PB96-964506
EPA/ROD/R09-96/148
August 1996
EPA Superfund
Record of Decision:
March Air Force Base, Operable Unit 1,
Area 5 and Site 4, Riverside County, CA
6/20/1996
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MARCH AIR FORCE BASE
OPERABLE UNIT #1
RECORD OF DECISION
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TABLE OF CONTENTS
Section Page No.
1.0 Site Name, Location, & Description 1-1
1.1 Location 1-1
1.2 Population 1-1
1.3 Land Use 1-1
1.4 Climate 1-1
1.5 Geology 1-1
1.6 Soil 1-1
1.7 Surface Water and Wetlands 1-1
1.8 Hydrogeology 1-3
1.9 Water Use and Well Inventory 1-3
1.10 Threat of Site 1-5
2.0 Site History & Enforcement Activities 2-1
2.1 Sites With No Further Action Planned 2-4
2.2 Sites Requiring Soil Remediation 2-4
2.3 Sites Requiring Groundwater Remediation 2-5
3.0 Highlights of Community Participation 3-1
4.0 Scope & Role of Operable Unit 4-1
5.0 Summary of Site Characteristics 5-1
5.1 Geology and Aquifer Characteristics 5-1
5.2 Groundwater Contamination 5-1
5.2.1 Organic Contaminants 5-4
5.2.2 Inorganic Contaminants 5-4
5.3 Soil Contamination 5-5
6.0 Summary of Site Risks 6-1
6.1 Chemicals of Potential Concern 6-1
6.2 Exposure Assessment 6-1
6.3 Toxicity Assessment 6-2
6.4 Risk Characterization and Conclusions 6-2
6.5 Cleanup Standards and Goals 6-9
6.5.1 Groundwater Cleanup Standards and Goals 6-9
6.5.2 Soil Cleanup Standards and Goals 6-10
6.5.2.1 Surface Soil Cleanup Standards and Goals 6-10
6.5.2.2 Subsurface Soil Cleanup Standards and Goals 6-21
6.5.2.3 Summary of Soil Cleanup Standards and Goals 6-26
7.0 Description of Alternatives 7-1
7.1 Remedial Alternatives for Groundwater 7-1
7.2 Remedial Alternatives for Soil 7-6
8.0 Summary of Comparative Analysis of Alternatives 8-1
8.1 Comparative Analysis of Alternatives 8-2
8.1.1 Groundwater 8-2
8.1.2 Soil 8-16
9.0 Selected Remedies 9-1
9.1 Groundwater 9-1
9.2 Soil 9-4
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TABLE OF G()SrrENTS CONI!NBED
10.0 Statutory Determinations 10-1
10.1 Groundwater 10-1
10.2 Soil 10-3
11.0 Documentation of Significant Changes 11-1
Appendix A Responsiveness Summary
Appendix B Administrative Record Index
Appendix C ARAR Tables
in
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LIST OF FIGURES
Figure Page No.
1-1 Location of March AFB 1-2
1-2 Locations of Past or Existing Wells in Ferris Valley near March AFB, California 1-4
2-1 Areas to be Retained by March Air Force Base 2-2
2-2 Location of Operable Unit 1 Sites 2-3
2-3 Locations of Groundwater Contaminant Plumes in OU1 2-6
4-1 OUs and IRP Sites 4-2
5-1 Locations of Groundwater Contaminant Plumes in OU1 5-2
6-1 Site 4 Surface Soil Contamination 6-15
6-2 Site 10 Surface Soil Contamination 6-17
6-3 Site 15 Surface Soil Contamination 6-18
6-4 Site 31 Surface Soil Contamination 6-20
6-5 Site 34 Surface Soil Contamination 6-22
6-6 Site 18 Subsurface Soil Contamination 6-23
6-7 Site 31 Subsurface Soil Contamination 6-24
6-8 Site 34 Subsurface Soil Contamination 6-25
6-9 Decision Tree for Vadose Zone Cleanup 6-27
LIST OF TABLES
Table Page No.
5-1 Groundwater Contaminants 5-3
5-2 Surface Soil Contaminants Exceeding EPA Region IX PRGs 5-6
6-1 Summary of GUI Risk 6-4
6-2 Groundwater Cleanup Standards 6-11
6-3 Concentrations of Surface Soil Contaminants Exceeding EPA Region IX PRGs 6-13
6-4 Cleanup Goals for Chemicals in Soil that Require Remediation 6-28
8-1 Comparative Ranking of Remedial Alternatives for Groundwater - Site 4/OU1 Groundwater Plume
March Air Force Base 8-3
8-2 Comparative Ranking of Remedial Alternatives for Soil - Site 4 March Air Force Base 8-4
8-3 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 10 March Air Force
Base 8-5
8-4 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 15 March Air Force Base . 8-6
8-5 Comparative Ranking of Remedial Alternatives for Groundwater - Site 18 March Air Force
Base 8-7
8-6 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 18 March Air Force
Base 8-8
8-7 Comparative Ranking of Remedial Alternatives for Groundwater - Site 31 March Air Force
Base 8-9
8-8 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 31 March Air Force
Base 8-10
8-9 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 31 March Air Force
Base 8-11
8-10 Comparative Ranking of Remedial Alternatives for Surface Soil - Site 34 March Air Force
Base 8-12
8-11 Comparative Ranking of Remedial Alternatives for Subsurface Soil - Site 34 March Air Force
Base 8-13
IV
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OF DECISION
SITE NAME AND LOCATION
Operable Unit 1
March Air Force Base
Riverside County, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial actions for Operable Unit (OU) 1 at March Air
Force 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 Contingency
Plan (NCP). This decision is based on information contained in the Remedial Investigation/Feasibility
Study (RI/FS) report dated July 1994 and the administrative record for March AFB and complies with
40 Code of Federal Regulations (CFR), Part 300.
The U.S. Air Force (Air Force), has selected remedies in concurrence with the U.S. Environmental
Protection Agency (USEPA) Region IX, and the State of California.
ASSESSMENT OF THE SITES
The purpose of this ROD is to set forth the remedial actions to be conducted to remediate soil and
groundwater contaminated with polycyclic aromatic hydrocarbons (PAHs) and volatile organic compounds
(TCE, PCE) beneath OU1 and adjacent off-base areas.
Actual or threatened releases of hazardous substances from OU1, if not addressed by implementing the
response 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 plume
of contaminated groundwater. Eight of the sites have no further action planned by the Air Force based
on the results of a risk assessment performed as part of the OU1 Remedial Investigation. No further
action is planned for Sites 5, 7, 9, 13, 14, 16, 29, and 38 by the Air Force and in concurrence with the
USEPA, 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 2.0
of 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 this
evaluation, the following cleanup methods have been selected:
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Soil Cleanup
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. The
preferred cleanup method for soils and solid wastes at Site 4 is closure of the landfill in accordance with
California regulations (Title 23, Chapter 15, Article 8). This will include installation of a cap over the
landfill, protection of the cap from erosion, long-term maintenance of the cap, and groundwater
monitoring.
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 low
temperature thermal desorption.
Site 15. At Site 15 a small volume of surface soil is contaminated with PAHs and requires cleanup. The
preferred 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 preferred
method of cleanup for the soils is soil vapor extraction (SVE). Soil will be treated by extracting vapors
from the same wells used to extract contaminated groundwater (see Site 18 groundwater plume).
Extracted vapors will be treated at the surface using the Purus PADRE system.
Site 31. For PAH surface soil contamination at Site 31, the preferred method of cleanup is excavation
and low temperature thermal desorption. The preferred method for cleanup of subsurface soils
contaminated with trichloroethene (TCE) at Site 31 is SVE with carbon adsorption. Soil vapors will be
extracted 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 PAHs and the preferred method of cleanup is
excavation and low temperature thermal desorption. Subsurface soils at Site 34 are contaminated with
fuels. The preferred method for cleanup of the soils is bioventing. Bioventing consists of injecting
oxygen (air) into the soil to stimulate the growth of hydrocarbon degrading microbes. These microbes
use the hydrocarbons as an energy source and break them down into nonhazardous compounds.
Groundwater
The occurrence of groundwater contaminants is discussed within the context of "plumes" of contaminants
that share a 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 as an entity, without consideration for site boundaries. Four plumes have been
identified: The OU1 groundwater plume, the Site 4 groundwater plume, the Site 18 groundwater plume,
and the Site 31 groundwater plume.
OU1 Groundwater Plume. The OU1 groundwater plume extends from the area of Site 31 to the south
and east and offbase. The preferred method for cleanup of the plume is to withdraw groundwater using
extraction wells and treat the groundwater using liquid phase GAC adsorption to remove TCE and related
compounds. The groundwater extraction system will use existing extraction wells located along the
eastern base perimeter, supplemented with additional wells to assure complete containment of that portion
of the plume presently underlying the base. Groundwater from the OU1 groundwater plume will be
combined with groundwater from Site 4 for treatment. Treated water will be discharged either to the base
wastewater treatment plant, to the Heacock Storm Drain or reinjected into the aquifer. In accordance
with California Health and Safety Code Section 25230, deed restrictions will be implemented as an
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institutional control to prohibit the installation of wells to restrict groundwater use in onbase contaminated
areas, until groundwater cleanup standards have been achieved in onbase contaminated areas.
Groundwater monitoring will be conducted to ensure that migration of the plume offbase has stopped,
that offbase water supplies are not threatened, and that the concentrations of contaminants offbase are
decreasing. If contaminant concentrations in offbase portions of the plume do not decrease or migration
has not stopped, the Air Force will take action to cleanup these portions of the plume, including
installation of offbase extraction wells as necessary. Groundwater monitoring will be conducted to ensure
that the onbase portion of the plume does not migrate offbase, to ensure that the maximum concentration
of offbase contaminants continues to fall, and to ensure that the offbase plume does not threaten offbase
water supplies.
Site 4 Groundwater Plume. The preferred method for cleanup is to withdraw water using extraction
wells 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 with
groundwater from the OU1 groundwater plume for treatment. Treated water will be discharged either
to the base wastewater treatment plant, to the Heacock Storm Drain or reinjected into the aquifer. In
addition, 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 offbase water
supplies.
Site 18 Groundwater Plume. The groundwater at Site 18 is contaminated with jet fuel and its
components. The preferred method of groundwater cleanup is total fluids recovery followed by oil/water
separation. Groundwater and jet fuel will be removed using extraction wells_and free-phase product will
be recovered for recycling. Contaminated groundwater will be treated by air stripping to remove volatile
contaminants, 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 Storm
Drain.
Site 31 Groundwater Plume. Site 31 is a likely source for much of the TCE found in the groundwater
beneath 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 remove
TCE and related compounds. Treated water will be discharged to the base wastewater treatment plant
or 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, 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 solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable and satisfy the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume of contaminants as a principal element. For remedies that do
not achieve numerical cleanup goals within five years, a review of implemented technologies will be
conducted to ensure that the remedies continue to provide adequate protection of human health and the
environment.
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 solutions
and alternative treatment technologies to the maximum extent practicable and satisfy the statutory
preference for remedies that employ treatment that reduces toxicity, mobility, or volume of contaminants
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as a principal element. Since the selected remedies for these sites will result in permanent destruction
of 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, complies
with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. However, because treatment of the principal site
contaminants was not found to be practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element. Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted within five years after commencement of
the remedial action, and at each five year period in the future to ensure that the remedy continues to
provide adequate protection of human health and the environment.
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©19096553449
AFBCA-March AFB
06/20/96 09:45 P.002
This Record of Decision (ROD) presents the selected remedial actions for Operable Unit 1 (OU1), March
Air Force Base, California, developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executed
and delivered shall be deemed to be an original, but such counterparts shall together constitute one and
the same document.
Signature ' United States Air Force
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This Record of Decision (ROD) presents the selected remedial actions for Operable Unit 1 (OUI), March
Air Force Base, California, developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executed
and delivered shall be deemed to be an original, but such counterparts shall together constitute one and
the same document.
Signature
Julie Anderson, Director, Federal Facilities Compliance
Branch, USEPA, Region IX
Date
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This Record of Decision (ROD) presents the selected remedial actions for Operable Unit 1 (OU1), March
Air Force Base, California, developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA),
This ROD may be executed and delivered in any number of counterparts, each of which when executed
and delivered shall be deemed to be an original, but such counterparts shall together constitute one and
the same docdffient.
Signature
John E. Scandura, C$def of Operations
Southern California Office of Military Facilities
Department of Toxic Substances Control
Date '
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This Record of Decision (ROD) presents the selected remedial actions for Operable Unit 1 (OUI), March
Air Force Base, California, developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
This ROD may be executed and delivered in any number of counterparts, each of which when executed
and delivered shall be deemed to be an original, but such counterparts shall together constitute one and
the same document.
Signature (I Date
Gerard J. Thibeault, Executive Officer, California Regional
Water Quality Control Board, Santa Ana Region
Xll
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1.0 SITE NAME, LOCATION, & DESCRIPTION
1.1 LOCATION
March Air Force Base (AFB) is located in the northern end of the Ferris Valley, east of the city of Riverside, in
Riverside County, California. The base is approximately 60 miles east of Los Angeles and 90 miles north of San
Diego (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- and
spanish-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 industrial
areas are located to the north. Agriculture is located to the east and south. Residential areas are located in all
directions 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 varies
according to elevation and distance from the Pacific Ocean. The weather generally consists of warm to hot, dry
summers and mild winters.
1.5 GEOLOGY
The Main Base lies in the Perris Valley where alluvium is found at the surface. The Perris Valley is characterized
as a broad, nearly flat surface dotted with bedrock hills. The numerous bedrock hills that interrupt this flat surface
are described as erosional remnants of the underlying crystalline basement rocks. Surficial alluvial deposits are
composed of alternating layers of varying amounts of clay, silt, sand, and gravel. In general, the deposits consist
of silty sand and sandy silt with varying amounts of clay. Based on drilling information to date, thickness of the
alluvial deposits ranges from zero to over 150 feet.
1.6 SOIL
Two major soil associations exist in the March AFB area: the Cieneba-Rockland-Fallbrook association and the
Monserate-Arlington-Exeter association. The Cieneba-Rockland-Fallbrook association is derived from granitic rock
and occurs on the western portion of the base. These soils are typically 1 to 3 feet thick, have a surface layer of
sandy loam to fine sandy loam, are well drained, are coarse- to medium-grained, and have slopes ranging from 2
to 50 percent. The Monserate-Arlington-Exeter association is derived from granitic alluvium and occurs on the
eastern portion of the base. These soils have a surface layer of sandy loam to loam, are well drained, are fine- to
medium-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 two
permanent surface water bodies within 3.5 miles of March AFB. Lake Perris, located 4 miles southeast of the base,
provides approximately 130,000 acre feet of storage for State Project Water brought in by the California Aqueduct
which runs north and east of the base. An east-west portion of the Colorado River Aqueduct is located
approximately 3.5 miles south of the base. This aqueduct flows into Lake Matthews, which is located about 10
1-1
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March Air Force Base, California
Location of March AFB
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miles west of March AFB. A very small recreation lake is located approximately 2 miles east of the Base. It is
maintained by the Moreno Valley Ranch homeowners association and is located just south of Iris Street and west
of 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 the base. Most are
located on West March, outside OU1. The U.S. Army Corps of Engineers (USAGE) has performed a delineation
of jurisdictional wetlands associated with the Cactus and Heacock flood control channels (USAGE, 1992). Although
these are artificial channels excavated in uplands, they act as ephemeral streams, support some scattered wetland
vegetation and are considered waters of the United States. The USAGE determined that approximately 2.17 acres
of jurisdictional wetlands exist in the Heacock Storm Drain channel with 0.8 acres of wetlands adjacent to the Site
4 landfill. The wetlands are not continuous but are localized patches of wetland vegetation that change position each
year due to the high volume, high velocity storm water flow from the spring rains through these channels which
causes scouring of the earthen bottom and sides.
1.8 HYDROGEOLOGY
The Main Base is located in the Ferris Valley where coarse-grained alluvial deposits form the main aquifer. These
deposits are highly permeable and capable of yielding large amounts of water under unconfmed conditions. Based
on 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 general
stratigraphy consists of silty sands and sandy silts from the surface to depths of approximately 50 feet below ground
surface (bgs). Below a depth of approximately 50 feet bgs, boring logs from OU1 reveal highly permeable clean
sands ranging in thickness from a few inches to tens of feet alternating with relatively impermeable clays, silts, and
silty 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 by
a mantle of fractured and weathered rock. Water-bearing properties of the weatfiered 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 Ferris Valley south, east, and north of March AFB. These wells have been used for
industrial, agricultural, and domestic water supplies. Figure 1-2 shows the locations of existing and abandoned
wells for which data are available through the Eastern Municipal Water District and the California Department of
Water Resources. Several water wells are also located southwest of March AFB in Mead Valley. It is possible
that 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 were
formerly used for the base water supply. BPW-2, which was located just north of BPW-3 in the middle of Building
100, 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 Road
and Meyer Drive. Use of BPW-3 and BPW-4 was discontinued in July 1978 because yields from these wells were
not sufficient to meet water supply demands. Although BPW-1 has not been abandoned, it has not been used as
a 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 wells
were drilled in areas of greater aquifer thickness and permeability than the on-base production wells. These wells
are located in the center of Perns 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 the
Eastern Municipal Water District. The Final Installation Restoration Program, Remedial Investigation/Feasibility
Study Report for Operable Unit 1, published in July 1994 provides detailed well characteristics for each of the wells
shown in Figure 1-2.
1-3
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Explanation
Existing Well Location
O Abandoned Well Location
No Information Available
Base Boundary
0 1 Mile
Scale
North
March Air Force Base, California
Locations of Past and Existing Wells
In Ferris Valley near March AFB,
California
9-95
c'jre 1-2
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1.10 THREAT OF SITE
Base operations have resulted in contamination of soil and groundwater at a number of sites within OU1.
Contaminants include chlorinated solvents, fuels, and polycyclic aromatic hydrocarbons (PAHs). The selected
remedy for each site addresses the principal threat from contaminants found at that site.
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2.0 SITE HISTORY & ENFORCEMENT ACTIVITIES
March AFB is located on 7,123 acres in the northern end of the Ferris Valley, east of the City of Riverside, and
south of the City of Moreno Valley in Riverside County, California. The base is approximately 60 miles east of
Los 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 Alessandro
Aviation Field, was initially used to train "Jenny" pilots during World War I. Following World War I, the base
closed for about four years, then reopened in 1927. By 1938, March AFB was considered to be the central location
for 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 an
Air Mobility Command installation. Its primary mission is air refueling but reserve and guard units have cargo and
fighter missions as well.
In September 1993, March AFB was designated by Congress to realign its forces. Active duty Air Force personnel
and aircraft will transfer to Travis AFB, California, by March 1996. Air Force Reserve and Air National Guard
units will remain at March, and the base will be redesignated "March Air Reserve Base." In addition, the base is
expected to decrease to about one-third of its present size. After the base realignment, property that is not retained
by the base will be available for transfer to the local community. Figure 2-1 shows the base as it is today, with
areas 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 of
operations that involve the use, storage, and disposal of hazardous materials. In 1980, the Installation Restoration
Program (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 have
generated a variety of hazardous wastes. Past waste disposal practices have resulted in contamination of soil and
groundwater at several areas onbase. The March AFB IRP process began in September of 1983. Six studies have
been completed at March AFB in support of the IRP. The initial study consisted of employee interviews and
reviewing aerial photographs and base records. The records search identified 30 potentially contaminated sites for
further investigation. A second study, completed in March 1987, consisted of the collection of soil, water, and soil
gas samples. This study indicated that further investigation was needed at 5 of the 30 sites to determine the type
and extent of contamination in the soil and groundwater. In June 1987, further investigation was conducted. This
investigation indicated that additional work was required to better define the extent of soil and groundwater
contamination 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 the
presence of contamination in groundwater beneath the base. The NPL is a list of sites that are considered by the
USEPA 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 California
to establish procedures for involving Federal and state regulatory agencies and the public in the March AFB
environmental restoration process. Three separate OUs were created in order to facilitate the environmental
restoration 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 OU2. The
latest investigation at OU1 was performed from November 1991 to November 1993. The overall objectives of the
investigation were to collect additional data to confirm contaminant source areas, better define contamination
boundaries, assess potential risks to human health or the environment, and evaluate the feasibility of different
remedies at OU1 sites. Groundwater at Site 4, Site 18, Site 31 and within the OU1 groundwater plume and soil
at Sites 4, 10, 15, 18, 31, and 34 require remedial action. Descriptions of the sites are presented below.
2-1
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,-J
Current base boundary
Combat camera
Telephone switch
i i
j
||i] HF antenna facility
,-J
Explanation
i I Area to be retained
3000 6000 Feet
MM
Scale
2-95
2-2
March Air Force Base, California
Areas to be Retained
by March Air Force Base
Figure 2-1
-------
8
2400
Scale
4800 Feet
2-3
March Air Force Base, California
Location of
Operable Unit 1 Sites
9-95
Figure 2-2
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\
2.1 SITES WITH No FURTHER ACTION PLANNED
Based 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 primarily
of 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 pits
were identified in historic aerial photographs of the Base. A portion of this site may have been used for crash
rescue training. Wastes used in training exercises reportedly included contaminated fuel, waste solids, and spent
solvents.
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 the
flightline 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 construction
with a large baffle that divides the separator into two compartments. The separated oil is picked up by a skimmer
and pumped to a holding tank for off-base disposal. This facility drains into the Flightline Drainage Channel (Site
10) and then to the Ferris 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 northern
portion of Site 5. In 1973, approximately 5,000 gallons of JP-4 jet fuel spilled from a tank truck to the ground at
this location. The accidental discharge resulted from a mechanical malfunction. There was no reported spill
containment 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 Building
1245. The spill was contained in the unpaved area south of the pump station and allowed to percolate into the
ground.
Site 16 (East March Sludge Drying Beds). Site 16 is located on the eastern part of the Base, at the south end of
the flight line parking apron, and near the former East March Wastewater Treatment Plant. The treatment plant
was constructed in 1938 and provided secondary treatment for sanitary and industrial waste-water. Primary and
secondary 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 industrial
wastes to the sanitary sewer system. These drying beds operated from 1938 to 1977, when the plant was destroyed
in place.
Site 29 (Fire Training Area No.l). Site 29 is located on the eastern part of the Base, north of Site 9. The area
was used as a fire training pit prior to 1951. Suspected contaminants at the site include contaminated fuel, waste
oil, and spent solvents.
Site 38 (PCB Contamination, Building 1311). Building 1311 is located at the southeast end of the taxiway,
northwest of IRP Site 23. In 1984, soils from four areas contaminated with transformer oils were sampled. Soils
from two of the areas (Buildings 317 and 1305) were determined to be PCB-contaminated. The soils were
excavated and removed from the Base. Records to verify the cleanup have not been located.
2.2 SITES REQUIRING SOIL 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 feet
deep, containing primarily sanitary waste, construction rubble, and debris. Small amounts of medical wastes and
empty fuel containers are also present. RI sampling data indicated the presence of very low concentrations of
2-4
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chlorinated solvents in soils and soil gas beneath the site. A groundwater monitoring well situated in the southeast
comer of the site has consistently contained elevated concentrations of tetrachloroethene (PCE) and TCE. Both PCE
and TCE are found in solvents which were used to clean and degrease military equipment. In addition, vinyl
chloride 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 1960s) up to the eastern boundary of the base
where it discharges to the Penis Valley Storm Drain. The Penis Valley Storm Drain flows east approximately 2
miles, where it joins another drainage and flows south approximately 6 miles to the San Jacinto River. Prior to
1974, wastes disposed of in the drainage channel may have been discharged directly to the Ferris Valley Storm
Drain. Since 1974, the main oil/water separator (Site 9) has pretreated the runoff before its discharge offbase.
Primary contaminants of concern are PAHs, which were detected in drainage ditch sediments. PAHs are a series
of 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 and
between Sites 5 and 7 (Figure 2-2). The area was developed in 1978 and was reportedly constructed by placing
an 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 pond
located adjacent to Site 15. Approximately 6,000 gallons per year of contaminated JP-4 have been bumed in
training exercises since the facility was constructed in 1978. This site is no longer being used as a fire training
area. The primary 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 cell
was 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 base
wastewater 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 wells
installed to date. Potential source(s) of the fuel include overflow of tanker trucks and fuel tanks on aircraft that
have 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-1950s
to 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 water
standards.
Site 34 (Pritchard Aircraft Fueling System). Site 34 is located next to Building 1245, at the southeast end of
Taxiway No. 1 (Figure 2-2). In 1962, six 50,000-gallon tanks were moved to this site from the Panero Fueling
System. During a geological investigation (July 1988) for a construction project just south of the site, stained soils
and fuel odors were observed. In 1990, use of this system was discontinued, and in 1991, the tanks and system
were removed.
2.3 SITES REQUIRING GROUNDWATER REMEDIATION
The occurrence of groundwater contaminants is discussed within the context of "plumes" of contaminants that share
a 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 as
an 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).
2-5
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North
Approximate Boundary
of Site 4 and OU1
Groundwater Plume
OU1 Groundwater Plume
8
-------
OU1 Groundwater Plume. The OU1 groundwater plume is the most widespread plume at the base, extending from
Site 31 south and east through the area of Sites 34, 9, and 5, and extending to a maximum of approximately 1300
feet 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 /ig/1 in monitoring well
31 -PW1 at Site 31 on base and 42 /ig/1 in monitoring well 5-MW11 300 feet southeast of Site 5, off base. The
following contaminants were also detected above cleanup standards: bis(2-ethylhexl)phthalate (maximum 130/ig/l);
1,1-dichloroethene (maximum 260 /tg/1); benzene (maximum 420 /^g/1); carbon tetrachloride (maximum 3/ig/I);
cis-1, 2-dichloroethene (maximum 30 /ig/1); methylene chloride (maximum 45 /ig/1); tetrachloroethene (PCE),
(maximum 19/ig/l); 1,2-dichloroethane (maximum 25 /ig/1) and total phenols (maximum 79 /ig/1).
Site 4 Groundwater Plume. This plume is localized in the vicinity of Site 4 with the apparent source area near
the 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 18 with the apparent source area west
of the engine test cell in the center of Site 18 (Figure 2-3). Fuel has been detected in four of 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 been parked on the site in the past.
Site 31 Groundwater Plume. Concentrations of contaminants at Site 31 (primarily TCE) are much higher than
those in the rest of the OU1 plume, and these high concentrations are confined to a relatively small area. These
conditions coupled with the history of Site 31 (reported solvent disposal) indicate that Site 31 is a likely source area
for much of the TCE found in OU1 groundwater. Therefore, even though the Site 31 plume has the same
contaminants and is contiguous with the OU1 plume, it is appropriate to treat Site 31 separately from the remainder
of the OU1 plume, in order to eliminate the source of contamination.
2-7
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3.0 HIGHLIGHTS OF COMMUNITY PARTIGIPATION
The RI/FS report and Proposed Plan for OU1 were released to the public on April 28, 1994. These two documents
were made available to the public in the Administrative Record, the information repositories at the Moreno Valley
and March AFB libraries, and at the Moreno Valley Chamber of Commerce. The notice of availability of these
documents was published in the Press-Enterprise on April 27, 1994. A fact sheet, condensed from the Proposed
Plan, was sent to everyone on the March AFB mailing list, which includes Restoration Advisory Board (RAB)
members. An OU1 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 May
12, 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, Santa
Ana, 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 OU1 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 OU1 sites are based on the
Administrative 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(f)(3).
3-1
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4.0 SCOPE & ROLE OF OPERABLE UNIT
OUl represents one component of the comprehensive environmental investigation and cleanup program presently
being performed at March AFB. The investigations are being performed to comply with CERCLA and the Air
Force's IRP. As part of the comprehensive cleanup program, the Air Force is presently evaluating cleanup
alternatives as related to these IRP sites. Plans are currently being developed for the proper cleanup and closure
of all sources of soil and groundwater contamination that have been shown to pose unacceptable health or
environmental risks.
At March AFB, aircraft maintenance, fuel storage operations, fire-training exercises, and base operations have
generated a variety of hazardous wastes. Past waste disposal practices have resulted in contamination of soil and
groundwater at several areas on base. March AFB was added to USEPA's National Priorities List of hazardous
waste 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 were
created based on geographic location of sites, similarity of contaminants, and location of groundwater contaminant
plumes (See Figure 4-1). Sites included in each OU are as follows:
OUl. OUl encompasses Sites 4, 5, 7, 9, 10, 13, 14, 15, 16, 18, 29, 31, 34, and 38. Sites 21
and 23 were initially included in OUl, but were transferred to OU2. OUl also includes the off-
base plume area along the Eastern boundary of March AFB.
OU2. OU2 includes the remaining sites not in Operable Units 1 or 3. It includes all of the area
known as West March, the Hawes site, and the sites in the northern portion of the Main Base west
of 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.
OU3. OU3 consists of IRP Site 33 (Panero Aircraft Fueling System). Soils and groundwater
in OU3 have been contaminated by jet fuel.
OUl was created based on geographic location of sites, similarity of contaminants (primarily TCE) and commingling
of groundwater contaminant plumes migrating southeastward offbase. The scope of the operable unit includes
groundwater containing TCE and other compounds over the majority of OUl sites and offbase, groundwater
containing primarily PCE at Site 4, groundwater containing jet fuel at Site 18, and sources of these contaminants
in soils above the groundwater that have caused the plumes. The remedial investigation identified a possible source
for TCE contamination at Site 31 although other sites within the OUl groundwater plume area may be contributing
TCE 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 by
environmental contamination at the base.
4-1
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949032 IRP ROD
Site 41 (OU2) is located
19 miles east of Barstow, CA
Site35c Site 26a V///A site 26b
Q Site 20
S/(e 76
Site 29
Sita 5
Site 13
Source: USAF.1992
Explanation
Bass Boundary
Sita 28 (OU2) is a group of
monitoring wells spread across
the main base.
Site 32 (OU2) is composed of
several construction material
landfills not currently located.
IRP Sita in Operable Unit 1
IRP Site in Operable Unit 2
IRP Site in Operable Unit 3
nj
0 900 1800 3600 Ft.
March Air Force Base. California
OUs and IRP Sites
9-95
Figure 4-11
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5.0 SUMMARY OF SITE CHARACTERISTICS
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 are
discussed below.
5.1 GEOLOGY AND 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 300
feet in the southeast corner of OU1. Beneath the alluvial deposits granitic bedrock is present. A significant zone
of weathered bedrock overlies the competent bedrock. The weathered bedrock zone varies in thickness from a few
feet to 70 feet at Site 29. Depth to competent bedrock varies from a few feet bgs at site 18 to greater than 300 feet
bgs in the southeast corner of OU1, and the bedrock surface is undulating.
Below a depth of approximately 50 feet bgs, highly permeable clean sands ranging in thickness from a few inches
to tens of feet are found alternating with relatively impermeable clays, silts and silty sands. This zone of vertically
and laterally discontinuous sands is capable of yielding large amounts of water, but the amount of water yielded is
highly variable based on the thickness and permeability of the sand zones. The weathered bedrock zone beneath
the 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 considered
non-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 OU1. For a more
detailed discussion of the OU1 lithology and aquifer characteristics please refer to the March Air Force Base OU1
RI/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 share
a common source area, geographic distribution, and composition. Four plumes have been identified: OU1
groundwater plume, Site 4 groundwater plume, Site 18 groundwater plume, and Site 31 groundwater plume (Figure
5-1). Cleanup standards for groundwater are based on Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs). The rationale and approach used for establishing cleanup standards are presented in Section
6.0. The compounds that most frequently exceed applicable standards in groundwater in OU1 are chlorinated
hydrocarbons (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:
OU1 Groundwater Plume. The OU1 groundwater plume is the most widespread plume at the
base. It has been divided into the onbase OU1 groundwater plume, and the offbase OU1
groundwater plume. The onbase OU1 plume extends from Site 31 south and east through the area
of Sites 34, 9, and 5 and has TCE levels ranging from 1,400 /tg/1 at Site 31 to 76 /tg/1 at Site 5.
The offbase OU1 groundwater plume extends south and east from the Site 5 boundary with TCE
levels gradually decreasing to non-detect 2500 feet southeast of Site 5. The primary contaminants
are TCE and other chlorinated volatile hydrocarbons.
Site 4 Groundwater Plume. This plume is localized in the vicinity of Site 4 with the apparent
source area near the southern end of the landfill (Figure 5-1). The primary contaminants are PCE
and TCE.
5-1
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North
Approximate Boundary
of Site 4 and OU1
Groundwater Plume
OU1 Groundwater Plume
4000 Feet
5-2
9-95
March Air Force Base, California
Locations of Groundwater
Contaminant Plumes in OU1
Ron re 5-1
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TABLE 5-1
GROUNDWATER CONTAMINANTS
Plume
Site 4
Site 18
Site 31
GUI
Contaminant
Methylene Chloride
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Vinyl Chloride
Bis(2-ethylhexyl)phthalate
cis-l,2-Dichloroethene
Benzene
Toluene
Ethylbenzene
Methylene Chloride
Phenols, Total
Xylenes, Total
Bis(2-ethylhexyl)phthalate
1,1-Dichloroethene
Trichloroethene
Bis(2-ethylhexyl)phthalate
Benzene
Carbon Tetrachloride
Trichloroethene (TCE)
1,1-Dichloroethene
cis-1 ,2-Dichloroethene
Methylene Chloride
Tetrachloroethene (PCE)
1 ,2-Dichloroethane
Phenols, Total
Maximum
Concentration
Otg/i)
9
260
85
8
290
21
12,000
11,000
1,500
440
73
7,700
63
260
1,400
130
420
3
1,400
260
30
45
19
25
79
Note:
Key: jtg/1
RWQCB
MCL
Maximum concentrations are from the basewide
groundwater monitoring data as of Summer 1994.
= Micrograms per liter
= California Regional Water Quality Control
Board, Santa Ana Region
= Maximum Contaminant Level
5-3
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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 four
of 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 been
parked on the site in the past.
Site 31 Groundwater Plume. Concentrations of contaminants at Site 31 (primarily TCE) are much higher
than those in the rest of the OU1 plume, and these high concentrations are confined to a relatively small
area. These conditions coupled with the history of Site 31 (reported solvent disposal) indicate that Site 31
is a likely source area for much of the TCE found in OU1 groundwater. Therefore, even though the Site
31 plume has the same contaminants and is contiguous with the OU1 plume, it is appropriate to treat Site
31 separately from the remainder of the OU1 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 cleanup
standards. PCE was detected at a maximum concentration of 260 micrograms per liter (/ig/1), exceeding the cleanup standard
of 5 jig/I. TCE was detected at a concentration of 85 /tg/1, exceeding the cleanup standard of 5 /tg/1. Vinyl chloride was
detected at a concentration of 8 /tg/1, exceeding the cleanup standard of 0.5 /tg/1. Methylene chloride was detected at a
concentration of 9 /tg/1, exceeding the cleanup standard of 5 /tg/1. Bis (2-ethylhexyl)phthalate and cis-l,2-dichloroethene
were also detected at concentrations exceeding the cleanup standards of 4 /ig/1 and 6 /ig/1, respectively. The Site 4 plume
and 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 fuel
components. Benzene (12,000 /tg/1), toluene (11,000./ig/1), ethylbenzene (1,500 /ig/1), and total xylenes (7,700 /tg/1),
exceeded the respective cleanup standards of 1 /tg/1, 10 /ig/1, 10 /tg/1, and 10 /tg/1. Total phenols (73 /tg/1) exceed the
cleanup standard of 40 /tg/1. A methylene chloride concentration of 440 /tg/1 detected at site 18 was determined to be a
laboratory contaminant. Methylene chloride was detected in associated blanks and has not been historically detected at site
18.
For the OU1 groundwater plume, several organic contaminants exceeded applicable standards. The most widespread and
concentrated contaminant was TCE, detected at a maximum concentration of 1,400 /ig/1. This sample was collected at Site
31. Site 31 is a likely source area for TCE in the OU1 plume and therefore is treated separately. The maximum
concentrations 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 1,400
/ig/1. Bis(2-ethylhexyl)phthalate and 1,1-dichloroethene were also detected at maximum concentrations of 63 /ig/1 and 260
/ig/1, 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, most
of these metals do not require cleanup. Of these metals, thallium was the only metal detected above background levels, and
was only detected in the Site 18 plume. Thallium concentrations were determined by analytical method SW6010 (Inductively
Coupled 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 (detection
limit for thallium is reported as 0.100 mg/L). Therefore, the presence of thallium in the filtered samples but not in the
associated unfiltered samples suggests that the reported thallium values are an artifact of the analytical program, and thallium
was determined not to require cleanup.
. In addition to metals, other inorganic water quality criteria 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
exceeded in all four groundwater plumes as well as in OU1 background samples. The water quality objective for surfactants
was exceeded in the Site 4 and OU1 plumes. TDS is the subject of an ongoing basewide groundwater srudy. Insufficient
water quality data are currently available to determine cleanup requirements. A basewide groundwater monitoring program
5-4
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is currently being conducted. The results of this program will be included in the basewide ROD. The Basewide ROD will
address cleanup requirements of the water quality objectives for hardness, chloride, sulfate, and TDS.
5.3 SOIL CONTAMINATION
Concentrations of analytes detected in the surface soil (0- to 2-foot) interval were compared to Region IX Preliminary
Remediation Goals (PRGs). The PRGs 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 PRGs warrant further
evaluation. However, a contaminant concentration that exceeds a PRG does not necessarily indicate an unacceptable health
risk. In determining the cleanup standards and goals for OU1, both the results of the PRG comparisons and the results of
the 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 PRG
for that analyte. The following contaminants do not have a PRG: calcium, iron, magnesium, mercury, potassium, sodium,
benzo(g,h,i)perylene, phenanthrene, 2-methyInaphthalene, alpha-chlordane, gamma-chlordane, endosulfan sulfate, andendrin
aldehyde. For some of these contaminants, surrogates were applied. The PRG for anthracene, a noncarcinogenic
polynuclear aromatic hydrocarbon (PAH), was selected as a surrogate for benzo(g,h,i)perylene and phenanthrene, which are
also noncarcinogenic PAHs. The PRG for naphthalene was used for 2-methylnaphthalene. The PRG for chlordane was used
for alpha-chlordane and gamma-chlordane. The PRG for endosulfan was selected as a surrogate for endosulfan sulfate and
endrin was used for endrin 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 is
the most toxic of the dioxin isomers. However, California EPA has determined Toxicity Equivalency Factors (TEFs) that
consider the relative toxicity of each of the dioxin isomers. These TEFs were applied to the 2,3,7,8-TCDD PRG and the
maximum concentration of each dioxin detected at a site was compared to the modified PRG.
Table 5-2 presents maximum surface soil concentrations of site contaminants, where the maximum concentrations exceed
Region IX PRGs. The residential land use PRGs were used for all sites. The occurrence of soil analytes at each site are
discussed below:
Site 4. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (3,960.0-9,310.0 mg/kg), barium (73.4-117.0
mg/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 (5.0-10.9
mg/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-5.3 mg/kg), potassium (2,240.0-4,090.0 mg/kg), sodium (ND-175.0 mg/kg), vanadium (15.9-25.6
mg/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 PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (5,450.0-7,290.0 mg/kg), barium (83.7-159.0
mg/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 (6.9-10.0
mg/kg), iron (8,570.0-10,800.0 mg/kg), lead (ND-18.1 mg/kg), magnesium (2,540.0-3,400.0 mg/kg), manganese (203.0-
221.0 mg/kg), nickel (ND-4.7 mg/kg), potassium (2,570.0-3,010.0 mg/kg), vanadium (17.2-20.8 mg/kg), zinc (27.0-41.8
mg/kg), di-n-butyl phthalate (ND-0.56 mg/kg), fluoranthene (ND-0.41 mg/kg), DDE (ND-0.0088 mg/kg). and DDT (ND-
0.0041 mg/kg).
Site 7. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (4,020.0-10,000.0 mg/kg), barium (35.5-214.0
mg/kg), cadmium (ND-1.9 mg/kg), calcium (817.0-2,780.0 mg/kg), chromium, total (7.4-22.1 mg/kg). cobalt (2.4-8.1
mg/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-8.6
mg/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
5-5
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TABLE 5-2. SURFACE SOIL CONTAMINANTS EXCEEDING
EPA REGION IX PRGs
Site
4
5
7
Chemical
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)pery!ene
Chrysene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Bervllium
Beryllium
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Hexachlorinated dibenzo-p-dioxins, total
Beryllium
Lead
Manganese
9 1 Beryllium
10
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
13 | Beryllium
15
16
18
29
31
34
Benzo(a)pyrene
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Bervllium
Beryllium
Manganese
Beryllium
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Beryllium
Lead
Manganese
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Indeno(l,2,3-c,d)pyrene
Beryllium
Lead
Manganese
Benzo(a)anthracene
3enzo(a)pyrene
3enzo(b)fluoranthene
Maximum Site
Concentration (rag/kg)
5.5
8.7
14.0
20.0
9.7
4.2
21.0
0.39
0.27
0.00075
0.0013
0.0001
0.58
855.0
449.0
Region DC
Residential
PRG
: :. (mg/kg)
0.61
0.061
0.61
19"'
6.1°
0.061
0.61
0.14
0.14
0.0003811'
0.0003S01
0.000038'5'
0.14
130<:>
380
0.42 0.14
3.2
3.5
3.7
1.8
0.96
3.9
0.61
0.061
0.61
0.61
0.061
0.61
0.27 0.14
0.34
0.00095
0.0016
0.33
0.061
0.00038'3'
0.00038'3'
0.14
0.41 ! 0.14
654.0 380
0.45
0.00079
0.0014
0.66
246.0
554.0
0.96
1.0
1.5 j
0.85
0.79
311.0
610.0
0.14
0.0003S'3'
0.00038"'
0.14
130':i
380
0.61
0.061
0.61
0.61
0.14
130':i
380
5.8 0.61
3.2 0.061
4.9 0.61
5-6
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TABLE 5-2. SURFACE SOIL COINTAMINANTS EXCEEDING
EPA REGION IX PRGs
Site
34
38
Chemical
Indeno(l,2,3-c,d)pyrene
Beryllium
Beryllium
Maximum Site
Concentration (mg/kg)
2.2
0.28
0.29
Region K
Residential
PRG
(mg/k°)
0.61
0.14
0.14
(1)
(2)
(3)
A PRG was not available for this noncarcinogenic polynuclear aromatic hydrocarbon (PAH). The PRG for
anthracene, which is the most conservative PRG for the noncarcinogenic PAHs, was used as a surrogate.
The California EPA PRG was used for this chemical because it is more restrictive than the Region IX PRG.
2, 3, 7, 8-TCDD is the only dioxin for which Region IX has calculated PRGs (3.8E-06 for residential soil
and 2.4E-05 for industrial soil). Therefore, this PRG has been adjusted using a TEF (See Table 6-3 for a
listofTEFs.)
Key: PRG = Preliminary Remediation Goal
TEF = Toxicity Equivalency Factor
5-7
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mg/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-0.0115 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 of
concentrations) were detected at concentrations below the PRGs: aluminum (6,220.0-11,100.0 mg/kg), barium (97.6-129.0
mg/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 (8.5-17.4
mg/kg), iron (10,300.0-14,600.0 mg/kg), lead (ND-11.9 mg/kg), magnesium (3,220.0-4,370.0 mg/kg), manganese (230.0-
300.0 mg/kg), nickel (4.5-5.7 mg/kg), potassium (3,100.0-4200.0 mg/kg), sodium (ND-117.0 mg/kg), vanadium (22.5-28.3
mg/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 of
concentrations) were detected at concentrations below the PRGs: aluminum (1,610.0-1,790.0 mg/kg), barium (89.0-222.0
mg/kg), cadmium (ND-0.52 mg/kg), calcium (1,830.0-2,940.0 mg/kg), chromium, total (3.4-8.8 mg/kg), cobalt (1.8-2.2
mg/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 (5.6-6.7 mg/kg), zinc (31.1-57.1 mg/kg), bis(2-
ethylhexyl)phthalate (ND-1.5 mg/kg), benzo(g,h,i)perylene (3.1-3.6 mg/kg), benzo(k)fluoranthene (1.5-1.8 mg/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 rag/kg).
Site 13. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (for the one sample collected
at this site) were detected at concentrations below the PRGs: 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
(3,170.0 mg/kg), manganese (221.0 mg/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 of
concentrations) were detected at concentrations below the PRGs: aluminum (5,730.0-7,980.0 mg/kg), barium (29.7-108.0
mg/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 (7.3-15.1
mg/kg), iron (9,330.0-17,300.0 mg/kg), lead (ND-10.0 mg/kg), magnesium (3,000.0-5,170.0 mg/kg), manganese (160.0-
372.0 mg/kg), nickel (4.7-11.1 mg/kg), potassium (1,330.0-4,040.0 mg/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)perylene (ND-0.4 mg/kg),
chrysene (ND-0.41 mg/kg), fluoranthene (ND-0.38 mg/kg), indeno(l,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 of
concentrations) were detected at concentrations below the PRGs: aluminum (5,550.0-10,500.0 mg/kg), barium (106.0-172.0
mg/kg), cadmium (ND-0.76 mg/kg), calcium (1,490.0-10,400.0 mg/kg), chromium, total (6.2-27.6 mg/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 (17.3-38.8 mg/kg), zinc (21.3- 88.8 mg/kg), alpha-chlordane (ND-0.0031 mg/kg),
gamma-chlordane (ND-0.0041 mg/kg), ODD (ND-0.016 mg/kg), DDE (ND-0.0042 mg/kg), and DDT (ND-0.0098 mg/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 of
concentrations) were detected at concentrations below the PRGs: aluminum (6,980.0-9,540.0 mg/kg), barium (101.0-143.0
mg/kg), calcium (2,810.0-10,500.0 mg/kg), chromium, total (11.2-17.3 mg/kg), cobalt (5.1-7.6 mg/kg), copper (10.7-14.0
mg/kg), iron (9,960.0-13,500.0 mg/kg), lead (6.9-38.8 mg/kg), magnesium^ ,410.0-5,480 mg/kg), manganese (244.0-349.0
mg/kg), mercury (ND-0.14 mg/kg), nickel (5.3-9.2 mg/kg), potassium (3,060.0-4,530.0 mg/kg), vanadium (17.3-21.9
mg/kg), zinc (31.6-45.5 mg/kg), di-n-butylphthalate (ND-0.56 mg/kg) alpha-chlordane (ND-0.011 mg/kg), gamma-chlordane
(ND-0.012 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 of
concentrations) were detected at concentrations below the PRGs: aluminum (6,970.0-13,500.0 mg/kg), antimony (ND-7.6
mg/kg), barium (84.8-200.0 mg/kg), cadmium (ND-4.2 mg/kg), calcium(l ,820.0-4,790.0 mg/kg), chromium, total (8.1-23.9
mg/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-
122.0 mg/kg), benzo(b)fluoranthene (ND-0.37 mg/kg), fluoranthene (ND-0.68 mg/kg), alpha-chlordane (ND-0.0063 mg/kg),
5-8
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gamma-chlordane (ND-0.0062 mg/kg), DDD (ND-0.011 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 PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (6,440.0-18,000.0 mg/kg), antimony (ND-8.3
mg/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),
chrysene (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-0.062 mg/kg).
Site 34. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (7,260.0-8,760.0 mg/kg), barium (87.5-139.0
mg/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 (7.7-10.9
mg/kg), iron (13,600.0-16,800.0 mg/kg) lead (5.7-37.8 mg/kg), magnesium (3,140.0-4,430.0 mg/kg), manganese (249.0-
315.0 mg/kg), nickel (ND-4.2 mg/kg), potassium (3,790.0-4,880.0 mg/kg), sodium (128.0-274.0 mg/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-6.0
mg/kg) fluoranthene (ND-13.0 mg/kg), phenanthrene( ND-10.0 mg/kg), pyrene (ND-10.0 mg/kg), and DDT (ND-0.045
mg/kg).
Site 38. In addition to the analytes that exceed PRGs listed in Table 5-2, the following analytes (and the ranges of
concentrations) were detected at concentrations below the PRGs: aluminum (6,860.0-9,900.0 mg/kg), barium (103.0-148.0
mg/kg), calcium (1,950.0-2,200.0 mg/kg), chromium, total (10.0-14.1 mg/kg), cobalt (5.2-7.0 mg/kg), copper (10.0-13.4
mg/kg), iron (10,900.0-14,700.0 mg/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 (24.4-32.8
mg/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), and
dieldrin (ND-0.017 mg/kg).
5-9
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6.0 SUMMARY OF SITE RISKS
A human health risk assessment was conducted for March AFB OU1 sites following USEPA Region IX and California EPA
guidance. This baseline risk assessment produced estimates of the potential risks to public health from site contaminants
as if no cleanup would occur. Exposures to contaminated surface soil, groundwater, and air were addressed by the risk
assessment. Although groundwater is not currently used as a source of drinking water in the vicinity of March AFB, the
State of California considers the groundwater a potential source of drinking water. Therefore, risk to potential future
groundwater consumers (residents and industrial workers) was evaluated. Ecological risks for OU1 sites were not addressed
by 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 sites
or groundwater plumes. All organic analytes detected in one or more site samples were retained as chemicals of potential
concern for that site. For naturally-occurring inorganic chemicals in the soil, the selection process included statistical
comparisons of site inorganic concentrations to OU1 background data. For inorganic chemicals in groundwater, total
inorganic concentrations were statistically compared with background data for total inorganics. Selection of a chemical as
a potential chemical of concern does not in itself indicate a need for remediation. Chemicals of potential concern were
evaluated in the human health risk assessment, and the results of the risk assessment were used to determine the need for
remediation.
Soil gas data collected at Sites 4, 5, 18, and 31 were used to select volatile organic compounds (VOCs) of potential concern
in air at these sites. All volatile chemicals of potential concern in soil that had a vapor pressure greater than 1 millimeter
of mercury were also selected as VOCs of potential concern in air.
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.
Organochlorine 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 Remedial
Investigation/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
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Contaminated site surface soil.
Contaminated site subsurface soil.
Contaminated groundwater (i.e., the OU1 Plume, Site 4 Plume, and Site 18 Plume). Contaminated
groundwater is not currently consumed by onbase or offbase receptors.
Contaminated air (i.e., contaminated dust or airborne VOCs) at an OU1 site or contaminated air that has
migrated 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 offbase school children, current offbase workers, future
onsite 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 pathways
are 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 and
U.S. EPA acceptable intake models (i.e., formulas). Specific current receptor exposure information (i.e., receptor exposure
frequency and duration) was obtained through interviews of March AFB personnel and offbase 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 exposure
to contaminants. The U.S. EPA has developed RfDs for both the oral exposure route and reference concentrations (RfCs)
for the inhalation exposure route. The first source for RfDs and RfCs (which were converted to inhalation RfDs) was the
U.S. EPA's IRIS database. If RfDs or RfCs had not been published in IRIS, the U.S. EPA's Health Effects Assessment
Summary Tables (HEAST) was used as a second source. If values were not available from either IRIS or HEAST, Applied
Action Levels (AALs) developed by the State of California were used to calculate RfDs. In such cases, the AAL for air
or water was assumed to be equivalent to a unit risk concentration and was converted to an inhalation or oral RfD. Only
AALs derived from non-carcinogenic endpoints for human receptors were used to convert to RfDs.
A slope factor is an upper 95th percent confidence limit of the probability of a carcinogenic response per unit intake of a
chemical over a lifetime. Slope factors were obtained from the U.S. EPA's IRIS as a first source. These slope factors have
been verified by the U.S. EPA Carcinogen Risk Assessment Verification Endeavor (CRAVE) work group. If a slope factor
could not be retrieved from IRIS, the slope factor was obtained from the HEAST as a second source. Slope factor values
developed by the California EPA Standards and Criteria Work Group were used if more conservative than IRIS or HEAST
values.
6.4 RISK CHARACTERIZATION AND 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, the
greatest concern is that exposure may result in cancer. Therefore, the exposure is compared to the probabiliry of increasing
6-2
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the risk of cancer. A risk level of 1 in 1,000,000 means that one additional person out of 1 million people exposed could
develop cancer as a result of the exposure. To be considered protective of human health, the cancer risk from exposure to
a chemical should be within or less than the range of 1 in 10,000 to 1 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. The
acceptable hazard index for protection of human health is less than or equal to 1. Risk from exposure to lead in the
environment 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 government
agencies or the public. Therefore, the risk assessment considered potential future land uses as well as current land uses in
the determination of risks posed by soil, air, and groundwater contaminants.
The populations potentially exposed to contaminants in OU1 include workers currently at the base, current offbase residents
and school children, and potential future residents, industrial workers, or construction workers, if the base is redeveloped
for residential and/or industrial purposes. Table 6-1 presents the increased risks to current workers and potential future
residents, 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, Offbase Residents, and Offbase School/Children from Exposure to
Contaminated Soils. A potential exists for current base workers to be adversely exposed to contaminants
through dermal contact with or ingestion/inhalation of contaminated soils. Additionally, offbase residents
and school children could be adversely exposed to soil contaminants through inhalation of contaminants
migrating 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 6-1.
Future Risk for Residents from Exposure to Contaminated Soils. This setting assumes that there is
unrestricted land use and that the base is redeveloped for residential housing. A potential exists for future
residents 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, and
34. Table 6-1 presents increased risks for future residents. Increased noncancer risk was identified for
exposure to contaminants in soils at Sites 10, 16, and 29.
Future Risk for Industrial Workers from Exposure to Contaminated Soils. This setting assumes that
the future use of the base is light industrial (such as continued use for aircraft repair). Future workers
could be exposed to site chemicals through contact with soil, or through soil ingestion/inhalation. Increased
cancer risk was found for exposure to contaminants in soils at Sites 4, 7, 9, 10, 15, 29, 31, and 34. A
summary 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 assumed
that the base will be redeveloped in the future, construction activities, especially excavation, could cause
construction workers to be adversely exposed through dermal contact with or ingestion/inhalation of
contaminated 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 Table
6-1.
Future Risk for Residents and Industrial Workers from Drinking and Personal Use of Contaminated
Groundwater. The State of California considers groundwater beneath the base a potential source of
drinking water. The risk related to drinking and using water (such as showering) from a plume was
assessed. A summary of increased risks from exposure to contaminated groundwater is presented in Table
6-1.
Risk From Soils. The findings of the carcinogenic and noncarcinogenic risk assessment for receptor exposure to soil
contaminants for each site are discussed briefly below. Current onsite base workers and future onsite residents and industrial
workers have been assumed to be exposed to the 0- to 2-foot surface soil interval. Future construction workers have been
assumed to be exposed to the 0- to 12-foot subsurface soil interval.
6-3
-------
TABLE 6-1
SUMMARY OF OU1 RISK
SOIL
Site
Setting
Hazard Index:
Adult
Child
Cancer Risk
30- Year Resident Adult
4
4
4
7
7
9
9
10
10
10
15
Future Industrial Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsitc Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Construction Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Industrial Worker
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Industrial Worker
Direct Contact with Surface Soil
Future Industrial Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Construction Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Industrial Worker
Inge.slion of Surface Soil
Direct Contact with Surface Soil
0.002
0.05
0.005
0.05
0.02
0.07
0.03
0.05
0.05
0.0001
0.002
0.002
0.01
0.2
0.05
0.2
0.07
0.3
0.01
0.04
NA
NA
0.05
0.3
NA
NA
0.3
0.3
NA
0.001
0.01
NA
NA
NA
0.5
1
NA
NA
NA
NA
NA
NA
1 in 1 thousand
9 in 1 thousand
NA
NA
1 in 100 thousand
5 in 100 thousand
NA
4 in 1 million
5 in 100 thousand
NA
NA
NA
4 in 10 thousand
3 in 1 thousand
NA
NA
NA
NA
1 in 10 thousand
5 in 1 thousand
NA
NA
4 in 1 million
3 in 100 thousand
NA
NA
2 in 100 thousand
NA
NA
2 in 100 thousand
5 in 100 thousand
1 in 1 thousand
NA
NA
2 in 100 thousand
1 in 10 thousand
4 in 1 million
1 in 10 thousand
6-4
-------
TABLE 6-1
SUMMARY OF OU1 RISK
Continued
Site
Setting
Hazard Index
Adult
Child
Cancer Risk
30-Year Resident
Adult
SOIL (CONTINUED)
15
15
15
16
29
29
29
31
31
31
31
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Construction Worker
Direct Contact with Surface Soil
Current Base Fire Department Worker
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact wilh Surface Soil
Future Industrial Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Current Worker at Radar Facility
Direct Contact with Surface Soil
Future Industrial Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Construction Worker
Direct Contact with Surface Soil
Current Site Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
0.03
0.04
0.1
0.004
O.I
0.7
0.2
0.6
0.06
0.6
0.6
0.01
0.1
0.03
0.1
0.001
0.01
0.1
0.3
0.2
NA
NA
1
4
1
4
NA
NA
NA
NA
NA
0.3
0.7
NA
NA
NA
4 in 100 thousand
3 in 10 thousand
NA
NA
1 in 10 million
1 in 10 million
1 in 100 thousand
1 in 10 thousand
NA
NA
NA
NA
NA
4 in 100 thousand
3 in 10 thousand
NA
NA
NA
NA
NA
1 in 100 thousand
1 in 100 thousand
NA
NA
NA
NA
2 in 1 million
5 in 100 thousand
5 in 100 thousand
4 in 1 million
1 in 10 thousand
NA
NA
1 in 100 thousand
4 in 1 million
1 in 10 thousand
6-5
-------
TABLE 6-1
SUMMARY OF OU1 RISK
Continued
She
Setting
Hazard Index
Adult
Child
Cancer 'Risk-:
30-Year Resident
Adult
SOIL (CONTINUED)
34
34
34
Future Industrial Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Onsite Resident
Ingestion of Surface Soil
Direct Contact with Surface Soil
Future Construction Worker
Ingestion of Surface Soil
Direct Contact with Surface Soil
0.001
0.02
0.002
0.02
0.0006
0.004
NA
NA
0.02
0.1
NA
NA
NA
NA
4 in 10 thousand
4 in 1 thousand
NA
NA
4 in 100 thousand
2 in 1 thousand
NA
NA
6 in 1 million
7 in 100 thousand
GROUNDWATER
OUl Plume
OU1 Plume
Site 4 Plume
Site 4 Plume
Site 18 Plume
Future Industrial Worker
Direct Contact with Water While Showering
Ingestion of Groundwater
Inhalation of Vapors While Showering
Future Onsite Resident
Direct Contact with Water While Showering
Ingestion of Groundwater
Inhalation of Vapors While Showering
Future Industrial Worker
Direct Contact with Water While Showering
Ingestion of Groundwater
Inhalation of Vapors While Showering
Future Onsite Resident
Direct Contact with Water While Showering
Ingestion of Groundwater
Inhalation of Vapors While Showering
Future Industrial Worker
Direct Contact with Water While Showering
Ingestion of Groundwater
Inhalation of Vapors While Showering
0.09
0.3
10
0.1
0.3
20
0.1
0.3
20
0.3
0.5
20
4
80
200
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8 in 1 million
3 in 100 thousand
2 in 1 thousand
NA
NA
NA
6 in 100 thousand
2 in 10 thousand
4 in 1 thousand
NA
NA
NA
4 in 1 million
2 in 100 thousand
9 in 10 thousand
NA
NA
NA
3 in 100 thousand
1 in 10 thousand
3 in 1 thousand
NA
NA
NA
2 in 1 thousand
7 in 1 thousand
5 in 10
6-6
-------
TABLE 6-1
SUMMARY OF OU1 RISK
Continued
Site
Setting
Hazard Index
Adult
Child
Cancer Risk
30-Year Resident
Adult
GROUNDWATER (CONTINUED)
Site 18 Plume
Future Onsilc Resident
Direct Contact with Water While Showering
Ingeslion of Groundwater
Inhalation of Vapors While Showering
5
100
3(K)
NA
NA
NA
4 in 1 thousand
1 in 1 hundred
9 in 10
NA
NA
NA
Key: NA = Not Applicable
Note: Only pathways which contributed significantly to risk are included.
6-7
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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 might
live or work on or near Site 4. For hypothetical future residents, industrial workers, and construction
workers, an increased cancer risk was identified. The contaminants at Site 4 that most affected risk are
PAHs.
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 and
industrial workers, an increased cancer risk was identified. The contaminants at Site 7 that most affected
risk are beryllium and dioxins.
Site 9. No risk to current populations was identified for Site 9. For hypothetical future residents and
industrial workers, an increased cancer risk was identified. The contaminant at Site 9 that most affected
risk 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 contaminants
at Site 10 that most affected cancer risk are PAHs and beryllium. For hypothetical future residents, an
increased 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 future
residents, industrial workers, and construction workers, an increased cancer risk was identified. The
contaminants 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, an
increased 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. For
hypothetical future residents and industrial workers, an increased cancer risk was also identified. The
contaminants at Site 29 that most affected cancer risk are beryllium, PAHs and dioxins. For hypothetical
future residents, an increased noncancer risk was identified. The contaminant that most affected noncancer
risk is manganese.
Site 31. An increased cancer risk was identified for current onsite workers at Site 31. For hypothetical
future residents, industrial workers, and construction workers, an increased cancer risk was also identified.
The contaminants at Site 31 that most affected risk are PAHs 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 contaminants
at Site 34 that most affected risk were PAHs.
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 receptors
exceed the Pb-B concentration of concern of 10 /ig/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
-------
Risk from Groundwater. Results of the carcinogenic and noncarcinogenic risk assessment for exposure to groundwater
contaminants within each plume are discussed briefly below:
OU1 Groundwater Plume. Throughout the area of the OU1 groundwater plume, there are no current
users of groundwater. Therefore, no receptors are currently exposed to groundwater contaminants and
there is no increased risk of cancer. However, since the State of California considers all groundwater as
potential drinking water, the risk assessment considered the exposure of hypothetical future resident adults
and industrial workers who may occupy this area. For future receptors, an increased risk for both resident
adults and industrial workers was identified using this assumption. This increased risk was due to exposure
to groundwater contaminated with benzene, bromodichloromethane, bromoform, carbon tetrachloride,
dibromochloromethane, 1,2-dichloroethane, 1,1-dichloroethene, methylene chloride, tetrachloroethylene,
and trichloroethylene. For future resident adults and industrial workers, an increased noncancer risk was
identified for exposure to OU1 plume water. The contaminants that most affected noncancer risk were
TCE and carbon tetrachloride.
Site 4 Plume. There are no current users of groundwater from the Site 4 plume. Therefore, no receptors
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 tetrachloroethylene, trichloroethylene,
benzene, bis(2-ethylhexyl)phthalate, 1,4-dichlorobenzene, 1,2-dichloropropane, cis-l,2-dichloroethene,
methylene chloride, and vinyl chloride. For future resident adults and industrial workers, an increased
noncancer risk was identified for exposure to Site 4 plume water. The contaminants that most affected
noncancer 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, no
receptors 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. The
contaminants that most affected noncancer risk were TCE, toluene, xylenes (total), ethylbenzene, and
thallium.
Site 31 Plume. For risk assessment purposes, the Site 31 plume was considered part of the OU1 plume.
Conclusions. Actual or threatened releases of hazardous substances from OU1 sites at March AFB, if not addressed by the
response actions selected in this ROD, may present a current or potential threat to public health, welfare, or the environment
as discussed in Section 6.4.
6.5 Cleanup Standards and Goals
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 protection
of 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 and
appropriate". "Applicable" requirements are those promulgated Federal or state requirements that specifically address a
hazardous 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 sites
that their application is appropriate. Relevant and appropriate requirements are applied in the same manner as applicable
requirements.
For those situations or chemicals where no ARAR exists, or where the ARAR is not protective of human health and the
environment, to-be-considered (TBC) information is evaluated. There are a number of guidance documents and
non-promulgated standards that can be used in the development of "criteria" for remedial action. This step of the ARARs
6-9
-------
process involves review of advisory, guidance, and nonpromulgated standards documents to aid in the development of other
considerations for site remedial actions.
There are three types of ARARs: chemical-specific, location-specific, and action-specific. In addition to the
chemical-specific standards used as cleanup standards, CERCLA requires that site cleanups comply with other
location-specific and action-specific ARARs. Location-specific ARARs govern activities in certain environmentally
sensitive 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 hazardous
substances. These ARARs generally set performance, design, or other similar action-specific controls or restrictions
on 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 considers
groundwater 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 cleanup
standards. The Federal MCLs are established in 40 CFR 141.61(a) and the California MCLs are established in Title 22 CCR
64444.5. Where the Federal and State MCLs for a contaminant are not the same, the more stringent of the two is used as
a cleanup standard.
Table 6-2 presents maximum concentrations of groundwater contaminants in each plume identified and the associated
groundwater 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 to
prevent further degradation of groundwater from contaminants migrating downward through the soil. Cleanup levels
necessary to meet these two standards were determined by considering two soil zones: surface soil (0-2 feet below ground
surface) and subsurface (from the ground surface to groundwater level). For the surface soil interval, cleanup standards were
based on U.S. EPA Region IX risk-based PRGs; for subsurface soil, the standards were based on results of computer
modeling. 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 PRGs; residential
PRGs were used because they are considered protective of human health. These PRGs were determined to be appropriate
for 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 use
scenario PRGs are discussed below.
The following is a discussion, by site, of the chemicals that exceed U.S. EPA Region IX PRGs. Table 6-3 presents
concentrations of chemicals that exceed Region IX PRGs at each site. It also presents U.S. EPA Region IX residential
PRGs for all sites as well as industrial PRGs for Sites 7 and 29. As discussed in Section 5.0, a contaminant does not
necessarily require remediation even though it may be detected at concentrations greater than the PRG. Contaminants that
require remediation were determined by considering chemicals that exceed PRGs as well as by considering the results of the
risk assessment (see Section 6.4 Risk Characterization and Conclusions) and other relevant site-specific information.
6-10
-------
TABLE 6-2
GROUNDWATER CLEANUP STANDARDS
Plume
Site 4
Site 18
Site 31
OU1
Contaminant
Methylene Chloride
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Vinyl Chloride
Bis(2-ethylhexyl)phthalate
cis-1 ,2-Dichloroethene
Benzene
Toluene
Ethylbenzene
Methylene Chloride
Phenols, Total
Xylenes, Total
Bis(2-ethylhexyl)phthalate
1,1-Dichloroethene
Trichloroethene
Bis(2-ethylhexyl)phthalate
Benzene
Carbon Tetrachloride
Trichloroethene (TCE)
1,1-Dichloroethene
cis-1 ,2-Dichloroethene
Methylene Chloride
Tetrachloroethene (PCE)
1 ,2-Dichloroethane
Phenols, Total
Maximum
Concentration
Otg/I)
9
260
85
8
290
21
12,000
11,000
1,500
440
73
7,700
63
260
1,400
130
420
3
1400
260
30
45
19
25
79
Cleanup Standard
(State or Federal MCL)
:::(Atg/i) : :
5 (federal)1
5 (state and federal)1-2
5 (state and federal)1-2
0.5 (state)2
4 (state)2
6 (state)2
1 (state)2
10 (federal)4
10 (federal)4
5 (federal)
40 (state RWQCB)3
10 (federal)4
4 (state)2
6 (state)2
5 (state and federal)1-2
4 (state)2
1 (state)2
0.5 (state)2
5 (state and federal)1-2
6 (state)2
6 (state)2
5 (federal)1
5 (state and federal)1-2
0.5 (state)2
40 (state RWQCB)3
Key:
RWQCB
MCL
Micrograms per liter
California Regional Water Quality Control Board, Santa Ana Region
Maximum Contaminant Level
1 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, Maximum
Contaminant Levels for Organic Chemicals.
3 Water Quality Control Plan, Santa Ana River Basin, 1984. Water Quality Objectives.
4 NPDES Permit, CAG918001, 14 March 1995
6-11
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Site 4. Beryllium and several PAHs were detected in surface soil at concentrations greater than U.S. EPA Region IX
residential PRGs (see Table 6-3). The results of the risk assessment indicate that beryllium at this site does not require
remediation. However, the risk assessment indicates that the following PAHs, which also exceed PRGs, 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(l,2,3-c,d)pyrene. The estimated area requiring remediation at Site 4 is 435,164 square
feet. 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 results
of the risk assessment indicate that beryllium does not require remediation. Consequently, no contaminants at this site
require remediation.
Site 7. Beryllium, lead, manganese, and several dioxins were detected at concentrations greater than U.S. EPA Region IX
residential PRGs (see Table 6-3). For lead, a method developed by the California EPA, Department of Toxic Substances
Control was used to estimate blood-lead concentrations, based on exposure to lead by multiple pathways. Results of this
method indicate that lead does not require remediation. The results of the risk assessment indicate that manganese does not
require remediation. U.S. EPA Region IX industrial PRGs, rather than residential PRGs, were used to determine the need
for 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 have
access.
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 industrial
PRGs) would be $22 million.
The Air Force will ensure that this site is used appropriately in the future by implementing deed restrictions prohibiting
residential land use. Based on U.S. EPA Region IX industrial land use PRGs, beryllium and dioxins do not require
remediation 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); the
risk assessment also indicates increased risk for beryllium at this site. The average surface soil (0-2 ft. bgs) concentrations
of beryllium (0.34 mg/kg) slightly exceeded the average background concentration (0.27 mg/kg). However, concentrations
of beryllium observed at Site 9 are considered naturally-occurring for the reasons outlined below, and do not require
remediation:
There is no current or historical information indicating that beryllium was used, stored, or disposed of at
Site 9.
The range of beryllium concentrations observed at Site 9 falls within the range of background
concentrations observed, i.e., the maximum site concentration (0.42 mg/kg) is less than the maximum
background concentration (0.43 mg/kg).
Background concentrations of beryllium exceed the U.S. EPA Region IX PRG 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 "hot
spots" or areas of elevated concentrations.
Levels of beryllium found at Site 9 are within the acceptable range for cancer risk (10"* to 10"6 cancer risk)
for unrestricted land use. There are no other contaminants detected at Site 9 that would contribute to
unacceptable risk.
Consequently, no contaminants at this site require remediation.
6-12
-------
TABLE 6-3. CONCENTRATIONS OF SURFACE SOIL CONTAMINANTS
EXCEEDING EPA REGION IX PRGs
Site
4
5
7
9
10
13
15
16
18
29
31
31
34
Chemical
Ben2o(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Chrysene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Beryllium
Beryllium
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Hexachlorinated dibenzo-p-dioxins, total
Beryllium
Lead
Manganese
Beryllium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Beryllium
Benzo(a)pyrene
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Beryllium
Beryllium
Manganese
Beryllium
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
rieptachlorinated dibenzo-p-dioxins, total
Beryllium
Lead
Manganese
3enzo(a)anthracene
3enzo(a)pyrene
3enzo(b)fluoranthene
ndeno(l,2,3-c,d)pyrene
Beryllium
-ead
Manganese
ienzo(a)anthracene
ienzo(a)pyrene
5enzo(b)fluoranthene
ndeno( 1 ,2.3-c,d)pyrene
Range of
Concentration
at Site
(TTL& (\ta\_
ND-5.5
ND-8.7
ND-14.0
ND-20.0
ND-9.7
ND-4.2
ND-21.0
ND-0.39
ND-0.27
ND-0.00075
ND-0.0013
ND-0.0001
ND-0.58
ND-855.0
111.0-449.0
0.26-0.42
2.0-3.2
2.9-3.5
3.3-3.7
1.5-1.8
ND-0.96
3.6-3.9
0.27<5>
ND-0.34
ND-0.00095
ND-0.0016
ND-0.33
ND-0.41
186.0-654.0
0.23-0.45
ND-0.00079
ND-0.0014
0.27-0.66
5.3-246.0
250.0-554.0
ND-0.96
ND-1.0
ND-1.5
ND-0.85
ND-0.79
ND-311.0
188.0-610.0
ND-5.8
ND-3.2
ND-4.9
ND-2.2
95% Upper
Confidence
Limit
(ma/kaY
5.5
8.7
14.0
20.0
9.7
4.2
21.0
0.39
0.27
0.00075
0.0013
0.000089
0.38
80.6
256.7
0.39
3.2
3.5
3.7
1.8
0.96
3.9
0.27
0.34
0.00095
0.0016
0.3
0.41
450.1
0.42
0.00079
0.0014
0.45
82.9
351.5
0.30
0.34
0.53
0.26
0.39
121.0
307.1
5.8
3.20
4.90
2.20
Region LX
Residential
PRGm
fmo/Vo^
0.61
0.061
0.61
19«
6.1°'
0.061
0.61
0.14
0.14
0.00038'4'
0.0003814'
0.000038'4'
0.14
130(3)
380
0.14
0.61
0.061
0.61
0.61
0.061
0.61
0.14
0.061
0.00038<4>
0.0003814'
0.14
0.14
380
0.14
0.00038'4'
0.00038(4)
0.14
130°>
380
0.61
0.061
0.61
0.61
0.14
130'3'
380
0.61
0.061
0.61
0.61
Region LX
Industrial
PRG'"
fmalkci)
-
-
-
-
-
-
-
-
-
0.0024'41
0.0024'4'
0.00024'41
1.1
1000
7800
-
-
-
-
-
-
-
-
.
-
-
-
-
-
0.0024'4'
0.0024W
1.1
1000
7800
-
-
-
-
-
-
-
-
-
-
-
6-13
-------
TABLE 6-3. CONCENTRATIONS OF SURFACE SOIL CONTAMLNANTS
EXCEEDING EPA REGION IX PRGs
Site
34
38
Chemical ;
..'"". - " :'. ::. ' ''--'-: '"-
' "' . v '':..' ' :-'"..' :''
Beryllium
Beryllium
Range of
Concentration
at Site
fTnoriroV
0.22-0.28
ND-0.29
95% Upper
Confidence
Limit ;
^ma/Wat
0.27
0.29
Region IX
Residential
PRG">
Ymff/Viyi
0.14
0.14
Region DC
Industrial
PRG'"
fmol\:a)
.
-
(1)
(2)
(3)
(4)
Region IX residential soil PRGs were used for all sites except sites 7 and 29. At sites 7 and 29, industrial soil PRGs were
used.
A PRG was not available for this noncarcinogenic polynuclear aromatic hydrocarbon (PAH). The PRG for anthracene,
which is the most conservative PRG for the noncarcinogenic PAHs, was used as a surrogate.
The California EPA PRG was used for this chemical because it is more restrictive than the Region IX PRG.
2, 3, 7, 8-TCDD is the only dioxin for which Region IX has calculated PRGs (3.8E-06 for residential soil and 2.4E-05 for
industrial soil). Therefore, this PRG has been adjusted using a TEF listed hi the table below. This adjusted value was
compared to site concentrations.
Toxicity Equivalency Factors for Dioxins
Congener
TEF
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Heptachlorinated dibenzo-p-dioxins, total
Hexachlorinated dibenzo-p-dioxins, total
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
0.01
0.01
0.1
0.001
0.001
TEFs were obtained from "Supplemental Guidance for Human
Health Multimedia Risk Assessments of Hazardous Waste Sites
and Permitted Facilities", State of California Environmental
Prelection Agency, Department of Toxic Substances Control,
Office of the Science Advisor Tulv 1992.
Key: PRG = Preliminary Remediation Goal
TEF = Toxicity Equivalency Factor
(5)
Only one sample was collected at this site.
6-14
-------
\5
Site 4 Boundary
Approximate Locations
Capped Landfill Areas
10' downward sJope of 20% of cover
4' space between cover and storm drain
Explanation
Surface soil sample location
Inactive landfill area to be capped
400 800 Feet
March Air Force Base, California
Site 4 Surface Soil
Contamination
6-15
-------
Site 10. Several PAHs were detected in surface soil at concentrations that exceed U.S. EPA Region IX PRGs (see Table
6-3) and were also identified by the risk assessment as presenting a potential health risk. The PAHs that require remediation
are: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenz(a,h)anthracene, and
indeno(l,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, the
maximum concentration of manganese (132.0 mg/kg) is less than the U.S. EPA Region IX PRO for residential land use (380
mg/kg). Furthermore, the concentrations of manganese at Site 10 are 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 of
at Site 10.
The range of manganese concentrations observed at Site 10 falls within the range of background
concentrations observed, i.e., the maximum site concentration (132.0 mg/kg) is less than the maximum
background concentration (402.0 mg/kg).
The mean concentration at the site (112.8 mg/kg) is less than the mean background concentration (266.1
mg/kg).
The spatial distribution of manganese is fairly uniform, with no apparent patterns of elevated
concentrations.
Site 13. Beryllium was detected at concentrations greater than the U.S. EPA Region IX PRO (see Table 6-3). The results
of the risk assessment indicate that beryllium at this site does not require remediation. Consequently, no contaminants at
this site require remediation.
Site 15. Beryllium, benzo(a)pyrene, and two dioxins were detected at concentrations greater than U.S. EPA Region IX
residential PRGs (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 dioxins
is within the acceptable range for cancer risk (10^ to 10'6 cancer risk) and therefore dioxins do not require remediation at
Site 15. Other contaminants present at Site 15 (PAHs) will be remediated and will not contribute to excess cancer risk. The
estimated volume of PAH-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 at
concentrations that indicated potential risk. For manganese, the average surface soil concentration of 366.5 mg/kg slightly
exceeds the average background concentration of 266.1 mg/kg. However, concentrations of manganese detected at Site 16
are 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 of
at Site 16.
Of the 10 surface soil samples collected at Site 16, all but one fall within the range of background
concentrations. 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 PRG for
unrestricted land use, indicating naturally-elevated concentrations of manganese at March AFB.
The spatial distribution of manganese is fairly uniform, with no apparent patterns of elevated
concentrations.
The mean concentration of manganese (366.5 mg/kg) is less than the U.S. EPA Region IX PRG for
residential land use. The 95% UCL of the mean (450.1 mg/kg) only slightly exceeds the PRG. There are
no other contaminants at Site 16 that would contribute to unacceptable risk.
6-16
-------
a
§
North
Flightline Drainage Channel
Ferris Valley Storm Drain
Lateral A
Explanation
j Source area
T"j Area requiring excavation
320 Feet
March Air Force Base, California
Site 10 Surface Soil
Contamination
9-95
Figure 6-2
6-17
-------
22.14 -X
\
, Underground JP-4 Line. //
Explanation
Area Requiring Excavation
o
o
IT
200 Feet
March Air Force Base, California
Site 15 Surface Soil
Contamination
9-95
Fiaure 6-3
6-18
-------
Consequently, no contaminants at this site require remediation.
Site 18. Beryllium was detected at concentrations greater than 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, no surface
soil contaminants at this site require remediation.
Site 29. Beryllium, lead, manganese, and two dioxins were detected at concentrations that exceed U.S. EPA Region IX
residential land use PRGs (see Table 6-3). For lead, the method developed by the California EPA, Department of Toxic
Substances 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 have
access.
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 be
achieved. The combined cost for Site 29 and Site 7 (which has also been selected for remediation based
on industrial PRGs) would be S22 million.)
The Air Force will ensure that this site is used appropriately in the future by implementing deed restrictions prohibiting
residential 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 PAHs exceed U.S. EPA Region IX PRGs (see Table
6-3). For lead, the method developed by the California EPA, Department of Toxic Substances Control was used to estimate
blood-lead concentrations. Results indicated that lead does not require remediation. The results of the risk assessment
indicate 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 of
beryllium (0.27 mg/kg). However, concentrations of beryllium at the site are considered naturally-occurring for the reasons
outlined below, and do not require remediation:
There is no current or historical information indicating that beryllium was used, stored, or disposed of at
Site 31. Site 31 is a solvent spill area. Chlorinated solvents were discharged to the ground through a
leaking drain pipe and potentially through surface spillage. Soils data show no anomalous values for
beryllium in the areas contaminated by chlorinated solvents, indicating that beryllium occurrences in Site
31 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 mg/kg)
was only slightly higher than the maximum background concentration (0.43 mg/kg).
Background concentrations of beryllium exceed the U.S. EPA Region IX PRG for unrestricted land use,
indicating naturally-elevated levels of beryllium at March AFB.
Concentrations of beryllium detected at Site 31 are within the acceptable range for cancer risk (10"4 to 10"*
cancer 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 contribute
to unacceptable risk.
The risk assessment indicates that the following PAHs, which also exceed PRGs, present a potential health risk and
therefore require remediation: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, and indeno(l,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
-------
Site 31 Boundary
1216 Discharge of
Spent Solvents
Explanation
Area Requiring Excavation
200
Scale
400 Feet
March Air Force Base, California
Site 31 Surface Soil
Contamination
9-95
Figure 6-4|
6-20
-------
X
Site 34. Beryllium and several PAHs were detected at concentrations that exceed U.S. EPA Region IX PRGs (see Table
6-3). The results of the risk assessment indicate that beryllium at this site does not require remediation. The following
PAHs, which also exceed PRGs, present a potential health risk and, therefore, require remediation: benzo(a)anthracene,
benzo(a)pyrene, benzo(b)fluoranthene, and indeno(l,2,3-c,d)pyrene. The estimated volume of soil requiring remediation
at 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, no
contaminants 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 that
the Air Force develop and propose cleanup criteria for soils that would be protective of groundwater. Cleanup criteria for
subsurface soils were developed such that soil contaminants would not be expected to leach into groundwater at
concentrations 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 the
ground surface to groundwater. Two models were used: VLEACH, a vadose zone contaminant transport model, and
MIXCELL, a mixing cell model that calculates groundwater contaminant concentrations from contaminant fluxes supplied
by VLEACH. Based on modeling results, Site 18 is the only site at which soil contaminants could be expected to leach into
groundwater at concentrations that exceed MCLs.
Subsurface soils at Sites 31 and 34 were also evaluated for potential contributions to groundwater contamination. Neither
site exceeded allowable limits predicted using the VLEACH/MIXCELL methodology. However, due to the existing
groundwater contamination at these sites and the potential for subsurface soil contaminants to provide a continuing source
of groundwater contaminants, the California Regional Water Quality Control Board requested that these two sites be included
in subsurface soil remediation strategies.
Site 18. The primary subsurface soil contaminants of concern are jet fuel and its components. Since jet fuel has migrated
to the water table and impacted groundwater with concentrations of contaminants above MCLs (i.e., benzene), the California
Regional Water Quality Control Board, Santa Ana Region requires soil remediation. Contaminants detected include volatile
jet fuel components (BTEX compounds) as well as oil and grease, and semivolatiles (naphthalene, bis(2-ethylhexl) phthalate,
and Di-n-butyl phthalate). The volatile components of jet fuel (BTEX compounds) are the most mobile in soil and
groundwater and are therefore of greatest concern. Maximum concentrations detected were 97 mg/kg for benzene, 69 mg/kg
for toluene, 36 mg/kg for ethylbenzene, and 238 mg/kg for xylenes. Figure 6-6 presents subsurface soil contamination at
Site 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 Ana Region requires soil cleanup
to prevent degradation of the groundwater through migration of contaminants from soil to groundwater. Since the
groundwater at Site 31 is currently being degraded, the Air Force has chosen to address the soil contamination at Site 31
in 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 detected
in 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 the
groundwater through migration of contaminants from soil to groundwater. Since the groundwater at Site 34 is currently being
degraded, the Air Force has chosen to address the soil contamination at Site 34 in order to prevent further groundwater
degradation. 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 soil
cleanup criteria is based on controlling impacts to groundwater exposure pathways. Therefore, MCLs are used as indirect
endpoints 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 underestimate
contaminant 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
-------
1269
D«
1267
North
»' ' i
_.. * < } ;< * >
* ' f 1 i ' ! J
;/ ti II /'
\
(' I Tl '; 1J"
x\ iyjriy,'
\ "~ - ~~
\--
\
\
x Area of Former USTs
Site 34
Boundary
/
/
Explanation
Proposed Excavation Area
120 Feet
6-22
March Air Force Base, California
Site 34 Surface Soil
Contamination
9-95
Figure 6-5
-------
North
Equipment
^Compound
Approximate
ditch location >j
t
i
2
i
Explanation
Proposed Dual Phase Soil Vapor/Groundwater
Extraction Well
Proposed Soil Vapor Extraction Well
Approximate subsurface soil
remediation area
150
Scale
300 Feet
March Air Force Base, California
Site 18 Subsurface Soil
Contamination
9-95
Figure 6-6
6-23
-------
Site 31 Boundary
Equipment Compound
Explanation
Proposed dual phase soil
vapor/groundwater
extraction well
Proposed soil vapor
extraction well
Approximate areal extent of
contaminated soil
400 Feet
March Air Force Base, California
Site 31 Subsurface Soil
Contamination
9-95
Figure 6-7
6-24
-------
1269
1267
North
Site 34
Boundary
Site 14
Boundary x
Explanation
Approximate subsurface soil
remediation area
60 120 Feet
Scale
March Air Force Base, California
Site 34 Subsurface Soil
Contamination
9-95
Fiaure 6-8
6-25
-------
Vadose zone cleanup (SVE and bioventing) will be implemented in combination with contaminant transport modeling. The
process of cleanup and evaluation will be iterative so that cleanup effectiveness is maximized. Cleanup system operation
will be followed by model application to predict vadose zone contaminant migration potential. The results of model
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 is
a tool for directing operation of vadose zone cleanup systems. Vadose zone cleanup will be initiated and will operate until
SVE 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 input
to VLEACH and MIXCELL models (or similar, mutually agreed upon models). The models will be used to predict
groundwater contaminant concentrations for comparison with groundwater cleanup standards and will determine whether the
vadose 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 mutually
agreed-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 the
Remedial 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 Region
IX residential PRGs are used as cleanup goals for all sites listed in Table 6-4. As stated previously, based on U.S. EPA
Region IX industrial PRGs, remediation is not required at Sites 7 and 29.
6-26
-------
Re-evaluate model,
data and criteria
YES
Monitoring data,
model revisions
G.W. contamination is the predicted
concentration in groundwater based on
VLEACH and MIXCELL applications.
Stop vadose zone
remediation
at this site
o
a
i
2
Implement vadose
zone cleanup
at the site
Continue system
operation
Is G.W.
contamination
(VOC or fuel)*
> cleanup
standards?
NO
Stop and monitor
vapor for rebound
Is G.W.
contamination
(VOC or fuel)*
> cleanup
standards?
I NO
Perform
confirmation
sampling (vapor)
contamination
{VOC or fuel)*
> cleanup
standards?
VOC:
LEGEND
Volatile organic
compound
G.W. = GrounAvater
Restart system
YES
YES
March Air Force Base, California
Decision Tree for
Vadose Zone Cleanup
9-95
Ficure 6-9
6-27
-------
TABLE 6-4. CLEANUP GOALS FOR SOIL CONTAMINANTS
REQUIRING REMEDIATION
Site
4
10
15
18
31
34
Chemical
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenz(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Benzo(a)pyrene
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Indeno(l,2,3-c,d)pyrene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Indeno(l,2,3-c,d)pyrene
Maximum Site
Concentration
(rag/kg)
5.5
8.7
14.0
9.7
4.2
21.0
3.2
3.5
3.7
1.8
0.96
3.9
0.34
97
0.96
1.0
1.5
0.85
5.8
3.2
4.9
2.2
.Cleanup Standard
Region DC TOG
(mg/kg)
0.61
0.061
0.61
6.1
0.061
0.61
0.61
0.061
0.61
0.61
0.061
0.61
0.061
6.8<:i
0.61
0.061
0.61
0.61
0.61
0.061
0.61
0.61
(1)
a)
Residential soil PRGs 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
A Feasibility Study (FS) was conducted to develop and evaluate remedial alternatives for Operable Unit 1. The following
sections present summaries of cleanup alternatives evaluated for both groundwater and soil during the FS. The FS was
approved 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 OU1. A variety of treatment
methods 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 comparison
of existing site conditions with other proposed alternatives. Under this alternative, no action would be taken to address
groundwater contamination or to minimize further contaminant releases.
Alternative 2G - Limited Action. Under the limited action response, groundwater monitoring is implemented to check
whether contaminants are migrating or increasing in concentration.
Alternative 3G - Direct Treatment with Liquid Phase Granular Activated Carbon Adsorption. Activated carbon
adsorption is a proven technology for removing organic compounds from groundwater. Contaminated groundwater, once
extracted from a well, is passed through a carbon filter which traps the contaminants. The treated water is then discharged
to the base wastewater treatment system, the ground surface, or returned to the aquifer via injection wells. Once the carbon
becomes saturated with contaminants, the carbon is replaced. The organic compounds identified in OU1 groundwater can
be effectively removed by activated carbon adsorption.
Alternative 4G - Ultraviolet (UV) and Chemical Oxidation Treatment. UV and chemical oxidation uses a combination
of UV radiation, hydrogen peroxide, and ozone to destroy contaminants. Groundwater is introduced to the UV and chemical
oxidation unit, where hydrogen peroxide is injected. The groundwater then enters a reaction chamber. Ozone is bubbled
through the water while it is exposed to UV light in the reaction chamber. The UV light increases the chemical reaction
rate and thus reduces the time required for treatment. Contaminants are rendered harmless with no toxic residuals requiring
treatment. Treated wastewater is discharged to the base treatment plant, the ground surface, or returned to the aquifer via
injection wells.
Alternative 5G - Total Fluids Recovery. Total fluids recovery can be used in combination with other technologies to treat
groundwater contaminated with immiscible fluids, such as the jet fuel found at Site 18. The method includes the retrieval
of groundwater and floating product simultaneously using recovery wells. Jet fuel would be separated from the groundwater
in an above-ground oil/water separator and disposed of offsite or recycled. The remaining contaminated groundwater would
be 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 from
groundwater. Groundwater is sprayed into a tank filled with packing material. As the water flows downward by gravity
it comes into contact with air blown upward into the tank from below. The packing material has a large surface area to
increase water/air contact. Contaminants are volatilized from the water and transferred to the air stream. Contaminant-laden
air 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 granular
activated carbon (GAC) may be used to remove trace contaminants. Treated wastewater is then discharged to the base
treatment 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 described
in 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 they
oxidize to form carbon dioxide and water. The treated air stream is then cooled and vented to the atmosphere.
7-1
-------
Alternative 8G - Air Stripping with Purus PADRE System. Under this alternative air stripping would take place as
described in Alternative 6G. Contaminants that are volatilized from the water enter the air stream and require further
treatment. 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 other
bed is regenerated. The beds are regenerated by heating the resin to desorb the contaminants back into a vapor. The vapors
are 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 used
to remove organic contaminants from groundwater. The groundwater is pumped to the surface where it is passed through
a sedimentation basin to remove particulate matter. The groundwater then flows to biological reactors such as a trickling
filter, rotating biological disk, or aeration basin where microbes biologically degrade the organic contaminants. The treated
water then passes through another settling tank where the microbial mass is removed. The water may be disinfected with
chlorine 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 4/OU1 plume, Site 18 plume and
the Site 31 plume. The following sections summarize remedial technologies considered for each site. The implementation
of 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 worth
of each alternative represents the total project costs in present day dollars based on the capital costs and annual operating
costs.
Site 4/OU1 Groundwater Plume. An alternative for full-treatment of the entire groundwater plume was considered (out
to the 5ppb isopleth), however, the $12 million cost was so disproportionate, this alternative was not included in subsequent
drafts 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 similar
contaminants and site conditions. The remedial alternatives evaluated were as follows:
1G - No Action
2G - Limited Action
3G - Direct Treatment with Liquid Phase GAC
4G - UV and Chemical Oxidation Treatment
6G - Air Stripping with Carbon Adsorption
Alternative 1G - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison of
existing 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 is
implemented. Further, compliance with ARARs is not required for a no-action decision and therefore applicable or relevant
and appropriate chemical-, action-, and location-specific requirements are not summarized in Appendix C (Tables C-l and
C-2).
Implementation of the no action alternative would result in a continuation of risk posed by the presence of TCE, vinyl
chloride, 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 through
groundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does not
reduce 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-l and C-2). This alternative does not
reduce the toxicity, mobility or volume of contamination since no treatment is involved.
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Capital Cost: $ 209,415
Total 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 for
removing VOCs from groundwater, and has been successfully implemented at March AFB. This technology is capable of
removing greater than 99 percent of contaminants from groundwater and reducing the levels of contaminants 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-l and C-2).
Capital Cost: $ 736,216
Total 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 contaminants
from groundwater, and reducing the levels of contaminants 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-l and C-2). Implementation may be somewhat limited due to the small number of vendors.
Capital Cost: $ 1,851,216
Total 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 from
groundwater. This technology is capable of removing greater than 99 percent of contaminants from groundwater and reducing
the levels of contaminants to below cleanup standards. Contaminant-laden air is run through carbon filters prior to 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-l and C-2).
Capital Cost: $ 769,716
Total 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 been
successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated are as
follows:
1G - No Action
2G - Limited Action
3G/5G - Direct treatment with Liquid Phase GAC/Total Fluids Recovery
7G/5G - Air Stripping with Catalytic Oxidation/Total Fluids Recovery
8G/5G - Air Stripping with Purus PADRE System/Total Fluids Recovery
Alternative 1G - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison of
existing 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 and
appropriate 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 fuel
contaminants (primarily BTEX compounds). 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.
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Alternative 2G - Limited Action. The limited action alternative provides some protection to human health through
groundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does not
reduce 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 C-4). This alternative does not
reduce the toxicity, mobility or volume of contamination since no treatment is involved.
Capital Cost: $ 57,477
Total Project Cost/Present Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
Alternative 3G/5G - Direct Treatment with Liquid Phase GAC/Total Fluids Recovery. Total fluids recovery will be used
to extract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminated
groundwater will require further treatment. Activated carbon adsorption is a proven technology for removing organic
compounds from groundwater, and has been successfully implemented at March AFB. This technology is capable of
removing greater than 99 percent of contaminants from Site 18 groundwater, and reducing the levels of contaminants 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-3 and C-4).
Capital Cost: S 274,271
Total Project Cost/Present Worth: $1,027,000. Annual O&M Costs: $ 72,608
(30 years required)
Alternative 7G/5G - Air Stripping with Catalytic Oxidation/Total Fluids Recovery. Total fluids recovery will be used to
extract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminated
groundwater 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 the
levels of contaminants to below cleanup standards. The catalytic oxidation process converts contaminants in the contaminated
air stream to nonhazardous compounds, carbon dioxide and water. The remedy will comply with all applicable or relevant
and appropriate chemical-, action-, and location-specific requirements as summarized in Appendix C (Tables C-3 and C-4).
Capital Cost: $ 531,771
Total Project Cost/Present Worth: $3,006,000. Annual O&M Costs: $ 238,604
(30 years required)
Alternative 8G/5G - Air Stripping with Purus PADRE System/Total Fluids Recovery. Total fluids recovery will be used
to extract groundwater and free-phase fuel. Fuel will be removed in an oil/water separator and recycled. Contaminated
groundwater 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 the
levels of contaminants to below cleanup standards. The PADRE System removes contaminants from the contaminated air
stream by adsorption onto a proprietary resin. Liquid wastes are later condensed and disposed of or recycled. The remedy
will comply with all applicable or relevant and appropriate chemical-, action-, and location-specific requirements as
summarized in Appendix C (Tables C-3 and C-4). This system is proprietary and implementation is limited to one vendor.
Capital Cost: $ 504,036
Total 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 been
successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated are as
follows:
1G - No action
2G - Limited Action
3G - Direct Treatment with Liquid Phase GAC
4G - Ultraviolet (UV) and Chemical Oxidation Treatment
6G - Air Stripping with Carbon Adsorption
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Alternative 1G - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison of
existing site conditions with other proposed remedial alternatives. No remedial action is implemented under the no action
alternative.
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 appropriate
chemical-, action-, and location-specific requirements are not summarized in Appendix C (Tables C-5 and C-6).
Implementation of the no action alternative would result in a continuation of risk posed by the presence of TCE at
concentrations greater than the MCLs for groundwater at Site 31. This alternative does not reduce the toxiciry, 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 through
groundwater monitoring to detect further migration of groundwater contaminants. The limited action alternative does not
reduce 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-5 and C-6). This alternative does not
reduce the toxicity, mobility or volume of contamination since no treatment is involved.
Capital Cost: $ 57,477
Total Project Cost/Present Worth: $400,000. Annual O&M Costs: $ 33,124
(30 years required)
Alternative 3G - Direct Treatment with Liquid Phase GAC. Activated carbon adsorption is a proven technology for
removing organic compounds from groundwater, and has been successfully implemented at March AFB. This technology
is capable of removing greater than 99 percent of contaminants from Site 31 groundwater and reducing the levels of
contaminants 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-5 and C-6).
Capital Cost: $ 349,446
Total Project Cost/Present Worth: $1,103,000. Annual O&M Costs: S 72,664
(30 years required)
Alternative 4G - Ultraviolet (UV) 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
contaminants from Site 31 groundwater, and reducing the levels of contaminants 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-5 and C-6). Implementation may be somewhat limited due to the small number of
vendors.
Capital Cost: $ 479,782
Total 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 from
groundwater. This technology is capable of removing greater than 99 percent of contaminants from Site 31 groundwater and
reducing the levels of contaminants to below cleanup standards. Contaminant-laden air is run through a carbon filters prior
to 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-5 and C-6).
Capital Cost: $ 296,478
Total Project Cost/Present Worth: $1,068,000. Annual O&M Costs: $ 74,403
(30 years required)
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7.2 REMEDIAL ALTERNATIVES FOR SOIL
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 comparison
of existing site conditions with other proposed alternatives. Under this alternative, no action would be taken to address soil
contamination or to minimize further contaminant releases.
Alternative 2S - Limited Action. Under the limited action response, mechanisms to prevent access to the site and direct
contact with the contaminants are implemented such as fences and deed restrictions. Access to the site is controlled. For
sites with surface soil contamination, periodic monitoring of the soil contaminant concentrations is conducted. For sites with
subsurface soil contamination, periodic monitoring of groundwater is conducted to assess potential health impacts. This
alternative reduces risk by limiting exposure to contaminants.
Alternative 3S - Resource Conservation and Recovery Act (RCRA) Capping. Capping protects human health and the
environment by controlling exposure from ingestion, inhalation, and dermal contact with the contaminants. It also reduces
migration of contaminants from the site through air, surface water, and groundwater. This alternative includes installing
a low-permeability cap over the existing wastes, protecting the cap from erosion, and long-term maintenance to ensure cap
integrity.
Alternative 4S - Landfill Closure. This alternative implements final closure of the existing landfill at Site 4, in accordance
with the California Water Regulations (California Code of Regulations, Title 23, Waters, Division 3). Closure of the landfill
includes construction of a cover, installation of an impermeable barrier to isolate landfill materials from surface water
drainage, water quality monitoring and response programs, closure maintenance activities, and post-closure maintenance
activities.
Alternative 5S - Excavation and Low Temperature Thermal Desorption. In a thermal desorption process, soils are
excavated 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 Washing/Ion Exchange. Under this alternative, soil washing would be conducted as described above
for Alternative 5S. 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 is
regenerated using a concentrated wash solution which releases the bound metal ions from the resin. The wash solution
requires further treatment or disposal.
Alternative 7S - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated soil and
treatment/reuse at an offsite location. The contaminated soils are mixed with asphalt, which is then used as a sub-base for
pavement. This is especially effective for PAH-contaminated soils which bond with the asphalt, thereby reducing migration
and minimizing risk.
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, excavated soils would be added to other
solid wastes and consolidated beneath a low-permeability cap. Before placement under the cap, the soils must pass the toxic
characteristic leaching procedure (TCLP) and California leachate tests. Capping minimizes contaminant migration from
buried wastes by preventing water infiltration and controlling surface water runoff. This alternative involves installation of
a 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 and
placement of the soil in an approved offsite landfill.
Alternative 10S - Bioventing. Bioventing is an in-situ treatment technology for petroleum contaminated soils. It consists
of 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 dioxide
and water. Air flow through contaminated soils is controlled through the use of air injection or air extraction wells. Flow
rates are maintained at low levels to minimize volatilization of contaminants.
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Alternative US - 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. Contaminants
are 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 to
remove VOCs with vapor pressures greater than 1 millimeter of mercury from soil. Air flow is induced through
contaminated soils by extracting air through wells installed in the soil column. Air flow may be enhanced by using air
injection wells in conjunction with extraction wells. VOCs are stripped from the soils into the air as the air flows through
the soil column. The contaminated vapors are then brought to ground surface for treatment using catalytic oxidation. The
contaminated air stream is preheated and the hot air is passed over a catalyst. Contaminants adsorb to the surface of the
catalyst where they are oxidized to carbon dioxide and water. The treated air stream is then cooled and vented to the
atmosphere.
Alternative 13S - Soil Vapor Extraction with Purus PADRE System. Under this alternative SVE would be performed
as described above for alternative 12S. The contaminated vapors are then brought to ground surface for treatment by the
Purus PADRE System. The PADRE System removes contaminants from the extracted vapor stream by adsorption onto
a proprietary resin. The system is operated with two resin beds. Contaminants are adsorbed onto one resin bed while the
other bed is regenerated. The beds are regenerated by heating the resin to desorb the contaminants which are condensed
to 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 performed
as described in Alternative 12S. The contaminated vapors are then brought to ground surface for treatment by GAC. GAC
removes contaminants from the extracted vapor stream by adsorption onto the carbon. The carbon may be regenerated onsite
or 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 following
sections summarize remedial technologies for remediating soil at each site. The implementation of the various technologies,
including the estimated costs, is discussed below.
Site 4 Soil. Site 4 alternatives were identified based upon contaminant types and concentrations, and current plans for site
restructuring. 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 other
proposed remedial alternatives. Under a no action alternative the landfill would be left in its current state. This alternative
would not reduce the potential for waste migration due to precipitation or surface drainage, and therefore provides no overall
protection 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 of
landfill materials would remain. In addition, this alternative does not control contaminant migration to groundwater and does
not provide a mechanism for monitoring contaminant migration.
Cost: The no action alternative is by definition a no cost alternative.
Alternative 2S - Limited Action. The limited action alternative provides some protection to human health by limiting the
potential for direct site contact and monitoring contaminant migration. The limited action alternative does not comply with
ARARs 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: S 209,415
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Total Project Cost/Present Worth: $1,148,000. Annual O&M Costs: S 90,508
(30 years required)
Alternative 3S - RCRA Capping. Capping protects human health and the environment by minimizing exposure from
ingestion, inhalation, and dermal contact with the contaminants. It also reduces migration of contaminants from the site
through air, surface water, and groundwater. The remedy will comply with ARARs as summarized in Appendix C (Table
C-7).
Capital Cost: S 1,816,059
Total Project Cost/Present Worth: $2,853,000. Annual O&M Costs: $ 100,008
(30 years required)
Alternative 4S - Landfill Closure. The closure alternative would involve closure of the landfill in accordance with California
Water Regulations (California Code of Regulations, Title 23, Waters, Division 3). Closure of the landfill would include
construction of a cover, isolation of landfill materials from surface water drainage, water quality monitoring and response
programs, closure maintenance activities, post-closure maintenance activities. The remedy will comply with ARARs as
summarized in Appendix C (Table C-7).
Capital Cost: $ 1,390,102
Total Project Cost/Present Worth: $2,427,000. Annual O&M Costs: S 100,008
(30 years required)
Alternative 9S - Excavation and Of/site Disposal. This alternative involves the excavation of contaminated soil and
placement of the soil in an approved offsite landfill. The remedy will comply with ARARs as summarized in Appendix C
(Table C-7). This alternative does not reduce the toxicity or volume of the contaminants.
Capital Cost: $ 96,712,000
Total 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:
IS - 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
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of other
proposed remedial alternatives. Under this scenario, PAH-contaminated soils would remain in the drainage channel and
continue to pose potential risk. Because the drainage channel leads offbase, contaminants could eventually migrate offbase.
This alternative does not mechanism for reduction of toxicity, mobility or volume of contaminants. Compliance with ARARs
is 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 the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations and does
not 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.
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Capital Cost: S 51,004
Total Project Cost/Present Worth: $87,000. Annual O&M Costs: $ 3,480
(30 years required)
Alternative 5S - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated soils are
excavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroys
them in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C-8).
Capital Cost: S 37,000
Total Project Cost/Present Worth: $37,000. Annual O&M Costs: S 0
(not required)
Alternative 75 - Excavation and Of/site Treatment. This alternative involves the excavation of contaminated soil from the
drainage ditch for treatment/reuse at an offsite location. The offsite facility will mix contaminated soils with asphalt. The
mixture is used as sub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby reducing migration
and minimizing risk. The remedy will comply with ARARs as summarized in Appendix C (Table C-8).
Capital Cost: S 22,000
Total Project Cost/Present Worth: $22,000. Annual O&M Costs: $ 0
(not required)
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, soils excavated from Site 10 would be added
to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated soils would
be controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in Appendix C (Table
C-8).
Capital Cost: $ 7,000
Total Project Cost/Present Worth: $7,000. Annual O&M Costs: $ 0
(not required)
Alternative IIS - Ex-Situ Bioremediation. Under this alternative, contaminated surface soils are excavated and aerated to
stimulate biodegradation. Nutrient amendments may also be required. Contaminants are converted to carbon dioxide and
water as a result of biodegradation processes. The remedy will comply with ARARs as summarized in Appendix C (Table
C-8).
Capital Cost: S 50,000
Total 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:
IS - 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
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of other
proposed 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 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.
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Alternative 25 - Limited Action. The limited action alternative provides some protection to human health by limiting the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. This
alternative 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: S 32,348
Total Project Cost/Present Worth: $68,000. Annual O&M Costs: S 3,480
(30 years required)
Alternative 5S - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated soils are
excavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroys
them in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C-9).
Capital Cost: $ 26,000
Total Project Cost/Present Worth: $26,000. Annual O&M Costs: S 0
(not required)
Alternative 7S - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated soil for
treatment/reuse at an offsite location. The facility will mix contaminated soils with asphalt. The mixture is used as sub-base
for pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy will comply with
ARARs as summarized in Appendix C (Table C-9).
Capital Cost: S 7,000
Total Project Cost/Present Worth: $7,000. Annual O&M Costs: S 0
(not required)
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, soils excavated from Site 15 would be added
to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated soils would
be controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in Appendix C (Table
C-9).
Capital Cost: S 4,000
Total Project Cost/Present Worth: $4,000. Annual O&M Costs: $ 0
(not required)
Alternative IIS - Ex-Situ Bioremediation. Under this alternative, contaminated soils are excavated and aerated to stimulate
biodegradation. Contaminants are converted to carbon dioxide and water as a result of biodegradation processes. The
remedy will comply with ARARs as summarized in Appendix C (Table C-9).
Capital Cost: $ 43,000
Total Project Cost/Present Worth: $43,000. Annual O&M Costs: S 0
(not required)
Site 18 Subsurface Soil. Remedial alternatives evaluated for Site 18 subsurface soil have been limited to those that have
been successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated were
as follows:
IS - No Action
2S - Limited Action
10S - Bioventing
12S - Soil Vapor Extraction with Catalytic Oxidation
13S - Soil Vapor Extraction with Purus PADRE System
Alternative IS - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison of
existing 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. Compliance
with ARARs is not required for a no-action decision, therefore, ARARS are not summarized in Appendix C (Table C-10).
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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 the
potential for direct site contact and monitoring contaminant concentrations. The limited action alternative provides no
reduction in contaminant concentrations. This alternative does not reduce the toxicity, mobility or volume of contamination
since no treatment is involved. No ARARs apply to the limited action alternative as summarized in Appendix C (Table C-
10).
Total Project Cost/Present Worth: $400,000.
Capital Cost: S 57,477
Annual O&M Costs: S 33,124
(30 years required)
Alternative 10S - Bioventing. Bioventing is an in-situ treatment technology for hydrocarbon-contaminated soils including
petroleum products. Bioventing is the process of accelerating the natural microbial biodegradation of hydrocarbons in
unsaturated zone soils by providing sufficient air flow in these soils to maintain oxygenated conditions. Under aerobic (with
oxygen) conditions, indigenous microorganisms that are already acclimatized to using the hydrocarbons as an energy source
reduce contaminants to carbon dioxide and water. Either air injection or withdrawal can be used. However, air injection
offers the additional benefit of no secondary residuals (i.e., vapor) to control. The remedy will comply with ARARs as
summarized in Appendix C (Table C-10).
Total Project Cost/Present Worth: $891,000.
Capital Cost: $ 863,954
Annual O&M Costs: $ 26,740
1 year only: (project costs are incurred during
1st year)
Alternative 12S - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 18 are primarily VOCs. SVE removes
VOCs 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 and
water. The remedy will comply with ARARs as summarized in Appendix C (Table C-10).
Total Project Cost/Present Worth: $1,229,000.
Capital Cost: S
Annual O&M Costs: $
1 year only: (project costs
1st year)
979,704
130,000
are incurred during
Alternative 13S - Soil Vapor Extraction with Purus PADRE System. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 18 are primarily VOCs. SVE removes
VOCs from unsaturated soils by mechanically drawing air through the soil pore spaces, transferring the contaminants to the
vapor phase. The PADRE System removes contaminants in the contaminated air stream by adsorption onto a proprietary
resin. The remedy will comply with ARARs as summarized in Appendix C (Table C-10).
Total Project Cost/Present Worth: $1,215,000.
Capital Cost: $ 1,014,469
Annual O&M Costs: $ 105,170
1 year only: (project costs are incurred
1st year)
during
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
2S - Limited Action
5S - Excavation and Low Temperature Thermal Desorption
7S - Excavation and Offsite Treatment
8S - Excavation and Onsite Consolidation
US - Ex-Situ Bioremediation
7-11
-------
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of other
proposed 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 ARARs 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 the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. This
alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARs
apply to the limited action alternative as summarized in Appendix C (Table C-ll).
Capital Cost: $ 29,085
Total 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 soils
are excavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and
destroys them in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C-ll).
Capital Cost: $ 372,000
Total Project Cost/Present Worth: $372,000. Annual O&M Costs: $ 0
(not required)
Alternative 75 - Excavation and Of/site Treatment. This alternative involves the excavation of contaminated surface soils
for treatment/reuse at an offsite location. The offsite facility will mix contaminated soils with asphalt. The mixture is used
as sub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy will
comply with ARARs as summarized in Appendix C (Table C-ll).
Capital Cost: S 374,000
Total 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 would
be added to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated
soils would be controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in
Appendix C (Table C-ll).
Capital Cost: $ 41,000
Total Project Cost/Present Worth: $41,000. Annual O&M Costs: $ 0
(not required)
Alternative US - Ex-Situ Bioremediation. Under this alternative, contaminated surface soils are excavated and aerated to
stimulate biodegradation. Nutrient amendments may also be required. Contaminants are converted to carbon dioxide and
water as a result of biodegradation processes. The remedy will comply with ARARs as summarized in Appendix C (Table
C-ll).
Capital Cost: $ 81,000
Total 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 and
concentrations, and site conditions. Remedial alternatives evaluated were as follows:
7-12
-------
IS - No Action
2S - Limited Action
12S - Soil Vapor Extraction with Catalytic Oxidation
13S - Soil Vapor Extraction with Purus PADRE System
14S - 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 of
existing site conditions with proposed remedial alternatives. No remedial action is implemented under the no action
alternative.
The no action alternative provides no protection of 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 site
contaminants. This alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is
involved. Compliance with ARARs is not required for a no-action decision, therefore, ARARS are not summarized in
Appendix C (Table C-12).
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 the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. This
alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARs
apply to the limited action alternative as summarized in Appendix C (Table C-12).
Total Project Cost/Present Worth: $400,000.
Capital Cost: $ 57,477
Annual O&M Costs: $ 33,124
(30 years required)
Alternative 12S - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs from
unsaturated 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 ARARs
as summarized in Appendix C (Table C-12).
Total Project Cost/Present Worth: $612,000.
Capital Cost: $ 481,457
Annual O&M Costs: $ 130,592
1 year only: (project costs are incurred
1st year)
during
Alternative 13S - Soil Vapor Extraction with Purus PADRE System. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs from
unsaturated 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 proprietary resin. The
remedy will comply with ARARs as summarized in Appendix C (Table C-12).
Total Project Cost/Present Worth: $621,000.
Capital Cost: $ 516,222
Annual O&M Costs: $ 55,579
1 year only: (project costs are incurred during
1st year)
Alternative 14S - Soil Vapor Extraction with Carbon Adsorption. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 31 are VOCs. SVE removes VOCs from
unsaturated soils by mechanically drawing air 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 as
summarized in Appendix C (Table C-12).
7-13
-------
Total Project Cost/Present Worth: $417,000.
Capital Cost:
Annual O&M Costs:
1 year only: (project
1st year)
$ 361,457
S 55,579
costs are incurred durine
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:
IS - 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
Alternative IS - No Action. The purpose of presenting a no action alternative is to provide a basis for comparison of other
proposed 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 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 2S - Limited Action. The limited action alternative provides some protection to human health by limiting the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. This
alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARs
apply to the limited action alternative as summarized in Appendix C (Table C-13).
Total Project Cost/Present Worth: $55,000.
Capital Cost:
Annual O&M Costs:
(30 years required)
19,087
3,480
Alternative 5S - Excavation and Low Temperature Thermal Desorption. Under this alternative, contaminated soils are
excavated and heated to volatilize and drive off contaminants. The process removes contaminants from the soil and destroys
them in an afterburner. The remedy will comply with ARARs as summarized in Appendix C (Table C-13).
Total Project Cost/Present Worth: $111,000.
Capital Cost: $ 111,000
Annual O&M Costs: S 0
(not required)
Alternative 7S - Excavation and Offsite Treatment. This alternative involves the excavation of contaminated surface soils
for treatment/reuse at an offsite location. The facility will mix contaminated soils with asphalt. The mixture is used as
sub-base for pavement. The PAH-contaminated soils bond with the asphalt, thereby minimizing risk. The remedy will
comply with ARARs as summarized in Appendix C (Table C-13).
Total Project Cost/Present Worth: $101,000.
Capital Cost:
Annual O&M Costs:
(not required)
101,000
0
Alternative 8S - Excavation and Onsite Consolidation. Under this alternative, surface soils excavated from Site 34 would
be added to the Site 4 wastes, beneath a low permeability cap. The principal threats from exposure to PAH-contaminated
soils would be controlled by emplacement beneath the cap. The remedy will comply with ARARs as summarized in
Appendix 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 US - Ex-Situ Bioremediation. Under this alternative, contaminated surface soils are excavated and aerated to
stimulate biodegradation. Nutrient amendments may be required. Contaminants are converted to carbon dioxide and water
as a result of biodegradation processes. The remedy will comply with ARARs as summarized in Appendix C (Table C-13).
Total Project Cost/Present Worth: $54,000.
Capital Cost: S 52,000
Annual O&M Costs: S 0
(not required)
Site 34 Subsurface Soils. Remedial alternatives evaluated for Site 34 subsurface soils have been limited to those that have
been successfully implemented at sites with similar contaminants and site conditions. Remedial alternatives evaluated were
as follows:
IS - No Action
2S - Limited Action
10S - Bioventing
12S - Soil Vapor Extraction with Catalytic Oxidation
13S - Soil Vapor Extraction with Purus PADRE System
Alternative IS - No Action. The purpose of presenting the no action alternative is to provide a basis for comparison of
existing site conditions with proposed remedial alternatives. No remedial action is implemented under the no action
alternative.
The no action alternative provides no protection of 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. Compliance with ARARs is not required for a no-action decision, therefore ARARs are not summarized in
Appendix 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 the
potential for direct site contact. The limited action alternative provides no reduction in contaminant concentrations. This
alternative does not reduce the toxicity, mobility or volume of contamination since no treatment is involved. No ARARs
apply to the limited action alternative as summarized in Appendix C (Table C-14).
Total Project Cost/Present Worth: $992,878.
Capital Cost: S 55,419
Annual O&M Costs: $ 83,654
(30 years required)
Alternative 10S - Bioventing. Bioventing is an in-situ treatment technology for hydrocarbon-contaminated soils such as
petroleum products. The contaminants of concern in subsurface soils at Site 34 are petroleum components. Bioventing is
the process of accelerating the natural microbial biodegradation of hydrocarbons in unsaturated zone soils by providing
sufficient air flow in these soils to maintain oxygenated conditions. Under aerobic (with oxygen) conditions, indigenous
microorganisms that are already acclimatized to using the hydrocarbons as an energy source reduce contaminants to carbon
dioxide and water. Either air injection or withdrawal can be used. However, air injection offers the additional benefit of
no secondary residuals (i.e., vapor) to control. The remedy will comply with ARARs as summarized in Appendix C (Table
C-14).
Total Project Cost/Present Worth: $89,000.
Capital Cost: $ 58,717
Annual O&M Costs: $ 29,545
1 year only: (project costs are incurred during
1st year)
Alternative 12S - Soil Vapor Extraction with Catalytic Oxidation. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 34 are primarily VOCs. SVE removes
VOCs from unsaturated 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 ARARs as summarized in Appendix C (Table C-14).
7-15
-------
Total Project Cost/Present Worth: $223,000.
Capital Cost: S 159,386
Annual O&M Costs: S 63,900
1 year only: (project costs are incurred during
1st year)
Alternative 13S - Soil Vapor Extraction with Purus PADRESystem. SVE is a proven technology for treatment of soils
contaminated with VOCs. The contaminants of concern in subsurface soils at Site 34 are primarily VOCs. SVE removes
VOCs from unsaturated 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 proprietary
resin. The remedy will comply with ARARs as summarized in Appendix C (Table C-14).
Total Project Cost/Present Worth: $204,000.
Capital Cost: S 151,540
Annual O&M Costs: $ 52,300
1 year only: (project costs are incurred
1st year)
during
7-16
-------
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF
ALTERNATIVES
The nine criteria established by CERCLA and Superfund Amendments and Reauthorization Act (SARA) were used to
evaluate the alternatives in detail. The nine criteria encompass statutory and practical factors that assist in gauging the overall
feasibility 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 a
remedy provides adequate protection of human health and the environment and describes how risks posed
through 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 is
used to determine whether each remedy will meet all ARARs or provide grounds for invoking a waiver
of the requirements. These include chemical-, location-, and action-specific ARARs. Appendix C provides
a detailed analysis of compliance with ARARs for each site/media remedy.
3. Long-term Effectiveness and Permanence. This criterion includes evaluation of the long-term
effectiveness of the remedy in maintaining protection of human health and the environment after the
response action is complete.
4. Reduction of Toxicity, Mobility, or Volume through Treatment. This criterion addresses the anticipated
performance of the specific treatment technologies that an alternative may employ.
5. Short-term Effectiveness. This criterion addresses the effectiveness of alternatives in protecting human
health and the environment during the construction and implementation of a remedy until the remedial
action is complete.
6. Implementability. This criterion addresses the technical and administrative feasibility of alternatives and
the 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 and
overhead) costs. Direct costs include materials, labor and equipment required to install a remedial
system, equipment for the remedial system, land and site-development, buildings and associated
utility services. Indirect capital costs include engineering licenses or permit fees, star: up costs, and
contingency allowances.
O&M Cost. O&M costs are post-construction costs necessary to ensure the continued effectiveness
of a remedial alternative. These costs include operating labor, maintenance, and materials, auxiliary
materials and energy, disposal of residues, purchased services (i.e., analytical laboratory), and
administrative services.
Total Project Cost. The total project cost represent the present worth of each of the alternatives
incorporating the capital cost and the annual O&M costs. They project time periods may be varied
for the various alternatives and the present worth analysis allows them to be evaluated on an equal
basis.
8. State Acceptance. This criterion summarizes the technical and administrative concerns of the State of
California for each remedial alternative presented.
9. Community Acceptance. This criterion indicates whether community concerns are addressed by each
cleanup 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 against
each criterion individually using a numerical system ranging from 1 to 5 (1 being least desirable and 5 being most desirable).
Compliance with criteria 8 and 9 were evaluated qualitatively by considering any objections, concerns, or preferences raised
by the community or the state. Tables 8-1 through 8-11 presents the ranking for each site. A detailed ARARs analysis
for each site/media alternative is presented in the tables in Appendix C.
8.1.1 Groundwater
Site 4 Groundwater Plume/OUl Groundwater Plume. A comparative analysis was completed using the alternatives and
criteria previously identified. The alternatives are:
1G - No Action
2G - Limited Action
3G - Direct Treatment with Liquid Phase GAC
4G - Ultraviolet (UV) and Chemical Oxidation Treatment
6G - Air Stripping with Carbon Adsorption
Overall Protection of Human Health and the Environment. With the exception of the no action and limited action
alternatives, all the potential remedial alternatives will provide overall protection of human health and the environment. The
no action and limited action alternatives will not reduce the long-term risk posed by the presence of TCE and PCE hi the
groundwater, 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 treatment
alternatives are capable of treating effluent to below MCLs. However, aquifer restoration is limited by the rate at which
contaminants can be extracted from the aquifer.
Long-term Effectiveness and Permanence. As stated previously, the no action and limited action alternatives provide no
reduction in risk since contaminants are not removed. The limited action alternative does provide long-term monitoring of
the site but provides no protection of human health and the environment. The three groundwater treatment alternatives will
reduce the magnitude of risk, by cleanup of the groundwater through contaminant removal. The direct treatment with liquid
phase 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 not
reduce 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 levels
of groundwater withdrawal and contaminant removal efficiencies.
Short-term Effectiveness. The three active remedial action alternatives (3G, 4G, 6G) include treatment of the groundwater
to remove contamination and therefore address both current and future risks. However, minor potential risks to the
community, workers and the environment through generation of dust may result during installation of the three treatment
alternatives. 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 training
of workers and adherence to standard operation procedures for disposal of residual wastes.
8-2
-------
TABLE 8-1
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR GROUNDWATER - SITE 4/OTJ1 GROUNDWATER
PLXJME MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative 1G
No Action
1
1
1
1
1
5
5
Alternative 2G
Limited Action
2
1
1
1
2
5
4
Alternative 3G
Direct Treatment
with Liquid Phase
GAC
5
5
4
5
3
5
4
Alternative 4G
t)V and Chemical
Oxidation
5
5
5
5
3
3
1
Alternative 6G
Air Stripping with
Carbon Adsorption
5
5
4
5
3
4
3
Total Score
15
16
31
27
29
-------
TABLE 8-2
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SOIL - SITE 4
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
2
1
2
5
4
Alternative 3S
RCRA Capping
4
3
4
3
3
4
3
Alternative 4S
Landfill Closure
4
4
4
3
3
4
3
Alternative 9S
Excavation and
Offsite Disposal
5
5
5
3
2
2
1
Total Score
15
17
24
25
23
-------
TABLE 8-3
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SURFACE SOIL - SITE 10
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
1
Alternative SS
Excavation and
Low
Temperature
Thermal
Desorption
5
5
5
5
3
4
2
Alternative 7S
Excavation and
Offsite
Treatment
5
5
5
5
3
4
3
Alternative 8S
Excavation and
Onsite
Consolidation
5
5
4
4
4
1
4
Alternative IIS
Ex-Situ
Bioremediation
5
5
5
5
3
2
2
Total Score
15
13
29
30
27
27
8-5
-------
TABLE 8-4
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SURFACE SOIL - SITE 15
MARCH ATR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
1
Alternative 5S
Excavation and
Low
Temperature
Desorption
5
5
5
5
3
4
3
Alternative 7S
Excavation and
Offsite
Treatment
5
5
5
5
3
3
4
Alternative 8S
Excavation and
Onsite
Consolidation
5
5
4
4
4
1
4
Alternative US
Ex-Situ
Bioremediation
5
5
5
5
3
2
2
Total Score
15
13
30
30
27
27
8-6
-------
TABLE 8-5
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR GROUNDWATER - SITE 18
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative 1G
No Action
1
1
1
1
1
5
5
Alternative 2G
Limited Action
2
1
1
1
2
5
4
Alternatives 3G/5G
Direct Treatment
with Liquid Phase
GAC/Total Fluids
Recovery
5
5
4
5
4
4
3
Alternatives 7G/5G
Air Stripping with
Catalytic
Oxidation/Total
Fluids Recovery
5
5
5
5
4
3
1
Alternatives 8G/5G
Air Stripping with
Puriis PADRE"
System/Total Fluids
Recovery
5
5
4
5
4
4
3
Total Score
15
16
30
28
30
8-7
-------
TABLE 8-6
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SUBSURFACE SOIL - SITE 18
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
4
Alternative 10S
Bioventing
5
5
5
5
3
4
3
Alternative 12S
Soil Vapor
Extraction with
Catalytic Oxidation
5
5
5
5
4
4
2
Alternative 13S
Soil Vapor
Extraction with
Pnrus PADRE'"
System
5
5
4
5
5
4
2
Total Score
15
16
30
30
30
-------
TABLE 8-7
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR GROUNDWATER - SITE 31
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicily, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative 1G
No Action
1
1
1
1
1
5
5
Alternative 2G
Limited Action
2
1
1
1
2
5
4
Alternative 3G
Direct Treatment
with Liquid Phase
GAC
5
5
4
5
4
5
3
Alternative 4G
UV and Chemical
' Oxidation
5
5
5
5
4
3
2
Alternative 6G
Air Stripping with
Carbon Adsorption
5
5
4
5
4
4
3
Total Score
15
16
31
29
30
8-0
-------
TABLE 8-8
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SURFACE SOIL - SITE 31
MARCH AIR FORCE BASE
Criteria .
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
3
Alternative 5S
Excavation and
Low
Temperature
Thermal
Desorption
5
5
5
5
3
4
1
Alternative 7S
Excavation and
Offsite
Treatment
5
5
5
5
4
4
1
Alternative 8S
Excavation and
Onsite .
Consolidation
5
5
4
4
4
1
4
Alternative IIS
Ex-Situ
Bioremediation
5
5
5
5
3
2
3
Total Score
15
15
28
29
27
28
-------
TABLE 8-9
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SUBSURFACE SOIL - SITE 31
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
4
Alternative 12S
Soil Vapor
Extraction with
Catalytic Oxidation
5
5
5
5
4
2
3
Alternative 13S
Soil Vapor
Extraction with
Punts PADRE
System
5
5
4
5
4
3
3
; Alternative ;i4S
Soil Vapor
Extraction with
Carbon Adsorption
5
5
4
5
4
3
4
Total Score
15
16
29
29
30
8-11
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TABLE 8-10
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SURFACE SOIL - SITE 34
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
3
Alternative 5S
Excavation ami
Low
Temperature
Thermal
Desorption
5
5
5
5
3
4
2
Alternative 7S
Excavation and
Offsite
Treatment
5
5
5
5
3
4
2
Alternative 8S
Excavation and
Onsite
Consolidation
5
5
4
4
4
1
4
Alternative IIS
Ex-situ
Bioremediation
5
5
5
5
3
2
3
Total Score
15
15
29
29
27
28
8-12
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TABLE 8-11
COMPARATIVE RANKING OF REMEDIAL ALTERNATIVES FOR SUBSURFACE SOIL - SITE 34
MARCH AIR FORCE BASE
Criteria
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Alternative IS
No Action
1
1
1
1
1
5
5
Alternative 2S
Limited Action
2
1
1
1
2
5
3
Alternative 10S
Biovcnting
5
5
5
5
4
5
4
Alternative 12S
Soil Vapor
Extraction with
Catalytic Oxidation
5
5
5
5
5
4
2
Alternative 13S
Soil Vapor
Extraction with
Purus PADRE
System
5
5
4
5
5
4
2
Total Score
15
15
33
31
30
-------
Implementability. The no action and limited action alternatives are easy to implement but will likely require future
groundwater 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 the
treatment processes. The likelihood that technical 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. In addition, there are a limited number of vendors for the UV and chemical oxidation system where the oxidation
includes 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 (51,148,000) 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 participated
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. The public comment period for the Proposed Plan was 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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any 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 and
criteria previously identified. The alternatives are:
1G - No Action
2G - Limited Action
3G/5G - Direct treatment with Liquid Phase GAC/Total Fluids Recovery
7G/5G - Air Stripping with Catalytic Oxidation/Total Fluids Recovery
8G/5G - Air Stripping with Purus PADRE System/Total Fluids Recovery
Overall Protection of Human Health and the Environment. Implementation of the no action alternative will result in a
continuation of risks to the community through the presence of the contaminants in groundwater, representing a potential
exposure pathway. The limited action alternative will slightly reduce risks to the community by monitoring contaminant
migration. The no action and limited action alternatives will not reduce the long-term risk posed by the presence of the
volatile petroleum hydrocarbons in groundwater at Site 18, and therefore are considered to pose an unacceptable risk to
human health and the environment. The three groundwater treatment remedial alternatives will reduce the contaminant
concentrations in groundwater, therefore providing protection to human health and the environment.
Compliance With ARARs. The no action and limited action alternatives will not meet ARARs. All three groundwater
treatment alternatives will reduce the contaminants present in treated groundwater at Site 18 to meet ARARs. All three
alternatives are capable of treating effluent to below MCLs; however, aquifer restoration is limited by the rate at which
contaminants 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. The limited action alternative does provide monitoring of the site. The three groundwater
treatment remedial alternatives will reduce the magnitude of risk through contaminant removal or destruction, which in all
cases is permanent and irreversible. Residuals management will be required for all three treatment alternatives, which
involve recycling of recovered fuels.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do not
reduce the toxicity, mobility or volume of contaminants in the groundwater while the three groundwater treatment remedial
alternatives significantly reduce these constituents. All three treatment alternatives provide similar levels of contaminant
removal.
Short-term Effectiveness. The three groundwater treatment alternatives include removal and treatment of the groundwater
to control plume migration and to reduce contamination to acceptable levels. Short-term risks to workers posed by
construction of any of the three treatment systems could be controlled using dust suppression techniques and personal
8-14
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protective equipment. The air stripping with catalytic oxidation and air stripping with Purus PADRE System alternatives
present 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 the
environment. These risks can be controlled with proper training of workers and adherence to standard operating procedures
for transportation, handling and disposal of this waste stream.
Implementability. The no action and limited action alternatives are easy to implement but will likely require future
groundwater treatment. The three ground water treatment alternatives will not require future treatment.
The differences in implementability among the three groundwater treatment alternatives are inherent in the treatment
processes. All three groundwater treatment alternatives will result in recovery of the floating product and offsite disposal
of recovered fuels. The implementation of air stripping to transfer the contaminants from the liquid to vapor phase prior
to adsorption onto activated carbon is advantageous due to the higher efficiency of the vapor phase adsorption process
resulting in reduced carbon usage as compared with liquid phase adsorption. However, this transfer results in additional air
permitting requirements and increased O&M.
The Purus PADRE System is a proprietary treatment system. Therefore the timely construction and efficient operation
of this system is dependent upon the supplier.
Cost. No action is by definition a no-cost alternative. Limited action (5400,000) is most favorable in terms of cost,
followed by liquid-phase GAC treatment/total fluids recovery (51,027,000), air stripping with Purus PADRE system/total
fluids recovery (51,288,000), and air stripping with catalytic oxidation/total fluids recovery (53,006,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and
participated 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 Toxic
Substances Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any 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:
1G - No action
2G - Limited Action
3G - Direct Treatment with Liquid Phase GAC
4G - Ultraviolet (UV) and Chemical Oxidation Treatment
6G - Air Stripping with Carbon Adsorption
Overall Protection of Human Health and the Environment. With the exception of the no action and limited action
alternatives, all the potential remedial alternatives will provide overall protection of human health and the environment. The
no 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 ARARs. The no action and limited action alternatives will not meet ARARs. All three groundwater
treatment alternatives will reduce the contaminants present in treated groundwater at Site 18 to meet ARARs. All three
alternatives are capable of treating effluent to below MCLs; however, aquifer restoration is limited by the rate at which
contaminants 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, but
provides no protection of human health and the environment. The three groundwater treatment alternatives will reduce the
magnitude of risk through contaminant removal to cleanup standards, and maintain reliable protection of human health and
the environment by removing the source. The direct treatment with liquid phase GAC and air stripping with carbon
8-15
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adsorption alternatives require disposal or regeneration of spent or used GAG, 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 not
reduce the toxicity, mobility or volume of contaminants in the groundwater. The direct treatment with liquid phase GAG,
air stripping with carbon adsorption and UV and chemical oxidation treatment alternatives provide for very similar levels
of contaminant removal efficiencies.
Short-term Effectiveness. The three remedial action alternatives include treatment of the groundwater to remove
contamination and therefore address this risk. However, a potential risk to the community, workers and the environment
through generation of dust may result during installation of the three treatment alternatives. 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 training of workers and adherence to standard
operating procedures for disposal of residual wastes.
Implementability. The no action and limited action alternatives are easy to implement but will likely require future
groundwater 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 the treatment processes. The
likelihood that technical problems will lead to schedule delays is considered low for direct treatment with liquid phase GAG,
moderate for air stripping with carbon adsorption and moderate for UV and chemical oxidation. There are a limited number
of 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 (5400,000) is rated most favorably, followed by air
stripping with vapor-phase GAG treatment ($1,068,000), liquid-phase GAG treatment ($1,102,000), and UV/chemical
oxidation ($1,549,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS 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. The
alternatives 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 overall
protection of human health and the environment. The no action alternative will not affect the mobility, toxicity, or volume
of Site 4 contaminants which are a continuing source of groundwater contamination. The limited action alternative provides
some protection to human health by limiting the potential for direct site contact. RCRA capping, landfill closure, and offsite
disposal 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 air
pathways. Offsite disposal will provide protection through removal of wastes and placement of wastes in an offsite facility
designed for waste management.
8-16
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Compliance with ARARs. The no action and limited action alternatives would not provide compliance with ARARs because
erosion of the landfill and deposition of contaminants into the Heacock Storm Drain would not be prevented. Both the RCRA
capping and landfill closure alternatives would provide compliance with ARARs because they prevent landfill erosion and
deposition of contaminants into the Heacock Storm Drain. The excavation and offsite disposal alternative removes site
contaminants to an approved facility which complies with ARARs.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to control or monitor
the migration of soil contaminants to groundwater. The limited action, RCRA capping and landfill closure alternatives
provide for monitoring of the site although only the RCRA capping and landfill closure are proven technologies for
controlling migration of soil contamination. Excavation and offsite disposal would remove site contaminants and provide
for long-term monitoring at an approved facility offsite.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and limited action alternatives do not
reduce the toxicity, mobility, or volume of the contaminated soil. The RCRA capping, landfill closure and offsite disposal
alternatives 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 immediate
impact on reduction of potential soil contaminant migration. Threats to workers and surrounding community during landfill
closure, RCRA capping, or excavation and offsite disposal could be controlled using dust suppression techniques and ongoing
contaminant monitoring.
Implementability. The no action and limited action alternatives can be easily implemented. The landfill closure and capping
alternatives are essentially construction activities and are easily implemented. The offsite disposal alternative requires the
availability of permitted disposal facilities and licensed waste transporters in addition to the excavation of contaminated soil.
Cost. No action is by definition 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 participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any 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 alternatives
are:
IS - No action
2S - Limited Action
5S - Excavation and Low Temperature Thermal Desorption
7S - Excavation and Offsite Treatment
8S - Excavation and Onsite Consolidation
US - Ex-Sim Bioremediation
Overall Protection of Human Health and the Environment. The excavation and offsite treatment, excavation and onsite
consolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protection
from the principal health and environmental threats associated with soils at Site 10. The no action alternative does not reduce
the 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
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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 for
this 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 access
to contaminated soils or to control or monitor the migration of soil contaminants offbase. The limited action, excavation
and offsite treatment, excavation and onsite consolidation, 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 low temperature thermal desorption alternatives provide permanent treatment. Excavation
and 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 do
not reduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsite
consolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation and
low temperature thermal desorption reduce the toxicity of the wastes. Blending contaminated soils with asphalt, as presented
in the excavation and offsite treatment alternative, increases the total volume of treated material. However, the contaminant
concentrations 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 occur
if sediments are left onsite. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situ
bioremediation, 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., dust
suppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presented
as a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermal
desorption presents a risk of contaminated air emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation is
not an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and
excavation 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 favorably
in 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 participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any 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. The
alternatives are:
IS - 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. Excavation and offsite treatment, excavation and onsite
consolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protection
from the principal health and environmental threats connected with soils at Site 15. The no action alternative does not reduce
8-18
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the 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 for
this 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 access
to contaminated soils or to control or monitor the migration of soil contaminants offbase. The limited action, excavation
and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and excavation and low temperature
thermal desorption alternatives provide for long-term although only the excavation and offsite treatment, ex-situ
bioremediation, and excavation and low temperature thermal desorption alternatives provide permanent treatment. Excavation
and 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 not
reduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsite
consolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation and
low temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavation
and offsite treatment alternative, increases the total volume of treated material. However, contaminant concentrations
identified are not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situ
bioremediation, 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., dust
suppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presented
as a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermal
desorption presents a risk of contaminated air emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation is
not an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and
excavation 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 (54,000) is rated
most favorably in terms of cost, followed by excavation and offsite treatment ($7,000) excavation and low temperature
thermal 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 participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS 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:
IS - No Action
2S - Limited Action
10S - Bio venting
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 the
Purus PADRE System alternatives provide protection from the principal health and environmental threats associated with
soils at Site 18. The no action alternative does not reduce the migration of contaminants to the groundwater and therefore
8-19
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does not control contaminant exposure. The limited action alternative provides some protection to human health by
monitoring contaminant migration.
Compliance With ARARs. There are currently no applicable cleanup criteria for the contaminants of concern in soils at
Site 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. These
technologies 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 initially
to confirm that these technologies can attain the proposed cleanup criteria.
Long-term Effectiveness and Permanence. The no action alternative provides no risk reduction since contaminants are
not removed or treated. The limited action alternative provides for monitoring of the site although no contaminants are
removed or treated. SVE with catalytic oxidation, SVE with Purus PADRE System, and bioventing will reduce the
magnitude of risk through removal or destruction of contaminants. The final amount of residual contaminant with each of
these 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 do
not reduce the toxicity, mobility, or volume of contaminants in the soil, while the SVE with catalytic oxidation, SVE with
Purus PADRE System, and bioventing treatment alternatives significantly reduce toxicity of soils by destroying or removing
contaminants. SVE with Purus PADRE System will generate vapor treatment residual wastes. The bioventing and SVE
with 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 and
the environment through generation of dust during installation. This potential risk can be addressed through implementation
of engineering controls such as dust suppression. With SVE, there is a potential for release of vapors if the vapor abatement
system malfunctions. However, this risk can be minimized by using engineering controls such as automatic shut-offs. SVE
will probably require a shorter time period than bioventing for removal of a given mass of contaminants.
Implementability. The primary differences in implementability of the alternatives are those that exist between the no action
or limited action alternatives and the treatment alternatives. The no action and limited action alternatives can easily be
implemented and the treatment alternatives will be more difficult to implement. The three treatment alternatives will require
pilot scale treatability 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 used
technology; however, the subsurface soil characteristics may limit optimum air flow through the soil. Similarly with
bioventing, the ability to supply oxygen to the vadose zone may be impeded by fine-grained subsurface materials. SVE
generates treatment residuals which require further treatment while bioventing does not. There is little difference in
implementability between SVE with catalytic oxidation and SVE with Purus PADRE System with the exception that the
Purus 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 (5891,000), SVE with Purus PADRE System (51,215,000), and SVE with catalytic oxidation
(51,229,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/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. The
alternatives are:
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IS - 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 onsite
consolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protection
from the principal health and environmental threats connected with soils at Site 31. The no action alternative does not reduce
the migration of contaminants offsite 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 for
this 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 access
to contaminated soils or to control or monitor the migration of soil contaminants offbase. The limited action, excavation
and offsite treatment, excavation and onsite consolidation, 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 low temperature thermal desorption alternatives provide permanent treatment. Excavation
and 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 not
reduce the toxicity, mobility, or volume through treatment. Excavation and offsite treatment, and excavation and onsite
consolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation and
low temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavation
and offsite treatment alternative, increases the total volume of treated material. However, the contaminant concentrations
identified are not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situ
bioremediation, 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., dust
suppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presented
as a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermal
desorption presents a risk of contaminated air emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation is
not an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and
excavation 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 (341,000) is rated most favorably
in terms of cost, followed closely by limited action ($65,000), ex-situ bioremediation ($77,000), excavation and low
temperature 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 participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS 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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IS - No Action
2S - Limited Action
12S - Soil Vapor Extraction with Catalytic Oxidation
13S - Soil Vapor Extraction with Purus PADRE System
14S - Soil Vapor Extraction with Carbon Adsorption
Overall Protection of Human Health and the Environment. The SVE with catalytic oxidation, SVE with Purus PADRE
System, and SVE with carbon adsorption alternatives provide protection from the principal health and environmental threats
associated with subsurface soils at Site 31. The no action alternative does not reduce the migration of contaminants to the
groundwater and therefore does not control contaminant exposure. The limited action alternative provides some protection
to human health by monitoring the migration of contaminants.
Compliance With ARARs. There are currently no applicable cleanup criteria for the contaminants of concern in soils at
Site 31. SVE remedial alternatives will reduce the concentrations of contaminants present in the soil and 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 testing is required to confirm technical feasibility of the technologies.
Long-term Effectiveness and Permanence. The no action alternative provides no long-term risk reduction since
contaminants are not removed or treated. The limited action alternative provides for monitoring of the site although no
contaminants are removed or treated. SVE with catalytic oxidation, SVE with Purus PADRE System and SVE with carbon
adsorption will reduce the magnitude of risk through removal or destruction of contaminants. The final amount of residual
contaminant with each of these remedial alternatives will be affected by site-specific conditions; therefore, some residual
risk may remain. SVE with Purus PADRE system and SVE with carbon adsorption will generate treatment residuals
requiring further handling.
Reduction of Toxicity, Mobility, or Volume Through Treatment. The no action and the limited action alternatives do
not reduce the toxicity, mobility or volume of contaminants in the soil while the SVE alternatives significantly reduce waste
toxicity by removing contaminants.
Short-term Effectiveness. The SVE alternatives present a potential risk to the community, workers and the environment
through generation of dust and organic vapors during installation. This potential risk can be addressed through
implementation of engineering controls such as dust suppression. With SVE, there is a potential for release of vapors during
treatment if the vapor abatement system malfunctions, however, this risk can be minimized by using engineering controls
such as automatic shut-offs.
Implementability. The primary differences in implementability of the alternatives are those that exist between the no action
or limited action alternatives and the treatment alternatives. These differences are that no action and limited action can easily
be 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 (5467,000), SVE with Purus PADRE System ($717,000), and SVE with catalytic
oxidation ($730,000).
State Acceptance. The State of California was actively involved in the RI/FS and remedy selection process and participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS 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:
IS - No Action
2S - Limited Action
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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 onsite
consolidation, ex-situ bioremediation, and excavation and low temperature thermal desorption alternatives provide protection
from the principal health and environmental threats connected with soils at Site 34. The no action alternative does not reduce
the migration of contaminants offsite 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 for
this 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 monitor
the migration of soil contaminants offbase. The limited action, excavation and offsite treatment, excavation and onsite
consolidation, 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 low
temperature thermal desorption alternatives provide permanent treatment. Excavation and 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 not
reduce the toxicity, mobility and volume through treatment. Excavation and offsite treatment, and excavation and onsite
consolidation would effectively reduce the mobility of site contaminants. Only ex-situ bioremediation, and excavation and
low temperature thermal desorption reduce the toxicity of the wastes. Blending soils with asphalt, as presented in excavation
and offsite treatment, increases the total volume of treated material. However, the contaminant concentrations identified are
not expected to impede the asphaltic encapsulation process.
Short-term Effectiveness. In the excavation and offsite treatment, excavation and onsite consolidation, ex-situ
bioremediation, 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., dust
suppression, hearing protection) and therefore the short-term risks are judged to be controllable. Community risks presented
as a result of the transportation of the sediments either onbase or offsite, are considered negligible. Low temperature thermal
desorption presents a risk of contaminated air emissions, however these can easily be controlled.
Implementability. The no action and limited action alternatives have no construction phase and as such implementation is
not an issue. The excavation and offsite treatment, excavation and onsite consolidation, ex-situ bioremediation, and
excavation 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 favorably
in 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 participated
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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary 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 - Limited Action
10S - Bioventing
12S - Soil Vapor Extraction with Catalytic Oxidation
13S - Soil Vapor Extraction with Purus PADRE System
Overall Protection of Human Health and the Environment. With the exception of the no action and limited action
alternative, all the potential remedial alternatives will provide overall protection of human health and the environment. The
no action alternative will not reduce the long-term risk posed by the presence of the petroleum-derived organics in soil at
Site 34. The limited action alternative will provide minimal protection to human health and the environment through
monitoring of contaminant migration. However, the site would continue to be a source of groundwater contamination.
Compliance With ARARs. There are currently no applicable cleanup criteria for the contaminants of concern in soils at
Site 34. Preliminary remediation goals for subsurface soils at this site are based on groundwater protection.
Long-term Effectiveness and Permanence. The no action alternative does not provide a mechanism to control or monitor
the migration of soil contaminants offbase. The limited action alternative provides for monitoring of the site. The bioventing
alternative and the SVE alternatives will reduce the magnitude of risk through contaminant reduction. The final amount of
contaminant reduction with each of these remedial alternatives will be affected by site specific conditions; therefore, some
residual risk may remain. The SVE with Purus PADRE System generates residual wastes requiring further handling; no
other alternative generates residual wastes.
Reduction of Toxicity, Mobility, or Volume Through Treatment. No action and limited action alternatives do not reduce
the toxicity, mobility, or volume of contaminants in the soil. Both of the SVE alternatives and the bioventing alternative
reduce waste toxicity by removing or destroying contaminants.
Short-term Effectiveness. Implementation of the no action and limited action alternatives will result in a continuation of
risks 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 dust
and organic vapors may result during installation of any of the treatment remedial alternatives. This potential risk can be
addressed through implementation of engineering controls such as dust control. Due to the removal of contaminated vapors
in the SVE technique, an additional potential risk to the community, workers, and the environment is possible exposure to
contaminated vapors should the vapor treatment system fail. The risk can be reduced through engineering controls, such
as automatic shut-offs.
Implementability. The SVE and bioventing alternatives are proven technologies that do not present major implementation
problems. However, subsurface soil characteristics may cause operational problems related to the ability to attain optimum
air flow or oxygenated conditions in site soils. Pilot studies will be required to demonstrate technical feasibility and to
generate data for full-scale system design.
Minimal action is required to implement either the No Action or Limited Action alternative and as such implementability
is not considered an issue.
Cost. No action is by definition a no-cost alternative. Bioventing (389,000) is rated most favorably in terms of cost,
followed by limited action ($180,000), SVE with Purus 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 and
participated 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 Toxic
Substance Control, and California Regional Water Quality Control Board, Santa Ana, attended the public meeting to address
any questions concerning the RI/FS and Proposed Plan. A Responsiveness Summary is included as Appendix A.
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9.0 SELECTED REMEDIES
Modification to the selected remedies may be necessary as a result of remedial design (RD) construction processes. Detailed
design specifications, performance evaluations, verification sampling methods, and schedule will be determined during the
RD. 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 cleanup
standards have been achieved. The following are the preferred alternatives for each site to be remediated.
9.1 GROUNDWATER
Site 4/OU1 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 extraction
component of the system consists of nine wells that were located in order to interdict the Site 4 and OU1 plumes at the base
boundary. The treatment system utilizes GAC to remove contaminants of concern.
The preferred remedy for the Site 4/OU1 groundwater plume is to utilize the existing GETS system, supplemented with
additional extraction wells and GAC treatment units as necessary (Alternative 3G), and to stop the migration of the onbase
plume offbase and to treat the contaminated groundwater in the existing plume. Contaminated groundwater extracted from
Site 4 will be combined for treatment with groundwater extracted from the OU1 plume. Treated water will be discharged
to either the base wastewater treatment plant, the Heacock Storm Drain downgradient from the wetlands location, or injected
into the aquifer. The Heacock Storm Drain discharges to the Ferris Valley Storm Drain Lateral A. An unlined infiltration
pond 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 onbase
contaminated groundwater and will prevent further escape of onbase contaminated groundwater offbase.
Since there are low concentrations of contaminants (a maximum of 19 /ig/1 and 42 /ig/1, PCE and TCE, respectively) in the
downgradient plume, this portion of the plume will be allowed to dissipate. This decision is based on the following three
factors:
First, the predictive modeling performed by the Air Force, as well as recent sampling results, indicate that
dissipation may be presently occurring. With the elimination of the source for the downgradient plume
through 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 will
accelerate, resulting in dissipation.
Second, on completion of the risk assessment, it was determined that the risk from allowing the
contaminants in the downgradient plume to naturally dissipate is within EPA's acceptable cancer risk range
of 1 x 10"1 to 1 x 10"6. With the existing levels of contaminants, residential use of the groundwater in the
downgradient plume is within a cancer risk range of 10"5. Although the Air Force has been advised by the
Eastern Municipal Water District that their district provides full water service and that there are no known
users of this groundwater, the Air Force will continue to monitor the progress of the dissipation of
contaminants. Through this monitoring, it will be possible to determine whether additional measures are
necessary to assure that there are no threats to human health or the environment during the period of
dissipation of the downgradient plume. As an additional safety precaution, the Air Force is notifying
County officials of the identity of property owners whose properties may be affected by the downgradient
plume and requesting that the County not issue permits to install wells until the contaminants have been
reduced below cleanup standards.
Third, the existing groundwater data indicate that levels of TCE and PCE contamination in the
downgradient 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 OU1 contaminant plume (including the
downgradient plume) was included in the Draft RI/FS Report for OU1 in July 1993. The system was
projected to have a total cost exceeding 12 million dollars, or approximately 10 million dollars more than
the chosen alternative. Past experience has indicated that it is difficult to treat such low levels of
contamination, and the incremental cost for treatment of the downgradient plume at this site was not
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considered to be warranted. Thus, the alternative of pumping and treating the entire OU1 plume was
deleted 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 ensure
that the maximum concentration of offbase contaminants continues to fall, and to ensure that the offbase plume does not
threaten offbase water supplies. Monitoring of the entire offbase plume will be conducted, which will necessitate installation
of additional monitoring wells to fully define the horizontal and vertical extent of contamination and monitor its movement
through time. Several additional wells will be installed offbase. The actual number and location of these wells will be
recommended 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 used
to evaluate the effectiveness of the augmented GETS system in stopping contaminant migration offbase, and to ensure
protection of offbase water supplies.
If monitoring data show that the operation of the GETS system combined with dissipation is not reducing the maximum
concentration of contaminants in the downgradient plume, or is not stopping migration of the onbase plume offbase, or if
offbase water supplies are threatened, then expansion of active treatment into the downgradient plume will be initiated. If
at the end of 30 years the contaminants have not dissipated to cleanup standards, then the Air Force will expand active
treatment 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 (EPA
Method 6010), semivolatile organics (EPA Method 8270), and California Title 22 General Minerals. Groundwater
measurements, to the nearest 0.01 foot, shall be obtained quarterly. All groundwater samples shall be collected using the
techniques described in Chapter 4 of the RCRA Groundwater Monitoring Technical Enforcement Guidance Document (EPA
1986b) 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 data
verification by the Air Force, the semi-annual reports will be forwarded to signatories of the FFA and other interested
parties. These reports will include semi-annual groundwater contour maps. At the conclusion of each five years of
sampling, 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 BREAKDOWN
INSTALLED CAPITAL:
Site Preparation
Installation of Wells
Construction Oversite
Extraction System
Groundwater Treatment
Subtotal Installed Capital:
Annual O&M Costs:
PRESENT WORTH OF O&M COSTS:
TOTAL PROJECT COSTS:
S 29,471
S 206,900
S 43,560
S 198,380
S 110,662
S 588,973
S 106,348
51,102,787
51,839,000
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 conduct
cleanup of the groundwater will be made.
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Site 18 Groundwater Plume. The preferred alternative for Site 18 involves a combination of soil and groundwater treatment
technologies. 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 order
to simultaneously extract groundwater and contaminated soil vapors. Dual extraction of soil vapors and groundwater will
enhance groundwater cleanup in several ways. Most importantly, the continuing source of contaminants from the vadose
zone will be removed. In addition, application of a vacuum to the dual-purpose wells will increase groundwater flow to the
wells. Lastly, by lowering the water table and exposing contaminated aquifer materials to air flow, contaminant mass
removal rates will be increased. This is because contaminants of concern are volatile, and are removed much more
efficiently in the vapor phase than in groundwater.
Groundwater will be remediated using total fluids recovery followed by oil/water separation and air stripping for groundwater
remediation (Alternatives 8G/5G). Free-phase product will be recovered in an above-ground oil/water separator for
recycling. Contaminated groundwater will be treated by air stripping to remove volatile contaminants, followed by liquid
phase carbon polishing to remove any remaining fuel components. Treated water will be discharged either to the base
wastewater treatment plant, to the Heacock Storm Drain downgradient from the wetlands location, or reinjected to the
aquifer. An unlined infiltration pond will be constructed over the plume area to store treated water during high flow periods
in the Heacock Storm Drain, if applicable. Contaminant-laden air from the SVE process and the air stripper will be cleaned
using 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 BREAKDOWN
INSTALLED CAPITAL:
Site Preparation
Installation of Wells
Construction Oversight
Extraction System
Groundwater Treatment
Design/Contingencies
Subtotal Installed Capital:
Annual O&M Costs:
PRESENT WORTH OF O&M COSTS:
TOTAL PROJECT COSTS:
S 27,871
S 54,990
S 9,410
S 67,030
S 60,116
S 54,855
S 274,271
S 72,608
S 752,916
51,027,188
Site 31 Groundwater Plume. Site 31 is a likely source for much of the TCE found in groundwater beneath OU1. The
preferred method for cleanup of groundwater at Site 31 is to use groundwater extraction and treatment (Alternative 3G) in
combination with SVE. Dual-purpose wells will be installed in order to simultaneously extract groundwater and contaminated
soil vapors. Dual extraction of soil vapors and groundwater will enhance groundwater cleanup in several ways. Most
importantly, the continuing source of contaminants from the vadose zone will be removed. In addition, application of a
vacuum to the dual-purpose wells will increase groundwater flow to the wells. Lastly, by lowering the water table and
exposing contaminated aquifer materials to air flow, contaminant mass removal rates will be increased. This is because
contaminants 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 downgradient
from the wetlands location, or reinjected to the aquifer. An unlined infiltration pond will be constructed over the plume area
to store treated water during high flow periods in the Heacock Storm Drain, if applicable. Soil vapors will be treated using
vapor phase GAC. GAC removes contaminants from the extracted vapor stream by adsorption on the carbon. When the
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carbon becomes saturated, it will be shipped offsite for regeneration. The estimated cost for groundwater extraction and
treatment at Site 31 is approximately 51,103,000. The cost breakdown is as follows:
COST SUMMARY BREAKDOWN
INSTALLED CAPITAL:
Site Preparation
Installation of Wells
Construction Oversight
Extraction Systems
Groundwater Treatment
Design/Contingencies
Subtotal Installed Capital:
Annual O&M Costs:
PRESENT WORTH OF O&M COSTS:
TOTAL PROJECT COSTS:
S 19,576
S 74,400
S 9,410
$ 120,275
S 55,896
S 69,890
S 349,446
S 72,664
S 753,497
$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-term
maintenance, and long-term monitoring. Closure of the landfill will minimize the potential for leachate generation and
further groundwater contamination.
Site 10. A small volume of contaminated soil at Site 10 requires cleanup. The preferred method of cleanup of these soils
is excavation and low-temperature thermal desorption (Alternative 5S). Low-temperature thermal desorption will destroy
the 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 (Alternative
5S). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and the
requirement for long-term monitoring.
Site 18. Subsurface soil remediation (Alternative 13S) at Site 18 has been combined with the remediation of the Site 18
groundwater plume. See the Site 18 groundwater plume discussion above for a detailed discussion of both soil and
groundwater remediation.
Site 31. The preferred method of cleanup of these soils is excavation and low-temperature thermal desorption (Alternative
5S). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and the
requirement for long-term monitoring.
Site 34. The preferred method of cleanup of these soils is excavation and low-temperature thermal desorption (Alternative
5S). Low-temperature thermal desorption will destroy the contaminants of concern, thereby eliminating risk and the
requirement for long-term monitoring.
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10.0 STATUTORY DETERMINATIONS
Under its legal authorities, EPA's involvement at Superfund sites is to undertake remedial actions that achieve adequate
protection of human health and the environment. In addition, section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete, the selected remedial action for OU1 must comply with
applicable or relevant and appropriate environmental standards established under Federal and state environmental laws unless
a statutory waiver is justified. The selected remedy also must be cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment technologies that permanently and significantly reduce the volume, toxiciry,
or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedies meet
the statutory requirements.
10.1 GROUND WATER
Site 4/OU1 Groundwater Plume - Direct Treatment with Liquid Phase GAC
Protection of Human Health and the Environment.- The selected remedy provides protection of human health and the
environment through recovery of contaminated groundwater and subsequent removal of the contaminants. The alternative
provides both short-term and long-term solutions to contaminant migration by removal of these constituents from the
groundwater. This alternative utilizes extraction and treatment technologies that have been successfully implemented at other
sites with similar conditions as well as at March AFB. Residuals from treatment (i.e. saturated activated carbon) will require
regeneration or offsite disposal.
Recovery of contaminated groundwater and subsequent removal of contaminants will provide long-term effective remediation
of 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 99
percent of the organic contaminants from the extracted groundwater and will reduce the concentrations of volatile organics
to 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 been
achieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completed
using conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated during
site 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 the
technology.
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, Tables C-l and C-2).
Cost-Effectiveness. The selected remedy was chosen because of the three remedies that provide effective overall protection
of human health and the environment, it is the least expensive.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum 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 the Site 4 and OU1 groundwater plumes. Direct
treatment with GAC provides the best balance of 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 that
employ treatment as a principal element. By treating the VOC-contaminated groundwater with GAC, the selected remedy
addresses the principal threat posed by the Site 4 and OU1 groundwater plumes through the use of a proven treatment
technology.
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Site 18 Groundwater Plume - Air Stripping with Purus PADRESystem/Total Fluids Recovery
Protection of Human Health and the Environment. The selected remedy provides protection of human health and the
environment through recovery of contaminated groundwater and subsequent removal of contaminants. Free-phase product
will also be recovered for recycling. The remedy provides both short-term and long-term solutions by removing the
contaminants from the groundwater. This alternative utilizes groundwater extraction and treatment technologies that have
been successfully implemented at sites with similar conditions. The selected remedy is a permanent solution to the existing
problem.
The process efficiency of the selected remedy has been demonstrated. Recovery of contaminated groundwater and subsequent
removal of contaminants will provide long-term effective remediation of 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 reducing the concentration of volatile organics present in the
extracted groundwater to 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 been
achieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completed
using conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated during
site 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 the
technology.
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, Tables C-3 and C-4).
Cost-Effectiveness. Two alternatives were rated equally on all evaluation criteria. The Purus PADRE system was chosen
because it can be used to treat not only contaminated vapors from the air stripper, but also contaminated vapors from the
SVE system, thereby minimizing costs for combined treatment of soil and groundwater.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum 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 the Site 18 groundwater plume. Groundwater
treatment through air stripping with treatment of the vapor stream with the Purus PADRE System provides the best balance
of 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 that
employ treatment as a principal element. By treating the fuel-contaminated groundwater with an air stripper, the selected
remedy addresses the principal threat posed by the Site 18 groundwater plume through the use of a proven treatment
technology.
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 the
environment through recovery of contaminated groundwater and subsequent removal of the contaminants. The remedy
provides both short-term and long-term solutions to contaminant migration by removal of these constituents from the
groundwater. The selected remedy utilizes extraction and treatment technologies that have been successfully implemented
at sites with similar conditions. Residuals from treatment (i.e. saturated activated carbon) will require regeneration or offsite
disposal.
Recovery of contaminated groundwater and subsequent removal of contaminants will provide long-term effective remediation
of 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 in
the extracted groundwater. Based on successful application at numerous similar sites, at least 99 percent of the organic
contaminants will be removed from the extracted groundwater. In addition, this alternative provides permanent, irreversible
treatment of the groundwater.
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Implementation of deed restrictions to prohibit the use of groundwater, until groundwater cleanup standards have been
achieved, will reduce or eliminate the threat of exposure to human health. The installation of the remedy will be completed
using conventional techniques, and no adverse impact to the community, workers, or the environment is anticipated during
site 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 the
technology.
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, 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 is
either cheaper than or comparable to the other alternatives.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum 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 the Site 31 groundwater plume. Direct groundwater
treatment with GAC provides the best balance of 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 that
employ treatment as a principal element. By treating the VOC-contaminated groundwater with GAC, the selected remedy
addresses the principal threat posed by the Site 31 groundwater plume through the use of a proven treatment technology.
10.2 SOIL
Site 4 - Landfill Closure
Protection of Human Health and the Environment. The selected remedy protects human health and the environment through
landfill closure and construction of a cap over the landfill which will reduce infiltration of precipitation and prevent erosion
of landfill wastes. Additionally, the closure would isolate the storm drainage system from the landfill material through the
installation of an impermeable vertical barrier. The selected remedy provides long-term maintenance and water quality
monitoring of the closure system, response programs, and establishment of a closure fund to support the required
maintenance 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 the
groundwater. The mobility of soil contaminants will be reduced through the construction of a low permeability cover and
a vertical barrier along the surface water drainage channel. Upon completion of the cap, the alternative will have an
immediate impact on reduction of potential soil contaminant migration.
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-7).
Cost-Effectiveness. The selected remedy was chosen because it was rated highest in terms of the overall evaluation criteria
and 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 the
Maximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions
can be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; and
cost.
Preference for Treatment as a Principal Element. The selected remedy does not satisfy 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 landfill
was conducted, no apparent source area for contaminants was observed.
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Site 10 - Excavation and Low Temperature Thermal Desorption
Protection of Human Health and the Environment. The selected remedy protects human health and the environment by
treating the contaminated soils with low-temperature thermal desorption. Exposure to PAH-contaminated soils is reduced
by reducing the PAH levels within the soils. The exposure to workers and the public during excavation and treatment of
contaminated soils 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 Site
10. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at the
site. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicity
reduction 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 applicable
or relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-8).
Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protection
of human health and the environment and are implementable, it is the only one that offers a permanent solution, and costs
are comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions
can be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; and
cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies that
employ treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet air
quality ARARs, the selected remedy addresses the principal threat posed by Site 10 soils through the use of proven treatment
technologies.
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 by
treating the contaminated soils with low-temperature thermal desorption. Exposure to PAH-contaminated soils is reduced
by reducing the PAH levels within the soils. The exposure to workers and the public during excavation and treatment of
contaminated soils 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 Site
15. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at the
site. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicity
reduction through low-temperature thermal treatment is dependant 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 applicable
or 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 protection
of human health and the environment and are implementable, it is the only one that offers a permanent solution, and costs
are comparable.
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Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions
can be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; and
cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies that
employ treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet air
quality ARARs, the selected remedy addresses the principal threat posed by Site 15 soils through the use of proven treatment
technologies.
Site 18 - Soil Vapor Extraction with Purus PADRESystem
Protection of Human Health and the Environment. The selected remedy protects human health and the environment by
mechanically removing volatile contaminants from unsaturated soils and treating the contaminants at the surface. This
remedy 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 the
technology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may not
be effectively treated to the required cleanup standards.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. Engineering
controls will be employed as necessary during the installation of the remedy to mitigate exposure to and offsite migration
of 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 the
environment is minimized.
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-10).
Cost-Effectiveness. Of the three alternatives that provide effective protection of human health and the environment, all were
rated equally in terms of the overall selection criteria. The selected remedy is slightly higher in cost, but was chosen because
it integrates with the Site 18 groundwater treatment system. The Purus PADRE system can be used to treat contaminated
vapors from both the SVE system and the air stripper, thereby minimizing costs of combined soil/groundwater treatment.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum 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. SVE provides the best balance
of 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 that
employ 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 of
proven 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 by
treating the contaminated soils with low-temperature desorption. Exposure to PAH-contaminated soils is reduced by reducing
the PAH levels within the soils. The exposure to workers and the public during excavation and treatment of contaminated
soils 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 Site
31. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at the
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site. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxicity
reduction 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 applicable
or relevant and appropriate chemical-, action-, and location-specific ARARs (refer to Appendix C, Table C-ll).
Cost-Effectiveness. The selected remedy was chosen because of the two similar alternatives that provide for overall protection
of human health and the environment and are implementable, it is the only one that offers a permanent solution, and costs
are comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions
can be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness 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 that
employ treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet air
quality ARARs, the selected remedy addresses the principal threat posed by Site 31 soils through the use of proven treatment
technologies.
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 by
mechanically removing volatile contaminants from unsaturated soils and treating the contaminants at the surface. This
remedy 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 the
technology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may not
be effectively treated.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. Engineering
controls will be employed as necessary during the installation of the remedy to mitigate exposure to and offsite migration
of 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 the
environment is minimized.
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-12).
Cost-Effectiveness. The selected remedy was chosen because of the three similar alternatives that provide for overall
protection of human health and the environment, it is the least expensive.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum 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. SVE provides the best balance
of 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 that
employ 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 of
proven treatment technologies.
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Site 34 Surface Soil - Excavation and Low Temperature Thermal Desorption
Protection of Human Health and the Environment. The selected remedy protects the human health and the environment by
treating the contaminated soils with low-temperature thermal desorption. Exposure to PAH-contaminated soils is reduced
by reducing the PAH levels within the soils. The exposure to workers and the public during excavation and treatment of
contaminated soils 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 Site
34. Low-temperature thermal treatment should effectively mitigate the risk by eliminating the residual contamination at the
site. Periodic inspections and long-term operation and maintenance would not be required for this alternative. Toxiciry
reduction through low-temperature thermal treatment is dependant 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 applicable
or 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 protection
of human health and the environment and are implementable, it is the only one that offers a permanent solution, and costs
are comparable.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Extent Practicable. The selected remedy represents the maximum extent practicable to which permanent solutions
can be utilized in a cost-effective manner. The selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence; reduction in toxicity, mobility, or volume; short-term effectiveness; implementability; and
cost.
Preference for Treatment as a Principal Element. The selected remedy satisfies the statutory preference of remedies that
employ treatment as a principal element. By removing PAHs from the soils and controlling the air emissions to meet air
quality ARARs, the selected remedy addresses the principal threat posed by Site 34 soils through the use of proven treatment
technologies.
Site 34 Subsurface Soil - Bioventing
Protection of Human Health and the Environment. The selected remedy protects human health and the environment through
enhancement of the natural microbial biodegradation of hydrocarbons in unsaturated soils. This remedy is completed by
providing sufficient air flow in the soil to maintain oxygenated conditions. This remedy will reduce soil contaminant
concentrations 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 the
technology is limited by subsurface soil conditions. It is therefore possible that in some areas the contamination may not
be effectively treated.
Implementation of the selected remedy should not adversely impact the community, workers, or the environment. The
injection of ambient air into the subsurface will not result in air discharges that could affect local residents. Monitoring of
surface ambient air will confirm potential discharges through the surface soils. The selected remedy has a positive impact
on the environment in that natural processes are used to degrade contaminants to non-toxic end products. The time period
for treatment is site specific depending upon the rate of degradation attainable with the microorganisms present in the soil
and 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 criteria
and is cheaper than other alternatives that provide effective protection of human health and the environment.
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Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Event 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 best
balance of 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 that
employ treatment as a principal element. By enhancement of the natural microbial biodegradation of hydrocarbons in
unsaturated zone subsurface soils, the selected remedy addresses the principal threat posed by Site 34 soils through the use
of treatment technologies.
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11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes to the OUI ROD were required as a result of public comments received by the Air Force.
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APPENDIX A
RESPONSIVENESS
SUMMARY
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Responsiveness Summary
A.
Overview
Prior to the public comment period March Air Force Base (AFB) had chosen preferred remedial
alternatives for each individual site within the Operable Unit 1 (OU1). The March AFB chosen
alternatives addressed the soil and/or groundwater problems for each site. The preferred alternative for
each site located within OU1 is as follows:
Site Number Contamination Media
4 Groundwater
4 Subsurface Soil
10 Surface Soil
15 Surface Soil
18 Groundwater
18 Subsurface Soil
31 Groundwater
31 Surface Soil
31 Subsurface Soil
34 Surface Soil
34 Subsurface Soil
Preferred AlternativeCs)
Direct treatment with liquid phase granular
activated carbon (GAC).
Landfill Closure
Excavation and on-site consolidation, or
excavation, or low temperature thermal desorption
Excavation and on-site consolidation, or
excavation, or low temperature thermal desorption
Air stripping with Purus PADRE system/ total
fluids recovery
Soil vapor extraction with Purus PADRE17'1 system
and bioventing
Direct treatment with liquid phase GAC adsorption
Excavation and on-site consolidation, or
excavation, or low temperature thermal desorption
Soil vapor extraction and carbon adsorption
Excavation and on-site consolidation, or
excavation, or low temperature thermal desorption
Bioventing
The Superfund Amendments and Reauthorization Act (SARA) of 1986 requires federal facilities, like
March AFB, to work closely with the Environmental Protection Agency (EPA) and follow their guidelines
while conducting hazardous waste site investigations and cleanup. Following a July 1989 proposal for
the inclusion of March AFB to the National Priorities List (NPL), March AFB began coordinating with
EPA, the California Department of Health and Safety (DHS), and the California Regional Water Quality
Control Board (RWQCB) to develop a plan to address the regulatory requirements of these agencies while
continuing ongoing efforts to characterize and clean up waste sites. These negotiations were successfully
concluded on September 27, 1990, by which time representatives of the three regulatory agencies and the
Air Force had signed the Federal Facilities Agreement (FFA). In September of 1990 the FFA provided
a schedule of future Installation Restoration Program (IRP)/Superfund activities at March AFB which was
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released for public comment.
B. Background on Community Involvement
The Remedial Investigation / Feasibility Study (RI/FS) report and Proposed Plan for OU1 were released
to the public on April 28, 1994. These two documents were made available to the public in the
Administrative Record, the information repositories at the Moreno Valley and March AFB libraries, and
at the Moreno Valley Chamber of Commerce. The notice of availability of these documents was
published in the Press-Enterprise on April 27, 1994. A fact sheet, condensed from the Proposed Plan, was
sent to everyone on the March AFB mailing list, which includes Restoration Advisory Board (RAB)
members. An OU1 RI/FS subcommittee, formed by the RAB, provided oral comments to the RAB at its
April 26, 1994 meeting.
C. Summary of Public Comments Received During Public Comment Period and Agency
Responses
A public comment period was held from April 28 to May 28, 1994. In addition, a public meeting was
held on May 12, 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, Santa Ana, attended the public meeting to address any questions about the RI/FS
and 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 lesser
known methods. The Air Force wants to get the cleanup done as quickly as possible, and to their
standards. They will pay extra for this.
2. Question: Why are you not moving sites 10 and 15 to Site 4?
March AFB Response: Air Force policy is to not move the problem somewhere else. To take care
of 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 more
expensive, but you picked the liquid-phase granular activated carbon. Was that because it is being
used 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?
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March 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 migrated
through 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 UVB
is up and running and has been working well, and the program has been extended for another
year. Earth Tech will be putting in two soil vapor extraction systems to work on the vadose zone
removal 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 operation
as 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 cost
effective to use thermal oxidation?
March AFB Response: The carbon is reused. We have elected to use the Purus system because
it recirculates the carbon and you never have to reinstall the carbon for a 20 year period. In the
GETS system, we install new carbon once a year, and we put in 20,000 pounds. Also, in these
types of systems there is always 10 percent left over that has hazardous material in it that we can
not rejuvenate. The Purus system does not do that.
6. Question: The minutes of the March 16 meeting, in describing the presentation on the OU1
Proposed Plan, say that there will be no further action on some sites. Could there be an
explanation 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
1. Question: What is the plan for Site 4 dust control, where the cap will be installed over the
landfill?
March AFB Response: We will be planting natural plants that do not need much water, that will
live with the existing rainfall we have. We do not want to put in a sprinkler system because that
just 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 not
puncture it. It will have one foot to 18 inches of soil on top. The life of the cap is a minimum
of 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 are
not proposing to bury anything more in the ground. We may be moving some contaminated
material into existing ones, and we have two alternatives. It is cheaper to move the contaminated
material than to oxidize it. We would prefer to dispose of it permanently (by oxidation), but if
we do not have the funding at the appropriate time to do that, we need a fallback position, which
is to move 2,000 yards of material that are similar to the landfill into the existing landfill and cap
it. We are still doing geophysical studies to see if the faults we have found on base have moved
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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 in
other 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 are
getting. We do not expect large amounts of movement of contaminants in the vadose zone, this
is an innovative system that has never been used at March AFB. It is a method of permanent
monitoring to determine vadose zone cleanup, and monitoring of groundwater cleanup. An
advantage of the system is that it monitors at discrete depths, so we can always tell if there is
migration to other areas, and if there is, there will be time to put in other methods of controlling
it.
Cost/Funding 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 in
primarily operation and maintenance (O&M), which will remain constant until the year 2010, at
which 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 the
monitoring.
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 the
repositories located at the RWQCB, the base library, and the Moreno Valley library. The EPA
can 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 Proposed
Plan and ask questions like you are now. The questions and answers will be written up and attached to
the Plan, so it will become a matter of permanent record. We will have court stenographer at that
meeting taking down the entire proceedings.
Enforcement
1. Question: In regard to the annual reviews, how stringent is EPA in following these annual
reviews; how frequently do they monitor?
EPA Response: This is really two questions. The first is how often the monitoring is done, and
A-4
-------
John (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 are
statutory requirements.
Part II - Comprehensive Response to Specific Legal and Technical Questions
Reports by the Engineering Evaluation/Cost Analysis (EE/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 no
munitions at Site 2 which was a waste oil/paints/solvents site. The munitions are associated with
Site 25 A and B.
2. Comment by Ms Helen Grinyer. There's a mistake in English, too "With on" should be "With
only" (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 not
mentioned in the EE/CA. There might have been a mis-communication between the contractor
who did the report and the contractor who did the survey. The EE/CA will be corrected to
include the last survey.
3. Comment by Ms. Helen Grinyer: In Figures 2-4 and 2-5, magnetic surveys, the gas line doesn't
show up although it is shown in Figure 2-7.
March AFB Response: If these Figures were the magnetometer surveys, the gas line should have
been detected and be included in the Figures. This will be reviewed and corrected.
4. Question: How was the benzene concentration determined?
March AFB Response: There is a series of EPA protocols that are used to determine the
contaminants. They should have listed all the EPA protocols and what types of contaminants that
they find.
Comment: The figures given don't reflect the maximum amount of benzene allowed as shown
on 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 you
keep the contaminants from being airblown during the process?
March AFB Response: The contamination is only 5 parts per billion, which is a low level. If
there is a problem, a foam spray is available to spray on the dirt to keep airborne emissions down.
A-5
-------
The Air Force will be requiring the contractors to comply with all local, state, and federal
regulations to prevent and airborne emissions. The exact methods to be used are left up to the
contractors.
Site 17
1. Comment by Mr. Barry McClellan: I've had most of my questions answered in the report and
from 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 according
to standard protocol. You've tested the soil around the pool, and afterwards you will be coring
to test the soil under the pool.
March AFB Response: We'll remove the pool entirely. The concrete will be taken out, the soil
at the bottom will be sampled to determine the degree of contamination, and if there is
contamination then wee will develop a system that will work.
D. Remaining Concerns
None
A-6
-------
APPENDIX B
ADMINISTRATIVE
RECORD INDEX
-------
-------
ADMINISTRATIVE RECORD INDEX
KRK OU
AR0174 I
AR0176 1
AR0001 2
AR0002 I)
AR0003 2
AR0004 R
AR0005 I
AR0006 2
AR0007 1
AR0172 B
AR0173 B
AR0135 2
AR0129 2
AR0008 B
AROI70 B
AR0100 B
TITLE
ADDITIONAL SITE CHARACTERIZATION, WORK PLAN ADDENDUM
OPERABLE UNIT 1
ADDLSITE CHARACTERIZATION WORKPLAN ADDENDUM, OU#1
AIR FORCE CORDONS OFF POSSIBLY TOXIC MATERIALS
AIR FORCE ENVIRONMENTAL PROGRAM CLEANS UP HAZARDOUS
WASTE SITES
AIR FORCE VILLAGE WEST LAND CONVEYANCE ENV ASSESSMENT
AREA 5, PANERO. SITE 11, STATEMENT OF WORK DRILLING AND
WELL INSTALLATION
BASE EXTRACTS, CLEANS CONTAMINATED WATER
BASE WASTE DUMP FOUND IN GRAVEL PIT
BASE WELLS SET TO CLEAR POLLUTION
BASEWIDE GROUNDDWATER MONITORING PROGRAM - SUMMER QTR
1993
BASEWIDE GROUNDWATER MONITORING PROGRAM - SPRING QTR
1993
BUDGET AND SCHEDULE CONFIRMATION, APPENDIX A
CALTRANS SAMPLING RESULTS
CERCLA OF 1980
CHILD DEVELOPMENT CENTER EXPANSION FINAL PRELIM
ENDANGEKMENT ASSESS
CITY OF MORENO VALLEY COMMENTS ON MAFB FFA
DATE
11/01/93
12/03/93
01/17/92
08/30/91
10/01/87
02/26/91
05/22/92
01/18/92
05/15/92
10/01/93
10/01/93
01/06/92
02/25/92
12/12/86
01/07/93
01/02/91
TYPE
WORK PLAN
DOCUMENT REVIEW
NEWSPAPER ARTICLE
NEWSPAPER ARTICLE
REPORT
REPORT
PRESS RELEASE
NEWSPAPER ARTICLE
NEWSPAPER ARTICLE
ANALYTICAL DATA
ANALYTICAL DATA
WORK PLAN
CORRESPONDENCE
FEDERAL DOCUMENT
REPORT
DOCUMENT REVIEW
AUTHOR
EARTH TECH CORP
RICHARD RUSSELL
UNKNOWN
WENDY WILLIAMS, 22
ARW/PA
WIKHAUS &
ASSOCIATES
INEL
KIM RANSFORD, 22
ARW/PA
GARY POLAKOVIC
GARY POLAKOVIC,
PRESS ENTERPRISE
TETRA TECH
TETRA TECH
RADIAN CORP
JOHN KEMMERER, US
EPA
US CONGRESS:
WASHINGTON
TETRA TECH
MURRAY L. WARDEN,
CITY MANAGER
RECIPIENT
AFCEE/ESR
JOIINSABOL
BEACON
SAC
BEACON
HQ AMC
HQ AMC
US CORP OF
ENGINEERS
LAWRENCE WATSON,
22 CES/DEV
USEPA: NAFB:
HQ AMC/CEVR
22 AREFW/PA
B-l
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0009 B
AR0010 B
AROOI1 B
AR0012 I
AR0013 1
AR0014 B
AROOI5 B
AR0111 B
AR0130 2
AR0143 B
AR0180 3
AROI54 2
AR0016 1
AR0017 B
AROI68 U
AR0169 B
AR0167 I)
AROI66 B
TITLE
COMMUNITY RELATIONS PLAN FOR MARCH AFB, FINAL
COMPILING ADMINISTRATIVE RECORDS IN REGION 9, DRAFT
COMPREHENSIVE SITE MANAGEMENT PLAN
DESIGN DESCRIPTION, SEPCIFICATIONS DRAWINGS AREA 5
DISPLAY AD FOR GETS PUBLIC MEETING
DISPLAY AD FOR TECHNICAL REVIEW COMMITTEE
DISPLAY AD, TRC MEETING 14 MAY 92
DOD AND STATE MEMORANDUM OF AGREEMENT (DSMOA)
DRAFT FINAL RI/FS WORKPLAN AND SAP DEADLINE
DRAFT INVESTIVATION-DERIVED WASTE MANAGEMENT PLAN
EE/CA REPORT, OU #3 REMOVAL ACTION - DRAFT FINAL
ENERGY DISSIPATORS, SITE 40 WORK PLAN
ENG EVAI7COST ANALYSIS AREA 5 AND SITE 5 REMOVAL ACTIONS
GETS
ENVIRONMENTAL PROGRAM DEVELOPS CLEANUP PLAN
EXPANDED SOURCE INVEST/KCRA APPENDIX 1): VISUAL SITE 1NSP
NOTES - VOL 1
EXPANDED SOURCE INVEST/RCRA APPENDIX B: VISUAL SITE INSP
NOTES - VOL 2
EXPANDhS OURCE INVESTIGA'IION/RCRA APPhNDIX A: - PHOTO LOG
EXPANDEDSOURCE INVEST1GATION/RCRA FACILITY ASSESSMENT
DATE
05/01/91
01/17/91
12/01/90
05/30/91
05/19/92
02/22/92
05/08/92
11/08/90
07/24/92
08/26/92
12/01/93
09/01/92
01/01/91
06/22/90
10/01/92
10/01/92
10/1/92
05/01/93
TYPE
COMMUNITY
RELATIONS
PROGRAM GUIDANCE
PLAN
WORK SPECIFICATION
PUBLIC NOTICE
PUBLIC NOTICE
PUBLIC NOTICE
INTER-AGENCY
AGREEMENT
CORRESPONDENCE
DOCUMENT REVIEW
REPORT
WORK PLAN
REPORT
NEWSPAPER ARTICLE
REPORT
REPORT
REPORT
REPORT
AUTHOR
ALBERT B.: EBASCO:
USEPA/R9:
INEL
KIM RANSFORD, 22
SPTG/DEV
KIM RANSFORD, 22
ARW/PA
KIM RANSFORD
DOD/STATE
RICHARD RUSSELL
JOHN BRODERICK,
CRWQCB
INEL
KLEIKFELDER
INEL
SGT RENEE WRIGHT
EARTH TECII
EARTH TEC! I
EARTH TECII
EARTH TECII
RECIPIENT
EG&G: INEL:
MAFB/DEV/PAR:
MEIDLEIM C,
MAFB/PAE
DOD/DEV
PRESS-ENTERPRISE
PRESS-ENTERPRISE
PRESS ENTERPRISE
22 CSG/DEV
JOHN SABOL
JOHN SABOL
MARCH AFB
MARCH AFB
MAFB
I1Q AMC
HQ AMC
1 IQ AMC
HQ AMC
B-2
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0018 B
AR0156 n
AR0158 B
AR0157 B
AR0155 B
AR0019 3
AR0120 1
AR012I 1
AR0122 1
AR0126 1
AROI39 2
AR0134 2
AR0020 3
AROI09 B
AR0148 B
AR0170 1
AKOI62 U
AR0106 B
TITLE
FEDERAL FACILITIES AGREEMENT, MARCH AIR FORCE BASE, CALIF.
FFA DRAFT PRIMARY DOCUMENT DEADLINES
FFA DRAFT PRIMARY DOCUMENT DEADLINES
FFA DRAFT PRIMARY DOCUMENTS AND SUBMITTAL DEADLINES
FFA REVISED DRAFT PRIMARY DOCUMENT DEADLINES
FREE PRODUCT RECOVERY, PANERO
GETS STARTUP DATE
GETS STARTUP DATE
GETS STARTUP DATE
GROUNDWATER CLEANUP AT EAST MARCH AFB
GROUNDWATER SAMPLING AND ANALYSIS PLAN ADDENDUM, SITE II
HEALTH & SAFETY PLAN CALTRANS T.O. NUMBER 08-227502-03
HEALTH & SAFETY PLAN, PANERO DRAFT
INTER-AGENCY AGREEMENT BETWEEN USAF AND ATSDR
INVESTIGATION-DERIVED WASTE MANAGEMENT PLAN - DRAFT
IRP SAMPLING & ANALYSIS PLAN ADDENDUM
LETTER ()l; CONCERN
MAFB REMEDIAL PROJECT MANAGER
DATE
09/27/90
01/23/91
01/08/91
02/07/91
02/06/91
03/01/90
12/20/91
01/14/92
02/05/92
05/20/92
01/12/91
01/07/92
04/01/90
01/18/91
10/01/92
10/01/93
0-1/05/90
03/06/92
TYPE
INTER-AGENCY
AGREEMENT
CORRESPONDENCE
DOCUMENT REVIEW
CORRESPONDENCE
CORRESPONDENCE
REPORT
COMMENTS
COMMENTS
COMMENTS
FACT SHEET
PLAN
WORK PLAN
PLAN
INTER-AGENCY
AGREEMENT
DOCUMENT REVIEW
PLAN
CORRESPONDENCE
INTER-AGENCY
AGREEMENT
AUTHOR
USEPA: MAFB: CDBS:
SARWQCB:
JAMES E. FREDERICK
RICHARD RUSSELL
RICHARD RUSSELL
J. POLAND
HYDRO-FLUENT, INC
RICHARD RUSSELL, US
EPA
LTC THOMAS GROSS, 22
SPTG/DE
RICHARD RUSSELL, US
EPA
KIM RANSFORD
INEL
GEO/RESOURCE
CONSULTANTS, INC
HYDRO-FLUENT, INC
RICHARD RUSSELL
RICHARD RUSSELL
EARTH TECH
FRED II. WECK, COL
ALBERT A. ARELLANO,
CAL-EPA
RECIPIENT
USEPA: MAFB:
CDIIS: SARWQCB:
EPA & STATE
REGULATORS
J. POLAND
J. POLAND
EPA & STATE
REGULATORS
INEL
JOAN POLAND
RICHARD RUSSELL,
US EPA
LTC GROSS, 22
SPTG/DE
IIQSAC
CALTRANS
INEL
JOAN POLAND
JOHNSABOL
AFCEE/22, CES/CEVR
RAYMOND T.
SWHNSON, LTC
JOAN POLAND
B-3
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0179 B
AROI71 B
AR0132 B
AROI78 B
AROI14 B
AR0126 2
AR0117 B
AR0118 B
AR0164 B
AR0022 B
AR0023 B
AR0161 B
AR0024 I
AROI76 B
AR0025 B
AR0026 1
AR0027 B
AK0028 1
AR01I6 B
AR0144 B
TITLE
MANAGEMENT AACTION PLAN
MANAGEMENT ACTION PLAN APPENDIX A - DRAFT
MANAGEMENT ACTION PLAN DRAFT
MANAGEMENT ACTION PLAN, APPENDIX A, ATCH A AND B
MARCH ADDED TO SUPERFUND LIST
MARCH AFB ADDITIONAL INFO REGARDING THE PRELIM
CHARACTERIZ - SITE 40
MARCH AFB CLEANING UP PRACTICES OF THE PAST
MARCH AFB CLEANUP PROGRAM
MARCH AFB FEDERAL FACILITY AGREEMENT ISSUES
MARCH AFB MAY JOIN LIST OF WORST WASTE SITES
MARCH AFB NEWS RELEASE "PUBLIC INVITED TO TRC MEETING"
MARCH AIR FORCE BASE SIGNATURE PAGE TRANSMITTAL
MARCH DELAYS CLEANUP OF TOXIC POLLUTION
MARCH FIELD, 75 YEARS OF SERVICE 1813-1993
MARCH INVITES PUBLIC TO DISCUSS CLEANUP
MARCH RELEASES NEW GETS SCHEDULE
MARCH STEPS FORWARD WITH CLEAN UP PROGRAMS
MARCH WASTE CLEANUP FALLS BEHIND SCHEDULE
MARCH, NORTON MAY GET FUNDS TO CLEAN WASTES
MINUTES OF MAFB RPM MEETING - 25 AUG 92
DATE
12/31/93
10/22/93
10/22/93
12/31/93
11/14/89
02/14/92
07/1 1/90
05/21/92
03/28/91
07/14/89
05/21/92
09/19/90
01/28/92
10/01/93
05/13/92
01/23/92
03/06/92
05/19/90
06/28/90
08/25/92
TYPE
PLAN
PLAN
PLAN
PLAN
NEWSPAPER ARTICLE
REPORT
PRESS RELEASE
FACT SHEET
CORRESPONDENCE
NEWSPAPER ARTICLE
PUBLIC NOTICE
CORRESPONDENCE
NEWSPAPER ARTICLE
REPORT
NEWSPAPER ARTICLE
NEWS RELEASE
NEWSPAPER ARTICLE
NEWSPAPER ARTICLE
NEWPAPER ARTICLE
MEETING MINUTES
AUTHOR
RADIAN
RADIAN
RADIAN CORP
RADIAN
GARY POLAKOVIC
JOAN POLAND
SGT RENEE WRIGHT
KIM RANSFORD
MARK E. SMALLWOOD,
CAPT
GARY POLAKOVIC
KIM RANSFORD, 22
ARW/PA
ALBERT A. ARELLANO
GARY POLAKOVIC
TSGT RANDOLPH J.
SAUNDERS
HEMET NEWS
KIM RANSFORD, 22
ARW/PA
COL WILLIAM COBB, 22
ARRFW/CC
GARY POLAKOVIC
PRESS-ENTERPRISE
EARTH TECH
RECIPIENT
HQ AMC
HQ AMC, 22
CES/CEVR
22 CES/CEVR
HQ AMC
US & STATE
REGULATORS
MORENO VALLEY
J. POLAND
J. POLAND
JOHN SABOL
B-4
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AROI23 n
AR0029 B
AROI63 B
AR0030 B
AR003 1 B
AR0032 B
AR0033 B
AR0034 3
AR0035 2
AR0036 2
AR0125 2
AR0037 3
AR0038 I
AR0039 3
AR0115 B
AR0040 B
AR004I B
AK0043 11
AR0042 B
AR0112 B
TITLE
MORE CLEANUP FUNDS FOR MARCH
MORE POLLUTION SITES DISCOVERED AT MARCH
NATIONAL PRIORITY LIST SUPERFUND SITE
NOTICE OF THE MEETING (14 MAY 92) & GETS PUBLIC MEETING (21
MAY 92)
PHASE II CONFIRMATION/QUANTIFICATION, STAGE 2, FINAL REPORT
PHASE II STAGE 1 RI/FS CONFIRMATION/QUANTIFICATION
PHASE II STAGE 2, TECHNICAL OPERATIONS PLAN
PHOTOS OF TANK REMOVAL
POTENTIALLY HAZARDOUS MATERIALS DISCOVERED AT MARCH AFB
PRILIMINARY ASSESSMENT/SITE INSPECTION HQ 15AF/DRMO
PRELIMINARY CHARACTERIZATION OF I1QI5AF SITE 40
PRELIMINARY SITE CHARACTERIZATION, PANERO
PROJECT MANAGMENT PLAN FOR AREA #5 GROUNDWATER
REMEDIATION
PROJECT MANAGEMENT PLAN, PANERO
PUBLIC INVITED TO TRC MEETING, 14 MAY 92
PUBLIC NOTICE OF FEDERAL FACILITY AGREEMENT
PUBLIC NOTICE OF FEDERAL FACILITY AGREEMENT
PUIILIC NOTICE OF FEDERAL FACILITY AGREEMENT
PUBLIC NOTICE OF FEDERAL FACILITY AGREEMENT
PUBLIC NOTICE OF TRC MEETING, 23 JAN 92
DATE
08/16/90
/ /
02/07/90
05/07/92
06/01/88
03/01/87
04/01/87
09/18/91
01/16/92
02/14/92
02/06/92
04/01/91
01/01/90
04/01/90
05/02/91
11/10/90
11/19/90
1 1/24/90
11/24/90
01/22/92
TYPE
NEWSPAPER ARTICLE
NEWSPAPER ARTICLE
CORRESPONDENCE
PUBLIC NOTICE
DATA VERIFICATION
REPORT
PLAN
NEWSPAPER ARTICLE
NEWS RELEASE
DOCUMENT REVIEW
CORRESPONDENCE
REPORT
PLAN
PLAN
PRESS RELEASE
PUBLIC NOTICE
PUBLIC NOTICE
PUBLIC NOTICE
PUBLIC NOTICE
PUBLIC NOTICE
AUTHOR
GARY POLAKOV1C
GARY POLAKOVIC
JERRY CLIFFORD
KIM RANSFORD/22
ARW/PA
E-8
ENGINEERING SCIENCE
E-S
PRESS-ENTERPRISE
KIM RANSFORD, 22
ARW/PA
RICHARD RUSSELL,
USEPA
ROBERT HERRINGTON,
TETRA TP.CII
EARTH TECH
INEL
INEL
22 ARW/PA
22 ARW/FA
22 ARW/PA
22 ARW/PA
22 ARW/PA
KIM RANSFORD
RECIPIENT
COL R. RIZZO
USEPA: MAFB:
CDIIS: SARWQCB:
HQ SAC/AFCEE
OEHLATS: IIQ
SAC/SQPB: MAFB
BEACON
JOAN POLAND, 22
SPTG/DEV
CAPT SMALLWOOD,
AFCEE
AFCEE
HQ SAC
HQ SAC
PRESS-ENTERPRISE
IIEMET NEWS
IIEMET NEWS
PRESS-ENTERPRISE
PRESS-ENTERPRISE
B-5
-------
ADMINISTRATIVE RECORD INDEX
KKU OU
AR0044 1
AR0045 3
AR0046 B
AR0153 2
AR0047 B
AR0128 2
AR0141 3
AR0160 B
AR0107 B
AROI59 B
AR0108 B
AR0048 B
AR0147 2
AR0147 2
AR0103 B
AR0105 B
AROIOI B
AR0049 B
TITLE
PUMPING TEST FOR EIGHT WELLS AREA 5 DRAFT
PUMPING TEST, PANERO
QUALITY ASSURANCE PROJECT PLAN UNDERGROUND STORAGE PLAN
INVESTIGATE
RACK/GASOLINE PUMP ISLAND WORK PLAN
RECORDS SEARCH REPORT
REFERENCE MATERIAL FOR OPERABLE UNIT 2 SITES
REMOVAL OF HYDRANT SYSTEM
REQUIREMENTS OF THE FEDERAL FACILITIES AGREEMENT
RESPONSE TO CITY OF MORENO VALLEY COMMENTS ON MAFB FFA
RESPONSE TO PROPOSED TIMELINES IRP OPERABLE UNITS
RESPONSES SUMMARY ON PUBLIC COMMENTS ON MAFB FFA
REVIEW OF STAGE 4 SITE CHARACTERIZATION SUMMARY
RI REPORT/RISK ASSESSMENT
RI/FS APPENDIX AND WORK PLAN FOR AIR FORCE VILLAGE WEST
RI/FS BASEWIDE WORK PLAN/ANALYSIS AND SAMPLING PLAN-DRAFT
RI/FS BASEWIDE WORK PLAN/SAMPLING AND ANALYSIS PLAN-DRAFT
RI/FS BASEWIDE WORK PI .AN/SAMPLING AND ANALYSIS PLAN -
DRAI'T FINAL
RI/FS FINAL BASEWIDE SAMPLING AND ANALYSIS PLAN
DATE
08/01/91
07/01/91
05/01/90
09/21/92
04/01/84
05/04/92
01/05/90
11/15/90
04/03/91
01/07/91
02/28/91
06/26/91
09/30/92
08/10/92
09/27/91
12/02/91
12/19/91
01/01/92
TYPE
INFORMAL REPORT
REPORT
PLAN
DOCUMENT REVIEW
REPORT/STUDY
CORRESPONDENCE
REPORT
CORRESPONDENCE
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
REPORT/STUDY
AUTHOR
INEL
INEL
JOHN BRODERICK
HILL CH2M
ROBERT HERRINGTON,
TETRA TECH
INEL
JOHN KEMMERER
COL. WILLIAM COBB,
22 AREPW/CC
KENNETH R. WILLIAMS
RICHARD RUSSELL, US
EPA
KENNETH R. WILLIAMS
RICHARD RUSSELL
RICHARD RUSSELL
RICHARD RUSSELL, US
EPA
KENNETH WILLIAMS,
RWQCB
RICHARD RUSSELL, US
I-:PA
EARTH TECHNOLOGY
CORP
RECIPIENT
MAFB
DOE
JOHN SABOL
USEPA:
MAFB/DEV:
JOHN SABOL, 22 DEV
HQ SAC
NORMAN R. KING
J. POLAND
JOAN POLAND
JOAN POLAND
JOHN SABOL
JOHN SABOL
JOAN POLAND
JOAN POLAND
JOAN POLAND
HQ SAC/DE:
AFCEE: MAFB
B-6
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0050 B
AR0051 1
AR0052 1
AR0053 3
AR0054 3
AR0055 B
AR0056 3
AR0104 1
AR0102 1
AR0137 3
AR0099 D
AR0127 2
AR0021 11
AR0098 I
AIM) 136 3
AR01I9 1
TITLE
RI/FS FINAL BASEWIDE WORK PLAN
RI/FS FINAL SAMPLING AND ANALYSIS PLAN ADDENDUM
RI/FS FINAL WORK PLAN ADDENDUM FOR OPERABLE UNIT 1
RI/FS OPERABLE UNIT 3 (PANERO SITE) WORK PLAN
RI/FS SAMPLING AND ANALYSIS PLAN ADDENDUM OU3 (PANERO)
FINAL
RI/FS WORK PLAN DRAFT
RI/FS WORK PLAN ADDENDUM OPERABLE UNIT 3 ( PANERO SITE)
FINAL
RI/FS WORK PLAN ADDENDUM OU I/SAMPLING AND ANALYSIS PLAN -
DRAFT
RI/FS WORK PLAN ADDENDUM/SAMPLING AND ANALYSIS PLAN GUI -
DRAFT FINAL
RI/FS WORK PLAN ADDENDUM/SAP ADDENDUM, OU 3
RI/FS WORK PLAN AND SAMPLING ANALYSIS PLAN
RI/FS WORK PLAN AND SAMPLING AND ANALYSIS PLAN
RI/FS WORK PLAN AND SAMPLING AND ANALYSIS PLAN - DRAFT
RI/FS WORK PLAN AND SAMPLING AND ANALYSIS PLAN - DRAFT
Itl/l-'S WORK PLAN AND SAP, OU 3 DOCUMENT REVIEW
RI/FS WORK PLAN/SAMPLING AND ANALYSIS PLAN ADDENDUMS
(OUI)- DRAFT
DATE
01/01/92
01/01/92
01/01/92
06/01/91
02/01/92
02/01/88
02/01/92
09/27/92
12/19/91
12/26/91
09/30/91
03/18/92
12/20/91
12/20/91
12/30/91
10/02/91
TYPE
WORK PLAN
REPORT STUDY
WORK PLAN
REPORT
WORK PLAN
ADDENDUM
WORK PLAN
WORK PLAN
ADDENDUM
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
DOCUMENT REVIEW
AUTHOR
EARTH TECHNOLOGY
CORP
EARTH TECHNOLOGY
CORP
EARTH TECHNOLOGY
CORP
INEL
INEL
E-S
INEL
RICHARD RUSSELL, US
EPA
RICHARD RUSSELL, US
EPA
RICHARD RUSSELL
EMAD E. YEMUT, CAL-
EPA
RIZGARGIIAZI, CAL-
EPA
ALBERT ARELLANO,
CAL-EPA
ALBERT A. ARELLANO,
CAL-EPA
ALBERT ARELLANO
KENNETH WILLIAMS
CRWQCB
RECIPIENT
HQ SAC/DE:
AFCEE: MAFB
I IQ SAC/DE:
AFCEE: MAFB
MAFB
HQ SAC: DOE
I IQ SAC/DE:
OKIII/rS: MAFB
HQ SAC: DOE
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND
B-7
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0149 B
AROI31 n
AR0152 2
AR0057 1
AR0058 2
AR0059 2
AR0060 2
AR0061 2
AR0062 2
AR0063 2
AR0146 2
AR0150 2
AR0064 3
AR0065 3
AR0066 3
AR0067 3
AR0069 1)
AR0070 B
AR0068 1)
AR0071 1
TITLE
RPM MEETING MINUTES W/AGENDA
RPM MEETING MINUTES, 20 JUL 92
SAMPLING & ANALYSIS PLAN ADDENDUM, OU 2
SEEING IS BELIEVING
SITE 1 1 YIELD SAMPLING PLAN DRAFT
SITE 1 1 PROJECT MANAGMENT PLAN
SITE 1 1 PROJECT MANAGMENT PLAN ADDENDUM DRAFF
SITE 1 1 SOIL GAS SAMPLING AND ANALYSIS
SITE 1 1 SOIL GAS SURVEY DRAFF
SITE 40 HAZARD
SITE CHARACTERIZATION STUDY, BLDG 3404
SITE CHARACTERIZATION STUDY, BLDG 3404
SOIL GAS SURVEY FOR PANERO LIQUID FUEL SYS
SOIL MANAGEMENT PLAN FOR PANERO ACPT FUELING SYS PROJECT
SOIL STORAGE AND TREATMENT FOR PANERO ACPT FUELING SYS
SOIL TREATMENT WORK PLAN, PANERO
STAGE 3 QUALITY ASSURANCE PROGRAM PLAN (QAI'P) DRAFT
STAGE 3 RI/PRELIMINARY FS, AREA #5, FINAL REPORT
STAGE 3 WORK. PLAN
STAGE 4 ANALYTICAL DATA, INFORMAL TECHNICAL INFORMATION
REPORT
DATE
10/21/92
07/27/92
09/21/92
02/02/92
03/01/90
02/01/90
12/01/91
04/01/91
04/01/91
01/16/92
01/09/92
10/05/92
12/01/89
05/01/90
06/01/90
06/12/90
03/01/88
09/01/89
05/01/88
03/01/91
TYPE
MEETING MINUTES
MEETING MINUTES
DOCUMENT REVIEW
NEWSPAPER ARTICLE
SAMPLING PLAN
PLAN
SAP PLAN
REPORT
REPORT
PUBLIC NOTICE
REPORT
DOCUMENT REVIEW
SURVEY
PLAN
SPECIFICATION
WORK PLAN
QAPP
REPORT STUDY
WORK PLAN
REPORT
AUTHOR
EARTH TECH
EARTH TECH
JOHN BRODERICK
INEL
INEL
INEL
GOLDER ASSOCIATES
INEL
KIM RANSFORD, 22
ARE/PA
EARTH TECH
TETRA TECH
TARGET
ENVIRONMENTAL
SERVICES
INEL
E-S
E-S
E-S
E-S
EARTH TECH
RECIPIENT
DISTRIBUTION
REGULATORS
JOHN SABOL
SAC
SAC
SAC/DOE
INEL
SAC/DOE
ORANGECREST/ARN
OLD HEIGHTS
AFCEE/DEV
JOHN SABOL
EG&G
MAFB
EG&G
EA
SAC/DE:AFCEE: MAFB
USEPA: MAFB:
GDI IS: SARWQCB
IIQ SAC/DE: OEIII/rS:
MAFB
IIQ SAC/DE: HQ
IISD/YAQ
B-8
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0072 B
AR0073 B
AR0075 B
AR0076 B
AR0077 B
AR0165 B
AR0074 B
AR0078 2
AR0079 2
AR0085 B
AR0080 2
AR0081 2
AR0082 2
AR0086 B
AR0084 2
AR0083 2
AR0087 1
A KOI 30 2
AR0088 3
TITLE
STAGE 4 HEALTH AND SAFETY PLAN
STAGE 4 QUALITY ASSURANCE PROJET PLAN ADDENDUM
STAGE 4 RI/FS WORK PLAN, DRAFT REPORT
STAGE 4 RI/FS, QAPP, FINAL REPORT
STAGE 4 SITE CHARACTERIZATION SUMMARY
STAGE 4 SITE CHARACTERIZATION SUMMARY
STAGE 4 SITE CHARACTERIZATION SUMMARY, APPENDICES A THRU G
STAGE 5 DRMO AND HQ 15AF STATEMENT OF WORK
STAGE 5 DRMO SITE CHARACTERIZATION SUMMARY INFORMAL TECH
INFO
STAGE 5 HEALTH AND SAFETY PLAN DRAFF
STAGE 5 HQ 15AF AREA SITES DRAFF SITE CHARACTERIZATION
SUMMARY
STAGE 5 SAMPLING AND ANALYSIS PLAN ADDENDUM DRMO & HQ 15
DRAFF
STAGE 5 SAMPLING AND ANALYSIS PLAN ADDENDUM FOR OU2
STAGE 5 STATEMENT OF WORK
STAGE 5 WORK PLAN ADDENDUM FOR DRMO & 15 AP SITES DRAFT
STAGE 5 WORK PLAN ADDENDUM, OU 2
STATEMENT OF WORK, AREA 5, SITE 4 GUTS
STATEMENT OF WORK, REIIAIIII.ITA'I ION OF CKI-I-K CHANNEL, SITE
40
SUBSURFACE INVESTIGATION/SOIL SAMPLING RPT - PANERO
DATE
01/01/89
09/01/90
01/01/89
05/01/90
06/27/91
04/01/91
04/01/91
06/01/91
01/31/92
06/01/91
01/31/92
08/16/91
08/27/92
01/01/90
08/16/91
08/27/92
09/01/90
07/29/92
08/29/91
TYPE
PLAN
PLAN
WORK PLAN
REPORT/STUDY
DOCUMENT REVIEW
REPORT
REPORT
PLAN
REPORT
PLAN
REPORT
PLAN
PLAN
STATEMENT OF WORK
WORK PLAN
WORK PLAN
WORK PLAN
WORK PLAN
REPORT
AUTHOR
EARTH TECH
EARTH TECH
EARTH TECH CORP
EARTH TECH CORP
RICHARD RUSSELL,
USEPA
EARTH TECH
EARTH TECH
TETRATECII
EARTH TECH
TF
TETRA TECH
TETRA TECH
TT
TETRA TECI I
JOHN R. SAHOI.
DEOMATRIX
RECIPIENT
SAC/AFCEE
HA SAC/AFCEE
USEPA: MAFB:
CDHS: SARWQCB:
HQ SAC/DE: MAFB:
IISDYAQ
JOAN POLAND
HQ SAC
I IQ SAC/DE: IISD/YQB
HQ SAC/DE:
AFCEE/ESR
I IQ SAC/AFCEE
I IQ SAC/DE:
AFCEE/ESR
HQ SAC/DE:
HSD/YAQ
HQ SAC/DE: AFCEE
IIQ SAC/DE:
I ISD/YAQ
SAC/AFCEE
22 ARW/I.GC
COE
B-9
-------
ADMINISTRATIVE RECORD INDEX
KRR OU
AR0089 B
AR0090 B
AR0091 B
AR0092 B
AR0093 B
AR0094 B
AR0095 B
AR0140 3
AR0096 B
AR0097 B
AR0123 2
AR0151 2
AR0145 2
AR0133 2
TITLE
TALK MUTED ABOUT MARCH POLLUTION
TASK V9 PROJECT MANAGMENT PLAN
TRC AGENDA 14 MAY 92 MEETING
TRC CHARTER
TRC MINUTES
TRC MINUTES
TRC TRANSCRIPT
TREATMENT TECH ASSESS FOR CORR ACTION OF JP-4 FUEL RELEASE
TREATMENT TECHNOLOGY ASSESSMENT DRAFT
WELL CLOSURE METHODS AND PROCEDURES PLAN
WIPE SAMPLING FOR PCBs IN BOILER ROOM OF BLDG 3404
WORK PLAN ADDENDUM AND SAP
WORKPLAN ADDENDUM & SAP, OU2, STAGE 5-DRAFT FINAL
WORKPLAN DEPT OF TRANSP T.O. NUMBER 08-227502-03 (SITE 43)
DATE
06/28/91
06/01/89
05/14/92
03/19/91
09/10/91
06/18/91
03/21/92
02/28/90
02/01/90
05/01/91
03/26/90
09/18/92
08/27/92
01/07/92
TYPE
NEWSPAPER ARTICLE
INFORMAL PLAN
MEETING AGENDA
INTER-AGENCY
AGREEMENT
MEETING MINUTES
MEETING MINUTES
MEETING TRANSCIPTS
REPORT INEL
REPORT
DRAFT PLAN
CORRESPONDENCE
DOCUMENT REVIEW
DOCUMENT REVIEW
WORK PLAN
AUTHOR
GARY POLAKOV1C
INEL
JOHNSABOL, 22
SPTG/DEV
JOAN POLAND
JOAN POLAND
JOAN POLAND
JOAN POLAND, 22
CES/DEV
HQ SAC
INEL
INEL
MAJ FORREST R.
SPRESTER
ALBERT A. ARELLANO
RICHARD RUSSELL
GEO/RESOURCE
CONSULTANT, INC
RECIPIENT
SAC
TRC MEMBERS
TRC MEMBERS
TRC MEMBERS
TRC MEMBERS
TRC MEMBERS
IIQSAC
DOE
22CSG/DEV
JOHN SABOL
JOHN SABOL
CALTRANS
B-10
-------
APPENDIX C
ARAR TABLES
-------
-------
TABLE C-l
SITE 4/OU1 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH CHEMICAL-SPECIFIC ARARs
Contaminant of Concern In
Groundwater
Bis(2-ethylhexyl)phthalate
Benzene
Carbon Tetrachloride
Vinyl Chloride
Trichloroethene (TCE)
1,1-Dichloroethene
cis- 1 ,2-DichIoroethene
Tetrachloroelhene (PCE)
1 ,2-Dichloroetliane
Methylene Chloride
Source
(1)
(1)
(1)
(1)
(1), (2)
(1)
(1)
(1), (2)
(1)
(2)
Applicable, Relevant and
Appropriate, or To-be-
consiilercd (TBC)
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Alternative 2Gi
Limited Action
4 ^g/L California Cleanup
Standard will not be
achieved
1 fig/L California Cleanup
Standard will not be
achieved
0.5 ^g/L California Cleanup
Standard will not be
achieved
0.5 ng/L California Cleanup
Standard will not be
achieved
5 ng/L California and
Federal Cleanup Standard
will not be achieved
6 jig/L California Cleanup
Standard will not be
achieved
6 ^g/L California Cleanup
Standard will not be
achieved
5 ng/L California and
Federal Cleanup Standard
will not be achieved
0.5 ftg/L California Cleanup
Standard will not be
achieved
5 fig/L Federal Cleanup
Standard will not be
achieved
Alternative 3G
Direct Treatment with
Liquid Phase GAC
4 ftg/L California Cleanup
Standard will be achieved
1 /
-------
TABLE C-2
SITE 4/OU1 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAC
Alternative 4G
UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
Adsorption
LOCATION-SPECIFIC
Clean Water Act
Section 404(b)(l)
Protection of
Wetlands
RCRA Location
Standards
40 CFR Section
230.10
Executive Order
11990
40 CFR 6,
Appendix A
Title 22 CCR,
Chapter 14, Section
66264.18
Applicable
Applicable
Applicable
NA; no discharge will
occur.
NA; no discharge will
occur.
NA
Will meet ARAR, because no discharge to
wetlands is expected.
Will meet ARAR, because no discharge to
wetlands is expected.
ARAR will be met. Facility will not be
constructed within 20 feet of an
earthquake fault or within a 100-year
floodplain.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
ACTION-SPECIFIC
California
Hazardous Waste
Rules:
Standards
Applicable to
Generators of
Hazardous
Waste
Title 22 CCR,
Division 4.5,
Chapter 12, Section
66262 et seq.
Applicable
NA; no wastes are
generated.
ARAR will be met; spent carbon,
cuttings, and other residues will be
handled and disposed of as hazardous
wastes if they meet California
classification criteria. Accumulation and
storage requirements will be met.
NA; no wastes are generated.
See Alternative 3G.
C-2
-------
TABLE C-2
SITE 4/OU1 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-berConsidered ;
(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAC
Alternative 4G
UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
Adsorption
ACTION-SPECIFIC (Continued)
California
Hazardous Waste
Rule:
Standards for
Operators of
Hazardous
Waste
Transfer,
Treatment &
Disposal
Facilities:
Tanks
Miscellaneous
Units
Waste Classification
and Management
Title 22 CCR,
Division 4.5, dipt
14, Section
6624.190 - Section
6624.199
Title 22 CCR,
Division 4.5, dipt
14, Sections
66264.600-
66264.603
Title 23, Division
3, Chapter 15,
Article 2 Seclion
2522
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
NA; no wastes
generated.
NA; no wastes
generated.
NA; no wastes are
generated
Will meet ARAR; relevant and
appropriate substantive requirements will
be incorporated into construction and
design of tanks used to store groundwater.
NA; carbon units and associated tanks are
regulated under RCRA tank regulations.
ARAR will be met; spent carbon,
cuttings, and other residue, if not
ha/aidotis waste, will he disposed of ;is
designated waste
Same as Alternative 3G.
NA; associated tanks are
regulated under RCRA tank
regulations.
NA; no wastes are generated
Same as Alternative 3G.
The unit will be located,
designed, constructed,
operated, maintained, and
closed in a manner that
ensures protection of human
health and the environment
(e.g., prevention of releases)
and will thereby comply with
the relevant and appropriate
requirements for
miscellaneous treatment
units.
See Alternative 3G.
C-3
-------
TABLE C-2
SITE 4/OXJ1 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAC
Alternative 4G
UV and Chemical Oxidation
Alternative 4G
UV and Chemical
Oxidation
ACTION-SPECIFIC (Continued)
South Coast Air
Quality
Management
District Rules &
Regulations - New
Source Review of
Carcinogenic Air
Contaminants
New Source
Review of Air
Contaminants
Statement of Policy
with Respect to
Maintaining High
Quality of Waters
in California
Prohibitory Rules -
Rule 1401
Regulation XIII,
Rule 1303
SWCB Resolution
Number 68-16
Applicable
Applicable
Applicable
NA; no emissions.
NA; no emissions.
NA; no discharge will
occur.
Will meet ARAR; additional controls will
not be necessary because risk from
emissions will be below 1 X 10"' risk level
stated in the rule.
Will meet ARAR. Due to low
concentrations of VOCs in groundwater,
air emissions without controls will be
below the 1 pound/day limit above which
BACT is required to limit emissions
increases (SCAQMD considers an
emissions increase to be at least 1
pound/day). Nonetheless, BACT will be
used for all alternatives.
Treated groundwater will be discharged to
the base wastewater treatment plant, to the
ground surface or reinjected to the
aquifer. Discharge to the ground surface
will no degrade water quality (see NPDES
requirements below).
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
C-4
-------
TABLE C-2
SITE 4/OU1 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
considered(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAC
Alternative 4G
UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
Adsorption
ACTION-SPECIFIC (Continued)
National Pollutant
Discharge
Elimination System
(NPDES) Program
40 CFR Parts 122-
125; NPDES
Permit No.
CAG918001 for
March AFB
Groundwater
Cleanup Project
(March 1995)
Applicable
NA; no discharge will
occur.
Will meet substantive requirements of
regulation through compliance with
discharge limits for inorganics and total
dissolved solids found in permit.
Maximum Daily Limits for regulated
constituents are in ^g/L are:
Total Petroleum Hydrocarbons 100;
benzene 1.0 ; toluene 10; xylenes 10;
ethylbenzene 10; chloroform 5; methyl
ethyl ketone 10; tetrachloroethene (PCE)
5; methyl isobutyl ketone 10; 1,1-
dichloroethylene 6; trichloroethylene
(TCE) 5; dichlorobromomethane 5; 1,1,1-
trichloroethane (TCA) 5; 1,2-
dichloroethylene 10; 1,1-dichlorethane 5;
carbon tetrachloride 0.5; naphthalene 10;
Maximum Daily Limits for regulated
constituents are in mg/1:
chromium 0.052; total lead 0.05; total
residual chlorine3 0.1; suspended solids
75; sulfides 0.4; cadmium 0.01; zinc 5
See Alternative 3G.
See Alternative 3G.
Key:
GAC
RCRA
UIC
ARAR
NA
Granular Activated Carbon
Resource Conservation and Recovery Act
Underground Injection Control
Applicable or Relevant and Appropriate Requirement
Not an Applicable or Relevant and Appropriate Requirement
Micrograms per liter
SCAQMD = South Coast Air Quality Management District
MCL = Maximum Contaminant Level
OSWER = Office of Solid Waste and Emergency Response
BACT = Best Available Control Technology
VOC = Volatile Organic Compound
SWCB = State Water Control Board
NA - Not applicable
C-5
-------
TABLE C-3
SITE 18 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH CHEMICAL-SPECIFIC ARARs
Contaminant of Concern in
Groundwater
Melhylene Chloride
Benzene
Toluene
Ethylbenzene
Xylenes. Total
Source
(2)
(1)
(2)
(1)
(1)
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Alternative 2G
Limited Action
5 ftg/L Federal Cleanup
Standard will not be
achieved
1 ftg/L California Cleanup
Standard will not be
achieved
1 50 ftg/L California Cleanup
Standard will not be
achieved
680 jig/L California Cleanup
Standard will not be
achieved
1750 ng/L California
Cleanup Standard will not be
achieved
Alternatives 3G/5G
Direct Treatment with
Liquid Phase GAC/Total
Fluids Recovery
5 ftg/L Federal Cleanup
Standard will be achieved
1 fig/L California Cleanup
Standard will be achieved
150 pg/L California Cleanup
Standard will be achieved
680 ftg/L California Cleanup
Standard will be achieved
1750 ftg/L California
Cleanup Standard will be
achieved
Alternatives 7G/SG
Air Stripping with
Catalytic Oxidation/Total
Fluids Recovery
5 fig/L Federal Cleanup
Standard will be achieved
1 fig/L California Cleanup
Standard will be achieved
1 50 fig/L California Cleanup
Standard will be achieved
680 f
-------
TABLE C-4
SITE 18 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable,
Relevant and
Appropriate, or
To-be-
considered
(TBC)
Alternative 2G
Limited Action
Alternative 3G/SG
Liquid Phase GAG Adsorption/Total
Fluids Recovery
Alternatives 7G/5G
Air Stripping with Catalytic
Oxidation/Total Fluids
Recovery
Alternatives 8G/5G
Air Stripping with Purus
PADRE'" System/Total Fluids
Recovery
LOCATION-Sl'ECIMC
TSDF Location Standards
Title 22 CCR,
Chapter 14,
Section 66264.18
Applicable
NA
Facility will not be constructed within
200 feet of an earthquake fault and, if
sited within the 100-year floodplain, will
be designed, constructed, operated, and
maintained to prevent washout of waste.
See Alternative 3G/5G.
See Alternative 3G/5G.
AerioN-Si'Ecinc
California Hazardous
Waste Rules:
Standards Applicable
to Generators of
Hazardous Waste
Standards for
Operators of
Hazardous Waste
Transfer, Treatment
& Disposal
Facilities:
Tanks
Miscellaneous Units
Title 22 CCR,
Division 4.5,
Chapter 12,
Section 66262 et
seq.
Title 22 CCR,
Division 4.5,
dipt 14, Section
6624.190-
Section 6624.199
Title 22 CCR,
Division 4.5,
Chap 14,
Sections
66264.600 -
66264.603
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
NA; no wastes.
NA; no wastes.
NA; no units.
Spent carbon and residues will be
handled and disposed of as hazardous
wastes if they meet classification
criteria.
Relevant and appropriate substantive
requirements will be incorporated into
construction and design of tanks.
The unit will be located, designed,
constmcted, operated, maintained, and
closed in a manner that ensures
protection of human health and (be
environment (e..g, prevention of
releases) and will thereby comply with
relevant and appropriate requirements
for miscellaneous units.
Residues will be handled and
disposed of as hazardous wastes if
they meet classification criteria.
See Alternative 3G/5G.
The unit will be located, designed,
constructed, operated, maintained,
and closed in a manner that
ensures protection of human health
and the environment (e..g,
prevention of releases) and will
thereby comply with relevant and
appropriate requirements for
miscellaneous units.
See Alternative 7G/5G.
See Alternative 3G/5G.
See Alternative 7G/5G.
C-7
-------
TABLE C-4
SITE 18 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable,
Relevant and
Appropriate, or
To-be-
considered
(TBC)
Alternative 2G
Limited Action
Alternative 3G/SG
Liquid Phase GAC Adsorption/Total
Fluids Recovery
Alternatives 7G/SG
Air Stripping with Catalytic
Oxidation/Total Fluids
Recovery
Alternatives 8G/5G
Air Stripping with Purus
PADRE System/Total Fluids
Recovery
Action-Specific (Continued)
Waste Classification and
Management
South Coast Air Quality
Management District
Rules Regulations New
Source Review of
Carcinogenic Air
Contaminants
New Source Review of
Air Contaminants
Statement of Policy with
Respect to Maintaining
High Quality of Waters in
California
Title 23, Division
3, Chapter 15,
Article 2, Section
2522
Prohibitory Rules
- Rule 1401
Regulation XIII,
Rule 1303
SWCB
Resolution
Number 68-16
Applicable
Applicable
Applicable
Applicable
NA; No waste
NA; no
emissions.
NA; no
emissions.
NA; no discharge
will occur.
Spent carbon and residues, if non-
hazardous waste, will be disposed of as
designated waste
NA; no emissions.
NA; no emissions.
Treated groundwater will be discharged
to the base wastewater treatment plant,
to the ground surface, or reinjected to
the aquifer. Discharge to the ground
surface will not degrade water quality
(See NPDIiS requirements below)
Residues will be handled and
disposed of as designated waste, if
non-hazardous waste
Controls will not be necessary
because risk from emissions will
be below 1 x 10 6 risk level stated
in the rule.
Due to low concentrations of
VOCs in groundwater, air
emissions without controls will be
below the 1 pound/day limit above
which BACT is required to limit
emissions increases (SCAQMD
considers an emissions increase to
be at least 1 pound/day.
Nonetheless, BACT will be used
for all alternatives.
See Alternative 3G/5G.
See 7G/5G
See Alternative 7G/5G.
See Alternative 7G/5G.
See Alternative 3G/5G.
C-8
-------
TABLE C-4
SITE 18 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable,
Relevant and
Appropriate, or
To-be-
considered
(TBC)
Alternative 2G
Limited Action
Alternative 3G/5G
Liquid Phase GAC Adsorption/Total
Fluids Recovery
Alternatives 7G/5G
Air Stripping with Catalytic
Oxidation/Total Fluids
Recovery
Alternatives 8G/SG
Air Stripping with Pnrus
PADRE1" System/Total Fluids
Recovery
Action-Specific (Continued)
National Pollutant
Discharge Elimination
System (NPDES)
Program
40 CFR Parts
122-125; NPDES
Permit No.
CAG918001 for
March AFB
Groundwater
Cleanup Project
(March 1995)
Applicable
NA; no discharge
will occur.
Will meet substantive requirements of
regulation through compliance with
discharge limits for inorganics and total
dissolved solids. Limits for regulated
constituents in mg/L are:
Total Petroleum Hydrocarbons 100,
benzene 1.0; toluene 10; xylenes 10;
ethylbenzene 10; chloroform 5; methyl
ethyl ketone 10; tetrachloroethene (PCE)
5; methyl isobutyl ketone 10; 1,1-
dichloroethylene 6; trichloroethylene
(TCE) 5; dichlorobromomethane 5;
1,1,1-trichloroethane (TCA) 5; 1,2-
dichlorethylene 10; 1,1-dichlorethane 5;
carbon tetrachloride 0.5; naphthalene
10; Maximum Daily Limits for regulated
constituents are in mg/l:
chromium 0.05!; total lead 0.05; total
residual chlorine3 0.1; suspended solids
75; sulfides 0.4; cadmium 0.01; zinc 5
See Alternative 3G/5G.
See Alternative 3G/5G.
Key:
GAC
RCRA
TBC
OSWER
BACT
VOC
Granular Activated Carbon
Resource Conservation and Recovery Act
To Be Considered
Office of Solid Waste and Emergency Response
Best Available Control Technology
Volatile Organic Compound
SCAQMD = South Coast Air Quality Management District
MCL = Maximum Contaminant Level
UIC = Underground Injection Control
ARAR = Applicable or Relevant and Appropriate Requirement
NA = Not an Applicable or Relevant and Appropriate Requirement
/ig/L = Micrograms per liter
SWCB - Stale Water Control Board
C-9
-------
TABLE C-5
SITE 31 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH CHEMICAL-SPECIFIC ARARs
Contaminant of Concern in
Grbundwater
Bis(2-elhylhexyl)phthalate
Tricliloroethene (TCE)
1,1-Dichloroeihene
Source
(1)
(1), (2)
(1)
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Alternative 2G
Limited Action
4 /
-------
TABLE C-6
SITE 31 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
consiclcred(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAG
Alternative 4G
UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
Adsorption
LOCATION-SPECIFIC
Clean Water Act
Section 404(b)(l)
Protection of
Wetlands
40 CFR Section
230.10
Executive Order
11990
40 CFR 6,
Appendix A
Applicable
Applicable
NA; no discharge will
occur.
NA; no discharge will
occur.
Will meet ARAR, because no discharge to
wetlands is expected.
Will meet ARAR, because no discharge to
wetlands is expected.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 30.
ACTION-SPECIFIC
California
Hazardous Waste
Rules
Standards
Applicable to
Generators of
Hazardous
Waste
Title 22 CCR,
Division 4.5,
Chapter 12, Section
66262 et seq.
Applicable
NA; no wastes are
generated.
ARAR will be met; spent carbon,
cuttings, and other residues will be
handled and disposed of as hazardous
wastes if they meet California
classification criteria. Accumulation and
storage requirements will be met.
NA; no wastes are generated.
See Alternative 3G.
C-ll
-------
TABLE C-6
SITE 31 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
considered(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAG
Alternative 4G
UV and Chemical Oxidation
;AHernative 6G
Air Stripping with Carbon
Adsorption
ACTION-SPECIFIC (Continued)
Standards for
Operators of
Hazardous
Waste
Transfer,
Treatment &
Disposal
Facilities:
Tanks
Miscellaneous
Units
Waste Classification
and Management
Title 22 CCR,
Division 4.5, Clip
14, Section
6624.190 - Section
6624.199
Title 22 CCR,
Division 4.5, Clip
14, Sections
66264.600-
66264.603
Title 23, Division
3, Chapter 15,
Article 2 Section
2522
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
NA
NA
NA; no wastes are
generated
Will meet ARAR; relevant and
appropriate substantive requirements will
be incorporated into construction and
design of tanks used to store groundwater.
The unit will be located, designed,
constructed, operated, maintained, and
closed in a manner that ensures protection
of human health and the environment
(e.g., prevention of releases) and will
thereby comply with the relevant and
appropriate requirements for
miscellaneous treatment units.
ARAR will be met; spent carbon,
cuttings, and other residue, if not
hazardous waste, will be disposed of as
designated waste
Same as Alternative 3G.
The unit will be located,
designed, constructed,
operated, maintained, and
closed in a manner that
ensures protection of human
health and the environment
(e.g., prevention of releases)
and will thereby comply with
the relevant and appropriate
requirements for
miscellaneous treatment
\mits.
NA; no wastes are generated
Same as Alternative 3G.
The unit will be located,
designed, constructed,
operated, maintained, and
closed in a manner that
ensures protection of human
health and the environment
(e.g., prevention of releases)
and will thereby comply with
the relevant and appropriate
requirements for
miscellaneous treatment
units.
See Alternative 3G.
C-12
-------
TABLE C-6
SITE 31 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
considered(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAG
Alternative 4G
UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
^Adsorption
ACTION-SPECIFIC (Continued)
South Coast Air
Quality
Management
District Rules &
Regulations - New
Source Review of
Carcinogenic Air
Contaminants
New Source
Review of Air
Contaminants
Statement of Policy
with Respect to
Maintaining High
Quality of Waters
in California
Prohibitory Rules -
Rule 1401
Regulation XIII,
Rule 1303
SWCB Resolution
Number 68-16
Applicable
Applicable
Applicable
NA; no emissions.
NA; no emissions.
NA; no discharge will
occur.
Will meet ARAR; additional controls will
not be necessary because risk from
emissions will be below 1 x 10 6 risk level
stated in the rule.
Will meet ARAR. Due to low
concentrations of VOCs in groundwater,
air emissions without controls will be
below the 1 pound/day limit above which
BACT is required to limit emissions
increases (SCAQMD considers an
emissions increase to be at least 1
pound/day). Nonetheless, BACT will be
used for all alternatives.
Treated groundwater will be discharged to
the base wastewater treatment plant, to the
ground surface or reinjected to the
aquifer. Discharge to the ground surface
will not degrade water quality (see
NPDES requirements below).
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
See Alternative 3G.
C-13
-------
TABLE C-6
SITE 31 GROUNDWATER PLUME
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
considered(TBC)
Alternative 2G
Limited Action
Alternative 3G
Direct Treatment with Liquid
Phase GAC
Alternative 4G:
;UV and Chemical Oxidation
Alternative 6G
Air Stripping with Carbon
Adsorption
ACTION-SPECIFIC (Continued)
National Pollutant
Discharge
Elimination System
NPDES) Program
40 CFR Parts 122-
125; NPDES
Permit Ab. CAG
918001 for March
AFB Groundwater
Cleanup Project
(March 1995)
Applicable
NA; no discharge will
occur.
Will meet substantive requirements of
regulation through compliance with
discharge limits for inorganics and total
dissolved solids. Limits for regulated
constituents in /
-------
TABLE C-7
SITE 4 SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
Alternative 2S
Limited Action
Alternative 3S
RCRA Capping
Alternative 4S
Landfill Closure
Alternative9S
Excavation and Off-site
Disposal
LOCATION-Sl'KCIHC
Protection of Wetlands
Clean Water Act Section
404(b)(l) and Executive
Order 11990
Applicable
ARAR will not be met;
erosion of landfill and
deposition of contaminants
into Heacock Storm Drain
will not be prevented.
ARAR will be met; closure
will prevent erosion of
landfill and deposition of
contaminants into Heacock
Slorm Drain and will not
adversely impact wetlands.
Measures will be taken
during construction to
prevent adverse impacts on
wetlands.
ARAR will be met; closure
will prevent erosion of
landfill and deposition of
contaminants into Heacock
Storm Drain and will not
adversely impact wetlands.
Measures will be taken
during construction to
prevent adverse impacts on
wetlands.
ARAR will be met; potential
source of contamination will
be eliminated. Measures
will be taken during
construction to prevent
adverse impacts on wetlands.
ACTION-SPECIFIC
Discharges of Wastes to
Land (Landfill Closure and
Post-Closure)
Title 23 CCR, Division 3,
Chapter 15, Article 8,
Section 2581
Applicable
ARAR will not be met; no
waiver is justified.
Isolation of landfill materials
will be accomplished. A
RCRA cap will be
constructed and the adjacent
Heacock Slorm Drain will be
lined with an impermeable
barrier. ARAR will be met;
closure and post-closure
requirements include
construction of a cover,
isolation of landfill materials
from surface water drainage,
water quality monitoring and
response programs, closure
mainlcmmcc activities, anil
post-closure mainlcnancc
activities.
ARAR will be met; closure
and post-closure requirements
include construction of a
cover, isolation of landfill
materials from surface water
drainage, water quality
monitoring and response
programs, closure
maintenance activities, and
post-closure maintenance
activities. ,
Will meet ARAR; landfill
materials will be eliminated,
covered and other
requirements will be
complied wilh.
C-15
-------
,": >^>?;; ^v..; TABLE C-7 ;
SITE 4 SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant and
Appropriate, or To-be-
consiclcred (TBC)
Alternative 2S
Limited Action
Alternative 3S
RCRA Capping
Alternative 4S
Landfill Closure :
: . . ; ' .
Alternative 9S
Excavation and Off-site
Disposal
ACTION-SPECIFIC (Conlinued)
South Coast Air Quality
District Rules and
Regulations:
Fugitive Dust
Gaseous Emissions
from Inactive Landfills
California Hazardous Waste
Rules:
Standards for
Operators of
Hazardous Waste
Transfer Treatment
and Disposal
Facilities:
Landfills
Rule 403
Regulation IX, Rule
1150.2
Title 22, Division 4.5,
Section 66264.300-
66264.318
Applicable
Applicable
Relevant and Appropriate
NA; no excavation of soil
will occur.
NA; no excavation of soil
will occur.
Will not meet ARAR; no
waiver is justified.
ARAR will be met;
constmction activities will
comply with regulations;
paniculate matter will not
exceed 50 /
-------
TABLE C-8
SITE 10 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
: Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2S
Limited Action
Alternative SS
Excavation and Low
Temperature Thermal
Desorplion
Alternative 7S
Excavation and Offsite
Treatment
Alternative 8S*
Excavation and Onsite
Consolidation
Alternative IIS
Ex-Situ
Bioremedialion
ACTION-SPECIFIC
California Hazardous
Waste Rules:
Standards
Applicable to
Generators of
Hazardous Waste
Standards for
Operators of
Hazardous Waste
Transfer,
Treatment and
Disposal
Facilities:
Landfills
Waste Piles
Title 22, Division 4.5,
Chapter 12, Section
66262 el sei|.
Title 22, Division 4.5,
Section 66264.300 -
66264.318
Tide 22, Division '1.5,
Section 66264.250 -
66264.259
Applicable
Applicable
Applicable
NA; no wastes
generated.
N A ; no wastes
generated.
NA; no waste piles.
See Alternative 8S.
N A ; no wastes
generated.
See Alternative 7.S.
Will meet ARAR; will
comply with
characterization, and
onsite container and
storage requirements if
soils or residuals are
determined to be
hazardous waste. Will
meet ARAR; only soils
without hazardous waste
characteristics will be
consolidated onsite.
NA; wasles will not be
placed in onsite landfills.
Will meet AKAR by
complying wit b
regulations. Relevant
only if temporary
storage of RCRA waste
in piles occurs.
Will meet ARAR; will
comply with
characterization, and
onsite container and
storage requirements if
soils or residuals are
determined to be
hazardous waste. Will
meet ARAR; only soils
without hazardous waste
characteristics will be
consolidated onsite.
Will meet ARAR; only
non-hazardous wastes
will be placed in onsite
landfills.
See Alternative 7S.
See Alternative 7S.
N A ; no wasles
generated.
See Alternative 7S.
C-17
-------
TABLE C-8
SITE 10 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2S
Limited Action
Alternative SS
Excavation and Low
Temperature Thermal
Dcsorption
Alternative 7S
Excavation and Offsite
Treatment
Alternative 8S*
Excavation and Onsite
Consolidation
Alternative IIS
Ex-Sit u
Bioremediaiion
ACTION-SPECIFIC
Waste Classification
and Management
Discharges of Waste to
Land (Soil Disposal)
South Coast Air Quality
Management District
Rules and Regulations
Fugitive Dust
New Source
Review of
Carcinogenic Air
Contaminants
Title 23. Division 3,
Chapter 15, Article 2,
Section 2522
Title 23, Division 3,
Chapter 15
Prohibitory Rules, Rule
403
Rule 1401
Applicable
Relevant and
Appropriate
Applicable
Applicable
NA; no waste generated
NA; no discharges will
occur.
NA; no emissions.
NA; no emissions.
NA; no waste generated
NA; no discharge of
waste will occur.
See Alternative 7S.
Will meet ARAR;
emissions of PAHs will
be below 1x10' risk
level staled in the rule;
controls will not be
required.
ARAR will be met; non-
hazardous waste will be
disposed of as designated
waste
NA; no onsite discharges
will occur.
ARAR will be met;
excavation activities will
comply with regulations,
paniculate matter will
not exceed 50 fig/m3.
Not applicable to this
alternative.
ARAR will be met; non-
hazardous waste will be
disposed of as designated
waste
ARAR will be met; only
non-hazardous soils will
be discharged, and a cap
will prevent leaching of
any contaminants to
groundwater.
See Alternative 7S.
N/A
See Alternative 7S
NA; no discharge of
waste will occur.
See Alternative 7S.
See Alternative 5S.
Key:
ARAR
RCRA
PAH
NA
Applicable or Relevant and Appropriate Requirement
Resource Conservation and Recovery Act
I'olynuclear Aromatic Hydrocarbon
Not an Applicable or Relevant and Appropriate Requirement
Micrograms per cubic meter
" Alternative 8S is no longer a viable alternative
C-18
-------
TABLE C-9
SITE 15 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-
considered(TBC)
Alternative 2S
Limited Action
Alternative SS
Excavation and Low
Temperature Thermal
Desorption
AIternative7S
Excavation and Offsite
; Treatment
Alternative 8S'
Excavation and Onsile
: Consolidation
Alternative IIS
Ex-Sit u
Bioremediation
ACTION-SPECIFIC
California Hazardous
Wasle Rules
Standards
Applicable lo
Generators of
Hazardous Waste
Standards for
Operators of
Hazardous Waste
Transfer,
Treatment and
Disposal Facilities:
Landfills
Waste Piles
Wasle Classification and
Management
Title 22, Division 4.5,
Chapter 12, Section
66262 el seq.
Title 22, Division 4.5,
Section 66264.300 -
66264.318
Title 22, Division 4.5,
Section 66264.250 -
66264.259
Title 23, Div. 3,
Chapter 15, Article 2,
Section 2522
Applicable
Applicable
Applicable
Applicable
NA; no wastes
generated.
NA; no wastes
generated.
NA; no waste piles.
NA: no waste generated
See Alternative 8S.
NA; no wastes.
See Alternative 7S.
NA: no waste generated
Will meet ARAR; will
comply with
characterization, and
onsile container and
storage requirements if
soils or residuals are
determined to be
hazardous waste.
NA; wastes will not be
placed in onsile landfills.
Will meet ARAR by
complying with
regulations. Relevant
only if temporary
storage of RCRA waste
in piles occurs.
ARAR will be met; lion
hazardous waste will be
disposed of as designated
waste
Will meet ARAR; only
soils without hazardous
waste characteristics will
be consolidated onsite.
Will meet ARAR; only
non-hazardous wastes
will be placed in onsile
landfills.
See Alternative 7S.
ARAR will be met; non
hazardous waste will be
disposed of as
designated waste
See Alternative 7S.
NA, no wastes.
See Allernalive 7S
See Alternative 7S.
C-19
-------
TABLE C-9
SITE 15 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Discharges of Waste to
Land (Soil Disposal)
South Coast Air Quality
Management District
Rules and Regulations
Fugitive Dust
New Source
Review of
Carcinogenic Air
Contaminants
Source
Title 23, Division 3,
Chapter 15
Prohibitory Rules, Rule
403
Rule 1401
Applicable,: Relevant
and Appropriate, or
To-be-
considcred(TBC)
Relevant and
Appropriate
Applicable
Applicable
Alternative 2S
Limited Action:
NA; no discharges will
occur.
NA; no excavation will
occur.
NA; no emissions.
Alternative 5S
Excavation and Low
Temperature Thermal
Desorption
NA; no discharge of
waste will occur.
See Alternative 7S.
Will meet ARAR;
emissions of PAHs will
be below 1 x 10'' risk
level stated in the rule;
controls will not be
required.
Alternative 7S
Excavation and Offsite
Treatment
NA; no onsite discharges
will occur.
Compliance will occur
by controlling fugitive
dust to levels of <50
Me/m'
Not applicable.
Alternative 8S'
Excavation and Onsite
Consolidation
ARAR will be met; non-
hazardous soils will be
covered by a cap to
prevent leading.
See Alternative 7S.
Not applicable.
Alternative IIS
Ex-Situ
llioremediation
NA; no discharge of
waste will occur.
See Alternative 7.
See Alternative 5S.
Key: ARAR = Applicable or Relevant and Appropriate Requirement
RCRA = Resource Conservation and Recovery Act
PAH = Polynuclear Aromatic Hydrocarbon
NA = Not an Applicable or Relevant and Appropriate Requirement
jig/ni1 = Micrograms per cubic meter
' Alternative 8S is no longer a viable alternative.
C-20
-------
TABLE C-10
SITE 18 SUBSURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable,
Relevant and
Appropriate, or
To-be-
considered
(TBC)
Alternative 2S
Limited Action
Alternative 1 OS
Bioventing
Alternative 12S
Soil Vapor Extraction with Catalytic
Oxidation
'.' ' '
Alternative 13S
Soil Vapor Extraction with Purus
PADRE System
ACTION-SPECIFIC
California Hazardous Waste
Rules.
Standards Applicable io
Generators of Hazardous
Waste
Standards for Operators
of Hazardous Waste
Transfer, Treatment &
Disposal Facilities:
Tanks
Waste Classification and
Management
South Coast Air Quality
Management District Rules
Regulations - New Source
Review of Carcinogenic Air
Contaminants
New Source Review of Air
Contaminants
Title 22, Division 4.5,
Chapter 12, Section
66262 et seq.
Title 22, Division 4.5,
Section 6624.190 -
Section 6624.19°
Title 23, Division 3,
Chapter 15, Article 2,
Section 2522
Prohibitory Rules -
Rule 1401
Rule 1303
Applicable
Relevant and
Appropriate
Applicable
Applicable
Applicable
NA; no wastes.
NA; no tanks are
used.
NA; no wastes
NA; no
emissions.
NA; no
emissions.
NA; no wastes.
NA; no tanks are
used.
NA; no wastes
NA; de minimus
emissions.
NA; de minimus
emissions.
NA; no wastes are generated.
NA; no tanks are used.
NA; no wastes
Will meet ARAR, emissions of BTEX will be
below IX 10'* risk level slated in (he rule;
additional controls will not be required.
Will meet ARAR; emissions will be below the
1 pound/day threshold.
Will meet ARAR. Residue will be handled
and disposed of as hazardous waste if it meets
classification criteria.
Will meet ARAR. Relevant and appropriate
requirements will be incorporated into the
design and construction of Purus tanks.
Residue will be handled and disposed of as
designated waste, if it is non hazardous
See Alternative 12S.
See Alternative 12S.
Key: ARAR = Applicable or Relevant and Appropriate Requirement RCRA
BTliX = Benzene, Toluene, lilhylbenzene, and Xylenu NA
= Resource Conservation and Recovery Act
= Not an Applicable or Relevant and Appropriate Requirement
C-21
-------
TABLE C-ll
SITE 31 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2S
Limited Action
Alternative 5S
Excavation and Low
Temperature Thermal
Desorption
Alternative 7S
Excavation and Offsite
Treatment
Alternative 8S
Excavation and Onsile
Consolidation
Alternative IIS
Ex-Situ
Rioremediation
ACTION-SPECIFIC
California Hazardous
Waste Rules
Standards Applicable
to Generators of
Hazardous Waste
Standards for
Operators of
Hazardous Waste
Transfer, Treatment
and Disposal
Facilities:
Landfills
Waste Piles
Title 22, Division 4.5,
Chapter 12, Section
66262 et seq.
Title 22, Division 4.5,
Section 66264.300 -
66264.318
Title 22, Division 4.5,
Section 66264.250 -
66264.259
Applicable
Applicable
Applicable
NA; no wastes
generated.
NA; no wastes
generated.
NA; no waste piles.
See Alternative 8S.
NA; no wastes.
See Alternative 7S.
Will meet ARAR; will
comply with
characterization, and
onsile container and
storage requirements if
soils or residuals are
determined to be
hazardous waste.
NA; wastes will not be
placed in onsile landfills.
Will meet ARAR by
complying with
regulations. Relevant
only if temporary
storage of KCKA waste
in piles occurs.
Will meet ARAR; only
soils without hazardous
waste characteristics will
be consolidated onsite.
Will meet ARAR; only
non-hazardous wastes
will be placed in onsite
landfills.
See Alternative 7S.
See Alternative 7S.
NA; no wastes.
See Alternative 7S.
C-22
-------
TABLE C-ll
SITE 31 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
: Alternative 2S
Limited Action:
Alternative 5S
Excavation and Low
Temperature Thermal
Desorption
Alternative 7S
Excavation and Offsitc
Treatment
Alternative's*
Excavation and Onsite
Consolidation
Alternative IIS
Ex-Situ
Bioremediation
ACTION-SPECIFIC
Waste Classification and
Management
Discharges of Waste to
Land (Soil Disposal)
South Coast Air Quality
Management District
Rules and Regulations
Fugitive Dust
New Source
Review of
Carcinogenic Air
Contaminants
Title 23, Division 3,
Chapter 15, Article 2,
Section 2522
Title 23, Division 3,
Chapter 15
Prohibitory Rules, Rule
403
Rule 1401
Applicable
Relevant and
Appropriate
Applicable
Applicable
NA; no waste generated
NA; no discharges will
occur.
NA; no excavation will
occur.
NA; no emissions.
NA; no waste generated
NA; no discharge of
waste will occur.
See Alternative 7S.
Will meet ARAR;
emissions of PAIIs will
be below 1x10' risk
level stated in the rule;
controls will not be
required.
ARAR will be met; non-
hazardous waste will be
disposed of as
designated waste
NA; no onsite
discharges will occur.
Compliance will occur
by controlling fugitive
dust to levels of <50
/(g/m3
Not applicable.
ARAR will be met; non-
hazardous waste will be
disposed of as
designated waste
ARAR will be met; non-
hazardous soil will be
covered by a cap.
See Alternative 7S.
See Alternative 5S.
See Alternative 7S
NA; no discharge of
waste will occur. See
Alternative 7S
See Alternative 7S.
See Alternative 7S.
Key:
ARAR = Applicable or Relevant and Appropriate Requirement
HCRA Resource Conservation and Recovery Ac!
I'AII I'olynuclear Aiomalic llydiocaibiin
NA = Not an Applicable or Relevant and Appropriate Requirement
/ig/m1 = Micrograms per cubic meter
* Alternative 8S is no longer a viable alternative
C-23
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TABLE C-12
SITE 31 SUBSURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
Alternative 2S
Limited Action
Alternative 12S
Soil Vapor Extraction with Catalytic
Oxidation
Alternative 13S
Soil Vapor Extraction
with Purus PADRE
System ;
Alternative 14S
Soil Vapor Extraction
with Carbon Adsorption
ACTION-SPECIFIC
California Hazardous Waslc
Rules
Standards Applicable
lo Generators of
Hazardous Waste
Standards for
Operators of
Hazardous Waste
Transfer, Treatment &
Disposal Facilities:
Tanks
Waste Classification ami
Management
South Coast Air Quality
Management District
Rules/Regulations
New Source Review of
Carcinogenic Air
Contaminants
Title 22 CCR, Division
4.5, Chapter 12, Section
66262 et seq.
Title 22 CCR, Division
4.5, Section 6624.190 -
Section 6624.199
Title 23, Division 3,
Chapter 15, Article 2,
Section 2522
Rule 1401
Applicable
Relevant and Appropriate
Applicable
Applicable
NA; no waste generated.
NA; no wastes.
NA; no wastes
NA; no emissions.
See Alternative 2S.
Relevant and appropriate substantive
requirements will be incorporated into
construction and design of tanks.
NA; no wastes
Will meet ARAR; emissions will be
below 3 x 10 ' risk level stated in rule.
ARAR will be met; spent
carbon, cuttings, and
other residues will be
handled and disposed of
as hazardous wastes if
they meet California
classification criteria.
Accumulation and storage
requirements will be met.
See Alternative 12S.
NA; no wastes
See Alternative 12S.
See Alternative 13S.
See Alternative 12S.
Residue will be handled
and disposed of as
designated waste, if it is
non hazardous
See Alternative 12S.
C-24
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TABLE C-12
SITE 31 SUBSURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
'Alternative 2S
Limited Action
Alternative 12S
Soil Vapor Extraction' with Catalytic
Oxidation
: Alternative 13S
Soil Vapor Extraction
with Purus PADRE
System
Alternative 14S
Soil Vapor Extraction
with Carbon Adsorption
ACTION-SPECIFIC (Continued)
South Coast Air Quality
Management District
Rules/Regulations
(Continued)
New Source Review of
Air Contaminants
Rule 1303
Applicable
NA; no emissions.
Due to low concentrations of VOCs in
groundwater, air emissions will be
below the 1 pound/day limit above
which BACT is required to limit
emissions increases (SCAQMD
considers an emissions increase to be at
least 1 pound/day. Nonetheless, BACT
will be used for all alternatives.
See Alternative 12S.
See Alternative 12S.
Key:
RCRA
ARAR
NA
VOC
BACT
Resource Conservation and Recovery Act
Applicable or Relevant and Appropriate Requirement
Not an Applicable or Relevant and Appropriate Requirement
Volatile Organic Compound
Best Available Control Technology
C-25
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TABLE C-13
SITE 34 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2S
Limited Action
Alternative 5S
Excavation and Low
Temperature Thermal
Desorplion
Alternative 7S
Excavation and Offsite
Treatment
Alternative 8S
Excavation and Onsile
Consolidation
Alternative IIS
Ex-Situ
Bioremediation
ACTION-SPECIFIC
California Hazardous
Waste Rules:
Standards
Applicable lo
Generators of
Hazardous Wasle
Standards for
Operators of
Hazardous Wasle
Transfer ,
Treatment and
Disposal
Facilities:
Landfills
Waste Piles
Waste Classification
and Management
Title 22, Division 4.5,
Chapter 12, Section
66262 et seq.
Tille 22, Division 4.5,
Seciion 66264.300 -
66264.318
Tille 22, Division 4.5,
Seciion 66264.250 -
66264.259
Tille 23, Division 3,
Chapter 15, Article 2,
Seciion 2522
Applicable
Applicable
Applicable
Applicable
NA; no wastes
generated.
NA; no wastes
generated.
NA; no wastes piles.
NA; no wastes
generated
See Alternative 8S.
NA; no wastes.
See Alternative 7S.
NA; no wastes
generated
Will meet ARAR; will
comply with
characterization, and
onsite container and
storage requirements if
soils are delermined to
be hazardous waste.
NA; wastes will not be
placed in onsite
landfills.
Will meet ARAR by
complying with
regulations. Relevant
only if temporary
storage of KCKA waste
in piles occurs.
ARAR will be met; non
hazardous waste will be
disposed of as
designated waste
Will meet ARAR; only
soils without hazardous
waste characteristics
will be consolidated
onsite.
Will meet ARAR; only
non-hazardous wastes
will be placed in onsite
landfills.
See Alternative 7S.
See Alternative 7S
See Alternative 7S.
NA; no wastes.
See Alternative 7S.
See Alternative 7S
C-26
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TABLE C-13
SITE 34 SURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Continued
Requirement
Source
Applicable, Relevant
and Appropriate, or
To-be-considered
(TBC)
Alternative 2S
Limited Action
Alternative SS
Excavation and Low
Temperature Thermal
Dcsorplion
Alternative 7S
Excavation and Offsite
Treatment
Alternative SS*
Excavation and Onsite
Consolidation
Alternative IIS
Ex-Situ
Bioremcdiation
ACTION-SPECIFIC (Continued)
Discharges of Waste to
Land (Soil Disposal)
South Coast Air Quality
Management District
Rules and Regulations
Fugitive Dust
New Source
Review of
Carcinogenic Air
Contaminants
Title 23, Division 3,
Chapter 15
Prohibitory Rules, Rule
403
Rule 1401
Relevant and
Appropriate
Applicable
Applicable
NA; no discharges will
occur.
NA; no excavation will
occur.
NA; no emissions.
NA; no discharge of
waste will occur.
See Alternative 7S.
Will meet ARAR;
emissions of PAHs will
be below 1x10' risk
level stated in the rule;
controls will not be
required.
NA; no onsite
discharges will occur.
Compliance will occur
by controlling fugitive
dust to levels of <50
(
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TABLE C-14
SITE 34 SUBSURFACE SOIL
COMPARATIVE ANALYSIS OF COMPLIANCE WITH LOCATION-SPECIFIC AND ACTION-SPECIFIC ARARs
Requirement
Source ;
Applicable, Relevant and
Appropriate, or To-be-
considered (TBC)
Alternative 2S
Limited Action
Alternative IDS
Bioventing
Alternative 12S
Soil Vapor Extraction with:
Catalytic Oxidation
Alternative 13S
Soil Vapor Extraction with
Punis PADRE System
ACTION-SPECIFIC
California Hazardous
Waste Rules
Standards Applicable
to Generators of
Hazardous Waste
Waste Classification and
Management
South Coast Air Quality
Management District
Rules Regulations:
New Source
Review of
Carcinogenic Air
Contaminants
New Source Review
of Air Contaminants
Title 22, Division 4. 5,
Chapter 12, Section
66262 et seq.
Title 23, Division 3,
Chapter 15, Article 2,
Section 2522
Prohibitory Rules - Rule
1401
Regulation XIII; Rule
1303
Applicable
Applicable
Applicable
Applicable
NA; no waste generated.
NA; no wastes
NA; no emissions.
NA; no emissions.
NA; no waste generated.
NA; no wastes
NA; no significant
emissions.
NA: no significant
emissions.
NA; no waste generated.
NA; no wastes
Will meet ARAR; rise from
emissions of BTEX will be
below 1 X 10 ' risk level slated
in rule; additional controls
will not be required.
Will meet ARAR, air
emissions with controls will
be below the 1 pound/day
threshold
Will meet ARAR. Residue
will be handled and disposed
of as hazardous waste if it
meets classification criteria.
Residue will be handled and
disposed of as designated
waste, if it is non hazardous
See Alternative 12S.
See Alternative 12S.
Key:
ARAR
RCRA
BTEX
NA
Applicable or Relevant and Appropriate Requirement
Resource Conservation and Recovery Act
Benzene, Toluene, Eihylhenzene, and Xylenes
Not an Applicable or Relevant and Appropriate Requirement
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