United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-93/096
August 1993
&EPA Superfund
Record of Decision:
Applied Materials, CA
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5021'2-101
REPORTDOCUMENTA~ON 1" REPORT NO. ' 2. 3. Reclplenh Acca8slon No.
PAGE EPA/ROD/R09-93/096
4. T"le and Subt"le S. Report Dat. -,
SUPERFUND RECORD OF DECISION 08/25/93
Applied Materials, CA 6.
Second Remedial Action - Final
7. Aut.har(s) 8. Performing Organization Rept. No.
9. Performing Organlutlon N8ma and Addr... 10 Project Ta.kIWoric Un" No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and Addres. 13. Type 01 Repoet & Period CoYeAld
U.S. Environmental Protection.Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Note.
PB94-964528
16. Abstract (Llm": 200 words)
;
The 9-acre Applied Mater~als site is an active equipment manufacturing facility located
in Santa Clara, Santa Clara County, California. Land use in the area is mixed light
industrial, commercial, and residential. The site is located within the San Tomas
Aquino floodplain; and shallow ground water is considered to be a potential drinking
water source. Onsite operations include manufacturing vapor deposition equipment for
use by the semiconductor industry. In 1983, Applied Materials discovered that several
leaks and/or spills from three onsite underground tanks near Building 1 had
contaminated onsite soil and shallow ground water with VOCs and other organics. In
1984 and 1985, as part of interim onsite cleanup activities, Applied Materials
excavated and removed underground tanks, piping, and more than 60 yd3 of contaminated
soil, and installed an air stripper onsite to treat VOC-contaminated ground water. It
,was discovered' during soil surveys that surface and near surface soil was not
contaminated. This ROD addresses the potentially contaminated soil in the saturated
zone beneath Building 1, the utility pad, and the dock at the site. A 1990 ROD
addressed contaminated ground water at the site; however, previous remedial actions
further evaluated the onsite soil contamination and determined that the soil located at
I
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Applied Materials, CA
Second Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement 19. Security Class (thIs Report) 21. No. 01 Pages
None 62
20. Security Class (thIs Page) 22. Price
None
(See ANSI-Z39.18)
SIN/Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerty NTIS-3S)
Department 01 Commerce
-------
EPA/ROD/R09-93/096
Applied Materials, CA
Second Remedial Action - Final
Abstract (Continued)
or near the surface was not contaminateq; therefore, there are no contaminants of concern
affecting this site.
The selected remedial action for this site is no further action. Since the saturated
zone soil is part of the aquifer that contains the ground water, it is believed that the
previous r'emedial actions selected for ground water addressed this contamination" and as a
result, no additional remediation is needed to protect human health and the environment.
There are no present worth or O&M costs associated with this no action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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APPLIED MATERIALS, INC
SANTA CLARA, CA
\
RECORD Of DECISION.
1993 FINAL
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4.
5.
APPLIED MATERIALS, INC
SANTA CLARA, CA
RECORD OF DECISION
1993 FINAL
** * * Table of Contents * * * *
I..
Declaration Statement
2.
Order No. 93-056 issued by the California Regional Water
Quality Control Board, San Francisco Bay Region, June 16, 1993
3.
Staff Report: Internal Memo; Regional Water Quality Control
Board; San Francisco Bay Region; June 4, 1993 including
the Response to Comments .
Staff Report: Internal Memo; Regional Water Quality Control
Board; San Francisco Bay Region; March 1, 1993
Administrative Record Index; Volumes IX, X, XI
January 1991 through June 30, 1993
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RECORD OF DECISION
1993 FINAL
APPLIED MATERIALS, INC
SANTA CLARA, CA
DECLARATION STATEMENT
SITE NAME AND LOCATION
Applied Materials, Inc.; Santa Clara County
Santa Clara, CA
STATEMENT OF BASIS AND PURPOSE
, ,
This decision document presents the selected remedial action
for the Applied Materials Site, located in Santa Clara, CA,
developed in accordance with the Comprehensive Environmental
Response, . Compensation, . and Liability, Act of 1980, 42 U.S.C.
Section 9601, (CERCLA) and the National Oil and Hazardous
Substances Pollution contingency Plan, 40 C.F.R Part 300, 55 Feb.
Reg. 8666 (3/9/90) (NCP). The' decision is based on the
administrative record for the site.
The State of California concurs on the selected remedy.
DESCRIPTION OF THE REMEDY
The EPA has determined that no further remedial action other
than tha~ already implemented at the site is required to ensure
protection of human health and the environment. A remedy for
groundwater contamination was previously selected and documented in
the September 28, 1990 Record of Decision (ROD) for this site.
The earlier ROD did not address cleanup of soils, because
further evaluation of contaminated soils known to exist under
Building 1 and the utility' pad and dock was underway. Further
analysis of the data showed that the unsaturated portion of the
soil located at the surface and near surface were not contaminated
and that the contaminated soils, under investigation at the time of
the first ROD, were in the saturated portion of the soils beneath
the structures. Since these saturated zone soils, which begin
about with feet below the surface, are part of the aquifer that
contains the groundwater, the remedy selected in groundwater
operable unit ROD'provides for remediation of this contamination.
The response action that is underway consists of the following
major components:
a. Continue pumping from the existing groundwater extraction
wells until the Maximum contaminant Levels (MCLs) are not
exceeded;
-------
b. Treat extracted
stripping system;
groundwater
using
an
existing
air
c. continue groundwater monitoring at the site during the
cleanup period;
d. Implement institutional controls, such as deed
restrictions, which will control and restrict the withdrawal
and use of contaminated groundwater and control and limit
activities that could result in exposure to volatile organic
compound (VOC) contamination. Controls and restrictions
within the plume will be necessary until drinking water levels
have been achieved for all VOCs. .
. .
e. Reclamation and/or reuse of 100% of the groundwater that
is extracted and treated is a goal of this remedial action;
f. Discharge treated water off-site to a storm sewer system
tributary of San Tomas Creek pursuant to an NPDES permit.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health" and the
environment, complies with federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent
solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable and satisfies the
statutory preference for selecting remedies that employ treatment
as a principal element and that significantly and permanently
reduces the toxicity, mobility, or volume of the ,hazardous
substances. .
A review of the remedial action will be conducted within five
years of implementation of the remedy to insure that the remedy
continues to provide protection of human health and the
environment.
8,25, q~
Date
,.
~W\4A-
ohn Wise, Acting
Regional Administrator
EPA Region IX
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CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
ORDER NO. 93-056
AMENDING ORDER NO. 90-134 WHICH AMENDED ORDER NO. 89-167, SITE
.~
CLEANUP REQUIREMENTS FOR:.
APPLIEDMA TERIALS, INC.
3050 BOWERS AVENUE BUILDING 1 FACILITY
SANTA CLARA, SANTA CLARA COUNTY
The California Regional Water Quality Control Board, San Francisco Bay Region
(t:1ereinafter called the Board) finds that:
1.
Applied Materials, Inc. (hereinafter called the Discharger) has filed acceptable
deed restrictions for the 3050 Bowers Avenue Building 1 facility as of June 10,
1992 with the Santa Clara County Recorder.
2.
The Discharger submitted a January 28, 1991 "Annual Progress Report -
. Disposal of Extracted Ground Water, for Applied Materials Building 1, 3050
Bowers Avenue, Santa Clara, California", and a July 1, 1991 "Addendum-1991
Annual Progress Report -. Disposal of Extracted Ground Water, for Applied
Materials Building 1, 3050 Bowers Avenue, Santa Clara, Cal.ifornia", concerning
groundwater reuse/reclamation and concluded that extracted groundwater
could potentially have some onsite industrial application, but costs of reuse
would be prohibitively high and reuse is not economically feasible. The reports
stated that treated groundwater would not be accepted by a publicly-owned.
treatment works and that reclamation by groundwater re-injection .was costly. .
and of small benefit. . ....... .
3.
The Discharger reports that some operations will be moved out of Building 1
but the equipment pad will remain in use and it will not be feasible to remediate
soil beneath the pad or building.
4.
The analyses of groundwater samples have verified an interval of volatile
organic compound (VOC) pollution in groundwater below the A-aquifE~r sand
near the. source area. The VOCs were first detected in 1990. Historically the.
maximum reported concentrations in well AM 1-10 (Figure 1) were 60 parts per
million (ppml 1,1, 1-TCA on September 11, 1990, 4,8 ppm 1, 1-DCA. on
January 3, 1991, and 2.7 ppm 1, 1-DCE on September 11, 1990. This deeper
interval is not controlled by groundwater extraction wells AM 1-1 and AM 1-5E.
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7.
8.
The Board believes that the Discharger's estimated time required for the
Discharger's proposed remediation to achieve cleanup standards .is optimistic
for the following reasons:
a.
The effect of on-going groundwater extraction on the source-area A sand
cannot be directly verified because there is not a well into the A sand
directly beneath the source area; and, the A sand in the source area may
require a long time for remediation by groundwater extraction by a well
outside the source area. Well AM1-EP which was constructed above the
A sand has provided data on the effectiveness of groundwater extraction
.. at the source area from 1985 through September 3rd, 1991. Although.
concentrations generally decreased during this period, showing declines
from 370 to 0.180 ppm for 1,1, 1-TCA, 13 to 0.043 ppm for 1, 1-DCA,
and 19 to 0.034 ppm for 1, 1-DCE, concentrations of 1, 1-DCA and 1,1-
DCE were still above MCLs of 0.005 ppm and 0.006 ppm, respectively,
when the period ended.
.'1 .
b.
As suggested by geohydrologic and chemical data from well AM1-10, a .
potential but yet-unidentified source of vacs in the A zone may exist,
and may be dense non-aqueous phase liquid (DNAPL) vacs. If DNAPL
vacs are present they most likely will not be remediated by groundwater
extraction but, depending on the quantity and concentration, could
continue to release pollutants to the groundwater for many years,
perhaps longer than the time estimated for remediation by the
Discharger. .
c.
The vac pollution in the silty clay at the AI A2 interface may desorb
slowly into groundwater and increase vac concentrations and the time
required for remediation.
d.
The "tailing effect" associated with groundwater extraction which has
been found to extend the time to achievegroundwater'cle.anup. .
The Board is willing to accept the Discharger's proposal for the following
reasons:
a.
The equipment pad and Building 1 are expected to remain operational for
an unspecified period; the remediation of saturated soil under the pad
and building will be costly to Applied Materials and may have limited
effect on site cleanup time. Consideration of any requirement for the
direct remediation of this polluted soil will be deferred until the five-year
status report is reviewed. and the efficiency of the extraction system is
evaluated.
3
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9.
10.
11.
e.
b.
A deed restriction to restrict the installation of wells on the property and
disturbance of the soil by excavation by any future owners is in place
and will remain in place until cleanup is accomplished.
c.
Groundwater monitoring and reporting requirements will continue.
d,.
The existing Order requires the Discharger to maintain physical, control
of the pollutant plume. ..
..
The Board will make a detailed review of site remediation at the end of
five years, concurrently with the submittal of the Discharger's 5-year
Status Report due October 1, 1994. The 5-year review will include a
detailed evaluation of groundwater extraction and monitoring to show
that cleanup standards are being achieved in a timely manner.
f.
If extraction alone is not effective in remediating site pollution in a timely
manner, the Board can modify requirements of this Order.
This action is an Order to enforce the laws and regulations administered by the
Board. This action. is categorically exempt from the provisions of the CEQA
pursuant to Section 15321 of the Resources Agency Guidelines. .
The Board has notified the Discharger and interested agencies and persons of
its intent under the California Water Code to amend Site Cleanup Requirements
and has provided them with the opportunity for a public hearing and an
opportunity to submit their written views and recommendations.
The Board, in a public meeting, heard and considered all comments pertaining
to the discharge.
. .
IT IS HEREBY ORDERED, pursuant to provisions of theCaldornia Water. Code and.
regulations adopted thereunder, that the Discharger sha'il comply with the following:
1.
SPECIFICATION 3 in Order No. 90-134 is changed as follows: the final cleanup
standard for 1,1 ,2-trichloroethane (1, 1.2-TCA), based on-- the Californi,a.
Department of Health Services Maximum Contaminant Level (MCL), currently
is 32 parts per billion (ppb). not 5 ppb as shown.
The U'.S. EPA has adopted a drinking water MCL of 5 ppb for this chemical,
and a ry1aximum Contaminant Level Goal (MCLG) of 3 ppb. both of which will
be enforced beginning January 1994. From Findings of the previous Order, the
groundwater cleanup standard for 1,1,2- TCA at this site shall be 3 ppb in
1994.
4
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2.
PROVISION 6 is modified to include the following:
The annual report due March 15, 1994 shall be acceptable to the Executive
Officer and shall include the results of an evaluation of groundwater extraction
and monitoring to show that (1) extraction wells AM 1-1 and AM 1-10 can and
do remediate the A-zone and A2-zone groundwater pollution in the source area,
and (2) extraction well AM 1-5E does hydraulically contain the pollutcmt plume
6nsite and prevents VOCs from migrating offsite. .
This evaluation shall include but not be limited to:
a.
Verification of the concentrations of VOCs in the A-zone aquifer;
b.
Determination and documentation of the change of A2-zone groundwater
pollution;
c.
Discussion of the probability of the presence or absence of DNAPL in the
. A and A2 zones; and,
d.
A review of the disparity in geological interpretations of the A zone
between the Applied Materials Building 1 site on one side of Bowers
Avenue and the Avantek site on the opposite side of Bowers Avenue,
and correlation to show the relationship between the A zones of both
sites; and a discussion of the potential influence of A2-zone groundwater
on the VOC pollution detected in Avantek well A V-1 B. . .
Following a review of. the annual report and appropriate comments, the
evaluation shall be utilized to prepare the 5-year status report to be submitted
no later than October 1, 1994.
1; Steven R. Ritchie, Executive Officer, do hereby certify that the foregoing is a full,
true and correct copy of an Order adopted by the California Regional Water Quality
Control Board, San Francisco Bay Region, on June 16, 1993. .---
Steven R. Ritchie
Executive Officer
. .
5
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WEISS ASSOCIA TĢS V m
. .
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.
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0AMI-PI
Figure I
transformer
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AMI-10
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.
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transjOrmer
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generator ..
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transformer
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scrubber
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EXPLANA TlON
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0AMI-PI
Borehole
Piezometer
4.97
Highest total VOC
concentration, parts per
million (ppm)
fan
"
....... 1
Total VOC
jsoconcentration contour,
approximately located
Total VOC Concentrations Greater Than Ippm in the A/A2-Zone Confining Layer at Applied Materials
Building 1 Equipment Pad
7I23/Q:O
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REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
INTERNAL MEMO
TO:
Steve Mors~, Chief
SBT Cleanup Division
Dat~: June 4, 1993
.'
Greg Walker
Section Leader
FROM:
Tony Mancini
Asso EG () J ,~'nu
SUBJECT:
Responsiveness Summary: Staff R~spons~s to Comments Received
Pertaining to Tentative Order Am~nding Ord~r No. 90-134 Which Amended
Order No. 89-167, Site Cle.mup Requirem~nts For Applied Materials, Inc.
3050 Bowers Avenue Building 1 Facility, Santa Clara, CA
EXECUTIVE SUMMARY
Comments were r~c~ived only from Applied Materials (Discharger) during the legally
noticed 30-day comment period (April 14 - May 14, 1993). All comments have been
addressed and described below.
The Discharger's main concern was that Applied Materials would be required to perform
new field investigation work (borings, wells, etc.). The Order and amended RAP does not
require additional field work. The revised Order and RAP do require Applied Materials
to continue to confirm its conclusion that groundwater extraction will clean up the site's.
groundwater and soil po\1ution in a timely fClshion by collecting. and ana\yzingda.ta from.
existing wells. The Discharger's other "lain concern WLIS that neither the Board nor Board
staff has predetermined whether any additional wells, boreholes or soil rerilediation will
be required in the future. While neither staff rior the existing Board can speak for future
Board actions, Board staff finds that if circumst,mces chLlnge at a future date (e.g. risk,
etc.), requirements may also ch.mge,either by Board direction or Discf1argerIRP request
and Board concurrence. There is no intent to require future changes at this tirile.
Technical comments were received concer.ning four broad technical issues (brief staff
responses are provided below, detail~d r~sf'0ns~s an~ provided later):
.
Suspected (by staff) pr~st'n(t' of dense nlJn-;1qul'lJUS ph;1st' liquids (DNAPLs).
Response: Staff still SLlSpccts tl1(' l'rc~cl1(c 0," DNAPLs, II/It agrees that finding tl1ml is
impractical at this timc.
-------
.
Further characterization of the source area. .
Response: The suspected source area lacks dl't.'p borings or wells beneath the former
tank becnuse of lnaccessbility. BeCQ,use of the relatively small size of this
volume and area and the apparmt impracticnbility of access, this lack of
. data is considered acceptable. .
.
Discharger's cleanup time estimates.
Response: The estimated cll't111UP times still appear optimistic to staff compared to
." . other similar sites in. tile South Bay and dsewlu:re. However,. if .tile
disdmrgrr is right, the site will be cleaned up earlier than staff expects.
.
Downgradient offsite VOC migration.
Response: Staff is concerned that some of the pollutants are still not under control and
halle been and may still be migrating downgradient across Bowers Avenue
on tile Avnntek site. Till' Order requires further geologic evaluation of
available information to document control.
Comments on Findings and Provisions of the Tentative Order were also received during
the comment period. Respom;es have been provided to Applied Materials on all specific
comments. None were considered significant. Numerous other minor comments were
received concerning the Staff Report. None were considered significant. Some were
addressed by responses to earlier comments, others were addressed by reformatting the
report organization, and some were not adopted. Most of the comments were minor
wording changes. In staff's opinion, there are no outstanding, significant, unresolved
issues remaining from the comments received during the comment period.
lNTRODUCT10N
Staff introduced the subject Tentative Order (TO) at the Regional Board Meeting of April
21, 1993, for the purpose of making the proposed Order available for comment, and
publicizing the 30-day public comment period' which began April 14 qnd ended May 14,.
1993. The Board issued Fact Sheet N(). 4in April, whi~hprovided a description qf the
proposed. minor revisions to the cleanup. plan along with-relevant. background
information. A local public meeting and open house was held in Santa Clara the evening
of April 21, 1993. (A newspaper advertisement for the Board Meeting and the local public
meeting ran in the Santa Clara zone of the S"1l Jose Mercury News-oil April 14, 199..3..)
On May 3, 1993 Board staff met with Applied Materials representativt:'s in Santa Clttr(1 to
discuss the TO, and toured the Building 1 fa.cility. A meeting was held in Board ()ffices
in Oakland on May 6, 1993, to discuss issues of a technical nttture. After this meeting (1nd
prior to the close of the public comm~nt period, we received four written submiU41ls from
Applied Materials which require responses. No other comments were received. The
submittals were:
'"I
....
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1.
2.
3.
4.
Revised TO from Weiss Associates, Applied Materials' technical consultant.
Letter from Applied Materials' legal counsel.
Letter from Weiss Associates.
Revised Board Staff Report from Weiss Associates (the second of two
revisions of the Board Staff Report submitted by the Discharger).
Staff responses are presented in the same sequence as the submittals identified above.
. .
.~
COMMENTS AND.5TAFF RESPONSES.
Revised Tentative Order
1.
Comment. In Sb, Discharger suggests the following word changes in the first line:
strike "up to" and replace with less than. .
Response. Staff agrees with the suggested change.
2.
Comment. In Ba, Discharger suggests the following changes:
Add, following "will be costly to Applied Materials" (third line), the phrase, and
have limited affect on site cleanup time.(period, end of sentence) .
Delete original "and" following "Applied Materials", and add beginning of new
sentence, Consideratio,n of, before "any requirement form-------".
Response. Staff agrees to the suggested changes, with the addition of the word
"may":and may 'have limited effect (affect) on site cleanup time.
3.
Comment. ]n Bc, Discharger suggests adding one word, will, between
"requirements" and "continue".
Response. Staff agrees with the sugg~stedchahge.
4.
Comment. At the top of page 4, Discharger makes a spelling correction.
Response. Staff agrees with the correction.
No other changes to the proposed Tenti'ltive Order h<1ve been sugg~sted.
3
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Legal Counsel Letter
1.
Comment. The May 14, 1993 letter states an understanding by Applied Materials
. that:
a.
The Tentative Order is intended to require Applied Materials to confirm its
conclusion that groundwater extraction and treatment will clean up the
Site's groundwater and saturated soils in a timely fashion by collecting and
analyzing data from existing weBs~ .. .. . ...
."
b.
The Order is not intended to require Applied Materials to install any
additional weBs nor to drill any additional boreholes.
c.
Neither the Board nor the Board staff has predetermined whether any
future weBs, boreholes, or soil remediation (other than through continued
pumping and treatment of groundwater) will be required in the future. .
With this understanding and in light of changes discussed and agreed upon,
Applied Materials wiB accept the Tentative Order as revised.
Response. Staff agrees with the Discharger's understanding pertaining to the
Tentative Order. The intent of "c" above is unclear. If circumstances change at a
future date (toxicity, risk, etc.), requirements mny nlso chnnge, either by Board
direction or DischargerlRP request and Board concurrence.
Weiss Associates Letter
The May 14, 1993 letter identifies four technical issues discussed in the Board Staff Report.
(Internal Memo dated March 1,1993) which the Discharger feels are not supported by site
d~a: .... . . . ..... . . .
1.
-. Dense non-aqueous phase liquids are .suspected at the site.
2.
The source area is not adequately characterized and may need additional
saturated soil remediation. .- --- ..
3.
Applied Materials cleanup time estimates are optimistic because of several
factors, including DNAPLs and "tailing effects". .
4.
Further investigation is needed to characterize downgradient VOC
migration along Applied Materials and AV
-------
The Jetter then discusses three Findings and one Provision of the Revised Tentative
Order: Findings 6, 7 (b, c, and d), 8 (a); and Provision 6 (2d). Attached to the letter were
copies of the Discharger's latest graphs of Relative Concentration vs. Time, for 1,1,1-TCA,
1,1-DCA, and 1,1-DCE, in wells AM1-1and AM1-SE. (Two assumptions are: well AM1-1
represents a well in the former source area, and well AM1-SE represents a well in the
non-source area; and, the non-source area well should clean up (reach MCLs for all
VOCs] before the former source-area well cleans up.) .
Staff responses are made to the specific comments in the letter, as follows:
~ .. .. .
1.
Comment. The RWQCB JnternalMemo presented four interpretations or
conclusions the Discharger feels are not supporkd by site data.
Response. Staff will address specifics (below) as presented.
2.
. Comment. With reference to Finding 6 of the Revised Tentative Order (RTO), the,
Jetter infers that, the rationale for the Discharger's proposal that no additional soil
remediation be done, should be presented in ,this Finding.
Response. Finding 5 of the RTO,presents the Discharger's determinations based
upon the completion of a site soil investigation in 1992, after previous Board Order
90-134 was adopted. Finding 6 reiterates the Discharger's qmclusions made in the
report of that investigation. Staff does not agree that a more detailed explanation
of the Discharger's rationale is necessClry in Finding 6.
3.
Comment. . With reference to Finding 7b, the letter states that no site
characterization data directly-indicate the presence of DNAPLs; and if DNAPLs are
present, the effectiveness of groundwater extraction depends on their quantity,
concentration, and subsurface conditions.
Response. The presence of VOC DNAPL has .not been reported by. the Dis.charger
but staff suspects the possible'. presence. ()f VOC DNAPL based on the reported
results of the U.S. EPA's re-evaluation of a number of Superfund Sites nationally
and locally, and the application of EPA-developed criteria to this site.
The VOCs at this site, if in the free phase, are denser (heavier)~than-water colo'i'less
Jiquids not easily identified by visual observi'ltioll in saturated soil or water samples
recovered from borings and wells. Board s~aff began to suspect the presence of
VOC DNAPL when high amounts of VOCs were found in groundwater from new
well AM1-10, near the former source arei'l, in 1990. The top of the extraction
interval at 28-37 feet in AM1-10 is about 4 feet deeper than the base of the
extraction interval in downgrildient well AM1-1, and Clbout 12 feet deeper thCln the
bottom 'of AM1-EP (extrilctio!1 pit) in the former Source areil. Total VOCs in sever<1/
soil samples ti'lken from the extri'lction interv<1/ in 'Well AM1-10 were ND (2
5
-------
samples, one at 31 feet and the other at 35 feet), 0.01 ppm (1 sample at 33 feet), and
0.68 ppm (1 sample at 28 feet); total VOCs in one soil sample. of silty clay at 26 feet,
above the top of the extraction interval, was about 5 ppm. One of the goals of the
most recent soil survey was to attempt to determine the locality of the source of
the high VOC concentrations found in groundwater by we)) AM1-l0; however, a
local source was not identified. It has been postulated by the Discharger that well
AM1-l0 pu))ed VOCs into the we)) bore from elsewhere (in the former source
area), an unidentified "hot spot". (It has been reported by theConsulta~t that all .
,soil samples from borings made in the A2 zone in the near-source area as part of.
the most recent soil investigation were carefully inspected .lor DNAPLs but none
were noted.) . . . .
Following an EP A-sponsored DNAPL workshop in 1991, the EP A published the
report, "Dense Nonaqueous Phase Liquids--A Workshop Summary" (EPN6001R-
92/030, February 1992) in which it is concluded that: (1) failure to directly observe
DNAPL at a site does not mean it does not exist; (2) often, only very low aqueous
concentrations of DNAPL constituents are detected in monitoring wells at known
DNAPL sites; (3) if dense, free-phase chemicals were widely used, handled, and
disposed of according to standard industry practices common more than several
years ago, chances are high that DNAPL is present; arid more.
The EPA issued several other documents, including Oanuary 1992) Publication
9355.4-07FS, "Estimating Potential for Occurrence of DNAPL at Superfund Sites",
which provides several decision charts usdul for indicating the potential presence
of DNAPL. Decision Chart 1, "Does Historical Site Use Information Indicate
Presence of DNAPL?", uses a flowchart to arrive at a logical answer. It identifies
industries with high probability of historical DNAPL release, industrial processes
or waste disposal practices with high probability of historical DNAPL release, and
DNAPL-Related Chemicals including Halogenated Volatiles (l,l-DCA, 1,1-DCE,
1,1,1-TCA, and others). Site use information: electronics manufacturing; solvent use,
storage and disposal (undergroundacid-neutralizatiot:\ system tankS); and DNAPL-. .
related chemicals, indicate the presence of DNAPLat the BuildiDg 1 facility, by use
of Decision Chart 1. . . .'. ..... . .
Decision Chart 2 is, liDo Site Chilrilcterization Datil Indicate the Presence of
DNAPL?" This chart uses physical data, such as: methods to 'confirm DNAPL.in
wells and soil samples; conditions that indicate potential for DNAPL based on
laboratory data; and charactefistics of extensive field programs to help indicate the
presence or absence of DNAPL. Bilsed on reported information, DNAPL hils not
been visually identified in water or soil samples, and field programs are not kmw,:n
to have been designed to help indicate the presence or absence of VOC DNAPL
at this site. Based on laboratory data, at least two of four conditions cited on CheHt
2 thJt indicJte a potentiill for the presence of DNAPL may exist at this site:
conct:'ntrations of DNAPL-rdilkd chemicals in groundwilter art:' > 1 '}:, of purL'
6
-------
phase solubility, and concentrations of DNAPL-related chemicals in groundwater
increase with depth or appear in anomalous upgradient/across gradient locations.
Pure phase solubility for 1,1,1-TCA is given in the literature as 720, 950, or 1,500
mgll. Relatively recent concentrations of 1,1,1-TCA in groundwater in new A2 zone
extraction well AM1-10 near the former source area were as high as 60 mgll(and
7.5 mgll most recently). Concentrations of 1,1,1-TCA were as high as 370 mgll in
shallow A-zone well AM1-EP in February of 1985. As part of apreyious soil
.investigation (1989-1990) several soil borings were completed peripheral to and
. upgradient from. the former source area: boring B~23 just outside the excavation
boundary, slightly upgradient of well AM1-EP and in proximity. to the outside wall
of Building 1, Boring B-25 approximately 20 feet upgradient from well AM1-EP in
the other direction (towards the southwest), and boring B-30 about 20 feet
upgradient of boring B-25. .
Soil samples from depths of 15 and 20 feet in B-23 each found a total VOC
concentration of about 0.31 or 0.32 ppm; a water sample from 20 feet had 720 ppb
1,1,I-TCA, 78 ppb 1,I-DCA, 34 ppb 1,1-DCE and 8 ppb TCE. Boring B-25 found1.14
ppm total VOCs in a soil sample from sandy silt at 16 feet. This was considered
.. anomalous at the tim~, but not indicative of another source. (A water sample was
not collected from this boring.) Boring B-30 found minor concentrations of TCE
and Freon-113 in silt/clay from depths of 12, 15 and 19 feet. A water sample from'
20 feet had 2.5 ppb 1,1,1-TCA, 1.2 ppb 1,1-DCA, 1.2 ppb Freon-113, and 12 ppb
TCE.
In January of 1990 it was not surmised that VOCs detected in these' bodngs could
be due to a downgradient former source. In light of recently published information
relative to DNAPL, it appears that the VOC concentration found in upgradient
Borings B-23, B-25 and B-30 may be related to the former source and the former
source at one time may have contained VOC DNAPL, and may still host DNAPL
locally. Staff is a.ware that the Discharger, in the sub.mitted report, states that the..
VOCs in the upgradientBoring B-23 resulted from the effects of "groundwater .
. mounding at the tanks and a concrete slab underlying the tanks". The report does
not provide data and calculations to support this contention, and does.not mention
VOCs in Borings B-25 and B-30 as resulting from this mounding.
The combined indications of the EPA Decision Charts 1 and 2 suggest at least a
moderat~ potential (on a scale of from low, to moderate, to confirmed or high
potential) for DNAPL at this site.
Staff agrees that the extent and concentration of DNAPL and subsurface conditions
are some of the factors which c&'ln influence the effectiveness of groundw<1ter
extraction.
7
-------
4.
Comment. With reference to Finding 7c and 7d, the letter states that Applied
Materials' improved and revised cleanup time estimates include the effects of any
DNAPLs and sorption in fine-grained sediments ("tailing effect") at this site.
Response. This comment implies that the time estimates now can and do predict
the future effects of any VOC DNAPL which may contribute dissolved VOCs to
the pollutant plume, and future effects of VOC desorption from fine-grained
sediments such as clays and silts.
.'1 ..
. Staff does not agree with the implications of this co~ment. The Discharger first
ptesented site cleanup time estimates based on this new approach in a report dated
January 15, 1991 ("Soil Cleanup Evaluation and Proposal for Applied Materials
Building 1,3050 Bowers Avenue, Santa Clara, California"), wherein estimates were
8 to 9 years without further source removal and about 8 years with additional soil
(source) removal. These estimates were based on site data (through 1990)
interpretations, using well AM1-1 to represent cleanup without further source
removal (8 to 9 years), and well AM1-5E to represent cleanup with source removal
(8 years). By this interpretation the source area would clean up by year 1999 or
2000, and the remainder of the site one year earlier, 1998 or 1999. The Discharger
continued to update the interpretation; in a report dated August 14, 1992, cleanup
times were estimated at about 7 years with source removal and about 9 years of
groundwater extraction without source removal to reach ARARs sitewide.
The most recent interpretation by the Discharger, submitted with the May 14, 1993
letter from Weiss Associates, uses site data collected through the end of 1992 and
into 1993, and updates the .cleanup time estimates: the former source area (well
AMI-1) is expected to clean up, by only groundwater extraction, by the end of year
1999, and the remainder of the site (well AM1-5E) will clean up by year 2007 or
2008. This seems to indicate that the estimated cleanup time has lengthened frorn
about 9 years, as derived from projections based on site data through 1990, to 17
or 18 years based on site d<1ta)hrough 1992 and into 1993. Staff notes that the.
earlier cleanup time estimate of.8 years fc)r well AMl-5Edoes appea'r to have been
optimistic. Also noting th<1t the cleanup time estimate for well AM1-5E to .reach
MCLs for all VOCs has recently doubled, it seems logical to consider that cleanup
time may have been extended bec<1use of the influence of desorption and perhaps
DNAPL ("tailing effect") Clnd to ponder whether the timti for cleanup~..by
groundwater extraction ,a!ont:' may be further extended <1S more annual data
become available. It is also noted that the "source-rem<1ining-well" now is projected
to be remediated before the "sourct:'-rt:'movt:'d-well", but no eXplc\l1C1tiol1 for this has
been provided,
5.
Comment. With reft:'rence to Finding 8A, the letter st<1tes thClt the DischClrger sees
no justification for even considering t:'xcavCltion.
8
-------
Response. Staff has agreed to modify this Finding as suggested by both the RTQ
and the Jetter submitted by the Discharger's outside Jegal counsel.
6.
. Comment. With reference to Provision 6, the Jetter states an understanding that
while an evaluation of existing datJ is requested, no additional field work is
required, and additionClI investigation is not presently necessary .
Response. Provision 6 does nqt require field work or a field investigation. The
Provisionspecifies certain elements to be included in an evaluation of groundwater
extraction and monitoring.
."
Revised Board Staff Report
In November 1992 Staff prepared Draft Review Comments on the Discharger's most
recent soil-investigation report, and asked the Discharger to comment before the Staff
Report was finalized. After receiving the Discharger's comments, a revised Draft dated
March 1, 1993 was prep~red and again released, along with the proposed Tentative Order,
for comment. The Discharger's technical consultant's submittal included a "Revised Board
Staff Report". The following comments and responses pertain to this item.
The Staff Report is divided into 5 mCljor pClrtS: Summary, Background, Recent Work,
Discussion, and Conclusions and Recommendations. The Discharger's submittal (again)
included numerous suggested changes, in all 5 parts. As a means of reducing staff's task
to a more manageClble level, all suggestions which relate to work done by the Discharger
are adopted; suggestions relating to Staff Conclusions and Recommendations are
reviewed, and may be adopted or otherwise made if deemed appropriate or necessary to
make a conclusion or" recommendation conform to the Revised Tentative Order. The.
Discussion is the .result of BOClrd staff eV<1luation of significant information in the
. Discharger's reports and data, in light of develc)pri1ents described in EPA and other
literature.The Discharger's suggested changes haw been considered but not necessarily
adopted. The Sumniary consists of two parts: "Applied Materials' Report" and "Board
Staff Review". The first part is substituted for the first pClragrClph unaer Recent Work and
incorporates all suggested changes. The removed p
-------
Response. All the Discharg~r's comm~nts (with one correction) on the first part of
the Summary are adopted, and this is sub.stituted for the first paragraph under
Recent Work in the Staff Report. '
The second part of the Summary, noted as Board Staff Review, is moved to become
the Summary preceding the Discussion, and both now are under a new major
topic called Board Staff Review. The Discharger's comments will be addressed as
appropriat~ in the n~w s~qu~nc~ of topics. . . .
.'
2.
Comments have been mad~on statements in the Background section by the
Discharger.
Response. All the Discharger's comments on statements in the Background section
which relate to the Discharger's activities are adopted and changes are made in the
Staff Report. Any comment which relates specifically to Board actions or activities
is not adopted.
3.
Comments have 'been made on the Recent Work section by the Discharger.
Response. The first two paragraphs of the Summary, a.s revised by the Discharger,
are substituted for the original first paragraph under Recent Work. The original.
first paragraph, which was notrevis~d by the Discharger's comments, is deleted'
from this section and moved to the beginning of the Discussion.
Beginning with "New Soil Boring~", all the Discharger's comments on the Recent
Work section are adopted and chang~s are made in the Staff Report. .
4.
Comments have been made on the Discussion section by the Discharger.
Response. The title of this section is changed to Board Staff Review, and there are
two subsections, Summary and Discussion. Th~ new Summary is the second part.
of the original Summary, which had a subheading of Board Staff Revi~w and'
consisted of two paragraphs. '. .
Board Staff Review: Summary
"
5.
Comment. Several word del~tions and additions ar~ propos~d by the Discharg~r
in the first paragraph, beginning with the third sentence.
Response. Wording is changed to re
-------
DNAPL has not been identified at the site, Board staff suspects its presence and
if present it could significantly increase cleanup time by groundwater extraction
alone. If extensive DNAPL is present, the only techniques currently known for
completely remediating this poll';ltion are excavation and isolation." .
6.
Comment. In the second sentence of the second paragraph, Discharger proposes
to change "are being achieved" to "will be achieved".
.,Response. Wording is changed to conform to the TentativeOrder: "----cleanup
. standards are being a(hieved-----~--in a timely manner." .. .
Board Staff Review: Discussion
7.
No comments were made on the new first paragraph.
8.
Comment. The Discharger has proposed several word deletions and new word and
phrase additions in the next (new second) paragraph.
Response. Staff does not agree with the proposed changes.
Extent of Pollution: Groundwater pollution
9.
Comment. In the first paragraph, the Discharger has deleted and added several
new words. .
Response. Staff does not agree with the proposed changes.
10.
Comment. The Discharger hCls suggested several changes in the second paragraph.
Response. Staff agrt~es with the proposed changes, with slight modification: well
AM1-EP initially extracted groundwater having a total VOC concentraticmin
excess 0Ģ400 ppm (not 370 pplll, whiCh was the concentration of only 1,l,l-TCA)..
Extent of Pollution: Soil pollution.
11.
Comment. The Discharger has made J number of suggested changes in t.his
paragraph.
Response. Staff is not in full Jgreement with the suggested chJnges, but agrees to
rewrite this pJragraph in the following manner: The first sentence is unchanged;
the remainder of the pari1graph now rei1ds: "At the Building 1 site the soil
pollution is, for all prJctical purposes, .in the zone of SJturation and the 1 ppm
guidance may not be appropriClte for the purpose of determining cleanup
objectives. The most recent groundwi1ter Jlllendlllent to the Basin Pl,m adopted ,by
11
-------
the Regional Board implies that 1 ppm is appropriate for the unsaturated zone but
is silent on a soil cleanup standard for the saturated zone. The cleanup standard
. for polluted soil adopted in the existing Board Order is 1 ppm total VOCs or some
other level justified by the Discharger. Groundwater extraction has been
satisfactory for remediating this site thus far, but the NA2 aquitard is a low
permeability interval which may not be amenable to groundwater extraction by
pumping. The VOCs in the aquitard may desorb intc) the overlying Aaquif~r and
.'tould eventually be removed .by extraction from the aquifer but this process
(desorption) is very slow~ The results of this most recent investigation confirm the
presence of VOC soil pollution which could continue to impact A-zone
groundwater quality, perhClps for many years to come.
Well AM1-l0
12.
There were no comments for the first paragraph.
13.
Comment. The Discharger has proposed extensive changes to this short second
paragraph.
Response. This parClgraph is entirely rewritten as: "Prior to the implementation of
the most recent soil investigCltion by Applied Materials, Board staff expressed a
concern and desire; the concern was based on the staff belief that the extent of
high VOC concentrations found in well AM1-10 had not been fully determined,
and there were no deep borings below the excavation in the former source area.
the desire was for the focus of the new soil investigation to be below the depth
of the excavation, and for the Discharger to complete 3 or 4 deep soil borings in
the former source area, possibly below the A2 zone. One of the main questions to
be answered by this investigCltion was: WhClt and where is the source of VOC
pollution found in well AM1-10? The investigCltion report attempted to answer this.
question with: "--tt'le VOCs migrated to well AM1-10's screened interval from a
nearby area"; and, "--pumping at weIlAM1-.10 prc)bablyiriduced VOC migration.
into its screened intervaL" Board staff believes another possible explanation is a yet
unidentified pocket (hot spot) of VOC pollution in the former source area, below
the main A-zone aquifer, Clnd that this mClY be VOC DNAPL::'_-
Dense Non-Aqueous PhClse Liquid (DNAPL)
14.
Comment. The Discharger hCls suggested several chClnges in the first pClrC1graph. .
Response. The first sentence is deleted. The second senttmce is rewritten as, "As
mentioned above, the subject report stCltes thJt VOCs migrated to well AM1-10's
screened interv<11 from a ne<1rby ClreC1." The remJindl'r of the. pClragrC1ph is
unchanged.
12
"\
-------
15.
Comment. The Discharger has suggested a number of changes in the second
paragraph.
Response. This paragraph is rewritten to conform to the staff response given earlier
to comment #3 of the Weiss Associates Letter, and now reads: ''The presence of
DNAPL at the Building 1 site is inferred from application of EPA guidelines, stated
in EPA-issued documents, such as:(l) type of industry - Electronics manufacturing;
(2) solvent use, storage and disposal - VOC liquids. were used and stored onsite,
,and wasted into underground acid~neutralization tanks (inadvertent discharges to
these tanks, according to Discharger's comment); (3) DNAPL-related chemicals-
Halogenated volatiles. DNAPL has not been visually identified in water and soil
samples (this is a difficult accomplishment by direct observation, and it would have
been extremely unusual but fortuitous if DNAPL had been visually observed), and
field programs are not known to have been designed to help indicate the presence
or absence of VOC DNAPL at this site. Based on laboratory data, at least two of
four conditions cited by the EPA which indicate a potential for the presence of
DNAPL may exist at this site: concentrations of DNAPL-related 1,1,1-TCA were
> 1 % of pure phase sol1;Jbility in groundwater, and concentrations of DNAPL-
related chemicals appear in an anomalous upgradienVacross gradient locations at
borings B-23, B-25 and B-30. At least a moderate potential for DNAPL exists at this
site."
16.
Comment. The Discharger has made suggested changes in tne third and final
paragraph of this sub-section.
Response. The suggested individual word changes are adopted; the two suggested
new sentences are adopted as modified by staff and now read: "The U.s. EPA and
some academic entities, with industry support, have been conducting research and
field studies of DNAPL and are becoming more active in disseminating
information on their findings. There is now a greater awareness of the potential
impact of DNAPL on site remediation where DNAPL-related chemicals were used
in the past." . . . . ... . .. . .. ..
Offsite Pollution Migration
17.
Comment. The Discharger ht1s mt1de sever(1) suggested ch"a-nges to the first
paragraph.
Response. Staff agrees only to t1dd the date, in Mt1y 1992, as suggested.
18.
Comment. The Discharger has made several suggested changes to the second
paragraph.
Response. St(lff does not agree with any of the suggested changes.
13
-------
I .
19.
Comment. The Discharg~r has mad~ s~ver<11 sugg~st~d changes to th~ third
paragraph.
Response. Staff does not agree with any of the suggested changes.
A2-Zone Pollution
20.
Comment. The Discharger has made sev~ral suggested changes to the. first
. paragraph. .
Response. Staff agrees with some of the suggested changes. Changes made are:
About the middle of the paragraph, in the sentence beginning, "Boring DB-22 was.
drilled-", the word saturated is added between "VOC" and "soil". In the second-
to-last sentence, the phrase, three-foot-thick is added between the words "the" and
"aquitard", and the wor~ -aquifer is added between "A" and "gravelly".
No other changes are made.
21.
Comment. The Discharger has suggested several changes in the second paragraph.
Response. Staff agrees to some of the suggested changes. Changes made are: In the
second sentence, add the word saturated between "VOC" and "soil". In the third
sentence, add 25.25 feet. at between "10.93 ppm, at" and "the ~ase of', and -aquifer
between "A" and "sand"; and 1.38 ppm at 31 feet in the A2 zone. These VOCs
between "sand, and",' and "include mainly". .
No other changes are made.
Time to Accomplish Site Remediation
22.
No comments were made on the first paragraph..
23.
Comment. The Discharger has made suggested changes at the end of the second
paragraph.
."
Response. This comment refers to information not of the report, but recently
submitted.with the Weiss Associat~s Letter and addressed earlier. Staff does not
agree with the suggested changes.
24.
Comment. The Discharger has proposed sever<1! changes in the third p<1rC1grC1ph.
Response. Staff does not agree with the suggested changes.
14
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25.
Comment. The Di:;charger has suggested a number 'Of changes in the fourth
paragraph.
Response. Staff agrees with ~()me of the ~uggested changes. The following changes
are made: In the second sentence, add the word actively between "being" and
"remediated"; delete the words, "does not appear to be", and'replace with, mayor
may not be. Near the end of the fourth sentence, add -aquifer betwe~n "A" and
"sand". In the fifth sentence, add the phrase, and will be evaluated in the five-year
~ .' .
status report. after "---is not known'.'~ .'
26.
Comment. The Discharger has made several suggested changes to the fifth (final)
paragraph.
Response. The basis for this comment appears to ,be the post-report information
recently submitted with the Weiss Associates Letter addressed earlier in this
Responsiveness Summary. Rather than repeat the earlier staff response, this
paragraph is deleted in its entirety. .
Staff Conclusions and Recommendations
27.
Comment. The Discharger has suggested numerous changes in the conclusions. .
Response. Staff has considered all suggested changes and has modified some of the
conclusions and recommendations, as shown below:
Conclusions:
1.
No change.
2.
Ddeted; rewritten to conform to the ~evised Tentative Order, as :
'The effect of em-going groundwaterextra'ction on the source-area A '
sand cannot be directly verified because there is not a well into the.
A sand directly beneath the source area; and, the A sand in the
source area may require a long time for remediation by groundwater
extraction by a well outside the source area. Well-AM1-EP whichw.as
constructed above the A sand has provided data on the effectiveness
of groundwL1ter extraction at the source area from 1985 through
September 3rd, 1991. Although concentrL1tions generally decreased
during this period, showing declines from 370 to 0.180 ppm for-1,1,1-
TCA, 13 to 0.043 ppm for 1,1-DCA. and 19 to 0.034 ppm for 1,1-DCE.
concentrations of 1,1-DCA and 1,1-DCE were still above MCLs of
0.005 ppm and 0.006 ppm, respectively, when the period ended."
15
-------
3.
4.
5.
.'1 6.
7.
8.
9.
10.
11.
12.
13.
14.
Suggested word changes are adopted.
No change.
No change.
No change.
No change.
No change.
Suggested word changes are adopted.
Suggested change is adopted, but the word "significantly" is added
after may, so that the words may significantly now appear between
"present," and "increase".
Deleted; this is now included in #2.
New #11; suggested word change is adopted.
New #12; the suggested change based on post-report information is
not adopted, but the single word change ( "rt;'ct;'nt" to "prior") is
adopted.
New #13; no changt;'o
Recommendations
1.
.,
.....
3.
4.
Changed by adding after "remediated," as mClY be required to meet
Board cleClnup standClrds.
No chonge.
No chClngt;'.
Changt;'d to conform to word and intent of the Revised Tentiltive
Order, and now reClds: "Croundw<1ter monitoring and remediation
should bt;' evalu<1ted with the submittC\1 of the Stiltus Report, due
Oetobt;'r 1, 1994. The evalu<:1tion should C\ttempt to show that
extrC\etion wells AM 1-1 <1nd AM 1-1 0 eCl n C\nd do rt;'med iate tht;' A-zont;'
16
-------
."
and A2-zone. groundwater pollution in the source area, and
extraction well AMl-5E does hydraulically contain the pollutant
plume onsite and prevents VOCs from migrating offsite."
5.
Changed by adopting word changes suggested by the Discharger:
delete "increasing and" between "by" and "coordinating", and
replacing the word "investigating", between "and by" and "and
interpreting", with the word eVi1luClting. .
17
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,
REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
INTERNAL MEMO
."
S. Morse, Division Chief
G. Walker, Section Leader
DATE: March I, 1993.
TO:
SUBJECT:
. .
.. A. Mancini, Asso. EG C1 J/12 ~~-f.,t::C~'t.-<-.
<-
Review and Comments on August 14, 1992" A2-Zone Hydrogeology, VOC Mass
and Distribution, and Feasibility Study Alternatives at Applied Materials Building
I, 3050 Bowers Avenue, Santa Clara,California"
. FROM:
BACKGROUND
Regulatory History
June 19, 1985 - NPDES permit adopted
September 17, 1986 - Waste Discharge Requirements Order adopted
July 22, 1987 - Site added .to final National Priorities List (NPL)
December 21, 1988 - Revised NPDES permit adopted
September 20, 1989 - Site Cleanup Requirements Order adopted
. June 20, 1990 - NPDES permit renewal adopted
September 19, 1990 - Order amending Site Cleanup Requirements adopted.
September 28, 1996 - Record of Decision for Groundwater Operable Unit issued
Site Cleanup Requirements Order No. 90-134
A final cleanup plan for this site was adopted by Board Order on September 19, 1990. This plan
includes remediation of groundwater pollution to reach cleanup standards which are the most
stringent of MCLs, ALs, or non-zero MCLGs for drinking water; soil po]]ution to reach the
cleanup standard of less than or equal to one ppm total VOCs.
-------
I.
Soil and Groundwater Pollution
Previous work by AppJied Materials found soil and groundwater pollution in the A zone, an
interval of sand/gravel/silt/clay from the surface to a depth of about 25 feet, with a
predominantly sand/gravel aquifer interval at about 15-25 feet. (The gravelly sand thickness is
not constant and varies, as reported, from 4 to 10 feet.) SoiJ pollution reportedly begins about
9-10 feet below the ground surface, at about the same depth as the present top of the piezometric
surface, with all concentrations of total VOCs greater than one ppm occurring in saturated soil.
There ~e presently two active groundwater extraction wells' in the A. zone: well AM 1..1
(installed in. 1983) is about 20-25 feet downg11idient from the former source area; and well
AM 1-5E further downgradient, near' the site boundary along Bowers Avenue, about 500 feet
northeast from the former source area.
A third extraction well, AM1.EP (completed at a depth of 17 feet in 1985), was installed in a
void created by excavation of the underground tanks in the source area. In 1989 a hand auger
was used to go inside the well casing (after temporary removal of the pump) and recover two
soil samples from about 19 feet. The maximum total VOC concentration was 1.69 ppm. Use of
this well was discontinued in late 1991 because it was a poor water producer and Board staff
wanted to increase the sampling frequency of another well without necessarily increasing Applied
Materials' operating costs.
Supplemental Soil Survey
In 1989 and 1990 Applied Materials conducted a near-source area soil survey with major
objectives of (1) evaluating concentrations of VOCs still present in saturated soils around the
former tank excavation, (2) determining whether or not a separate as yet unidentified source
could be contributing to the volume of VQCs being extracted in groundwater, and (3)
determining whether or not VOCs were present below the A water-bearing zone which were not
controlled by extraction of groundwater in the A zone. One boring (DB-22) was located on the
concrete equipment pad near existing monitoring well AM 1-2 and reached a depth of about 45
. feet into a sand believed to be the top of the B zone, Eleven saturated soil .sa~ples indicated
VOCs in tested intervals from 16 to 40 feet, with a total VOc.concentration from 0.09 to 20.47
ppm, with the highest VOC concentrations in a thin zone at about 26 feet depth. Total VOC
concentrations in saturated soil samples decreased to 0,11 ppm at, 28.25 feet and 1.25 and 4.61
ppm at 28.5 feet and much less between 28.75 and 39.75 feet. The groundwater level was about
11 feet in January 1990; water samples were not collected for analyses. " "
Another soil boring located on the equipment pad about 4 or 5 feet away from AM l-EP, similar
to DB-22, found 4.97 ppm VOC soil concentration at 2.5.5 feet, below the base of the A-aquifer
. sand. This boring was converted into a fourth extraction well, AM 1-10, which did not examine
groundwater in the main A-zone aquifer but did find VOC groundwater pollution in an interval
about 10 to 15 feet deeper, in what came to be called the A2 zone. The soil survey of 1989-90
determined that VOCs were present below the A water-bearing zone which were not controlled
by extraction of groundwater in the A zone. '
.,
J..
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A geohydrologic investigation of the A2 zone in 1991-1992 included the installation of one
downgradient monitoring well in the A2 zone but did not provide information needed to interpret
the significance of VOC pollution thus far found in soils and groundwater in the A2 zone.
Following this investigation, staff reviewed the site history and concluded that regulatory
concerns still remained. Staff had several major concerns: the unknown source and undefined
extent of pollution which had resulted in the high VOC concentrations being detected in well
AM1-10, and there were no borings extending below the former source-area excavation to
delineate the extent of pollution. Staff did not believe that the existing information was adequate
for making a determination about final soil cleanup. Staff was concerned about a potential
pollution source area located under the air stripper foundation structure, and proposed that
Applied Materials fully investigate the former source area with three or four deep soil borings
and relocate equipment as necessary. Applied Materials objected to moving the air stripper, but
was amenable to conducting one more soil survey.
December 1991 and January 1992 Meetings
In December 1991 and January 1992 staff and Applied Materials' consultant developed a work
plan for an A2-zone investigation. The work plan included an item to determine the VOC mass
already removed from the site by interim remediation, and the VOC mass remaining. Consistent
with Board Staff recommendations, the investigation's focus was on the A2 zone, below the A
zone and immediately above the B zone, in and near the former source (underground tank) area,
presently covered with a concrete equipment pad adjacent to the west side of Building 1. Work
was initiated and concluded, resulting in the submittal of the subject report.
RECENT WORK
Applied Materials has completed a new soil investigation of the low to moderate permeability
A2 water-bearing zone (A2 zone) and found an interval of high volatile organic compound
(VOC) concentrations, up to 20.47 ppm (this value should be 10.93 ppm, 20.47 ppm was
detected previously) in saturated soil at the base of the "A" aquifer. (According to the
Discharger) Applied Materials' report presents a plausible explanation for the source of VOCs
in A2-zone groundwater based on site groundwater and soil data. VOC concentrations increased
to about 64.5 ppm in A2-zone groundwater only after pumping started in A2-zone well AM1-10,
indicating that pumping induced VOC migration into the well's screened interval.
About 620 pounds of VOCs have been removed by groundwater extraction; Applied Materials
calculates that about 52 pounds of VOCs remain in soil and groundwater, and estimates about
9 additional years of groundwater extraction will be enough to achieve drinking water MCLs
throughout the site in the A-zone groundwater and is proposing to complete site'cleanup by
groundwater extraction alone. The Discharger states that these cleanup time estimates include
the potential effects of any dense nonaqueous phase liquids (DNAPLs) and sorption from fine-
-------
grained sediments in the former source area, and that historical groundwater chemical data show
that the groundwater extraction system is remediating groundwater according to the predicted
calculations. .
New SoH Borings
Three soil borings were made for the purpose of investigating the A2 zone and collecting soil
samples for analyses. Due to the presence of electrical lines beneath the concrete equipment pad,.
. conside~ble preliminary work was required to locate Safe and accessibl~ drilling sites.. Restricted
access necessitated the use. of specialized equipment. The final selected boriflg location was not
always the location selected as a first choice for obtaining information from the A2 zone. A
strategic location was made in the former source area, to probe the subsurface underneath the
locations of soil samples of 1985 which detected total VOC concentrations up to 65 ppm at 17
feet; however, field conditions prevented completing this boring. The three borings that were
completed were B-38, B-39, and B-40. These borings are shown on Figure 1. No deep borings
were completed below the former tank excavation.
Boring B-38. Boring B-38 was placed within the former excavation near the excavation limit
next to Building 1, and completed at a depth of only 20 feet which was two feet into clayey sand
(probably the top of the A-aquifer sand). A soil sample had 0.08 ppm 1,1,I-TCA.
Boring B-39. Boring B-39 was located between DB-22 and AMI-IO, and completed at a depth
of 40.5 feet; and had 10.93 ppm total VOCs in s11t)' day at 25.5 feet, at the AI A2 interface
(1.38 ppm total VOCs were found at 31 feet, and VOCs at or below 0.34 ppm were detected
in deeper intervals to 38.5 feet).
Boring B-40. Boring B-40 was about 8 feet downgradient of well AM 1-10, just inside the
equipment pad enclosure and completed at a depth of 40 feet. VOCs (0.59 ppm, total) were
found at 19.5 feet at the top of the A sand, and at the A/A2 interface at 26 feet (0.19 ppm). A
very low soil concentration (0.02 ppm) was found at 39 feet.
Soil Pollution at AI A2 Interface
Previous work found VOC concentrations in soil, up to 20.47 ppm, immediately underlying the
base of the main A..:aquifer gravelly sand, in fine-grained material sometimes referred to as the
AI A2 aquitard. The recent investigation has confirmed that concentrations of VOCs, principally
I,l,l-TCA, I,I-DCA, and I,l-DCE, persist in tine-grained soils at the base of the A aquifer
beneath a portion of the equipment pad on the west side of Building I, and may extend under
the building as wel1. The report describes this soil layer as having an average thickness of about
3.3 feet and containing VOCs greater than I ppm around the 25-foot depth beneath the
equipment pad. The VOC mass in soil and groundwater is calculated using an average total VOC
concentration of 12 ppm, but the cutoff for the area of concern in the report is the I ppm
concentration.
4
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Based on an evaluation of soil data Applied Materials interprets high concentrations of total
VOCs in fine-grained soil at the base of the A aqui fer (AI A2 interface) extending under the
equipment pad from the vicinity of the air stripper in a northeasterly direction about 25-40 feet
to the west side of Building I (Figure I). For potential VOC mass calculations only, (according
to the Discharger), the report assumes the extent of this po1lution under the building equals its
extent under the pad.
VOCs in We1l AMI-tO
~ .'
The report inc1udesan evaluation of the performance of extraction we1l AMI-tO. Concerning'
.'. the apparent disparity between VOC concentrations in soil and concentrations in groundwater
in this well, the report states that data suggest that both soil and groundwater VOC
concentrations were initially low in the vicinity of AMI-lO's screened interval, but the pumping
of wen AM 1-10 pulled polluted groundwater into this well from elsewhere; and that this' "
apparent source has a limited size and mass and is being effectively remediated by well AM 1-10.
Investigation of 1989-90. This investigation showed that VOCs were present below the zone then
being remediated by groundwater extraction. A new extraction well was constructed to remediate
the near-source area A2 zone: AM 1-10 is located about 4 or 5 feet downgradient of the former
source area (we1l AM I-EP), and completed to extract water from an interval about 30-37 feet
deep, identified as the A2 zone. This interval underlies and is separated from the main A-zone
water-bearing sand in the former source area by a "Ieaky confining layer (according to the
Discharger), and is deeper than the bottom of the vault created by tank excavation. The pumping
yield from this well has not been sustainable, and.is very low and intermittent. The analyses of
groundwater samples from this well showed a significant change in water quality after the first
month ~f pumping. Early results were as follows: .'
I, I, I-TCA
1, I-DCA
I,I-DCE
PCE
1,2-DCA
1,1,2-TCA
TCE
vinyl chloride
Freon 113
chloroform
methylene chloride
Concentration in PPB
05-03-90 06-05-90
46-93 15,000
29-34 1,300
"36-4.0 2,700
0.7-<1.0 160
0.5- < 1.0 < 0.5
<0.2-<1.0 9.7
<0.2-< 1.0 12
2.2- < 1.0 1.6
< 0.2- < 1.0 < 0.5
O"9~1.0 5.7
3-< 1.0 <2
09-11-90
60,000
1,800 .
2,500
120
27
34
24- --
3.4
7.1
14
17
The results of an increased sampling frequency for well AM 1-10 (every two mon"ths) showed
continued high but decreasing levels of pollutants; 1,1, I-TCA decreased from 28,000 ppb i~
January '91 to 11,000 ppb in March '92, 6,700 ppb in May, 1,900 ppb in July, and 3.300-
5
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5,300 ppb in September '92. While these concentrations show a decreasing trend, they are much
above concentrations in all other onsite wells for the corresponding time periods. (According to
the Discharger) this is expected because extraction wells in the A zone have been removing and
treating ,groundwater since 1985. In addition, AMI-IO is an extraction well and is puJling in
VOCs from the former source area, and is expected to have higher concentrations than
monitoring wells in the area for the same time. Previously high concentrations were reponed
'from AMI-EP in February 1985 (370,000 ppb I,I,I-TCA) aJ1d AMI-I in December 1985
(44,000 ppb .I,I,I-TCA). The 60,000 ppb in AMI-IO is,greater than anything ever reponed
from A~1-1 , but is much less than the highest total VOC concentration in groundwater at AM 1-
EP). ,. '.' . ." . . , .'
Extent of VOCs in Groundwater
The repon includes a depiction of the lateral extent of VOCs in groundwater and shows, by
inference, that the A zone plume has migrated offsite, across (under) Bowers Avenue and onto
the Avantek site (Figure 2). To provide a conservative estimate of the VOC mass in the A2-zone
groundwater only, the repon's authors assume that polluted groundwater bodies in the A and A2
zones have both a similar shape and VOC distribution.
Previous work. The actual date of the "leak" which resulted in soil and groundwater pollution
has not been reponed and presumably is not known, but predates November 21, 1983. (The
Building I facility has been in operation since the early 1970's.) The suspected source was a nest
, of three underground acid neutralization tanks and associated lines on the west side of Building
. I. This was verified by a number of soil borings in the vicinity of the tanks; after the tanks were
removed several saturated soil samples were taken from I to 3 feet below the bottom of one of
the former tanks, at a depth of 14 to 17feet, and showed a maximum total VOC concentration
of about 65 ppm. At this time the static water level was about 7 to 8 feet below ground level.
All of the soil samples were taken in the zone of saturation but above the main A-zone water-
bearing unit at about 20-25 feet below ground level. '
The main area of polluted soil was shown to underlie one of the tanks and ilJferred to extend
from the base of the tank downward to the'lop of the main water-bearing gravelly sand (refer
to Figures 3A; 3B, and 3C). In 1984-85 some but not all of the polluted soil was removed, and
extraction well AM I-EP was installed in the void of a former tank and the area backfilled with
clean gravel. A total of three A-zone extraction wells were installed and remediation by
groundwater extraction, treatment and discharge was implemented. .-
Groundwater pollution detected. VQC pollution in groundwater was detected when Applied
Materials installed the AM 1-1 well downgradient of the underground tanks in 1983. This well
was later convened to an extraction well. In 1984 monitoring well AM 1-5 was installed funher
downgradient, near the propeny boundary along Bowers Avenue. Later, in 1985, well AMI-EP
, (extraction pit) was installed in the source area, in a vault (void) created by excavation and
removal of the acid neutralization tanks. The initial groundwater sample analysis for each well
showed the following:
6
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Concentration in PPB
l,l,l-TCA
l,I-DCA
l,I-DCE
l,2-DCA
TCE
.~
'PCE .
, . Freon 113
1,I,2-TCA
vinyl chloride
chloroform
methylene chloride
AMl-1
01-21-83)
14,000
790
380
37
6
AMI-5
(06-11-84)
4,000
54
80
AM l-EP
(02-06-85)
370,000
13,000
19,000
560
70
.65
110
190
18
41
7
. 45
15
Wells 1 and 5 were screened in the interval 14-24 feet, in the main water-bearing gravelly sand
of the A zone. Well AM] -EP bottomed at about 17 feet, in the saturated A zone but several feet
above the main water-bearing sand; at this location the main water-bearing sand may be only
about 3-5 feet thick. Following a suggestion by Board staff, during the soil irivestigation of 1990
the investigators were able to collect two soil samples from below the bottom of AM I-EP, by
inserting an auger through the six-inch well casing. Samples were taken from clay or silt.
at depths of 19.0 and 19.25 feet; analyses showed total VOC concentrations of 1.69 and 0.70
ppm, predominantly 1, I, I-TCA. It was not possible to auger deeper, and the main aquifer sand
was not reached. .
Groundwater extraction. A groundwater extraction and containment program was implemented
by pumping AMJ-EP in the source area, AMI-I about 20 feet downgradient, and AMI-5E some
500 feet further downgradient in the direction of groundwater movement and near the site
boundary along Bowers Avenue. The pumping yield from AMI-EP.. which bottomed several feet
above the main water-bearing sand, was low and intermittent. The yieid of each of the other two
wells was relatively constant. (A.pplied Materials reports that) historical groundwater monitoring
. data to date show the A zone is being remediated and the plume is being contained onsite.
VQC Mass Removed and Remaining
The report includes information to further characterize the A2 zone in the near-source area and
calculations to show how much VOC mass has been removed from the A zone (and B zone) and
how much remains. About 620 pounds of chemicals (VOCs) have been removed by groundwater
extraction (an unrecorded quantity of VOCs was removed by the initial soil excavation); about
52 pounds oĢ. VOCs remain in the A-zone soil and groundwater by Applied Materials' estimate.
and an addition quarter-pound (0.25 pound) is estimated to remain in the underlying B-zone
groundwater. .
7
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Time to Accomplish Groundwater Remediation
Applied Materials continues to suppon a belief that linear regression models based on empirical
data indicate about 9 additional years of groundwater extraction will achieve MCLs (ARARs
sitewide), and if this pumping is augmented by source-area soil removal MCLs will be achieved
in 7 years, only a two-year improvement in site cleanup time. Applied Materials is not proposing
any changes to the remediation program currently being implemented.
. Report Conclusions
.~
. .
Applied Materials has concluded that:
1.
The calculated mass of VOCs remaining represents only about 8 % of the estimated VOCs
historically in the subsurface; hence, groundwater extraction has reduced the VOC mass
by about 92 % in seven years.
2.
The VOC mass with concentrations over one ppm sorbed onto soil panicles in the AI A2-
zone confining layer beneath the equipment pad represents only about 3 % of the total
VOC mass remaining at the site, and only 0.25% of the original mass before cleanup
began.
3.
The only two technically feasible remedial alternatives are soil excavation and continued
groundwater extraction. The cost to remove' the mass of VOC-bearing saturated soil
beneath the equipment pad is substantial; the additional cost would be without significant
benefit because cleanup time may be enhanced by only a few years.
Report Recommendation
Applied Materials recommends not removing the remaining VOC mass in saturated soil, but to
continue groundwater extraction and treatment until MCLs are achieved sitewide.
BOARD STAFF REVIEW
Summar)'
"
The VOCs at the base of the" A" aquifer are in fine-grained saturated soil which is poorly
permeable and believed not to be amenable to timely remediation by groundwater extraction.
VOCs may be released by the slow process of desorption, over a long or very long period of
time. An explanation provided in the report assumes that a pumping well AM 1-10 pulls in
. polluted groundwater from elsewhere. Another explanation may be the presence of one or more
as yet unidentified VOC hot spots contributing to the concentrations found in the A2 zone, and
these may be dense non-aqueous phase liquids (DNAPLs). Although DNAPL has not been
identified at the site, Board staff suspects its presence and if present it could significantly
8
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increase cleanup time by groundwater extraction alone. If extensive DNAPL is present, the only
techniques currently known. for completely remediating this pollution are excavation and
isolation.
Board staff recommend conditional acceptance of the Applied Materials proposal to cleanup the
site by groundwater extraction alone. This conditional acceptance requires the Discharger to
document in the 5-year status repon due October 1, 1994 that groundwater cleanup standards
are being achieved throughout the site including the" A" and" A2" zones in the form~rsource
(undergr~und tank) area in a timely manner. Because the equipment pad and Buildjng 1 are
expected .to remain operational for an unspecified period of time, any requirement for direct
cleanup of saturated soil under the pad and building will be deferred until the 5-year status repon
js reviewed, and the efficiency of the extraction system is evaluated. If the existing extraction
program is not remediating VOC pollution in the" A" aquifer clOd deeper in the source and near-
source areas, a plan to address these areas shall be developed and implemented.
Discussion
Applied Materials has submitted, for our review and comment, a repon on the most recent soil
investigation at the Building 1 site in Santa Clara. The goals of this investigation were discussed
at a meeting in December of 1991: the overall goal was to determine if soil remediation would
be required at this site. The investigation (soil survey) was to be conducted to provide
information to fill in knowledge gaps, and set the stage for final site cleanup provisions.
Extraction by pump-and-treat, based on information and data presented in the repon, has
removed about 620 pounds of VOCs from site A-zone groundwater since 1985. The repon's
authors have calculated a percentage of VOCs remaining at the site, and have estimated a
percentage of VOCs removed since 1985. The quantity of VOCs spil1ed has never been reponed
and presumably is unknown, so the estimate is not based on complete knowledge or information,
and it may not be appropriate to relate the mass removed to the mass remaining, as a percentage
removed.
Extent or Pollution
Groundwater pollution. VOC pollution in groundwater at the Building I site has been
characterized by the results of an ongoing monitoring program which began in 1983 and the
ensuing extraction program. However, the extent of VOC pollution in the -f6rmer source .area
has not been fully characterized. Well AM 1- I ~as originally installed (1983) as a downgradient
monitoring well to examine shallow groundwater for signs that the underground tanks on the
west side of Building I may have been leaking. After tank leakage was detected by this well,
AM I - I was converted to an extraction well.
In 1984 the tanks and soil around them were excavated and well AM l-EP (extract.ion pit) was
installed in the source area excavation to a depth of about 17 feet, which was in the A zone
above the depth of the main water-bearing sand. This well initially did extract groundwater
9
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having total concentrations of VOCs in excess of 400 ppm from an interval in the A zone above
the main aquifer gravelly sand, but did not examine (or remediate) the main A-zone aquifer from
which VOC pollution is being removed by downgradient extraction wells AM 1-1 and AM I-SE.
Follow-up investigations of the source area were made extremely difficult by the presence of
underground utilities, a concrete equipment pad, and an air stripper treatment unit over the
source area.
I '
Soil pollution. The soil remediation standard in the Board Order is 1 ppm total VQCs; however,
this gui4ance was developed to address soir pollution'in the vadose lone, with the object,ive of
remediating a source above the water table before the source could impact or add to' the pollution'
in the underlying groundwater. At the Building) site the soil pollution is, for all practical
purposes, in the lone of saturation and the I ppm guidance m,ay not be appropriate for the
purpose of determining cleanup objectives. The most recent groundwater amendment to the Basin
Plan adopted by the Regional Board implies that 1 ppm is appropriate for the unsaturated zone
but is silent on a soil cleanup standard for the saturated zone. The existing Board Order implies
that 1 ppm is the cleanup standard for saturated soil at this site. Groundwater extraction has been
satisfactory for remediating this site thus far, but the AI A2 aquitard is a low permeability
interval which may not be ,amenable to groundwater extraction by pumping. The VOCs in the
aquitard may desorb into the overlying A aquifer and could eventually be removed by extraction
from the aquifer but this process (desorption) is very slow. The results of this most recent
investigation confirm the presence of VOC soil pollution which could continue to impact A-lone
groundwater quality, perhaps for many years to come.
Well A M I-tO. )n ) 989 staff developed some concerns about site characterization and
remediation, and Applied Materials began a supplemental soil survey which revealed the
presence of high concentrations of VOCs in soil in the A2 lone beneath the equipment pad and
resulted in the installation of a fourth extraction well, AM I-tO, near the source area, in 1990
(refer to Figure 4). In well AM)-tO polluted groundwater is extracted from an interval at a
depth of about 30-37 feet below the surface, close to the estimated 'top of the B zone at about
42 feet. The results of analyses of periodic water samples from, AMI-I0 influenced the
implementation of a geohydrologic investigation of the A2 lone, followed by "the most recent soil"
, investigation. ' ' ' " " ' "', ' '"
Prior to the implementation of the most recent soil investigation by Applied Materials, Board
staff expressed a concern and desire; the concern was based on the staff belief that the extent
of high VOC concentrations found in well AM) -to had not been fully determined, and there
were no deep borings below the excavation in the former source area. The desire was for the
focus of the new investigation to be below the depth of the excavation, and for the Discharger
to complete 3 or 4 deep soil borings in the former source area, possibly below the A2 zone. One
of the main questions to be answered by this investigation was: What and where is the source
o~ VOC pollution found in well AM I-tO? the investigation report attempted to answer this
question with: ":---the VOCs migrated to well AMI-IO's screened interval from a nearby area";
and, "---pumping at well AM I-tO probably induced VOC migration into its screened interval."
Board staff believes another possible explanation is a yet unidentified pocket (hot spot) of VOC
to
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pollution in the former source area, below the main A-zone aquifer, and this may be VOC
DNAPL.
Dense Non-Aqueous Phase LiQuid (DNAPU. As mentioned above, the subject report states that
VOCs migrated to well AM 1-10' s screened interval from a nearby area. It is possible that a yet-
undetected source exists at or near (beneath) the former tanks, in a place not yet penetrated by
a well or boring. Such a source may include pockets of DNAPL. As stated in U.S. EPA
Publication 9355.4-07FS, dated January 1992 ("Estimating Potential for Occurrence of DNAPL
at Superfund Sites"), DNAPL is separate-phase hydrocarbon liquid that is denser th~in water,
including'l chlorinated solvent either as a single component or as' a mixture of solvents. Most
DNAPLs undergo only limited degradation in the subsurface, and persist for long periods while
slowly releasing soluble organic constituents to groundwater through dissolution. Even with
moderate DNAPL release, dissolution may continue for hundreds of years or longer under
natural conditions before all the DNAPL is dissipated and concentrations of soluble organics in
groundwater return to background levels.
The presence of DNAPL at the Building I site is inferred from application of EPA guidelines,
stated in EPA-issued documents, such as: (1) type of industry - Electronics manufacturing; (2)
solvent use, storage and disposal - VOC liquids were used and stored onsite, and wasted into
underground acid-neutralization tanks (inadvertent discharges to these tanks, according to
. Discharger's comments); (3) DNAPL-related chemicals - Halogenated volatiles. DNAPL has not
been visually identified in water and soil samples (this is a difficult accomplishment by direct
observation, and it would have been extremely unusual but fortuitous if DNAPL had been
visually observed, or even detected by use of indirect methods); and field programs are oot
known to have been designed to help indicate the presence or absence of VQC DNAPL at this
site. Based on laboratory data, at least two of four conditions cited by the EP A which indicate
a potential for the presence of DNAPLmay exist at this site:' concentrations of DNAPL-related
1,1,I-TCA were> 1 % of pure phase solubility in groundwater, and concentrations of DNAPL-
related chemicals appear in an anomalous upgradient/across gradient locations at borings B-23,
B-25 and B-30. At least a moderate potential for DNAPL exists at this site.
. it is difficult if not impossible, as reported t>y the U.S. EPA, roidentify and recover all reslduai .
. DNAPL in the subsurface. Pump-and-treatmay remove only a small fraction of residual
. DNAPL. To date there have been no field demonstrations where an aquifer impacted by DNAPL
has been returned to drinking water quality. The U.S. EPA and some academic entities, 'with
industry support, have been conducting research and field studies of DNAPL.1nd are becomin,~
more active in disseminating information on their findings. There is now a greater awareness
of the potential impact of DNAPL on site remediation where DNAPL-related chemicals were'
used in the past.
Offsite Pollution Migration
The possible presence of DNAPL is a major concern, but not the only concern. According to
the report, the extent and lateral distribution of gro~lI1dwater pollution in the A'2 zone
II
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approximates that in the shallower main A-zone aquifer. Figure 2 shows the extent of total
VOCs in the A-zone water-bearing sand, in May 1992, on the Building 1 site and extending
under Bowers A venue and onto the A vantek site. Th~ position of the 1 ppb contour is controlled
by Avantek wel1 AV-IA. Wel1s AV-IA and AV-IB are Avantek monitoring wells located
upgradient from the A vantek source area, but downgradient from Applied Materials. Both
Avantek weJls indicate the presence of VOC pollutants. Only well A V-IA was included in the
VOC mass calculations in the subject report.
Avantek has identified two polluted groundwater intervals and calls them A and B; however, it
is apparent that Avantek's B zone is between Applied Materials' A zone and.B zone, and
probably is equivalent to the A2 zone (refer to Ffgure 5). With this in mind, it appears that the
A2 zone was penetrated by AM 1-5B and found to contain a gravelly sand about 3 to 4 feet thick
and having high estimated permeability; the presence of VOCs has not been reported. This A2
interval is interpreted to be in A vantek' s well A V -I B and may be a conduit for the movement
of polluted groundwater. It also appears that pollution in the A water-bearing sand, and perhaps
also in the A2 zone, is migrating from the Building I site to the A vantek site, as measured in
well A V-I B. The source of the pollutants previously identified in Avantek well A V-I A most
likely is also the Building I site. .
On the Applied Materials side of Bowers Avenue, extraction well AMI-5E pumps 5-15 gpm
polluted groundwater from the A-zone aquifer at 14-24 feet. The water-producing interval is
a mediu~-grained sand, increasing in grain size to 1/2-inch gravel, and with high estimated
permeability at a depth interval of about 16 to 21 feet. The total depth of this well is 25 feet,
and a lower A2 sand was not penetrated. Pumping this well influences the shallow A zone
(including well A V-I B) on the Avantek site, but there is no information to indicate if the
pumping influences the deeper sand interval found at 32-37 feet in the A V-I B well, which is
equivalent to an A2 interval on the Applied Materials site. The B zone identified at the Building
1 site has not been explored on the other side of Bowers Avenue, on the Avantek site, and the
downgradient extent of pollution detected in well AM 1-5B has not been determined. However,
the current concentrations of VOCs in well AM 1-5B are below MCLs.
A2-Zone Pollution
The report does not recommend .placing any additional extraction wells in theA2 zone, nor does
the report acknowledge that A2 groundwater maybe migrating offsite and may be transmitting
pol1ution to the A vantek well A V -1 B. (The offsite migration of A-zone groundwater is inferred
on Figure 14 of the report.) No samples of groundwater have been obtained for analyses from
either boring DB-22 or boring B-39 on the Applied Materials equipment pad. Boring DB-22 was
drilled into the top of the B zone in the vicinity of B-zone monitoring well AMI-2, about 15-20
feet downgradient of the source area (refer to Figure I) and found VOC saturated soil pollution
throughout the interval from the base of the A aquifer (about 24 feet) to the top of the B zone
(about 42 feet). The highest concentration was a reported 20.47 ppm total VOCs in the three-
foot-thick aquitard immediately underlying the A gravelly sand. The pollutants were mainly
l,l,I-TCA and I,I-DCA, with some PCE. .
12
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- - -- -.-------;---------,-~, ----
, . . .
Boring B-39 is also located near AM 1-2 but closer to the former source area. This boring did
not reach the top of the B-zone sand and found VOC saturated soil pollution within the interval
from the base of the A aquifer (about 25 feet) to the bottom of the boring (about 40 feet). The
highest concentration of total VOCs was 10.93 ppm, at 25.25 feet at the base of the A sand, and
1.38 ppm at 31 feet in the A2 zone. These VOCs included mainly I, I, I-TCA, 1, I-DCA and
1,I-DCE, with PCE, TCE, and 1,2-DCA. The total VOC concentrations in soil inDB-22 and
B-39 were much greater than that found in well AMI-I0 (4.97 ppm); groundwater from AMI-tO
.contained very high concentrations of VO~s, but water samples were not available for.analyses'
from either DB-22 or B-39. .
. "
Time to Accomplish Site Remediation
The existing site cleanup requirements (Order No. 90-134) summarizes the 5 cleanup plans
originally evaluated in the RI/FS, and includes mention of a later re-evaluation with a c~nclusion
by Applied Materials that remediation can be accomplished either by (I) groundwater extraction
alone or by (2) extraction combined with partial soil removal, with an estimated cleanup time
of 53 years for (1) and 35 years for (2). Applied Materials favored (1) possibly modified by
some soil removal if future operational changes at Building 1 provide an opportunity to transfer
manufacturing and R&D activities out of Building 1. Applied Materials has' recently reported that
operational changes within Building I will take place very soon, but accessibility to the area
beneath the equipment pad will not improve and soil remediation does not appear to be any more
feasible now than it was earlier.
The submitted report includes a review of feasibility study alternatives with some modifications.
Remedial action alternatives have been updated to show a cleanup time of about 9 years from
the present "to achieve ARARs sitewide" by groundwater extraction alone, and about 7 years
of groundwater extraction if augmented by partial soil removal (augured caisson). With such a
similarity in cleanup times, soil remediation is not considered worthwhile by Applied Materials.
These cleanup times are based on linear regression analyses using data from two extraction
wells, AMI-I and AMI-5E. The 7-year estimate is for well AMI-SE in which 1,1,I-TCA has
been below the MCL for some time, and the 9-year estimate is for . well AM I ~ 1 which is closer
to the source area. When Applied Materials used a similar. model in 1988, staff thought it was. .
too optimistic based on the historical information and. analysis of pump-and-treat by the U.S.
EPA. Applied Materials later revised the estimate upward. Now, the estimate has been revised
downward and is about the same as it was in 1988.' .
Applied Materials' model utilizes data from the permeable A-zone groundwater interval found
in two downgradient wells: one well is about 25 feet from the tank source area, the other is
about 400 feet from the source area, We would normally expect the more-distant well (AM 1-5E)
to clean up faster than the other well. The extent of pollution in the A zone in the source area
. is not known; to consider well AMI-I a "source-area well" mayor may not be appropriate: well
AMI-I may clean up several years after.well AMI-5E cleans up, but that doesn't necessarily
mean the source area is clean. There is not now (nor has been) a well in the source area to
monitor cleanup of the A-sand aquifer,
J3
-------
Soil surveys have identified a silty clay interval (poorly permeable), below the A-sand aquifer,
which has high concentrations of VOCs in three borings in the near-source area. This po11uted
interval is not now being actively remediated and mayor may not be amenable to remediation
by groundwater extraction. The full extent of this pollution is unknown but it is projected to
extend from under the equipment pad on the west side of Building I, to under Building I. Well
AMI-tO removes VOC pollution from an interval about 15 feet deeper than the A-aquifer sand.
The source of the VOCs extracted by AMI-IO has not .been identified. The effectiveness of
AM 1-1O~ in remediating this source is no.t known and wi11 be evaluated in. the five-year status
report. It has bee.nconjectured that this source could be DNAPL; if s6, it most likely will not
be remediated by groundwater extraction, or could take a very long time (decades and longer)
to remediate.
STAFF CONCLUSIONS AND RECOMMENDATIONS
Conclusions
1.
Applied Materials considers the "signature" VOCs of the Building I site to be 1, 1,1-
TCA, I,I-DCA, and I;I-DCE.
2.
The effect of on-going groundwater extraction on the source-area A sand cannot be
directly verified because there is not a well into the A sand. directly beneath the source
area; and, the A sand in the source area may require a long time for remediation by
groundwater extraction by a well outside the source area. Well AM I-EP which was
constructed above the A sand. has provided data on the effectiveness of groundwater
extraction at the source area from 1985 through September 3rd, 1991. Although
concentrations generally decreased during this period, showing declines from 370 to
0.180 ppm for I,I,I-TCA, 13 to 0.043 ppm for 1,I-DCA, and 19 to 0.034 ppm for 1,1-
DCE, concentrations of 1, I-DCA and I, I-DCE were still above MCLs of 0.005 ppm and
. 0.006 ppm, respectively, when the. period ended. .
Well AMI-I0, the extraction well closest to the former tank location, found
concentrations, up to 60 ppm, of a number of VOCs in groundwater from an interval,
now called the A2 lOne, about 10-15 feet deeper than the bottom of the main A aquifer.
The concentrations of VOCs in saturated soil of the water-producing A2 interval are ND
(one sample had 0.01 ppm 1,1, l-TCA) and do not correspond to the subsequent high
concentrations of VOCs in the extracted groundwater after pumping of well AM 1-10.
3.
4.
The source of high concentrations of VOCs in groundwater from well AM 1-10 has not
been revealed by the recent investigation; nor has the investigation revealed a definitive
correlation between VOC soil pollution and VOC groundwater pollution in this well.
14
-------
5.
6.
7.
8.
9.
The VOCs detected in groundwater from well AMI-IO may be pulled into the well from
elsewhere by the pumping of well AM 1-10, or may indicate a yet-undetected source at
or near (beneath) the, former tanks.
No deep borings were completed be10w the former tanks.
The presence of electrical and other equipment above ground and underground utilities,
(electrical lines and conduits) interferes with the installation of borings and wells on the
e.quipment pad which overlies the source and near-source areas.' ' ,
VOC soi1 pollution at the Building 1 site appears to be in the zone of saturation; high
concentrations of VOCs found in the AI A2 aquitard are in poorly permeable soil and are
not believed to be amenable to rem,ediatiori by groundwater extraction.
The subject report shows high-concentration VOC soil pollution to exist under the
concrete equipment pad, and assumes that it may extend under Building I. This pollution
occurs in saturated soil, and desorption may take place over a long period of time. The
concentrations of VOCs, including potential carcinogens, above MCLs may persist for
the period that pollutants are desorbing from soil. VOCs which desorb into groundwater
may eventually be captured by groundwater extraction.
10.
The presence of DNAPL is suspected, and if present, may significantly increase cleanup
time by groundwater extraction alone.
11.
It is highly unlikely that changing circumstances will allow Applied Materials to attempt
soil remediation beneath the concrete equipment pad and buiiding in the foreseeable
future.
12.
Applied Materials now estimates that sitewide groundwater remediation wil1 be
accomplished by groundwater extraction alone in less than ten years, as compared to a
prior estimate of 53 ,years by extraction alone and 35 years by groundwater extraction
augmented by soit, remediation. ",,", " ,
13.
Variable concentrations of the signature VOCs have been detected in groundwater in
monitoring wel1s on the Avantek site, across Bowers Avenue and downgradient from the
Applied Materials Building I sf'te, but upgradient from the former source area at
Avantek. Polluted groundwater apparently has migrated from the Applied Materials site
to the Avantek site.
- Recommendations
1.
If and when feasible, polluted soil under the equipment pad and Building I should be
remediated, as may be required to meet Board cleanup standards.
15
-------
I .
2.
Polluted groundwater should be completely contained onsite and not allowed to migrate
off site.
3.
Groundwater remediation should achieve Cleanup standards, sitewide.
4.
Groundwater monitoring and remediation should be evaluated with the submittal of the
Status Report, due October I, 1994. The evaluation should atte~pt to show that
extraction wells AM I-I and AM 1-10 can and do remediate the A-zone and A2-zone
groundwater pollution in the source area, and extraction well AM I-~E does hydraulically. - ..
~ontain the pollutant plume onsite and prevents VOCs from migrating offsite.
5.
Applied Materials should be required to evaluate the adequacy of downgradient plume
containment, by coordinating groundwater sampling and water-level measurement events
on both sides of Bowers Avenue, and by evaluating and interpreting the geology of the
A zone from the surface to the top of the underlying B zone and describing potential
pathways for transmitting groundwater pol1uti~n offsite. If required, a plan to address
offsite migration should be developed and implemented.
(~J (} lvrt~
Concur
Greg Walker
Section Leader
.;J~
Concur
S.1. Morse, Chief
South Bay Toxics Cleanup Division
.-
-
16
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APPLIED MATERIALS BUILDING 1
ADMINISTRATIVE RECORD
TABLE OF CONTENTS
VOLUME IX: 1991
Date:
Author: Recipient Contents: Volume
**01/15/91
Weiss Associates Applied Materials Soil Cleanup Evaluation and IXB
Proposal
**0 1/28/91
\Veiss Associates Applied Materials Annual Progress Report - IXB
Disposal of extracted ground
water
**02/06/91
S. t\lorse J. Schoening Acknowledgement of "Soil IXA
RWQCS Applied Materials Cleanup" and "Disposal of
Ground Water" reports
**02/22/91
S. t\t.:>rse J. Schoening Comments on disposal IXA
R \\'QCB Applied Materials of extracted ground water
report
u03/04/91
L. Bc:"g/ A.J. Mancini Installation of wells AMI-II IXA
R. Weiss R WQCS and AMI-12
Weiss Associates
**03/13/91
J. Schoening A.J. Mancini Response to comments on IXA
Applie'd Materials . R WOCS .disposalof ground water report
**03/1'3/91
J. Schoening A.J. Mancini Annual Monitoring Report IXC
Appl ied Materials RWQCB
u03/28/91
Appl ied R WOCS Extraction System O&M and IXB
r-btcrials HMMP Reports for BMPP
"03/28/91
Appl ied M:1terialsl R WOCS Hazardous Materials Business IXB
eli.A.S.E. Plan, Applied Materials; Inc.;
Submitted as part of BMPP
**04/16/91
S. ~torse J. Schoening Response to March 13, 1991 rXA
R WQCB Applied Materials letter about Extracted Ground
Water Reuse Report
L,-'-.i.L'. "~A..\1\16'1X IJA2 .WP
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Date:
Aut h.)r: Recipient Contents: Volume
u04/17/91
S, \lorsc J. Schoening Status of Regulatory Review IXA
R WOCB Applied Materials and Actions
u04/19/91
S. Morse ' J.Schoening Correction to WQCB letter IXA
R WOCA Applied Materials dated April 17, 1991
"04/24/91
S. Morse J. Schoening Compliance Monitoring Report IXE
R WOCB Applied Materials
**05106/91
L. Berg A. J. Mancini Analytical results for soil IXA
Weiss Associates R WOCB borings AMI-II and AMI-12
**05106/91
G. Grimm S. Morse Comments on Revised Proposed IXA
R WQCB R WOCB Deed Restriction
**05110/91
J. S " h l1 e n i n g A.J. Mancini Explanation of trench on IXA
Appl icd Materials R WOCB equipment pad
**05/20/91
S, Morse J. Schoening Review of "Soil Cleanup IXA
R \\'OCB Applied Materials Evaluation and Proposal"
report
**05/20/91
S. Morse J. Schoening Comments on Applied. .IXA
, R WOCB . Applied Materials. MaterialS' Revised Proposed
Deed Restriction
**06/18/91
A, Haubenstock A.J. Mancini Proposed Deed Restriction IXA
O!'iick, Herrington, R WOCB Extension confirmation
and Sutcli ffe
u06/26/91
A. Haubenstock S. Morse Applied Materials Deed IXE
Orrick, Herrington, R WOCB Restriction and Staff
and S~tcliffe Comments
*"'0:"01/91
J. S: boen ing A.J. Mancini Report: Addendum 1991 IXB
A j.' P i i c d Mat e rial s R WOCB Annual Progress Report -
Disposal of extracted Ground
\Vater
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L
Date:
Author: Recipient Contents: Volume
u07 i08/91 Ground Water Monitoring and IXC
Weiss Associates AJ. Mancini Remedial Action Self-
R WOCB Monitoring Report, February-
May 1991
'"'"07/11/91 .
W~iss Associates R WOCB Agenda and handouts at IXE
Applied Materials July II, 1991 meeting
** 0 7 / 1 5 /91
S. r-.loJ'se . J. Schoening Comments on July 11,1991 IXA
R WOCS Applied Materiah meeting
**07/22/91
S. Morse J. Schoening Comments on Februar,y - May IXA
R \VOCB Applied Materials 1991 triannual mO:1itoring
report
u07 /23/91
J. SdlOcning S. 'Morse Propo:;al addressing comments IXB
ApFlicd M:lterials R WOCB in July 15, 1991 letter
u07/23/91
S. ~1orse J. Schoening Addition to reporting IXA
R WOCS Applied Materials requirements (NPDES)
**07/24/91
Weiss Associates R WOCB Work proposal in response to IXB
Applied Materials RWOCB 7/15/91 letter
u07/29/91
S. Morse J. Sci}oening Implementation oJ BMPP IXA
R wOCS Applied Materials
*'"07/29/91
S. Morse R. Bruni Comments on A2-Zone IXA
R WQCB Applied Materials investigation
**08/06/91
Weiss Associates A.J. Mancini Ground water monitoring IXA
R WOCB report modifications
uOS/13/91
S. Morse R. Bruni Response to August 6, 1991 IXA
R \\(}C8 Applied Materials letter pertaining to RWQCBs
request for modifications to
monitoring reports
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Date:
Author: Recipient Contents: Volume
**08/15/91
Weiss Associates A.J. Mancini A2-Zone Investigation Schedule IXA
R WOCB
**OS/21/91
S. ~1orse R. Bruni A2-Zone Irivestigation and IXA
R"QCB . 'Applied Materials Administrative Record'
**09/13/91
J. Schoening A.J. Mancini August 1991 NPDES Reporting IXD
Applied Materials R WOCB
"'09/16/91 '
Weiss Associates A.J. Mancini Progress of A2-Zone' IXA
R WOCB In vestigat ion
**09/18/91
S. Morse J. Schoening Deed restriction comments IXE
R WQCB Applied Materials
**09/18/91
S. ~1ors!: J. Schoening Comments on Soil Cleanup IXA
R \\vCB Applied Materials Evaluation and Proposal report
**09/26/91
S. Morse J. Schoening Comments on Report IXA
R \\'OCB Applied Materials "Addendum, 1991 Annual
Progress Report - Disposal of
Extracted Ground Water"
**10/01/91
Weiss Associates A.J. Mancini ' September Influent data IXA
ROWCB
**10111191
J. Schoening A.J. Mancini September 1991 NPDES IXD
Appiied Materials R WQCB Reporting
ul0115/91
\\'eiss Associates A.J. Mancini A2-Zone Investigation update IXA
R WOCB
**10/16/91
J. S:lioening A.J. Mancini 9/26/91 letter reporting IXA
Applied Materials R WOCB deadlines
ul0/24/91
S. ~1orse J. Schoening Extensionof due dates IXA
R \\'Q CB Applied Materials
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Date:
Author: Recipient Contents: Volume
**11/11/91
J, Schoening A.J. Mancini October 1991 NPDES reporting IXD
Applied Materials R WOCB
**11/12/91
\\"t:is~ Associates A.J. Mancini A2-Zone Reporting deadline IXA'
R WOCB extension req uest
**111i2/91
Applied Materials RWOCB Ground Water Monitoring an-d IXC
Remediation Action Self-
Monitoring Report, June -
September, 1991
**11/19/91
J. DeLong S. Morse Response to R WOCB IXA
Appiied Materials R WOCB September 18, 1991 letter
**11/19/91
Weiss Associates A.J. Mancini A2-Zone Investigation Update IXA
R WOCB
**11/25/91
S. Ritchie J. DeLong A2-Zone Report' deadline IXA
R WOCS J. Schoening extension and proposed
Applied Materials December 1991 meeting
**11/27/91
Weiss Associates S. Morse Response to R WOCB IXA
R WOCB September 18.' 1991 letter
**11/"::.7/91
A.LM3ncii1i R. Bruni Proposed content of IXA
R \\'QCB Applied Materials December 1991 meeting
**12/03/91
S. Morse J. Schoening NPDES compliance monitoring IXD
R \\'QCB Applied Materials report
**12/04/91
:'\.J. Mancini R. Bruni Revised proposed content of IXA
R WQCS Applied Materials December 1991 meeting
** 1:: /09/9 I
Weiss Associates RWOCB A2 Water-bearing zone IXB
investigation
'\LL " ':\.\\' 11i9\:lJA2,\\'P
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Date:
Author:
Recipient
Contents:
Volume
J. Schoening
Applied Materials
"12/12/91
A. Haubenstock
Orrick.
Herrington &
Sutcliffe
A.J. Mancini
RWQCB
S. Morse
RWQCB
November 1991 NPDES
reporting
Comments on RWQCB
September 26, 1991 letter
IXD
IX A
12/13/91
Weiss Associates
12/13/91
Weiss Associates
12/13/91
Weiss Associates
12/17/91
RWQCB
12/18/91
S. Morse
RWQCB
12/26/91
Weiss Associates
12/26/91
S. Morse
RWQCB
12/27/91
S. Morse
RWQCB
S. Morse
RWQCB
S. Morse
RWQCB
S. Morse
RWQCB
Applied Materials
J. Schoening
Applied Materials
A.J. Mancini
RWQCB
J. Schoening
Applied Materials
J. Schoening
Applied Materials
Comments on RWQCB IXA
September 26, 1991 letter
Response to comments on IXB
Report "Addendum, 1991,
Annual Progress Report -
Disposal of Extracted Ground
Water"
Response to 12/17/91 IXA
Meeting Agenda
12/17/91 meeting agenda and IXE
attendance sheet
Change in self monitoring
program and request for IXA
Administrative Record update
Air stripper effluent IXA
noncompliance
Acceptance that ground water IXA
reuse is not presently feasible
NPDES noncomplaince IXA
s. ALl
Page 6
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APPLIED MATERIALS BUILDING 1
ADMINISTRATIVE RECORD
TABLE OF CONTENTS
VOLUME X: 1992
Date:
Author:
Recipient
Contents
Volume
**01/14/92
Weiss Associates
**01/14/92
Weiss Associates
A.J. Mancini
RWQCB
A.J. Mancini
RWQCB
Request for 12/13/92 report to ' XA
fulfill annual disposal of extracted
ground water report requirement
Response to 11/7/91 compliance XA
monitoring report
**01/23/92
S. Morse
RWQCB
**01/30/92
J. Schoening
Applied Materials
Ŧ*02/06/92
J. Schoening
Applied Materials
**02/10/92
S. Morse
RWQCB
**02/13/92
S. Ritchie/
S. Morse
RWQCB
*ŧ02/18/92
J. Schoening
Applied Materials
*ŧ02/26/92
Weiss Associates
02/27/92
J. Schoening
Applied Materials
L. Berg
Weiss Associates
S. Morse
RWQCB
A.J. Mancini
RWQCB
J. Schoening
Applied Materials
R. Bruni
Applied Materials
S. Morse
RWQCB
A.J. Mancini
RWQCB
S. Ritchie
RWQCB
Acceptance of 12/13/92 report as XA
annual disposal of extracted
ground water report
Response to 12/27/91 letter XA
providing requested O&M
information
January 1992 NPDES self XD
monitoring report
NPDES self monitoring report XA
transmittal letter requirements
Request for information related to XA
the extraction system O&M
Complete transmittal letter for XD
December 1991 self monitoring
report
Work Plan for Soil Investigation at XB
Building 1
Response ro extraction system
O&M questions in 02/13/92 letter
XA
J:\APMATRLS\169XIJA3.WP
p,8e I
-------
..,. ',--
Date:
Author:
Recipient
-~ .. . I J I..~:
Weiss Associates" r It . ".."
Contents
Volume
**03/06/92
J. Schoening
Applied Materials
**03/09/92
L. Berg
Weiss Associates
**03/11/92
K. Takata
EPA
**03/12/92
J. Schoening
Applied Materials
**03/26/92
b. Berg
Weiss Associates
**03/30/92
S. Morse
R WQCB
**04/07/92
Weiss Associates
**04/10/92
J. Schoening
Applied Materials
**04/16/92
S. Morse
R WQCB
**04/16/92
W. Attwater
SWRCB
**04/16/92
A. Haubenstock
Orrick,
Herrington, &
Sutcliffe
J :\APMA TIU.S\l69XIJAJ.WP
A.J. Mancini
RWQCB
A.J. Mancini
. R WQCB
J. Stewart
Applied Materials
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
R. Bruni
Applied Materials
A.J. Mancini
RWQCB
A.J. Mancini
R WQCB
J. Schoening
Applied Materials
D. Alden
Orrick, Herrington,
& Sutcliffe
S. Morse
R WQCB
Annual Ground Water Monitoring
Report
January 1992 analytic data for..
well AMI-I0 .
Liability notice and demand for
payment of EPA costs
February 1992 NPDES self
monitoring report
March 1992 analytic data for well
AMI-I0
Comments on 2/26/92 Proposed
Work Plan
Response to 3/30/92 Building 1
Work Plan Comments
March 1992 NPDES self
..' monitoring report.
Request for 4/5/92 sample COC
form Clarification
Dismissal of old site cleanup Order
89-167 petition for review
Deed restrictions
XC
XA
XA
XD
XA
XB
XB
XD
XA
XA
XA
Pa,e 2 .
-------
J '.
Weiss Associates.. r".
Date:
Author: Recipient Contents Volume
**04/21/92
A. Haubenstock A.J. Mancini Maps o( parcel described in the XA
Orrick, R WQCB legal description (or the deed
Herrington, & restriction
Sutcliffe
**04/28/92
. S. Morse . J. Schoening Air stripper O&M plan XA
R WQCB Applied Materials
**04/28/92
S. Morse J. Schoening Notice to provide deed restriction XA
R WQCB Applied Materials in 30 days
**04/29/92
Weiss Associates A.J. Mancini Response to 4/16/92 letter XA
R WQCB clarifying 4/5/92 COC procedure
**05/08/92
A. Haubenstock A.J. Mancini Legal description (or the original, XA
Orrick, R WQCB unpartitioned parcel of land (or
Herrington, & AMI
Sutcli ffe
**05/13/92
A. Haubenstock A.J. Mancini Map of property described in XA
Orrick, R WQCB Exhibit A in deed restriction
Herrington, &
Sutcliffe
**05/14/92
J. Schoening. A.J. Mancini Aprii 1992 NPDES self monitoring XD.
Applied Materials R WQCB report
**05/15/92
Weiss Associates A.J. Mancini Request to return to normal XA
R WQCB turnaround for air stripper
effluent samples
**05/19/92
L. Berg A.J. Mancini May 1992 analytic data for well XA
Weiss Associates R WQCB AMI-I0
**05/27/92
A. Haubenstock S. Ritchie Replacement signature page for XA
Orrick, R WQCB deed restriction
Herrington, &
Sutcliffe
J :\APMA TRLS\169X IM3.WP
Pa,e 3
-------
Date:
Author:
Recipient
Weiss ~SSOclates ~ ~'-~
Contents
Volume
**06/03/92
J. Schoening
Applied Materials
**06/11/92
R. Bruni.
Applied Materials
. **06/15/92
S. Morse
R WQCB
**06/18/92
L Schoening
Applied Materials
**07/10/92
J. Schoening
Applied Materials
**07/27/92
A. Haubenstock
Orrick,
Herrington, &
Sutcliffe
**08/03/92
Weiss Associates
**08/10/92
J. Schoening
Applied Materials
**08/14/92
Weiss Associates
**09/09/92
J. Schoening
Applied Materials
**10/03/92
J. Schoening
Applied Materials
**10/05/92
L. Berg
Weiss Associates
J :\APMA TRLS\169XIJAJ. WP
A.J. Mancini
R WQCB
S. Morse
RWQCB
R. Bruni
Applied Materials
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
R WQCB
A.J. Mancini
RWQCB
A.J. Mancini
R WQCB
May 1992 NPDES self monitoring
report .
Summary of 5/29/92 meeting
Request that a Pinette Salvage
yard-type analysis be incorporated.
in the 8/15/92 report
February-May, 1992 Ground Water
Monitoring Report
June 1992 NPDESself monitoring
report
Final recorded deed restriction
July 1992, NPDES noncompliance
. .
July 1992 NPDES self monitoring
report
A2-zone hydrogeology, VOC mass
and distribution, and feasibility
study alternatives report
October 1992 NPDES self
monitoring report
September 1992 NPDES self
monitoring report
September 1992, NPDES
noncompliance
XD
XA
XA
XC
XD
XE
XA
XD
XB
XD
XD
XA
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Date:
Author:
Recipient
Contents
Weiss Associates It"M
Volume
**10/07/92
L. Berg
Weiss Associates
**10/15/92
S. Morse
. R WQCB
**10123/92
R. Bruni
Applied Materials
**11/06/92
J. Schoening
Applied Materials
**11/09/92
J. Schoening
Applied Materials
**11/23/92
S. Morse
R WQCB
**12109/92
J. Schoening
Applied Materials
J :\APMA TRLS\169XIJAJ. WP
A.J. Mancini
RWQCB
R. Bruni
Applied Materials
S. Morse
R WQCB
A.J. Mancini
RWQCB
A.J. Mancini
R WQCB
R. Bruni
Applied Materials
A.J. Mancini
R WQCB
.September 1992 analytic results for
air stripper efflue~t
Letter requesting location of data
on vadose zone samples
Response to 10/15/92 letter from
R WQCB .
June - September 1992 Ground
Water Monitoring Report
October 1992 NPDES self
monitoring report
Tentative agenda for 12/9/93 .
meeting
November 1992 NPDES self
monitoring report
XA
,XA
XA
XC
XD
XA
XD
P.ee S
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IJ '.
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APPLIED MATERIAlS BUILDING 1
ADMINISTRATIVE RECORD
TABLE OF CONTENTS
VOLUME XI.
JANUARY 1 - JUNE 30, 1993
Date:
Author: Recipient Contents Volume
**Olil2193
J. Schoening. . . A.J. Mancini December 1992. NPDES self XID
Applied Materials RWQCB . monitoring report
**01/27/93
L. Berg A.J. Mancini Transmittal of the 1992 XIA
Weiss Associates RWQCB Administrative Record Update
**01/27/93
L. Berg Information Transmittal of the 1992 XIA
Weiss Associates Repository - Santa Administrative Record Update
Clara Public Library
**01/29/93
Weiss Associates A.J. Mancini Extracted Ground Water Reuse XIB
RWQCB Annual Report
**02105/93
L. Berg A.J. Mancini January 1993 analytical results for XIA
Weiss Associates RWQCB well AMI-I0
**02109/93
J. Schoening . A.J. Mancini January 1993 NPDES self mo~toring XID
Applied Materials RWQCB rePOrt
. **03/09/93
J. Schoening A.J. Mancini . .. February 1993 NPDES self XID
Applied Materials RWQCB monitoring report
**03/11/93
J. Schoening A.J. Mancini Ground Water Monitoring and XIC
Applied Materials RWQCB Remedial Action Self-Monitoring
Annual Report January 1992 -
January 1993
**03/23/93
J. Weingast A.J. Mancini March 1993 analytical results for well XIA
Weiss Associates RWQCB AMI-10
J :\APMA TRLS\MISC\169XUU3.WP
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pate:
Author: Recipient Contents Volume
**04/02/93
S. Morse R. Bruni Tentative Order XIA
RWQCB Applied Materials
**04/12/93
J. Shoening A.J. Mancini March 1993 NPDES self monitoring. XID
Applied Materials RWQCB report . .
**04/12/93
A. Martorana A.J. Mancini Air stripper shutdown XIA
Weiss Associates RWQCB
**04/93
RWQCB Public Record Applied Materials Building I, Fact XIE
Sheet No.4
**04/21/93
RWQCB Public Record Executive Officer Summary Report: XIE
Tentative Order and 3/1/93 Internal
Memo
**04/26/93
Weiss Associates A.J. Mancini VOC Characterization in Vadose XIB
RWQCB Zone Soil
**04/30/93
J. Thompson Public Record Notification for public meeting XIE
RWQCB
**05/05/93
. Weiss Associates A.J. Mancini Suggested chailges to Tentative XIA
RWQCB Order: edited and clean version
..
**05/06/93
S. Morse J. Schoening Transmittal of compliance monitoring XIA
RWQCB Applied Materials report
**05110/93
A.J. Mancini T. Martorana Revised Tentative Order XIA
RWQCB Weiss Associates
J : \APM A TRLS\MISC\169XlJU3. WP
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Date:
Author: Recipient Contents Volume
**05/12/93
I. Schoening A.I. Mancini April 1993 NPDES self monitoring XID
Applied Materials RWQCB" report
**05/12/93
Weiss Associates A.I. Mancini Suggested revisions to the 5/10/93 XIA
RWQCB Revised Tentative Order, and to the.
3/1193 Internal Memo
**05/14/93
Weiss Associates S. Morse Technical issues on Revised Tentative XIA
RWQCB Order No. 90-134
**05/14/93
A. Haubenstock S. Morse Comments on the Tentative Order XIA
Orrick, Herrington RWQCB
& Sutcliffe
**05/20/93
S. Morse R. Bnmi Request to update the Administrative XIA
RWQCB Applied Materials Record
**05/24/93
A. Martorana A.I. Mancini May 1993 analytical results for well XIA
Weiss Associates RWQCB AMI-lO
**06/07/93
S. Morse R. Bnmi Notification of Board meeting XIA
RWQCB Applied Materials
**06/08/93 ..
A. Haubel]$tock S. Morse Consent to revised order and XIA
Orrick, Herrington RWQCB comments on staff memo.
& Sutcliffe
**06/10/93
I. Schoening A.I. Mancini May 1993 NPDES self monitoring XID
Applied Materials RWQCB report
**06/16/93
RWQCB Public Record Executive Officer Summary Report: XIE
Iune 16, 1993
J :\APMA TRLS\MISC\169XlJU3.WP
Page 3
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Date:
Author:
Recipient
Volume
**06/21/93
S. Morse
RWQCB
1. Schoening
Applied Materials
**06/21/93
s. Morse
RWQCB
1. Schoening
Applied Materials
I
J :\APMA TRLS\MISC\169XUU3.WP
Contents
Transmittal of Final Documents
Order No. 93-056
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XIE
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