therefore address both current and future risks. However, minor potential risks to thecommunity, workers and the environment through generation of dust may result during installation of the three treatmentalternatives. This potential risk can be addressed through implementation of engineering controls such as dust suppression.Residuals handling may also pose risks to workers and the community. These risks can be controlled with proper trainingof workers and adherence to standard operation procedures for disposal of residual wastes.
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544 95Implementability. The no action and limited action alternatives are easy to implement but will likely require futuregroundwater treatment. No permits are required and groundwater sampling and analysis services are readily available for• the limited action alternative. The differences in implementability among the three treatment alternatives are inherent in thetreatment processes. The likelihood that technical problems will lead to schedule delays is considered low for directtreatment with liquid phase GAC, moderate for air stripping with carbon adsorption and moderate for UV and chemicaloxidation. In addition, there are a limited number of vendors for the UV and chemical oxidation system where the oxidationincludes both hydrogen peroxide and ozone. Construction of the three treatment alternatives is considered similar.
Cost. No action is by definition a no-cost alternative. Limited action ($1,148,000) and liquid phase carbon treatment($1,839,000) are the most favorable alternatives in terms of cost, followed by air stripping with vapor-phase GAC($2,494,000) and UV/chemical oxidation ($6,014,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, final stateacceptance will occur in the approved ROD.
Community Acceptance. The public comment period for the Proposed Plan was from April 28 to May 28, 1994. Inaddition, a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 18 Groundwater Plume. A comparative analysis was completed using the groundwater remedial alternatives andcriteria previously identified. The alternatives are:
• 10 - No Action• 20 - Limited Action• 30/50 - Direct treatment with Liquid Phase GAC/Total Fluids Recovery• 70/50 - Air Stripping with Catalytic OxidationlTotal Fluids RecoveryS 80/SG - Air Stripping with Puns PADRE" System/Total Fluids Recovery
Overall Protection of Human Health and the Environment. Implementation of the no action alternative will result in acontinuation of risks to the community through the presence of the contaminants in groundwater, representing a potentialexposure pathway. The limited action alternative will slightly reduce risks to the community by monitoring contaminantmigration. The no action and limited action alternatives will not reduce the long-term risk posed by the presence of thevolatile petroleum hydrocarbons in groundwater at Site 18, and therefore are considered to pose an unacceptable risk tohuman health and the environment. The three groundwater treatment remedial alternatives will reduce the contaminantconcentrations in groundwater, therefore providing protection to human health and the environment.
Compliance With AIRARs. The no action and limited action alternatives will not meet ARARs. All three groundwatertreatment alternatives will reduce the contaminants present in treated groundwater at Site 18 to meet ARARs. All threealternatives are capable of treating effluent to below MCLs; however, aquifer restoration is limited by the rate at whichcontaminants can be extracted.
Long-term Effectiveness and Pennanence. The no action and limited action alternatives provide no reduction in risk sincecontaminants are not removed. The limited action alternative does provide monitoring of the site. The three groundwatertreatment remedial alternatives will reduce the magnitude of risk through contaminant removal or destruction, which in allcases is permanent and irreversible. Residuals management will be required for all three treatment alternatives, whichinvolve recycling of recovered fuels.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do notreduce the toxicity, mobility or volume of contaminants in the groundwater while the three groundwater treatment remedialalternatives significantly reduce these constituents. All three treatment alternatives provide similar levels of contaminantremoval.
Short-term Effectiveness. The three groundwater treatment alternatives include removal and treatment of the groundwaterto control plume migration and to reduce contamination to acceptable levels. Short-term risks to workers posed byconstruction of any of the three treatment systems could be controlled using dust suppression techniques and personal
8-14
544 96protective equipment. The air stripping with catalytic oxidation and air stripping with Puns PADRE"' System alternativespresent a potential risk to the community, workers and the environment through generation of a contaminated gas stream.• However, implementation of vapor phase treatment immediately following air stripping will sufficiently address this concern.Liquid residuals generated by the Purus PADRE"' Systems can also pose short-term risks to workers, the community or theenvironment. These risks can be controlled with proper training of workers and adherence to standard operating proceduresfor transportation, handling and disposal of this waste stream.
Implementability. The no action and limited action alternatives are easy to implement but will likely require futuregroundwater treatment. The three groundwater treatment alternatives will not require future treatment.
The differences in implementability among the three groundwater treatment alternatives are inherent in the treatmentprocesses. All three groundwater treatment alternatives will result in recovery of the floating product and offsite disposalof recovered fuels. The implementation of air stripping to transfer the contaminants from the liquid to vapor phase priorto adsorption onto activated carbon is advantageous due to the higher efficiency of the vapor phase adsorption processresulting in reduced carbon usage as compared with liquid phase adsorption. However, this transfer results in additional airpermitting requirements and increased O&M.
The Puns PADRE"' System is a proprietary treatment system. Therefore the timely construction and efficient operationof this system is dependent upon the supplier.
Cost. No action is by definition a no-cost alternative. Limited action ($400,000) is most favorable in terms of cost,followed by liquid-phase GAC treatment/total fluids recovery ($1,027,000), air stripping with Puns PADRE"' system/totalfluids recovery ($1,288,000), and air stripping with catalytic oxidation/total fluids recovery ($3,006,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process andparticipated in the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS,final state acceptance will occur in the approved ROD.
S Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28 1994. In addition,W a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of Toxic
Substances Control, and California Regional Water Quality Control Board, Santa Ma, attended the public meeting to addressany questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included is Appendix A.
Site 31 Groundwater Plume. A comparative analysis was completed using the alternatives and criteria previously identified.The alternatives are:
• 10 - No action• 20 - Limited Action• 30 - Direct Treatment with Liquid Phase GAC• 40 - Ultraviolet (UV) and Chemical Oxidation Treatment• 60 - Air Stripping with Carbon Adsorption
Overall Protection of Human Health and the Environment. With the exception of the no action and limited actionalternatives, all the potential remedial alternatives will provide overall protection of human health and the environment. Theno action and limited action alternatives will not reduce the long-term risk posed by the presence of TCE in the groundwater,and therefore would result in an unacceptable risk to human health and the environment.
Compliance With ARABs. The no action and limited action alternatives will not meet ARARs. All three groundwatertreatment alternatives will reduce the contanñnants present in treated groundwater at Site 18 to meet ARARs. All threealternatives are capable of treating effluent to below MCLs; however, aquifer restoration is limited by the rate at whichcontaminants can be extracted.
Long-term Effectiveness and Permanence. The no action and limited action alternatives provide no reduction in risk since• contaminants are not removed or treated. The limited action alternative does provide long-term monitoring of the site, butprovides no protection of human health and the environment. The three groundwater treatment alternatives will reduce themagnitude of risk through contaminant removal to cleanup standards, and maintain reliable protection of human health andthe environment by removing the source. The direct treatment with liquid phase GAC and air stripping with carbon
8-15
544 97adsorption alternatives require disposal or regeneration of spent or used GAC, whereas the UV and chemical oxidationtreatment alternative does not generate a residual waste stream.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do notreduce the toxicity, mobility or volume of contaminants in the groundwater. The direct treatment with liquid phase GAC,air stripping with carbon adsorption and UV and chemical oxidation treatment alternatives provide for very similar levelsof contaminant removal efficiencies.
Short-term Effectiveness. The three remedial action alternatives include treatment of the groundwater to removecontamination and therefore address this risk. However, a potential risk to the community, workers and the environmentthrougb generation of dust may result during installation of the three treatment alternatives. This potential risk can beaddressed through implementation of engineering controls such as dust suppression. Residuals handling may also pose risksto workers and the community. These risks can be controlled with proper training of workers and adherence to standardoperating procedures for disposal of residual wastes.
Implementability. The no action and limited action alternatives are easy to implement but will likely require futuregroundwater treatment. No permits are required and groundwater sampling and analysis services are readily available forthe limited action alternative.
The differences in implementability among the three treatment alternatives are inherent in the treatment processes. Thelikelihood that teclmical problems will lead to schedule delays is considered low for direct treatment with liquid phase GAC,moderate for air stripping with carbon adsorption and moderate for UV and chemical oxidation. There are a limited numberof vendors for the UV and chemical oxidation system where the oxidation includes both hydrogen peroxide and ozone.
Cost. No action is by definition a no-cost alternative. Limited action ($400,000) is rated most favorably, followed by airstripping with vapor-phase GAC treatment ($1,068,000), liquid-phase GAC treatment ($1,102,000), and UV/chemicaloxidation ($1,549,000).• State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, fmal stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. In addition,a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ma, attended the public meeting to addressany questions concerning the RIIFS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
8.1.2 Soil
Site 4 Surface Soil. A comparative analysis was completed using the alternatives and criteria previously identified. Thealternatives are:
• IS - No Action• 2S - Limited Action• 3S - RCRA Capping• 4S - Landfill Closure• 9S - Excavation and Offsite Disposal
Overall Protection of Human Health and the Environment. The no action alternative does not provide for overallprotection of human health and the environment. The no action alternative will not affect the mobility, toxicity, or volumeof Site 4 contaminants which are a continuing source of groundwater contamination. The limited action alternative providessome protection to human health by limiting the potential for direct site contact. RCRA capping, landfill closure, and offsitedisposal will provide overall protection of human health and the environment. RCRA capping and landfill closure will• provide protection by limiting direct access to wastes and by reducing the mobility of wastes in the groundwater and airpathways. Offsite disposal will provide protection through removal of wastes and placement of wastes in an offsite facilitydesigned for waste management.
8-16
544 98Compliance with AltARs. The no action and limitedaction alternatives would not provide compliance with ARARs becauseerosion of the landfill and deposition of contaminants into the Heacock Storm Drain would not be prevented. Both the RCRAcapping and landfill closure alternatives would provide compliance with ARARs because they prevent landfill erosion anddeposition of contaminants into the Heacock Storm Drain. The excavation and offsite disposal alternative removes sitecontaminants to an approved facility which complies with ARARs.
Long-term Effectiveness and Pennanence. The no action alternative does not provide a mechanism to control or monitorthe migration of soil contaminants to groundwater. The limited action, RCRA capping and landfill closure alternativesprovide for monitoring of the site although only the RCRA capping and landfill closure are proven technologies forcontrolling migration of soil contamination. Excavation and offsite disposal would remove site contaminants and providefor long-term monitoring at an approved facility offsite.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do notreduce the toxicity, mobility, or volume of the contaminated soil. The RCRA capping, landfill closure and offsite disposalalternatives would reduce the mobility of soil contaminants, but not reduce contaminant toxicity or volume.
Short-term Effectiveness. The landfill closure, RCRA capping, and offsite disposal alternatives would have an immediateimpact on reduction of potential soil contaminant migration. Threats to workers and surrounding community during landfillclosure, RCRA capping, or excavation and offsite disposal could be controlled using dust suppression techniques and ongoingcontaminant monitoring.
Implementability. The no action and limited action alternatives can be easily implemented. The landfill closure and cappingalternatives are essentially construction activities and are easily implemented. The offsite disposal alternative requires theavallability of permitted disposal facilities and licensed waste transporters in addition to the excavation of contaminated soil.
Cost. No action is by defmition a no-cost alternative. Limited action ($1,148,000) is rated most favorably in terms of cost,followed by landfill closure ($2,427,000), RCRA capping ($2,853,000), and lastly by excavation and offsite disposal($96,712,000) which is cost-prohibitive.
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RIIFS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. In addition,a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 10 Soils. A comparative analysis was completed using the alternatives and criteria previously identified. The alternativesare:
• 1S - No action• 2S - Limited Action• 5S - Excavation and Low Temperature Thermal Desorption• 7S - Excavation and Offsite Treatment• 8S - Excavation and Onsite Consolidation• uS - Ex-Situ Bioremediation
Overall Protection of Human Health and the Environment. The excavation and offsite treatment, excavation and onsiteconsolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protectionfrom the principal health and environmental threats associated with soils at Site 10. The no action alternative does not reducethe migration of contaminants offsite or reduce onsite concentrations and therefore does not control contaminant exposure.The limited action alternative provides some protection to human health by limiting the potential for direct site contact.However, offsite migration and potential exposure are not addressed by the limited action alternative.
8-17
544 99Compliance with AIRARs. Excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation,and excavation and low temperature thermal desorption alternatives provide for compliance with the ARARs identified forthis site, while the no action and limited action alternatives do not comply with the ARARs.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to prevent direct accessto contaminated soils or to control or monitor the migration of soil contaminants offbase. The limited action, excavationand offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and excavation and low temperaturethermal desorption alternatives provide for long-term risk reduction although only the excavation and offsite treatment, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives provide permanent treatment. Excavationand onsite consolidation would result in placement of untreated soils on-base, and would therefore require monitoring.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and the limited action alternatives donot reduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsiteconsolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation andlow temperature thermal desorption reduce the toxicity of the wastes. Blending contaminated soils with asphalt, as presentedin the excavation and offsite treatment alternative, increases the total volume of treated material. However, the contaminantconcentrations identified are not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. Due to the potential migration of Site 10 sediments offbase, community exposure could occurif sediments are left onsite. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives, worker protection during excavation,transportation and treatment poses a minor concern. Engineering controls can be used for worker protection (i.e., dustsuppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presentedas a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermaldesonption presents a risk of contaminated air emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no constniction phase and as such implementation isnot an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, andexcavation and low temperature thermal desorption alternatives are proven technologies, and all are easily implemented.
Cost. No action is by definition a no-cost alternative. Excavation and onsite consolidation ($7,000) is rated most favorablyin terms of cost, followed by excavation and offsite treatment ($22,000), excavation and low temperature thermal desorption($37,000), ex-situ bioremediation ($48,000), and limited action ($87,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RIIFS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. Inaddition, a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany question concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 15 Surface Soil. A comparative analysis was completed using the alternatives and criteria previously identified. Thealternatives are:
• is - No action• 25 - Limited Action• 5S - Excavation and Low Temperature Thermal Desorption• 7S - Excavation and Offsite Treatment• 8S - Excavation and Onsite Consolidation• 11S - Ex-Situ Bioremediation
• Overall Protection of Human Health and the Environment. Excavation and offsite treatment, excavation and onsiteconsolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protectionfrom the principal health and environmental threats connected with soils at Site 15. The no action alternative does not reduce
8-18
544 100the migration of contaminants offsite or reduce onsite concentrations and therefore does not control contaminant exposure.The limited action alternative provides some protection to human health by limiting the potential for direct site contact.
Compliance with ARARs. Excavation and offsite treatment, excavation and onsite consolidation, ex—situ bioremediation,and excavation and low temperature thermal desorption alternatives provide for compliance with the ARARs identified forthis site, while the no action and limited action alternatives will not allow compliance with the ARARs.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to prevent direct accessto contaminated soils or to control or monitor the migration of soil contaminants ofibase. The limited action, excavationand offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and excavation and low temperaturethermal desorption alternatives provide for long-term although only the excavation and offsite treatment, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives provide permanent treatment. Excavationand onsite consolidation would result in placement of untreated soils on-base, and would therefore require monitoring.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action or the limited action alternative do notreduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsiteconsolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation andlow temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavationand offsite treatment alternative, increases the total volume of treated material. However, contaminant concentrationsidentified are not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives, worker protection during excavation,transportation and treatment poses a minor concern. Engineering controls can be used for worker protection (i.e., dustsuppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presentedas a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermaldesorption presents a risk of contaminated air emissions, however these can easily be controlled.
linplementability. The no action and limited action alternatives have no construction phase and as such implementation isnot an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, andexcavation and low temperature thermal desorption alternatives are proven technologies, and all are easily implemented.
Cost. The no action alternative is by definition a no-cost alternative. Excavation and onsite consolidation ($4,000) is ratedmost favorably in terms of cost, followed by excavation and offsite treatment ($7,000) excavation and low temperaturethermal desorption ($26,000), ex-situ bioremediation ($43,000), and limited action ($68,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. Inaddition, a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany questions concerning the RIJFS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 18 Subsurface Soils. A comparative analysis was completed using the alternatives and criteria previously identified.The alternatives are:
• 15 - No Action• 2S - Limited Action• 103 - Bioventing• 12S - Soil Vapor Extraction with Catalytic Oxidation• 13S .. Soil Vapor Extraction with Purus PADRE"' System
Overall Protection of Human Health and the Environment. Bioventing, SVE with catalytic oxidation, and SVE with thePurus PADRE" System alternatives provide protection from the principal health and environmental threats associated withsoils at Site 18. The no action alternative does not reduce the migration of contaminants to the groundwater and therefore
8-19
544 101does not control contaminant exposure. The limited action alternative provides some protection to human health bymonitoring contaminant migration.
Compliance With AitARs. There are currently no applicable cleanup criteria for the contaminants of concern in soils atSite 18. Preliminary remediation goals for subsurface soils developed for this site are based on groundwater protection.The no action and limited action alternative will not meet the cleanup criteria developed and proposed for this site.Bioventing and SVE remedial alternatives will reduce the concentrations of contaminants present in the soil. Thesetechnologies have been used to treat contaminated soils with similar properties. However, due to the potential for site-specific conditions to significantly affect the achievable cleanup standards, pilot-scale treatability testing is required initiallyto confirm that these technologies can attain the proposed cleanup criteria.
Long-tenn Effectiveness and Pennanence. The no action alternative provides no risk reduction since contaminants arenot removed or treated. The limited action alternative provides for monitoring of the site although no contaminants areremoved or treated. SVE with catalytic oxidation, SVE with Purus PADRE"' System, and bioventing will reduce themagnitude of risk through removal or destruction of contaminants. The final amount of residual contaminant with each ofthese remedial alternatives will be affected by site-specific conditions; therefore, a reduced level of residual risk may remain.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and the limited action alternatives donot reduce the toxicity, mobility, or volume of contaminants in the soil, while the SVE with catalytic oxidation, SVE withPurus PADRE7" System, and bioventing treatment alternatives significantly reduce toxicity of soils by destroying or removingcontamJnants. SVE with Purns PADRE" System will generate vapor treatment residual wastes. The bioventing and SVEwith catalytic oxidation alternatives will not generate residual wastes requiring further handling.
Short-term Effectiveness. SVE and bioventing remedial alternatives present a potential risk to the community, workers andthe environment through generation of dust during installation. This potential risk can be addressed through implementationof engineering controls such as dust suppression. With SVE, there is a potential for release of vapors if the vapor abatementsystem malfunctions. However, this risk can be minimized by using engineering controls such as automatic shut-offs. SVEwill probably require a shorter time period than bioventing for removal of a given mass of contaminants.
Implementability. The primary differences in implementabiity of the alternatives are those that exist between the no actionor limited action alternatives and the treatment alternatives. The no action and limited action alternatives can easily beimplemented and the treatment alternatives will be more difficult to implement. The three treatment alternatives will requirepilot scale treatabiity studies in order to demonstrate technical feasibility and to generate data for full-scale system design.
The differences that exist between SVE and bioventing are inherent in the treatment processes. SVE is a commonly usedtechnology; however, the subsurface soil characteristics may limit optimum air flow through the soil. Similarly withbioventing, the ability to supply oxygen to the vadose zone may be impeded by fme-grained subsurface materials. SVEgenerates treatment residuals which require further treatment while bioventing does not. There is little difference inimplementability between SVE with catalytic oxidation and SVE with Purus PADRE"' System with the exception that thePurus System is proprietary and therefore limited to only one vendor for service and supplies.
Cost. No action is by definition a no-cost alternative. Limited action ($400,000) is rated most favorably in terms of cost,followed by bioventing ($891,000), SVE with Purus PADRE" System ($1,215,000), and SVE with catalytic oxidation($1,229,000).
State Acceptance. The State of California was actively involved in the RIIFS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A Public comment period was on the Proposed Plan from April 28 to May 28, 1994. Inaddition, a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Departmentof ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany questions concerning the P.J/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 31 Surface Soils. A comparative analysis was completed using the alternatives and criteria previously identified. Thealternatives are:
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• is - No Action• 25 - LimitedAction 544 102• 55 - Excavation and Low Temperature Thermal Desorption• 75 - Excavation and Offsite Treatment• 85 - Excavation and Onsite Consolidation• 115 - Ex-Situ Bioremediation
Overall Protection of Human Health and the Enviromnent. The excavation and offsite treatment, excavation and onsiteconsolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protectionfrom the principal health and environmental threats connected with soils at Site 31. The no action alternative does not reducethe migration of contaminants offsite and therefore does not control contaminant exposure. The limited action alternativeprovides some protection to human health by limiting the potential for direct site contact.
Compliance with ARARs. Excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation,and excavation and low temperature thermal desorption alternatives provide for compliance with the ARARs identified forthis site, while the no action and limited action alternatives do not comply with ARARs.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to prevent direct accessto contaminated soils or to control or monitor the migration of soil contaminants offbase. The limited action, excavationand offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and excavation and low temperaturethermal desorption alternatives provide for long-term risk reduction although only the excavation and offsite treatment, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives provide permanent treatment. Excavationand onsite consolidation would result in placement of untreated soils on-base, and would therefore require monitoring.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action or the limited action alternatives do notreduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsiteconsolidation would effectively reduce the mobility of site contaminants. Only ex-sim bioreniediation, and excavation andlow temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavationand offsite treatment alternative, increases the total volume of treated material. However, the contaminant concentrationsidentified are not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives, worker protection during excavation,transportation and treatment poses a minor concern. Engineering controls can be used for worker protection (i.e., dustsuppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presentedas a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermaldesorption presents a risk of contaminated alr emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation isnot an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, andexcavation and low temperature thermal desorption alternatives are proven technologies, and all are easily implemented.
Cost. No action is by definition a no-cost alternative. Excavation and onsite consolidation ($4 1,000) is rated most favorablyin terms of cost, followed closely by limited action ($65,000), ex-situ bioremediation ($77,000), excavation and lowtemperature thermal desorption ($372,000), and excavation and offsite treatment ($374,000).
State Acceptance. The state of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. In addition,a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address• any questions concerning the RI/PS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 31 Subsurface Soils. A comparative analysis was completed using the alternatives and criteria previously identified.The alternatives are:
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• 15 -NoAction 544 103• 2S - Limited Action• 12S - Soil Vapor Extraction with Catalytic Oxidation• 135 - Soil Vapor Extraction with Puns PADRE"' System• i4S - Soil Vapor Extraction with Carbon Adsorption
Overall Protection of liwnan Realth and the Environment. The SVE with catalytic oxidation, SVE with Punts PADRE"'System, and SVE with carbon adsorption alternatives provide protection from the principal health and environmental threatsassociated with subsurface soils at Site 31. The no action alternative does not reduce the migration of contaminants to thegroundwater and therefore does not control contaminant exposure. The limited action alternative provides some protectionto human health by monitoring the migration of contaminants.
Compliance With ARABs. There are currently no applicable cleanup criteria for the contaminants of concern in soils atSite 31. SVE remedial alternatives will reduce the concentrations of contaminants present in the soil and have been usedto treat contaminated soils with similar properties. However, due to the potential for site-specific conditions to significantlyaffect the achievable cleanup standards, pilot testing is required to confirm technical feasibility of the technologies.
Long-tenu Effectiveness and Permanence. The no action alternative provides no long-term risk reduction sincecontaminants are not removed or treated. The limited action alternative provides for monitoring of the site although nocontaminants are removed or treated. SVE with catalytic oxidation, SVE with Puns PADRE"' System and SVE with carbonadsorption will reduce the magnitude of risk through removal or destruction of contaminants. The final amount of residualcontaminant with each of these remedial alternatives will be affected by site-specific conditions; therefore, some residualrisk may remain. SVE with Puns PADRE"' system and SVE with carbon adsorption will generate treatment residualsrequiring further handling.
Reduction of Toxicity, Mobility, or Vohune Through Treatment. The no action and the limited action alternatives donot reduce the toxicity, mobility or volume of contaminants in the soil while the SVE alternatives significantly reduce wastetoxicity by removing contaminants.
Short-term Effectiveness. The SVE alternatives present a potential risk to the community, workers and the environmentthrough generation of dust and organic vapors during installation. This potential risk can be addressed throughimplementation of engineering controls such as dust suppression. With SVE, there is a potential for release of vapors duringtreatment if the vapor abatement system malfunctions, however, this risk can be minimized by using engineering controlssuch as automatic shut-oils.
Implementability. The primary differences in implementability of the alternatives are those that exist between the no actionor limited action alternatives and the treatment alternatives. These differences are that no action and limited action can easilybe implemented, while the treatment alternatives will be somewhat more difficult to implement.
Cost. No action is by definition a no-cost alternative. Limited action ($400,000) is rated most favorably in terms of cost,followed by SVE with GAC treatment ($467,000), SVE with Puns PADRE"' System ($717,000), and SVE with catalyticoxidation ($730,000).
State Acceptance. The State of California was actively involved in the RI/PS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS, final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. Inaddition a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to addressany questions concerning the RI/PS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
Site 34 Surface Soils. A comparative analysis was completed using the alternatives and criteria previously identified. The• alternatives are:
• 15 - No Action• 2S - Limited Action
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• 5S - Excavation and Low Temperature Thermal Desorption 5 4 4 1 0 4• 75 - Excavation and Offsite Treatment• 85 - Excavation and Onsite Consolidation• uS - Ex-Situ Bioremediation
Overall Protection of Human Health and the Environment. Theexcavation and offsite treatment, excavation and onsiteconsolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protectionfrom the principal health and environmental threats connected with soils at Site 34. The no action alternative does not reducethe migration of contaminants offsite and therefore does not control contaminant exposure. The limited action alternativeprovides some protection to human health by limiting the potential for direct site contact.
Compliance with ARABs. Excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation,and excavation and low temperature thermal desorption alternatives provide for compliance with the ARARs identified forthis site, while the no action and limited action alternatives do not comply with ARARs.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to control or monitorthe migration of soil contaminants ofibase. The limited action, excavation and offsite treatment, excavation and onsiteconsolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide for long-term risk reduction although only the excavation and offsite treatment, ex-situ bioremediation, and excavation and lowtemperature thermal desorption alternatives provide permanent treatment. Excavation and onsite consolidation would resultin placement of untreated soils on-base, and would therefore require monitoring.
Reduction of Toxicity, Mobility, or Volwne Through Treatment. The no action or the limited action alternatives do notreduce the toxicity, mobility and volume through treatment. Excavation and offsite treatment, and excavation and onsiteconsolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation andlow temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavationand offsite treatment, increases the total volume of treated material. However, the contaminant concentrations identified arenot expected to impede the asphaltic encapsulation process.
Short-tenn Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situbioremediation, and excavation and low temperature thermal desorption alternatives, worker protection during excavation,transportation and treatment poses a minor concern. Engineering controls can be used for worker protection (i.e., dustsuppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presentedas a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermaldesorption presents a risk of contaminated alr emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation isnot an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, andexcavation and low temperature thermal desorption alternatives are proven technologies, and all are easily implemented.
Cost. No action is by definition a no-cost alternative. Excavation and onsite consolidation ($14,000) is rated most favorablyin terms of cost, followed by ex-situ bioremediation ($52,000), limited action ($55,000), excavation and offsite treatment($101,000), and excavation and low temperature thermal desorption ($110,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participatedin the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS,final stateacceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. Inaddition, a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Aria, attended the public meeting to addressany questions concerning the RI/FS and Proposed Plan. A Responsiveness Summaiy is included as Appendix A.
Site 34 Subsurface Soils. A comparative analysis was completed using the alternatives and criteria previously identified.The alternatives are:
• is - No Action
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• 2S - LimitedAction 544 105• 105 - Bioventing• 12S - Soil Vapor Extraction with Catalytic OxidationS 135 - Soil Vapor Extraction with Puns PADRET1' System
Overall Protetion of Human Health and the Enviromnent. With the exception of the no action and limited actionalternative, all the potential remedial alternatives will provide overall protection of human health and the environment. Theno action alternative will not reduce the long-term risk posed by the presence of the petroleum-derived organics in soil atSite 34. The limited action alternative will provide minimal protection to human health and the environment throughmonitoring of contaminant migration. However, the site would continue to be a source of groundwater contamination.
Compliance With AIRARs. There are currently no applicable cleanup criteria for the contaminants of concern in soils atSite 34. Preliminary remediation goals for subsurface soils at this site are based on groundwater protection.
Long-tenn Effectiveness and Pennanence. The no action alternative does not provide a mechanism to control or monitorthe migration of soil contaminants offbase. The limited action alternative provides for monitoring of the site. The bioventingalternative and the SVE alternatives will reduce the magnitude of risk through contaminant reduction. The final amount ofcontaminant reduction with each of these remedial alternatives will be affected by site specific conditions; therefore, someresidual risk may remain. The SVE with Puns PADRE"' System generates residual wastes requiring further handling; noother alternative generates residual wastes.
Reduction of Toxicity, Mobility, or Volume Through Treatment. No action and limited action alternatives do not reducethe toxicity, mobility, or volume of contaminants in the soil. Both of the SVE alternatives and the bioventing alternativereduce waste toxicity by removing or destroying contaminants.
Short-term Effectiveness. Implementation of the no action and limited action alternatives will result in a continuation ofrisks to the community through the presence of the contaminants in soil representing a source of groundwater contamination.The SVE alternatives and bioventing alternative include treatment of the soil to remove this contamination, and therefore• address this risk. However, a potential risk to the community, workers, and the environment through the generation of dustand organic vapors may result during installation of any of the treatment remedial alternatives. This potential risk can beaddressed through implementation of engineering controls such as dust control. Due to the removal of contaminated vaporsin the SVE technique, an additional potential risk to the community, workers, and the environment is possible exposure tocontaminated vapors should the vapor treatment system fall. The risk can be reduced through engineering controls, suchas automatic shut-offs.
Implementability. The SVE and bioventing alternatives are proven technologies that do not present major implementationproblems. However, subsurface soil characteristics may cause operational problems related to the ability to attain optimumair flow or oxygenated conditions in site soils. Pilot studies will be required to demonstrate technical feasibility and togenerate data for full-scale system design.
Minimal action is required to implement either the No Action or Limited Action alternative and as such implementabilityis not considered an issue.
Cost. No action is by definition a no-cost alternative. Bioventing ($89,000) is rated most favorably in terms of cost,followed by limited action ($180,000), SVE with Puns PADRE"' System ($252,000), and SVE with catalytic oxidation($281,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process andparticipated in the public meeting held to inform the public of the proposed plan. While the state concurs with the RI/FS,final state acceptance will occur in the approved ROD.
Community Acceptance. A public comment period was on the Proposed Plan from April 28 to May 28, 1994. In addition,a public meeting was held on May 12, 1994. Representatives of the U.S. Air Force, USEPA, Department of ToxicSubstance Control, and California Regional Water Quality Control Board, Santa Ma, attended the public meeting to addressany questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
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9.0 SELECTED REMEDIES544 106
Modification to the selected remedies may be necessary as a result of remedial design (RD) construction processes. Detaileddesign specifications, performance evaluations, verification sampling methods, and schedule will be determined during theRD. The selected groundwater and soil remedies will meet the cleanup standards presented in Table 5-1 and Table 5-2.After the selected soil remedies have been completed, soil samples will be taken and analyzed to ensure that the cleanupstandards have been achieved. The following are the preferred alternatives for each site to be remediated.
9.1 GROUNDWATER
Site 4/01.11 groundwater plume. There is currently an operational groundwater extraction and treatment system (GETS)located along the eastern base boundary. The system was installed in 1992 as an interim removal action. The extractioncomponent of the system consists of nine wells that were located in order to interdict the Site 4 and OU 1 plumes at the baseboundary. The treatment system utilizes GAC to remove contaminants of concern.
The preferred remedy for the Site 4/0131 groundwater plume is to utilize the existing GETS system, supplemented withadditional extraction wells and GAC treatment units as necessary (Alternative 30), and to stop the migration of the onbaseplume ofibase and to treat the contaminated groundwater in the existing plume. Contaminated groundwater extracted fromSite 4 will be combined for treatment with groundwater extracted from the OU1 plume. Treated water will be dischargedto either the base wastewater treatment plant, the Heacock Storm Drain downgradient from the wetlands location, or injectedinto the aquifer. The Heacock Storm Drain discharges to the Penis Valley Storm Drain Lateral A. An unlined infiltrationpond will be constructed over the plume area to store treated water during high flow periods in the Heacock Storm Drain,if applicable. Implementation of a groundwater extraction and treatment program will provide for capture of onbasecontaminated groundwater and will prevent further escape of onbase contaminated groundwater ofibase.
• Since there are low concentrations of contaminants (a maximum of 19 pg/I and 42 jig/I, PCE and TCE, respectively) in thedowngradient plume, this portion of the plume will be allowed to dissipate. This decision is based on the following threefactors:
First, the predictive modeling performed by the Air Force, as well as recent sampling results, indicate thatdissipation may be presently occurring. With the elimination of the source for the downgradient plumethrough treatment and containment of the upgradient plume, the natural process of dilution, volatilization,adsorption, and/or partitioning to the solid phase, as well as biological degradation of the contaminant willaccelerate, resulting in dissipation.
Second, on completion of the risk assessment, it was determined that the risk from allowing thecontaminants in the downgradient plume to naturally dissipate is within EPA's acceptable cancer risk rangeof 1 x 1O' to 1 x l0. With the existing levels of contaminants, residential use of the groundwater in thedowngradient plume is within a cancer risk range of iO-5. Although the Air Force has been advised by theEastern Municipal Water District that their district provides full water service and that there are no knownusers of this groundwater, the Air Force will continue to monitor the progress of the dissipation ofcontaminants. Through this monitoring, it will be possible to determine whether additional measures arenecessary to assure that there are no threats to human health or the environment during the period ofdissipation of the downgradient plume. As an additional safety precaution, the Air Force is noti'ingCounty officials of the identity of property owners whose properties may be affected by the downgradientplume and requesting that the County not issue permits to install wells until the contaminants have beenreduced below cleanup standards.
Third, the existing groundwater data indicate that levels of TCE and PCE contamination in thedowngradient plume are minimal (refer to Section 2.3 and Table 6-2 for data and MCL information).Installation of a pump and treat system encircling the entire OU 1 contaminant plume (including thedowngradient plume) was included in the Draft RI/FS Report for OU1 in July 1993. The system wasprojected to have a total cost exceeding 12 million dollars, or approximately 10 million dollars more thanthe chosen alternative. Past experience has indicated that it is difficult to treat such low levels ofcontamination, and the incremental cost for treatment of the downgradient plume at this site was not
9-1
544 107considered to be warranted. Thus, the alternative of pumping and treating the entire OUt plume wasdeleted from consideration in the Final RI/FS report.
Groundwater monitoring will be conducted to ensure that the onbase portion of the plume does not migrate offbase, to ensurethat the maximum concentration of offbase contaminants continues to fall, and to ensure that the offbase plume does notthreaten oftbase water supplies. Monitoring of the entire ofibase plume will be conducted, which will necessitate installationof additional monitoring wells to fully define the horizontal and vertical extent of contamination and monitor its movementthrough time. Several additional wells will be installed ofibase. The actual number and location of these wells will berecommended by the Air Force and approved by the regulatory agencies and will be based on sound scientific information.These wells will be sampled at least twice yearly. Each five year period, the data collected from those samples will be usedto evaluate the effectiveness of the augmented GETS system in stopping contaminant migration offbase, and to ensureprotection of ofibase water supplies.
If monitoring data show that the operation of the GETS system combined with dissipation is not reducing the maximumconcentration of contaminants in the downgradient plume, or is not stopping migration of the onbase plume offbase, or ifoffbase water supplies are threatened, then expansion of active treatment into the downgradient plume will be initiated. Ifat the end of 30 years the contaminants have not dissipated to cleanup standards, then the Air Force will expand activetreatment of all Air Force related contamination into the downgradient plume.
Sampling shall be accomplished on a semi-annual basis for VOCs (EPA Method 8260) and annually for total metals (EPAMethod 6010), semivolatile organics (EPA Method 8270), and California Title 22 General Minerals. Groundwatermeasurements, to the nearest 0.01 foot, shall be obtained quarterly. All groundwater samples shall be collected using thetechniques described in Chapter 4 of the RCRA Groundwater Monitoring Technical Enforcement Guidance Document (EPA1986b) as modified for the existing March AFB Basewide Groundwater Monitoring Program.
Analytical data from each semi-annual round of sampling will be tabulated and summarized in a brief report. Following dataverification by the Air Force, the semi-annual reports will be forwarded to signatories of the FFA and other interestedparties. These reports will include semi-annual groundwater contour maps. At the conclusion of each five years ofsampling, all data generated will be compiled, reviewed, interpreted, and summarized in a report.
The estimated cost for continuation of the GETS is approximately $1,839,000. The cost breakdown is as follows:
COST SUMMARY BREAKDOWNINSTALLED CAPITAL:
Site Preparation $ 29,471
Installation of Wells $ 206,900
Construction Oversite $ 43,560
Extraction System $ 198,380
Groundwater Treatment $ 110,662
Subtotal Installed Capital: $ 588,973
Annual O&M Costs: $ 106,348
PRESENT WORTH OF O&M COSTS: $1,102,787
TOTAL PROJECT COSTS: $1,839,000
Because the selected remedy requires long-term O&M, it will require five year reviews. At the end of each 5-year period,• a collective decision between the regulating agencies and the Air Force on whether to continue monitoring and/or conductcleanup of the groundwater will be made.
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544 108
Site18 Groundwater Plume. The preferred alternative for Site 18 involves a combination of soil and groundwater treatmenttechnologies. This combination is preferred because both soil and groundwater are contaminated, free-phase fuel is present,• and contaminated soils have become submerged beneath a rising water table. Dual-purpose wells will be installed in orderto simultaneously extract groundwater and contaminated soil vapors. Dual extraction of soil vapors and groundwater willenhance groundwater cleanup in several ways. Most importantly, the continuing source of contaminants from the vadosezone will be removed. In addition, application of a vacuum to the dual-purpose wells will increase groundwater flow to thewells. Lastly, by lowering the water table and exposing contaminated aquifer materials to air flow, contaminant massremoval rates will be increased. This is because contaminants of concern are volatile, and are removed much moreefficiently in the vapor phase than in groundwater.
Groundwater will be remediated using total fluids recovery followed by oil/water separation and air stripping for groundwaterremediation (Alternatives 8G/5G). Free-phase product will be recovered in an above-ground oil/water separator forrecycling. Contaminated groundwater will be treated by air stripping to remove volatile contaminants, followed by liquidphase carbon polishing to remove any remaining fuel components. Treated water will be discharged either to the basewastewater treatment plant, to the 1-Jeacock Storm Drain downgradient from the wetlands location, or reinjected to theaquifer. An unlined infiltration pond will be constructed over the plume area to store treated water during high flow periodsin the fleacock Storm Drain, if applicable. Contaminant-laden air from the SVE process and the air stripper will be cleanedusing the Purus PADRE" System (Alternative 13S).
The estimated cost for dual extraction at Site 18 is approximately $1,027,188. The cost breakdown is as follows:
COST SUMMARY BREAKDOWNINSTALLED CAPITAL:
Site Preparation $ 27,871
Installation of Wells $ 54,990
Construction Oversight $ 9,410
Extraction System $ 67,030
Groundwater Treatment $ 60,116
DesigniContingencies $ 54,855
Subtotal Installed Capital: $ 274,271
Annual O&M Costs: $ 72,608
PRESENT WORTH OF O&M COSTS: $ 752,916
TOTAL PROJECT COSTS: $1,027,188
Site 31 Groundwater Plume. Site 31 is a likely source for much of the TCE found in groundwater beneath OU1. Thepreferred method for cleanup of groundwater at Site 31 is to use groundwater extraction and treatment (Alternative 3G) incombination with SVE. Dual-purpose wells will be installed in order to simultaneously extract groundwater and contaminatedsoil vapors. Dual extraction of soil vapors and groundwater will enhance groundwater cleanup in several ways. Mostimportantly, the continuing source of contaminants from the vadose zone will be removed. In addition, application of avacuum to the dual-purpose wells will increase groundwater flow to the wells. Lastly, by lowering the water table andexposing contaminated aquifer materials to air flow, contaminant mass removal rates will be increased. This is becausecontaminants of concern are volatile, and are removed much more efficiently in the vapor phase than in groundwater.
Extracted groundwater will be treated at the surface using activated carbon to remove the TCE and related compounds.Treated water will be discharged either to the base wastewater treatment plant, to the Heacock Storm Drain downgradientfrom the wetlands location, or reinjected to the aquifer. An unlined infiltration pond will be constructed over the plume areato store treated water during high flow periods in the Heacock Storm Drain, if applicable. Soil vapors will be treated usingvapor phase GAC. GAC removes contaminants from the extracted vapor stream by adsorption on the carbon. When the
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.
S
544 109carbon becbmes saturated, it will be shipped offsite for regeneration. The estimated cost for groundwater extraction andtreatment at Site 31 is approximately $1,103,000. The cost breakdown is as follows:
COST SUMMARY BREAKDOWN
INSTALLED CAPITAL:
Site Preparation $ 19,576
Installation of Wells $ 74,400
Construction Oversight $ 9,410
Extraction Systems $ 120,275
Groundwater Treatment $ 55,896
Design/Contingencies $ 69,890
Subtotal Installed Capital: $ 349,446
Annual O&M Costs: $ 72,664
PRESENT WORTH OF O&M COSTS: $ 753,497
TOTAL PROJECT COSTS: $1,103,000
9.2 SoIL
Site 4. The preferred cleanup method for solid wastes is closure of the landfill in accordance with California regulations(Alternative 4S). This will include installation of a cap over the landfill, protecting the cap from erosion, long-termmaintenance, and long-term monitoring. Closure of the landfill will minimize the potential for leachate generation andfurther groundwater contamination.
Site 10. A small volume of contaminated soil at Site 10 requires cleanup. The preferred method of cleanup of these soilsis excavation and low-temperature thermal desorption (Alternative 55). Low-temperature thermal desorption will destroythe contaminants of concern, thereby eliminating risk and the requirement for long-term monitoring.
Site 15. The preferred method of cleanup of these soils is excavation and low-temperature thermal desorption (Alternative5S). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and therequirement for long-term monitoring.
Site 18. Subsurface soil remediation (Alternative 13S) at Site 18 has been combined with the remediation of the Site 18groundwater plume. See the Site 18 groundwater plume discussion above for a detailed discussion of both soil andgroundwater remediation.
Site 31. The preferred method of cleanup of these soils is excavation and low-temperature thermal desorption (AlternativeSS). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and therequirement for long-term monitoring.
Site 34. The preferred method of cleanup of these soils is excavation and low-temperature thermal desorption (Alternative5S). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and therequirement for long-term monitoring..
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544 11010.0 STATUTORY DETERMINATIONS
Under its legal authorities, EPA's involvement at Superfund sites is to undertake remedial actions that achieve adequateprotection of human health and the environment. In addition, section 121 of CERCLA establishes several other statutoryrequirements and preferences. These specify that when complete, the selected remedial action for OUI must comply withapplicable or relevant and appropriate environmental standards established under Federal and state environmental laws unlessa statutory waiver is justified. The selected remedy also must be cost-effective and utilize permanent solutions and alternativetreatment technologies or resource recovery technologies to the maximum extent practicable. Finally, the statute includesa preference for remedies that employ treatment technologies that permanently and significantly reduce the volume, toxicity,or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedies meetthe statutory requirements.
10.1 GROuNDWATER
Site 4/01.11 Groundwater Plume -Direct Treatment with Liquid Phase GAC
Protection of Human Health and the Environment. The selected remedy provides protection of human health and theenvironment through recovery of contaminated groundwater and subsequent removal of the contaminants. The alternativeprovides both short-term and long-term solutions to contaminant migration by removal of these constituents from thegroundwater. This alternative utilizes extraction and treatment technologies that have been successfully implemented at othersites with similar conditions as well as at March AFB. Residuals from treatment (i.e. saturated activated carbon) will requireregeneration or offsite disposal.
Recovery of contaminated groundwater and subsequent removal of contaminants will provide long-term effective remediationof the groundwater. The remedy will permanently and significantly reduce the volume of the volatile organics present in• the treated groundwater. Based on successful application at similar sites, the technology is capable of removing at least 99percent of the organic contaminants from the extracted groundwater and will reduce the concentrations of volatile organicsto below currently acceptable levels. In addition, the remedy provides permanent, irreversible treatment of the groundwater.
Implementation of deed restrictions to prohibit the use of groundwater, until groundwater cleanup standards have beenachieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completedusing conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated duringsite preparation (i.e. grading the area) or installation of the treatment system. Engineering controls, such as dust suppression,will be employed as necessary to mitigate exposure to and migration of contaminants during the implementation of thetechnology.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Tables C-i and C-2).
Cost-Effectiveness. The selected remedy was chosen because of the three remedies that provide effective overall protectionof human health and the environment, it is the least expensive.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovety Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionsand treatment technologies can be utilized in a cost-effective manner for the Site 4 and OU 1 groundwater plumes. Directtreatment with GAC provides the best balance of tradeoffs in terms of long-term effectiveness and permanence; reductionin toxicity, mobility, or volume through treatment; short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By treating the VOC-contaminated groundwater with GAC, the selected remedyaddresses the principal threat posed by the Site 4 and OU 1 groundwater plumes through the use of a proven treatmenttechnology.
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544 111Site 18 Groundwater Plume - Air Stripping with Purus PADRE"'System/Total Fluids Recovery
-• Protection of Human Health and the Environment. The selected remedy provides protection of human health and theenvironment through recovery of contaminated groundwater and subsequent removal of contaminants. Free-phase productwill also be recovered for recycling. The remedy provides both short-term and long-term solutions by removing thecontaminants from the groundwater. This alternative utilizes groundwater extraction and treatment technologies that havebeen successfully implemented at sites with similar conditions. The selected remedy is a permanent solution to the existingproblem.
The process efficiency of the selected remedy has been demonstrated. Recovery of contaminated groundwater and subsequentremoval of contaminants will provide long-term effective remediation of the groundwater. The remedy will permanentlyand significantly reduce the volume of the volatile organics present in the treated groundwater. Based on successfulapplication at similar sites, the technology is capable of reducing the concentration of volatile organics present in theextracted groundwater to below currently acceptable levels. In addition, the remedy provides permanent, irreversibletreatment of the groundwater.
Implementation of deed restrictions to prohibit the use of groundwater, until groundwater cleanup standards have beenachieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completedusing conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated duringsite preparation (i.e. grading the area) or installation of the treatment system. Engineering controls, such as dust suppression,will be employed as necessary to mitigate exposure to and migration of contaminants during the implementation of thetechnology.
Compliance with Applicable or Relevant andAppropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Tables C-S and C-4).
Cost-Effectiveness. Two alternatives were rated equally on all evaluation criteria. The Puns PADRETMsystem was chosenbecause it can be used to treat not only contaminated vapors from the air stripper, but also contaminated vapors from theSVE system, thereby minimizing costs for combined treatment of soil and groundwater.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recoveiy Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionsand treatment technologies can be utilized in a cost-effective manner for the Site 18 groundwater plume. Groundwatertreatment through air stripping with treatment of the vapor stream with the Purus PADRE" System provides the best balanceof tradeoffs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment;short-term effectiveness; implementability; and cost, Additionally, free-phase product will be recovered and recycled.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By treating the fuel-contaminated groundwater with an air stripper, the selectedremedy addresses the principal threat posed by the Site 18 groundwater plume through the use of a proven treatmenttechnology.
Site 31 Groundwater Plume - Direct Treatment with Liquid Phase GAC
Protection of Human Health and the Environment. The selected remedy provides protection of human health and theenvironment through recovery of contaminated groundwater and subsequent removal of the contaminants. The remedyprovides both short-term and long-term solutions to contaminant migration by removal of these constituents from thegroundwater. The selected remedy utilizes extraction and treatment technologies that have been successfully implementedat sites with similar conditions. Residuals from treatment (i.e. saturated activated carbon) will require regeneration or offsitedisposal.
Recovery of contaminated groundwater and subsequent removal of contaminants will provide long-term effective remediationof the groundwater. The selected remedy will reduce the concentration of volatile organics present in the treated effluent• to acceptable levels. The remedy will permanently and significantly reduce the volume of the volatile organics present inthe extracted groundwater. Based on successful application at numerous similar sites, at least 99 percent of the organiccontaminants will be removed from the extracted groundwater. In addition, this alternative provides permanent, irreversibletreatment of the groundwater.
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544 112Implementation of deed restrictions to prohibit the use of groundwater, until groundwater cleanup standards have beenachieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completedusing conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated duringsite preparation (i.e. grading the area) or installation of the treatment system. Engineering controls, such as dust suppression,will be employed as necessary to mitigate exposure to and migration of contaminants during the implementation of thetechnology.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Tables C-5 and C-6).
Cost-Effectiveness. The selected remedy was chosen because it was rated highest overall in terms of the evaluation criteria.Of the three alternatives that provide effective overall protection of human health and the environment, this alternative iseither cheaper than or comparable to the other alternatives.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionsand treatment technologies can be utilized in a cost-effective manner for the Site 31 groundwater plume. Direct groundwatertreatment with GAC provides the best balance of tradeoffs in terms of long-term effectiveness and permanence; reductionin toxicity, mobility, or volume through treatment; short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By treating the VOC-contaminated groundwater with GAC, the selected remedyaddresses the principal threat posed by the Site 31 groundwater plume through the use of a proven treatment technology.
10.2 Sot
Site 4 - Landfill Closure
Protection of Human Health and the Environment. The selected remedy protects human health and the environment throughlandfill closure and construction of a cap over the landfill which will reduce infiltration of precipitation and prevent erosionof landfill wastes. Additionally, the closure would isolate the storm drainage system from the landfill material through theinstallation of an impermeable vertical barrier. The selected remedy provides long-term maintenance and water qualitymonitoring of the closure system, response programs, and establishment of a closure fund to support the requiredmaintenance activities. Capping is a proven technology in controlling migration of soil contaminants.
The selected remedy will ensure the long-term effectiveness in minimizing the migration of soil contaminants to thegroundwater. The mobility of soil contaminants will be reduced through the construction of a low permeability cover anda vertical barrier along the surface water dralnage channel. Upon completion of the cap, the alternative will have animmediate impact on reduction of potential soil contaminant migration.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-i).
Cost-Effectiveness. The selected remedy was chosen because it was rated highest in terms of the overall evaluation criteriaand is cheaper than other alternatives that offer effective protection of human health and the environment.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionscan be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-termeffectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; andcost.
Preference for Treatment as a Principal Element. The selected remedy does not satis' the statutory preference for remedies• that employ treatment as a principal element. Treatment of wastes found at Site 4 is not practicable for two reasons. First,the nature of the wastes (refuse, debris) is not amenable to treatment. Second, even though extensive sampling of the landfillwas conducted, no apparent source area for contaminants was observed.
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544 113Site 10 - Excavation and Low Tcmperature Thennal Desorption
• Protection of Human Health and the Environment. The selected remedy protects human health and the environment bytreating the contaminated soils with low-temperature thermal desorption. Exposure to PAN-contaminated soils is reducedby reducing the PAH levels within the soils. The exposure to workers and the public during excavation and treatment ofcontaminated soils will be minimized through engineering controls, personal protective equipment, and standard operatingprocedures. Dust suppression measures and engineering controls will be implemented to reduce exposure to the surroundingcommunity from dust particles and air emissions during the removal and treatment of soils.
Since the contaminated soils will be removed and treated, no long-term operational or monitoring considerations exist at Site10. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at thesite. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicityreduction through low-temperature thermal treatment is dependent on volatilization of the PANs and effective off-gastreatment. Catalytic oxidation and incineration will effectively destroy the contaminant, eliminating any toxicity concerns.In the event this process fails to meet expected remediation levels, alternative technologies can easily be implemented.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARABs (refer to Appendix C, Table C-8).
Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protectionof human health and the environment and are implementable, it is the only one that offers a permanent solution, and costsare comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionscan be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-termeffectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; andcost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies thatemploy treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet airquality AltARs, the selected remedy addresses the principal threat posed by Site 10 soils through the use of proven treatmenttechnologies.
Site 15 - Excavation and Low Temperature Thermal Desorption
Protection of Human Health and the Environment. The selected remedy protects the human health and the environment bytreating the contaminated soils with low-temperature thermal desorption. Exposure to PAH-contaminated soils is reducedby reducing the PAN levels within the soils. The exposure to workers and the public during excavation and treatment ofcontaminated soils will be minimized through engineering controls, personal protective equipment, and standard operatingprocedures. Dust suppression measures and engineering controls will be implemented to reduce exposure to the surroundingcommunity from dust particles and air emissions during the removal and treatment of soils.
Since the contaminated soils will be removed and treated, no long-term operational or monitoring considerations exist at Site15. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at thesite. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicityreduction through low-temperature thermal treatment is dependant on volatilization of the PANs and effective off-gastreatment. Catalytic oxidation and incineration will effectively destroy the contaminant, eliminating any toxicity concerns.In the event this process fails to meet expected remediation levels, alternative technologies can easily be implemented.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-9).
• Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protectionof human health and the environment and are implementable, it is the only one that offers a permanent solution, and costsare comparable.
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544 114Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionscan be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-termeffectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; andcost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies thatemploy treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet airquality ARARs, the selected remedy addresses the principal threat posed by Site 15 soils through the use of proven treatmenttechnologies.
Site 18 - Soil Vapor Extraction with Purus PADRE"'System
Protection of Human Health and the Environment. The selected remedy protects human health and the environment bymechanically removing volatile contaminants from unsaturated soils and treating the contaminants at the surface. Thisremedy will reduce soil contaminant concentrations and thus prevent further degradation of groundwater.
Implementation of the selected remedy will provide long-term effective remediation. However, the effectiveness of thetechnology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may notbe effectively treated to the required cleanup standards.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. Engineeringcontrols will be employed as necessary during the installation of the remedy to mitigate exposure to and offsite migrationof contaminants. The use of this technology will result in a contaminated gas stream that will require treatment. However,since the contaminated gas stream will be under a vacuum, the potential of leaks of the contaminated gas steam to theenvironment is minimized.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-tO).
Cost-Effectiveness. Of the three alternatives that provide effective protection of human health and the environment, all wererated equally in terms of the overall selection criteria. The selected remedy is slightly higher in cost, but was chosen becauseit integrates with the Site 18 groundwater treatment system. The Purus PADRETM system can be used to treat contaminatedvapors from both the SVE system and the alr stripper, thereby minimizing costs of combined soil/groundwater treatment.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionsand treatment technologies can be utilized in a cost-effective manner for source removal. SVE provides the best balanceof tradeoffs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment;short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By removing VOC contaminants in subsurface soils and treating the extracted vaporto meet air quality ARARs, the selected remedy addresses the principal threat posed by Site 18 soils through the use ofproven treatment technologies.
Site 31 Surface Soils - Excavation and Low Temperature Thermal Desorption
Protection of Human Health and the Environment. The selected remedy protects the human health and the environment bytreating the contaminated soils with low-temperature desorption. Exposure to PAll-contaminated soils is reduced by reducingthe PAH levels within the soils. The exposure to workers and the public during excavation and treatment of contaminatedsoils will be minimized through engineering controls, personal protective equipment, and standard operating procedures.Dust suppression measures and engineering controls will be implemented to reduce exposure to the surrounding community• from dust particles and air emissions during the removal and treatment of soils.
Since the contaminated soils will be removed and treated, no long-term operational or monitoring considerations exist at Site31. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at the
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544 115site. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicityreduction through low-temperature thermal treatment is dependent on volatilization of the PAHs and effective off-gas• treatment. Catalytic oxidation and incineration will effectively destroy the contaminant, eliminating any toxicity concerns.In the event this process fails to meet expected remediation levels, alternative technologies can easily be implemented.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARABs (refer to Appendix C, Table C-li).
Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protectionof human health and the environment and are implementable, it is the only one that offers a permanent solution, and costsare comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionscan be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-termeffectiveness and permanence; reduction in toxicity, mobility, volume; short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies thatemploy treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet airquality ARAIQS, the selected remedy addresses the principal threat posed by Site 31 soils through the use of proven treatmenttechnologies.
Site 31 Subsurface Soil - Soil Vapor Extraction with Carbon Adsorption
Protection of Human Health and the Environment. The selected remedy protects human health and the environment bymechanically removing volatile contaminants from unsaturated soils and treating the contaminants at the surface. Thisremedy will reduce soil contaminant concentrations and thus prevent further degradation of groundwater through contaminant• migration.
Implementation of the selected remedy will provide long-term effective remediation. However, the effectiveness of thetechnology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may notbe effectively treated.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. Engineeringcontrols will be employed as necessary during the installation of the remedy to mitigate exposure to and offsite migrationof contaminants. The use of this technology will result in a contaminated gas stream that will require treatment. However,since the contaminated gas stream will be under a vacuum, the potential of leaks of the contaminated gas steam to theenvironment is minimized.
Compliance with Applicable or Relevant andAppropriate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARABs (refer to Appendix C, Table C-12).
Cost-Effectiveness. The selected remedy was chosen because of the three similar alternatives that provide for overallprotection of human health and the environment, it is the least expensive.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionsand treatment technologies can be utilized in a cost-effective manner for source removal. SVE provides the best balanceof tradeoffs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment;short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By removing VOC contaminants in subsurface soils and treating the extracted vapor• to meet air quality ARARs, the selected remedy addresses the principal threat posed by Site 18 soils through the use ofproven treatment technologies.
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544 116Site 34 Surface Soil - Excavation and Low Temperature Thennal Desorption
• Protection of Human Health and the Environment. The selected remedy protects the human health and the environment bytreating the contaminated soils with low-temperature thermal desorption. Exposure to PAM-contaminated soils is reducedby reducing the PAM levels within the soils. The exposure to workers and the public during excavation and treatment ofcontaminated soils will be minimized through engineering controls, personal protective equipment, and standard operatingprocedures. Dust suppression measures and engineering controls will be implemented to reduce exposure to the surroundingcommunity from dust particles and air emissions during the removal and treatment of soils.
Since the contaminated soils will be removed and treated, no long-term operational or monitoring considerations exist at Site34. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at thesite. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicityreduction through low-temperature thermal treatment is dependant on volatilization of the PAils and effective off-gastreatment. Catalytic oxidation and incineration will effectively destroy the contaminant, eliminating any toxicity concerns.In the event this process fails to meet expected remediation levels, alternative technologies can easily be implemented.
Compliance with Applicable or Relevant and App top ri ate Requirements. The selected remedy will comply with all applicableor relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-13).
Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protectionof human health and the environment and are implementable, it is the only one that offers a permanent solution, and costsare comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutionscan be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-termeffectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; andcost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies thatemploy treatment as a principal element. By removing PARs from the soils and controlling the alr emissions to meet airquality ARARs, the selected remedy addresses the principal threat posed by Site 34 soils through the use of proven treatmenttechnologies.
Site 34 Subsurface Soil - Bioventing
Protection of Human Health and the Environment. The selected remedy protects human health and the environment throughenhancement of the natural microbial biodegradation of hydrocarbons in unsaturated soils. This remedy is completed byproviding sufficient air flow in the soil to maintain oxygenated conditions. This remedy will reduce soil contaminantconcentrations thereby providing protection to human health by limiting further degradation of the groundwater.
Implementation of the selected remedy will provide long-term effective remediation. However, the effectiveness of thetechnology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may notbe effectively treated.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. Theinjection of ambient air into the subsurface will not result in air discharges that could affect local residents. Monitoring ofsurface ambient air will confirm potential discharges through the surface soils. The selected remedy has a positive impacton the environment in that natural processes are used to degrade contaminants to non-toxic end products. The time periodfor treatment is site specific depending upon the rate of degradation attainable with the microorganisms present in the soiland the ability to apply oxygen.
Compliance with Applicable or Relevant and Appropriate Requirements. The selected remedy will comply with all applicable• or relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-14).
Cost-Effectiveness. The selected remedy was chosen because it was rated highest in terms of the overall evaluation criteriaand is cheaper than other alternatives that provide effective protection of human health and the environment.
10-7
544 117Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to theMaximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions• and treatment technologies can be utilized in a cost-effective manner for source removal. Bioventing provides the bestbalance of tradeoffs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume throughtreatment; short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference for remedies thatemploy treatment as a principal element. By enhancement of the natural microbial biodegradation of hydrocarbons inunsaturated zone subsurface soils, the selected remedy addresses the principal threat posed by Site 34 soils through the useof treatment technologies.
.
.10-8
544 11811.0 DOCUMENTATION OF SlGNmiciucr CHANGES.
No significant changes to the OU1 ROD were required as a result of public comments received by the Air Force.
.
.11—1
S
544 119
APPENDIX ARESPONSIVENESS
SUMMARY
Responsiveness Summary 544 12 0
A. Overview
Prior to the public comment period March Air Force Base (AFB) had chosen preferred remedialalternatives for each individual site within the Operable Unit 1 (OU1). The March AFB chosenalternatives addressed the soil andlor groundwater problems for each site. The preferred alternative foreach site located within OU1 is as follows:
Site Number Contamination Media Preferred Alternative(s)
4 Groundwater Direct treatment with liquid phase granularactivated carbon (GAC).
4 Subsurface Soil Landfill Closure
10 Surface Soil Excavation and on-site consolidation, orexcavation, or low temperature thermal desorption
15 Surface Soil Excavation and on-site consolidation, orexcavation, or low temperature thermal desorption
18 Groundwater Air stripping with Purus PADRE system! totalfluids recovery
18 Subsurface Soil Soil vapor extraction with Purus PADRE systemand bioventing
31 Groundwater Direct treatment with liquid phase GAC adsorption
31 Surface Soil Excavation and on-site consolidation, orexcavation, or low temperature thermal desorption
31 Subsurface Soil Soil vapor extraction and carbon adsorption
34 Surface Soil Excavation and on-site consolidation, orexcavation, or low temperature thermal desorption
34 Subsurface Soil Bioventing
The Superfund Amendments and Reauthorization Act (SARA) of 1986 requires federal facilities, likeMarch MB, to work closely with the Environmental Protection Agency (EPA) and follow their guidelineswhile conducting hazardous waste site investigations and cleanup. Following a July 1989 proposal forthe inclusion of March AFB to the National Priorities List (NPL), March MB began coordinating withEPA, the California Department of Health and Safety (DHS), and the California Regional Water QualityControl Board (RWQCB) to develop a plan to address the regulatory requirements of these agencies whilecontinuing ongoing efforts to characterize and clean up waste sites. These negotiations were successfidlyconcluded on September 27, 1990, by which time representatives of the three regulatory agencies and theAir Force had signed the Federal Facilities Agreement (FFA). In September of 1990 the FFA provideda schedule of future Installation Restoration Program (IRP)/Superfund activities at March AFB which was• A-i
544 121released for public comment.
B. Background on Community Involvement
The Remedial Investigation I Feasibility Study (RI/FS) report and Proposed Plan for OU1 were releasedto the public on April 28, 1994. These two documents were made available to the public in theAdministrative Record, the information repositories at the Moreno Valley and March AFB libraries, andat the Moreno Valley Chamber of Commerce. The notice of availability of these documents waspublished in the Press-Enterprise on April 27, 1994. A fact sheet, condensed from the Proposed Plan, wassent to everyone on the March AFB mailing list, which includes Restoration Advisory Board (RAB)members. An OUl RJIFS subcommittee, formed by the RAB, provided oral comments to the RAB at itsApril 26, 1994 meeting.
C. Summary of Public Comments Received During Public Comment Period and AgencyResponses
A public comment period was held from April 28 to May 28, 1994. In addition, a public meeting washeld on May 12, 1994 at 7 p.m. at the Best Western Image Suites in Moreno Valley. Representatives ofthe U.S. Air Force, USEPA, Department of Toxic Substances Control, and California Regional WaterQuality Control Board, Santa Ma, attended the public meeting to address any questions about the RI/FSand Proposed Plan.
The major comments expressed during the meeting held on May 12, 1994 are transcribed below:
• Remedial Alternative Preferences
1. Question: Why were some more expensive technologies picked over cheaper ones?
March AFB Response: Time: For example: Natural attenuation at Panero would take 200 years.We want to get the base cleaned up fast. Also, we prefer a sure-fire method instead of lesserknown methods. The Air Force wants to get the cleanup done as quickly as possible, and to theirstandards. They will pay extra for this.
2. Question: Why are you not moving sites 10 and 15 to Site 4?
March AFB i?esponse: Air Force policy is to not move the problem somewhere else. To take careof it permanently and not put it in the ground where it might cause us problems somewhere else.
3. Question: For the OU1 plume (Site 4), the air stripping with carbon adsorption was moreexpensive, but you picked the liquid-phase granular activated carbon. Was that because it is beingused in the GETS (Groundwater Extraction and Treatment System)?
March AFB Response: Yes, the GETS is already in place so we are just going to supplement that.
4. Question: What about the innovative technologies? What is happening with that?
•
544 122March AFB response: The IT (Innovative Technology) system needs to be relocated because the• results of our soil vaporization studies show that the contamination at Site 2 have migratedthrough the vadose zone and have now gone southerly. We think we know where they have gone,and we are doing some drilling to find out. The system has been temporarily shut off. The UVBis up and running and. has been working well, and the program has been extended for anotheryeas. Earth Tech will be putting in two soil vapor extraction systems to work on the vadose zoneremoval of TCEs. We will be putting in three Steamist systems to monitor the progress of those,and they will also monitor the effectiveness of the UVB. Those systems will remain in operationas long as there is a contaminant level that might degrade the groundwater.
5. Question: How much carbon is being used in the GAC systems, and would it be more costeffective to use thermal oxidation?
March AFB Response: The carbon is reused. We have elected to use the Purus system becauseit reciróulates the carbon and you never have to reinstall the carbon for a 20 year period. In theGETS system, we install new carbon once a year, and we put in 20,000 pounds. Also, in thesetypes of systems there is always 10 percent left over that has hazardous material in it that we cannot rejuvenate. The Purus system does not do that.
6. Question: The minutes of the March 16 meeting, in describing the presentation on the OUIProposed Plan, say that there will be no further action on some sites. Could there be anexplanation in the minutes of why those sites will have no further action?
March AFB Response: We could attach a summary to the minutes.
Remedial Alternative Safety Concerns
Question: What is the plan for Site 4 dust control, where the cap will be installed over thelandfill?
March AFB Response: We will be planting natural plants that do not need much water, that willlive with the existing rainfall we have. We do not want to put in a sprinkler system because thatjust introduces water into the landfill. The cap will be a modified cap under RCRA Title XV,which will have geosynthetic fibers in it, so that even if you penetrate the soil, you can notpuncture it. It will have one foot to 18 inches of soil on top. The life of the cap is a minimumof 20 years.
2. Question: Are Earthquake faults a problem if you are going to be burying materials?
March AFB Response: No. We have existing landfills that have been there since 1940. We arenot proposing to bury anything more in the ground. We may be moving some contaminatedmaterial into existing ones, and we have two alternatives. It is cheaper to move the contaminatedmaterial than to oxidize it. We would prefer to dispose of it permanently (by oxidation), but ifwe do not have the funding at the appropriate time to do that, we need a fallback position, whichis to move 2,000 yards of material that are similar to the landfill into the existing landfill and capit. We are still doing geophysical studies to see if the faults we have found on base have moved
A
544 123• structurally any number of inches in the last 10,000 years.
EPA Response: There are no active faults on base.
3. Question: Regarding bioventing - is it hard to control the air flow; will it push contaminants inother directions?
March AFB Response: We are only talking about 30 pounds of air pressure, which is nothing.We will have systems installed at Site 34 also, to monitor the amount of vadose cleanup we aregetting. We do not expect large amounts of movement of contaminants in the vadose zone, thisis an innovative system that has never been used at March APR It is a method of permanentmonitoring to determine vadose zone cleanup, and monitoring of groundwater cleanup. Anadvantage of the system is that it monitors at discrete depths, so we can always tell if there ismigration to other areas, and if there is, there will be time to put in other methods of controllingit.
CostlFunding Issues
1. Question: What happens to the long-term monitoring if funds are cut off?
March AFB Response: Our budget is figured until the year 1998, at which time we will be inprimarily operation and maintenance (O&M), which will remain constant until the year 2010, atwhich time the O&M dollars will decrease. The O&M costs are only about $1.2 million per year,for all the 6 to 8 systems on base that will be up running.
EPA Response: The EPA has the continual responsibility to make sure the Air Force does themonitoring.
Public Participation Process
1. Question: How do we get that information (on monitoring) - for example, in 15 years from now?
March AFB Response: The information will always be available (even in 15 years) in therepositories located at the RWQCB, the base library, and the Moreno Valley library. The EPAcan also be contacted as to when the last monitoring was conducted.
March AFB General Comment: We would like people to come to the public meeting on the ProposedPlan and ask questions like you are now. The questions and answers will be written up and attached tothe Plan, so it will become a matter of permanent record. We will have court stenographer at thatmeeting taking down the entire proceedings.
Enforcement
1. Question: In regard to the annual reviews, how stringent is EPA in following these annualreviews; how frequently do they monitor?
EPA Response: This is really two questions. The first is how often the monitoring is done, and
AA
544 124John (Sabol) is saying that this will be on the order of once a year. Second, under• CERCLA/Superfund legislation, the EPA is required to do a 5-year review with the lead agency(in this case the DOD) to see how well the corrective action is working. These reviews arestatutory requirements.
Part II - Comprehensive Response to Specific Legal and Technical Questions
Reports by the Engineering Evaluation/Cost Analysis (BE/CA) Review Subcommittee
Site 2
1. Comment by Ms Helen Grinyer: On page 6, paragraph 3, "munitions" are mentioned.
March AFB Response: The inclusion of the word "munitions" is a mistake. There were nomunitions at Site 2 which was a waste oil/paints/solvents site. The munitions are associated withSite 25 A and B.
2. Comment by Mi Helen Grinyer: There's a mistake in English, too "With on' should be "Withonly" (paragraph 7). Referring to page 14...when was the last survey done?
March AFB Response: The last survey was done about 4 weeks ago, although this was notmentioned in the EE/CA. There might have been a mis-communication between the contractorwho did the report and the contractor who did the survey. The BE/CA will be corrected toinclude the last survey.
3. Comment by Ms. Helen Grinyer: In Figures 2-4 and 2-5, magnetic surveys, the gas line doesn'tshow up although it is shown in Figure 2-7.
March AFB Response: If these Figures were the magnetometer surveys, the gas line should havebeen detected and be included in the Figures. This will be reviewed and corrected.
4. Question: Flow was the benzene concentration determined?
March AFB Response: There is a series of EPA protocols. that are used to determine thecontaminants. They should have listed all the EPA protocols and what types of contaminants thatthey find.
Comment: The figures given don't reflect the maximum amount of benzene allowed as shownon the tables.
March AFB Response: The maximum differs between the state and federal.
5. Question: If you're going to be digging up dirt and moving it from Site 2 to Site 4, how will youkeep the contaminants from being airblown during the process?
March AFB Response: The contamination is only 5 parts per billion, which is a low level. Ifthere is a problem, a foam spray is available to spray on the dirt to keep airborne emissions down.
• A-S
544 125
The Air Force will be requiring the contractors to comply with all local, state, and federalregulations to prevent and airborne emissions. The exact methods to be used are left up to thecontractors.
Site 17
1. Comment by Mr. Barry McClellan: I've had most of my questions answered in the report andfrom touring the site previously. In the swimming pool, 90% is backfill and 10% is metallic.The recommended action is to excavate and remove it. Everything seems to be done accordingto standard protocol. You've tested the soil around the pool, and afterwards you will be coringto test the soil under the pool.
March AFB Response: We'll remove the pool entirely. The concrete will be taken out, the soilat the bottom will be sampled to determine the degree of contamination, and if there iscontamination then wee will develop a system that will work.
D. Remaining Concerns
None
.
A6
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544 126
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it Pi
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t.vI'I
vI A
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F C
OM
IQIA
NU
E W
I-u.
n U
uwiic
.ti.—
si'u
ciu•
iu A
ltAR
s
Con
tam
inan
t of C
once
rn
Gro
undw
ater
-
--
Sou
rce
App
licab
le,
Rel
evan
t and
A
ppro
pria
te,
or T
o-be
- co
nsid
ered
(TU
C)
- A
ltern
ativ
e 2G
Li
mite
d A
ctio
n
Alte
rnat
ive
3G
Dire
ct T
reat
men
t w
ith
Liqu
id P
hase
GA
C
Alte
rnat
ive
4G
US
' and
hem
icnl
O
xida
tion
Alte
rnat
ive
6G
Air
Str
ippi
ng w
ith
Car
bon
Ads
orpt
ion
Bis
(2-e
thyl
hexy
l)pht
hata
te
(1)
Rel
evan
t an
d A
ppro
pria
te
4 ig
IL C
alifo
rnia
Cle
anup
S
tand
ard
will
no
t be
ac
hiev
ed
4 gg
IL C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
4 1s
gIL
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
4 M
gIL
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
Ben
zene
(I
) R
elev
ant
and
App
ropr
iate
I
ggfL
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill
not
be
achi
eved
I gI
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
I 1
sg(L
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
I g(
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
Car
bon
Tet
rach
torjd
e (1
) R
elev
ant
and
App
ropr
iate
0.
5 1i
g/L
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill
not
be
achi
eved
0.5
gsgI
L C
alifo
rnia
Cle
anup
S
tand
ard
wilt
be
achi
eved
0.
5 gI
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
0.
5 M
gIL C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
Vin
yl C
hlor
ide
(1)
Rel
evan
t an
d A
ppro
pria
te
0.5
pg/L
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ilt
not
be
achi
eved
0.5 gf
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
0.
5 tg
(L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
0.
5 .g
(L Ca
lifor
nia
Cle
anup
S
tand
ard
wilt
be
achi
eved
Tric
hlor
oeth
ene
(TC
E)
(1),
(2)
R
elev
ant
and
App
ropr
iate
S
pg
/L
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ill n
ot b
e ac
hiev
ed
5 pg
/L
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
5 1&
glL
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
S
gg(L
C
alifo
rnia
an
d F
eder
al
Cle
anup
Sta
ndar
d w
ill b
e ac
hiev
ed
1,1-
Dic
hlor
oeth
ene
(1)
Rel
evan
t an
d A
ppro
pria
te
6 pg
fL C
alifo
rnia
Cle
anup
S
tand
ard
will
no
t be
ac
hiev
ed
6 pg
fL C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
6
Mg/
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
6
tgIL
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
cis-
l,2-D
ichl
oroe
then
e (1
) R
elev
ant
and
App
ropr
iate
6
zg/L
Cal
iforn
ia C
lean
op
Sta
ndar
d w
ilt
nol
be
achi
eved
6 pg
JL
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
6 rig
/L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
6
1tgf
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
Tet
rach
loro
ethe
ne
(PC
E)
(I),
(2)
Rel
evan
t an
d A
ppro
pria
te
5 pg
/L
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ill n
ot b
e ac
hiev
ed
5 pg
/L
Cal
iforn
ia
and
Fed
eral
C
lean
up S
tand
ard
witl
be
achi
eved
5 *g
1L
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
5 p4
IL
Cal
iforn
ia
and
Fed
eral
C
lean
up
Sta
ndar
d w
ilt b
e ac
hiev
ed
1,2-
Dic
hlor
oeth
ane
(I)
Rel
evan
t an
d A
ppro
pria
te
0.5
pg/L
Cal
iforn
ia C
lean
up
Sta
ndar
d w
ill
not
be
achi
eved
0.5
gzg/
L C
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
0.
5 jz
g/L
Cal
iforn
ia C
tean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
0.5
g/LC
alifo
rnia
Cle
anup
S
tand
ard
will
be
achi
eved
Met
hyte
ne C
hlor
ide
. (2
) R
elev
ant a
nd A
ppro
pria
te
5 pg
fL
Fed
eral
C
lean
up
Sta
ndar
d w
ilt
not
be
achi
eved
5 M
g/L
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
5 pg
/L
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
5 &
g(L
Fed
eral
C
lean
up
Sta
ndar
d w
ill b
e ac
hiev
ed
Key
: pg
IL
=
Mic
rogr
am p
er li
ter
GA
C
Gra
nula
r A
ctiv
ated
Car
bon
UV
=
U
ltrav
iole
t A
RA
R
=
App
licab
le o
r Rel
evan
t and
App
ropr
iate
Req
uire
men
t
01
(I)
Titl
e 22
, C
alifo
rnia
Cod
e of
Reg
ulat
ions
(C
CR
), D
ivis
ion
4. C
hapt
er 1
5, A
rtic
le 5
.5,
Sec
tion
6444
4.5,
Max
imum
Con
tam
inan
t Lev
els fo
r Org
anic
Che
mic
a's.
(2
) 40
Cod
e oi
Fed
erni
Reg
ulat
ions
(C
FR
) 14
1.61
, M
axim
um C
onta
min
ant
Leve
ls fo
r Org
anic
Che
mic
als.
(3
) 40
Cod
e of
Fed
eral
Reg
ulat
ions
(C
FR
) 14
1.11
, M
axim
um C
onta
min
ant
Leve
ls fo
r Ino
rgan
ic C
hem
ical
s.
c-i
'1'.t
i;i..i
('—
2
Slit
410U
1 C
Iol;N
nv,v
ttR P
I.1M
E
CO
MPA
RA
TIV
E
AN
:uxs
Is O
F C
mIP
I.I.
tNcE
wrr
u L
oc.v
noN
—Sr
i:CW
IC
AM
) A
C'n
( )N
—SP
EC
IFIC
A
RA
Rs
Req
uire
men
t So
urce
A
pplic
able
Rel
evan
t an
d A
ppro
pria
te, o
r T
o-be
-con
side
red
(TB
C)
Alte
rnat
ive 2
G
Lim
ited A
ctio
n
Mte
rnat
ive 3
G
Dir
ect T
reat
men
t with
Liq
uid
Phas
e G
AC
A
ltern
ativ
e 4G
U
S' a
nd C
hem
ical
Oxi
datio
n
.4lte
nmtiv
e 6G
A
ir S
trip
ping
with
Car
bon
Ads
orpt
ion
LOC
AT
ION
-SP
EC
IFIC
Cle
an W
ater
Act
S
ectio
n 40
4(b)
(l)
40 C
ER
Sec
tion
230.
10
App
licab
le
NA
; no
dis
char
ge w
ill
occu
r,
Will
mee
t AR
AR
, be
caus
e no
dis
char
ge t
o w
etla
nds
is e
xpec
ted.
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
3G.
Pro
tect
ion o
f W
etla
nds
Exe
cutiv
e O
rder
1199
0 40
CF
R 6
, A
ppen
dix
A
App
licab
le
NA
; no
dis
char
ge w
ill
occu
r,
Will
mee
t AR
AR
, bec
ause
no
disc
harg
e to
w
etla
nds
is e
xpec
ted.
See
Alte
rnat
ive
30.
See
Alte
rnat
ive
3G.
RC
RA
Loc
atio
n S
tand
ards
T
itle
22 C
CR
, C
hapt
er
14,
Sec
tion
6626
4.18
App
licab
le
NA
A
RA
R w
ill h
e m
et.
Fac
ility
will
not
be
cons
tnic
ted
with
in
20
feet
of
an
ea
rthq
uake
fau
lt or
w
ithin
a
100-
year
flo
odpl
ain.
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
3G.
AC
TIO
N-S
PE
CIF
IC
.
Cal
iforn
ia
Haz
ardo
us W
aste
R
ules
:
• S
tand
ards
App
licab
le to
G
ener
ator
s of
H
azar
dous
W
aste
Titl
e 22
CC
R,
Div
isio
n 4.
5,
Cha
pter
12
, S
ectio
n 66
262
et s
eq.
App
licab
le
NA
; no
was
tes
are
gene
rate
d.
AR
AR
w
ill
be
met
; sp
ent
carb
on,
cutti
ngs,
an
d ot
her
resi
dues
w
ill
be
hand
led
and
disp
osed
of
as
haza
rdou
s w
aste
s if
they
m
eet
Cal
iforn
ia
clas
sific
atio
n cr
iteria
. A
ccum
ulat
ion a
nd
stor
age
requ
irem
ents
w
ill b
e m
et.
NA
; no
was
tes
are
gene
rate
d.
.
See
Alte
rnat
ive
3G.
C-2
01
Co
.—
'I'.%
IILE
C2
Sun:
410
U1
GI
wN
I.w:v
rEu
PLI
ME
C
(.)\
1I'A
ItA
II%
'E A
NA
I\SIS
01"
110
%IP
LI,%
NC
E W
I'II(
L()
CA
TI(
)N—
SP
EC
IflC
tN
I) A
CIR
)N—
SPE
('II'J
U
AR
1\R
s
(iiiI
iiiui
t'cI
Req
uire
men
t So
urce
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te, o
r T
o-be
-con
side
red
(mc)
Alte
rnat
ive 2
G
Lim
itS A
ctio
n
Alte
rnat
ive 3
0 D
irec
t Tre
atm
ent w
ith L
iqui
d Ph
ase
GA
C
Alte
rnat
ive 4
G
UV
and
Che
mic
al O
xida
tion
Alte
rnat
ive 6
0 A
ir S
trip
ping
with
Car
bon
Ads
orpt
ion
Acr
IoN
-SrE
cmc
(Con
tinue
d)
Cal
iforn
ia
Haz
ardo
us W
aste
R
ule:
• S
tand
ards
for
Ope
rato
rs o
f H
azar
dous
W
aste
Tra
nsfe
r,
Tre
atm
ent
&
Dis
posa
l F
acili
ties:
Tan
ks
Mis
cella
neou
s U
nits
Titl
e 22
CC
R,
Div
isio
n 4.
5, C
hpt
14,
Sec
tion
6624
.190
- S
ectio
n 66
24.1
99
Rel
evan
t an
d
App
ropr
iate
N
A;
no w
aste
s
gene
rate
d.
Will
m
eet
AR
AR
; re
leva
nt
and
appr
opria
te s
ubst
antiv
e re
quire
men
ts w
ill
be
inco
rpor
ated
in
to
cons
truc
tion
and
desi
gnof
tank
suse
dtos
tore
gtou
ndw
ater
.
Sam
e as
Alte
rnat
ive
3G.
Sam
e as
Alte
rnat
ive
3G.
Titl
e 22
CC
R,
Div
isio
n 4.
5 C
bpt
14,
Sec
tions
66
264.
600-
66
264.
603
Rel
evan
t an
d
App
ropr
iate
N
A;
no w
aste
s
gene
rate
d.
NA
; ca
rbon
uni
ts an
d as
soci
ated
tank
s ar
e
regu
late
d un
der R
CR
A ta
nk r
egul
atio
ns.
.
NA
; as
soci
ated
tan
ks a
re
regu
late
d un
der R
CR
A ta
nk
regu
latio
ns.
The
uni
t will
be
loca
ted,
desi
gned
, co
nstr
ucte
d,
oper
ated
, m
aint
aine
d,
and
clos
ed i
n a
man
ner
that
en
sure
s pr
otec
tion of
hum
an
heal
th a
nd t
he e
nviro
nmen
t
(e.g
., pr
even
tion of
rele
ases
) an
d w
ill th
ereb
y co
mpl
y w
ith
the
rele
vant
and
appr
opria
te
requ
irem
ents
fo
r m
isce
llane
ous
trea
tmen
t un
its.
Was
te C
lass
ifica
tion
and
Man
agem
ent
Tid
e 23
, D
ivis
ion
3, C
hapt
er
IS.
Art
icle
2 S
ectio
n 25
22
App
licab
le
NA
; no
was
tes
are
gene
rate
d
AR
AR
w
ill
be
met
; sp
ent
carb
on,
cutti
ngs,
an
d ot
her
resi
due,
if
not
haza
rdou
s w
aste
, w
ill b
e di
spos
ed o
f as
desi
gnat
ed w
aste
NA
; no
was
tes
are
gene
rate
d S
ee A
ltern
ativ
e 30
.
01 a a a 0
C-3
____
____
____
____
_w
.___
rI
.tBI
('-2
Sin:
4/0
1)1
Gno
uNus
vnI]
4 P
inw
C
O\I
I'AJt
VI'I
'E A
NA
I.Y
S1S
el' (
'o1v
I.nN
tt W
ITH
Loc
'gi'I
oN_.
Spu
:wJc
AN
I) A
c IO
N—
SPE
CIF
IC A
RA
Rs
('1)1
11 m
uLti
Req
uire
men
t So
urce
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te, o
r to
-be-
cons
ider
ed
f1'B
C)
Alte
rnat
ive Z
G
Lim
ited A
ctio
n
Alte
rnat
ive 3
G
Dir
ect T
reat
men
t with
Liq
uid
Phas
e G
AC
A
ltern
ativ
e 4G
C
V a
nd C
hem
ical
Oxi
datio
n A
ltern
ativ
e 4G
U
V a
nd C
hem
ical
O
xida
tion
AC
n0N
-SpE
cmc
(Con
tinue
d)
Sou
th C
oast
Air
Qua
lity
Man
agem
ent
Dis
tric
t R
ules
&
Reg
ulat
ions
- New
S
ourc
e R
evie
w of
C
arci
noge
nic
Air
Con
tam
inan
ts
Pro
hibi
tory
Rul
es -
R
ule
1401
A
pplic
able
N
A;
no e
mis
sion
s.
Will
mee
t A
RA
R; a
dditi
onal
con
trol
s w
ill
not
be
nece
ssar
y be
caus
e ris
k fr
om
emis
sion
s w
ill b
e be
low
lx 10
ris
k le
vel
stat
ed in
the
rule
.
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
3G.
New
Sou
rce
Rev
iew
of A
ir C
onta
min
ants
Reg
ulat
ion
XLI
I. R
ule
1303
A
pplic
able
N
A;
no e
mis
sion
s.
Will
m
eet
ALt
AR
. D
ue
to
low
co
ncen
trat
ions
of V
OC
s in
gro
undw
ater
, ai
r em
issi
ons
with
out
cont
rols
w
ill b
e be
low
the
1 po
und/
day
limit
abov
e w
hich
B
AC
T
is
requ
ired
to
limit
emis
sion
s in
crea
ses
(SC
AQ
MD
co
nsid
ers
an
emis
sion
s in
crea
se
to
be
at
leas
t I
poun
d/da
y).
Non
ethe
less
, B
AC
T w
ill b
e us
ed fo
r all
alte
rnat
ives
.
See
Alte
rnat
ive
30.
-
See
Alte
rnat
ive
3G.
-
Sta
tem
ent o
f Pol
icy
with
Res
pect
to
Mai
ntai
ning
Hig
h Q
ualit
y of
Wat
ers
in C
alifo
rnia
SW
CB
Res
olut
ion
Num
ber 6
8-16
A
pplic
able
N
A;
no d
isch
arge
will
oc
cur,
T
reat
ed g
roun
dwat
erw
ill be
dis
char
ged
to
the
base
was
tew
ater
tre
atm
ent
plan
t, to
the
gr
ound
su
rfac
e or
re
inje
cted
to
th
e aq
uife
r.
Dis
char
ge t
o th
e gr
ound
surf
ace
will
no
degr
ade
wat
er q
ualit
y (s
ee N
PD
ES
re
quire
men
ts b
elow
).
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
3G.
C-4
CJ1
S
S
Con
tinue
d
Req
uire
men
t So
urce
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te, o
r T
o-be
- co
ns id
ered
(TB
C)
Alte
rnat
ive 2
0 L
imite
d Act
ion
Alte
rnat
ive 3
0 D
irec
t Tre
atm
ent w
ith L
iqm
d Ph
ase
GA
C
Alte
rnat
ive
40
LW
and
Che
mic
al O
xida
tion
Alte
rnat
ive 6
0 A
ir S
trip
ping
with
Car
bon
Ads
orpt
ion
AC
TIO
N-S
PEC
IFIC
(C
ontin
ued)
Nat
iona
l Po
lluta
nt
Dis
char
ge
Elim
inat
ion
Syst
em
(NPD
ES)
Pro
gram
.
40 C
ER
Par
ts 1
22-
125;
NPD
ES
Perm
it N
o.
CA
G9I
800I
for
Mar
ch A
FB
Gro
undw
ater
Cle
anup
Pro
ject
(M
arch
199
5)
App
licab
le
NA
; no
dis
char
ge w
ill
occu
r,
Will
m
eet
subs
tant
ive
requ
irem
ents
of
re
gula
tion
thro
ugh
com
plia
nce
with
disc
harg
e lim
its f
or in
orga
nics
and
tot
al
diss
olve
d so
lids
foun
d in
pe
nnit.
M
axim
um
Dai
ly
Lim
its
for
regu
late
d co
nstit
uent
s are
in
gzg/
L a
re:
Tot
al
Petr
oleu
m
Hyd
roca
rbon
s 10
0;
benz
ene
1.0
; to
luen
e 10
; xy
lene
s 10
:
ethy
lben
zene
10;
chl
orof
orm
5;
met
hyl
ethy
l ket
one
10;
tetr
achl
oroe
then
e (P
CE
) 5;
m
ethy
l is
obut
yl
keto
ne
10;
lI-
dich
loro
ethy
lene
6;
tr
ichl
oroe
thyl
ene
(TC
E) 5
; dic
hlor
obro
mom
etha
ne 5
; 1,
1,1-
tr
ichl
oroe
than
e (T
CA
) 5;
1,
2-
dich
loro
ethy
lene
10;
1,1
-dic
hlor
etha
ne 5
; ca
rbon
tet
rach
lori
de 0
.5; n
apht
hale
ne to
; M
axim
um
Dai
ly
Lim
its
for
regu
late
d co
nstit
uent
s are
in
mg/
I:
chro
miu
m 0
.052
; to
tal
lead
0.
05:
tota
l re
sidu
al c
hlor
ine'
0.1
; su
spen
ded
solid
s 75
; su
lfid
es
0.4;
cad
miu
m 0
.01;
zin
c 5
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
30.
rIIII
I; ('—
2
Sill-
: 4/
0151
GR
oi;N
nw:v
rnt
PI.n
IE
CO
'1P
.tI4A
TiV
E
AN
AIX
SI.S
01:
CO
MP
LIA
NC
E W
hit
J.O
CA
TIO
N—
SP
EC
IIIC
,%N
l) A
CT
ION
—S
PE
CIF
IC
AR
AR
s
Key
: G
AC
=
G
ranu
lar
Act
ivat
ed C
arbo
n SC
AQ
MD
=
So
uth
Coa
st A
ir Q
ualit
y M
anag
emen
t D
istr
ict
RC
RA
=
R
esou
rce
Con
serv
atio
n an
d R
ecov
ery
Act
M
CL
=
M
axim
um C
onta
min
ant
Lev
el
UIC
=
U
nder
grou
nd I
njec
tion
Con
trol
O
SWE
R
=
Off
ice
of S
olid
Was
te a
nd E
mer
genc
y R
espo
nse
AR
AR
=
A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t B
AC
T
=
Bes
t Ava
ilabl
e C
ontr
ol T
echn
olog
y N
A
=
Not
an
App
licab
le o
r Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
VO
C
=
Vol
atile
Org
anic
Com
poun
d pg
/L
=
Mic
rogr
ams
per l
iter
SWC
B
=
Stat
e W
ater
Con
trol
Boa
rd
NA
-
Not
appl
icab
le
C/I
C-5
Ben
zene
.
Key
: A
RA
R
GA
C
. .
Con
tam
inan
t or C
once
rn In
-
Gro
undw
ater
•
Sow
ee
App
licab
le, R
elev
ant a
nd
App
ropr
iate
, or
To-
be-
cons
ider
ed (
FEC
)
- A
ltern
ativ
e 2G
L
imite
d Act
ion
Alte
rnat
ives
3G
/SG
I
Alte
rnat
ives
7G
/5G
D
irect
Tre
atm
ent w
ith
Air
Str
ippi
ng with
Li
quid
Pha
se GA
C(T
otal
C
atal
ytic
Oxl
datlu
nlT
ctat
Fl
uids
Rec
over
y Fl
uids
Rec
over
y L
Alte
rnat
ives
SG
/5G
A
ir St
ripp
ing
with
Pur
us
PL&
DR
W"
Syst
emllo
ta%
fl
uids
Rec
over
y
Met
hyle
ne C
hlor
ide
(2)
Rel
evan
t an
d A
ppro
pria
te
5 pg
/L
Fed
eral
C
lean
up
Stan
dard
w
ill
not
be
achi
eved
5 pg
/L
Fed
eral
C
lean
up
Stan
dard
will
be
achi
eved
S
pg/L
F
eder
al
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
S ig
/L
Fede
ral
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
(I)
Rel
evan
t an
d A
ppro
pria
te
I pg
/L C
alif
orni
a C
lean
up
Stan
dard
w
ill
not
be
achi
eved
1 pg
/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
1 pg
/L C
alif
orni
a C
lean
up
Stan
dard
will
be
achi
eved
1
pg/L
C
alif
orni
a C
lean
up
Stan
dard
will
be
achi
eved
(2)
Rel
evan
t an
d A
ppro
pria
te
150
pg/L
Cal
ifor
nia C
lean
up
Stan
dard
w
ill
not
be
achi
eved
150
pg/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
150
pg/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ilt b
e ac
hiev
ed
150
pg/L
Cal
ifor
nia C
lean
up
Stan
dard
wilt
be a
chie
ved
Eth
ylbe
nten
e (I
) R
elev
ant
and
App
ropr
iate
68
0 1z
g/L
Cal
ifor
nia C
lean
up
Stan
dard
w
ill
not
be
achi
eved
680
pg/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
680 p
g/I.
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
680 p
g/L
Cal
ifor
nia C
lean
up
Stan
dard
will
be
achi
eved
Xyl
enes
, T
otal
(I
) R
elev
ant a
nd A
ppro
pria
te
1750
pg
/L
Cal
ifor
nia
Cle
anup
Sta
ndar
d w
ill n
ot be
ac
hiev
ed
1750
pg
/L
Cal
ifor
nia
Cle
anup
St
anda
rd
will
be
ac
hiev
ed
1750
pg
/L
Cal
ifor
nia
Cle
anup
St
anda
rd
will
be
ac
hiev
ed
1750
pg
/L
Cal
ifor
nia
Cle
anup
St
anda
rd
will
be
ac
hiev
ed
Tol
uene
App
licab
le o
r Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
Gra
nula
r A
ctiv
ated
Car
bon
Mic
rogr
ams
per l
iter
(I)
Titl
e 22
, Cal
ifor
nia
Cod
e of
Reg
ulat
ions
(C
CR
), D
ivis
ion
4, C
hapt
er 1
5, A
rtic
le 5
.5, S
ectio
n 64
444.
5, M
axim
um C
onta
min
ant
Lev
els
for O
rgan
ic C
hem
ical
s.
(2)
40 C
ode o
f Fed
eral
Reg
ulat
ions
(C
FR)
141.
61,
Max
imum
Con
tam
inan
t L
evel
s fo
r Org
anic
Che
mic
als.
I ml i
C
—3
Sii'i
: 18
Glt(
)t'N
I)%
VA
TE
I( P
I.t)
JE
C't)
\II'A
IZA
TIV
E A
NA
LY
SIS
OF
CO
MPL
IAN
CE
W
ITh
CH
EM
IUA
LSP
EC
IFII
' A
RA
Rs
C-6
cn a C
o
'I'A
Ii'I.
' C
-4
SIT
E 1
8 G
ltorN
Inv.
vrE
R P
inw
C
(ThI
PA
RA
TI'V
E A
NA
I1'V
SIS
01:
Co\
1l'iL
tNc1
WI'I
'II I
.AK
:AII
ON
—SI
'EcI
I'Ic
AN
I) A
c:T
ION
—SP
EC
WR
.' AltA
Rs
Req
uire
men
t S
ourc
e A
pplic
able
, R
elev
ant a
nd
App
ropr
iate
, or
To-
be-
cons
ider
ed
(TB
C)
LOC
AT
ION
-SP
EC
IFIC
Alte
rnat
ive 2
G
Lim
ited
Act
ion
Alte
rnat
ive
3G/S
G
Liqu
id P
hase
GA
C A
dsor
ptio
n/T
otal
F
luid
s R
ecov
ery
Alte
rnat
ives
7G/S
G
Air
Stri
ppin
g with
Cat
alyt
ic
Oxi
datio
n/T
otal
Flui
ds
Rec
over
y
Alte
rnat
ives
8G/S
G
Air
Str
ippi
ng w
ith P
urus
P
AD
RE
" Sys
tem
/Tot
al
flui
ds
Rec
over
y
TSD
F L
ocat
ion
Sta
ndan
is
Titl
e 22
CC
R,
Cha
pter
14
. S
ectio
n 66
264.
18
App
licab
le
NA
Fa
cilit
y w
ill n
ot b
e co
nstr
ucte
d w
ithin
20
0 fe
et o
f an
ear
thqu
ake
faul
t an
d, if
site
dwith
inth
e lO
O-y
earf
lood
plai
n,w
ill
be d
esig
ned,
con
stru
cted
, op
erat
ed,
and
mai
ntai
ned
to p
reve
nt w
asho
ut of
wast
e.
See
Alte
rnat
ive
3G/5
G.
See
Alte
rnat
ive
30/5
G.
AC
rIO
N-S
PE
CIF
tC
Cal
iforn
ia H
azar
dous
W
aste
Rul
es:
• S
tand
ards
App
licab
le
to G
ener
ator
s of
H
azar
dous
W
aste
Titl
e 22
CC
R,
Div
isio
n 4.
5,
Cha
pter
12
, S
ectio
n 66
262
et
seq.
App
licab
le
NA
; no
was
tes.
S
pent
ca
rbon
an
d re
sidu
es
will
be
ha
ndle
d an
d di
spos
ed o
f as
haza
rdou
s w
aste
s if
they
m
eet
clas
sific
atio
n cr
iteria
.
Res
idue
s w
ill
be
hand
led
and
disp
osed
of a
s ha
zard
ous
was
tes if
they
mee
t cl
assi
ficat
ion
crite
ria.
See
Alte
rnat
ive
7G15
G.
• S
tand
ards
for
O
pera
tors
of
Haz
ardo
us
Was
te
Tra
nsfe
r, T
reat
men
t &
Dis
posa
l F
acili
ties:
Tan
ks
Mis
cella
neou
s U
nits
Titl
e 22
CC
R,
Div
isio
n 4.
5,
Chp
t 14,
Sec
tion
6624
.190
-
Sec
tion
6624
.199
Rel
evan
t an
d A
ppro
pria
te
NA
; no
was
tes.
R
elev
ant
and
appr
opria
te s
ubst
antiv
e re
quire
men
ts w
ill b
e in
corp
orat
ed
into
co
nstr
uctio
n an
d de
sign
of t
anks
.
See
Alte
rnat
ive
3G/S
G.
.
See
Alte
rnat
ive
3G/5
G.
Titl
e 22
CC
L D
ivis
ion
4.5,
C
hap
14,
Sec
tions
66
264.
600
- 66
264.
603
Rel
evan
t an
d
App
ropr
iate
N
A;
no u
nits
. T
he
unit
will
be
lo
cate
d,
desi
gned
, co
nstr
ucte
d,
oper
ated
, m
aint
aine
d,
and
clos
ed
in
a m
anne
r th
at
ensu
res
prot
ectio
n of
hu
man
hea
lth
and
the
envi
ronm
ent
(e.g
. pr
even
tion
of
rele
ases
) and
will
the
reby
co
mpl
y w
ith
rele
vant
an
d ap
prop
riate
re
quire
men
ts
for m
isce
llane
ous
units
.
The
uni
t will
be
loca
ted,
des
igne
d,
cons
truc
ted,
ope
rate
d, m
aint
aine
d,
and
clos
ed in
a
man
ner
that
en
sure
s pr
otec
tion o
f hum
an h
ealth
an
d th
e en
viro
nmen
t (e
.g.
prev
entio
n of
rel
ease
s)
and
will
th
ereb
y co
mpl
y w
ith r
elev
ant
and
appr
opria
te
requ
irem
ents
fo
r m
isce
llane
ous
units
.
See
Alte
rnat
ive
7G/5
G.
01
a a a a
C-7
TiC
-4
Sul
i: 18
G
Rol
.ND
AT
ER
PLU
ME
CO
1I'A
RA
TIV
E A
NA
I.SIS
OF
C()
\1P
IIAN
CF
. %%
ifiI
1.O
cAI1
ON
SP
EC
EF
'Ic A
ND
:V
TIO
N'S
PE
CIF
IC 4R
rtitS
(?
oiiti
iiut'd
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant a
nd
App
ropr
iate
, or
To-
be-
cons
ider
ed
(TB
C)
Alte
rnat
ive 2
G
Lim
ited A
ctio
n
Alte
rnat
ive
3G/S
G
Liq
uid
Phas
e G
AC
Ads
orpt
ion/
Tot
al
Flui
ds R
ecov
ery
Alte
rnat
ives
7G/S
G
Air
Str
ippi
ng w
ith C
atal
ytic
O
xida
tion/
Tot
al fl
uids
R
ecov
ery
Alte
rnat
ives
8G/S
G
Mr S
trip
ping
with
Pun
is
PAI)
RE
' Sys
tem
/Tot
al Fl
uids
Rec
over
y
Act
ion-
Spec
ific
(C
ontin
ued)
W
aste
Cla
ssif
icat
ion
and
Man
agem
ent
Tid
e 23
, D
ivis
ion
3, C
hapt
er 15
, A
rtic
le 2
, Sec
tion
2522
App
licab
le
NA
; N
o w
aste
Sp
ent
carb
on
and
resi
dues
, if
non
- ha
zard
ous
was
te, w
ill b
e di
spos
ed o
f as
desi
gnat
ed w
aste
Res
idue
s w
ill
be h
andl
ed
and
disp
osed
of a
s des
igna
ted
was
te,
if
non-
haza
rdou
s w
aste
See
70/S
C
Sout
h C
oast
Air
Qua
lity
Man
agem
ent
Dis
tric
t •R
ules
Reg
ulat
ions
New
So
urce
Rev
iew
of
Car
cino
geni
c A
ir
Con
tam
inan
ts
Proh
ibito
ry R
ules
- R
ule
1401
A
pplic
able
N
A; n
o em
issi
ons,
N
A: n
o em
issi
ons.
C
ontr
ols
will
no
t be
ne
cess
ary
beca
use
risk
fro
m e
mis
sion
s w
ill
be b
elow
I X
l06
risk
lev
el s
tate
d in
the
nile
.
See
Alte
rnat
ive
7015
0.
New
Sou
rce
Rev
iew
of
Air
Con
tam
inan
ts
Reg
ulat
ion
XII
I,
Rul
e 13
03
App
licab
le
NA
: no
emis
sion
s.
NA
; no
em
issi
ons.
D
ue
to
low
co
ncen
trat
ions
of
V
OC
s in
gr
ound
wat
er,
air
emis
sion
s w
ithou
t co
ntro
ls w
ill b
e be
low
the
I p
ound
/day
lim
it ab
ove
whi
ch B
AC
T i
s re
quir
ed t
o lim
it
emis
sion
s in
crea
ses
(SC
AQ
MD
co
nsid
ers
an e
mis
sion
s in
crea
se t
o be
at
le
ast
I po
und/
day.
N
onet
hele
ss,
BA
CT
will
be
used
fo
r all
alte
rnat
ives
.
See
Alte
rnat
ive
70/S
C.
Stat
emen
t of
Pol
icy
with
Res
pect
to M
aint
aini
ng
Hig
h Q
ualit
y of
Wat
ers
in
Cal
ifor
nia
SWC
B
Res
olut
ion
Num
ber 6
8-16
App
licab
le
NA
; no
dis
char
ge
will
occ
ur,
Tre
ated
gro
undw
ater
will
be
disc
harg
ed
to t
he b
ase
was
tew
ater
tre
atm
ent
plan
t, to
the
gro
und
surf
ace,
or
rein
ject
ed t
o
the
aqui
fer.
D
isch
arge
to
the
gro
und
surf
ace
will
no
t deg
rade
w
ater
qual
ity
(See
NPD
ES
requ
irem
ents
bel
ow)
See
Alte
rnat
ive
30/5
0.
.
See
Alte
rnat
ive
30/S
C.
-
c-s.
c-fl
01
a -
- -
a __
•
TA
• C-4
V
S
i'rc
18
GIi
urN
nw:v
rr.g
PLL
ME
CO
MP
AR
AT
IVE
AN
ALY
SIS
OF'
CO
MPL
IAN
CE
WIT
h JA
)('A
TI(
)NSP
E(1
I'IC
A
ND
Acr
Iox—
SPIr
wic
AR
AR
s —
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
T
o-be
. co
nsid
ered
(T
BC
)
Act
ion-
Seci
fic
(Con
tinue
d)
Alte
rnat
ive 2
G
Lim
ited A
ctio
n
Nat
iona
l Po
lluta
nt
Dis
char
ge E
limin
atio
n
Syst
em (
NPD
ES)
Pr
ogra
m
Alte
rnat
ive
3GIS
G
Liq
uid
Pha
se G
AC
Ads
orpt
ionf
Tot
al
Flui
ds R
ecov
ery
App
licab
le
40 C
FR P
arts
12
2-12
5; N
PDE
S P
erm
it N
o.
CA
G9I
800I
fo
r M
arch
AFB
G
roun
dwat
er
Cle
anup
Pro
ject
(M
arch
199
5J
Alte
rnat
ives
7GIS
G
Air
Str
ippi
ng w
ith C
atal
ytic
O
xida
tion/
Tot
al flu
ids
Rec
over
y
NA
; no
dis
char
ge
will
Occ
ur.
Con
tinue
d A
1ter
näi1
es 8
6/SC
A
ir S
trip
ping
with
Pur
us
PAD
RE
" Sy
stem
/Tot
al fl
uids
R
ecov
ery
See
Alte
rnat
ive
30/5
0.
See
Alte
rnat
ive
30/5
0.
Wilt
mee
t su
bsta
ntiv
e re
quir
emen
ts o
f re
gula
tion
thro
ugh
com
plia
nce
with
disc
harg
e lim
its f
or in
orga
nics
and
tot
al
diss
olve
d so
lids.
L
imits
for
reg
ulat
ed
cons
titue
nts
in m
g/L
are
: T
otal
Pe
trol
eum
H
ydro
carb
ons
100,
be
nzen
e 1.
0;
tolu
ene
10;
xyle
nes
10;
ethy
lben
zene
10;
chl
orof
onn 5
; m
ethy
l et
hyl k
eton
e 10;
tetr
achl
oroe
then
e (P
CE
) 5;
m
ethy
l is
obut
yl
keto
ne
tO;
1,1-
di
chlo
roet
hyle
ne
6;
tric
hlow
erhy
lene
(T
CI3
) 5;
di
chlo
robr
omom
etha
ne
5;
1,1,
l-tr
ichl
oroe
than
e (T
CA
) 5;
1,
2-
dich
lore
thyl
eae
10; 1
,1-d
ichl
oret
hane
5;
carb
on
tetr
achl
orid
e 0.
5: n
apht
hate
ne
10; M
axim
um D
aily
Lim
its f
or re
gula
ted
cons
titue
nts
are
in m
g/I:
chro
miu
m 0
.05'
; to
tal
lead
0.
05;
tota
l
resi
dual
chl
orin
e' 0
.1; s
uspe
nded
sol
ids
75; s
ulfi
des 0
.4; c
adm
ium
0.0
1; z
inc
5
Key
: G
AC
=
G
ranu
lar A
ctiv
ated
Car
bon
SCA
QM
D
Sout
h C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
RC
RA
—
R
esou
rce
Con
serv
atio
n an
d R
ecov
ery
Act
M
CL
=
M
axim
um C
onta
min
ant
Lev
el
TB
C
—
To
Be
Con
side
red
UIC
=
U
nder
grou
nd I
njec
tion
Con
trol
OSW
ER
O
ffic
e of
Sol
id W
aste
and
Em
erge
ncy
Res
pons
e A
ltAR
=
A
pplic
able
or
Rel
evan
t and
App
ropr
iate
Req
uire
men
t
BA
CT
B
est A
vaila
ble
Con
trol
Tec
hnol
ogy
NA
=
N
ot a
n A
pplic
able
or
Rel
evan
t and
App
ropr
iate
Req
uire
men
t
VO
C
Vol
atile
Org
anic
Com
poun
d zg
fL
SWC
B
=
- M
icro
gram
s pe
r lite
r St
ate
Wat
er C
ontr
ol B
oard
C-9
01 a a -S
0 C,
. .
.
TA
BLE
C—
S
Si'r
i 31
G1o
L:N
nsvn
nt P
i.i \W
C
O\I
PAR
A'I'
IVE
AN
AL
YSI
S O
F C
OM
I'I.I
AN
CE
W
ITH
Ci IE
MU
'Al.r
SP
EC
IFIC
A
RA
Rs
Con
tam
inan
t ot C
once
rn in
G
roun
dwat
er
App
licab
le,
Rel
evan
t and
So
urce
A
ppro
pria
te, o
r To-
be-
cons
ider
ed_(
TB
C)
Alte
rnat
ive
2G
Lim
itect
Acl
ion
Alte
rnat
ive 3
G
Dir
ect T
reat
men
t with
Liq
uid
Phas
e GA
C
Alte
rnat
ive 4
G
UV
and
Che
mic
al
Oxi
datio
n
Alte
rnat
ive 6
G
Air
Str
ippi
ng w
ith
Car
bon
Ads
orpt
ion
Bis
(2-e
thyl
hexy
l)ph
thal
ate
(I)
Rel
evan
t an
d A
ppro
pria
te
4 ig
/L C
alif
orni
a C
lean
up
Stan
dard
w
ill
not
be
achi
eved
4 gI
L C
alifo
rnia
Cle
anup
S
tand
ard w
ill b
e ac
hiev
ed
4 jig
/L C
alif
orni
a C
lean
up
Stan
dard
will
be
achi
eved
4
pg/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
Tri
chlo
roet
hene
(T
CE
) (I
), (2
)
.
Rel
evan
t an
d A
ppro
pria
te
5 zg
/L
Cal
ifor
nia
and
Fede
ral
Cle
anup
St
anda
rd
will
not
be
achi
eved
5 1t
gfL
C
alif
orni
a an
d Fe
dera
l C
lean
up
Stan
dard
w
ill b
e ac
hiev
ed
5 nI
L
Cal
iforn
ia
and
Fed
eral
Cle
anup
Sta
ndar
d w
ill b
e ac
hiev
ed
5 gz
g/L
C
alif
orni
a an
d Fe
dera
l C
lean
up
Stan
dard
w
ill b
e ac
hiev
ed
1,1-
Dic
hlom
ethe
ne
(I)
Rel
evan
t and
App
ropr
iate
6
pg/L
Cal
ifor
nia
Cle
anup
St
anda
rd
will
no
t be
ac
hiev
ed
6 jz
g/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
6 pg
IL C
alif
orni
a C
lean
up
Stan
dard
will
be
achi
eved
6
ig/L
Cal
ifor
nia
Cle
anup
St
anda
rd w
ill b
e ac
hiev
ed
Key
: A
RA
R
App
licab
le o
r R
elev
ant
and
App
ropr
iate
Req
uire
men
t G
AC
=
G
ranu
lar
Act
ivat
ed C
arbo
n =
M
icro
gram
s pe
r lite
r
(I)
Tid
e 22
, Cal
ifor
nia
Cod
e of
Reg
ulat
ions
(CC
R),
Div
isio
n 4,
Cha
pter
15,
Art
icle
5.5
, Sec
tion
6444
4.5,
Max
imum
Con
tam
inan
t Lev
els
for O
rgan
ic C
hem
ical
s.
(2)
40 C
ode
of F
eder
al R
egul
atio
ns (C
ER
) 14
1.61
, M
axim
um C
onta
min
ant
Lev
els
for O
rgan
ic C
hem
ical
s.
c-fl
-1
c-to
____
__
.. rI
1tIIJ
. C
'6
Sn:
31 G
uoi N
Ifl%
-tIE
R P
i.uui
: C
O\1
I'AR
AT
I'E A
NA
LY
SIS
OF
CO
MPl
iAN
CE
WIT
H L
OC
AT
ION
—SP
EC
IFIC
AM
) A
CT
ION
—SP
EC
IFIC
AR
AR
s
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To-
be-
cons
ider
ed(T
BC
)
Alte
rnat
ive
2G
Lim
ited
Act
zon
Alte
rnat
ive 3
G
Dir
ect
Tre
atm
ent w
ith L
iqui
d Ph
ase
GA
C
Alte
rnat
ive 4
G
UV
and
Che
mic
al O
xida
tion
Alte
rnat
ive 6
G
Air
Str
ippi
ng w
ith C
arbo
n A
dsor
ptio
n
LOC
AT
ION
-SP
EC
IFIC
Cle
an W
ater
Act
S
ectio
n 40
4(b)
(1)
40 C
FR
Sec
tion
230.
10
App
licab
le
NA
; no
disc
harg
e w
ill
occu
r,
Will
mee
tAR
AR
, bec
ause
no
disc
harg
e to
wet
land
s is
exp
ecte
d.
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
30.
Pro
tect
ion o
f W
etla
nds
&ec
utiv
e O
rder
11
990
40 C
FR
6,
App
endi
x A
App
licab
le
NA
; no
disc
harg
e w
ill
occu
r,
Will
mee
t AR
AR
, bec
ause
no
disc
harg
e to
wet
land
s is
exp
ecte
d.
See
Alte
rnat
ive
30.
See
Alte
rnat
ive
3G.
AC
TIO
N-S
PE
CIF
IC
Cal
iforn
ia
Haz
ardo
us W
aste
R
ules
• S
tand
ards
App
licab
le to
G
ener
ator
s of
H
azar
dous
Was
te
Titl
e 22
CC
R,
Div
isio
n 4.
5,
Cha
pter
12,
Sec
tion
6626
2 et
seq
.
App
licab
le
NA
; no
was
tes
are
gene
rate
d.
AR
AIt
will
be
m
et;
spen
t ca
rbon
,
cutti
ngs,
an
d ot
her
resi
dues
w
ill
he
hand
led
and
disp
osed
of
as
haza
rdou
s
was
tes
if th
ey
rnee
t C
alifo
rnia
cl
assi
ficat
ion
crite
ria.
Acc
umul
atio
n and
stor
age
requ
irem
ents
w
ill b
e m
et.
c
NA
; no
was
tes
are
gene
rate
d.
See
Alte
rnat
ive
30. .
c-li
C,'
QY
. .
. Con
tinue
d
Cr
-a
c)
Tul
I.E ('
—6
SE
1'E
31
(;Iu
n.N
nw:v
rIIt
P1A
.1%
li:
C(.
E%
1I'A
ItA
'I'I'E
AN
.&L
YSI
S O
F C
OM
I'IaI
:tNC
E V
IIII
LO
C'A
In)N
SI'E
CIF
IC 1
%N
1) ,A
c'I'I
()N
S19C
IFIt
' AI4
AR
s
Req
uire
men
t So
urce
A
pplic
able
R
elev
ant
and
App
ropr
iate
, or
To-
be-
cons
lder
ed(T
BC
)
Alte
rnat
ive 2
G
Lim
ited
Act
ion
Alte
rnat
ive
3G
Dire
ct T
reat
men
t with
Liq
uid
Phas
e CA
C
Alte
rnat
ive
4G
liv and C
hem
ical
Oxi
datio
n A
ltern
ativ
e 6G
A
ir S
trip
ping
with
Car
bon
Ads
orpt
ion
AC
rI0N
-SpE
CIr
tc (
Con
tinue
d)
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
W
aste
T
rans
fer,
T
reat
men
t &
Dis
posa
l Fa
cilit
ies:
Tan
ks
Mis
cella
neou
s U
nits
Titl
e 22
CC
R,
Div
isio
n 4.
5, C
hp
14,
Sect
ion
6624
.190
- S
ectio
n
6624
.199
Rel
evan
t an
d A
ppro
pria
te
NA
W
ill
mee
t A
RA
R;
rele
vant
an
d
appr
opri
ate
subs
tant
ive
requ
irem
ents
w
ill
be
inco
rpot
ated
in
to
cons
truc
tion
and
desi
gn of
tank
s use
d to
stol
e gro
undw
ater
.
Sam
e as
Alte
rnat
ive
30.
Sam
e as
Alte
rnat
ive
30.
Tid
e 22
CC
R,
Div
isio
n 4.
5, C
hp
14, S
ectio
ns
6626
4.60
0-
6626
4.60
3
Rel
evan
t and
App
ropr
iate
NA
T
he
unit
will
be
lo
cate
d,
desi
gned
, co
nstr
ucte
d, o
pera
ted,
m
aint
aine
d,
and
clos
ed i
n a
man
ner
that
ensu
res p
rote
ctio
n of
hum
an
heal
th
and
the
envi
ronm
ent
(e.g
., pr
even
tion
of r
elea
ses)
an
d w
ill
ther
eby
com
ply
with
th
e re
leva
nt
and
appr
opri
ate
requ
irem
ents
fo
r m
isce
llane
ous t
reat
men
t un
its,
The
uni
t w
ill b
e lo
cate
d,
desi
gned
, co
nstr
ucte
d,
oper
ated
, m
aint
aine
d, a
nd
clos
ed i
n a
man
ner
that
en
sure
s pr
otec
tion
of h
uman
he
alth
and
the
env
iron
men
t (e
.g.,
prev
entio
n of
rele
ases
) an
d w
ill t
here
by c
ompl
y w
ith
the
rele
vant
and
app
ropr
iate
re
quir
emen
ts f
or
mis
cella
neou
s tr
eatm
ent
units
,
The
uni
t will
be
loca
ted,
de
sign
ed,
cons
truc
ted,
op
erat
ed,
mai
ntai
ned,
and
cl
osed
in a
man
ner
that
en
sure
s pr
otec
tion
of hu
man
he
alth
and
the
envi
ronm
ent
(e.g
., pr
even
tion
of re
leas
es)
and
will
ther
eby
com
ply
with
th
e re
leva
nt a
nd a
ppro
pria
te
requ
irem
ents
for
m
isce
llane
ous
trea
tmen
t un
its.
Was
te C
lass
ific
atio
n an
d M
anag
emen
t
Titl
e 23
, Div
isio
n 3.
Cha
pter
15,
A
rtic
le 2
Sec
tion
2522
App
licab
le
.
NA
; no
was
tes
are
gene
rate
d
AR
AR
w
ill
be
met
; sp
ent
carb
on,
cutti
ngs,
an
d ot
her
resi
due,
if
no
t ha
zard
ous
was
te,
will
be
disp
osed
of a
s
desi
gnat
ed w
aste
NA
; no
was
tes
are
gene
rate
d Se
e A
ltern
ativ
e 3G
.
C-1
2
—.
____
____
____
____
T
2uu.
i: C
-6
Silt
31
(IR
OL
.'NI)
W'A
l'ER
PIU
.\IE
C
tE'IP
.tiU
TIV
E A
NA
LY
SIS
OF
CO
MPL
IAN
CE
W
ITH
LO
CA
TIO
N—
SPE
CIF
IC A
ND
AC
TIO
N—
SPE
CIF
IC A
RA
Rs
tt)fl
hillI
It'(I
Req
uire
men
t So
urce
A
pplic
able
! R
elev
ant
and
App
ropr
iate
, or
To-
be-
cons
lder
ed('l
tC)
Mte
niat
ive 2
G
Lim
ited A
ctio
n
Alte
rnat
ive 3
0 D
irec
t Tre
atm
ent w
ith L
iqui
d P
hase
GA
C
.
Alte
rnat
ive 4
0 IN
and
Che
mic
al O
xida
tion
Alte
rnat
ive 6
0 A
ir S
trip
ping
with
Car
bon
Ads
orpt
ion
AC
TIO
N-S
PE
CIF
IC (C
ontin
ued)
Sou
th C
oast
Air
Qua
lity
Man
agem
ent
Dis
tric
t Rul
es &
R
egul
atio
ns - N
ew
Sou
rce
Rev
iew
of
C
arci
noge
nic
Air
Con
tam
inan
ts
Pro
hibi
tory
Rul
es -
R
ule
1401
A
pplic
able
N
A;
no e
mis
sion
s.
Will
mee
t AR
AR
; ad
ditio
nal c
ontr
ols w
ill
not
be
nece
ssar
y be
caus
e ris
k fr
om
emis
sion
s w
ill b
e be
low
1 xI
O6
risk
leve
l st
ated
in th
e ni
le.
See
Alte
rnat
ive
3G.
See
Alte
rnat
ive
30.
New
Sou
rce
Rev
iew
of
Air
Con
tam
inan
ts
Reg
ulat
ion
XIII
, R
ule
1303
A
pplic
able
N
A;
no e
mis
sion
s.
Will
m
eet
AR
AR
. D
ue
to
low
co
ncen
trat
ions
of V
OC
s in
gro
undw
ater
, ai
r em
issi
ons
with
out
cont
rols
w
ill b
e be
low
the
I po
und/
day
limit
abov
e w
hich
B
AC
T
is
requ
ired
to
limit
emis
sion
s in
crea
ses
(SC
AQ
MD
co
nsid
ers
an
emis
sion
s in
crea
se
to
be
at
leas
t 1
poun
d/da
y).
Non
ethe
less
, B
AC
T w
ill b
e
used
fo
r all
alte
rnat
ives
.
See
Alte
rnat
ive
30.
•
See
Alte
rnat
ive
3G.
Sta
tem
ent o
f Pol
icy
with
Res
pect
to
Mai
ntai
ning
Hig
h Q
ualit
y of
Wat
ers
in C
alifo
rnia
SW
CB
Res
olut
ion
Num
ber 6
8-16
A
pplic
able
N
A;
no d
isch
arge
will
oc
cur,
T
reat
ed g
roun
dwat
erw
ill b
e di
scha
rged
to
the
base
was
tew
ater
tre
atm
ent pl
ant,
to t
he
grou
nd
surf
ace
or
rein
ject
ed
to
the
aqui
fer.
D
isch
arge
to
the
grou
nd su
rfac
e
will
no
t de
grad
e w
ater
qu
ality
(s
ee
NP
DE
S r
equi
rem
ents
be
low
).
See
Alte
rnat
ive
30.
See
Alte
rnat
ive
3G.
C-1
3
Cd,
0
MC
L
U1c
A
ltAR
N
A
pgIL
Ca,
-a
Ca,
. .
Tul
lE (
'-6
Sur
E 3
1 G
ItOU
NU
WA
lER
PL
UM
E
CO
MPA
RA
TIV
E
AN
AlY
SIS
OF
CO
MP
LIA
NC
E
%T
Ill
LO
C.%
TIO
N—
SPE
CIF
IC
AN
D
AC
TIO
N—
SPE
CIF
IC A
RA
Rs
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To-
be-
cons
ider
ed(T
BC
)
Alte
rnat
ive
20
Lim
ited
Act
ion
Alte
rnat
ive 3
0 D
irec
t Tre
atm
ent 'w
ith L
iqui
d Ph
ase O
AC
Alte
rnat
ive
40
UV
and
Che
mic
al O
xida
tion
Alte
rnat
ive 6
G
Air
Str
ippi
ng w
ith C
arbo
n A
dsor
ptio
n
AC
TIO
N-S
PEC
IFIC
(C
ontin
ued)
Nat
iona
l Po
lluta
nt
Dis
char
ge
Elim
inat
ion
Syst
em
NPD
ES)
Pro
gram
40 C
FR P
arts
122
- 12
5; N
PDE
S Pe
rmit
Ab.
CA
G
9180
01 fo
r Mar
ch
AFB
Gro
undw
ater
Cle
anup
Pro
ject
(M
arch
199
5)
App
licab
le
NA
; no
dis
char
ge w
ill
occu
r,
Will
m
eet
subs
tant
ive
requ
irem
ents
of
re
gula
tion
thro
ugh
com
plia
nce
with
disc
harg
e lim
its f
or i
norg
anic
s an
d to
tal
diss
olve
d so
lids.
L
imits
fo
r re
gula
ted
cons
tiwen
ts i
n gz
g/L
are
: T
otal
Pe
trol
eum
H
ydro
carb
ons
100;
be
nzen
e 1.
0 ;
tolu
ene
10;
xyle
nes
10;
ethy
lben
zene
10;
chl
orof
orm
5;
met
hyl
ethy
l ket
one
10; t
etra
chlo
roet
hene
(PC
E)
5;
met
hyl
isob
utyl
ke
tone
10
; 1,
1-
dich
loro
ethy
lene
6;
tr
ichl
oroe
thyl
ene
(TC
E) 5
; dic
hlor
obro
mom
etha
ne 5
; 1,1
,1-
tric
hlor
oeth
ane
(TC
A)
5;
1,2-
di
chlo
roet
hyle
ne 1
0; 1
,1-d
ichl
oret
hane
5;
carb
on te
trac
hlor
ide
0.5;
nap
htha
lene
10;
M
axim
um
Dai
ly
Lim
its
for
regu
late
d co
nstit
uent
s ar
e in
mg/
I:
chro
miu
m 0
.052
; to
tal
lead
0.
05;
tota
l re
sidu
al c
hlor
ine'
0.1
; su
spen
ded
solid
s 75
; su
lfide
s 0.
4; c
adm
ium
0.0
1; z
inc
5
See
Alte
rnat
ive
30.
.
See
Alte
rnat
ive
3G.
. .
Key
: G
AC
R
CR
A
TB
C
OSW
ER
B
AC
T
VO
C
Gra
nula
r A
ctiv
ated
Car
bon
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
To
Be
Con
side
red
Off
ice
of S
olid
Was
te a
nd E
mer
genc
y R
espo
nse
Bes
t A
vaila
ble
Con
trol
Tec
hnol
ogy
Vol
atile
Org
anic
Com
poun
d
SCA
QM
D
=
Sou
th C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
=
Max
imum
Con
tam
inan
t Lev
el
=
Und
ergr
ound
In
ject
ion
Con
trol
=
A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t =
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t =
M
icro
gram
s per
lite
r
C—
14
. .
. T
Ain
t C-7
Si
n: 4
Soi
l. C
O\II
'AI(
AT
IVE
AN
AL
YSI
S or
Co%
1Pin
NcI
WIT
H 1
.AK
'AT
ION
—SP
E('I
i'IC
AN
t) A
c'rio
y—S
pi:c
'iric
AR
AR
s
Req
uire
men
t So
urce
App
Bca
ble
Rel
evan
t and
App
ropr
iate
, or
To-
be-
cons
ider
ed (T
BC
) A
ltern
ativ
e 2$
L
imite
d Act
ion
Alte
rnat
ive
3$
RC
RA
Cap
ping
A
ltern
ativ
e 4$
Lan
dfill
Clo
swe
Alte
rnat
ive
95
Exc
avat
ion
and
Ott-
site
D
ispo
sal
LOC
AT
ION
-SP
EC
IFIC
Prot
ectio
n of
Wet
land
s C
lean
Wat
er A
ct S
ectio
n 40
4(b)
(1)
and
Exe
cutiv
e O
rder
1199
0
App
licab
le
AR
AR
w
ill
not
be
met
; er
osio
n of
la
ndfi
ll an
d de
posi
tion
of c
onta
min
ants
in
to
Hea
cock
Sto
rm
Dra
in
will
not
be
prev
ente
d.
AR
AR
will
be
met
; cl
osur
e w
ill
prev
ent
eros
ion
of
land
fill
and
depo
sitio
n of
co
ntam
inan
ts
into
H
eaco
ck
Stor
m
Dra
in
and
will
no
t
adve
rsel
y im
pact
wet
land
s,
Mea
sure
s w
ill
be
take
n du
ring
co
nstr
uctio
n to
pr
even
t ad
vers
e im
pact
s on
w
etla
nds,
AR
AR
will
be
met
; cl
osur
e w
ill
prev
ent
eros
ion
of
land
fill
and
depo
sitio
n of
co
ntam
inan
ts
into
H
eaco
ck
Stor
m
Dra
in
and
will
no
t ad
vers
ely
impa
ct w
etla
nds,
M
easu
res
will
be
ta
ken
duri
ng
cons
truc
tion
to
prev
ent
adve
rse
impa
cts
on
wet
land
s,
AR
AR
will
be
met
; po
tent
ial
sour
ce o
f co
ntam
inat
ion
will
be
elim
inat
ed.
Mea
sure
s w
ill
be
take
n du
ring
co
nstr
uctio
n to
pr
even
t ad
vers
e im
pact
s on
wet
land
s.
AC
TI0
N-S
FEC
II1c
Dis
char
ges
of W
aste
s to
L
and
(Lan
dfill
Clo
sure
and
Po
st-C
losu
re)
Tid
e 23
CC
R,
Div
isio
n 3,
C
hapt
er 15
, A
rtic
le 8
, Se
ctio
n2s8
l
App
licab
le
AR
AR
will
not
be
met
; no
w
aive
r is
jus
tifie
d.
Isol
atio
n of
land
fill
mat
eria
ls
will
be
ac
com
plis
hed.
A
R
CR
A
cap
will
be
co
nstr
octe
d an
d th
e ad
jace
nt
Hea
cock
Sto
rm D
rain
will
be
lined
with
an
im
perm
eabl
e ba
rrie
r. A
RA
R w
ill b
e m
et;
clos
ure
and
post
-clo
sure
re
quir
emen
ts
incl
ude
cons
tnzc
tion
of
a co
ver,
is
olat
ion
of l
andf
ill m
ater
ials
fr
om s
urfa
ce w
ater
dra
inag
e.
wat
er qu
ality
mon
itori
ng a
nd
resp
onse
pr
ogra
ms,
cl
osur
e m
aint
enan
ce
activ
ities
, an
d
post
-clo
sure
m
aint
enan
ce
activ
ities
,
AR
AR
will
be
met
; cl
osur
e
andp
ost-
clos
urer
equi
rem
ents
in
clud
e co
nstm
ctio
n of
a
cove
r,
isol
atio
n of
lan
dfill
m
ater
ials
fro
m s
urfa
ce w
ater
dr
aina
ge,
wat
er
qual
ity
mon
itori
ng
and
resp
onse
pr
ogra
ms,
cl
osur
e m
aint
enan
ce
activ
ities
, an
d
post
-clo
sure
m
aint
enan
ce
activ
ities
.
Will
m
eet
AR
AR
; la
ndfi
ll m
ater
ials
will
be
elim
inat
ed,
cove
red
and
othe
r re
quir
emen
ts
will
be
co
mpl
ied
with
.
c , cs t
C-1
5
. T
AtU
.E C
—7
Si'i
i 4
Son.
C
oII':
u4nI
vE A
x.L
YsI
s oi
CoI
I'I.I
,%N
c[:
%V
I'III
IOC
A'I'
ION
—S
pEcI
FI(
1%
NI)
A
unt )
N—
SI'I.
X'IF
IC A
RA
Rs C
ontin
ued
Req
uire
men
t
App
licab
le, R
elev
ant a
nd
$ow
ce
App
ropr
iate
, or T
o-be
- co
nsid
ered
{TB
C)
Alte
rnat
ive 2
S L
iSte
d A
ctio
n
I
Alte
rnat
ive
35
RC
RA
Cap
ping
A
ltern
ativ
e 4S
Lan
dfill
Clo
sure
Alte
rnat
ive
95
Exc
avat
ion
and
Off
-site
D
ispo
sal
AC
rIO
N-S
PE
CiF
IC (
Con
tinue
d)
Sout
h C
oast
Air
Qua
lity
Dis
tric
t R
ules
and
R
egul
atio
ns:
• Fu
gitiv
e D
ust
• G
aseo
us E
mis
sion
s fr
om I
nact
ive
Lan
dfill
s
Rul
e 40
3
Reg
ulat
ion
IX,
Rul
e 11
50.2
App
licab
le
App
licab
le
NA
; no
exc
avat
ion
of s
oil
will
occ
ur.
NA
; no
exc
avat
ion
of s
oil
will
occ
ur,
AR
AR
w
ill
be
met
; co
nstn
jctio
n ac
tiviti
es
will
co
mpl
y w
ith
regu
latio
ns;
part
icul
ate
mat
ter
will
no
t ex
ceed
50
Mg/
rn'.
May
be
ap
plic
able
to
co
nstr
uctio
n of
cap
; A
RA
R
will
be
co
mpl
ied
with
. L
andf
ill
gase
s w
ill
be
if
AR
AR
w
ill
be
met
; co
nstr
uctio
n ac
tiviti
es
will
co
mpl
y w
ith
regu
latio
ns;
part
icul
ate
mat
ter
will
no
t ex
ceed
50
pg/r
n'.
May
be
ap
plic
able
to
co
nstr
uctio
nof
land
fill
cove
r A
RA
R
will
be
co
mpl
ied
with
.
AR
AR
w
ill
be
met
; co
nstr
uctio
n ac
tiviti
es
will
co
mpl
y w
ith
regu
latio
ns;
part
icul
ate
mat
ter
will
no
t ex
ceed
50
pg/r
n'.
AltA
R
will
be
co
mpl
ied
with
.
Cal
ifor
nia
Haz
ardo
us W
aste
R
ules
:
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r T
reat
men
t an
d D
ispo
sal
Faci
litie
s:
Lan
dfill
s
Tid
e 22
, Div
isio
n 4.
5,
Sect
ion
6626
4.30
0-
6626
4.31
8
Rel
evan
t an
d A
ppro
pria
te
Will
no
t m
eet
AltA
R;
no
wai
ver
is ju
stif
ied,
—
nece
ssar
y.
AR
AR
will
be
met
; inc
ludi
ng
plac
emen
t of
a f
inal
cov
er,
grad
ing,
re
vege
tatio
n,
and
inst
alla
tion
of en
viro
nmen
tal
mon
itori
ng c
entr
al s
yste
ms,
AR
AR
will
be
met
; inc
ludi
ng
plac
emen
t of
a f
inal
cov
er,
grad
ing,
re
vege
tatio
n,
and
inst
alla
tion
of e
nvir
onm
enta
l m
onito
ring
cen
tral
sys
tem
s,
AltA
R w
ill b
e m
et; i
nclu
ding
pl
acem
ent
of a
fin
al c
over
, gr
adin
g,
reve
geta
tion,
an
d in
stal
latio
n of
envi
ronm
enta
l m
onito
ring
cen
tral
sys
tem
s.
Key
: A
RA
R
App
licab
le o
r Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
RC
RA
R
esou
rce
Con
serv
atio
n an
d R
ecov
ery
Act
pg
f =
M
icro
gram
s pe
r cub
ic m
eter
SCA
QM
D
=
Sou
th C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
NA
=
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t (f
l
CR
C
-16
(a)
• .
. T
.sm
.i•:
c—s
si-r
i: iü
Si
RE
Al -
F S
oil..
('O
¼1P
AItA
TIV
E ,
tNA
I,V
SIS
OF
CO
MI'I
.I.%
NC
E W
ilil L
OC
AT
1ON
SV
EI'I
Ilc .N
D A
cT1O
N—
SP
EU
IIic
.AR
AR
s
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To-
be-c
onsi
dere
d ('F
EC
)
Alte
rnat
ive
2$
Lim
ited A
ctio
n A
ltern
ativ
e 55
Exc
avat
ion
and
Low
Tem
pera
ture
The
rmal
D
esor
ptio
n
Alte
rnat
ive
7$
Exc
avat
ion
and
Off
slte
T
reat
men
t
Alte
rnat
ive S
S E
xcav
atio
n an
d O
nsite
C
onso
lidat
ion
Alte
rnat
ive 1
1$
Ex-
Situ
B
iore
med
iatio
n
Acr
ioN
-Spu
cinc
Cal
iforn
ia H
azar
dous
W
aste
Rul
es:
• S
tand
ards
App
licab
leto
G
ener
ator
s of
H
azar
dous
Was
te
Titl
e 22
, D
ivis
ion
4.5,
C
hapt
erl2
,Sec
tion
6626
2 et
seq
.
App
licab
le
N A
no
w
aste
s ge
nera
ted.
.
See
Alte
rnat
ive
85.
Will
mee
t A
RA
R;
will
co
mpl
y w
ith
char
acte
rizat
ion,
an
d on
site
co
ntai
ner
and
stor
age
requ
irem
ents
if
soils
C
T
resi
dual
s ar
e de
term
ined
to
be
ha
zard
ous
was
te.
Will
m
eet
AR
AR
; on
ly s
oils
w
ithou
t haz
ardo
us w
aste
ch
arac
teris
tics
will
be
co
nsol
idat
ed o
nsite
.
Will
mee
t A
RA
R;
will
co
mpl
y w
ith
char
acte
rizat
ion,
an
d on
site
co
ntai
ner
and
stor
age
requ
irem
ents
if
soils
or
res
idua
ls
are
dete
rmin
ed
to
be
haza
rdou
s w
aste
. W
ill
mee
t AR
AR
; on
ly s
oils
w
ithou
t haz
ardo
us w
aste
ch
arac
teris
tics
will
be
co
nsol
idat
ed
onsi
te.
See
Alte
rnat
ive
75.
• S
tand
ards
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r,
Tre
atm
ent
and
Dis
posa
l F
acili
ties:
Land
fills
T
itle
22,
Div
isio
n 4.
5,
Sec
tion
6626
4.30
0 -
6626
4.31
8
App
licab
le
NA
; no
w
aste
s ge
nera
ted.
N
A;
no
was
tes
gene
rate
d,
NA
; w
aste
s w
ill n
ot b
e
plac
ed in
onsi
te la
ndfil
ls,
Will
mee
t A
RA
R;
only
no
n-ha
zard
ous
was
tes
will
be
plac
ed in
ons
ite
land
fills
.
NA
; no
w
aste
s ge
nera
ted.
Was
te P
iles
Tid
e 22
. D
ivis
ion
4.5,
S
ectio
n 66
264.
250 -
6626
4.25
9 .
App
licab
le
NA
; no
was
te p
iles.
S
ee A
ltern
ativ
e 7$
. W
ill
mee
t A
RA
R
by
com
plyi
ng
with
re
gula
tions
. R
elev
ant
only
if
tem
pora
ry
stor
age
of R
CR
A w
aste
in
pile
s oc
curs
.
See
Alte
rnat
ive
7S.
See
Alte
rnat
ive
7$.
C-1
7
__.
.__
TA
BLE
C
-8
S-F
10
Sui
u-'.t
ci S
oii_
C
OM
I'AR
A'II
vi:
AN
M.v
sIs oi
Col
pu.k
NcI
win
i L( )
CA
II()N
—S
I'EU
IFIC
.%
NE
) A
(.T
ION
—S
PE
CII-
IU A
RA
Rs
Req
uire
men
t --
Sow
ce
App
licab
le,
Rel
evan
t d A
ppro
pfla
te, o
r T
o-be
-con
side
red
(FE
C)
Alte
rnat
ive 2
S L
ited
Muo
n -
-
Alte
rnat
ive S
S
cava
tion a
nd 1
4w
Tem
pera
ture
The
rmal
D
esor
ptio
n
Alte
rnat
ive 7
5 E
xcav
atio
n an
d O
ftdt
e T
reat
men
t
Alte
rnat
ive S
S E
xcav
atio
n and
Ons
ite
Con
solid
atio
n
Alte
rnat
ive u
S E
x-S
itu
Bio
rem
edia
tion
AC
TIO
N-S
PEC
IFIC
Was
te C
lass
ific
atio
n an
d M
anag
emen
t
Titl
e 23
, Div
isio
n 3,
C
hapt
er 1
5, A
rtic
le 2
, Se
ctio
n 25
22
App
licab
le
NA
; no
was
te g
ener
ated
N
A;
no w
aste
gen
erat
ed
AR
AR
will
be
met
; no
n-
haza
rdou
s w
aste
will
be
disp
osed
of a
s des
igna
ted
was
te
AR
AR
will
be
met
: no
n-
haza
rdou
s w
aste
will
be
disp
osed
of a
s des
igna
ted
was
te
See
Alte
rnat
ive
75
Dis
char
ges
of W
aste
to
Lan
d (S
oil
Dis
posa
l)
Tid
e 23
, Div
isio
n 3.
C
hapt
er 1
5 R
e I
e v
a n
t a
n d
App
ropr
iate
N
A;
no d
isch
arge
s w
ill
occu
r,
NA
; no
di
scha
rge
of
was
te w
ill o
ccur
, N
A; n
oons
itedi
scha
rges
w
ill o
ccur
, A
RA
R w
ill b
e m
et;
only
no
n-ha
zard
ous
soils
will
be
dis
char
ged,
and
a c
ap
will
pre
vent
lea
chin
g of
an
y co
ntam
inan
ts
to
grou
ndw
ater
.
NA
; no
di
scha
rge
of
was
te w
ill o
ccur
.
Sout
h C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
Rul
es a
nd R
egul
atio
ns
• Fu
gitiv
e D
ust
• N
ew S
ourc
e R
evie
w o
f C
arci
noge
nic
Air
C
onia
tnin
anis
Proh
ibito
ry R
ules
, R
ule
403
App
licab
le
NA
; no
emis
sion
s.
See
Alte
rnat
ive
7S.
AR
AR
w
ill
be
met
; ex
cava
tion
activ
ities
will
co
mpl
y w
ith r
egul
atio
ns,
part
icul
ate
mat
ter
will
no
t exc
eed
50 p
g/m
'.
See
Alte
rnat
ive
75.
See
Alte
rnat
ive
7S.
Rul
e 14
01
App
licab
le
NA
; no
emis
sion
s.
Will
m
eet
AR
AR
; em
issi
ons
of P
AR
s w
ill
be
belo
w lx
l0 ri
sk
leve
l st
ated
in
the
rule
; co
ntro
ls
will
no
t be
requ
ired
.
Not
ap
plic
able
to
th
is
alte
rnat
ive.
N
/A
See
Alte
rnat
ive
55.
Key
: A
RA
R
=
App
licab
le o
r Rel
evan
t and
App
ropr
iate
Req
uire
men
t R
CR
A
=
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
PAR
=
P
olyn
ucle
ar
Aro
mat
ic H
ydro
carb
on
NA
=
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t C
S!
Mg/
rn'
=
Mic
rogr
ams p
er c
ubic
met
er
Alte
rnat
ive
8S i
s no
long
er a
viab
le a
ltern
ativ
e
CR
C
iT
C-I
S
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To.
be
cons
ider
ed(T
BC
)
Alte
rnat
ive 2
S L
imite
d Act
ion
Alte
rnat
ive
SS
Exc
avat
ion a
nd L
ow
Tem
pera
ture
The
rmal
D
esor
ptiu
n
Alte
rnat
ive I
S E
xcav
atio
n and
Off
site
T
reat
men
t
Alte
rnat
ive 8
S E
xcav
atio
n and
Ons
ite
Con
solid
atio
n
Alte
rnat
ive I
tS
Ex-
Situ
B
iore
med
latio
n
AC
TIO
N-S
FE
Cm
C
Cal
ifor
nia
Haz
ardo
us
Was
te R
ules
• St
anda
rds
App
licab
le t
o G
ener
ator
s of
H
azar
dous
Was
te
Tid
e 22
, D
ivis
ion
4.5,
C
hapt
er 1
2, S
ectio
n 66
262
et s
eq.
App
licab
le
NA
; no
w
aste
s ge
nera
ted.
Se
e A
ltern
ativ
e 85
. W
ill
mee
t A
ltAR
; w
ill
c o
m p
I
y w
it h
ch
arac
teri
zatio
n,
and
onsi
te
cont
aine
r an
d
stor
age
requ
irem
ents
if
so
ils
or
resi
dual
s ar
e de
term
ined
to
be
ha
zard
ous
was
te.
Will
mee
t A
RA
R;
only
so
ils w
ithou
t ha
zard
ous
was
te c
hara
cter
istic
s w
ill
be c
onso
lidat
ed o
nsite
.
See
Alte
rnat
ive
iS.
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r,
Tre
atm
ent
and
Dis
posa
l Fa
cilit
ies:
Lan
dfill
s
Was
te P
iles
Tid
e 22
, Div
isio
n 4.
5,
Sect
ion
6626
4.30
0 -
6626
4.31
8
App
licab
le
NA
; no
w
aste
s ge
nera
ted.
N
A; n
o w
aste
s.
NA
; w
aste
s w
ill n
ot b
e pl
aced
in on
site
land
fills
, W
ill m
eet
AR
AR
; on
ly
non-
haza
rdou
s w
aste
s w
ill b
e pl
aced
in
onsi
te
land
fills
.
NA
. no
was
tes.
Tid
e 22
, D
ivis
ion
4.5,
Se
ctio
n6ó2
64.2
50
- 66
264.
259
App
licab
le
NA
; no
was
te p
iles.
.
See
Alte
rnat
ive
75.
Will
m
eet
AR
AR
by
co
mpl
ying
w
ith
regu
latio
ns.
Rel
evan
t
only
if
te
mpo
rary
st
orag
e of
RC
RA
was
te
in pi
les
occu
rs.
See
Alte
rnat
ive
75.
See
Alte
rnat
ive
7S
Was
te C
lass
ific
atio
n an
d M
anag
emen
t T
itle
23,
Div
. 3,
Cha
pter
IS,
Art
icle
2,
Sect
ion
2522
App
licab
le
NA
: no
was
te g
ener
ated
N
A:
no w
aste
gen
erat
ed
AltA
R w
ill b
e m
et;
non
haza
rdou
s w
aste
will
be
disp
osed
of a
s des
igna
ted
was
te
AR
AR
will
be
met
; no
n ha
zard
ous
was
te w
ilt b
e di
spos
ed
of
as
desi
gnat
ed w
aste
See
Alte
rnat
ive
7S.
IAB
I .i:
(:—
9
Srii
: 15
SI:R
FA
cE
S( H
L
Coi
rtitv
nvi:
AN
.u11
s1s
C)I
•' C
O\IP
14t1
%N
CE
VI'I
'II I
A)C
AT
ION
—SP
EC
II'IC
AN
I) :
tC'I'
ION
—SI
'ICIt
"IC
A
RA
Rs
C-1
9
TA
BL
E C
—9
Si'r
K 1
5 S
uIu'
Aci
Soi
l2
CO
MPA
RA
TIV
E
AN
AL
YSI
S oi
l Co%
lpIn
NcI
;: W
ITh
LOC
'.vI'I
ON
—S
PIX
'IFIC
AN
t) A
ui'to
N—
SrIr
li•tc
A
RA
Rs
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To-
be-
cons
ider
ed(T
BC
)
Alte
rnat
ive 2
5 L
imite
d Act
ion
Alte
rnat
ive 5
5 E
xcav
atio
n and
Low
T
empe
ratu
re T
herm
al
Des
orpt
ion
Alte
rnat
ive 7
5 E
xcav
atio
n and
Off
site
T
reat
men
t
Alte
rnat
ive 8
S E
xcav
atio
n and
Ons
ite
Con
solid
atto
n
Alte
rnat
ive
uS
Ex-
Situ
B
iore
med
iatio
n
Dis
char
ges
of W
aste
to
Lan
d (S
oil
Dis
posa
l)
Titl
e 23
, D
ivis
ion
3,
Cha
pter
15
R e
I e
v a
n t
a n
d A
ppro
pria
te
NA
; no
dis
char
ges
will
oc
cur,
N
A;
no
disc
harg
e of
w
aste
will
occ
ur,
NA
; noo
nsite
dis
char
ges
will
occ
ur, .
AR
AR
will
be
met
; no
n-
haza
rdou
s so
ils w
ill b
e co
vere
d by
a
cap
to
prev
ent
lead
ing.
NA
; no
di
scha
rge
of
was
te w
ill o
ccur
,
Sou
th C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
Rul
es a
nd R
egul
atio
ns
• Fu
gitiv
e D
ust
• N
ew S
ourc
e R
evie
w o
f C
arci
noge
nic
Air
C
onta
min
ants
Proh
ibito
ry R
ules
, R
ule
403
App
licab
le
NA
; no
exc
avat
ion
will
oc
cur,
Se
e A
ltern
ativ
e 7S
. C
ompl
ianc
e w
ill
occu
r by
co
ntro
lling
fu
gitiv
e du
st
to
leve
ls
of
<50
pg
/rn'
See
Alte
rnat
ive
75.
See
Alte
rnat
ive
7.
Rul
e 14
01
.
App
licab
le
NA
; no
em
issi
ons.
W
ill
mee
t A
RA
R;
emis
sion
s of
PA
ils w
ill
be
belo
w
IX 10
6 ri
sk
leve
l st
ated
in
the
nile
; co
ntro
ls
will
no
t be
re
quir
ed.
Not
app
licab
le.
Not
app
licab
le.
See
Alte
rnat
ive
5S,
Key
: A
RA
R
=
App
licab
le or
Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
RC
RA
=
R
esou
rce
Con
serv
atio
n an
d R
ecov
ery
Act
-
PA
H
=
Pol
ynuc
lear
Aro
mat
ic H
ydro
carb
on
NA
=
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t pg
/rn'
M
icro
gram
s pe
r cub
ic m
eter
C
r A
ltern
ativ
e 8S
is
no lo
nger
a v
iabl
e al
tern
ativ
e.
a 01
-4
C-2
0
• .
. T
AB
LE C
-1O
S
ITE
18
SU
BS
UR
FA
CE
SO
IL
CoM
PAR
AT
IVE
AN
AL
YSI
S O
F C
OM
PLIA
NC
E W
ITH
LO
CA
TIO
N-S
PEC
IFIC
AN
D A
CT
ION
-SPE
CIF
IC A
RA
BS
Req
uire
men
t So
urce
A
pplic
able
, A
ltern
ativ
e 25
A
ltern
ativ
e lO
S A
ltern
ativ
e 12
8 A
ltern
ativ
e 13
8 R
elev
ant a
nd
Lim
ited A
ctio
n B
iove
ntiu
g So
il V
apor
Ext
ract
ion
with
Cat
alyt
ic
Soil
Vap
or E
xtra
ctio
n w
ith P
urus
App
ropr
iate
, or
Oxi
datio
n PA
DR
E"
Syst
em
To-
be-
cons
ider
ed
ITB
C)
AC
UO
N-S
PE
cwIc
Cal
ifor
nia
Haz
ardo
us W
aste
R
ules
.
• St
anda
rds
App
licab
le t
o G
ener
ator
s of
Haz
ardo
us
Was
te
Tid
e 22
. Div
isio
n 4.
5,
Cha
pter
12,
Sec
tion
6626
2 et
seq
.
App
licab
le
NA
; no
was
tes.
N
A; n
o w
aste
s.
NA
; no
was
tes
are
gene
rate
d.
Will
mee
t A
RA
R.
Res
idue
will
be
hand
led
and
disp
osed
of a
s ha
zard
ous
was
te if
it m
eets
cl
assi
fica
tion
crite
ria.
• St
anda
rds
for O
pera
tors
of
Haz
ardo
us W
aste
T
rans
fer,
Tre
atm
ent &
D
ispo
sal
Faci
litie
s:
Tan
ks
Tid
e 22
, D
ivis
ion
4.5,
Se
ctio
n 66
24.1
90 -
S
ectio
n 66
24.1
99
Rel
evan
t and
App
ropr
iate
N
A;
no t
anks
are
us
ed,
NA
; no
tank
s are
us
ed,
NA
; no
tan
ks a
re u
sed.
W
ill m
eet
AR
AR
. R
elev
ant
and
appr
opri
ate
requ
irem
ents
w
ill
be
inco
rpor
ated
in
to
the
desi
gn a
nd c
onst
uict
ion
of P
ums t
anks
.
Was
te C
lass
ific
atio
n an
d M
anag
emen
t T
ide
23, D
ivis
ion
3,
Cha
pter
15,
Art
icle
2,
Sect
ion
2522
App
licab
le
NA
; no
was
tes
NA
; no
was
tes
NA
; no
was
tes
Res
idue
will
be
hand
led
and
disp
osed
of a
s de
sign
ated
was
te, if
it is
non
haz
ardo
us
Sout
h C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
Rul
es
Reg
ulat
ions
- N
ew S
ourc
e R
evie
w of
Car
cino
geni
c A
ir
Con
tam
inan
ts
Proh
ibito
ry R
ules
-
Rul
e 14
01
App
licab
le
NA
; no
em
issi
ons,
N
A; d
e m
inim
us
emis
sion
s,
Will
mee
t A
RA
R,
emis
sion
s of
BT
EX
will
be
belo
w lx
106
risk
lev
el s
tate
d in
the
m
le;
addi
tiona
l co
ntro
ls w
ill n
ot b
e re
quir
ed.
See
Alte
rnat
ive
12S.
New
Sou
rce
Rev
iew
of A
ir
Con
tam
inan
ts
Rul
e 13
03
App
licab
le
NA
; no
emis
sion
s,
NA
; de
min
imus
em
issi
ons.
W
ill m
eet A
RA
R;
emis
sion
s w
ill b
e be
low
the
I
poun
d/da
y th
resh
old.
Se
e A
ltern
ativ
e 12
8.
Key
: A
ltAR
=
A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t R
CR
A
=
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
ET
EX
=
B
enze
ne,
Tol
uene
, E
thyl
benz
ene,
and
Xyl
ene
NA
=
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t
C-2
1
. T
tIILE
041
S
im 3
1 S
UIW
tCE
Sf )
JL
C(T
hIP
AR
A'I'
IVE
AN
ALY
SIS
OF
CO
MI'I
.IAN
C'E
WI'I
'II
LO
CA
'IIO
NSP
IX'Il
IC A
M)
AC
IION
SP
EtIF
IC A
RA
Rs
Req
uire
men
t So
urce
A
pplic
able
, R
elev
ant
and
App
ropr
iate
, or
To-
be-c
onsi
dere
d (T
BC
)
Alte
rnat
ive 2
S L
imite
d Act
ion
Alte
rnat
ive S
S E
xcna
tion a
nd L
ow
Tez
nper
atw
e T
herm
al
Des
orpt
ion
Alte
rnat
ive 7
5 E
xcav
atio
n and
Otis
ite
Tre
atm
ent
Alte
rnat
ive 8
5 E
xcav
atio
n and
Ons
ite
Con
solid
atio
n
Alte
rnat
ive
115
Ex-
Situ
B
iore
med
iatlo
n
AC
H0N
-Spg
cwlc
Cal
ifor
nia
Haz
ardo
us
Was
te R
ules
• St
anda
rds
App
licab
le
to G
ener
ator
s of
H
azar
dous
Was
te
Tid
e 22
, Div
isio
n 4.
5.
Cha
pter
12,
Sec
tion
6626
2 C
t se
q.
App
licab
le
NA
; no
was
tes
gene
rate
d.
See
Alte
rnat
ive
8S.
Will
m
eet
AR
AR
; w
ill
c o
m p
I
y w
i t
h ch
arac
teri
zatio
n,
and
onsi
te
cont
aine
r an
d st
orag
e re
quir
emen
ts
if
soils
or
re
sidu
als
are
dete
rmin
ed
to
be
haza
rdou
s w
aste
.
Will
mee
t A
RA
R;
only
so
ils w
ithou
t ha
zard
ous
was
te c
hara
cter
istic
s will
be
con
solid
ated
ons
ite.
•
See
Alte
rnat
ive
75.
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r, T
reat
men
t an
d D
ispo
sal
Faci
litie
s:
Lan
dfill
s
Was
te P
iles
Titl
e 22
, Div
isio
n 4.
5,
Sect
ion
6626
4.30
0 -
6626
4.31
8
App
licab
le
NA
; no
was
tes
gene
rate
d.
NA
; no
was
tes.
N
A:
was
tes
will
not
be
plac
ed in
onsi
te la
ndfi
lls,
Will
mee
t A
RA
R;
only
no
n-ha
zard
ous
was
tes
will
be
plac
ed i
n on
site
la
ndfi
lls.
CJ1
r P- u'
NA
; no
was
tes.
(0
Tid
e 22
, Div
isio
n 4.
5,
Sect
ion
6626
4.25
0 -
6626
4.25
9
App
licab
le
NA
: no
was
te p
iles.
Se
e A
ltern
ativ
e 7S
. W
ill
mee
t A
RA
R
by
com
plyi
ng
with
re
gula
tions
. R
elev
ant
only
if
te
mpo
rary
st
orag
e of
RC
RA
was
te
in p
iles
occu
rs.
See
Alte
rnat
ive
iS.
See
Alte
rnat
ive
75.
C-2
2
Tui
i.i:
—1l
Si
n 31
Sun
ct S
oil.
CC
)MP
AR
:t'F
lVi
AN
AL
\SlS
OF
CC
flIP
1.IA
NC
E W
i'itl
1j(.
)t':t
ll()N
—SP
E('I
FIC
tNl)
AC
FUN
—Sp
EC
IFIC
A
RM
4s
Req
uire
men
t - -
Sow
ce
- -
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te, o
r T
o-be
-con
side
red
(FE
C)
Alte
rnat
ive
25
Lim
ited A
ctio
n
-
Alte
rnat
ive 5
5 E
xcav
atio
n an
d L
ow
Tem
pera
ture
The
rmal
D
esor
ptio
n
Alte
rnat
ive 7
5 E
xcav
atio
n an
d O
ffsi
te
Tre
atm
ent
Alte
rnat
ive 5
5*
Exc
avat
ion
and
Ons
ite
Con
solid
atio
n
Alte
rnat
ive
115
Ex-
Situ
B
iore
med
iatio
n
AC
UQ
N-S
pEcm
c
Was
te C
lass
ific
atio
n an
d M
anag
emen
t T
ide
23, D
ivis
ion
3,
Cha
pter
IS,
Art
icle
2,
Sect
ion
2522
App
licab
le
NA
; no
was
te g
ener
ated
N
A;
no w
aste
gen
erat
ed
AR
AR
will
be
met
; no
n-
haza
rdou
s w
aste
wilt
be
disp
osed
of
as
de
sign
ated
was
te
AR
AR
will
be
met
; non
- ha
zard
ous
was
te w
itt b
e
disp
osed
of
as
de
sign
ated
was
te
See
Alte
rnat
ive
75
Dis
char
ges
of W
aste
to
Lan
d (S
oil
Dis
posa
l)
TiO
e 23
, Div
isio
n),
Cha
pter
15
Re'
evan
t an
d
App
ropr
iate
N
A; n
o di
scha
rges
wil'
oc
cur,
N
A;
no
disc
harg
e of
w
aste
will
occ
ur,
N A
; no
0
n si
te
disc
harg
es w
ill o
ccur
, A
RA
R w
ill b
e m
et;
non-
ha
zard
ous
soil
will
be
co
vere
d by
a c
ap.
NA
; no
di
scha
rge
of
was
te
will
oc
cur.
See
Alte
rnat
ive
75
Sout
h C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
Rul
es a
nd R
egul
atio
ns
• Fu
gitiv
e D
ust
• N
ew S
ourc
e R
evie
w o
f C
arci
noge
nic
Air
C
onta
min
ants
Proh
ibito
ry R
ules
, Rul
e 40
3 A
pplic
able
N
A; n
o ex
cava
tion
will
oc
cur,
.
-
See
Alte
rnat
ive
7S.
Com
plia
nce
will
oc
cur
by
cont
rolli
ng
fugi
tive
dust
to
kve
ls o
f <
50
zg/m
'
See
Alte
rnat
ive
7S.
See
Alte
rnat
ive
75.
Rul
e 14
01
App
licab
le
NA
; no
emis
sion
s.
Will
m
eet
AR
AR
; em
issi
ons
of P
AR
s w
ill
be
belo
w lx
1o
risk
le
vel
stat
ed i
n th
e ru
le;
cont
rols
w
ill
not
be
requ
ired
.
Not
appl
icab
le.
See
Alte
rnat
ive
5S.
See
Alte
rnat
ive
7S.
Key
: A
RA
R
=
App
licab
le o
r Rel
evan
t and
App
ropr
iate
Req
uire
men
t R
CR
A
=
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
PAH
=
P
olyn
ucle
ar
Aro
mat
ic H
ydro
carb
on
Cii
NA
=
N
ot a
n A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t pg
/rn'
=
M
icro
gram
s per
cub
ic m
eter
A
ltern
ativ
e 85
is n
o lo
nger
a v
iabl
e al
tern
ativ
e
CD
0 C
-23
S
1'A
BLE
C-1
2 SI
rE 3
1 S
UB
SU
RF
AC
E So
il.
CO
4lPA
RA
TIV
E
AN
AL
YSI
S U
I: C
OM
PLIA
NC
E
WIT
h L
OC
AT
ION
-SPE
CIF
IC A
NI)
A
CT
ION
—SP
EC
IFIC
AR
AR
s
Req
uire
men
t So
urce
A
pplic
able
. R
elev
ant a
nd
App
ropr
iate
, or T
o-be
--
cons
ider
ed (F
EC
)
Alte
rnat
ive 2
S L
imite
d Act
ion
Alte
rnat
ive
12S
Soil
Vap
or E
xtra
ctio
n w
ith C
atal
ytic
O
xida
tion
Alte
rnat
ive 1
35
Soil
Vap
or E
xtra
ctio
n w
ith P
Uru
s PA
DR
E'
Syst
em
Alte
rnat
ive 1
4S
Soil
Vap
or E
xtra
ctio
n w
ith C
arbo
n A
dsor
ptio
n
AC
TIO
N-S
PE
CIF
IC
Cal
iforn
ia H
azar
dous
Was
te
Rul
es
• St
anda
rds
App
licab
le
to G
ener
ator
s of
H
azar
dous
Was
te
Tid
e 22
CC
R,
Div
isio
n 4.
5, C
hapt
er 12
, Se
ctio
n 66
262
et se
q.
App
licab
le
NA
; no
was
te g
ener
ated
. Se
e A
ltern
ativ
e 25
. A
RA
R w
ill b
e m
et;
spen
t ca
rbon
, cu
tting
s, a
nd
othe
r re
sidu
es w
ill b
e ha
ndle
d an
d di
spos
ed o
f as
haz
ardo
us w
aste
s if
th
ey m
eet C
alif
orni
a cl
assi
fica
tion
crite
ria.
A
ccum
ulat
ion
and
stor
age
requ
irem
ents
will
be
met
.
See
Alte
rnat
ive
I3S.
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r, T
reat
men
t &
Dis
posa
l Fa
cilit
ies:
Tan
ks
Titl
e 22
CC
R,
Div
isio
n 4.
5, S
ectio
n 66
24.t9
0 -
Sec
tion
6624
.199
Rel
evan
t an
d A
ppro
pria
te
NA
; no
was
tes.
R
elev
ant
and
appr
opri
ate
subs
tant
ive
requ
irem
ents
w
ill b
e in
corp
orat
ed i
nto
cons
tnic
tion
and
desi
gn o
f tan
ks.
See
Alte
rnat
ive
12S.
Se
e A
ltern
ativ
e 12
S.
Was
te C
lass
ific
atio
n an
d
Man
agem
ent
Tid
e 23
, Div
isio
n 3,
C
hapt
er 1
5, A
rtic
le 2
, Se
ctio
n 25
22
App
licab
le
NA
; no
was
tes
NA
; no
was
tes
NA
; no
was
tes
Res
idue
will
be
hand
led
and
disp
osed
of a
s
desi
gnat
ed w
aste
, if
it is
no
n ha
zard
ous
Sout
h C
oast
Air
Qua
lity
Man
agem
ent D
istr
ict
Rul
es/R
egul
atio
ns
• N
ew S
ourc
e R
evie
w o
f
Car
cino
geni
c A
ir
Con
tam
inan
ts
Rul
e t4
01
•
App
licab
le
NA
; no
emis
sion
s.
Will
m
eet
AR
AR
; em
issi
ons
will
be
be
low
3 x
10'
risk
leve
l st
ated
in n
ile.
See
Alte
rnat
ive
125.
c.n
.tb ,
See
Alte
rnat
ive
12S.
C-2
4
T.m
I.E C
-12
SIT
E 3
1 Si
Bsn
u'A
cI: S
oli
CoM
PA
RA
tIvE
AN
AL
YSI
S 01
('O
MPL
IAN
( 'K W
ITh
LO
CA
1'I(
)N.S
I'EcI
I'I('
AN
D A
CI'I
ON
SPE
C'IF
IC A
RA
RS
('1)1
11 in
ued
Req
uire
men
t So
urce
-
App
licab
le, R
elev
ant a
nd
App
ropr
iate
, or T
o-be
- co
nsid
ered
fEB
Q
Alte
rnat
ive 2
5 -
Lim
ited A
ctio
n A
ltern
ativ
e 12
5 --
Soi
l Vap
or E
xtra
ctio
n w
ith C
atal
ytic
O
xida
tion
Alte
rnat
ive 1
3S -
Soi
l Vap
or E
xtra
ctio
n w
ith V
urus
PA
DR
ET
h Sy
stem
Alte
rnat
ive
145
-
Soi
l Vap
or E
xtra
ctio
n w
ith C
arbo
n A
dsor
ptio
n
AC
H0N
-Si'g
cmc (
Con
tinue
d)
Sout
h Coa
st A
ir Q
ualit
y M
anag
emen
t Dis
tric
t R
ules
/Reg
ulat
ions
(C
ontin
ued)
• N
ew S
ourc
e R
evie
w o
f A
ir C
onta
min
ants
R
ule
1303
A
pplic
able
N
A;
no e
mis
sion
s.
Due
to
low
con
cent
ratio
ns o
f VO
Cs
in
grou
ndw
ater
, ai
r em
issi
ons
will
be
be
low
th
e I
poun
d/da
y lim
it ab
ove
whi
ch
BA
CT
is
re
quir
ed
to
limit
emis
sion
s in
crea
ses
(SC
AQ
MD
co
nsid
ers
an e
mis
sion
s in
crea
se t
o be
at
leas
t I p
ound
/day
. N
onet
hele
ss,
BA
CT
w
ill b
e us
ed f
or al
l alte
rnat
ives
.
See
Alte
rnat
ive
125.
Se
e A
ltern
ativ
e 12
S.
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
App
licab
le o
r Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
Not
an
App
licab
le o
r R
elev
ant
and
App
ropr
iate
Req
uire
men
t V
olat
ile O
rgan
ic C
ompo
und
Bes
t A
vaila
ble
Con
trol
Tec
hnol
ogy
C-2
5
01
a a a,
I')
Key
: R
CR
A
AR
AR
N
A
VO
C
BA
CT
• rr
%uh
i. C
I 3
Sui
t 34
SuI
wu'
E S
ouu.
C
OM
PA
RA
TIV
E A
NA
LYS
Is
01: C
oIi'i
..I.N
cI w
i-ru
IA
JCA
1'IO
N—
SPE
CIH
C..%
ND
AC
TIO
N—
SPE
CIF
IC A
LtA
Rs
Req
uire
men
t
- -
Sour
ce
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te, o
r T
o-be
-con
side
red
(TB
C)
Alte
rnat
ive
2S
Lim
ited A
ctio
n -
- -
Alte
rnat
ive 5
5 E
xcav
atio
n an
d L
ow
Tem
pera
twe
The
rmal
D
esor
ptio
n
Alte
rnat
ive I
S E
xcav
atio
n and
Off
site
T
reat
men
t
Alte
rnat
ive 8
5 E
xcav
atio
n an
d O
nsite
- C
onso
lidat
ion
Alte
rnat
ive 1
15
ExS
itu
Bio
rem
edia
tion
AC
TIO
N-S
PEC
IfiC
.
Cal
ifor
nia
Haz
ardo
us
Was
te R
ules
:
• St
anda
rds
App
licab
le t
o G
ener
ator
s of
H
azar
dous
Was
te
• St
anda
rds
for
Ope
rato
rs o
f H
azar
dous
Was
te
Tra
nsfe
r,
Tre
atm
ent a
nd
Dis
posa
l Fa
cilit
ies:
Lan
dfill
s
Was
te P
iles
Titl
e 22
. Div
isio
n 4.
5,
Cha
pter
12,
Sec
tion
6626
2 et
seq.
App
licab
le
-
NA
; no
was
tes
gene
rate
d.
See
Alte
rnat
ive
85.
Will
mee
t A
RA
R;
will
co
mpl
y w
ith
char
acte
riza
tion,
and
on
site
con
tain
er a
nd
stor
age
requ
irem
ents
if
soils
are
det
erm
ined
to
be h
azar
dous
was
te.
Will
mee
t A
RA
R;
only
so
ils w
ithou
t ha
zard
ous
was
te c
hara
cter
istic
s w
ill b
e co
nsol
idat
ed
onsi
te.
See
Alte
rnat
ive
75.
Tid
e 22
. Div
isio
n 4.
5,
Sect
ion
6626
4.30
0-
6626
4.3 t
8
App
licab
le
NA
; no
was
tes
gene
rate
d.
NA
; no
was
tes.
N
A;
was
tes
will
not
be
plac
ed i
n on
site
la
ndfi
lls,
Will
mee
t A
RA
R;
only
no
n-ha
zard
ous
was
tes
will
be
plac
ed i
n on
site
la
ndfi
lls.
Cr . —
NA
; no
was
tes,
Tid
e 22
, Div
isio
n 4.
5,
Sect
ion
6626
4.25
0 -
6626
4.25
9
App
licab
le
NA
; no
was
tes
pile
s.
See
Alte
rnat
ive
75,
Will
mee
t A
RA
R b
y co
mpl
ying
with
regu
latio
ns.
Rel
evan
t on
ly i
f te
mpo
rary
st
orag
e of
RC
RA
was
te
in p
iles
occu
rs.
Sec
Alte
rnat
ive
75.
See
Alte
rnat
ive
75.
Was
te C
lass
ific
atio
n an
d M
anag
emen
t T
ide
23, D
ivis
ion
3,
Cha
pter
15,
Art
icle
2,
Sect
ion
2522
App
licab
le
NA
; no
was
tes
gene
rate
d N
A;
no w
aste
s ge
nera
ted
AltA
R w
ill b
e m
et;
non
haza
rdou
s w
aste
will
be
disp
osed
of a
s
desi
gnat
ed w
aste
See
Alte
rnat
ive
7S
See
Alte
rnat
ive
7S
C-2
6
a a
Con
tinue
d
TA
BLE
C13
Si
ri 3
4 S
uiuc
tcr:
SO
IL.
CoM
IU4A
'rIV
E A
NA
LYS
IS O
F C
OM
PLI
AN
CE
WIT
H L
OC
AT
ION
—S
PE
CIF
IC
AM
) A
C'F
ION
SP
EC
IFIC
A
RA
RS
Req
uire
men
t
-
Sour
ce
- -
-
App
licab
le,
Rel
evan
t an
d A
ppro
pria
te,o
r -
To-
be-c
onsi
dere
d -
(TB
C)
Alte
rnat
ive 2
S L
imite
d Act
ion
..
Alte
rnat
ive
55
Exc
avat
ion
and
Low
-
Tem
pera
ture
The
rmal
D
esor
ptio
n
Alte
rnat
ive
75
Exc
avat
ion a
nd O
ffsi
te
Tre
atm
ent
-
Alte
rnat
ive 8
S E
xcav
atio
n and
Ons
ite
Con
solid
atio
n
Alte
rnat
ive
115
Es-
Situ
B
iore
ined
iatto
n
AC
FIO
N-S
FE
CW
IC (C
ontin
ued)
Dis
char
ges
of W
aste
to
Lan
d (S
oil
Dis
posa
l)
Titl
e 23
, D
ivis
ion
3,
Cha
pter
15
Rel
evan
t and
App
ropr
iate
N
A;
no d
isch
arge
s w
ilt
occu
r.
NA
; no
disc
harg
e of
w
aste
will
occ
ur,
NA
; no
ons
ite
disc
harg
es w
ill o
ccur
, A
RA
R w
ill b
e m
et:
non-
haza
rdou
s so
ils w
ill
be c
over
ed by
a c
ap.
NA
: no
dis
char
ge o
f w
aste
will
occ
ur.
Sout
h C
oast
Air
Qua
lity
Man
agem
ent
Dis
tric
t R
ules
and
Reg
ulat
ions
• Fu
gitiv
e D
ust
Proh
ibito
iy R
ules
, Rul
e 40
3 A
pplic
able
N
A: n
o ex
cava
tion
will
oc
cur,
Se
e A
ltern
ativ
e 'iS
. C
ompl
ianc
e w
in o
ccur
by
con
trol
ling
fugi
tive
dust
to l
evel
s of
<50
pg
/rn3
See
Alte
rnat
ive
75.
See
Alte
rnat
ive
75.
• N
ew S
ourc
e R
evie
w o
f C
arci
noge
nic
Air
C
onta
min
ants
Rul
e 14
01
App
licab
le
\
NA
; no
em
issi
ons.
W
ill m
eet
AR
AR
; em
issi
ons
of P
Al-
Is w
ill
be b
elow
I >
< 1
0 ri
sk
leve
l st
ated
in th
e ru
le;
cont
rols
will
not
be
requ
ired
.
Not
App
licab
le.
Not
App
licab
le.
See
Alte
rnat
ive
5S. cs
i , —
C, ,
Key
: A
ltAR
=
A
pplic
able
or R
elev
ant
and
App
ropr
iate
Req
uire
men
t R
CR
A
=
Res
ourc
e C
onse
rvat
ion
and
Rec
over
y A
ct
PAH
=
P
olyn
ucle
ar
Aro
mat
ic H
ydro
carb
on
NA
=
N
ot a
n App
licab
le o
r Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
pg/r
n'
Mic
rogr
ams
per c
ubic
met
er
Alte
rnat
ives
is n
o lo
nger
a vi
able
alte
rnat
ive
C-2
7
b T
AI;1
i C
-I-i
Si
n 34
SIt
suR
ncir
. Son
. C
ON
II'A
RA
'FIV
E A
N:tI
.VSI
S ()
I' C
0MI'I
IAN
CE
Wili
l 1.O
CA
T1O
NSI
'EC
IFIC
.\N
1) A
CT
ION
—SP
EC
IHU
AR
AIt
s
Req
uire
men
t So
wce
A
pplic
able
, R
elev
ant a
nd
App
ropr
iate
, or T
o-be
'- co
nsid
ered
(TB
C)
Alte
rnat
Ive
28
Lim
ited A
ctio
n A
ltern
ativ
e 10
8 8i
oven
ting
Alte
rnat
Ive
125
Soil
Vap
or E
xtra
ctio
n w
ith
Cat
alyt
ic O
xida
tion
Alte
rnat
ive
135
Soil
Vap
or E
xtra
ctio
n w
ith
Puni
s PA
DR
E"
Syst
em
AC
flON
-SP
EcW
IC
Cal
iforn
ia H
azar
dous
W
aste
Rul
es
• S
tand
ards
App
licab
le
to G
ener
ator
s of
H
azar
dous
Was
te
Titl
e 22
, D
ivis
ion
4.5,
C
hapt
er 1
2, S
ectio
n 66
262
et s
eq.
App
licab
le
NA
; no
was
te g
ener
ated
. N
A;
no w
aste
gen
erat
ed.
NA
; no
was
te g
ener
ated
. W
ill m
eet
AR
AR
. R
esid
ue
win
be
hand
led
and
disp
osed
of
as
haza
rdou
s w
aste
if
it m
eets
cla
ssifi
catio
n crit
eria
. W
aste
Cla
ssifi
catio
n an
d
Man
agem
ent
Titl
e 23
, D
ivis
ion
3,
Cha
pter
15
, A
rtic
le 2
, S
ectio
n 25
22
App
licab
le
NA
; no
was
tes
NA
; no
was
tes
NA
; no
was
tes
Res
idue
will
be
hand
led
and
disp
osed
of
as
desi
gnat
ed
was
te, if
it is
non
haz
ardo
us
Sou
th C
oast
Air
Qua
lity
Man
agem
ent
Dis
tric
t R
ules
Reg
ulat
ions
:
• N
ew S
ourc
e R
evie
w o
f C
arci
noge
nic
Air
Con
tam
inan
ts
• N
ew S
ourc
e R
evie
w
of A
ir C
onta
min
ants
Pro
hibi
tory
Rul
es -
Rul
e 14
01
App
licab
le
NA
; no
em
issi
ons.
N
A;
no s
igni
flcan
t em
issi
ons,
W
ill m
eet
AR
AR
; ris
e fr
om
emis
sion
s of
BT
EX
will
be
belo
w I >
< 1
0' ri
sk le
vel s
tate
d in
ni
le;
addi
tiona
l co
ntro
ls
will
not
be r
equi
red.
See
Atte
rnat
ive
128.
Reg
ulat
ion
XLI
I; R
ule
1303
A
pplic
able
N
A;
no e
mis
sion
s.
NA
: no
sig
nific
ant
emis
sion
s,
Will
m
eet
AR
AR
, ai
r em
issi
ons
with
co
ntro
ls
will
be
be
low
the
I
poun
dfda
y th
resh
old
See
Alte
rnat
ive
125.
Key
: A
RA
R
=
App
licab
le or
Rel
evan
t an
d A
ppro
pria
te R
equi
rem
ent
RC
RA
=
R
esou
rce
Con
serv
atio
n an
d R
ecov
ery
Act
C
ii B
TE
X
=
Ben
zene
, T
olue
ne, E
thyl
benz
ene,
an
d X
ylen
es
NA
N
ot a
n A
pplic
able
or R
elev
ant
and
App
rnpr
iate
Req
uire
men
t
0)
01
C-2
8
544 165
•
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544 167
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