United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-89/030
June 1989
Superfund
Record of Decision
Fairchild Semiconductor
(Mt. View), CA
First and Second
Remedial Actions
-------
50272-101
REPORT DOCUMENTATION 11. REPOATNO. 12.
PAGE EPA/ROD/R09-89/030
~ A8c:1pienC'1 AccMaIon No.
4. Tl1I8 and Subfte '
, SUPERFUND
Fairchild
First and
-, Au1hor(l)
RECORD OF DECISION
Semiconductor (Mt. View), CA
Second Remedial Actions
5. Aapon 0..
06/09/89 -06/30/89
s.
I. P8rf0nnl"ll OrganlDtion ReP'- No.
-. Pllrfonnlng Org8lnlD1i0n ...... and AddI-.
10. ProjactIT ulllWortI UnI1 No.
11. ConInc:t(C) Of' Q,ant(G) No.
(C)
(G)
12. SpoM«tng OrgenIzatIon ...... and Addrw8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
1~ Type of Repot1. Pariod Coveted
Agency
800/000
14.
15. Suppl8mant8ry No-
1 &. Ab8Irac:t (UnlIt: 2110 WOI'd8)
The Fairchild Semiconductor (Mt. View) site is one of three Superfund sites that are
being remediated concurrently. The other two sites are Intel (Mountain View Plant) and
Raytheon. The sites are located in the Middlefield/ElliS/Whisman (MEW) Study Area in
Santa Clara County in the city of Mountain View, California. Land use in the area is
primarily light industrial and commercial, with some residential areas. There are no
natural surface drainage features within or surrounding the site; most of the runoff is
intercepted by a storm drain system and discharged to an offsite creek. Various
'ndustrial activities were conducted in the vicinity of the site, including
miconductor manufacturing, metal finishing operations, parts cleaning, aircraft
aintenance, and other activities requiring the use, storage, and handling of a variety
of chemicals, particularly solvents. Site investigations at several of these facilities
during 1981 and 1982 revealed significant soil and ground water contamination by toxic
chemicals, primarily VOCs. The primary cause of the contamination was leaking storage
tanks and lines, and poor management practices. Before and during additional site
investigations, which were conducted under a 1985 Consent Order, interim cleanup
activities were conducted at the site by Fairchild, Intel, and Raytheon. These included
tank removals, soil removal and treatment, well sealing, construction of slurry walls,
and hydraulic control and treatment of local ground water. The primary contaminants of
(~~~. -~ ,." . \
17. ,Documan1 AnaIpI8 .. DMcripIDI8
Record of Decision - Fairchild Semiconductor (Mt. View), CA
First and Second Remedial Actions
Contaminated Media: soil, qw
Key Contaminants: VOCs (PCE, TCE, TCA, toluene, xylenes), organics (phenols)
b. 1dan1l1\enl0pen-EndacI T-
Co COSIo t1 ReIcIIGr1MIp
11. Avlilabllty ~
18. 5ecuri1y CIaa8 (11111 Report)
None
20. 5ecuri1y CIaa8 (11118 Ptoge)
1IJnn<:>
21. No. of Pagea
95
22. Price
,-- ANSl-Z38.18)
SHtMInJt:fI- on R.-
(4-77)
(Fonneny NTlS-~)
Depa/1men1 o' Commerce
-------
EPA/ROD/R09-89/030
Fairchild Semiconductor (Mt. View),CA
First and Second Remedial Actions
16.
Abstract (Continued)
~oncern affecting the site are VOCs including TCEi TCA, PCE, toluene, and xylenes, and
other organics including phenols.
The selected remedy for this site includes in situ vapor extraction with treatment by
vapor phase GAC of contaminated soil found within the Fairchild and Raytheon slurry
walls. There may be some limited soil excavation and treatment by aeration for some
areas outside of the slurry walls, with onsite disposal of residues in the excavated
area; ground water pumping and treatment using air stripping, and in some cases li~uid
phase GAC, with emissions controls consisting of GAC vapor phase carbon units, followed
by reuse of the ground water (reuse options including reinjection are being developed)
and, if necessary, discharge to surface water; sealing of any conduits or potential
conduits to protect the deep aquifer; and ground water monitoring. The present worth
cost for this remedial action is $49,000,000 to 56,000,000, which includes O&M costs.
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FAIRCHILD, INTEL, AND RAYTIIEON SITES
MIDDLEFIELD/ELLIS/WHISMAN (MEW) STUDY AREA
MOUNTAIN VIEW, CALIFORNIA
RECORD OF DECISION
United States Environmental Protection Agency
Region IX -- San Francisco. California
June 9, 1989
-------
PAXRCaiLD, XHTBL, AND RAYTHZOH 8XTB8
MXDDLBFXBLD/ELLI8/WHX8MAJf (NEW) STUDY AREA
MQ0HTAIH VXEW, CXLI7ORHIA
BBCOBO OF D B C X 8 X O
Onitcd Seat** Bzrrirooa*nc«l Protection Agency
E*gion XZ -- S«n Francisco, California
Hay 1989
-------
BCORD 01' D8CISIO.
ftBLB 01' CO.TUJTS
SECTION
Table of Contents
. 1.0
- 2.0
3.0
4.0
5.0
. _. 6.0
7.0
8.0
9.0
U&t
i
Table ot Figures and Tables
1i
Declara.tion
1ii
Site Location and Descr.iption
Site History
1
2
Enforcement
3
community Relations
Decision Scope
4
4
Nature and Extent of Contamination
5
Baseline Site Risks
6
Changes to the Proposed Plan
Description of Alternatives
8
9
---;:
10.0 ARARs
14
11.0 Other Criteria Considered
-.. 12.0 Summary of Al ternati ves Analysis
-=-> 13.0 The Selected Remedy
I..
14.0 statutory Determinations
18
21
22
24
-- Attachments --
Administrative Record Index
Responsiveness Summary
i
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DCOJU) OP 1)8C18101f
'fULB OP COftBJr1'8
-- P1qur.. --
FIGURE/TABLE
1-1
1-2
6-1
9-1
6-1
10-1
11-1
12-1
Site Location
Buildinq Occupants
Location of MEW Plume
Schematic of Subsurface Zones
-- 'faJ:tl.. --
--- Chemicals of Concern
--- Federal and State Groundwater Standards
--- Groundwater Criteria To Be Considered
--- Criteria for the Evaluation
of Remedial Alternatives
ii
FOLLOWING PAGE
1
1
5
9
5
15
19
21
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"CORD O~ DBCI.IO.
DBCLUA'1'IOK
Site
Name
and Location
Fairchild, Intel and Raytheon Sites, Midd1efie1d/Z11is/Whisman
(MEW) Study Area, Mountain View, California
Statement of Basis and. Puroose.
This decision document presents the 8e1ected 80i1 and qroundvater
remedial actions for the Fairchild, Intel, and Raytheon National
Priority List (NPL) Sites in the Midd1efie1d/E1lisfWhis~an (MEW)
Study Area of Mountain View, California. The .e1ected remedial
actions will also apply to the area-wide qroundwater
contamination and to other areas of 80i1 contamination in the MEW
Study Area, as appropriate. The remedial actions bave been'
developed in accordance with the Comprehensive' Environmental
Response, Liability, and Compensation Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA), and, to
the maximum extent practicable, the National Continqency Plan
(NCP). This decision is based upon the administrative record for
this site. The attached index identifies the items which comprise
the administrative record upon which the selection of the
remedial actions are based.
DescriDtion of the Remedies
The selected soil remedy is in-situ vapor extraction with
treatment ):)y vapor phase qranu1ar activated carbon, and
excavation with treatment by aeration. Most of the vapor
extraction will take place within the existinq Fairchild and
Raytheon slurry walls which contain the bulk of the site soil
contamination. Several smaller areas outside of the slurry valls
will also be remed~ated by in-situ vapor extraction. The cleanup
90als for soils are 1 part per million (ppm) trichloroethene
(TCE) inside the 81urry walls and 0.5 ppm TCE outside of the
slurry walls. The soil cleanup qoa1 i. based on the amount of
contamination that can ramain in the soil and 8till maintain the
qroundwater cleanup goal in the shallow aquifers (outside the
slurry walla). Further explanation of the different cleanup qoals
is provided on page 22 of this document, in Section 13 on IhA
Selected R888dies.
The groundwater r8m8dy is extraction and treatment. Extracted
qroundwater vi'.l be treated by air stripping towers. Airborne. .
emi8sions wi1l.eet all Bay Area Air Quality Manaqament District
emission standards. It is anticipated that ..i.sion controls by
qranu1ar activated carbon will be required once the full remedy
is implemented. The extracted groundwater will be reused to the
iii
-------
maximum extentteasible, with a qoal ot loot reuse. Extracted
water which cannot be reused will be diacharqed to local streams.
Allowable di8charqes to local streams will be regulated by the
National Pol1u~ant Discharqe Eliaination System (HPDZS) of the
Clean Water Act. '
The qroundwater cleanup qoals are 5 parts per billion (ppb) TCE
tor the ahallow aquiters (which are not currently ua8d tor
drinkinq water) and 0.8 ppb TCE for the deep aquiters which are
u.ed tor drinkinq water. Attainment'ot these levels will also
assure cleanup ot the other volatile orqani,c compounds to at
least their respective Maximum contaminant Levels (MCLs). The
shallow aquiter cleanup qoals also apply to the aquiters inside
the slurry walls.
The remedy includes the identitication an~ aealinq ot any
potential conduit wells. Several abandoned aqriculture wells
which acted as conduits tor contamination to miqrate trom the
shallow aquifers to the deep aquifers. have already been sealed.
Additional wells have been identified tor sealinq and others may
be identified which will also require 8ealinq.
The remedy also includes maintaininq inward and upward hydraulic
qradients (bypumpinq and treatment) inside the alurry walls and
reqular monitorinq ot aquiters within and adjacent to the, slurry
walls to monitor the inteqrity ot each slurry wall system.
Maintaininq inward and upward hydraulic qradientswill control'
contaminants trom escapinq due to slurry wall failure. Selected
. wells will be monitored tor chemical concentrations and water
levels.
The soil remedy is expected to be in operation between 1 to 6 -
years. The qroundwater remedy for the B~allow aquifers may be in
operation for as lonq as 46 years or into the indefinite future,
because of the physical and chemical nat~re of the aquifers. The
qroundwater remedy tor the deep aquiters is estimated to be in
operation for at least 2 years and possibly as lonq as 4S years.
There will be reqular monitorinq ot the,qroundwater and slurry
walls durinq the lite ot the remedy.
;,'~~>4,;
Iv
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Declaration
The seleCted remedies are protective of human health and the
environment, attain Federal and State requirements that are
applicable or relevant and appropriate to the remedial actions,
and are cost-effective. With respect to contamination in
qroundwater and soil, the statutory preference for remedies that
employ treatment, reduce toxi~ity, mobility or volume as a
principal element, and. utilize permanent solutions and
alternative treatment technoloqies to the.. maximum extent
practicable is satisfied.
Because of the anticipated length of time to achieve the cleanup
goals and the uncertainty whether the cleanup goals 'can be
achieved, both the technoloqies and the cleanup goals will be
::-eassessed every 5 years. .
i
I .
I
I
J (JMJ it I/JJ~
Daniel w. McGovern
. Regional Administrator
v
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UCOJU) 01'. D8CI8IOM.
D8CI.I08 'UXKaRY
1.0
SITE LOCATION AND DESCRIPTION
The Middlefield/Ellis/Whi.man (MEW) Study Area is located in
Santa Clara County in the city of Mountain View, California.
The site is divided into a Local Study Area (LSA) and a Regional
Study Area (RSA). Fiqure.1-1 identifies the LSA and RSA,.along
with local roads and landmarks. The LSA consists of three
National Priority List (NPL) aites (Fairchild, Intel and
Raytheon), .s well as aeveral non-Superfund sites. The LSA
encompasses about 1/2 aquare .ile of the RSA and contains
primarily light industrial and commercial areas, with some
residential areas west of Whisman Road. The RSA encompasses
approximately 8 square miles and includes Moffett Naval Air
Station Can NPL site) and NASA Ames Research Center, along with
light industrial, commercial, agricultural, park, golf course,
undeveloped land, residential, motel and school land uses.
Various owners or oCcupants in the area around the intersections
of Middlefield Road, Ellis Street, Whisman Road, and the Bayshore
Freeway (U.S. Highway 101), are or were involved in the
manufacture of 8emiconductors, metal finishing operations, parts
cleaning, aircraft maintenance, and other activities requiring
the use of it variety of chemicals. Local facilities with current
occupants ar.e presented on Fiqure 1-2. Site investigations at
several of these facilities have. revealed the presence ot toxic.
chemicals in the subsurface soils and groundwater. To investigate
the extent of groundwater contamination 8JDanating from the LSA,
and soil contamination at their respective facilities, Fairchild,
Intel, and Raytheon performed a Remedial Investigation and a
Feasibility Study of potential remedial alternatives under the
direction of. EPA.. ..
There are nc) natural 8urface drainage features within the Local
Study Area. The nearest significant natural surface drainage
features of the Regional Study Area are Stevens Creek to the west
and Calabaza8 Creak to the east. Calabazas creek is located
approximately four ailes east of the MEW Study Area. Stevens
Creek foraathe vestern boundary of the Regional Study Area. Both
discharge 1D~o the San Prancisco Bay. Surface vater runotf trom
most of the RIA and all of the LSA aouth of the Bayshore Freeway
i. intercept.ad by a storm drain system and is discharged into
Stevens. Crettk. To the north of the Bayshore Preeway, aost of. the
runoff from Moffett Field Naval Air Station is collected by a
storm drain systea that ulti..tely discharges to ~uadaluP8 Slough
of San. Francisco Bay. Runoff from the northwestern portion of
Moffett Field discharges into Stevens creek.
1
-------
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81t. Location
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The Local and Regional study Areas are underlain by a thick
.4quence ot unconsolidated .edimentsdeposited into a .tructural
depression. ~e .ediment. are comprised ot alluvial tan,' ,
estuarine, and bay 8ud deposits. Repeated variations in .ea
levels re.ulted in a complex sedimentary .equence characterized
by irregular interbedding and intertingering ot coar.e and tine
qrained depo.its. ' ,
. '
Groundwater aquifers at, the site are .Ubdivided into shallow and
deep aquiter .ystems, separated by a laterally extensive regional
aquitard. The shallow aqu~ter .ystem comprises aquiters and
aqui tards. . to a depth ot approximately 160 teet below the surtace.
Within the shallow system tour primary hydroqeoloqic aquiter
zones have been identitied based upon the occurrence ot aquiter
. materi'al and a similar depth below the .urtace.. The .hallow
aquiter .ystem is comprised ot the A-aquiter and the underlying
B1-, B2- and B3- aquiters. The regional B-C aquitard separates
the B3-aquifersfrom the C-aquiter and the deep aquifer system.
CUrrent groundwater flow in aquiter zones above the B-C aquitard
is generally to the north, toward San Francisco say.
2.0
SITE HISTORY
During 1981 and 1982, preliminary investigationsot tacilities
within the LSA indicated signiticant concentrations of
contaminants in soil and groundwater. By 1984, the Fairchild, "
Intel and Raytheon sites, located within the LSA, were proposed
for the Federal National Priorities List (NPL). By 1985, five
companies within the LSA (Fairchild, Intel, Raytheon, NEC, and
Siltec) initiated a joint investigation to document and
characterize the distribution of chemicals emanating from their
facilities. In April 1985, the Calitornia Regional Water Quality
Control Board - San Francisco Bay Region (RWQCB) adopted Waste
Discharge Requirements (WORs) for eachot the five companies. The
primary cause ot the subsurtace contamination was trom leaking
storage tanks and lines, and poor waste management practices.
On Auqust 15, 1985, Fairchild, Intel, and Raytheon entered into a
Consent Order with the EPA, the RWQCB, and the California
Department of Health Services (DBS). Since signing of the Consent
order, the three companies have carried out an extensive Ramedial
Investigation and Feasibility Study (RI/FS) of chemicals
emanating fraathe LSA and soil contamination at their respective
facilities. Work bas been Performed under the .upervision of EPA,
the awQeS, DBS, and the Santa Clara Valley Water District
(SCYWD). Prior to and during the .ite investigation, the
companies have been conducting interim clean up activities at the
.its. These interim remedial actions include tank r_ovals, soil
removal and treatment, well s.aling, construction ot slurry
2
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------"----._.-~-~~-- ..
---~
--- .
valls, and hydraulic control and treatment ot local groundwater.
NEC and Siltec declined to enter into the Consent Order and wer~
placed und.r RWQCB entorce.ent authority.
The three C08panie. tollowed an approved Quality Assurance and
Quality Control (QA/QC) Plan and approved Samplinq Plana. In
addition, 8plit sample. vere collected by EPA trom s.lected wells
and the.e result. were compared with the companie.' sampling
re.ults. EPA determined that the companies' data quality was
adequate ~~or the purpose ot. the RI/FS.
. The MEW Romedial Investigation Report was concluded in July,
1988. The dratt Feasibility Study and EPA's Proposed Plan were
presented to the community for review and public comment in
November, 1988. In May 1989, SPecial Notice letters tor the
Remedial Design/Remedial Action (RD/RA) Consent Decree were sent
out to the tive (5) original companies and twelve (12) other'
Potentially Responsible Parties (PRPs).
3 . 0 . ENFORCEMENT
The Regional Water Quality Control Board - San Francisco Bay
Region (RWQCB) was the lead agency until April 1985, when the
Board reterred the tive companies to EPA tor cleanup under
SUperfund. In May, 1985, EPA sent qeneral notice letters,
pursuant to Section 106 ot CERCLA, to the tive companies. NEC and
Siltec chose not to participate in the RI/FS negotiations and
were reterred back to the RWQCB. In Auqust 1985, Fairchild,
Intel, and Raytheon .igned an Administrative Order on Consent
with EPA, to conduct an RI/FS ot the MEW area. The RWQCB and
Calitornia Department ot Health Services were cosiqriees ot the
Consent Order.
The Consent Order and Work Plan called tor a comprehensive
groundwater investiqationot the MEW area and site specitic
(source) investiqation at Fairchild, Intel, and Raytheon. The
RWQCB issued Waste Discharge Requirements (WDRs) tor NEC and
Siltec which paralleled the Consent Order schedule and
requirements.
Durinq the course ot the RI/FS, EPA qathered new intormation and
evaluated existing intormation concerning other PRPs.
Durinq Deetl8b8r 1987 and January 1988, EPA issued twenty-tour
(24) RCRA3007/CERCLA 104 intormation request letters to various
other partie. in the MEW area. In July 1988, EPA issued a RCRA
3013 Unilateral Order to GTE to beqin an inveatiqation ot its
proPerty, to determine it the company had contributed to the .MEW
groundwater plume. Atter evaluatinq the 3007/104 response.
letters, EPA sent General Notice tetters to seventeen (17) PRPs
3
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in S.p~88ber 1988. An ini~ial PRP meeting was sponsored by EPA in
OC~ob.r 1988, ~oexplain~..Supertund process to ~e no~iced
PRPs. BPA i..ued ..ven (7) a4di~ional General Notice and/or
inforaatlon r.que.~ l.t~ers in March 1989. EPA subsequen~ly
issued Special Ho~ice Letters tor conducting the selected
remedies in ..y 1989.
4.0
COMMUN7TY RELAT70NS
The co..en~ period for the Proposed Plan opened November 21,
1988, and .closedJanuary 23, 1989. A public meeting was held on
December 14, 1988 a~ the Crittenden Middle School in Mountain
View and vas attended byapproxi88tely 75 people.
Prior to ~e beginning ot ~e public cOJIIJDen~ period, EPA
published notices in "The View", "The Los Al~os TovnCrier", "The
Times Tribune", and the "San Jose Mercury News" (Peninsula Extra
Edition). The notices brietly described the Proposed Plan and
announced the'public comment period and the public meeting. The
notice also announced the availability ot the Proposed Plan tor
review at the information repository established a~ the Mountain.
View. Public Library. .
A tact sheet describing the Proposed Plan vas delivered to the
Mountain View Public Library in November, 1988. Copies ot the
tact sheet were also mailed in November, 1988 to EPA's MEW
mailing list, vhich contains members of the. general public,
elected otticials, and PRPs.
In addition, EPA held several workshops and brietings.in November
and December, 1988 tor various cOJIIJDunity groups, the Mountain'
View City Council, and the Santa Clara County Board ot
Supervisors. The workshops vere used to brief community groups
and elected otticials on the resultsot the MEW RI/FS and to
describe EPA'a proposed remedial alternatives. .
EPA has prepared the attached response summary, which provides
Agency responses to comments submitted in writing during the
public comment period. Also attached is a transcript of the
proceedings of the December 14, 1988 cOJIIJDunity .eeting.
5.0
DEC7StOlf SCOPE
A8 discussed in ~e Declaration and Site History, the selected
r..edial actions that are presented in this decision document are
d.signed to protect the local drinking vater supplies, restore
the ..hallow, and deep aquifers to .eet MCLII and a 10.. risk level
respectively, control and remediate contamination in subsurface
4
-------
.oi15, and prevent vertical aigration ot contamination in the
aquiter.. The ditterence in decision on cleanup goal. tor the
.hallow and deep aquiter. i. provided on paqe 22 ot this
document, in Section 13 on The Selected Remedies.
The remedial actions, pumpinq and treatinq groundwater and
conduit .ealinq, vill address the area-wide groundwater
contamination. The remedial action., in-.itu .oil vapor
extraction, and excavation and treatment will addre.s .oil
contamination at the Fairchild, Intel, and Raytheon NPL sites and
other areas. ot .oil contamination identified in the MEW Study.
Area.
6.0
NA'I'URJe: AND EXTENT .OF CONTAMINATION
Industrial activities conducted within the MEW Study Area
required the storage, handling and use of a large number of
chemicals, particularly solvents and other chemicals used in a
variety of manufacturinq processes. Siqnificant quantities of
volatile oJ:'ganic chemicals were used tor deqreasinq, process
operations" and for general maintenance. Raw and waste .01 vents
and other chemicals were piped and .tored in underqround systems.
The presence of chemicals in the subsurface soils and
groundwater, .that originated trom facilities in the MEW area, are
primarily t~e result ot leaks trom these subsurtace tanks and
lines, sumps, chemical handling and storaqe' areas, and utility
. corridors. Chemical releases occurred, tor the most part, below
the ground surtace and migrated downward into the aquiter system.
Investigations at the .ite have revealed the presence of over 70
compounds in groundwater, .urtace water, .ediments, and
subsurface soils. The vast majority and quantity of these
compounds are found in qroundwater and subsurface .oils. Three
major classes of chemicals were investigated during the RI: (1)
volatile organic compounds, (2) semi-volatile acid and
base/neutral extractable organic compounds, and (3) priority
pollutant metals. Of these three classes, volatile organics are
the most prevalent. Table 6-1 presents chemicals ot concern,
frequency ot d.~ection, and aaximum concentrations. .
An extensive area at groundwater contamination has been detined
. in the RI and is presented in Figure 6-1. CUrrent site data
indicate that chemicals are present primarily in the A-, 81-, and
82-aquiter zones. To a auch lesser dec;ree, chemicals have been
detected in localized areas at the 83-, C-aquiter, and deeper
aquiter zones. contamination of the C-aquifer and deeper aqUifers
appears to have resulted trom chemicals aiqratinq downward trom
shallow areas containinq eleva~ed chemical concentrations,
through conduit wells, into qroundwater ot the deep aquiter
system. The C and Deep aquiters most attected by contamination
5
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TABLE 6-1
CHEMICALS OF CONCERN
IfIDDLEFIELD/ELLlS/WHISMAN STUDY AREA
Chemical
Frequency ot
Detection.
Geometric Mean Maximum
ConcentrationbConcentrationb
(mq/liter) . (89/liter)
oraanics
Chloroform 71/384 0.002 3.3
1,2-Dichlorobenzene 13/384 0.003 5.2
1,1-Dichloroethane 98/384 0.005 10.0
1,1~Dichloroethene 153/384 0.006 20.0
1,2-Dichloroethene 200/384. 0..030 330.0
Freon-113 181/384 0.. 009 46.0
Phenol 21/273 0.002 50.0
Tetrachloroethene 64/384 0.003 3.7
1,1,1-Trichloroethane 184/384 0.017 420.0
Trichloroethene 278/384 0.175 1000.0
Vinyl Chloriae 17/384 0.008 25.0
Inoraanics
Antimony 15/205 0.052 0.600
Cadmium 26/205 0.006 0.050
Arsenic 34/292 0.004 0.040
Leaa 44/292 0.002 0.043
Value. for organics are number ot detects/number ot aamples
tor the fourth round of groundwater sampling. Val\J... tor
inorqanic. are the number of detects/number of vell aamplea
tor dissolved ..tals.
a/
b/
Values reported are tor all groundwater samples tor each
chemical.
-------
".
!.8g8nd
. TeE Shallow Aquif.
CGntanilldon
. Agricutbn WeBI Showing
TeE D8IP Aquif.. Comamination
jV
c SIuny W8III
. FUchIld
m 1nt8t
. Raytheon
"IJJ
Location
01 MEW Plume
Figure 6-1
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are in'the areas of the so-called Rezendes Wells, located near
Fairchild Buildinq 20, and the Silva Well, located at 42 Sherland
Avenue. ~ vells have subsequently been s.aled. The closest
municipal _~er .upply vell, Mountain Viev '18 (MY 18), is
located approxiaately 1800 feet to the southwest of the Silva
Well. Groundwater samples are collected from MY 18 on a reqular
basis. Ho contaminants have been identified in any vater samples
fr08 MY 18. A8 part of the Remedial Desiqn and Remedial Action
(RD/RA) some additional qro~dwater investigations ~y be
necessary, particularly in the Silva Well area.
Subsurface soil contamination has been found at the Fairchild,
Intel, and Raytheon facilities, alonq vith the facilities of
other PRPs within the RSA. Trichloroethene (TCE), 1,1,1-
trichloJ:"oethane.(TCA), trichlorotrifluoroethane (Freon-113), 1,1-
dichloroethene (l,l-DCE), 1,2-dichloroethene (1,2-DCE), .ethylene
chloride, toluene, acetone, and xylene are the chemicals most
commonly detected in subsurface soil. in the LSA. Chemicals
associated vith activities in the RSA appear to be concentrated
in shallow soils above approximately 50 feet or rouqhly extending
to the Bl-aquifer. Chemicals are' not found in surface soil
samples (upper one foot of soil) and do not appear in soils and
clay of the B-C aquitard. Chemical found in subsurface soil
samples are generally similar to those found in adjacent
.qroundwater samples. As part of the Remedial Desiqn and Remedial
Action s01le additional soil investigations may be necessary in
certain areas. .
7.0
BASELINE SITE" RISKS
An Endangerment Assessment prepared by EPA as part of the RI/FS
was used to evaluate the ramifications of the no-action remedial
alternative and to determine if an actual or threatened release
of a hazardous substance from the site may present an imminent or
substantial endanqerment to public health, veltare, or the
environment.
Large areas of the site are contaminated. The bulk of the
contamination is pre.ent in groundwater and subsurface soils.
Investigation. at the site have revealed the pre.ence of over 70
compounds. Becau.. of the large number of chemicals detected at
the site, . ..lection process va. used to determine the chemicals
of primary concern at the site. The orqanic chemicals that were
selected are: trichloroethylene, 1, 1, 1,-trichloroethane, vinyl
chloride, 1,1-dichloroethane, 1-,1-dichloroethylene, 1,2-
dichloroethylene (cis and trans i.om.rs), dichlorobenzene,
chloroform, Freon 113, tetrachloroethylene, and phenol. Metals
vere detected infrequently. OVerall .etals are ot le.s concern at
the site that the volatile organic chemicals. Several of the
selected contaminants (trichloroethylene, chloroform,
6
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dichlorobenzene, tetrachloroethylene) have been shown to be
carcinogenic in animal. and have been classitied by EPA a.
possible or probable human carcinogens. Vinyl chloride i. a
buman carcinogen. The other contaminants have been shown to
systemic toxicity under certain exposure condition..
The result. ot the Endanqerment Assessment indicate that exposure
to contaminated qroundwater poses the qreatest public health
concern. Risks to public hea~th were estimated by combininq
intormation on exposure at possible exposure points with toxic
potencyot the qroundwatercontaminants. Drinkinq water from
hypothetical wells to the west of Whisman Road tor a litetime
would be ass~iated with an upperbound ~fcess litetime cancer
risk ot 6(10) (averaqe case) and 2(10) (maximum case).
Drinkinq water trom a well to the north of the' LSA in the A-
aquiter would be associated with an upperbound excess litetime
cancer risk ot 9(10)-3 (averaqe case) and 4(10)-2 (maximum case).
Drinkinq water trom a B1-aquiter well in the same ~rea would pose
an upperbound e~cess litetime cancer risk ot 1(10)- (averaqe .
case) and 5(10)- (maximum case). In addition, estimated intake
of noncarcinogenic compounds trom qroundwater at these locations
would exceed reterence dose levels (RtDs). .
known
cause
Contaminants are not present at elevated levels in exposed.
surtace soils. Consequently, substantial exposure via direct
contact with contaminated soils or via inhalation ot volatile
compounds trom soil or contaminated tuqitive dust is considered
unlikely under current land-use conditions. It redevelopment of
the site was to occur tor residential or other uses, signiticant
exposure to contaminants can occur it localized areas ot
contamination remained uncovered. Short-term excavation
activities at the site could lead to inhalation ot volatile
orqanic compounds or contaminated tuqitive dust, but exposure
would probably be ot ahort duration and trequency, and therefore
would not pose a siqniticant public health concern.
Low concentration-levels ot several chemicals were detected in
Stevens Creek, at the western boundary ot the RSA. Any exposure
to these chemicals would probably be ot short duration and
trequency, and therefore the risk would be neqliqible.
The Endanqerment Assessment also indicates that -environmental"
(flora and fauna) exposure to chemicals trom the MEW site is
neqliqible.
In summary, ~e result. ot the baseline risk assess.ent tor the.
no-action alternative indicate that exposure to contaminants in
qroundwater pos.s the qreatest potential .public healt~concern.
7
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8.0
1.
2.
3. .
CHANGES TO THE PROPOSED PLAN
The Proposed Plan identities vapor extraction as ~e
preferred alternative to address contaminated soils.
Bovever, because soil excavation and treataent by
aeration has been ettectively imple.ented at.MEW in ~e
past (at Intel), and other PRPs have expressed interest
in exploring this alternative for their site., the
selected re.edy tor 80i18 will also allow 80il
excavation to be implemented, provided tederal, 8tate,
and local air standards can be .et. In addition to
local air standards, Best Demonstrated Available
Technology (BCAT) treataent standards may also be
required depending upon hov the excavated 80i1 ia
handled. The addition of aoi1 excavation and treatment
by aeration allowstlexibility during the RD/RA phases
for other PRPs to use a cost effective alternative for
their particular sites while also protecting human
health and the environment. Soil excavation and
treatment by aeration would most likely be suitable for
small localized areas ot contamination.
The Proposed Plan appears to be ambiquous in the
cleanup goal tor aquiters within the slurry valls.
While the Proposed Plan cleanup goal for ~. shallow.
aquifers is 5 ppb for TCE, however, the plan also
states that the shallow aquifer zone is defined as
those shallov aquifers located outside the 8lurry
walls.
Although the aquifers confined by the slurry walls are
disconnected fro. ~e outside aquifers (vhen hydraulic
control is maintained by pumping aquiters inside the
slurry walls) a cleanup g081 of 5 ppb tor TCE (the MCL)
will also be established for aquifers inside the slurry
walls. This goal is aore protective ot the public
health and' the environment and is consistent with
cleanup goals set by the RWQCB for another site in
Santa Clara Valley.
Identi~ication and sealing ot potential conduits vas
disCU888d in text of ~e Feasibility Study (FS) and in
Appendix L ot the PS, but not 8pecifically noted in EPA's
Propoaad Plan. Potential conduits vill be, identified,
evaluated, and 8ealed if necessary.
8
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9.0
DESCRIPTION OP A.LTERNATIVES
The MEW pe..ibility Study identified an array of r..ediation
technologi.. that vere potentially applicable and then screened
those technologies based on their applicability to site
characteristics, compatibility vith site-specific chemicals, and
antic-ipated performance. A.fter the technoloqy screeninq process,
alternative. vere formulated usinq combinations of feasible
technologies that are capable of .eetinq rem.dial object~ves.
These.alternatives vere evaluated based on their publicbealth
and environmental impacts and on order of aaqnitude cost
considerations. The short- and lonq-term effectiveness of each
alternative vas also assessed. After this initial screeninq of
remedial alternatives, a detailed analysis of the selected
alternatives vas performed. This section of the Record of
Decision viII present the alternatives evaluated in the detailed
analysis of remedial alternatives.
To evaluate the remedial alternative., the MEW Study Area was
divided into five subsurface zones, as show in Piqure 9-1. The
first subsurface zone (Zone 1, the .cohesive shallow layer")
consists of soil stratum that beqins at the ground surface and
extends to the water table. The upper foot of the cohesive
shallow layer is not included in the analysis of alternatives
based upo~ the conclusion set forth in the Endanqerment
Assessment that there are no health risks from exposure to
surface soils. The second subsurface zone (Zone 2A, the
"unsaturated disconnected aquifers") consists of the unsaturated
zone within the area bounded by the existinq slurry walls. The
Fairchild slurry walls extend into the A/B aquitard. The Raytheon
slurry wall extends throuqh the A/B and B1/B2 aquitards and into
the 82 aquifer. The third subsurface zone (Zone 28, the
.saturated disconnected aquifers") consists of the saturated zone
within the slurry walls. The fourth subsurface zone (Zone 3, the
.shallow aquifers") consists of the shallow aquifer system
outside of the slurry walls. The fifth 8ubsurfacezone (Zone 4,
the "deep aquifers") consists of the C-aquifer and deeper aquifer
zones. .
The ranqe of potential remedial alternatives ara presented for
each subsurface zone: Zone 1 Soils: Zone 3 Shallow Aquifers; Zone
4 Deep Aquifer.: and Zones 2A and 2B Slurry Wall System.
Zone 1 - 8011s
No Further Action:
The No Action alternative serve.
other alternatives are compared.
would be conducted, and all soi1
discontinued.
as a .baseline" aqainst which
For soils, only 80il .onitorinq
pilot 8tudy activities would be
9
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SURFACE LAYER
I .
ZON£
I
I I. .
I 1
-~
. . SLURRY WALL
~ ~CONFINING AQUIT~RD
".
ZON £ /
ZON£ /
ZON£ 2A
ZONE 3
......
ZONE 3
ZON£-28
SLURRY WALL
'8-c' AOI.I/rARO
ZON£ '"
~
~ GR~UNO WATER L.EVEL.
r-: SI..\JRRY WAL.L. EXTENSION
. -
-- TtiROVGH AQ'JITARO
~
QONe D COHESIVE SHALLOW L.AYER
<:fpNe.w UNSA 1'URA T!D OISC~NNEC'T[D AOUIF'ERS
(lpN£ il) SA i"JRA ~ DISCONNECTED
AQUIFERS
. @Ne U SHALL.OW ACUIFERS
@N£ 0 OEEP AOUIF!RS
SCHEMATIC OF SUBSURFACE
ZONES AT MEW SITE
SLURRY WALL
MOUNTAIN V:EW, CALIFOR~JIA
PREPARED FOR
REMEDIAL INVESTtGATION/FEAStBLlTYSTUOY
MIOOLEFIElO-EI..LIS-WHISMAN AREA
Figure 9-1
-------
In-Situ Vapor Extraction and Treatment:
Soil vapor extraction involves removing the volatile aoil
contaminant. without excavating the .oil itaelt. Thi8 would be
accomplished by installing vapor extraction well. ,through which
air containing Volatile Organic Compounds (VOCa) ia pumped trom
the .oil. Contaminants in the extracted air are then removed
using carbon treatment, it necessary, and the treated air is
releaaed. The treatment process ia deaigned to .eet all
applicable air emisaion .tandards.
Partial Excavation and Ambient Temperature Aeration:
This alternative involves excavating and aerating the soil, which
causes the VOCs to volatilize. Treated aoila are then placed back
in their original locations. The areas that would be excavated
are those with the highest level ot contamination. Treatment by
ambient temperature aeration would be conducted inside a
controlled atmosphere enclosure where necessary. This enclosure,
would prevent the migration ot tugitive dust and chemicals vapors
trom the treatment area; Chemical vapors would be captured by
activated carbon, it necessary. The primary disadvantages ot this
alternative are that soils located under buildings and other
structures could not ~e excavated and treatment ot the air
emissions is ditticul t. . .
Partial Excavation and Ambient Temperature Aeration with In-Situ
Vapor Extraction:
This alternative involves a combination ot the previous two
cleanup alternatives. Excavation and aeration would be used at
those soil contamination zones that are accessible. Vapor '
extraction would be used tor selected contamination zones that
are not easily accessible, such as soil contamination zones
located under buildings.
Zone 3 - Shallow Aaui!ers
No Further Action:
The No Action alternative tor the shallow aquiters would involve
only groundwater 80nitoring; no additional cleanup activities
would be CODducted.
Hydraulic Control by Groundwater Extraction and Treatment:
This alternative involve. low-rate pumping ot the aftected
'aquiters with 80ni toring ot the plWl8, and represent. the lowest
level ot active restoration evaluated tor the ahallow groundwater
aystem. Recovery wells would be installed in appropriate
locations along the periphery ot the plume. The extraction well
10
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would operate at . pu8ping rate sufficient to insure that the
plume would not expand laterally. Extracted qroundwaterwould be
treated uaing air 8tripper-based treatment syste.. and vapor-
phase carbon adsorptiQn (where necessary) which would be operated
under applicable air and water quality requirements. The treated
water would be discbarqed to stevens Creek via the storm sewer
system. A netvorkor'aonitoringwells would be used to determine
any change. in the extent of the plume. .
Hydraulic Remediation by' Groundwater Extraction and Treatment:
This alternative tavolve. pumping the attected aquiters at a rate
sufficient to achi..e an accelerated reduction in the extent of
the plume and reduction ot chemical concentrations in the
groundwater. This a1ternative would also utilize a network of
monitoring wells to verify remediation progress. Extraction wells
would be installed in locations around the periphery and in the
plume. Extracted groundwater would be treated using air stripper-
based treatment systems and"vapor-phase carbon adsorption if
necessary, which waald be operated to meet applicable air
emission limitations.. Treated water would be discharged to
Stevens Creek via tbe storm sewer system.
Vertical Impermeablesarriers:
This alternative inwolV8s constructing a vertical impermeable
barrier around the entire MEW plume, in order to hydraulically
isolate the shallow aquiters. This alternative would not result
in a permanent reduction ot chemicals currently in the shallow
aquifer system, unless implemented in conjunction with other
remedial alternatives.
Zone 4 - ~eD Aaui~ers
No' Further Action:.
The No Action alternative, which is used as a baseline tor
evaluation of remedial alternatives, consists ot monitoring the
existing groundwater plume. .
Hydraulic Remediation by Groundwater Extraction and Treatment:
Elements of this a1~rnative are described above tor shallow
aquiters and are essentially the same tor the deep aquifers.
Zone 2A - un.atura+~ Disconnected Aauiters (Slurrv Wall System)
No Further Action:
The No Action alternative involves no turther treataent ot Zone
2A soils, located vithiD the are. bounded by the existing 8lurry
walls. Under this a1ternative, the unsaturated disconnected
11
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aquifer .oil. would remain contained laterally by the slurry
cutoff valla. tong-term 80nitoring of vater levels and chemical
concentration. in the ..turated disconnected aquifer. (Zone 2B)
and the .hallow aquifer (Zone 3) vater-bearinq zone. outside
(beneath and around) the .lurry valla vould be required to detect
migration of chemicals trom the unsaturated .oil. within the
.lurry vall..
In-Situ Vapor Extraction:
This alternative for rem.diation of the unaaturated disconnected
aquiter .oils involves aerating the Zone 2A .oils by vacuum .
extraction, treating the extracted air in accordance vith
applicable air quality requirements. Extracted volatiles vould
pass through an emission control .ystem consisting ot vapor-phase
carbon adsorption tor removal of the voc. trom the extracted air
prior to discharge to the atmosphere in accordance vith
appropriate air requirements. This alternative would also use
existing extraction .vells to remove the groundwater necessary to
maintain desired vater levels. The extracted groundwater vouldbe
treated using air strippers or carbon adsorption to remove VOC's
prior to discharge of the extracted groundwater to S~evens Creek.
Maintain Inward and Upward Gradients:
This alternative involves pumping limited quantities of .
groundwater trom the saturated portions- of the aquifers vithin
the slurry walls. This process vill maintain a hydraulic gradient
inward across the slurry valls and upward, thereby restricting
the movement of chemicals outward into the .hallow aquiter zone
(Zone 3). . The use of hydraulic control in conjunction with the
slurry walls ensures that contaminates vill be kept localized
(within the contines ot each slurry wall) and add an additional
level ot protection it a slurry vall failure was to. occur. The
conjunctive use of slurry walls and hydraulic control is referred
to as a slurry wall .yste.. The extracted groundwater would be
treated using air .tripping or carbon-adsorption prior to
discharge to Stevens Creek.
Flushing:
This alternative, for remediation of unsaturated aquiters within
the slurry valls (Zone 2A), involves the extraction of vater trom
the saturated 8Oil., re-saturation of the unsaturated .oils,
treatment of extracted groundwater by air .tripping, and
reinjection of the treated vater into resaturated .oils within
the .lurry valls. The unsaturated .oils vould be rem8diated by
flushing u.ing a network of vater injection and extraction vells.
Extracted groundwater vould be treated by air stripping prior to
reinjection through the injection vell network. .
12
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I
Partial Excavation and Ambient Temperature Aeration:
This alternative tor 2A aoi18 involve. the partial excavation ot
highly localized areas of chemicals containing unsaturated
disconnected aquiter .oi18. Treatment by ambient temperature
aeration vould be conducted inside a controlled atmosphere
enclosure vhere necessary. Thi. enclosure vould prevent the
aigration of fugitive dust ~nd chemicals vapors from the
treatment area. Chemical vaporsvould be captured by activated
carbon, it necessary.
Zone 2B - Saturated Disconnected Aauifers (Slurrv Wall System)
No' Further Action:
The No Acti~n alternative involves no turther treatment of the
contained soils or hydraulic gradient control vithin the area.
bounded by the slurry valls. Long-term monitoring of vater levels
and chemical concentrations in the saturated disconnected
aquiters> (Zone 2B} and the shallow aquifer (Zone 3) water-bearing
zones outside (beneath and around) the alur~ valls would be
required to detect migration of chemicals tram the unsaturated
soils wi thin the slurry walls. .
. In-Situ Vapor Extraction With Dewatering:
This alternative for remediation of aaturated aquifer soils
involves dewatering the aquifers within the area bounded by the
slurry valls, aerating the dewatered soil pore spaces by vacuum
extraction, treating the extracted air, if required, with vapor-
phase carbon adsorption, treating the extracted groundwater with
air stripping, and discharging the treated air and water in
accordance vith applicable air and water quality requirements.
The extracted groundwater would be treated. using air strippers or
carbon adsorption to remove VOCs prior to discharge of the
extracted groundwater to Stevens Creek.
Maintain Inward and Upward Hydraulic Gradients:
This hydraulic control alternative for aaturated aquifers within
the slurry valla (Zone 28), involves pumping relatively a.all
quantities ot vater from vithin the slurry wall areas tor the
purpose of lowerinq the interior water table to produce inward
and upward hydraulic qradienta. The inward and upward hydraulic
qradient. would preclude the outward aiqration of chemicals
present with the zone contained by the .lurry vall areas. The
88all quantities at qroundwater pumped tram within the alurry
valls would be treated usinq on-site air stripper-baaed ayatems
or carbon 4dsorpt~on, which would be operated in accordance with
applicable air and water quality requirements. The required
monitoring for this alternative would be the same acope as that
13
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required under the "No Further Action" (monitorinq only)
alternative.
Flushinq:
This alternative for remediation of saturated aquifers within the
slurry wall areas involves the extraction of water from the
saturated soils, treatment of extracted groundwater by air
stripping, and reinjection of the treated water into saturated
soils within the slurry walls. Extracted groundwater would be
treated using air strippers or carbon adsorption prior to
reinjection through the injection well network.
10.0 APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS (ARARs)
Under Section 121(d) of CERCLA, as amended by SARA, the selected
remedy must achieve a level or standard of cleanup that assures
protection of human health and the environment. In addition,
CERCLA requires that remedial actions achieve a level. or standard
of cleanup that meets legally applicable or relevant and
appropriate requirements, standards, criteria or limitations
. (ARARs). .
ARARs associated with the site have been. generally separated into
three categories: (1) ambient or chemical specific requirements
that set health or risk-based concentration limits or ranges for.
particular chemicals; (2) performance, design, or action-specific
requirements that govern particular activities: and (3) location-
spec;fic requirements. For this site the selection of ARARs is.
dependant on the defined beneficial use of groundwater as a
source of drinking water. .
Beneficial Use of Local Groundwater as a Source of Drinkina Water
The requlatory framework associated with the cleanup of
groundwater and soil at the site is driven by the beneficial
(current or potential) use of local groundwater. As stated in 40
CFR 300 of the Federal Register on page 51433 (December 21,
1988), "The goal of EPA's Superfund approach is to return usable
ground waterato their beneficial uses within a timeframe that is
reasonable-. Drinking water is considered to be the highest
beneficial use and affords the greatest level of protection and
cleanup.
As required' by the California Portor~Coloqne Water Quality
Control Act, the Regional Water Quality Control Board - San
Francisco Bay Region defines the beneficial uses of various water
bodies in the greater San Francisco Bay Area. Water bodies and
their beneficial uses are presented iri The San Francisco Basin
Plan. This regional plan has been promulgated and is an ARAR for
14
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this site. In the Basin Plan the Regional Board classifies the
shallow aquifers in the area of the MEW plume as a "potentially
suitable for Municipal or domestic water supply". In addition,
the Basin Plan states that the "use of waters in the vicinity
represent the best information on beneficial uses". Currently,
the c and Deep aquifers at the site are used as a municipal
drinking water supply.
CHEMICAL-SPECIFIC ARARS
Chemical-specific ARARs for the MEW site are Federal and State of
California drinking water standards. Each is relevant and
appropriate to set cleanup standards at the site. A list of
Federal and State drinking water standards are presented in Table
10-1.
Federal Drinking Water Standards
Potential drinking water standards at the site include Maximum
Contaminant Level Goals (MCLGs) and Maximum Contaminant Levels
(MCLs):
As stated in CERCLA Section 121 (d)(1), MCLGs are mentioned as
potential cleanup standards when these levels "are relevant and
appropriate under the circumstances". After weighing all factors,
EPA has determined that they are not relevant and appropriate for
the site.
The relevant and appropriate standards to establish groundwater
cleanup levels at the site are the Federal Maximum Contaminant
Levels (MCLs), as presented under Safe Drinking Water Act. EPA
bases this decision on the fact that MCLs are fully protective of
human health and, for carcinogens, fall within the established
acceptable risk range of 10*4 to 10 . MCLs are ARARs for
groundwater at the site and are also used to establish soil
cleanup levels.
State Drinking Water Standards
California Drinking Water Standards establish enforceable limits
for substances that may affect health or aesthetic qualities of
water and apply to water delivered to customers. The state's
Primary Standards are based on federal National Interim Primary
Drinking Water Regulations. Currently, California has promulgated
MCLs for cadmium, arsenic and lead, and some of the organics of
concern.
15
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TABLE 10-1
nDDAL AND STATE GROUNDWATER STANDARDS
MIDDLEFIELD/ELLIS/WHISMAN STUDY AREA
Chemical
Federal
Maximum Contaminant
Levels (HCLa)
(mq/liter)
State
HCLs
(mq/li ter)
Oraanics
Chloroform 0.100
1,2-Dichlorobenzene
1,1-Dichloroethane
1,1-Dichloroethene 0.007 0.006
1,2-Dichloroethene
Freon-l13
Phenol
Tetrachloroethene
1, 1, 1-Trichloroethane 0.200 0.200
Trichloroet.hene 0.005 0.005
Vinyl Chloride 0.002 0.0005
Inoraanics
Antimony
Cadmium 0.010 0.010
Arsenic 0.050 0.050
Lead 0.050 0.050
-------
-----~--~"--
ACl'I08 .nCDIC UAJt8
Groundwater extraction and treatment involves pumping, treating,
and discharging the treated groundwater and/or reinjecting it
into tbe aquiter.soil r_ediation can include excavation and/or
in-.itu treatment. With groundwater treatment andin-.itu vapor
extraction, Volatile Organic.Chemical. (VOCs) would be removed by
air .tripping and/or Granular Activated Carbon (GAC) adsorption.
Air .tripping requires consideration ot ARARs tor VOC ..issions,
GAC.- u.e requires consideration ot ARARs' a.sociated with carbon
rageneration or disposal, and discharge-or reinjection .ust meet
.pecitic ARARs. .
Discharge to Surface Water
Substantive National Pollutant Discharge Elimination System
(NPDES) permit requirements would apply to treated ettluent
discharging to surtace waters. These would primarily be ettluent
limitations and monitoring requirements. The RWQCB regulates
NPDES discharges. Ambient Water Quality Criteria are u.ed by the
State ot Calitornia to .et Water Quality Standards in the San
Francisco Bay Regional Basin Plan. Standards in the Basin Plan
are used by the RWQCB to set NPDES ettluent discharge
limitations.
Section 402 ot the Clean Water Act, as amended in 1987, will
result in the prohibition ot discharge ot non-s1:orm waters to the
City otMountain View storm sewer .yst.. by 1991. .
Rein;ection of Treated Effluent Into Aquifers
I
t.
i'
It treated groundwater is reinjected, regulations governing
underground injection m.y apply. Specitically, the Federal Safe
Drinking Water Act requires an Underground Injection Control.
(UIC) program. In California, the UIC program is administered by
U.S. EPA. The UIC program prohibits treated ettluent trom being
injected, into or above a .ource of drinking water. Except when
it is pursuant to a CERCLA cleanup UIC regulations do not
requlate the concentration of constituents, rather they regulate
only the .ethod and location ot the injection. The.e Pederal
requirement. regarding injection ..y be-relevant and
appropriate- to the .ite.
Pederal RCRA requir..ents and the State'. Toxic Injection Well
Control Act ot 1985 (C8l. Health , Satety Code Section 25159.10
. ~~) .igbt a180 be -relevant and appropriate- to the
reinjection ottreated groundwater.
16
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~scharqe ~ Sani~ary Sewers
Discharge of treated qroundwater to the local .anitary .ewer
system requires compliance with the City'. ot Mountain View's
Industrial Waste Ordinance and the Clean Water Act Pretreatment
Standards. The City'. Ordinance .ets torth effluent quantity ana
discharqe concentration limits, alonq with standards for
monitoring and reporting. Substantive requirements are 8legaliy
applicable- tor on-.ite discharges ot the treated water. The
Clean Water Act allows .unicipalitie. to determine pretreatment
standards for discbarges to Publicly owned Treatment Works
(POTWs), within its jurisdiction.
Air striDDinq - Air Emission standards
Any new source that emits toxic cbemicals to the atmospbere at
levels determined by the San Francisco Bay Area Air Quality
Management District (BAAQMD) -to be appropriate tor review" must.
bave authorization to construct and operate. Although on-site
treatment tacilities are exempted by CERCLA trom the
administrative requirements ot the permit, emission limits ana
monitoring requirements imposed by the BAAQMD permit must be met.
Carbon Adsorption
Use ot granular activated carbon (CAC) tor remediation ot VOCs
can trigger requirements associated with regeneration or disposal
ot the spent carbon. If the spent carbon is a listed waste or a
characteristic waste' then it is regulated as a hazardous waste
under RCRA and California'. hazardous waste control laws.
Disposal ot contaminants can trigger RCRA land disposal
restrictions. For disposal, the spent carbon would need to be
treated to meet Best Demonstrated Available Technology (BDAT)
treatment standards, and RCRA otf-site Subtitle C disposal
restrictions would also apply. .
Regeneration of activated carbon, usinq a high-temperature
thermal process, i8 considered -recycling- under both raderal and
California hazardous waste regulations. Transportation, .torage,
and generation ot hazardou8 wasta tor recycling .ust comply with
requirem.nta in RCRA and Calitornia hazardous waste control
regulationa. Pertormance standards tor hazardous waste
incinerator8 can also be requirements tor on-site carbon
reactivation. On-site atoraqe ot contaminated carbon ..y trigger
substantive requirements under municipal or county hazardous
..terials ordinances. It the 'spent carbon is a hazardous waste,
construction and .onitoring requirements tor storage tacilities
..ya180 apply.
17
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Excavation. Above-Ground Treatment and Disposal of Soil
Excavated contaminated soils will require on-site treatment or
disposal off-site. On-site treatment by above-ground soil
aeration, will need to comply with the substantive provisions of
the BAAQMD and possibly RCRA land disposal restrictions.
Excavated soil classified as a- hazardous waste can also trigger
RCRA, state and local requirements. EPA land disposal
restrictions may be applicable for off-site disposal. RCRA
Subtitle C may apply to disposal of soils on-site.
For the on-site treatment of soils, the BAAQMD regulates aeration
of soil containing over 50 ppb of organics. The BAAQMD sets rates
at which soil can be aerated depending upon the level of
chemicals. BAAQMD Regulation 8, Rule 40 on the treatment of soil,
assuming it is a hazardous waste, may also trigger RCRA land
disposal restrictions and BDAT treatment requirements.
LOCATION SPECIFIC ARARs
Fault Zone
The MEW sites are not located within 61 meters (200 feet) of a
fault. Therefore, the fault zone requirement of 40 CFR Part 264
is satisfied.
Eloodp la in
A hazardous waste treatment facility located in a 100-year
floodplain must be designed, constructed, operated, and
maintained to prevent washout of any hazardous waste by a 100-
year flood. The MEW site is not located in a floodplain,
therefore these requirements are neither applicable or relevant
and appropriate.
11.0 OTHER CRITERIA CONSIDERED
In establishing selected remedial alternatives, EPA considers
various procedures, criteria and resolutions. These "to be
considered" criteria (TBCs) do not raise to the level of ARARs,
but are relevant to the cleanup of the site. The following
discussion presents selected criteria relevant to the selection
of remedial alternations.
18
-------
~teria 2.tablishinq Local Groundwater as a Source of Drinkina
Water
Various cri~eria were used to establish that the shallow, C, and
Deep aquiters are a source ot drinking vater. EPA'. qroundwater
classitication system vas used. Using the "EPA Guidelines for
Ground-Water Classification" .as a quide, EPA determined that the
A- and a-aquifers in the MEW area are classified as "potential
drinkinq water sources". CUrrently, the C-aquifer'and Deep
aquifers are used for drinkinq water and therefore would be
classitied as a current drinkinqwater source. As stated in the
, ARARs section, the Reqional Water Quality Control Board
classitied the shallow groundwater as "potentially suitable for
municipal or domestic water supply". The RWQCB determined that
this. classification is consistent vith the state Water Resource
Control Board's Resolution No. 88-63, which describes criteria
tor designating sources ot drinkinq water.
State Criteria for Groundwater Cleanua
Calitornia has criteria for evaluating drinkinq water quality and
groundwate'r cleanup: advisory Drinking Water Action Levels, and
advisory Applied Action Levels.
Drinking Water Action Levels are health-based concentration
limits set by DBS to limit public exposure to substances not yet,
regulated by promulgated standards. They are advisory standards'
that would apply at the tap tor public water supplies, and do not
rise to the level ot ARARs. Nonetheless, they have been
considered in developinq cleanup standards for the MEW site.
Applied Action Levels' (AALs) were developed by DHS tor us. with
the California site Mitigation Decision Tree. AALs are quidelines
that DHS uses to evaluate the risk a site poses to certain
bioloqic receptors. They are neither entorceable, nor ARARs, but
have been considered in developinq cleanup standards for the MEW
site.
Groundwater criteria, to be considered for determining cleanup
levels, are pre.ented in Table 11-1.
California ".olution 68-16
Resolution 18-16 is california's "Statement ot Policy With
Respect to Kain~aininq High Quality ot Water. in Calitornia". EPA
regards Resolution 68-16 as criteria to establish qroundwater
cleanup levels. The policy require. maintenance of existing water
quality unless it is demonstrated that a change will benefit the
'people ot the state, will not unreasonably affect beneticial uses
of the water, and vill not re.ult in water quality le.. than
prescribed by other state policies.
19
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TABLE 11-1
GROUNDWATER CRITERIA TO BE CONSIDERED
MIDDLEFIELD/ELLIS/WHISMAN STUDY AREA
Chemical
State
DrinJcing Water
Action Levels
(ag/liter)
State
Applied
Action Levels"
(mg/liter)
Qraanics
Chloroform
1,2-Dichlorobenzene
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene
Freon-113
Phenol
Tetrachloroethene
1,1,1-Trichloroethane
Tri chloroethene
Vinyl Chloride
Inorganics
Antimony
Cadmium
Arsenic
Lead
0.020
0.130
0.020
0.016
18.000
0.004
0.006
a/ Applied Action Level for water for human receptors,
-------
A beneficial use of the groundwater in the shallow and deep
aquifer system is drinking water. Establishing a cleanup level
which maintains this beneficial use should attain the
requirements of Resolution 68-16. .
Remediation Levels for Soils
A standard for the remediatiqn of contaminated soils was reached
during the Feasibility Study by using a simple percolation-
transport model with the concepts presented in California's Site
Mitigation Decision Tree. The model was used to determine
concentrations in soil based upon transport downward into
~roundwater. Based upon the analysis from the model, a soil
remediation goal of 100 times the groundwater remediation level
.is appropriate to set cleanup standards in soil.
Health Advisories
EPA considers that for a remedial action of a drinking water
source to be protective, it" should have a cumulative risk that
falls within a range of 10.4 to 10'7 individual lifetime excess
cancer risk. To evaluate the risk to public health posed by
recommended cleanup goals, health advisories were used to
establish cumulative risk. Lifetime average daily doses (LADD)
were calculated by multiplying a concentration by 2 liters per
day and dividing by 70 kilograms. Cancer risk for a constituent
of a given concentration was determined by mUltiplying the LADD
by its Cancer Potency Factor (CPF).Ratios of contaminants in
aquifers of the site were then calculated in relation to TCE. A
summation of risk for carcinogens in each aquifer were calculated
for a given concentration of TCE. For a 5 ppb (MCL) cleanup goal
for TCE in the A-, B1-, and B2- aquifers the cumulative estimated
carcinogenic risk falls within a range of 1. 3 (10) -5 to 7.4 (10) -5.
In the C- and Deep aquifers the cleanup goal of 0.8 ppb
corresponds to a cumulative estimated carcinogenic risk of .
1.0(10)-6. Supporting calculations are presented in the
Feasibility Study.
Cleanup goals in the shallow aquifers, above the B/C aquitard,
are set at 5 ppb for TCE. Cleanup goals in the C and Deep
aquifers, below the B/Caquitard, are set at 0.8 ppb for TCE.
Assuming th. ratios of carcinogen remain relatively constant,
attainment of these goals will result in achieving EPA's
acceptable risk range of 10.4 to 10-7 upon completion of the
remedial action.
Air Strippina Control Policies
Any existing and new source(s) that emit toxic chemicals will
have to comply with any EPA, BAAQHD, or Air Resources Board
policies on control of air emissions from air-strippers.
20
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12.0 SUMMARY OP ALTERNATIVES ANALYSIS
Thi. .ection pre.ents an analyses ot the alternative., evaluated
in the detailed analysis ot remedial alternatives, vith respect
EPA'. evaluation criteria. Desiqn elements ot the alternatives
are pre.ented in section 9.0~ Table 12-1 provides a .U88ary ot
the advantages and disadvantages ot each alternative'.
pertormance and cost.
State and community acceptance are discus.ed below:
State
Acceptance
The State (of california) generally.supports EPA's proposed
cleanup plan. The state commented, however, that the cleanup
goals tor soils and groundwater inside the boundary ot the
existing slurry walls should be 0.5 ppm TCE tor soil and 5 ppb
TCE tor the groundwater: the same goals as tor outside otthe
slurry valls.
In the Responsiveness Summary, EPA stated that the .lurry valls
in conjunction vith pumping and monitoring will be protective of
the public health and the environment, vith the 1 ppm TCE cleanup
goal tor soils bounded by the slurry walls. This monitoring and
pumping strategy will limit the amount ot contamination that can
leach into the shallow aquiters, outside ot the slurry valls. EPA
did respond to the state's request ot a 5 ppb TCE cleanup goal
tor all shallow aquiters,by establishinq the 5 ppb TCE cleanup
goal tor the aquifers inside of the slurry valls.
Communitv AcceDtance
The community aqrees with EPA's proposed remedial alternatives,
although there is concern vith the lenqth ot time estimated to
achieve the shallow aquiter cleanup goals. The use ot the "hazard
index" was urged to establish cleanup goals instead ot MCLs. EPA
explained in the Responsiveness Summary that the hazard index was
not applicaDle to the MEW area.
In addition, reu.e ot the extracted groundwater was recommended
by the co..unity. As stated in the Responsiveness Summary, reuse
ot extracted groundwater will be evaluated and is a component of
the ROD.
The ResPOnsiven.ss Summary (attached) addre..es ~.s. concerns
and other. in 80re detail.
21
-------
~. 12-1
Crlt.'. for Ihe Evalu.lton 0' Ramed'al AU.naUv.
(continued)
LOMG. II" MIDI" -- PUSlI'
U*' . I (lut 'ROIIU ,. Of (AlIIAl 0 a.. "'IN
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,"
-------
Table 12-1
Criteria 'or the EvaluaUon 0' Ramadlal AlternaUvea
(unl'nued'
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-------
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. 12-1
Criteria 'or the Evalua8lon 0' Hemedlal Alt.na8lv..
.contlnued)
LOIIi.'I( All
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'abl. 12-1
Crll.la '01 Ihe EvaluaUon 0'. Remedial AII.nallv81
Icontlnu.eI,
tONG. II" ."L -- III U.'
L IllIG - 11111 'RoIU...* ar tAPIIAL 0 . II IIDI'H
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1
Note: Section 121(b) of CERCLA states 8 prefe,ence 10, treatment which permanently and
significantly ,ecb:es the vokJme, toxicity or mobility 01 the conlarDnants. The use of vertical
Impermeabte barriers (I.e., skJrry waDs) by lhemselvesls containment and source control, and
does 001 conslltule Irealment. Onty with the addillon of groundNaler extraction and trealment
does Ihls a"emallve meel slatulory crilerta. WhUe Ihis evakJallon dlUers son1ewhallrom lhe
evalualion lound In Ihe FS, It does 001 all eel EPA's remedy seleellon. .
-------
AL ullMAun
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» 12-1
Criteria tor the EvaluaUon ot Remedla' AlternaUv..
LONG- 11l1li
(ff(( 11'11(55
AND '1IUWtUI((
llDUtIS 1011(11'.
IlOl1 LI ". 'OlUltl-
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-------
13.0 TIm DL2C'l'ED REMEDIES
The selected remedies for soils are: 1) in-situ vapor extraction
vith treataent by vapor phase qranular activated carbon (CAC),
and 2) excavation and treatment by' aeration to .eet federal,
state, and local air standards. Moat of the vapor extraction will
be performed on soils inside of the existinq Fairchild and
Raytheon slurry valls, vhere the hiqhest concentrations of soil
contamination are found. The vapor extraction is e.timated to be
in operation from 1 to 6 years. The excavation and treatment of
contaminated .oils .ay invoke RCRA Landban requirements vhich
vould also require treatment to .eet BCAT .tandards. Intel has
previously excavated and aerated their contaminated soil under
RWQCB orders. These selected remedial alternatives viII likely be
used at other potential sources in the MEW area. EPA expects soil
remediation to be implemented by the PRPso .
The soil cleanup qoals for the MEW area are: 0.5 parts per
million (ppm) TCE for all soils outside ot the slurry valls and 1
ppm TCE for soils inside the slurry vallso The cleanup qoal for
soils outside of the slurry valls is based upon the amount of
contamination that can remain in the soil, leach into the
qroundwater and still achieve the cleanup qoal for the shallow
aquifers. The rationale for the use of a hiqher cleanup qoal for
soils bounded by the slurry valls is presented in the following
discussion. Although the aqUifers bounded by the slurry valls are
considered potential drinking vater .ources, this groundwater is
effectively isolated when local hydraulic control is implemented
by pumping inside the confines of the .lurry valls. This
isolation of contaminated groundwater and soil bounded by the
slurry walls provides an additional level of protection of the
significantly larqer drinking vater source outside of the slurry
valls. This additional level of protection through the use of a
slurry .all system (slurry wall and hydraulic control) allows for
a higher .oil cleanup goal for soils confined by the .lurry
valls. But, the use of the 1 ppm TCE cleanup level for these
soils is dependent upon the.continued operation of a pumping
.ystem which maintains local hydraulic control of groundwater
inside the 8lurry vall.. If local hydraulic control by pumping
vas to caa.., then the lower .011 cleanup goal of o.! ppm TCE
vould need ~ be attained. In summary, the .oil cleanup goal is
higher 1ft8id. of the .lurry valls becau.. of the extra degree of
protectivene.. provided by the .lurry wall. in conjunction vith
the maintenance of inward and '-pward qradients into the area
confined by the .lurry valls, v1th a .yst.. of hydraulic control
by pumpinq of qroundwater. To ensure that the .lurry vall system
is effectively vorkinq, regular .onitoring vill be performed of
local groundwater quality and water elevations. During the
22
-------
duration ot the. re.edy, there will be an evaluation ot the remedy
and cleanup 908ls at least every tive years.
The selected groundwater remedy is hydraulic remediation by
groundwater extraction and treatment. The qroundwater cleanup
goals by pu.ping and treatment are: 5 ppb TCE for the shallow
aquifers (including the aquifers inside the slurry walls) and 0.8
ppb TeE for the C and C.ep aquifers. The cleanup goal is aore
stringent for the C and C.ep aquifers, because they are currently
used as a supply for .unicipal drinking water and will.be
technically easier to remediate than the shallow aquiters. The
0.8 ppb cleanup goal corresponds to a 10.6 cumulative (human)
cancer risk.. .
Although the shallow aquifers are not currently used for drinking
water, they are a potential source for drinking water and .
therefore a 5 ppb TCE clean~ 90al has been established which
correspondS to between a 10. and 10.5 excess cancer risk, which
is within EPA's .cceptable risk ranqe. Cancer risks have been
screened tor all aquifers and the chemical ratio of TCE to other
chemicals found at the site is such.that achieving the cleanup
goal for TCEwill result in cleanup ot the other site chemicals
to at least their respective MCLa.
The estimated time to reach the deep aquifer cleanup goal is
between 2 to 45 years. The time to reach the shallow aquifer
cleanup qoal .ay be considerably longer, possibly from 46 years
or into the indefinite future, because of the physical and
chemical nature of the shallow aquifers. They are low yielding
and contain soils with a hiqh clay. content which attract and
retain the site chemicals. Durinq the duration of the remedial.
effort, both shallow and deep aquifers will be regularly
monitored for water quality and groundwater elevations.
The extracted groundwater will be treatedlarqely by air.
strippers, although some companies (e.g., Intel) ..y use their
existing liquid phase CAC units. The three currently operating
air strippers have been permitted by the Bay Area Air Quality.
Management District and are not using. emissions controls. The air
stripper stacks have been desiqned to..eet risk levels of <10.6
excess cancers. We anticipate that with the additional air
strippers to be installed and the increased tlow rat.s during
full seal. reaediation, emissions controls will likely be needed
to meet 80re stringent ai~ district standards. The emi.sions
. controls v111 consist of GAC vapor phas. carbon units.
Th. extracted groundwater vill be reused to the 1IaxiJlum extent
. ~Zeasible, with 100' reus. as a goal. The remaining extracted
groundwater vill be discharged under NPDES requir..ents to
Stevens Creek. Work has already commenced on various vater reuse
Options, vhich vill be presented and Uiple.ented durinq the RD/RA
phase.
23
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The remedy also includes the identification and sealing of any
conduits or potential conduits, using the decision process
outlined in the FS. Several identified abandoned agriculture
wells have allowed contamination to migrate from the shallow
aquifers to the deep aquifers. These wells have subsequently been
sealed. Additional wells have been identified for sealing and
other wells may also be identified during RD/RA phase which will
require sealing. .
To evaluate the effectiveness of remedial actions and to
determine when cleanup goals are attained, regular monitoring of
chemical concentrations and water elevations is required at .
selected wells across the site. For soil cleanup, EPA will need
to concur on a method to determine when the required cl~anup
goals have been achieved.
The estimated costs of the selected remedies are provided in
Table 12-1 and include the use of emissions controls, well
sealing, and monitoring. The total cost of the remedies, in
present worth dollars, is estimated to be between $49M to $S6M.
14.0 STATUTORY DETERMINATIONS
The selected remedies are protective of human health and the
environment -- as required by Section 121 of CERCLA -- in that
contamination in groundwater is treated to at least MCLs and
falls wi thin EPA' s acceptable risk range of 10.4 to 10.1. In
addition, the remedy at least attains the requirements of all
ARARs,. including Federal and State MCLs.
Furthermore, as shown on Table 12-1, the groundwater remedy -
pumping, and treating with air strippers and the soil remedy -
vapor extraction, are oost effective technologies. Soil
excavation with aeration has also been shown to be cost effective
when it was used at the Intel facility, and may also be used at
other facilities.
The selected remedies will permanently and significantly reduce
the toxicity, mobility, and volume of hazardous substances with
respect to their.presence in soils and groundwater. The use of
vapor extraction for soils is an innovative treatment technology
for removing VOCs. .
Contamination is controlled and removed from the groundwater,
thereby reducing the potential threat to the nearby public water
supply wells and also restoring the aquifers to meet drinking
water standards. The slurry walls in conjunction with pumping and
treatment reduces toxicity, volume and mobility of contamination
to migrate from major source areas. The sealing of conduit wells
24
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will reduce the' likelihood of vertical migration of
contamination. .
Emissions trom soil vapor extraction will be controlled by vapor
phase GAC. Emissions from air stripping towers will meet local
air district requirements, which are anticipated to be a 10.6
risk level, and therefore will likely require vapor phase GAC.
The regeneration of spent carbon from the GAC emission controls
will meet all Federal, State, and local requirements.
25
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, .
i
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A'ftACBKBJl'T8 . --
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IUISPOBSIVDrBSS SOIOQRY
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RESPONSIVENESS St1KKARY.FOR mE FAIRCHILD, INTEL, AND RAYTHEON SITES
MIDDLIFIELD-ELLIS-WHISMAN (K-E-W) STUDY AREA
Mountain View, California
1.
COMMUNITY RELATIONS HIS~ORY
EPA ha. carried on an active community relations program at the Kiddlefield-
Ellis-Whisman (HEW) Study Area.
In early 1986, EPA, in conjunction with. Santa Clara County, initiated monthly
_e,tings for all agencies involved in hazardous waste inve.tigation and cleanup
to review and coordinate activitie.. Repre.entative. of local, state and federal
agencies, elected officials, business and industry and public interest groups
attend the meetings. The meetings continue on-a quarterly basis.
In the spring of 1986, new contamination was found in Kountain View's deep
aquifer This discovery marked the first time contamination had been detected at
those depths in that part of Santa Clara County. In response to community
concerns and questions about the safety of the drinking water supply, EPA
prepared a fact sheet describing the situation and distributed it to the site
mailing list.
In Kay 1986,
page insert for'
construct three.
and to pUlllp and
EPA worked with Fairchild Semiconductor Corp. to prepared a 4-
KountainView's The View to explain Fairchild's proposal to
slurry walls in order to confine their site's contaminated soils
treat water confined by the walls.
In February 1987, Raytheon and EPA worked together to prepare another insert
for The View that described Raytheon's proposed slurry wall to contain
contamination around their site. .
In June 1987, EPA worked with Raytheon, Intel and Fairchild to produce an
insert for The View describing the draft Remedial Investigation (RI) report.
In November 1988, EPA released a Feasibility Study (FS) on the Kiddlefield-
Ellis-Whisman Study Are to the public. The report described and evaluated
various clean-up alternatives based on data and support documents available at
the time. EPA's preferred alternatives were: vapor extraction and treatment for
soils, pUlllping and treating for shallow and deep aquifers; and vapor extraction,
groundwater control and treatment for the slurry wall systems.
In fulfill8enc of c08mUnity participation require.ents, EPA held a public
comment period froa November 21, 1988, through January 23, 1989; briefings of
local official. and c08mUnity ..mbers; and a community meeting. EPA also
prepared a Propo.ed Plan fact sheet which outlined the range of cleanup
alternatives, cleanup goals, and EPA's preferred alternative for distribution to
the 8itemailinglist.Prior to the fact aheet, EPA a1so released a press
advisory announcing the range of alternatives and EPA's preferred alternative.
1
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The co.-unity ..eting vas held December 14, 1988, to pre.ent clean.up
alternatives, to 8ft8Ver questions and to take C08ments on the FS. Comments
centered on the 18Dgth of the cleanup period and on .vho would do the cleanup.
Written co..-nts on EPA's Proposed Plan focussed on the folloving issues:
cleanup level. for soil and groundwater, length of public comment period,
variations in the text of the FS report, and length of cleanup .t18e. Responses
to public comments are addressed in the attached response summary. Kost of the
c~mments vere submitted by Potentially Responsible Parties.
II.
SUMMAllY OF PUBLIC COMKEN'l'S. AND AGENCY RESPONSES
Technical Comments
1. Comment: Several comments concerned the number and location of recovery
wells to be placed in the HEW area.
EPA ResDonse:. The Feasibilicy Study (FS) and Pr9posed Plan are not design
documents. The exact number and location of recovery wells will be determined
duting the remedial design phase.
2. Comment: NASA.Ames Research Center. had several concerns: 1. how the
proposed treaCDent system would handle groundwater contaminated with fuel, 2.
how other cleanup actions may be influenced by the proposed. recovery wells, 3.
the effects that the proposed hydraulic remediation may have on existing
contamination at NASA.Ames and the adjacent Koffett.Naval Air Station.
EPA ReSDonse: The above concerns
Remedial Action (RD/RA) phases.
coordination will be required by
successful remediation program.
will be addressed .during the Remedial design and
Obviously, a large degree of cooperation and
the affected partie. during RD/RA, to ensure a
3. Comment: -The FS proposes to remediate soils using in situ soil aeration.
Air inlet wells may also be installed to increase the efficiency of the soil
aeration system. It is suggested that if air inlet veIls are to be installed they
should be used to control the extent of an in situ negative soil air pressure
field, not to increase soil air flow through the contaminated 80ils. If they are
installed solely for the purpose of increasing airflow across the contaminated
soil particles, their use is questionable.-
EPA ReSDonse: VOC's have a marked tendency to partition into the soil
acmo.phere. The rat. of desorption into pore .pace is principally a function of
chemical diffuaion in response to a concentration gradient. Sweeping of clean air
through a soil ..trix increases the concentration gradient and therefore
increases partitioning and the overall efficiency of the in situ soil aeration
syste.. The result of creating a negative air pressure field, vith an in situ air
stripping syste., does hav~ a .inor effect on soil.air partitioning, but the
field tends to be localized around the extraction vell(s) and the overall effect
is negligible. The key to an efficient in situ vapor extraction system is
increasing the airflow across contaminated soil particles and not s1aply to
2
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control the negative soil air pressure field. The use of air inlet veIls will be
analyzed further during the RD/RA phases of this project.
Comments On !PA'. Process
1. Comment: S8v8ral commenters who are Potentially Respon.ible Parties (PRPs)
stated that the C088ent period va. too short to adequately reviev the FS and
Remedial Investigation (RI) report. aequests vere ..de to extend the comment
period. .
EPA Re.~onse: The National Contingency Plan (NCP) requires that the RI, FS and
Proposed Plan be provided to the public for review and comment for a period of at
least 21 calendar days. The nev proposed NCP requires a minimum 30 calendar day
public comment period.
EPA has
cOllllllent
(at the
January
exceeded both of' these requirements by providing a 64 calendar day public
period on the RI, FS and Proposed Plan. The comment period vas extended
December 14, 1988 public hearing) to January 23, 1989, from the original
9, 1989 deadline.
2. Comment: Several PRPs stated that the RI report and FS were not readily
available for review.
EPA Res~onse: A draft RI repor~ has been available to the general public ae EPA
slnce July 1987 and also in the City of Kountain Viev public library since
August, 1987. The final RI report has been available at these respective
locations since July, 1988. Furtherm~re, EPA in its general notice letters
issued in August and September, 1988, notified the commenters and others of the
availability of an administrative record that contained supporting documentation
for the MEW study area. The FS vas sade available to the public in the EPA and
Kouneain Viev libraries at the beginning of the comment period November 21, :'988.
In addition, copies of the FS vere also available for purchase from Canonie
Engineers, the preparers of the FS.
3. Comment: Several PRPs claimed thae there vere 8 inconsistences 8 .becween FS
reports on reserve at the Kountain View Public Library, the FS report at the EPA
library, and copies provided by Canonie Engineers.
EPA Res~onse: EPA acknovledges these concerns, however, we believe any
differences to be minor in nature and vould not affect the -scope of the FS
report. Copies of the FS report vere readily available for review at the EPA
library during the entire public comaent period.
4. Comment: One commenter wrote tha~ EPA announcements regarding the review and
comment period and public meetings needed to be more widely distributed.
EPA Res~onse: AnnoUncements regarding the MEW public co..ent period and the
public meeting vere published in .The View., .The Lo. Alto. Town Crier., .The
Times Tribune8, .~~ the .San J08e Mercury News. (Penin.ula Extra Edition). In
addition, EPA's Proposed Plan, which also announced the public comment period and
public meeting, was sent to EPA'. MEW ..iling list that consists of over 100
3
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names. Ve vill al.o be periodically updaeing our ..iling li.eand will coneace
local officia18 and co-.mity group. for a..1aeance in updaeing that lise.
5. COlment: A -..ber of COllllenters cla1.lled thee they vere not PUs. SOlie of
these commencer. al.o cited reference. to other PIP. or inferred .ources, in the
ItI report.
EPA lesnonse: The determination of who is or who 18 noe a PIP 18 not relevant to
the .election of. a remedy. Furthermore, in it. August 8, 1988 approval of the RI
report, .EPA neither agrees nor di.agree. vith the a.sU8ptions or a..ertions
regarding 'inferred sources or other PIPs' .. presented in the II report.. EPA
..kes its own determination of liability independent of the RI/FS process.
6. Comment: Several cOllllenters who are PIPs vanted to know how other PUs will
be dealt with, how cleanup costs vill be allocated, and who i. responsible for
cleanup.
EPA lesnonse: EPA is currently evaluating PUs .to determine who will receive
Special Notice letters for lemedial Design and Remedial Action (RDfRA) to 17
parties. The responsibility for cleanup lies with whomever EPA determines to be
a PRP. The allocation of cleanup costs are usually decided ..ong the PUs.
7. Comment: Two PIPs wrote that remediaeion of the C and deep aquifers should
be addressed as a separaee operable unie. The reasons given were ehae the C and
deep aquifer coneaminaeion is lillited to localized areas, the contamination was
not caused by the respective cOllllenters, and, operaeion and maineenance cost will
be increased.
EPA lesnonse:' EPA does not designate operable units Co separaee cose allocations
among various PUs. The co~eneers have offered no compelling eechnical or
environmental reasons why ehere should be a separate operable unit for the C and
deep aquifer remediation. EPA believes thae including the deep aquifers in the
comprehensive remedial plan for the eneire MEW Study Area is the mose efficient
use of agency and PRP resources. Fur~hermore, 40 CFR Seceion 300.6 simply
defines an operable unit, .as a discrete par~ of the entire response aceion that
decreases a release, threat of release, or pathway of exposure.-
The Followini Selected Comments Concemin, EPA's
Process Vere
Submitted by Siltec
L Comment: Page 1. Slltec claims that.a copy of the final RI was not made
available to the. until January 13, 1989. Siltec has noe had a reasonable
opportunity to review or cOllllent on all of RI's contents.
EPA lesnonse: A draft RI has been in the Kouneain View public library since July
1987. The final aI vas delivered in July, 1988, to EPA and the Kountain View
Public Library. Siltec has had ample ti.e to review the RI since EPA stated at
the October 1988 .kickoff. meeting attended by Siltec representati~e~,~ that the
final RI was available for review in the EPA and Kountain View libraries.
"',
Siltec seems to be arguing that EPA should have had a separate public notice for
the RI, citing U.S. v. SeYmour Recyclin2 COrD. 679 F. Supp.859 at 864. If that
4
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is Siltec's contention, EPA disagree.. EPA notes that a separate ~I review
process i. .i8ply not conteaplated by CERCLA nor u.s. v. Seymour Recyclin, Cor~.
679 F. Supp 859 (S.D.Ind. 1987). In that ca.e, the court note. th~C, pursuant to
CERCLA a. ...Dd8d by SARA, the generator defendant. are entitled to comaent on
the selection of a r...dy before the r888dy i. .elected. In u.s. v. Seymour
iecvclin, COrD., .. bere, EPA provided the generator defendants an opportunity to
comment on the r...dy before a selection of the remedy ha. been ..de.
EPA also notes ~at Siltec was given notice that it vas a potential responsible
party in the MEW area in Kay, 1985 and va. given an opportunity to participate in
the RI/FS process. Thus, Slltec vas on notice that the RI/FS vas being prepared,
and therefore, Siltec should have been tracking the progress of the RI/FS.
2. Comment: Pages 3-4. Slltec has been unable to comment on the FS becaUse of
substantial uncertainty about the accuracy and validity of the FS distributed for
pub lic comment-. .
EPA Res~onse: EPA disagrees vith the statement that 8there is substantial
uncertainty about the accuracy and validity of the FS distributed for public
comment. 8 As stated above, the FS vas available to the public in the EPA and
Kountain View libraries at the beginning of the comment period, November 21,
1988. In addition, copies of the FS were 81so available for purchase from
Canonie Engineers. Any inconsistency becween the copies was minor in nature.
3. Comment: Siltec stated that8[T]he oppor~ity for meaningful comment is
compromised where complete copies of relevant agency documents have not been made
available in a timely fashion8 citing the case of u.S. v. ROM and Haas Co. Inc.
669 F. Supp. 672, 683.
EPA Res~onse: The facts of U.s. v. Rohn and Haas Co~anv. Inc. are very
different than here. In particular, the public vas given 5 days to submit
comments in U.s. v. Rohm and Haas Co~anv. Inc. Here the public, including
Siltec, was given 64 days to submit comments.
4. Comment: Siltec recommends that cleanup of the C aquifer (the areas below
the B-C aquitard) should be addressed as a separable operable unit as the term is
defined at 40 CFR Section 300.6 and as permitted by 40 CFR Section 300.68(c).
EPA Res~onse: 40 CFR Section 300.6 simply defines an operable unit as 8a
discrete part of the entire response action that decreases a release, threat of
release, or pathway of exposure.8 EPA fails to see the benefit of addressing the
C aquifer as a separate operable unit solely for cost allocation purposes.
The Followin, Selected Comments Concemini EPA's
Products
Proee55
Were Submitted bv Air
1. Comment: 8ErA does not have the power to create or affect liability of
persons at a 'Superfund site' simply by drawing the 'site boundary' at one
locationversus another.8 .
5
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EPA Resoonse: The FS does noc addre.. che Uabiliey of persons aC che MEW site.
EPA nOCe. thac liabiliey 1. determined by CERCLA Section 107, not the drawing of
.iCe boundarie.. .
2. Comment: .IrA lace. the authority under Section 104 to order Air Products to
require ce.ciftl..
EPA Resoonse:
the RI arid FS.
Orders requiring testing under Section 104 are noC addre.sed in
EPA note. Air Product's legal opinion.
Comments Conceminl the PronosedCleanuo Goals
1. Comment: The Regional Water Qualiey Control Board (RWQCB) commented that the
cleanup goal for the groundwater inside .the.slurry vall. should be set at 5 parts
per billion (ppb) .. the same goal seC for the groundwater outside of the slurry'
valls. The Board commented that EPA's groundwater cla..ificacion applies to all
aquifers including aquifers within slurry walls. .
EPA Resoonse: EPA's Proposed Plan recommended a 5 ppb cleanup goal for che
shallow aquifers. Although not specifically Icated, this 5 ppb goal would also
apply to the aquifers within the slurry walls. .
2. . Comment: The RW'QCB also commented thac che cleanup goal for soils within the
slurry walls should be set ac .5 parcs per million (ppm) .. the same level for
soils outside the slurry walls.. The Board was concerned abouc relying solely on
slurry walls to prevent migration of contaminacion 8because the long term
integrity of slurry walls has not been demonstrated.8
EPA Resnonse: In addition to pumping wichin the slurry walls (to a.sure an
inward gradient), there will be continuous monitoring of water levels and
chemical concencration inside and outside of the slurry walls. Performance
monitoring will be an integral part of any RD/RA Consent Decree. In the ev~nt of
a slurry wall failure, addit10nal measures can be taken such as, modification of
the walls and pumping rates, or applying more sCringent cleanup levels inside the
slurry walls. .'
3. Comment: The Santa Clara Valley Water District (SevwD) commented that they
would not prevent a well from Capping the shallow aquifers.
EPA Resoonse:
Comment acknowledged.
4. Comment: The SevwD is concerned that a cleanup goal has not been established
for the aquifers vithin the slurry walls.
EPA Resnonse:
See EPA response to comment no. 1.
5. Comment: The SCVVD co..ented that specific protocol should be developed for
reviewing and evaluac1ng.che performance of the selected remedy.
EPA Resoonse: The RD/RA process vill incorporace .pecific criteria for
evaluating the cleanup goals and. the effectiveness of the remedy. The cleanup
goals and remedy will be evaluated at least once everY 5 years.
6
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6. Comment: Th. SCWD reco..ended that a cleanup goal of 0.8 ppb a180 be
.stablished for db. shallow aquifers.
EPA Res~onse: A 5 ppb cleanup goal is protective of human health, ..pecially
since these aquif.rs are not currently used for drinking water. Th. 5 ppb level
also falls within £PA'. acceptable risk range of 10-4 to 10.7.
In addition, the cleanup goal say not even be technically feasible because the
aquifers are relatively .tight. (low water bearing zones) and have a high clay
content, thereby ..king che.ical removal difficult and costly.
7. .:omment: The League of YOllen Voters urged EPA to use a .hazard index" to
establish cleanup goals instead of the Maximum Contaminant Level (KCL) for TCE.
The League is concerned about the .lIixtures o~ chellicals" and their effects and
cited the IBM and Fairchild sites in San Jose where the hazard index was used.
EPA Res~onse: EPA believes that a 5 ppb TCE cleanup goal for the shallow
aquifers is protective of human health. See EPA response to the SCVWD.
The ratio of TCE to other chemicals (found at the site) i5 high enough that a 5
ppb cleanup of TCE will result in a cleanup of the other chemicals below their
corresponding MCLs. The 5 ppb cleanup goal takes into account the additive
effects of the chemicals found at the site, and the resulting risk falls within
EPA's acceptable range of 10.4 to 10.7.
The IBM and Fairchild San Jose sites have TCA as. the dominant chemical. Drinking
water wells have also been affected at the IBM and Fairchild sites in San Jose.
while no drinking water wells have been impacted at MEY.
8. Comment: One commenter wrote that Alternative Concentrations Limits (ACts)
would be appropriate .if no health risk occurs through exposure by contact or
through ingestion of the cont&llinated groundwater.. The commenter questioned
whether such exposures can be prevented.
EPA Res~onse: EPA is not proposing the use of ACLs at this time. The
applicability of ACts will be determined during subsequent review periods. once
the remedy has been implemented and periodically evaluated.
The Followin2 Selected Comments Concernin2 Cleanu~ Goals Yere Submitted Bv
Cros~y Heaflv. Roach and Mav. a Law Firm Re~resentini Sobrato Develo~.ent
1. Comment: Th. 5 ppb cleanup level for the shallow aquifers "is not necessary
to protect hU88D h.alth and safety., and the cleanup level .is unreasonably
burdensoll8 and cost inefficient. The firm also wrote that the shallow aquifers
.are not reasonably anticipated to becolI8 suppliers of drinking water in the near
or distant fucure., and that the enforcement of existing institutional controls
. can be used to protect human health. Therefore, less stringent standards should
be applied to the shallow aquifers naIIely 500 ppb.
. \(
7
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EPA Res~onse: It should first be noted that !PA has proposed cleanup loals
rather than cleanup levels. Thesa goals and the re..dies vill be evaluated
periodically to determine if they are technically practical, and therefore they
..y b. subject CO 8Odification.
EPA based it. propo.ed cleanup goals on several factors: 1. The shallow aquifers
are potential drinking vater sources even though they are not currently being
used for drinking. This determination i. also consistent with the aegional Water
Quality Control Board's lasin Plan and Non-Degradation Policy'which are designed
to protect naeural resources; 2. The 5 ppb goal ..ets !PA's acceptable risk
- range of 10-. to 10-7:. The 500 ppb cleanup level which the C018Hnter 18_-
proposing vould exceed this acceptable ri.k; 3. It i. unlikely that all of the
abandoned agriculture vella which are currently acting.. conduits or are -
potential conduits threatening the deep (current drinking vater) aquifers will
ever be located and properly .ealed. Experience ha. shown that abandoned wells
(e.g., Rezendes Wells) can cause significant cont..ination to .igrate from the
shallow aquifers to the deep aquifers. Therefore, absent .ealing all of the
abandoned wells, it becomes necessary to reduce the contamination in the shallow
aquifers. The 5 ppb level would then be the maximum level that could potentially
migrate to the deep aquifers.
2. Commene: 8The worst case scenario soil remediation application is
inappropriate.8 The commenter object:ed to unifom application of the worst-case
scenario to the entire ~ area. The commenter also .tated tnatfuture use
assumptions of the KEY site are inconsistent with the City of'Kountain View
General Plan and with California Health and Safety Code instieutional controls.
EPA Res~onse: Because multiple sources have impacted a common groundwater area
with commingled contaminant plumes (which threaten a current drinking water
,supply), EPA believes that a unifom application of a reasonable 8worst-case"
scenario and a unifom application of cleanup goals is the most efficient method
to assure the protection of public health. This is also consistent with the
approach taken at other sites in Santa Clara Valley and the country. Although
- the City of Kountain View's General plan ..y currently call for
industrial/commercial use of the site, General Plans and land use are subject to
change. The site is also presently bordered by residences west of Whisman and on
Koffett Naval Air Station, and a change in the electronics industry may make
residential use of the site plausible in the future. Other than deed
notifications, it is not clear to which institutional controls of the California
Health and Safety Code the commenter is referring.
Res~onse To Selected Comments From Sobrato
1. Comment: 8Th. KEW FS purports to apply a percolation rate of 2 inches/year
1n calculatina the allowable cont..1nation concentrations in the soil. Such a
percolation rat. i. considered extre.ely unlikely in properties, like SOIRATO's,
which have been covered and contained by asphalt. In addition, surface ~off at
the site is comprehensively routed to storm sewers and drains. Therefore, , "
percolation rates on the SOBRATO properties should be expected to approach nearly
zero.8 .
8
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'" ::
EPA ResDonse: Although field studies have not been conducted at the HEW site to
deteraine the 880unt of water infiltrating through the topsoil, the literature
describ.. exponentially decreasing infiltration rates following a rainstorm.
However, 80re vater ..y infiltrate to the aquifers in periods of long storms,
especially following extended dry perioda. .
The scenario of calculating 80il remediation level., by ..suming potential
r.sidential use rather than current industrial usage, i- EPA policy. This policy
has been consistently applied throughout other regions undersiailar
circumstances. The rationale 8upp~rting this policy i8 that surface coverings and
land use ..y change and, o~er the long term,. institutional control- ..y be
unreliable. The 2 inch/year percolation rate i. applied consistently throughout
the MEW area.
2. COllllllent: .Ve (Sobrato) would like to point out that if the rationale
the basis for the California Assessment Manual (Ca. Admin. Code Title 22,
Division 4, Chapter 30, Article 11) criteria i- applied to the subject
properties, the soil cleanup level would be, at a minimum, 5.0 mg/kg."
used as
EPA ReSDonse: The criteria presented in the cited California Administrative Code
defines a regulated hazardous waste and is not appropriate for determining a soil
cleanup level. "
The Followini Selected CQmments Were Submitted bv Heller. Ehrman.
McAuliffe. Attorneys for NEC Electronics, Inc
White &
1. Comment: The intended application of the "No Further Action" (monitoring
only) alternative is unclear, since it is discussed primarily for Zone 1 soils
located inside slurry walls.
EPA ReSDonse: EPA does not understand the comment, as we believe the application
of the "No Further Action" alternative is adequately explained for each of the
remedial alternatives in Chapter 8 of the FS. .
2. Comment: No estimates of the remediation periods for "Partial Excavation
with Ambient Temperature Aeration" (Alternative 3) and "Partial. EXcavation and
Ambient Temperature Aeracion with In Situ Soil Aeration" (Alternative 4) are
provided.
EPA Restlonse: The time frame for this alternative would be governed by the
factors identified in Appendices G and H of the FS, which state that the
remediation of excavated soils requires 48 hours of disking soils in six inch
lifts. The DU8ber of lifts required would depend upon the volume of soil to be
remediated. Tabl. 0-22 of Appendix 0 provides the volume of soils to"be
excavated andr...diated.
3. COllllllent: NEC Electronics requested the .latitude" to explore other "options"
in~l~~ing those remedial methods outlined in the FS, and other methods in order
to aChieve" the ROD cleanup goals for vadose zone soils.
9
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EPA Resnonse: EPA anticipate. that the MEW FS vill be applied a. appropriate to
other sites in the HEW area. The re..dy, in-situ vapor extraction, vas selected
based on a thorough evaluation of the alternative.. In addition, .oil excavation
and treac.ent by aeration va. also .elacted, ba.ed on prior i8ple.entation in
HEW. If new inforaation or alternative. are brought to the attention of the
agency in the fU~a, the EPA ..y conaider the..
4. Comment: It 1- highly unlikely that contaaination in the Rezendes Vells
could have co.. fro. NEC'. 501 Ellis Street facilities.
EPA aesnonse: The .pecific origina of the aazendes Vell.' contaaination is not
an i.sue in the Jalection of a re.edy, nor i. liability for the deep aquifers,
.inca Superfund liability i. strict, joint, and .everal.
5. Comment: Vben shallov groundwater is .ixed vith deep aquifer groundwater in
the same treaement sy~tem, there vill be a .deleterious effect on the vater so
treated. 8 This mixed groundwater vill have limited uses 8if .urface discharge is
rejected as an alternative after treaement..
EPA Res90nse: Vbile this appears to be mainly true for the A and Bl aquifers,
most of the B2 and B3 aquifers vould not require treaement for major ions and
coliform bacteria. See Table 1-6 (Volume I) of the Remedial Investigation
Report. Furthermore, the 8deleterious effects8 of mixing the deep and shallow
ground waters in a treaement system will ultimately be determined by the end use
of the vater. .
6. Comment: The effects of long term pumping of the shallow aquifers should be
carefully evaluated in light of recent experience with. a similar system at other
sites in the region. It is not clear if recharge rata. and aquifer yields have
been evaluated.
EPA Resnonse: Vbile it is not clear to which other sites 1n the region the
commenter is referring, aquifer yields and recharge rates will be thoroughly
evaluated during RD and before any full scale re.ediation beings. In addition,
vater levels, subsidence, etc. vill be carefully .onitored during RA.
7. Comment: There is no indication that scaling and biological grovth in the
air stripping columns have been considered in treacment facility design or in the
operation and maintenance costs (O&K) shown in the FS.
EPA Resnonse: The operation and maintanance cost estiaate. for the treatment
systems include packing replacement and acid feed syste. 88intenance, which are
intended to solve or prevent scaling and biological growth probleas. (Appendices
J and K).
8. Comment: 8There is no indication that the FS has considered the costs of
complete .replac...nt of treatment units in the annual O&K costs or the capital
costs for the facilities.8
EPA ReSDonse: The annual operation and aaintenance costs for each treatment
system includes replacement costs (e.g., $6,000 for blover repair or replacement,
10
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$11,500 for packing replacement, $14,000 to $22,000 for the acid feed system,
$1,000 for electrical controls, and $3,000 to $4,000 for the air stripper tower).
Resnense To Selected Comments From S1ltec
Comments on 5011 aemediation Levels
1. General Comment:
s011s throughout the
adequately supported
remediation level is
reasons.
The proposed soil remediation level of 0.5 ppm TCE for all
KEW site which, l1e outside the slurry walls 18 not
by the FS. We (Siltec) believe that a 0.5 ppm TCE 80il
incorrectly calculated and incorrectly expressed for several
2. Comment: The FS states that supporting justification and analysis for
selection of a soil remediation level is based on a .worst case. hypothetical
exposure scenario where the HEW site would be converted to an ~paved residencial
area characterized by open lawns and unsewered roof drains allowing maximum
infiltration and subsequent percolation (FS, Appendix Q, p. Q-10). We (Siltec)
believe the RI/FS errs in us1ng the worst case analysis to identify the 80il
remediation level. An appropriate analysis should consider other more probable
scenarios as the basis for selection of soil remedy for the KEW Study Area.
EPA ResDonse to Comments 1 and 2: The scenario of calcul~ting soil remediation
levels by assuming potential residential exposure is EPA policy. This policy
has been consistently applied throughout other regions under similar
circumstances. The rationale supporting this policy is that land use can change
and, over the long term, institutional controls (e.g., zoning and local planning)
may not be reliable. .
In addition, the modeling scenario in Appendix Q is certainly not an extreme
worst case. The following items are examples:
The model allows for instantaneous dilution with the groundwater aquifers
below the contaminated soil zone. In the real world, instantaneous mixing
would not occur leading to higher concentrations in the upper portion of
the aquifer than predicted by the model. The instantaneous mixing given by
the model allows for a dilution of 89 times (0.0112). At many sites.
throughout the country, where similar evaluations are performed, no
groundwater dilution would be allowed. The given model assumes the
receptor to be at the boundary of the contaminated zone. In many
instances, a theoretical receptor's well would be modeled directly below
the site. If all of the examples given above were incorporated into 'the
model, such higher receptor concentrations would be predicted. The result
would be 8UCb lower sol1 clean up levels. .
Because of the facts given above, the model is considered a reasonable worst case
scenario, not an extre- worst case. This 18 consistent with EPA guidance.
3. Comment: Further time sensitive apalysis such as the analysis pro~'ided in
Table Q-9 15 useful to evaluate the degree of potential harm as _asured by
various conservative assumptions. Table Q-9, for example, shows that health based
11
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levels of TCE in the aquifer would be approached for only one year in a chircy-
year period and that otherwise the level of TCE in groundwater vould be below
those levela.
[PA R.s~ons.: Table Q-9 represents one ca.e (conservative in concentracion and
percolacion, DOC conservative in Kd) from cbe potential cases given on Table Q-3.
Ocher cases could be performed. Given differenc scenarios, (e.g., longer areas,
higher soil concentracions and lower dilucion), long Cerm elevated groundwater
concentrations could easl1y be greater than 5 ug/L.
4. Comment: The vorse-caseanalysts used to support a .oil remediation level of
0.'5 ppm TCE in 8011 a.sumes. a' percolacion rate of 2 inches/year. However, the
EPA approved 80del used to arrive at percolation rates is staced to result in
.virtually no percolation to the saturated zone.. The FS use of a 2 inch
percolation race is based on a cheorecical possibility of the effecc of prolonged
Pacific froncal syscems. No juscification for or analysis of che effect, of the
froncal syscem is given by the FS. If a vorst case analysis is used at all, the
soil remediaCion level analysis should be calculaced Using a lower percolacion
race. '
[PA Resnonse: Alchough field scudies have noc been conducced at che HEW site to
determine t:he amount of vater infl1trating through the topsoil, the literacure
describes exponentially decreasing infiltracion rates following a rainstorm.
However, more wacer may infiltrate to the aquifers in periods of long storms,
especially following extended dry periods. '
Assumpcions used 1n the EPA model resulted in calculating little or no
infiltration in the MEW area. Th1s model uses average monthly precipitation and
temperatures to calculate average monthly evapotranspiration rates and
percolation rates. As a result, the percolation model does not consider the
single storm event. Infiltration calculations based on single storm events may
yield higher computed percolation rates. Also, the percolation model uses only
precipicacion as a vater input. Additional surface vater recharge can be caused
by irrigation related to landscaping. Based on these factors and conservative
engineering judgment, the FS used a percolation rate of ewo inches/year.
5. Comment: The worsc-case scenario is inconsistently applied for soil ,
remediacion levels. The 1 ppm TCE s011 remediacion level for inside che slurry
walls is based on che implicit assumpcion that those areas vill remain under
industrial/commercial control necessary to maintain effectiveness of the slurry
walls.
EPA Resnonse: A residencial reasonable vorst-case scenario was uniformly applied
throughout the KEY area. The i ppm TCE cleanup goal vas based on the added
degree of procection provided by the slurry valls and the continued monitoring
and pumping which vill be part of the overall remedy, regardless of the existing
or poeencial l8ad u.e.
6. Comment: Th. worst case assumption staced in the FS at Appendix Q uses a
retardation factor of 6.0. Based on Appendix peA, ,Che vorsc c~ recardacion
faccor discover-ed by the analysis lies at a minimum range of 6.5-8.5 as measured
12
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by laboracory daca and ac 7.0 as ..a.ured by field daca. Any calculacions
involving worsc case assumpciona should use che.e higher reCardacion faccors.
EPA Res~onse: Table Q-9 1. based on R of 12.0. Use of a R of 6.0 i.
conaervativ. buc cercainly noC worst case. Hany adsorpcion R value. aay be a5 low
a. 2.2 for TCI. Desorpcion R values aay be much higher. 8Vorsc ca.e8 analysis
should uae lower R values noC higher as implied.
7. Comment: The soi1 remediation analysis is ostenaib1y calculated so a. to
de80natrate protection of the underlying aquifer a. measured by a health based
concentracion of 5 ppb TCE in the aquifer. On chi. basi., the FS concludes that
0.5 ppm TCE in .oil i. an appropriate .oil remediation level. However, the
.olucion to the equationa provided in the analysi. have apparently been .olved to .
result in no 80re than 4.85 ppb TCE in the underlying aquifer.
EPA Res~onse: The difference berween 4.85 and 5.0 and che use of 8standard
.cientific conventions- (i.e., .ignificant figures) versus -nonstandard
convencion- is crivial and meaningless Co argue over given the accuracy of the
methodology and the assumptions. For example, the difference berween 0.0111 and
0.0112 (the dilution factor) is not meaningful or the difference is not
significant. .
8.
Commen t :
-
.. . the FS 1ncorrectly calculates the value for (Q in).. .
..
EPA Res~onse: The referenced calculations have been reviewed and found to be
correct. A typographical error exists in (Qin)., which should be expressed in
ft3/year. Despice the typographical error, che correct unics were accually used
and the calculation in the FS are correct as stated. .
9. Comment: 8 . the actual analysis provided to support the s01l
remediation level i. expressed as a concencracion of TCE in soil per s~ecified
unit of available sauare surface area throuch which ~ercolation may occur. Based
on this analysis, it 1s inadequace co express che remediacion level for the
entire site wichout reference Co che corresponding surface area.-
EPA Res~onse: Using che site specific approach given in Appendix Q requires
areas of contamination to be used in the calculacions. A similar calculation can
be made using percolatiori through a unit surface area through a given mass
resulting in flux into groundwater. The remediation levels calculated from these
approaches are presented in terms of mg/kg. Soil clean-up levels.need to be in
terms of mg/kg for application of an area-wide clean-up goal and for verification
of remediation.
10. Comment:
(llSCLs) .
The FS is unclear as to che use of recommended soil cleanup levels
EPA Res~onse: !Set. were D2k used to determine soil cleanup levels at HEW.
fact, RSCL8 are oucdated and are no longer used, even by che California
Departmenc of Health Services.
In
..A
13
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11. Commene: Sileec reco..ended ehae a cleanup level greaeer ehan 1 ppm for TCE
be see, based on soil cleanup levels ~found ae8 ocher relevane Superfund siees.
The sites referred to are found in New Hampshire, Iho~ Island and Michigan.
EPA Res~onse: . cleanup level established for one site (e.pecially in anoeher
part of che cOUDCry) i. noe necessarily adequaee at ocher sites. Site
characteristic. can vary greatly (e.g., soil, groundwater, geology, affeceed
populations, etc.) and, cherefore, each siee lN8e be evaluaeed on acase-by-case
bas is .
11.
COllllllene:
The RI repore incorracely staeed thae Sileec uaed TCA.
EPA Res~onse: Co..ene noted, however, EPA in its Au~e 8, 1988 approval leeter
for the RI seaeed, 8EPA neither agrees nor di.agre.. wieh the assumpeions or
assereions regarding 'inferred sources' or 'ocher PIP.' a. preseneed in the RI
repore.8
13. Commene: 8... TCE contaminaeion in ehe groundwaeer is not ateribueable to
leaks from an above ground storage eank and groundwater flow beneaeh Slltec
properey is eo the northease.8
EPA Re$~onse: See above response. In ies ill approval leteer, EPA also staeed,
8EPA neieher agrees nor disagrees with the configuraeions.and boundaries of ehe
chemical plumes, or with the graphical ineerpreeaeion of the poeeneiomeeric
surface/waeer cable of each aquifer a. preseneed in ehe ill report.8 8 The
configuration and boundaries are, however, adequaee to evaluaee remedial
aleernatives.8 The points raised by Siltecare minor since they deal with only a
small por~ion of the KEY area, and therefore are unlikely to have any bearing on
the selection of remedial alternatives for ehe overall area. Furehermore, well
elevaeion daea and .TCE concentraeion coneour plumes have been reviewed and ehe
data substaneiaees thae the groundwater (in ehe shallow aquifers) flows in a
noreh or norehwese direceion, consiseent with theRI repore.
14. Comment: Soil remediation ae Siltec would be unnecessary if soil
remediaeion levels were 8properly derived8, therefore, the seatement in
ehae on-siee soil remediaeion is necessary at Sileec should be sericken
text. .
ehe FS
from the
EPA Resnonse: Soil remediaeion levels for ehe KE\l area have been properly
derived. Individual siees .which will require soil remediation will be deeermined
by EPA on a case-by-case basis.
15. Commene: Siltec believes that the effeces of sanitary and st01'1l.sewers as
potential conduit. in the local study area (LSA) have not been aCSequaeely studied
and thae furcher iaveseigaeion may show thae sewers in the LSA do act as
conduits.
EPA Resnonse: An adequate evaluaeion of potential horizontal condQits was
performed by Fairchild, Intel, and Ray~eon as part of che RI. The re.ults of
the inve.tigation were included in the ill report. The repore concluded that
horizoneal conduits (ae least within the local seudy area) are not a problem.
Siltec wi she. eo perform an additional study, ie may do so during RD/RA.
If
14
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The Follovin, Selected Comments Yere Submitted by the Lea2Ue of Yomen Voters
1. Comment: Identification of all
to increase Cb8 financial resources
is also essential to guarantee that
participating in the cleanup..
the r.s~oft8ible ~arties should be expedited
needed for cleanup~ "Close monitoring by EPA
all polluters have been identified and are
EPA Resnonse: EPA has issued "Spectal Notice" letters for cleanu~ liability to
17 Potentially Res~onsible Parties (PRPs) in the HEW area. Agency negotiations
vith the PRPs for cleanup and oversight costs vill commence shortly. In
addition, as cleanup progresses, monitoring data vill be evaluated to determine
if other sources have contributed or are contributing to the HEW contamination:
2. Comment: The League agrees vith the "pump and treat alternative" for the
shallow aquifers.
EPA Resnonse:
Comment noted.
3. Comment:
groundwater.
The Proposed Plan should identify ways of reusing extracted
EPA Resnonse: Groundwater reuse is currently being evaluated and will be
incorporated into the ROD and the RDjRA Consent Decree.
The Followin2 Comments Yere
Submitted bv the U.S. Navv
General Comments
1. .Unlike other FS reports, this report does not present supporting engineering
calculations on treatment sizing, pumping requirements, simulated drawdown cones,
or construction materials and aethods. As such, the document is generic in
nature and essentially requires the reader to assume that the black box system is
optimal."
EPA Resnonse: Such detailed design information is :ypically ~ provided in the
FS because it is unnecessary, and consequently will be presented during Remedial
Design (Re).
2. "The report does not present specific design information for water treacment,
soils aeration, and several other alternatives discussed. Yithout this
fundamental lDfor.88tion, it is impossible to critique the authors conclusions."
EPA Resnonse: the information presented in the report is sufficient for
evaluating var10ua alternatives. Specific dasign information will be presented
during Re~
. . .
3. "A groundwater model is not specified, and pumping specifics (e.g., rate,
. duration, equipment) are not provided."
15
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[fA Resnonse: The inforaation regarding the groundwater model can be found in
Appendix P of che Fe..ibility Study.
4. 80ffsite r...d1at1on 1. ..ntioned throughout che docu.ent in a cursoryaanner,
yet a nuaber of pa8ping vells are shown on MAS Moffett Field property and a
treatment syst.. 1. shown on NASA property. How va. the inforaation gathered 1n
the MAS Koffett rleld Re..dial Investigation incorporated into che treatment
designs and ground vater extraction sche.es?8
[fA Resnonse: As the FS report states, the number and location of pumping wells
and treacment systems is. for costing 'estimates only. The actual number and
location' of these units will be provided,during RD. Also, site specific sources
on.Koffett Field vere not incorporated into the treatment designs and extraction
sche.es.
5. "The document does not present .inforaation as to the potential timing for
installation of off site or on site remediation. Due to other investigations
currently ongoing, extensive coordination is needed. To date, what coordination
is proposed?" .
[fA Resnonse: Timing and coordination for well installation will be part of the
Remedial Design and Remedial Action (RD/RA) negotiations process, and therefore
are not incorporated into the FS.
6. "It was difficult to determine if the unsaturated zone model is accurate
without supporting calculations. In addition, how is differentiation made
berween vapor phase tran~port and liquid phase transport?" .
EfA Resnonse: S~pporting calculations for. the unsacurated zone .odel are found
in Appendix P of the FS. Vapor phase transport was not considered.
Executive Summary
1. "ES-l. Uncontrolled sources are cited as present and impacting potential
remediation. These sources are not clearly defined in the text nor are their
impacts."
[PA Resnonse: Uncontrolled sources will be defined during the RD/RA phase and as
other PRPs are included in the process.
2. "ES-l. It 1s stated that the FS is designed to adequately address unknown or
uncontrolled source. of pollution. No reference was found in the text that
presents how uncontrolled sources are handled in the FS design process."
EPA iesnonse:
18. response above.
3. 815-2. Ch88ica1s have been detected in a1l 5 aquifers. ~as chere any
1nvestigation .. to the vertical distribution of che.icals in any of the
aquifers, particularly che C aquifer?"
16
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EPA Resnonse: Section 4.0 of the Remedial Investigation Report (July, 1987 and
revised June, 1988) contains the results of a thorough investigation of the
che.ical distribution in 80US and sroundvater 1n all aquifers.
4. .ES-2. How... the total volume of TCE, TCA, etc. calculated?
described in the text..
This was not
£PA Resnonse: The estimation of volumes of chemicals 1nvarioua aquifers i5
described in Section 4.3.2 (pp. 4-63 through 4-66) of the at aeport.
5. .Shallow aquifers beneath the site are c1ted by the aWQCB as being a potential
drinking water source. This argument appears unfounded since the general water
quality is poor and the aquifers thin, discontinuous, and low yielding. How much
potential does £PA or RWQCB see for the .hallow aquifer. being utilized as a
drinking water source?
EPA Resnonse: While the water quality and yields of the shallow aquifers may be
lesser in relation to the deep aquifers, the shallow aquifers near the site have
been used for drinking water' in the past, according to the Santa Clara Valley
Water District. Although currently no one 1s using the shallow aquifers. for
drink1ng water, the aquifers do meet EPA's groundwater class1fication criteria
for potential drinking water sources and are also protected under the RWQCB's
Bas1n Plan and Non-Degradation po11cy. Both agencies regard the shallow aquifers
as a resource that should be protected and restored.
6. .£S-5. The upper foot of .oil 1s not considered for remediation based on
health risk. Was potential leaching of these materials and subsequent
concentrations 1n lower zones considered?
EPA Resnonse: The Endangerment Assessment prepared by EPA concluded that there
is very little cont4mination present 1n surface s011s, therefore, leaching (from
the surface s011s) is unlikely to be a problem.
7. -ES-7. Throughout the document, mainta1n1ng an inward and upward hydraulic
grad1ent has been discussed. However, calculations on how much water should be
pumped to estab11sh this gradient or exactly what minimum magnitude of the
gradient is necessary but not present.-
EPA Resnonse:
Water pumpage will be determined during RD/RA.
Chapter 1
1. .P12. Recent groundwater extraction from within the slurry walls 1s
presented. There does not appear to be any reference in the text as to the
quanti ty of ..Cer being pumped or the qua 11 ty of effluent. This type of
information i8 critical in evaluating appropriate remedial alternatives. No
reference is 88de as to the established NPDES levels to Stevens Creek or the
POTY. This information is vital in establishing cost effective disposal
options.- .
17
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!PA Res~onse:, IPA doe. DOC ,bel1eve chac ch18 informacion 18 necessary for che FS
reporc. The'!.Dfor8&cion vill be provided c1uring che RD phase. NPDES levels may
be obcained fr08'die R~CI.
Chapcer 2
1. .P-17. Thr.. addicional recovery vell. vere added
racionale behind cheir inscallacion? Where are chey?
one creat8enC sysce.? If so, va. che original sysce.
creac.enc sysce.?
in 1985. Whac vas che
Do chey all C01.q)le inco
redesigned? Where i. che
2. 8P-17. Twenty-one (26?) recovery vell. are apparencly nov operacing. A
scheaacic of~ che operacing syscem(s) is e.sencial along vich de.ign decails and
racionale. None of chi. inforaacion i. provided ..king a good reviev of
additional pump andcreat scenario. difficult..
3. .P-18. Three stripping tovers are said to treat 80me porcion of the recovered
vacer. What porcion goes to che POTW and to, Stevens Creek?
EPA Res~onse: The above informacion is noc necessary for the '5 and vill be
provided during che RD phase.
4. .P-22.
aquifer.
The ltaycheon slurry vall is said to parcially penecrate the B2
Why vas che vall keyed into permeable ..terials?8
EPA,Res~onse: This information may be obtained by reading cheRaycheon .Slurry
. Wall. Conscruccion leporc8 Golder Associates, January 1988, which is'on file at
EPA and is a1so parc of che ac1ministracive record.
5. .P-23. 1,300 Ibs. and 230 lbs. of vecs vere removed from tWo plot..
percentage recovery of VOCs vas achieved?8
What
EPA Res~onse:
Th1s vill noc be known uncil che remedy has been completed.
6. 8P-24. In-sicu Cescs apparencly suggesc an effective radius of influence of
40 feec for vencing vells. The specifics of chese cescs vere noc presenced.
Whac vere che physical soil propercies? Soil mois~re and cemperacure? Tocal
concencration of chemicals in che soi11 Generally, 1n che fine grained soils,
venc vells are placed on 5 Co 10 feec cenCers. Alchough ic is not possible co
check the auchors' calculacions, previous experience suggescs chat the vent
syscem as given ..y not be adequace.8
EPA les~onse: The
Excraction SCUdy8,
February 8, 1'''.
che ac1mini.traC1ve
information ..y be found 1n a report titled, .5011 Vapor
Raycheon Company, prepared by Harding Lavson Associates dated,
The reporc 1s available for reviev ac ErA and 1. .lso part of
record.
7. .P-26. The slurry vall around Fairchild building 9 appears to be built
through a highly contaminaced area. Why? (Se. figure 2-1.6)8
EPA les~onse:
This informacion is not ,relevant Co the proposed cleanup plan.
18
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8. .P-27. Mecals have been deCecced in che groundwater but are essencially
discounced becaU8e of che 8tate..nc: .Mecals...are not very mobile in
groundvacer..... The pre.ence of ..cals in che soils and groundwater should be
considered in the design of CreaC88nt alternative.. Metal. pre.ent in the high
ppb range ..y h8ge adverse affects on potencial treat8ent opcions 8uch as
biological r.8C~or8 and promote 8caling in air scripping tovers..
EPA Resnonse:
MaCals vill be considered during RD.
9. .P-33. Chemical concencracions vere detected in Stevens Creek. Whac vere the
concencracions of these chemicals? 'Hov vere che.e chemicals addressed in NPDES
permitcing at the .ite?
EPA Resnonse: This information is' noc relevanc Co the FS.
requirements may be obtained from the RWQCB.
NPDES permitcing
10..P-33. How were the synergiscic and ancagoniscic effeccs of che various non
target chemicals addressed when designing wacer treatmenc syscems? For example,
is fouling of tpe aeration tower packing material due to high levels of
inorganics a potential problem ac the KEY remediation area?
EPA Resnonse:
This information will be developed during'RD.
11. .P.)4. Chemicals detected in samples below lOX or 5x associated field blanks
are reported as non-detected. Which specific compounds other than the four
chemicals listed fell under the lOX rule? On what basis was the 5X rule chosen?"
EPA Resnonse: This information can be found in che .Endangerment Assessment"
report' available at EPA and in the City of Mountain View Public Library.
12. .P-36. The mobility of mecals is again mentioned yet there is no discussion
on the redox potential, precipitation or exchange of chese" chemicals in the
presence of soil components such as humic acids. Lead for example can be
solubilized by some naturally , occurring acids and some lead compounds produced
are classified as soluble. If lead is able to come in contact with estuarine
benthic microbes through surface water transport or shallow groundwater flow,
these microbes can methylate lead to form tetramethyl lead which is volatile and
more toxic. Although situations like the one described are not common, a more
comprehensive review of ..tals concamination should be considered."
EPA Resnonse:
See above response and response to comment 8.
Chapter 3
1. .P-54. In paragraph 2, soil remediation levels are left open, yet all
remedial alterna~ives are based on 1 ppm and 0;5 ppm TCE cleanup levels.
apparent inconsiscency needs clarification.. '
This
EPA Resnonse: Soil remediacion levels inside the slurry walls are .lefc open"
only if Alternative ~oncencration Levels (ACLs) are chosen as cleanup levels for
19
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aquifers inside dbe slurry walls. EPA has chosen Maximum Contaminant Levels
(MCt.) for dbe shallow aquifers including dbose located inside slurry walls.
2. .P-57. The tederal pre-treacment guideline. for toxics of 1.37 pp. from
aanufaceurina tacilities would be relevant only if the local treacment works
would agree to uae dbi. guideline..
EPA Res'Donse:
Correc t .
Chapter 5
1. .P.92/l06. In-situ biological treacment i. considered only to a very limited
extent. Specifically, dbe authors addr.ss biodegradation in an undisturbed
state. FUrther dbey discount dbis option quickly by citing a single. study
performed by Stanford University. No significant concluaions were drawn from
this work.
Aerobic biodegradation can be performed using an above grade landfarming
technique. This technique is very successful with aromatic hydrocarbons and
would augment soil aeration. The technique can be used with similar farm .
equipment employed by the aeration alternative. Although biodegradation alone is
not a plausible solution, biodegradation using aarine bacteria, sewage sludge or
some strains of soil bacteria can enhance the remove of chlorinated alphatics
sorbed to the soil matrix and should be considered.- '
EPA Res'Donse:
Comment noted.
2. -P-95. On site treacment options deal exclusively with volatile compounds.
The extracted water stre.. will contain nuaerous other che.icals such as iron,
llagnes ium, calcium carbonate, and heavy IHtals. These compounds IlUSt be treated
prior to entry into an aeration tower to prevent fouling and to promote treatment
to the limits set. Treacment units including precipitation tanks and mixers. in
line filtration, and multimedia filtration should be addressed.-
EPA Res'Donse:
This will be addressed during RD.
3. .P-I01. The chemical characteristics listed are properties associated with
volatilization and sorption. Characteristics such as pH, TeS, BOD and TSS need
. to be quantified prior to design of water treatment..
EPA Res'Donse:
Comment noted.
4. .P-103. The contention that additional surface capping would have a minimal
influence on infiltration should be supported by calculations provided in the
docuaent..
EPA Res'Donse: Moat of the site (approx. 80t) is already capped.
additional capping will have little, if any. influence.
Therefore,
5. .P-104.
buildings.
It is contended that excavatior .rould require demolition of several
Which buildings?-
20
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EPA ResDonse:
Potentially, any buildln~8ituated over 8011 concaminacion.
6. .P-105. L1alted 8~ace available for 8tockpiling 80i18 is given as a reason co
discard excavation, yet landfaraing 80i18 for volatilization of organic. is
pa..ed throush for conslderatlon. If s~ace i. 118ited, where would the above
grade landfaraina be accomplished?
EPA Resoonse:
. thi. information vill be developed during RD.
7. .P-I08. Aeration is described as not being effective on phenol.
o treat8ent ..thod ls offered for phenol In lieu of aeraclon. Why?
Hovever, no
EPA Resoonse: As phenols in .oilhave not been quantitatively defined,
information vill be developed during RD, and incorporated as necessary into che
treatment ..thoda.
8. .P-108. What constitutes successful dewatering? (para 4). If vapor
extraction is to be successful, what Is the maximum residual water content in
sandy soils1 Cohesive soils18
EPA Resoonse:
This information will be developed during. RD.
9. 8P-I08. Adverse settling due to dewatering vas encountered. What vas.che
magnicude of chis setclement? Why vas this situation not reviewed in Chapcer 9
with respect to the long term pumping scheme?8
EPA Resoonse: It is not known if settlement vas due in part, solely, or at all
because of dewatering. Additional information vill be developed during RD/RA.
10. .P-108. It is stated that settl1ngvill not affect slurry vall integrity.
Were calculations performed to support this contention?8
EPA Resoonse: The FS Report states that settlement conditions are not expected
to affect the integrity of the slurry valls. Calculations to support this
conclusion vere performed by consultants for Raytheon independent of the FS
report ..
11. 8P-109. The report claims that in-situ aeration is applicable to soils
beneath buildings. It is not clear from the supplied figures how soils beneath
buildings are being remediated.8
EPA ReSDonse: 50ils beneath buildings are not currently being remediated.
areas vill be addressed during RD/RA.
Those
12. 8P-109.
Vhat are the serious concerns about steam injections?8
13. .P-I09. Vhat are the potential adverse effects of ateam flushing?
not presented 1D the discussion..
They are
EPA leSDonse: The concerns about 8team injections are that the levels of
development and field experience are .inima~. Massive injections of steam would
result in the significant elevation of subsUrface soil temperaeures and pore
21
-------
pressures under structures on the site.
result in po.sible injurie. to per.onnel
due to 1. heave or settl...nt- and/or 2.
.te.. to the aurface.
The.e temperatures and pressures could
and disruption of industrial operations
the accidental uncontrolled release of
14. -P-112. '1118 arsuaents that flushing II&Y increase the boundaries of chemical-
bearing groundwater and that the flov injected vater cannot be controlled are not
valid. If injection veIls ar.e properly placed upgrad1ent of the plUIH and
extraction ..11s placed downgradient, a closed loop syste. can be ..intained. .
Flushing increases the hydraulic gradient and can substantially reduce
re..diation time. Further, flov controllers connected to sensors in monitor
vells can ..intain a predetermined hydraulic head.-
EPA les'Oonse: Sections 5.3. 11, 5.3.25, 6.2.9, 7.2,.2.4, and 7.2.3.4 of the FS
explain vhy flushing is not considered for site remediation.
15. -P-112. 1. It 18 stated in the FS that it. is unlikely that enough water
could be injected to alter the piezometric surface. This arguaent contradicts
the previous statement regarding complex .tratigraphy. The aquifers are low
yielding, discontinuous and relatively thin bedded. All of the.e physical
characteristics suggest an induced head could be applied. 2. ,Were calculations
performed or a flow model used to show the effects of vater injection?"
EPA lesDonse: 1. The eext of the FS does not contradict the above statement.
The text does state that due to the -extre.ely variable permaabilieies . . . it
(ls) impossible to ensure that adequate flushing rate. can be lI&intained in all.
. . areas. Also, it is unlikely that it vill be possible to inject groundwater
at a rate that would significantly alter water levels or piezo.etric surfaces in
areas not in the tmmediate vicinity of the injection veIl". 2. No.
Chapter 7
l~ "P-160. An 80 foot square grid would be required according to .ection
7.2.1.2. Earlier In the report, a 35 foot .pacing vas presented."
EPA lesDonse:
during RA.
The exact spacing is unknown at ,this tiae, but wl1l be determined
2. "P-160. In figures 7.2-1 a-c, extraction veIls are shown but air inlet wells
are not shown. The text describes inlet/extraction wells. Is this a pump in.
pullout process or just vapor extraction?"
EPA ResDonse:
The process vill be determined during RD.
Chapter 9
1. "P-260. St898na Creek i. proposed as theult1Jlate receptor for treated
groundwater although it i. not specifically stated in this chapter. How vill the
added flow affect the stre.. channel?-
EPA Res'Oonse: As described in Section 2.2 (pp 2-4) of the II aepore, Stevens
Creek is an intermittent stre... Therefore, the addition of a year-round flow of
22
-------
~reaced groundvacer fro. MEW Aree re..d1al acc10na .1ghc change por~1ona of che
creek do~cre.. of groundvacer d1acharge po1n~a to a perenn1al condition, to che
extenc tha~ the dlacharge flow exceeded local .~re.. bed percolation capacicy.
However, the ,ropoaed flow of treaced groundvater 1a not expected to be large
enough, when cG8pared to not:1l8l atora run off, to _ter1ally affec~ the channel.
2. .P-260. aa.... channel hydraulica been IIOdelled \Ul1ng the HiC-l or a1allar
flood routine .ch88e to enaure that the added vater vill not create a local
flooding probl..?
EPA Res1)onse:
No.
3. .P-245. Sevententha of a pound ofTCE ia conaidered to be de minimus. How
.is this value calculated (veight or volwae basis)? Vitat criceriais uaed for
deceraining the volWle or veighc co te.C?
EPA Res1)onse: The cera .de m1nl~8 wa. developed by Fairchild, Intel, and
Raytheon to describe certa1n -.1nor- contaminated areas. EPA does not use this
cerainology Co describe. contaminaced areas. Calculacions and criceria may be
found in Appendix 0 of the FS report. .. .
4. .P-245.. Ho.w w.s che pumping scheme oucside the slurry valls designed to
ensure chat an upward gradient is _intalned inside the slurry walls? If the
groUndwater surface is sufficiently suppressed outside che walls then inside
pumping is negaced.8 .
EPA Res1)onse:
during RD/RA.
The gradiencs arecurrencly being monicored and will. be monicored
5. -P-260. Why are only Bl and A aquifer wells proposed offsice in che
dovngradienc direcCion?-
EPA Res1)onse:
aquifers.
Because chere is no concaminacion downgradienc in the B2 and B3
6. 8P-260. Whac is che racionale for plac8menc of wells within NAS Koffecc
Field? Was flow modelling performed?8
EPA Res1)onse:. Wells were placed in relacion Co the contaminacion plume.
modelling was not performed.
Flow
7. -P-260. Since chemical ~ransporc modelling was accoaplished in only tWo
dimensions, how vere the effects of drawdown ofche.icals through shallow
aqu1~ards conaldered?- .
EPA Res1)onse: The effects of dravdown of che.icals through shallow aquitards
were no~ conal_red .ince the IIOdel a.swaes that the aquifer is confined.
8. -'-261.
c08ponen~..
Air atripping and ac~iva~ed carbon f1l~ration are listed a. treatment
W1ll these .yste.. require co~~inuo\UI moni~oring?8
EPA Res1)onse:
No.
23
-------
9. .P-261.Vhac are the asc1aaced carbonU8e race. and packing life spans?
ocher c08ponenc. c08pri.e the creaC88nc sysce..? Hov 8UCh area vill be
required?
W'hac
10. .P-261.
How will ucilicies be handled for the off .iCe syscems?
11. .p. 266. ;bat 1. the racionale for the placellenc of che three .C. aquifer
vells? What are the proposed pumping raCes? Vill the higher volu.e pumped from
the.C. aquifer have a C8ndency Co diluce the vasce scre.. fro. che lower
yielding upper aquifer vells? If 10.. what is the 8xpecc8d average concencration
of chellicals on the influent 8ide of the air 8cripper1.
EPA le.vonse:
The informacion for quescions 9.11 vi1l be developed during RD.
12. .P-267. The Operacion and Kaincenence CO.8U are noc vell defined in the
appendices. How va. the 2.9 lIillion dollars of annual O&K derived for che off
site re.ediation sche.e? How ..ny treatment systellS are included in the off sice
program?- . -
EPA lesvonse: The O&K costs are adequate for the purposes of the FS.
number of treatment systellS will be developed during-RD.
The exact
13. .Figure 9.2-4. .So.e fairly exunsive piping is- shown on HAS Moffett Field
property. :Hov would this piping be installed? Have the numerous subgrade
utilities on the facility been factored into thee.tillated cost?-
EPA lesvonse: The drawn piping is a conceptual design and the installation will'
be refined during RD. Yes.
24
-------
( .
Ama)IIS'rJtA'1'IVB UCOJU) IIIDBZ
-------
1- - - -------- _.-.
I£VISIOII DATE: (Y.,IW89
PAGe.: 1
Mfddieffeld-Ellf.-Whf.-.n Area SUperfund Sfte
-"taf" Vf..., Cal ffomfa
- Adlf"istratfve I8COtd Index -
001:'
1
em
06/11116
~IZATtOll
Maic0&8 ...,. .
S8nU ctwe Vall., WIlt.,. Df.t.
TO/ORGANtZATlCII
COWIty SMlitari-
DESClIPTtCII/U.lECT
Well S88U", Instructions
V.,.f- Dr_I",.
"""0;5.
7
2 OZI08/as lover I. .I-t levised Tentative Order 8
NQC8
Sf ley I..;ion
3 03/20/85 Th...s Berk ir~ D0rt8ld Dalke su...ry leports for the 13
I.W.G.e.l. I.W.G.e.8. . Mauntai" View Five
SF Bay leg i on SF Bey "Region
I. 04/22/85 ThoMB. Berkins, Lester Roger .I... fairchild, Intel, NEe, a
Feldman, LavrenceKolb R.W.Q.C.B. Raytheon, Siltec, Mountain
R.W.G.e.B. SF Bay Region SF Bay Region Vi..., Santa Clara Co.
5 04/30/85 R.W.G.e.8. Fairchild, Intel, NEe, 2
Sf Bey legion hytMon, S fl tee, Mo&.rIta i n
"View, SMlta Clara Cou-Ity
lequir88ents for Site Cleanup
6 01126/85 Gordan SnoM Gl.., lCi.tner State leview of Mo&.rItain View
lesources Alency of Cal ffornia EPA legi on 9 Five SUperf\n:l Project
7 08/15185 Harding, LatlSon Assoc.; . EPA Region 9 Work Plan R~ial Invest;g. 7S
. Canonie Engineers F...ibility Study and Oper'
ati0rt81 unit F...ibility Study
Mlddlefield Ellis-WhiS88n Area
8 08/15/85 EPA Region 9 Intel, Fairchild & Raytheon Adliniltracive Order on 22
ConHnt
9 08/15/85 Ll~ I. .. Eric G. LIJIP81a Mountai" Vi... ~I/F$ and 1 .
Cool." ;C""--1, Caltro, Narding, L...-. Assoc. Q.U.F.S.
~leaon & TatUi
10 08131/85 Terrence.l. Mc:M8rL8 Gl.., lCiltner Proj«:t SdMcaI.le 6
Intel EPA Region 9
11
09106/85
Terrence MdCanua
Intel
G11m lCiltner
EPA R..ion 9
Project Schedule
5
-------
-- -- --- -.-----.---- . ------ - - -. --.--.. .--
IEVISICII DATE: OS/i2Jf19 PAG£: 2
Mfddleffeld-£n I.-'-lif-. A.... SUperfund Sfte
Mcuttafn Vf.., California
- AGilfnfacncfw 18COt'CI I'" -
DOC' oATE FICIMIIUIIZA TtCII TOIOlGAllIZATICII DESClIPTICII/SUlJECT f!S!
-
. 12 flf/1!j/85 c:..nfe InIf...... EPA R..lan 9 ~: ClAIOC Pi." bl.ting 175
MonitOt'fng Well. IIFS Mlddle-
ffeld-Ellf.-WhI88ln (MEV)
Area
13 fIf 12'5/85 Stew DoOrf j..,ic, Phillip Intel Monitorfng Report 188edial 175
Ant_ria In¥e8tigatian Feasibility
c:.nani. Entineers Stud¥ Date Through July 1985
l' 10/28/85 J.... McClure, Eric Lappe I I EPA Regian 9 Tecftnical 14eaIo: Well Inventory 25
Harding L....an Assoc. "iddlefield-ElI ia-Whisaan
Study Area RI/FS
15 11/15/85 c:.nani e Eng i neers Intel, Fairchild' Raytheon SoH evalU8tion Report 175
R.-.dial Investigation
Feasibility Study
VolUlle I
16 11/15/85 c:.nanie Engineers Intel, Feirchild' Raytheon SoH evalU8tian Report 175
R.-.dial Investigation
Feasibility Study
Vol\88 II
11/15/85 c:.nanie Engineers Intel Fairchild' Reythean SoH EvalU8tion Report 150
R..-dfal Investigation
Fe..ibility Study
VolUie III
18 11122/85 J.... McCLure, Eric LlppIl. EPA Region 9 Tecftnical Melle: Potent i.1 35
Hardfng, Lawsan Assoc. Conduits Ev.lU8tion Middle-
field Ellis-WhiS88n Study Area
19 11/26/85 GLem Kiscner Terrence ~ EPA C0888nts an the D.tabese 6
EPA R..lan 9 InCel ""18I1--t Syst- PI.",
Itydroveol og i c Model P len,
Well I rwentory
20 12100/85 c:.nanfe InIfneen Incel, Fafrchfld' Raytheon, Pulpfng Teat, City of 200
Siltec *,,-,c.fn Vf..
Wen 110. 18
21 12120/85 Gle,." KI.tner Terrence ~ . Preli.in8ry Definf cfon of 22
EPA R..fan 9 Intel R888df.l Accfan Objectives
MEW Study Area
*,,-,tain VfeW, CA (cowr I tr)
01/00/86 c:.nani e Eng i neer i ng F.irdlild . Pulping Teats Interi. R.-.dial 300
progr.. *,,-,t.in Vi.. Facility
Vol\88 1 of 2
-------
- - -" - .-- -.
UVISIOII DATE: OS/22/89 PAIii: 3
Middlefield-etti.-Whi88lft Aree SUperfund Site
~.In Vi_, CaUfomie
- Adltnl.trettw ,Iecord Indu -
DOC' 2m FIaRfaII8M 1 ZAT 1011 TO/OIGAIIIZA TI 011. DESClIPTICII/SUlJECT !S!
Z3 01/00/86 c.n.f. ....f.....1 FetrchHd Pulpl", T_tl Int.,.i. 300
I~tel Pf'OIn8 -"tei" viw
Feci t I ty VolYle 2 of 2
24 011281S6 Glem KI.tner T err.nce MdC8nuI EPA CCIII..'U to the Middle- 12
EPA I..ion 9 Intel fteld-EIll.-Whi.-.n Study Area
"SoH EY8luetion Report"
25 01/28//86 Glem Kistner T"~ Tr. Addtttonel EPA Can8ents 3
EPA Region 9 Lindell Ripley & Oi88Ond concerning the 8Soil
Evaluetion Report" and
Fairchild
26 01/30/86 Glem Kistner Terrence Mc:M8nua EPA Co88ents on the 8Existing 17
EPA Region 9 Intel Data ReviW" f~r the Middle-
field-ELLis-Whisman Study Area
Re8edilil InYeStigation
21 02/00/86 c.n.ie Engineers Intel, Feirchlld & laytheon Hi.tortcFlow.An8lysil 2Z
ItydI OteolOlic Model Oescrip-
tion R.-.diel InYeStigetion
Feeetbitity Study
25 02/25/86 Cathertne Henrich, EPA I..i on 9 Thtrd Gu8rterty Report 8Re8IId- 40
Eric L.-le iet lnv88til8tion Feesibility
Harding L8VSon Assoc. Study Middlefield-Ellis-
WhiS88n Study Area
29 02/25/86 Harding Levson Assoc. EPA Region 9 Tables Third Quarterly Report: 100
R888dtal Inwest;gation/Feasi-
bility Study Middlefield-Ellis
Whi.-.n Study Area
30 02/27/86 Canon; e Enei neers u.s. EPA Respanaes to EPA CC8Ier'Its on 60
For Intel, Fetrchitd & the Mtddtetteld-Etlis-Whisman
ReyttIeon Area II/FS Soil Evaluet;on
Report
31 02121/86 PhH tp L. Fftzweter GlIM ct.tner Tr8ft88ittal: leports tn reply .15
Herdf", &..-an A880c- EPA I..ton 9 to EPA CG888ntl on the 8Soil
EY8luetton R~rt"
32 03/12/86 Gl.." Kistner Larry Man EPA 8nd ~ Agree.ntl Z
EPA Regiait 9 Fei rchild
33
03/26/86
Catherine Henrich,
Eric L.-la
Harding LMllon Assoc.
Glent Ktltner
EPA Region 9
Tr8ft88ittal: ChronolOlY of
Events end Ch..ical Results
fr08 SWI-Z30, RJC end RIoC
100
-------
RfYISIOII OATE: OS/WtJ19
PAGa:: 4
Mfddteffetd-Ettfa-Wbf88lft Area Superfund Site
~.tn vt-. C8t tfOtftt.
- Adltntacl'8ctw I8COrd Indu -
!5-!
']4
Wl
03/28186
~IZATICII
eu... If--
EN IeIf.. ,
TOIOIGAIIIZA TICII
Larry A8Drt
Intet
DlSClIPTIOII/SUI~ECT
Initiat Sc....,f".. of
A l t8f'Nlt t..,..
~
4
35
04/03/86
Gtem Kistner
EPA -..ion 9
Larry A8Drt
F.irdlild
Detey re Aquifier Teat Report
36 04/04/86 Gtenn Kistner L.rry Man EPA'. dr.ft c~ts on: 10
EPA -..ion 9 F.irdli ld "Monitori". Network Well
~ry" Historic F\ow Anal.
ys i s Hydrogeo log I c Mode l
37 04/04/86 Rone~d Stoufer & Phillip R.ytheon Ph... IV S4.C8urface Invest i- 150
F i tzweter g.tion R.ytheon 350 Ellis St.
Mardi ng Lawon Assoe. Mountain View, Ca.
38 04/07/86 J.... Wilson, Eric Lappela EPA R..ion 9 OUIlity Assurance/Quality Con- 135
H.rdi". LMlSon Assoc- trot Plan: R888di.t Investi.
ption Fenibil ity Study and
Operable Unit. Fe..ibility
10 05/00/06 Internetionet Technotogy Intel S&e8urlace Soil .-.di.tion 310
Intel
Mountain View, CA
"0 05/02/86 "idlNl Rosa Gtem Kistner III/FS SchecS.lle
Raytheon EPA Region 9
"1
05/09/86
Glenn Kistner
EPA Region 9
"idl..l Ron
R~
Deep well Moni tori". Program .
2
42 05/13/86 c:an.t. ""I...,.. F.i rdltld Inwatfgetfon of well 65M2A3 32
SflV8 well, _.-.dt.l Investi-
ptfonF88ifbility Study
Mlddlefield-Ellis-Whi...n Area
43 OS/20/86 MfdlNl 8. Ron Ji. Grow Deep Aquifer Monitori". 8
Raytheon EPA R..ion 9 progr.
4
OS/21/86
Demia Fes8i re
Cananie EnvirCJn88nt8i
File
Att8Ch88nt 8 Contact with
Garcfa well wid Pulp Co.
2
-------
--- -----
ICfYISICJI DATE: (151121" PAGl: 5
Mtddlefleld-fU 1.-\111-- AN8 ~IN SUe.
Jllutfatn YI.., C81 tfomla
- AdIIlnl.trul.. I8catd Inda _.
DOC' 2m AICIU8UIIIZAT lOll TOICIGAIII ZATtON . DlSCllPTIOII/U.lECT ~A~t
45 f15/27/16 It... Da8rIJevic Larry A8an Statui leport Fairchild 300
"'IHlp __ria F.lrdlUd Mauntaln VI. Facility 9/1/85
c...fe Enltnaen tttrough 3/31186
Vol. I.
46 f15/27/16 Ste¥O Dobrljevlc Larl'y A8an Statue leport Fairchild 210
"'ill ip Ant~ri. F.i rchild ""'tain VI.. FacU fey
Camonie Er.ineers 9/1/85 thrGUllh 3/11/16
Vol. 2
107 00/00/86 Cenonie Engineers Intel, F.irdlild & Raytheon AI''' North of l8yshore 15
Freew8Y l.-.dlal Investigation
Fe.sibility Study
1,8 06/00/86 Canoni. Engineers F.i rchild Dr.ft Report: Interi. le.edial 10
Actions F.irchild Se8iconduct.
Mt. View Facility
Vol... 1 of 3
49 06/00/86 Canon,. Engineers F.irchild Draft I~~t: Interi. Reaedial 200
Acttons F.irdlild Seaiconduct.
Mt. VI.. FacU icy
Vol. 2 of 3
50 06/00/86 Canonie Engineers F.lrdlUd Draft leport: '. '~hi leaedl.l 400
Actions F.irdl. ~iconduct.
Mt. VI.. Facility
Vol. 3 of 3
51 06/02/86 Sry... Rector Glem Kist,.r Intel GroundMater leaedial 2SQ
Intel EPA leti an 9 Actions Attached: GrOY1dw8ter
Re.edialActions Final Phase
3/19/16
52 06/05/86 Mich..l 1088 G\em Kistrer Schedule for S81pling RCU'ICI 200
laytheon EPA letian 9 3.5 Mlddlefteld-Elll.-\IIisaan
II/FS
53 06/12/16 P .IC. ~n p ....,..., .n. WH8CIf'I .....t for LabOI'8tory 6
EcolOW' !nri~t ilardi", L88CIft Auoc. ANlyCfcal I.. Data
Mountain VI.. Site
54 06/16/86 Rebert P. Stem *,,-,Uln VI.. C\~
EPA Regian 9
I
I
I 55 06/17186 Terry Wilson Pr... CII4N8 ..1....) EPA Request P\Dltc ~t
EPA Regian 9 an FeirdlHd Grounca.ter
Cleenup Pl.ns in Mountain View
-------
~ISJ()II DATE: as/22/M
,
.
IUddlefteld-EU I.-"'t-- Ar- SUperf\nt st te
~aln vt-. C8llfomta
- Al8int.tr8ttw lecord Index -
~
2!L!
."56
TOIOIGAIIZA T 1111
GI8M rt.tNr
EPA I..ton 9
WI
06123/86
FICIUCIIUIIIZAT 1111
"fd888t ...
I~
DlSClIPTIIII/SUlJECT
IIOtlftC8tfon of Addl ttCINI
~t... a..pU... for tne
"fddleffetd-ettt.-Whl--.n
It/FS
57
07/00/&6
Mfddtefletd-ettla-Wht..-n Area
II/F5 weu I~tory S4.88ary
Pl'OCb:tion wella
58
07/00/&6
Canonie Engineers
F.ira.lld
P.rking Structure PriV8te Well
lr'NeStig8tiona arc Proposed
Well Sealing Plan MEW
Area, Mt. View, California
59
07/00/&6
Canonie Engineer
F.i rchild
Deep Wet l Ctuater IIUlCer 3 DW3 .
Installation' Pumping Chrono-
logy Middlefietd-"Ellis.Wtlisman
Aru Mou'Itain Vi..., CA
60
07/07/86
Robert Ste,;,
EPA
Fai rctlild Interi. Remedial
Action Proposat
Mfdl..l Kent
Citizens for. Better
E""ir~t
61
07/08/&6
Mfdl8elROM
Raytheon
Glem Kfatner
EPA Region 9
Well In¥efttory' Potential
Conduits EV8lU8t;on
62
07/23/86
Marry Seraya.rian
EPA Region 9
Larry A80n
D i 88Ind 1881"
Interi. ReDedial Actions
Report
63 07/21,186 Phillip Ant~ria Raytheon S-C Acuitard"Soil Che8ical 60
c.nonie E",ineers Anetysia Results Mlddlefleld-
Ellfs-Whf--.n Area Mountain
View, CA
64 07/a/&6 Mfd888t... Gt8M rtatner Draft Map showi", dfstrfbutfon 3
R~ EPA I..ion 9 - cl..sUIC8tfon of ...Us in
MEV stloGy Area
l 65 07129/86 Mfdl..l ROM Glem rfatner Loat well. 2
Raytheon EPA R..i on 9
66
08/00/86
c.nonie Engineers
Intel, Fairdlitd , Raytheon
SoH S8IIIpU", - Anelysia"
'.-.dlat Investig8tion
Feeatbittty StloGy
PAGE: 6
~
28
7
25
25
3
5
25
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1
i::YISICII OATE: (15/22189
~
)7
Rm
08120186
,
,
I
;;y
1
08125/86
,
i
I
i;69
i
FICIIImUIIZATICII
E..-'a %8rfcII
llerdh,. ~ A880c.
IUch_L I...
l~h8Gf'l
a9/04/86. Hardl,.. Lewson Assoc.
110
a9/05/86
1"
I
172
I
i
i
a9/17186
a9rl6/86
73
. a9/30186
74
10/01186
1
:75
10/14/86
76
10/20186
1'1
10/20/86
Cenonla EnYironeentaL
GLem Klstne"
EPA legion 9
Glem Kistner
EPA Region 9
David IC. Rogers
The MIIrk Group
St8¥O Dobrijevic , PhiLLip
Ant~ria
Canani. Engineers
StIW Dabri Jwic
"'flUp Ant r'a
Canani. Envi....-,tal
St8¥O Dobrijevic
Cananie Envi....-,tel
Eugenia Zoric:tl
J- McClure
Hardl,.. L....on Assoc.
MlddlefieLd-Ellfs-Whia8.n Area SUperfund Site
.......tein Vi..., Callfornle
- AdII'nlscnciw lecord Index -
TO/OIGAIII ZA TlCII
Glem ICIsCner
EPA Region 9
DISCI I PT ICII/SUlJECT
Tr8n88'ttal of Statui leport
WaCer Ou8l1ty s.-,.., 350
Ell'. St. Maunta'n v,..., CA
8-8-86
Glem 1C.lstner
EPA legion 9
leaponae to July 8 EPA Letter
on Pot8ntlel Condulca
EPA legion 9
Sellpli,.. Pt.,,: R-.dI.L InYes.
ti..tion Fe.sibiLity Study
MiddlefleLd-ellis-Whismen
Study Area Mountain View, CA
F.irchild
Evelu8cion Report Stevens
Creek Rech.rge: Groundwater
Treatllent F.irchild M~tain
. VI.., Fecil i ty
Mlc:tI_l G~ Rose
Reyth8Gf'l
8-27-86 Technic.l Meeti,.. of
the Agenei8 end ~i~
MlcMel I...
18yth8cn
Short end Long T.,.. Aquifier
Taat Report
Iryen lector
Intel
Tr8ftS8itt.l of SU888ry Report
Sol l AM Groundwater D.te
Intel Site Mountein View, CA
Mlc:tIMl Roa.
I~heon
I....... to ePA CC!888nta on
eM c-truction DW6 Multiple
Monitor'ng Wells in e Si,..Le
Iorehole
Tha8I8 Iert' ftI
Addlcionel Inf0r8cion
PerCeinlng to SC8¥8n8 Creek
I.W.G.C.I.
C.I. "tic
F.irchild
1on-ll/fS wecer Ou8llty Dete
felrchl ld Mauntaln VI..., CA
EPA Region 9
Interi. ROInt weter Ou8l Icy
SallpUng leport: Re8di.l
Inweatig./fe..ibility Study
PAGE: 7
!!iU
135
15
210
2S
4
11
200
25
110
100
160
-------
-
UVISICII DATE: 05/22/89
,
"fddl.fl.ld-EU I.-"'I~ Ar.. Superfund stt.
*'-'tal" VI_, Call fomla
- AdIf"f.tntfw lecord Index -
..ggu
nfWlMlWllZATtOl
Demf. L. Qn8n
Calw\1. ItWI~tal
TO~IZATtCII
Glern IClltner
ePA I..ion 9
DESClIPTIOI/SUlJECT
188P0N8 to EPA ec-ttl
Technfcal M80 Pvtl", Struc-
tur. Privet. WIIU Investl.ga-..
tfona with Att8Ch8entl.
OATt
10/21/86
79
10/21/86 0..,,11 curr."
tenon;. E"..,lr..-ntal
Glern Clltner
EPA -..ion 9
188P0N8 to EPA ec-ntl Tech-
nical M80 Partl", Structure
Prfvet. Weu Inwwstfgations
And Pr~ed well Sealing Plan
80
11/21/86
C.R. Bostic
Fai rdli lei
TecMfcal M4!8t Well Inventory
8nd evaluation ~te Middle-
flelel-Ellis."'fS88n Area
Remedial Investigation
Phillfp Ant~ria
Stevo Oobrijevic
Canon i e E"., i rorment a l
81
11121/86
GL.... Kistner
EPA Region 9
R8SP'ftSes to A41ifer Test
Report COII8entS
C.R. Bostic
Fa i rch Hel
82
11/24/86
Stevo Oobrijevic
Canonfe e".,irormental
C.I. Bostic'
Fairchilel .
Tr8nSllittal: Qb8ervation Wells
Feirdtild Mou'Itafn Vi.., CA
PAGE: 8
~
20
10
11
15
100
11/24/86 C.I. Boetfe Glem Clltner Water Level Data F,..1-86 7
Fai rchilel EPA Region 9 Through 12/86 for the 'e' and
. . Deeper A41ifer Wells, Retned;al
lnotestigation Feas;bil; ty Stdy
84 12/00/86 Caq) Dresser I ~lCee EPA Region 9 Final C08U1ity Itelations Plan 1.0
Mfddlefiald-Ellil-"'iS88n Area
McM1tain View, CA
~5 12/19/86 O....il J. Curran Gl.... Kistner Tr8nS8ittal Nlltorie Water 200
tenoni. E"..,i I"CIr8ental EPA Region 9 Level Data ItI/FS
Study MEW Area
86 00100/00 (~tI ruIIbend out of 7
...-.:. )
87
12124/86
Ale.fl Str_1
EPA Region 9
It..,;.. of ANlytfClll Data Ra:
Mountain VI.. Sft. utilizing
Organfca Analysfl
Att8Ch8entl
Cent Citehing88n
EPA Region 9
12/30/86
Welll Itee: I.ded Saaled By
the C08p8ni.. .. of 11/21/86
Mountain View MEW Site
65
-------
I£YISI~ DATE: a5122189
, .
,
Mlddlefleld-IU I.-"'i~ Ar.. ~ Sfte
Mcuwtaln .,f.., Callfoml.
- Adalnl.tntl". lecord Index ...
PAGE: 9
DOC'
89
WI
01/02181
,..,..I.A.'ZATtCII
lobert Vf t t f-
EcolOW & IlWiror-.t, Inc.
TOIOIGAJIZA TlCII
DlSClIPTICII/..JECT ,
~ter S8IIpUng ~It
... ,~ AI'II8
~
40
90 01/22/81 EUl8flia Zorldt EPA I..ion 9 Fourth Weter Gu8 U ty Sallpli nv 150
J- McClure Round Report R..-dlat Investi-
N.rdlng L_on Auoc:. I18rlon F..ibH ity Study
Mlddlefield-Elli..Whi..-n Area
91 01/22/81 Nardi", L_on Assoc. EPA Fourth Werer Gu8Uty Sallpl i"9 360
RCUId RtIp)rt Re88dial ,Irwesti-
I18rion Feesibitity Study
Middlefield.Ellis.Whisman Area
92 01/22/87 Terrence Mdt... Glem Cfstner ResponM to EPA'. C~t on 18
Intel EPA Ration 9 OeteM8ination of a Clean Well
Letter of 12/24/86
93 01129/87 Cent M. Citdlingll8n Aluis Str..s. Rwi.. of ANllytic.l Oau 325
EPA Ration 9 EPA Ration 9 Gu8l i ty A88urance RtIp)C"ta
1/6 through 1/29/87
Separate Attach8ents
94 02101/87 Canonie ErNi~tal EPA R..;on 9 . Tedlnfcal M80 DW6 Well 150
Cluster Inst.ll.rians MEW Area
Re88dlal Investigat;on
Feasibility Study
9S 02/04/87 Glem leistner C.R. Bostic Request for aound 3 Laboratory
EPA R..ion 9 FairdtHd Oara
96
02/05/87
Glem Cistner
EPA l..iOl\ 9
Midt..l Rosa
ltaydMon
Inr.,.;. R-.:Iial Measures
9
V7
02/06/81
C.I. Io8ttc
FalrdtHd
Gl8m IClatner
, EPA Rellon 9
Mountain VI.. ll/lA/FS
Sc:Mdul..
2
98 02110/81 Cent CI tdth...., J- Grow levi.. of ANlytical Data, 60
1''' Ration 9 1''' Ration 9 QUll I ty A88ur8nc8 Itepwrs
213/81 dI", 2/10181
Sep8rate 'epwts
99 02/13/81 E.I. Bost;c Gl8fW\ Cistner Oerafled Feasibility Study 4
Fai rdti ld EP" Ration 9 Anll.,.is
-------
IIIYISICII OAT!: rt5/22/89
PAGE: 10
"tddlefteld.Ellla.~t888n Area SUperfund Site
*'-'t.tn vt_, Callforrd.
- Adlltntatrnt". lacord I'" -
QQC ,
-
1C-
OATE
02I1J/81
~IZATICII
Cra', ¥In ......
c:-. D,...,. & MdC.. Inc.
TOIOlGAJlIZATlCII .
lilem lelat,.,.
EPA I..ion 9
DESCII PTICII/SUIJECT .
lev'- of. leytMan Interf.
l...t.1 M88aure(a)
~
3
101
rJ3/oo/81
Golder Aaaoc.
18'(d\eon
Interf. l.-eIf al "'..ures
Voh.. I
300
102
03/00/81
Golder Assnc.
Raytheon
Interf. Reaedial Measures
Vol~ II
1.00
103
03/02/81
C.R. Bostic:
Fai rchild
Glerr. leistner
EPA Region 9
Tr8ft88itt~1 Sfltec Area Water
Quality Data Mountain View, CA
25
104 03/05/81 C.R. Bostic: Glenn Itistner Add8ndus to Tec:tlnical Meno: 250
Fairchild EPA Region 9 Short.and long tera Aquifer
Tests R.-eIfal Investigation
F...ibillty MEW Study Area
1" rJ3/11/81 Glem lelatrler C.I. laatic Potential cOnduits EVIIluation 8
EPA R..ion 9 Fai rchild (-Deciaion Tr"')
106 03/23/81 Ste¥O Oobr;jevic: C.R. Bostic: Status Report Fairchild 125
Phillip AntG888ria F.; rdlild -"'tain Vf.. Faci lHy 1./1/86
Canonfe Env;ronaental through 12/31/86
Vol. J
107 03/23/81 St8¥O Oobrijevic C.R. Bost;c: StatUS Report Fairchild 300
Phfll.p AntG888rfa Fairchild -"'t.in v.... Facil I ty 4/1/86
Canon,. EIw'ror88\tal through 12/31/86
Vol. 2
I 108 rJ313O/81 Gl... If8tIW C.I. "tic leqwst for I"'" 3.5 and 4 3
EPA I8ifen 9 Fa'rdlild l8D0r8tory D.t.
..
109 04/00/81 Meredith loll r. Aasoc. ~ PIP Search Mcu1tain 300
vi.. Sita April 1981
voh.. I
I 11 04/00/81 "-"edith Iol i r. Assoc. Expanded PIP Search 250
Mcu1ta;n VI.. Site
Aprn 1987
-------
I£VtSJOII DATI!: OS/22189
PAGE: 11
Mfddl.ff.I~Eltf.-Whfa..n Ar..' SUperfund Sfte
~afn Vf... CaUfornfa
- Adlfnl.cncfw lecord Inda'-
,~
111
WI
04/f11J87
-IftHMIZATIC11
Gtem c.~
EN lei'" 9
TOICIGAIII ZA TlCII,
C.I. "tfc
'.i rdltld
DlSClIPT ICII/St8.lECT
188U", of Potentlat ~ft.
e!S£
3
',2 04/08/87 Ted SIItth Iobti't P. Stem Mountafn Vf.. Cleanup 2
Sit Icon Valtey Toaics EPA I..ion 9
Coelltfon .
"3 04/'0/87 , .Iosftua I.' ,to,.. fit em Kfstner four lef. No. T-'-3 .2
Melter, Ehr88n, White' EPA Reiion 9
McAul f ff.
1110 04/13/87 Micll..t ,Kent RoO Stern I"teri. Cte... ~ p,....t 2
Citizen8 for a letter EPA R..ion 9 by Ir,theon IbI'tain View
Envir~t
115 04/13/87 C.I. IIo8tic GteNt Kistner Data Verification of S8Rple 2
'.1 rdlild EPA R..ion 9 lcanM
116 04/13/87 .1-- I. ftO&.- Gtn lef atner I8ythean SIurt"Y wall 2
MeUer, Ehr88n, White EPA I..fon 9
, McAul fffe
',7 05/12/87 Jeff Zelltson Mich..l R088 Interi. R-.diat Measures 2
EPA R..ion 9 laytheon
i
118 05/19/87 .1oM Meat8r88n Gtem leiatner Tr8n88ittat Laboratory Data 3
Intet' EPA legion 9 VaUd8cfon water Guetfty ~-
U'" I..... 3.5 & 4
II/FS MEV Area
"9 06/05/87 "'f t t f, "UI8t.. I8ytheon ICaaa 18PD'"t: wat.. Guellty 250
L..t. CIIIMIr snd wec.. L8'i8t Data ~ry
lIII",f", ...... Assoc.
i '20 06/12/87 .1oM Meater88n Gtsnn Klatner Tr8N8iual Selected Orpnic 200
Intel EPA I..ion 9 & lnorvenlc OI8lcela
III'S MEW A....
'21 06/26/87 Golder A88OC. Steaa Report SOf t Iori", and 250
Monltori", well PrOlr-
-------
, . .
UY!SICII DUE: a5IWtYi PAG£: 12
Mfddteffel~Ellfa-Whf888ft Are. Superfund Site
-..cafn VI.., Cel tfomfa
-- AdIIinlatratt". lecordlndu -
s.! 2m FICII/CIIGMIZATICli. TOIOIGoUII ZA TICII DESClI'TICli/SUIJECT PAGES
1:.t 06/29/87 .Iutl. TurN"88 Intel, 18ytMon " Fafrdlf ld Mcu'ltafn VI.. Well 18 MY18 30
.... tl tip ,. t88t8t" ~tff8t" T_t lEV Study Area
I18rdt", "-' Auoc. Mcu'ltaln VI.., CA
Vol. I
123 06/29/87 Harding LM8CIn Aa8OC. Intal, leytheon" Fairchild Mcu'ltain Vf.. Well 18 (MY18) 400
~fff8t" Test (MEW) Study Area
Mcu'lt8in Vi.., CA
vol. II
1124 06/29/87 Anthony Burgess Glenn Kfstner Deep Soil Irwntfl8tion 365 20
;;older Asaoc. EPA Region 9 Eat Middlefiled R~
Mcuttein VI..., CA
!125 06/30/87 .11111eS M. Ol iver Glem Kistner Intel Soil 80ring Dau 2CO
Phillip FitzM8ter EPA Region 9 Mcutuin Vi..., CA
Harding LM8CIn Assoc.
126 07100/87 Middlefield-Ellis.WhiS88n EPA Region 9 RI Vol. 1-3 " 9 Doc. , Vol. 2- 2102
COIIIIp8n i es 8 Revised Materials in Record
(Vol. 4-8 Aveil. atMt. Vi...
Public Lib. " EPA Region 9.)
1127 07/21/87 Glem Kiatner .10M ....c...... ~ftiONIl Deep Monitoring 2
EPA Region 9 Intel Wells
I
!128 07/21187 Phillip FitzM8ter MichNl Rosa Tr8ftS8ittal of Final Pha.e III 225
Harding LM8CIn Assoc. Reytheon Subsurface Investigation
Report
29 07/2'/87 John Maate,..." Glenn Kiatner Intel Response to EPA '1
Intel EPA Region 9 6/11/87 ~ts on R..aial
lnwstigetion .. '
30 08/04/87 .1oM ""t...,. Glenn Kfatner ~ftfONIl Deep Monitoring 2
Intel EPA legfon 9 Well.
I
I
I
I 11 08/04/87. .Ieff Zel i Don D8V8 D..rdorf Vapor Extraction Work 2
I EPA Region 9 Reytheon
,
;2
08/11/87
Kent Kitch;'.."
EPA legiOn 9
., Zi..er
EPA Regfon 9
Revi.. of AnalytfC81 Data
2
-------
r.
IEVISIOII DATE: (15/22/89
29£..!
133
DATE
00/00/00
~IZATICII
Mlddleffel~Elll..Whf888n Are. Superfund Site
l8cu1tetn vt_, CaUfomt.
- Aaltnl.tntfw lecord Indu-
TOIOlGAlIZATlCII
DESClIPT lOll/SUBJECT
Orpnfc OM8ic:al Analvai.
Methoda
PAGE: 13
~
2
-------
-..-- ._--~~- -" --..
""- 110. .' 1
12/29/88
Mtddl.ff.I~£llfs.Whi888ft Ar.. SUperfund Sit.
leaYltain vt-. eel tfomia
ADIIIIISTlATlW IICCID lax
SI4IPt~t 10. 1
DOC. , DATI FIaVOIGAlI ZA T 1 CII TO/QIGAlIZATlCII DISCI I PT ICII/...,ECT PAGES
----
11114/86 .1- M. GI iwr EPA legion 9 Tedlnicel "-0: Fl'8ftCfa Wel I 85
.1- G. McClure Tf. Sert. T.t II/FS
I18rdf", L880ft
A880Cfat.
2 03/02187 St8¥O Dobrijevie C.I. "tfe Siltac Area W8ter Quality Data 37
c.noni. FatrdtHd
~rwir~tal Se8ieorQctor Corp.
3 11/01/87 Canoni. an-Sit. Concentrations of Metals 26
in GrCuld W8ter
4 12/04/87 Karding.Lawson EPA Occurrence of Anti.."." Arsenic, '87
t.IdI8fui II'Id Lead in P\bl iCly
$8Ipled W8ter ~I y Wells and
W8ter ~ly Syst-. s.nta
Clara County, CA. RI/FS
5 01/04/88 IC' . C\~ c-. Dresur & Elldallge......t AU...."t (Draft) 228
MdC... Inc. '
6 01/08/88 C.R. Io8tic Glenn R. Kistner Ltr: Ad8infstrative Record for
Faf relit ld Corp. EPA Region 9 ROD
7 01/27/88 K.ith A. Takata C.I. Io8tic Ltr: Use the Upper Aquifers (A & 3
EPA Reti an 9 FairdtUd 8) in Mt. Vi...
8 02/00/88 Canoni e EPA Retian 9 Report: RezendeS Well 23~2 '27
~ing Test Faireni lei Mt. "iew
Foc:ility
9 02/04/88 Glenn I. Kistner C.I. Io8tie Ltr r.: Ad8iniatratfve Record
EPA Region 9 FafrdtHd for the She
10 02/08/88 .1- .Iuperae Raytheon Soil Vapor Extraction Study 260
Dwtd P. IIocI8rth
ItIIrdt", L880ft
11 03/03/. . ~ts L. CUrran Glenn I. Kfstner Ur: Nanftorfng Well Locations 4
c:.nante EPA legton 9 end Scr'88ft Int8f'V8ls. Addftionel
.1. WeUsllorth of 1eyMor.
12 03/10/. C.I. "ttc Glenn I. Kfstner leport: Potenttal Condutts Study 71
Fatrchild EPA Regton 9 end R-.dtation BouGry
-------
Page 110.
12/29/88
, 2
Middlefield-£llfa.Whi-..n Ar.. Superfund Site
-"tai" Vi.., CIII ffomla
ADIIIMISTUTIVE lEaIID IIDEX
~l~t 110. 1
DOC. .
DATE
FlClt/CltGAMI ZA T I 011
TO/CIGAIIIZATI011
DESClIPTIOM/SUlJECT
PAGES
13 03/11/88 Intal, F.irchlld & IPA Region 9 S.lec:tion of Metala of Concern 19
Reythecn
14 03/11/88 Intal, Fairchild & EPA Regfon 9 ~ta on the 1nd8nge,.."t 7
Reythean Aaaes888nt
15 03/24/88 Eric G. L8AI8la "Intel, F.f rchitd & Ltr: COM Modeling for the IIIFS 7
Harding L_on Reytheon
16 04/01.188 I,.;c G. Lappel. Intel, Fairchild & L tr: 313/88 Neeting with c)M On :s
Hardf ng Lawaon leytheon Model ing For the RIIFS
17 01.105/88 Glenn I. Kistner C.I. Bostic Ltr: EPA leview of the 7
EPA legion 9 Fai rchitd '''Potential ConciJits Study and
R~I at i on 8oI.n8ry leport",
3/88
18 01./05/88 C.I. Bostic Glenn I. rf.tner Ltr: CoIIputer ModeU ng for the 3
Faf rch i ld EPA Region 9 .ite
" 04/06/88 J... G. McClure C.I. "tic Ltr: su..ary of Actlvitfes for 2
Harding'LW8on Fairchild 3/88
20 04/14/88 Cllnanf. EPA legion 9 W8ter Gu8l.fey Test lesult. 18
21 04/15/88 Dennis l. Curren C. lobert Bostfc ltr: Monthly Status Report 3/88
Canonie
.22 04/25188 Glenn I. Kistner George IiUllaoe Ltr: DaCa Validation
EPA legion 9 ReytMon
23 01./27/88 John M8at~ Glenn I. riatner Ltr: Responae to Specific II (,
Intel, EPA Region 9 Report ec-nts b'f EPA
24 05/09188 C.I. Bostic loger 8. J88S Se8i8nnU81 Status leport: 180
Fairchild .egi _1 Water Fairchild 7"'87 . 12/31/87
Gu81 fey Control
..rd
. .
25 05/18/8 ILenn I. rlacner G8orI8 Gull... Ltr: .~Ul'" To ~f.., 3
IJIA _eglon 9 R~ Latter on Grcua.ter Modeling
26 OS/20/88 CMi" Ping ho Helen MClClnley Ltr: Stat. AIAIS for the afte 5
~"S EPA Region 9
-------
._----~--~._~~~--~---~.
"...e No.
12/29/88
.3
Mfddleffel~Ellis-Whil88ft ~re8 Superfund Site
MowIt.fn Yf_. c:.Ufomi.
MlltI.JSTIATiVI UCDD IIIDD
~l~t 110. 1
g.x. ,
DATI
~GAlIZATIOII
TO/GIGAII I ZAT 1011
DlSClIPTIOII/~ECT
PAGES
27 06/14/88 Eric G. l~la . Intel. Fairchild' Ur: lequi~t. for AdditiONIl 4
llerdi,. l-.on 18Ytheaft InfOl"8tfon to ~tely I..,....
Gf'OIftt-weter Flow 8nd fr_port
Model i,. Perfor8ld by Q)M
28 06/15/88 GeorIe A. Gullege Glenn 1- Kistner Ltr: II leport - 6/15/88 3
18Ytheon EPA I...ion 9 I..,ision 11/':$
29 06/24/88 Dennis L. Curran C.I. Bostic Ltr: InfOl"8tion Needed on Cl)M
Cananie Fai rctlild Silva ~ll Model
30 07/05/88 C.I. Bostic Glenn R. Kistner Iotr:. CDM Model i,. Reports 2
Fa, rctlHd EPA letion 9
31 07/11/88 George I. Gullitge Glenn I. Kistner L tr: Preli.inary 18SJIO"Ses to 13
R8'(ttleon EPA leti on 9 EPA ec-enu on FS
32. 08/08/88 Ptt'l Iobel George Gullege Ltr: Approval Of 6/15/88 RI 2
EPA lesion 9 18Ytheon lepwt
D. 08/12/88 Glenn I. Kistner George Gullege L tr: CaIIp Dresser 8nd MdCee's 3
EPA lesion 9 18'(theon GrCUldweter Model i,..
34 (19/02188 ICF . Cl~t. CaIIp 0"""".' MdC.. Erd8nger-.t ~t 215
35 10/12/88 c. I~ Bostic SteYeft I. Ritchie S..,annual Status Report: 123
Fairchi ld letional water Fairchild 1/88 - 6/88
Qual i ty Control
Board
36 10/21/88 C8IIp Dresser & MclCee EPA Evaluation of Potencial Conduits 22
in the Local SCucIV Area
31 11/01/88 Glenn I. Kistner Guidance D~ts For 2
Ad8inistrac.ve Record
38 11/01/88 EPA Resion 9 Fact Sheet: EPA ~.. 10
prQt:108ed Plan to Clean Up M-E-W
. I Superf&nd Sit..
39 11/01181 c.nanf e 'ai rdltld. Intel' Draft apt: ,...ibil Ity StuclV. 1100
I8Ytheon M-E-W A..... 1ft. Yf_. CA
~~x
-------
Psge NO.
12/29/88
DOC. ,
40
.1.
DATE
11/23/88
. .
Ntddtef;e'~£tlt..Whi888n Ar.. Superfund Site
Ncutt8fn Ylew. caHfoml.
.U..STUtJVE 1ECD8 IIIDO
~t~t 180. 1
FICII/OIGAIIIZATICII
"' fl label
IPA Region 9
. .
TO/CIGAIUZATICII
Georwe Gut I...
Raytheon
OESClIPTICII/~ECT
Ur: AAlrDV81 of ,...fbfl ity
S~ 1epM't for "'1-11 A...., Nt.
Ylew, CA. IIlth Cavuta
PAGES
2
-------
p... 110.
.. a5/7:!/89
IUdendl.tet-lt I f.."'I.., ,......,\ftt Sft.
liIaUtt.ln VI_. CIIt Ifomf.
MlUllllTUTlW llCOB 18EX
~~ Mo. 2
.ATE
DOC. ,
AUfIlOl
IICIPIEIIT
DESClIPTIOM/SUlJECT
PAGES
0.00 Guldllnc. D~t8 for
Ad8lnistr.clve Record
02/01/&6 1.00 EPA-9 IIstionel priorities List (NPL) 28
R-.:Iist Response Sit. Raytheon Corp., Mtn. View,
Progr. CA
02/01/&6 2.00 EPA.9 lIationel priorities List (NPL) 2'-
R8IIedi.t Response Site, Intel Co~., Mtn. View, CA
P"OIr.
02/01/&6 3.00 EPA-9 National priorities List (NPL) 10
R-.:Iial Response Site Fairchild C88era ,
progr. lnat".."t Corp., Mtn. View, CA
05/01/&6 10.00 .- EPA-9 EtWi~cat News: New 2
ConC_inacion FO&n:I in Mtn.
VI..'. Deep Aquif.... "/-.p.
07/07/&6 5.00 Mfchael Kent RoberC Stem ~c. on Fairchild 3
R..arch Assoc. EPA c:-..,i ty Se8fconducCor Inceri. Re88di.l
Clth- for. aetations Action Pl'OpD88l.
letter Environment Coordinator EPA-9
01/21/&6 6.00 thet L8Uchner Clem Kistner C0888nts on -Interi. ReNedial 3
Director - EPA-9 Accions, Fsrichi ld Selllicanductor
Facilities Plenning, Corporacion, Mcn. View Facility
Inc'l 0,.., SUtec - DrafC Report by Canonie 6/&6
Corp
07/~/&6 7.00 Ted SIIlth Robert SCem ~ts on Fairchi ld 2
Executive Director EPA c:-..,i ty Se8ic:onductor Inc...i. Cle8nUP
sn fcon V.Hey Relacions
TOIies CoIticion Coordinacor EPA-9
08/22186 8.00 . I8n'y ser.,a.ri 8ft Cltec L8UChner L tr: a..... to7/Z1 , 08107/&6 2
IN ...ion 9 SHCec Lcr. 8bout Fairchild Slurry watl
10/01/86 8.10 CDM SOH SellpUng , Tn IlW'8fttory 153
DsCs ea.pltaclon.
01/09188 8.90 Di eme MdCenne Glem Kistner Ur: C0888nt on tlte Clean-~
Senta Clara, Ioard EPA R..lon 9 Pl8ft
of ~i8or
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Mtddleftet~Ettla-WhII8l" SUperfund Site
-..uln vt.., C.tffornla
MlMIIIITUTiVI IICCIIDIMDex
Suppt.-.ntNo. 2
I
'I
p... No.
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DATI
ooc. t
MID
IEtlPIEilT
DESClJPTIOM/~ECT
PAGlS
. 02/04/U 9.00 C. Robert Io8tlc Gtenn I. Clltner Interi. Decllion Proc... 7
EPA legion 9 Potentlat ConcaIita EvalU8tlon
Ipt "ltfI COWf" letter
06/01/U 10~OO LorenceD. Wllaon Glenn It. Clltner Ltr: Claeure'of Frenzia , Silva
Santa Clara Valley EPA Itegion 9 wel ls
lIater District
06/15/88 11.00 Glem Kiltner George Gullage General ea..ents on Draft fS for 6
I'" Proj. ~inator MEW Study Area, w/Tl to George
EPA.9 latheon Co. Gul lege 6/15/88
06/22/88 12.00 loge.. . J... ""it ip Iobel C~ts on the MEW feasibility I.
Eaecutive Officer EPA-9 Study b¥ c.nonie 5/3/88
cawcs..SF
06/24/U 13.00 Glem Klltner George Gullage EPA ~I on The MEW 10
It". Proj. Coordinato.., f...lbillty Study W/Tl to George
EPA-' MEV Study ~rea, Gull... 7124/88
18y'tt\8a'I ~
06/28/88 14.00 II£C Electronics, Technic.al Itwl... C08IIInts 21
. Inc. le88dial Investigation Report
Il/fS MEV ",.e., Mtn. View CA
wiLT. to Glenn Kistner 6/28/88.
w/charts & 88PS.
09/00/88 15.00 Gereghty , Mfller Intel ItI/EAlFS Vol. 1-4 with 2000
COWf" letter
09/14/88 16.00 Georte A. Gull... Glenn lefstner Ltr: Cal8ents on Final Draft 2
I8ytMon . EPA legion , ElIdaII"",-,t u...-,t
09/15/88 17.00 Ifck lobbon Glenn lefat.... CADOIfS ~s on MEV Draft fS 2
III. Z . Toale "" l.rt 1116'. !twiafon
.1181tanc88 control EPA-9
Dtvt..,
CADGIIS
10/00/88 18.00 ~I. R$)t: S8IIpl I", 'len AddInI:UI No. 9
2 Watker D..lw Inwstl..tlon
Il/f$
10"3/88 ".00 Georte A. Gut l... Mart .......11 Ltr: A --ry of MV18 ... and 3
lteytMon City of Mt. vi.. -o...,.~ifer Mani torlng
Actlvltl.. with a Dllt..lbutlon
Lilt
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i' -,.-,\."".,,.-
,,,'.,"
p... No.
a5!7j/89
3
IUddteffeld-IUfs."'f~ ~ Sfte
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ADIUIISTUTlW lEaIII) III)£X
S&4IPt-'t 110.' 2
DATE
DOC. ,
AUTU
IECIPIENT
DESClIPTIOI/SUlJECT
PAQS
10/13/. . 20.00 G lem K fa tner G80rte A. GuU... Co¥8f" Ltr of Sallpl f"ll Pl8n 2
EPA legion 9 laythean AddIncUI 110. 2 "fth a
Dfstrfbutfon list
10/19/.' 21.00 Stew Nors. Gl.." Kfstner ltr: Draft FS, 10/07/88 Revision 2
Clt\,QC8 EPA Region 9
10/21/88 21.10 Cl)M Evaluation of Potential Conduits 310
in the Local Stlody Area, IEW
(Upd8te of 5/9/88 O~t).
10/23/88 22.00 Terrence J. MdIIenus Phi l ip SObel Ltr: Request to Caa.ent on
Intel EPA Region 9 RI/EA/FS , Sign Sep8rate ROO
10/25/88 23.00 Bryan N. Rector Glenn Kfstner Intel Mt. View Ground Water Data 850
EPA Region 9 . .... apt. Fraa 10/86 . 7/8/!
attadled "ith Lab Analytical
. apt.. Cowrlette,., Airbill,
Tr8ft88ittal letter
, IOO/8/! 210.00 EPA P\Glic Feet Sheet
11/10/88 25.00 Glenn R. Kfstner George Gull.g- Ltr: Approval of Sa.pling Plan 2
EPA legion 9 Raytheon ~ No.2 Walker Drive
IrMllltfption RI/FS But Not of
Objective of the Plan
11/21/88 26.00 C. Robert Bostic Phil fp IIobel ltr: Intel's RI/EA/'S for Lot 13 2
SdllUliberger EPA Reefon 9 , Concern about Separate Ita)
11/23/88 27.00 Ph il label George Gull... ltr: Approval of Rev;sed FS 2
EPA ...fon 9 I8ytMan w8r 5 Cawats
11/25/88 21.00 8t.... Kfstner Gtenn Stober ltr: Cowl' Ltr of FS for ~t 2
IN ...fon 9 CA Offfce of
P\ennf". , I....n:n
12/01/88 29.00 Georte GuU... Glenn Kfstner Ltr: Canffnl8tfon of the 2
laythean EPA Regfon 9 Sallpt f"ll P l8n AddIncUI 110. ~
Welt... Drfw Il'W'88tfptfon,
II/'S. "ith a Distribution list
12/02/88 30.00 Gl.." I. Kistner George Gull... Ltr: leuse of Groundweter
EPA legfon" 9 laytheon
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p... 110.
fIS/l5/.
4
.lddL8fleld-ELLla-~I..-n SUperfund Site
-.wealn VI_, CIIUfomfa .
M*IIISTUTlW IECOID lIDO
...,l..-nt 110. 2
DATE
DOC. ,
AUT_.
IECIPIE.T
DESCII PTlCll/SILIECT
PAGES
12/09/88 31.00 Gordon C. Atkln80ft o.rid Mc:f8dden Ltr: InteL'a _IIEAlfS Lot 13 & Z
Cool.., Godw8rd EPA _..fon9 s..-r ate ICJ)
CUtro Nuddleaon ..
TatUi
12/14/88 32.00 $us." IIfsbet CC88.II\i ty Meet f "II 81
Cr.,.le .. As.".
12/14188 33.00 Leura T. Tarquinio Glem Kistner Ltr: Co8Ient on the Proposed 2
Lell9U8 of W08In EPA Retfon 9 Cle~ Pl."
Voters
12/14/88 34.00 Michele I. Coraah. - Zi.fer Ltr: Request Extension of 4
Morrison .. Foerster EPA Retion 9 ~t Period an Draft FS
12/21/88- 35.00 '. Water Elevation Rpt~ 52
I
I
01/04/89 36.00 Gordon F. $noM.- . Gl8m Kfatner Ltr: State haa no CG888nts an FS
Th4t'R..ourc..A~ EPA legion 9
of CA
01/04/89 31.00 George A. Gull... Gl8m R. Kfatner $ub8ittal of Technfcal leport an 28
Il'(theon EPA letian 9 Extracted Groundwater Use
01/09/89 38.00 Margaret I. Dollbaua Glem Kfatner Ltr: Litronix lleeds More Tf.. to
Folgor .. Levin EPA letion 9 levi... Draft FS
01/10/89 40.00 George A. Gull... Gl8m I. KIatner Ltr: Propose Inter'. l.-.dial 2
IlYtheon EPA letion 9 ActiON of OW.] Cluster and
Pactfng of Silva well
01/11189 41.00 Ph Il label Terf'W'1C8 .I. Mc:Maru8 Ltr: Ca888nta on II/FS/IA for 2
EPA -..ion 9 Intel Intel Lot 13
01/17/89 42.. "'I L labeL GeOrI8 GulL... Ler: Autborization to ..ark on ItA
IN _..fon 9 I8ytMon at the ow-] well CLuster &
P\IIiping Ind Treec.nt of
. Gr0&rdw8ter. .
01/18/89 43.00 ~ au i188 GLem KIatner . Ler: .0, letIaU of JIASA.... to 2
A88s ....rda C8'1ter EPA ...ion 9 ~t on FS
01/20/89 44.00 D8Vfd C. Keen GLennKIatnet' Ltr: Ca888nta on Draft fS and 3
Air Pr-..cta EPA I..fon 9 Propose Selaction of 188dy for
ttM Sit.
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