United States       Office of
          Environmental Protection   Emergency and
          Agency          Remedial Response
EPA/ROD/R09-93/097
August 1993
v°/EPA   Superfund
         Record of Decision:
         Newmark Groundwater
         Contamination, CA

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 50272-101
  REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/RO9-93/097
3. Recipient's Accession No.
    THIe and Subtitle
    SUPERFUND RECORD OF DECISION
    Newmark Groundwater Contamination, CA
    First Remedial Action
                                          &   Report Data
                                          	     08/04/93
                                          &
 7.  Authors)
                                          a  Performing Organization Rapt. No.
 9.  Performing Organization Name and Address
                                          10  Project Task/Work Unit No.
                                                                     11.  Contract(C)orGrant(G)No.
                                                                     (G)
 12.
    Sponsoring Organization Name and Address
    U.S. Environmental Protection Agency
    401 M  Street,  S.W.
    Washington,  D.C.  20460
                                          13.  Type of Report & Period Covered

                                             800/800
                                          14.
 15.  Supplementary Note*
                       PB94-964516
 10.  Abatract (Limit: 200 word*)

  The Newmark Groundwater Contamination site is a  5-mile area of  ground water
  contamination in San  Bernardino, California.  Land use in the area is predominantly
  residential and commercial, with a  small amount  of industrial use.  The 110-square mile
  aquifer,  known as the Bunker Hill Basin, is bounded by the San  Bernardino and  San
  Gabriel mountains to  the north, the Crafton Hills  and badlands  to the southeast,  and a
  hydrogeologic barrier formed by the San Jacinto  fault to the southwest.  Water flowing
  from all  parts of the aquifer joins in a confined  "artesian zone" before leaving the
  basin, where the Santa Ana crosses  the San Jacinto Fault Line.   Most of the western
  part of the basin is  an unconfined  aquifer with  no substantial  barriers to infiltration
  from the  surface.  The estimated half-million residents in nearby communities  use an
  aquitard  contained in the south central portion  of the basin to obtain their drinking
  water  supply.  In 1980,  State monitoring studies identified contamination by VOCs,
  including TCE and PCE,  in large portions of ground water in the Bunker Hill Basin.
  Fourteen  wells, which supply approximately 25% of  the city of San Bernardino's drinking
  water  supply, also were found to be contaminated above State and Federal levels.
  Following regional and State investigations, the State constructed four water  treatment
  systems to protect the water supply,  but after years of testing it became apparent that

  (See Attached Page)
17. Document Analysis     a. Descriptor*
   Record of Decision - Newmark  Groundwater  Contamination,  CA
   First Remedial  Action
   Contaminated Medium: gw
   Key Contaminants:  VOCs  (1,2-DCE,  PCE, TCE)

   b.   Identifiers/Open-ended Term*
   c.  COSATI Field/Group
ia Availability Statement
                          19.  Security Clan (This Report)
                                    None
                                                     20.  Security Class (This Page)
                                                               None
          21.  No. of Pages
                  38
                                                                              22.  Price
(See ANSI-Z39.18)
                                   See Jnafruction* on Revere*
                                                   OPTIONAL FORM 272 (4-77)
                                                   (Formerly MTIS-35)
                                                   Department of Commerce

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EPA/ROD/RO9-93/097
Newmark Groundwater Contamination, CA
First Remedial Action

Abstract  (Continued)

the solvents still continued to  flow southward, threatening other neighboring communities.
In 1986 and 1989, after several  State investigations suggested that the widespread
contamination had resulted from  numerous, unidentified sources; several plumes were
identified in the Basin, including an eastern Newmark plume and the western Muscoy plume.
In 1990, aerial photographs taken as part of EPA investigations, along with reports of
witnesses, suggested that the primary source of contamination was the result of
intermittent, improper disposal  activities from the 1950s to 1970s at a solvent disposal
pit (cat pit) located at the former site of the San Bernardino airport, near the Newmark
wellfield.  However, this could  not explain the fact that the solvents also were found in
wells scattered throughout the west side of the Shandin Hills, so EPA and the State now
believe that the contamination is not from a single source. Additionally, at one point,
EPA thought the Newmark and Muscoy plumes were distinct, but additional well drilling in
1992 confirmed that ground water flows from the west to east through a previously
undiscovered channel.  Based on  this information obtained during the RI, the San
Bernardino plume is no longer suspected to be the source of the contamination, and it is
now believed that the principle  contaminant source stems from the northwest side of the
Shandin Hills, and most likely contributes to both plumes.  Although the actual
contamination source has not been identified yet, several possible sources in the area
that currently are under investigation include Camp Ono, a former army base; an inactive
county landfill; and an area of  industrial development.  This ROD addresses an interim
remedy for the area of ground water contamination north and east of the Shandin Hills, as
the Newmark OU.  A separate action will address the ground water contamination west of the
Shandin Hills, as the Muscoy OU.  The primary contaminants of concern affecting the ground
water are VOCs, including 1,2-DCE, PCE, and TCE.

The selected remedial action for this site includes extracting and treating contaminated
ground water onsite, using either granular activated carbon (GAC) filtration, an
innovative modification of liquid phase GAC, known as advanced oxidation, or air
stripping, with vapor phase GAC  to control air emissions, as determined during the RD
stage; piping the treated water  to the public water supply system for distribution;
providing for a contingent remedy to recharge the treated water into the aquifer through
reinjection, if the public water supply does not accept all or any of the treated water;
and monitoring ground water.  The estimated present worth cost for this remedial action is
$49,900,000, which includes an unspecified O&M cost for 33 years.

PERFORMANCE STANDARDS OR GOALS:

Ground water cleanup goals are based on the more stringent of State standards or SDWA
MCLs,  and are expected to be met in the final action for this site.

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              NEWMARK OPERABLE UNIT

               RECORD OF DECISION



            PART I:     DECLARATION

            PART II:    DECISION SUMMARY

            PART III:   RESPONSIVENESS SUMMARY
NEWMARK GROUNDWATER CONTAMINATION SUPERFUND SITE

           SAN BERNARDINO, CALIFORNIA
  United States Environmental  Protection Agency
      Region 9 - San Francisco, California

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NEWMARK Record of Decision	ii	August 3. 1993


                        TABLE OP CONTENTS

                                                  Page No.

Part I.   Declaration                                  1

Part II.  Decision Summary                             4

     1.0  Site Location and Description                4

     2.0  Site History                           '      7

     3.0  Enforcement Activities                       10

     4.0  Highlights of Community Participation        10

     5.0  Scope and Role of the Operable Unit          12

     6.0  Summary of Newmark OU Site
          Characteristics                              13

     7.0  Summary of Site Risks                        13

     8.0  Description of Alternatives                  16

     9.0  Summary of Comparative Analysis
          of Alternatives                              18

     10.0 Applicable or Relevant and Appropriate
          Requirements                                 22

     11.0 The Selected Remedy                          31

     12.0 Statutory Determinations                     33

     13.0 Documentation of Significant Changes        "34

Part III. Responsiveness Summary                       35

     Executive Summary                                 35

     Part I - Responses to Written Comments            37

     Part II - Responses to Comments and Questions     45
               at Public Meeting Held April 14, 1993

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NEWMARK Record of Decision	1	August 3. 1993


                        RECORD OF  DECISION

              NEWMARK OPERABLE UNIT INTERIM REMEDY

                       PART  I.   DECLARATION



SITE NAME AND LOCATION

Newmark Groundwater Contamination Superfund Site
Newmark Operable Unit
San Bernardino,  California

STATEMENT OF BASIS AND PURPOSE

     This decision document presents the selected remedial action
for the Newmark Operable  Unit,  Newmark Groundwater Contamination
Superfund site,  chosen in  accordance with CERCLA as amended by SARA
and, to  the extent practicable,  the National  Contingency Plan.
This decision  is  based  on  the  administrative  record  for  this
operable unit.

     In a letter to EPA dated July 29, 1993 the State of California
concurred with the selected remedy for the Newmark OU.

ASSESSMENT OF THE SITE

     Actual or  threatened releases of hazardous  substances from
this site,  if not addressed by implementing the  response action
selected  in this ROD,  may  present  an imminent  and  substantial
endangerment to public health, welfare or the environment.

DESCRIPTION OF THE REMEDY

     EPA has selected  an  interim.remedy  for the Newmark plume of
groundwater contamination in the Newmark Groundwater Contamination
Superfund Site.  This portion of the site cleanup is referred to as
the Newmark Operable  Unit  (OU) .   The Newmark  OU is  an interim
action focusing  on contamination in the underground water  supply in
the Bunker  Hill Basin of San  Bernardino, north  and  east  of the
Shandin Hills (Figures 1  and  2).   The portion  of the groundwater
contamination west of  the  Shandin Hills, called  the Muscoy OU, will
be addressed in  a  separate action.  An OU is a discrete action that
comprises an  incremental step  toward  comprehensively addressing
Superfund site problems.  The  remedy and all of the alternatives
presented in  the feasibility  study were developed  to  meet the
following specific objectives for the Newmark OU:

     •    To inhibit migration  of groundwater  contamination into
          clean portions of the aquifer;

     •    To limit 'additional contamination from continuing to flow
          into the Newmark OU plume area;

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NEWMARK Record of Decision	2	August 3, 1993

     •    To  begin to  remove  contaminants from  the groundwater
          plume  for  eventual  restoration  of  the  aquifer  to
          beneficial uses  (This  is a long-term project objective
          rather  than  an  immediate  objective   of  the  interim
          action.)

     The  remedy  involves  groundwater  extraction  (pumping)  and
treatment of 8,000 gallons per minute (gpm)  in the  vicinity of 14th
Street, between Arrowhead and Waterman Avenues, at  the leading edge
of  the contaminant  plume,  and  an additional 4,000 gpm at  the
Newmark wellfield  (near 48th  Street and Little  Mountain  Drive)
where the contamination enters the eastern part of  the valley (Fig.
2).  The exact number,  location and other design specifics of new
extraction wells  will  be determined during the  remedial  design
phase of the project to inhibit  the migration of  the contaminant
plume most effectively.

     All the extracted contaminated groundwater shall be treated to
remove  VOCs  by  either  of  two  proven treatment  technologies:
granular activated carbon (GAG) filtration or air stripping.  EPA
determined during  the  Feasibility  Study (March 1993)  that  these
treatment technologies are equally effective at removing VOCs and
are similar in cost at this OU.  Both technologies have been proven
to be reliable in similar applications.  It is acceptable  to use
one technology for the  northern  (Newmark wellfield)  facility and
the other  at the  southern  treatment facility.   As a  result  of
comments received during the public comment period,  EPA may use a
modification of liquid  phase GAC  (Advanced Oxidation pretreatment)
if this modification proves to be effective and economical during
design phase testing and analysis.   The VOC treatment technology
which best meets the objectives of  the  remedy for the Newmark OU
will be  determined during the remedial design phase,  when more
detailed information  is available to assess effectiveness and cost.

     After treatment, the water shall meet drinking water standards
(maximum contaminant levels or MCLs) for VOCs.   If  air stripping
treatment is  selected,  air  emissions shall be treated  using the
best available control technology (e.g., vapor phase  GAC) to ensure
that all air emissions  meet applicable or relevant and appropriate
requirements.

     The treated water  will  be piped to the  public water  supply
system for  distribution.   Groundwater  monitoring wells will  be
installed and sampled regularly to help  evaluate the effectiveness
of the remedy.

     If the public water supply system does not accept any or all
of the  treated water  (possibly  due to water  supply needs),  any
remaining portion of water will be recharged into the aquifer via
reinjection wells near  the edge of the plume.  The  number, location
and design of the reinjection wells will be determined during the
remedial design phase to best meet the objectives  of  the remedy and
meet applicable or relevant and appropriate requirements.

     The total duration of the Newmark OU interim remedy will be 33
years, with the first three years for design and construction.  EPA

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NEWMARK Record of Decision	3	August 3. 1993

will review this action every  five  years  throughout this interim
remedy period and again at the conclusion of this period.

     The remedial action for the Newmark OU represents a discrete
element in the overall  long-term remediation of groundwater at the
Newmark Groundwater Contamination Superfund Site.  The objectives
of this interim action  (i.e.  inhibiting migration of groundwater
contamination  to  clean  portions   of. the  aquifer,  controlling
additional contamination from entering this portion of the aquifer,
and beginning to remove contaminant mass  from the aquifer in the
Newmark  Plume)   would   not  be  inconsistent  with  nor  preclude
implementation of  any  final,  overall remedial action  or actions
selected  by  EPA  in  the  future   for  the  Newmark  Groundwater
Contamination Superfund Project.

     EPA is the lead agency  for this project and the Department of
Toxic Substances Control of the State of California Environmental
Protection Agency is the support agency.

DECLARATION

     This  interim  action  is protective of human health  and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements directly associated with this action
and is cost effective.  This  action utilizes permanent solutions
and alternative treatment  (or  resource  recovery)  technologies to
the maximum  extent practicable, given  the limited scope  of the
action.  Because this action does not constitute the final remedy
for the site,  the  statutory preference for  remedies  that employ
treatment that reduces toxicity, mobility,  or volume as a principal
element will be addressed at the time of  the final response action.
Subsequent  actions are planned to fully address  the  principal
threats at these sites.

     Because  this   remedy will  result  in hazardous  substances
remaining  on-site  above health-based  levels,  EPA shall conduct a
review, pursuant to CERCLA Section 121;  42 U.S.C. Section 9621, at
least once every five years after commencement of remedial action
to ensure that the  remedy  continues  to provide adequate protection
of human health., and the environment.
John C.'Wise     /                      Date
Acting Regional Administrator

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NEWMARK Record of Decision	4    	August 3. 1993
                    PART II-  DECISION SUMMARY

     This Decision Summary provides an overview of the Nevmark ou
interim remedy, including a  description of the nature and extent of
contamination *:o be addressed, and the remedial alternatives, the
comparative analysis of the remedial alternatives,  a description of
the selected remedy and the rationale for remedy selection.

1.Q  SITE LOCATION AND DESCRIPTION

     The Newmark OU is located within the Bunker Hill Basin  (also
known  as  the  Upper Santa  Ana  River  Basin)  in  San Bernardino,
California.  The following  sections  present a basin description,
regulatory history,  and a summary of the Remedial Investigation and
Feasibility Study (RI/FS) activities within the Newmark Superfund
Site.

l.l  Description of the Bunker Hill Basin

     The Newmark Groundwater Contamination affects a  large portion
of a  110  square  mile  aquifer  in the San  Bernardino Valley  of
southern California. (Figure 1).   The  aquifer, known  as the Bunker
Hill Basin,  is bounded by  the  San  Bernardino  and  San  Gabriel
Mountains  to  the north,  the Crafton Hills  and badlands  on the
southeast, and by a hydrogeologic barrier formed by the San Jacinto
fault along the southwest. (Figure 2)  Water  flowing  from all parts
of the aquifer  join  in a  confined 'artesian zone'  before leaving
the  basin where  the  Santa Ana  River crosses  the  San  Jacinto
faultline.

     Coarse  erosional  material   (alluvial   and   river   channel
deposits)  have accumulated in the  this area of the basin to depths
of 400 to  over 1900  feet, atop  older   formations  that  act  as
barriers to further vertical movement.   A  fold in  one  of these
impermeable bottom  formations forms the  Shandin  Hills (formerly
called Bunker Hill in reference to military emplacements from the
WWII era), which force groundwater flowing from the north and west
to flow aroundl  either  side  rather than directly south toward the
Santa Ana River.

     Most  of  the  western portion  of  the basin is  an unconfined
aquifer, with  no substantial barriers to infiltration  from the
surface.   In  the  lowest area  of  the basin  (the   south-central
portion around the Santa Ana River), several extensive clay layers
have 'formed an  aquitard,  overlying and capping the  water-bearing
sand and gravel aquifers.   This  confined portion  of the aquifer
produces tremendous supplies of water for nearby communities.

     The  aquifer  receives  rainfall  and  natural runoff  from the
surrounding mountains,  collected  floodwaters  from rivers, creeks
and washes, and water  imported from outside the region  that is
spread over percolation basins.   According  to the San Bernardino
Municipal  Water District,  the  Bunker Hill  Basin is  capable of
storing approximately 5 million acre-feet (1.6 trillion gallons)

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                           EXPLANATION
33° 52' 30
    T5S
        .....  BOUNDARY OF STUDY

                AREA (Bunker Hill basin)
UPPER SANTA ANA RIVER

 BASIN  Approximate
                          SAN


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0     100 KILOMETERS  D'*° n?: " "''«»"   ''«*
                                                FIGURE 1  Location of study area.

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         n  5 w
                                   117*20'
R. 4W.
                                                                                                                                          EXPLANATION

                                                                                                                                           UNCONSOUDATED DEPOSTTS
                                                                                                                                           PARTLY CONSOLIDATED DtPO'
                                                                                                                                           CONSOLIDATED ROCKS

                                                                                                                                           CONTACT
                                                                                                                                           FAULT
                                                                                                                                           BOUNDARY OF STUDY AREA
                                                                                                                                           GROUND WATER BARRIER

                                                                                                                                —1700	 POTENTIOMETRIC COT/TOUR  !•
                                                                                                                                             cotnpodlt a)OM4< >l wtikh win
                                                                                                                                             tautl would tuM Hood m nghdy.
                                                                                                                                             wttt tapping both uppti an) \o»
                                                                                                                                             •qullm Contour IniBvtl vwul>l<
                                                                                                                                                Oilum li Mi Icvtl

                                                                                                                                           IXRECTXINOF GROUNDWATII
                                                                                                                                             MOVEMENT
APPROXIMATE LIMITS
OF MUSCOY PLUME
APPROXIMATE  LIMITS
OF NEWMARK PLUME
                                                                                                                  G«olof? modifird from Dibbltt (1963. I9OI) tnd DuKhtr mil r.tiiin <
                      FIGURE  2 •   Altitude ol potenHometrtc surface and direction of ground-water movement, summer 1986.

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NEWMARK Record cf Decision	7	August 3,  1993

and  producing  250,000 acre-feet  (81  billion  gallons)  each year.
Nearly a  half-million residents of San Bernardino, Riverside and
surrounding communities rely on this portion of the aquifer  for at
least part of their water supply.

     The  Newmark  OU lies almost entirely within  the city of San
Bernardino.  Residential  and commercial use predominates throughout
the OU, although some industrial development has been identified.
Very little of the area remains undeveloped.

1.2  Description and Background of the Newmark OU     .

     The  solvents  (tetrachloroethene, PCE,  and trichloroethene,
TCE)   spreading   from   the   Newmark  Superfund   site   threaten
approximately one-half of the Bunker Hill Basin.

     The  EPA placed the  Newroark site  on  the  National Priorities
List (NPL) in March, 1989.  At that time,. EPA believed the eastern
(Newmark)  plume of contamination to be completely separate from the
western (Muscoy)  groundwater  contamination.   Results  of earlier
investigations identified a possible contaminant source  (a disposal
pit  for   waste  liquids  at  a former  airport)  near  the Newmark
wellfield.

     The  EPA Remedial Investigation  (RI)  began in late 1990.   In
1992 eight sets of monitoring wells were drilled and sampled  in the
Newmark OU, and nearby city and state wells were  also sampled by
EPA.  PCE and TCE were the most prevalent contaminants in all the
contaminated wells.   Other VOCs have also been detected in trace
quantities.   Results  from the RI  showed  that   the  originally
suspected source  of  the Newmark plume was not currently a  source of
contamination.    Additional  well drilling  in  the  summer of  1992
traced groundwater contamination through a previously undiscovered
underground channel flowing from the western (Muscoy) side of the
valley.   The Newmark site was  officially expanded in September,
1992 to include the Muscoy plume.   EPA began additional RI studies
for the Muscoy  plume and  finished a feasibility study (FS) for the
Newmark OU which evaluated a range of cleanup alternatives  for
addressing the.five mile  long  contaminated groundwater plume.  The
RI/FS report for the Newmark OU was finalized in March,   1993.


2.0  SITE HISTORY

     In 1980, the California  Department  of  Health Services (DHS)
initiated a monitoring program  in  San Bernardino  to  test for the
presence  of industrial chemicals  in the  water from public supply
wells.  The  results  of  initial tests and  of  subsequent testing
revealed  the presence  of PCE   and  TCE  contamination   in  large
portions of the groundwater of the Bunker Hill Basin.

     Fourteen wells operated  by the city  of San Bernardino Water
Department in the North San Bernardino / Muscoy area were found to
contain concentrations of PCE and TCE above the state and federal
MCLs  of  5 parts  per billion (ppb)  for both  TCE and PCE.   The
solvents were found in wells scattered around the north, east and

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NEWMARK Record of Decision	8	August 3, 1993

west sides of the Shandin Hills. (Figure 3)  The affected wells had
supplied  nearly 25  percent  of  the water  for  the  city  of San
Bernardino.  As  of  1993, a total  of thirteen public water supply
wells have been  contaminated by the solvents apparently spreading
from the  Newmark plume,  and  seven water supply  wells  have been
affected in the  area of  the Muscoy plume.

     Following  investigations by  the Santa  Ana  Regional  Water
Quality Control Board and California Department of Health Services
(now the California  EPA Department of Toxic Substances Control),
the  state provided  over  $6  million  to  construct  three  water
treatment systems, with a fourth under construction, to protect the
public water  supply.   After years  of  testing  it became apparent
that the solvents in the  groundwater were continuing to flow south,
threatening many more wells operated by San Bernardino, Riverside
and other communities.   The state reguested federal involvement to
address this regional problem.

     It  should  be  noted that  the  cities of San  Bernardino,
Riverside and other water agencies  in the  area  closely monitor the
quality of drinking water delivered to residents. The water served
to  residents   meets   all  Federal  and   state  drinking  water
requirements.

     The  state   investigations published  in 1986  and  1989  both
suggested  that  the widespread  contamination in  northern  San
Bernardino probably  resulted from numerous small,  unidentified
sources.  The Shandin Hills and nearby hill formations were assumed
to separate  the  eastern  (Newmark area) aquifer from  the western
(Muscoy area) aquifer,  making it unlikely that all 14 wells could
have been contaminated from a single source.

     Continued  monitoring  of  existing  water  supply   wells  and
monitoring wells constructed by the state established a record of
contamination relatively uniform in composition and concentration
throughout the  area  north and east of the Shandin Hills.   This
pattern strongly suggested a single plume in this area.

     Aerial   photographic  analysis   was  completed .  by  EPA's
Environmental "Monitoring Systems  Laboratory in September,  1990.
This analysis, along with interviews of witnesses, suggested that
the  primary  source  of   contamination  was  a   suspected  solvent
disposal pit  ('cat  pit') on  the  former  site  of  the  private San
Bernardino Airport.  This activity occurred from the late 1950's
intermittently through the early  1970's.   Several minor activities
in different  parts  of the  airport site were  also identified as
potential waste  releases.  No other  sources  could be  identified
between the  disposal  site  and  the closest  uncontaminated wells
upgradient.  The plume from this  single  source would extend over
four miles.  The waste  disposal pit was also within several hundred
feet of the Newmark  wellfield (four City of San Bernardino Water
Department wells) .  These wells exhibited the highest concentration
of contaminants measured in any wells  in the area, nearly  200 fJ.g/1.
(parts per billion) of PCE.

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            FIGURE 3:  LOCATION  OF PUBLIC WATER  SUPPLY  WELLS  AND IDENTIFIED  CONTAMINANT PLUMES
                        IN  THE BUNKER HILL GROUNDWATER  BASIN

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NEWMARK Record of Decision	10	August 3, 1993

     In  1984-85,  the area  near the "cat  pit",  which  was  later
identified as the probable contaminant source, was developed into
a residential community.

     Based   on   information   obtained   during   the   Remedial
Investigation,  the  San Bernardino  Airport  site is  no  longer
suspected to be  the source  of the Newmark  Plume.    It is  now
believed that the principle  source  (or sources)  lies on the west
side of  the  Shandin Hills  and likely contributes  to  both  the
Newmark and Muscoy Plumes.

     While ongoing investigations attempt to identify the source,
EPA determined  that  the Newmark plume could  be addressed  as  an
interim action (the Newmark OU).
3.0  ENFORCEMENT ACTIVITIES

     The  results   of   the  Remedial  Investigation   and  other
investigations undertaken by EPA and state agencies indicate that
the project lead for the Newmark OU will  remain with  EPA until a
probable source is located.

     Considerable effort was expended on a PRP search while the San
Bernardino Airport  site was suspected  to be  the source  of  the
contamination.  Results of the  Remedial  Investigation traced the
source more than one mile upgradient of the suspected source.  No
residual contamination was  found  in the unsaturated  zone or the
upper portion of the aquifer immediately  beneath former disposal
pits.  The airport site  is  no longer considered a likely source of
the contamination.

     The focus of the ongoing PRP search will be potential sources
located to the  northwest  of the Shandin Hills.   These potential
sources include Camp Ono  (a WWII-era  army base decommissioned in
1947   and    subsequently    developed   for    residential   and
commercial/industrial use), a closed county landfill,  and an area
of industrial,development.  The Department of  Defense was sent a
copy  of  the  Newmark  Proposed   Plan  at the  start of  the public
comment period,  along with an information request letter concerning
the operations at the former Camp Ono.


4.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

     EPA's  preferred   alternative,   as   well  as   four  other
alternatives were described in EPA's Proposed Plan  for the Newmark
OU (March 1993) .  The Proposed Plan was in the form of  a fact sheet
and was distributed  to  all parties  on EPA's  mailing list for the
Newmark project.   The  original  30 day public  comment period was
extended to  6 weeks  (45  days)  after EPA received  requests for
extensions from members of the public.  The public comment period
closed on May 5,  1993.   EPA received approximately 50 comments.
These comments and EPA's responses to these comments are summarized
in Part III (the Responsiveness Summary)  of this ROD.

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NEWMARK Record of Decision	11	August 3,  1993

     A press release to announce the release of the Proposed  Plan
was issued March 17,  1993.  Notice of the public meeting as well as
the availability of the Proposed Plan was published in the Inland
Empire  Sun on March  18,  1993.   In addition,  several newspaper
articles  were  written  about  the  remedial   investigation,  the
feasibility  study  and the  Proposed  Plan  for  the   Newmark OU
including: Inland  Empire  Sun - March  18,  1993; Riverside Press-
Enterprise - March 18,  1993.   A map  of  the Newmark OU was provided
in the Proposed Plan and the various newspaper articles published
maps and described the area that would be impacted by the Newmark
OU.                              "       .              .       .

     A  public  meeting was  held  in the City  of  San  Bernardino
Council Chambers  on April 14,  1993,  to discuss  EPA's preferred
alternative and the other alternatives.  At this meeting EPA  gave
a  brief  presentation  regarding  the  Proposed  Plan,  answered
questions, and accepted comments from members of the public.   This
meeting was broadcast live on the local cable channel.

     EPA expended considerable effort developing  strong community
relations.  A Technical Advisory Committee has been successful in
maintaining close communication with local and state agencies.  For
communication with the  local  community, three principle mechanisms
have been  employed:  formal  presentations  (open houses, meetings
with organizations and fact sheet distribution), contact with the
print and  electronic media  and  informal discussions  with  home-
owners '  associations and individuals.

     The  San  Bernardino and Riverside  papers have published  a
number of positive and  well-researched  articles  about the project.
Major  television  networks   broadcast  reports  of  the  drilling
operation in February,  1992.   The Project Manager participated in
a 90 minute call-in talk show on the public television station in
August,  1992.

     Invitations were accepted to speak at a city-wide Neighborhood
Watch meeting and at a San Bernardino "town-hall" meeting sponsored
by the  California Water Education  Foundation.   Two  open  house
meetings were held to introduce the field work in February,  1992,
and another open house was held on-site for the  community and press
shortly after drilling  began.  Three fact sheets in addition to the
Proposed Plan have been distributed.

     Three different home-owners' associations accepted  EPA's offer
for informal discussions of  the project.  Drilling  around  these
communities  was  greatly  facilitated  by   open  communication.
Presentations were  made to  the  staff and teachers  at a  local
school,  and the Project Manager  taught the  5th grade class about
groundwater and chemical pollution  as it relates to  the Newmark
site.

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NEWMARK Record of Decision	12	August 3, 1993
5.0  SCOPE AND ROLE OF THE OPERABLE UNIT

     The interim remedial  action  for  the  Newmark OU represents a
discrete  element   in  the  overall   long-term   remediation  of
groundwater in the San Bernardino area.  Since the source has not
been identified, the final overall plan for the remediation of the
entire Newmark  Groundwater Contamination Site  has not  yet been
determined.   The Newmark plume constitutes a major portion of the
contaminated aquifer  and  this  remedy will be a  significant step
toward eventual remediation.  EPA  does  not.expect these objectives
to be  inconsistent  with,  nor preclude, any final  action for the
entire site.

     The objectives of the Newmark OU are:


     •    To inhibit  migration of groundwater  contamination into
          clean portions of the aquifer;

     •    To limit additional contamination from continuing to flow
          into the Newmark OU plume area;

     •    To begin  to remove  contaminants  from the  groundwater
          plume  for  eventual  restoration  of  the  aquifer  to
          beneficial uses  (This is  a  long-term  project objective
          rather  than  an immediate   objective  of  the  interim
          action.)

     The analysis of  the  no-action option indicates  that unless
this action  is implemented,  the  contamination will  continue  to
spread to clean areas of the aquifer  which are  currently used as
important sources of drinking water.

     EPA is  currently using the results of the Newmark OU remedial
investigation  in  basinwide  feasibility studies  to  address  VOC
contamination  in the Muscoy. OU  and  to  investigate  potential
sources.   As  part   of the Muscoy  OU  FS,  EPA  is revising  and
recalibrating .the groundwater  flow  model  for the  entire site to
incorporate the most recent data.   When sufficient information is
available on the contaminant  source  and transport from the source,
EPA  will review  and  evaluate various groundwater  remediation
options for  the complete site.  It is  expected that the Newmark OU
remedy will constitute an integral part of the complete remedy.

     EPA will continue to  monitor  aquifer behavior and contaminant
transport as part of this interim action. The information gathered
will  be  important  in the analysis  of a  remedy for  the entire
Newmark site.

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NEWMARK Record of Decision	13	August 3, 1993

6.0  SUMMARY OF NEWMARK OU SITE CHARACTERISTICS

     Results  of  EPA's  Remedial Investigation  provided critical
understanding   in   three   general   areas:   groundwater   flow
characteristics,  contaminant identification and concentration, and
potential for exposure through the unsaturated zone.

     The result that was least expected was that  a significant flow
of contaminated groundwater was entering the eastern  (Newmark OU)
side of  the basin  from the western  portion (Muscoy  OU) .   Most
recharge to  the  Newmark  OU  part, of  the Bunker Hill. Basin does
originate along the  San  Bernardino Mountains to the  north, and this
source is not contaminated.  Another important observation was that
clay  or silt  layers  that  would  inhibit  vertical   contaminant
migration were not present in the monitoring well drilled near the
leading edge of the plume. The  contaminants cannot be  expected to
remain in an isolated vertical layer.  A groundwater flow model was
successfully developed to describe the aquifer behavior.

     The contaminants  identified were  predominantly  chlorinated
solvents.  Tetrachloroethene  (PCE)  was found in all contaminated
wells  at concentrations  less  than 40  parts per  billion  (ppb) .
Trichloroethene  (TCE) was the next most  common contaminant,  and
never exceeded 10 ppb.  Other related solvents were identified at
concentrations below drinking water standards. Chlorof luorocarbons
(freons) were also observed.   Monitoring wells were constructed to
collect  samples  at  two or  more  depths  at each  well location.
Generally,  the highest concentrations of contaminants were  found in
the deeper wells.  Typically, a well near bedrock  (about 500 feet
deep) would have PCE levels of 10 to 20 ppb while  the  well  in the
upper  part  of the  aquifer  would have  PCE  less  than  2 ppb.
Monitoring well data compared quite closely with data  from  nearby
water production wells.

     Subsurface soil samples at the originally suspected source had
no  detectable  levels of  contaminants.   Air samples  from  homes.
directly above the contaminant plume had no more volatile chemicals
than samples from homes outside the plume area.   Levels were not
different from, values observed in homes throughout  the Los Angeles
metropolitan area.   These results  confirmed that volatilization
from the subsurface  does not provide a  measurable exposure pathway.


7.0  SUMMARY OF SITE RISKS

     Baseline risk assessments are conducted at  Superfund  sites to
fulfill one of the requirements of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).  The NCP (40  CFR Part
300) requires  development of  a  baseline risk assessment at sites
listed  on  the  National  Priorities List  (NPL) under  CERCLA.  The
CERCLA process for baseline risk assessments is intended to address
both human health and the environment.  However, due  to the  nature
of the contamination at the site and the highly urbanized setting
of the Newmark OU, the focus of the baseline risk assessment  was on
human health issues, rather than environmental  issues.

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NEWMARK Record of Decision	14	August 3, 1993

     The objective of the baseline risk assessment for the Newmark
OU was to evaluate the human health and environmental risks posed
by the contaminated groundwater if it were to be used as a source
of drinking water without treatment.  The baseline risk assessment
incorporated the water quality information generated during the RI
field investigation and  sampling  program to  estimate current and
future human health and environmental risks.

     The  risk  assessment was  conducted in  accordance  with  EPA
guidance including:  Guidance for Conducting Remedial Investigation
and Feasibility Studies under CERCLA (USEPA, 1988), Risk Assessment
Guidance for Superfund. Vol. I  Health Evaluation Manual (Part AV
and  Vol.  2  Ecological  Assessment (USEPA,   1989),  The  Exposure
Factors Handbook  (USEPA,  1989), and Risk Assessment Guidance for
Superfund  Human   Health  Risk   Assessment.   USEPA  Region   IX
Recommendations (USEPA, 1989).

     A risk assessment involves the qualitative  and quantitative
characterization of potential health effects of specific chemicals
on  individuals or  populations.   The  risk  assessment  process
comprises four  basic  steps:   1)  hazard identification,  2)  dose-
response  assessment,  3)   exposure   assessment,  and   4)   risk
characterization.   The purpose of  each element is as follows:

     •     Hazard identification characterizes the potential threat
          to human health and the environment posed by the detected
          constituents.

     •     Dose  response   assessment   critically   examines   the
          toxicological data  used to  determine  the  relationship
          between the experimentally  administered animal dose and
          the predicted  response   (e.g., cancer  incidence)   in  a
          receptor.

     •     Exposure assessment estimates  the  magnitude,  frequency,
          and duration of human exposures  to chemicals..

          Risk  characterization  estimates  the  incidence. of  or
          potential for an adverse health  or environmental effect
          under the conditions of  exposure defined in the exposure
          assessment.

Human Health Risk Assessment

     Risk assessments estimate the  possibility that  additional
occurrences of cancer will result  from exposure to contamination.
The background probability of  developing cancer from all causes in
California is approximately one in four  (or 250,000 in a million).
An excess cancer risk  of  1 in a million means that a person exposed
to a certain  level of contamination  would  increase the risk of
developing cancer from 250,000 in a million to  250,001 in  a million
as a result of  the exposure.   EPA considers  excess cancer  risks
greater than 100 in a million to be unacceptable.

     In preparing  risk  assessments,   EPA  uses very conservative
assumptions that weigh in favor of protecting public health.  For

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NEWMARK Record of Decision	15	August 3. 1993

example,  EPA may assume  that  individuals consume  two liters of
drinking water from wells  situated within a contaminant plume every
day  for  a  30-year  period,  even  though typical  exposure  to the
chemical would be far less.

     EPA  included  two   potential   exposure  routes  (ways  the
contamination gets into the body) in the risk assessment:

•    drinking the groundwater during residential use;  and

•    inhaling  the  chemicals  in groundwater   as  vapors .during
     showering.

     Skin contact with contaminated water was also considered but
EPA found that it didn't pose a significant risk.  Results of the
RI indicated  that direct exposure to  volatile  organic compounds
(VOCs)  from  the  soil  or  water  100  feet  below   ground  was
insignificant at this site.

     Chemicals of potential concern in the Newmark OU  used in the
risk  assessment  calculations   included:   PCE,   TCE,  cis  1,2-
dichloroethene (DCE),  and six other VOCs detected in at least one
well.  EPA will continue  to monitor the groundwater  in  the Newmark
OU for any changes that would affect the risk analysis.

     The results of the risk  assessment indicated that  the current
contaminant levels in  the aquifer of  the Newmark OU would not meet
state or Federal drinking water standards  if  this water were to be
delivered directly  to  local residents,  without being  treated.
However,  the  levels are  currently below  the concentrations that
would pose  an unacceptable risk  to  human health,  as defined by
CERCLA.   If the groundwater  were  used  as  a drinking water source
without  treatment,  the   chance  of  developing  cancer during  a
lifetime would  increase  by as much  as 20 in a million.   EPA is
taking an action  at the Newmark  OU  in  order to meet the drinking
water standards  (MCLs) even  though the .risk levels  do not exceed
100 in a million.                 .     " .

     The baseline risk assessment for the Newmark OU is presented
in the Remedial Investigation and Feasibility Study Report for the
Newmark.OU  (March 1993).

Environmental Risk Assessment

     Given  the  present  developed condition  of  the  site  and the
major' exposure pathway consideration of contaminated groundwater,
there was  no  expectation for significant  impact  to potential
environmental receptors.  Urbanization has already replaced habitat
potential; therefore,  no significant number of receptors appeared
to be present.   There appeared  to  be  no  apparent  mechanism for
exposure to environmental receptors from contaminated groundwater.
Also,  there  was no  indication  that  future  site  plans  would
reinstate   habitat   and   thereby   recreate  a  potential   for
environmental receptors in the future.

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NEWMARK Record of Decision	16	 August 3, 1993

8.0  DESCRIPTION OF ALTERNATIVES

Development of Alternatives to Meet Project Objectives

     Before  developing  a  range  of  cleanup  alternatives  for
evaluation, EPA identified  the  objectives  of  the interim cleanup
for the Newmark OU.   All of  the  alternatives were screened for: 1)
effectiveness at protecting public health and the environment, 2)
technical  feasibility   (implementability),  and  3)  cost.    In
addition,  the  alternatives were  developed  to meet  the specific
cleanup objectives for the Newmark OU described previously.

               IUP Alternatives

     Based on the results of  the  RI,  EPA identified five cleanup
alternatives  for  addressing  groundwater  contamination  of  the
Newmark  OU.    Detailed  descriptions  of  these alternatives  are
provided in the Newmark OU RI/FS Report  (March  1993) .  Rather than
including all potential  combinations  of extraction locations and
amounts,  the  initial  screening  process  identified  the  most
efficient  extraction   scenario  that  would  meet   the  stated
objectives.  The  five alternatives were evaluated  based on nine
specific criteria:  1) Overall Protection of Human Health and the
Environment,   2)   Compliance  with  Applicable  or  Relevant  and
Appropriate Requirements  (ARARs),  3)  Long-term Effectiveness and
Permanence, 4) Reduction of Toxicity, Mobility or Volume through
Treatment, 5)  Short-term Effectiveness, 6) Implementability,  7)
Cost, 8) State Acceptance, and 9)  Community Acceptance.

     With the exception  of the  Alternative  1  - No Action,  all of
the alternatives  involve the extraction of 4,000 gallons per minute
(gpm) of groundwater near the Newmark wellfield  and 8,000 gpm of
groundwater near the  leading  edge of  the plume (approximately at
14th Street between Arrowhead  and Waterman Avenues)  for a period of
30 years.  Individual wells would pump from 800 to 2,000 gpm, the
range for a typical city drinking water well..

     A computer model was used to determine that these extraction
rates would result in effective inhibition of plume migration and
optimal contamination removal for this  interim action.   With the
exception of Alternative 1  -  No  Action, all  of  the alternatives
would involve the  construction  and operation  of  a VOC treatment
system,  construction and sampling of additional monitoring wells,
and analysis of  any  changes  in the current operations of nearby
public water supply wells.

     During the  first three  years  after the  ROD  is signed, the
remedy  would  go   through   the   remedial  design  and  initial
implementation stages.  EPA must plan,  build the equipment and test
it to make sure it functions  properly.

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NEWMARK Record of Decision	17	August 3. 1993

ALTERNATIVE 1:  No Action

     This  alternative  serves  as  a  baseline  to compare  other
alternatives.  This alternative is evaluated to determine the risks
that would  be posed to public  health and the  environment  if no
action were taken  to treat or contain the contamination.   The No
Action Alternative would  involve only groundwater monitoring; no
additional  cleanup activities  would  be  conducted.   The  cost of
constructing the necessary monitoring wells and sampling them over
30 years would be approximately $3.5 million  (present net worth).


ALTERNATIVE 2:   Extract/Treat(Granular  Activated Carbon)/Public
Water System

Extraction
     Alternative  2  involves the   extraction  of  8,000  gpm  of
contaminated groundwater placed  at the leading edge of the Newmark
plume and extraction of 4,000 gpm within the plume  near the Newmark
wellfield.  The extraction wells would be located to inhibit most
effectively the migration of the contaminant plume.

Treatment
     The extracted groundwater would be transmitted via underground
piping to Granular Activated Carbon  (GAC) treatment  plants (two
separate treatment plants, one for each set of extraction wells).
(Note that Alternative  3,  involving  treatment  by air stripping, is
considered by EPA  to be equivalent to Alternative 2,  and may be
substituted for  all  or part of  Alternative 2  during  the design
phase of the project.)

Final Use of Treated Water
     The  treated  water  would meet all  legal requirements  for
drinking water and would be piped to the public supply  system for
distribution.   Groundwater monitoring wells would be installed to
evaluate  the  effectiveness  of  the  remedial action.  Following.
approximately 2 to 3 years for design and construction,' this system
would operate  for 30  years.   Operation of  nearby public  water
supply  wells  is  not  expected  to  interfere  with  this  remedy,
although any significant changes in operations would be analyzed to
determine the effect on this cleanup  action.   EPA will conduct a
review of the project effectiveness every five years.


ALTERNATIVE   3:     Extract/Treat(Air   Stripping  with  Emission
Control)/Public Water System

     Alternative  3 involves  the same  extraction system,  final
distribution and monitoring design as Alternative 2.   Alternative
3 differs from Alternative 2 in  the treatment of  the extracted
groundwater to remove VOCs to meet  drinking  water standards.   In
Alternative 3, the extracted contaminated water would be  treated by
air stripping with emission  control to  meet  the  South Coast Air
Quality  Management  District's  requirement   for  best  available
control  technology.    Currently,  vapor-phase  granular  activated
carbon meets  this requirement,  and EPA  used  this technology for

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NEWMARK Record of Decision	18 	August 3, 1993

cost   and  .effectiveness   analysis.     New   emissions  control
technologies  developed  prior  to  the  final  design  could  be
considered if they meet the air quality requirement.  Air stripping
is  essentially  equal  to GAC  (Alternative  2)  in effectiveness,
technical feasibility and the remaining criteria.


Alternative 4: Extract/Treat (Advanced Oxidation - Peroxide/Ozone)/
Public Water System

     Alternative  4   involves  the  same extraction,  end use  and
monitoring design as Alternative 2.  The extracted water would be
treated for  VOCs using  an  advanced oxidation  process  that uses
peroxide and  ozone to  destroy  (oxidize)  the contaminants (rather
than  transferring the  contaminants to  a  carbon  filter).    The
advanced oxidation process  was the primary treatment  method for
this  alternative.    The treated  water  would meet  all  legal
requirements for a drinking water supply  and  would be  piped to a
public distribution system.  Groundwater monitoring wells would be
installed to evaluate the effectiveness of the action.


ALTERNATIVE 5:  Extract/Treat (GAC or Air  Stripping)/Return to the
Aquifer via Reinjection).

     Alternative  5  involves the  same extraction,  treatment and
monitoring designs as Alternative 2  (including the option to use
either GAC or air stripping to treat the extracted water for VOCs).
The water would  be  returned to the aquifer in reinjection wells
downgradient from the extraction  wells.   The  treated water would
meet drinking water standards before being returned to the aquifer.
9.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     A comparative analysis of  the  alternatives against the nine
evaluation criteria is presented in this, section.

No Action versus the Nine Criteria,  clearly, Alternative 1 would
not be effective  in the  short-  and long-term in protecting human
health and the environment as  it does not provide for removing any
contaminants from the aquifer, for inhibiting further downgradient
contaminant plume migration, or for reducing the  toxicity, mobility
and volume  of contaminants through treatment.   Implementing the
no-action alternative would be  simple and  inexpensive  since it
involves only groundwater monitoring.  As indicated by the baseline
risk assessment  presented in  the RI Report, Alternative 1 could
pose both carcinogenic and non-carcinogenic risk if a person were
exposed to  the groundwater from the  upper zone  of  the aquifer,
although these risks  are below the 100 in  a million excess risk
level  (10~4)  which EPA  considers  generally unacceptable.   The
current contaminant level would  not meet state or federal drinking
water standards  if this  water  were to be  delivered  directly to
local residents  without  treatment.   Loss  of  a  valuable water
resource  from continued  degradation  of the  aquifer is  a major

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NEWMARK Record of Decision	19	August 3. 1993

concern for the State and the public.

Overall Protection of Human Health and the Environment, Short Term
Effectiveness and Long Term Effectiveness.

Alternatives 2,  3,4  and 5 have the same effectiveness in the short
and  long term  in reducing the  risk  to  human  health  and  the
environment  by  removing  contaminants  from  the    aquifer;  by
inhibiting  further  downgradient  contaminant  migration;  and  by
reducing the toxicity, mobility and volume of contaminants in the
aquifer.                                              .

Reduction of Toxicity, Mobility and Volume through Treatment.  The
VOC treatment technologies used in Alternatives 2, 3  and 5 (either
air  stripping  with  emission  control  (e.g.,  vapor-phase  GAC
adsorption)   or  liquid  phase   GAC adsorption)   are technically
feasible and effective in meeting ARARs for VOCs  in  the extracted
and treated groundwater.   Treatment of the extracted contaminated
groundwater via air  stripping  with vapor-phase GAC adsorption or
liquid phase GAC adsorption would reduce substantially the toxicity
and mobility of  contaminants in the aqueous phase.  The adsorption
of  contaminants  onto  the  GAC   would  reduce  the  volume  of
contaminated media.   However,  a substantially larger quantity of
contaminated GAC media would be generated with either  air stripping
with  vapor-phase  GAC  or  liquid-phase GAC  systems  compared  to
perozone oxidation (which is a  destructive technology) followed by
either air  stripping with vapor-phase  GAC adsorption or liquid-
phase  GAC.    This contaminated  GAC  would  require  disposal  or
regeneration.  During the design phase, an  alternative emission
control technology will be tested  to eliminate the need for vapor-
phase  GAC  while meeting  the  Best Available  Control Technology
requirement.

     Treatment  of the  extracted contaminated  groundwater  via
perozone oxidation in Alternative 4 would destroy greater than 90
percent  of  the  VOCs,   and   generate  a.  smaller,  quantity  of
contaminated GAC media compared .to the. conventional technologies
alone.  VOC  treatment using perozone oxidation has  only been tested
and applied  in pilot-scale/limited applications,  and limited O&M
data  are  available.    Concern  has  been  expressed  over  the
reliability   of   this   innovative  technology   at   large-scale
application  for drinking water  supply treatment.    Incomplete
oxidation  can  lead   to  the  formation  of   by-products   such  as
formaldehyde which would  also need to  addressed.   Coupled with the
uncertainties associated with design,  capital  and operational costs
and d-ay-to-day reliability at a large scale,  and  finally the fact
that a municipality  will  be  receiving this water, all combine to
make Alternative 4 less  preferable than Alternatives  2,  3  and 5
which  propose  using   liquid  phase GAC  or  air  stripping  for  VOC
treatment.

     As a result  of  comments received  during the public comment
period, EPA further  evaluated  the use of an advanced oxidation
system as pretreatment for liquid-phase GAC.   Additional research
on perozone use and revised cost estimates based  on  a bench scale
treatability  study  can   be found in the   following  technical

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NEWMARK Record of Decision	20	.	August 3, 1993

memorandum:  Analysis of "Hybrid"  Advanced Oxidation Pretreatment/
Activated Carbon Alternative for the Newmark Operable Unit   (June
25, 1993)  included in the Administrative Record for the Newmark OU.
Pretreatment  with a  destructive  technology has  the theoretical
advantage  of  reducing  contaminant  mass  while  enhancing  the
operation of a reliable conventional technology.   EPA may use this
modification of liquid phase GAC if this modification proves to be
effective and economical during design phase testing and analysis.

Compliance with ARARs.  As discussed in the ARARs section (Section
10) of this ROD, since this remedial action is an interim action,
there are no chemical-specific ARARs for aquifer cleanup for any of
the alternatives.   For Alternatives 2  through 5,  the  chemical-
specific ARARs for the treated water from the VOC treatment plant
at this site  are  Federal MCLs and more stringent  State  MCLs for
VOCs.   Alternatives  2,  3, and  5 are  expected  to meet these ARARs
for the treated water.  There is some uncertainty regarding the
ability of Alternative 4 to meet these ARARs because perozone has
not been used  to  treat such high concentrations  of  VOCs  at such
high flow rates.  Therefore, there is the potential  for not meeting
MCLs unless the air  stripping  or  liquid-phase  GAC unit  following
the perozone system  is a  redundant  treatment  system (which would
add substantially to the cost).

     For the Alternatives that  involve distribution of the treated
water to a public water supply  system  (Alternatives  2,  3  and 4),
secondary drinking water standards are ARARs.  For water that will
be served at the tap, all legal requirements will have to be met.
In Alternative 5,  the treated water will meet MCLs for VOCs prior
to return to the aquifer at an on-site location.

Implementability.   Technically and administratively, Alternatives
2, 3,  and 5 could  be  implemented.  The technologies considered for
groundwater monitoring, extraction,  and conveyance are proven and
have been applied extensively.  For Alternative  5, the availability
of an  appropriate on-site location for reinjection  of extracted and
treated groundwater would need to bie addressed.

State and Public Acceptance.  Based on comments  received during the
public comment period, the public generally expressed support for
Alternatives  2 through  5,  although  strong  reservations  were
expressed about alternative  4.    EPA received  comments  from the
City of San Bernardino Water Department,  two other water agencies
in  the  area,  and  members  of  the  San  Bernardino  community
specifically in support of Alternatives 2 and 3.  Comments received
during  the public comment  period along  with EPA  responses are
presented in Part  III of this ROD, the Responsiveness Summary.  In
a letter dated July  29,  1993,  the State (Cal-EPA) concurred with
EPA's selected remedy  for the Newmark OU.

Cost.  The estimated total present worth of Alternatives 2,  3 and
5 ranges from $47,900,000 to $49,900,000.   The total present  worth
cost for Alternative  4  is $61,000,000.   For alternatives 2,  3 and
4, some of these  costs are expected to  be offset  by  the  water
supply  agencies which  accept  the treated water.   These overall
project costs do not take into account the value of utilizing the

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NEWMARK Record of Decision	21	August 3. 1993

groundwater resource directly as opposed to recharging the water to
the aquifer to be eventually pumped to the surface again prior to
use (Alternative 5).

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NEWMARK Record of Decision	22	August 3. 1993

10.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

     This section discusses Applicable or Relevant and Appropriate
requirements,  (ARARs) for the Newmark OU.  Under Section 121(d)(1)
of  the Comprehensive  Environmental  Response,  Compensation  and
Liability Act of  1980  as  amended  by the Superfund Amendments and
Reauthorization Act  of 1986 (collectively, CERCLA),  42  U.S.C. §
9621(d) remedial actions must attain a level or standard of control
of  hazardous  substances  which complies  with  ARARs of  Federal
environmental  laws  and  more  stringent  state  environmental  and
facility  siting laws.   Only  state requirements  that are more
stringent than  Federal ARARs,  and  are  legally enforceable  and
consistently enforced may be ARARs.

     Pursuant to Section 121(d)  of CERCLA,  the on-site portion of
a remedial action selected  for  a  Superfund site must comply with
all ARARs. Any portion of a remedial action which takes place off-
site must comply with  all  laws  legally applicable  at the time of
the off-site activity occurs, both administrative and substantive.

     An  ARAR  may  be  either  "applicable",   or  "relevant  and
appropriate",  but not  both.  According  to the National  Oil  and
Hazardous Substances Pollution Contingency  Plan  (NCP)  (40 CFR Part
300) ,  "applicable" and "relevant  and appropriate"  are defined as
follows:

      •   Applicable requirements are  those  cleanup  standards,
          standards of  control,  or other substantive environmental
          protection   requirements,   criteria,   or   limitations
          promulgated  under Federal  or state  environmental  or
          facility  siting  laws  that  specifically  address  a
          hazardous  substance,  pollutant,   contaminant,  remedial
          action, location,  or other circumstance found at a CERCLA
          site.   Only those state  standards  that are identified by
          a state in a timely manner and that are more stringent
          than   Federal    requirements    may   be   applicable.
          "Applicability" implies that.the remedial .action or the
          circumstances   at  the   site  satisfy   all   of  the
          jurisdictional prerequisites of a requirement.

      .   Relevant and appropriate requirements are those cleanup
          standards, standard of  control,   and  other substantive
          environmental  protection  requirements,  criteria,   or
          limitations  promulgated under  Federal environmental or
          State environmental or facility siting laws that, while
          not "applicable"  to  a  hazardous  substance,  pollutant,
          contaminant,   remedial   action,   location,   or  other
          circumstance  at  a  CERCLA  site, address problems  or
          situations sufficiently similar to those encountered at
          the CERCLA  site that their  use  is  well  suited to the
          particular site.   Only those state standards  that are
          identified in a timely manner and that are more stringent
          than   Federal  requirements  may   be   relevant  and
          appropriate.

Chemical-Specific ARARs.   Chemical-specific ARARs are health- or

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        Record of Decision	23	August  3,  1993

risk-based concentration limits, numerical values, or methodologies
for various environmental media (i.e.,  groundwater, surface water,
air, and  soil) that are established for a specific chemical  that
may be  present  in a specific  media at the site,  or  that may be
discharged to the site  during remedial activities.  These ARARs set
limits  on   concentrations   of  specific  hazardous  substances,
pollutants, and contaminants in the environment.   Examples  of  this
type of ARAR are  ambient water  quality  criteria and drinking water
standards.

Location-Specific  ARARs.    Location-specific  requirements  set
restrictions  on  certain  types  of  activities  based  on   site
characteristics.    Federal and state location-specific  ARARs are
restrictions placed  on the  concentration of a contaminant or the
activities to be  conducted because they are in a specific  location.
Examples of special locations possibly  requiring ARARs may  include
flood plains, wetlands, historic places, and sensitive ecosystems
or habitats.

Action-Specific   ARARs.     Action-specific   requirements   are
technology- or activity-based requirements which are triggered by
the type of remedial activities under consideration.  Examples are
Resource,  Conservation and Recovery Act  (RCRA)  regulations for
waste treatment,  storage or disposal.

     Neither CERCLA nor the National Oil and Hazardous Substances
Pollution Contingency  Plan  (NCP)  (400 C.F.R. Part  300)  provides
across-the-board  standards  for determining whether  a particular
remedy will  result  in  an adequate  cleanup  at a  particular site.
Rather,  the  process recognizes that each site will  have unique
characteristics  that  must  be  evaluated and  compared  to those
requirements that apply under the given  circumstances.   Therefore,
ARARs are identified  on  a  site-specific basis  from information
about specific chemicals at the site, specific features of the  site
location, and actions that are being considered as remedies.

     The following section .outlines: the Applicable or"Relevant and
Appropriate Requirements  (ARARs)  that apply to. this site.

10.1 Chemical-Specific ARARs

     10.1.1  Federal Drinking Water Standards

Section  1412  of  the Safe Drinking Water  Act (SDWA) .  42 U.S.C.
S300Q-1.  "National Water Regulations"; National Primary Drinking
Water- Regulations. 40  CFR Part 141.

     EPA has established Maximum  Contaminant Levels  (MCLs)  (40 CFR
Part 141)  under  the Safe Drinking Water  Act (SDWA)  to  protect
public health from contaminants that may be found  in drinking water
sources.  These  requirements are  applicable at  the tap for water
provided directly to 25 or more people or which will be supplied to
15 or more  service connections.   The  MCLs  are  applicable to any
water that would  be  served  as  drinking water.   Under NCP  Section
300.430(f) (5), remedial actions must generally attain MCLs and  non-
zero Maximum Contaminant Level Goals (MCLGs) for remedial  actions

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NEWMARK Record of Decision	24	August 3, 1993

where  the groundwater  is currently  or  potentially  a  source of
drinking water.

     The groundwater  at the Newmark OU  is  a  potential source of
drinking water. However, since the Newmark OU remedial action is an
interim  action,  chemical-specific  cleanup  requirements  for the
aquifer such as attaining MCLs and non-zero MCLGs, which would be
ARARs for a final remedy,  are not ARARs  for this interim action.
(See NCP, 55  Fed.  Reg. 8755.)   Nevertheless,  EPA has determined
that for  the  treatment plant effluent  from the  Newmark  OU, the
Federal Maximum  Contaminant Levels (MCLs)  for VOCs  and any more
stringent State of  California   MCLs  for VOCs  are  relevant and
appropriate and  must  be  attained regardless  of  the end  use or
discharge method for the treated water.

     For the treated water which will  be  put into  the public water
supply, all legal requirements for drinking water in existence at
the time that the water is served will have to be met because EPA
considers serving of  the  water  to the public  (at the tap)  to be
off-site.  Since these are  not  ARARs, these requirements are not
"frozen" as of the date of the ROD.  Rather, they can change over
time as  new  laws  and  regulations  applicable to  drinking  water
change.  See NCP, 55 Fed. Reg. 8758 (March 8,  1990).

10.1.2  State Drinking Water Standards

California  Safe Drinking Water  Act. Health and  Safety  Code.
Division 5.  Part 1.  Chapter 7. §4010 et  sea..  California Domestic
Water Quality  Monitoring  regulations,  CCR Title  22,  Division 4.
Chapter 15.  S64401 et sea.

     California has also established drinking water standards for
sources  of  public  drinking  water,  under  the   California  Safe
Drinking  Water Act  of  1976,  Health  and  Safety Code  Sections
4010.l(b) and  4026(c).   California has promulgated  MCLs for primary
VOCs.   Several of the State MCLs are.more stringent than Federal
MCLs.  In these cases, EPA has determined that the more stringent
State MCLs for VOCs  are relevant  and appropriate for the treatment
plant effluent from the Newmark  OU interim  remedy.   The VOCs for
which there are more stringent State standards include:  benzene;
carbon   tetrachloride;    1,2-dichloroethane    (1,2-DCA);    1,1-
dichloroethene (1,1-DCE); cis-l,2-DCE; trans-1,2-DCE; and xylene.
There are also some  chemicals where State MCLs exist but there are
no Federal MCLs.   EPA  has  determined that these State MCLs are
relevant and appropriate for the treated water prior to discharge
or delivery  to the water purveyor.  The VOCs  for which  there  are no
Federal MCLs  but for  which  State MCLs   exist  include:   1,1-DCA;
1,1,2,2-tetrachloroethane; and 1,1,2-trichloroethane.

     Water served as drinking water is required to  meet MCLs  at the
tap, not MCLGs.  Therefore, EPA would generally not expect a future
change in an  MCLG to  affect the use  of  treated  groundwater as  a
drinking water source.  The cumulative hazard  index  is also not an
ARAR.  However,  EPA does retain the authority to require  changes in
the  remedy   if  necessary   to   protect   human  health  and  the
environment, including  changes to previously selected ARARS.  See

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NEWMARK Record of Decision	25	August 3,  1993

40    C.F.R.    Sections     300.430 ( f) (1) (ii) (B) (1)     and
300.430(f)(5)(iii)(C).  If EPA receives new information indicating
the remedy is not protective of public  health  and  the environment,
EPA would review the remedy and make any changes  necessary to
ensure protectiveness.

     EPA has also determined that the monitoring requirements found
in CCR Title 22 Sections 64421-64445.2 are relevant and appropriate
for any treated  water which will be delivered to a public water
distribution system.  However, the selection of these sections as
ARARs involves only  the  requirements that specific monitoring be
performed.   It would not include any administrative requirements
(such as reporting requirements) and would also not include meeting
substantive  standards set within these  sections since no   such
standards have been  identified by the State as  being more stringent
than  Federal requirements.   For  the off-site portion of   this
remedy,  including  serving of  the treated water,  all  applicable
requirements would have  to be  satisfied including the monitoring
requirements in CCR Title 22 Sections 64421-64445.2.

     Accordingly,   the  chemical-specific  standards   for   the
groundwater  extracted and treated under  the  Newmark  OU interim
remedy are the current Federal or State MCLs for VOCs, whichever is
more stringent.

10.2   Location-Specific ARARs

     No  special characteristics exist in the Newmark OU to warrant
location-specific requirements.  Therefore, EPA has determined  that
there are no location-specific ARARs for the Newmark OU.

10.3   Action-Specific ARARs

10.3.1  Clean Air Act. 42 U.S.C. S7401 et  sea.

Rules and  Regulations of the South  Coast  .Air Quality Management
District                        .       ,         '    . '

     The Newmark OU alternative treatment of VOCs by air stripping,
whereby  the v'olatiles are  emitted  to the atmosphere,  triggers
action-  specific ARARs with respect to air quality.

     The  Clean Air  Act regulates air  emissions to  protect human
health and  the  environment,  and is the enabling  statute for air
quality programs and  standards.   The substantive  requirements of
programs provided under the Clean Air Act are implemented primarily
through Air Pollution Control  Districts.   The  South  Coast  Air
Quality Management District (SCAQMD) is the district regulating air
quality in the San Bernardino area.

     The  SCAQMD  has  adopted  rules that  limit air  emissions of
identified  toxics and contaminants.    The  SCAQMD  Regulation  XIV,
comprising  Rules 1401,  on new source  review  of carcinogenic air
contaminants is applicable for  the Newmark OU.  SCAQMD Rule  1401
also requires that best  available control technology (T-BACT) be
employed for new stationary operating equipment, so the cumulative

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NEWMARK Record of Decision	26	August 3. 1993

carcinogenic  impact  from air toxics does not  exceed the maximum
individual cancer risk limit of  ten  in one million (1 x 10"5) .  EPA
has determined that this T-BACT  rule is applicable for the Newmark
OU  because  compounds  such  as  PCE  and  TCE  are  present  in
groundwater, and release of these compounds to the atmosphere may
pose health risks exceeding SCAQMD requirements.

     The substantive portions of SCAQMD Regulation XIII, comprising
Rules 1301 through 1313, on  new source review  are also ARARs for
the Newmark OU.

     The SCAQMD also has rules to limit the visible emissions from
a point source  (Rule 401), which prohibits  discharge of material
that is  odorous or  causes  injury,  nuisance or  annoyance  to the
public (Rule 402),  and limits down-wind particulate concentrations
(Rule 403) .   EPA has  determined that these rules are also ARARs for
the Newmark OU interim remedy.


10.3.2    Water Quality Standards for Reinjection and  Discharges of
          Treated Water to Surface Waters or Land

Federal Standards

     The Safe Drinking  Water Act provides Federal authority over
injection wells. The Federal Underground  Injection Control Plan is
codified in Part 144  of 40 C.F.R and  prohibits injection wells such
as those  that would be  located at the  Site  from (1)  causing  a
violation of primary  MCLs in the receiving waters and  (2) adversely
affecting the health of persons.    40 C.F.R.  §144.12.   Section
144.13 of the Federal Underground Injection Control Plan provides
that  contaminated  ground  water  that has  been  treated may  be
reinjected into the  formation from  which it is withdrawn if such
injection is conducted pursuant to a CERCLA cleanup and is approved
by EPA.  40  C.F.R. §144.13.  These  regulations are applicable to
any Newmark OU treated water that is reinjected into the aquifer.

     The Resource Conservation and Recovery Act  .(RCRA) Section 3020
is also an  action-specific ARAR.  This  section  of  RCRA provides
that the ban  on the  disposal of hazardous waste into a formation
which contains an underground source of drinking water (set forth
in  Section   3020(a))   shall  not  apply  to   the  injection  of
contaminated groundwater into the aquifer if: (i)  such injection is
part of  a response  action under CERCLA;  (ii)  such  contaminated
groundwater   is  treated  to   substantially   reduce   hazardous
constituents  prior  to  such  injection;  and (iii) such response
action will, upon completion, be sufficient to protect human health
and the environment.  RCRA Section 3020(b).

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NEWMARK Record of Decision	27	.	August 3.  1993

State Standards

     Rein-jection to Groundwater

     For  any  reinjection to  the basin,  including  spreading, or
discharges  to surface  water  or  land  that  occur  on-site,  the
reinjected or discharged water must meet all action-specific ARARs
for  such  reinjection or discharge.   The ARAR  applicable  to the
reinjected water (Alternative 5)  is:

     •    The  Santa  Ana Regional Water Quality  Control Board's
          Water Quality Control Plan for the Santa Ana River  (and
          specific Bunker  Hill  Sub-basins),  which  incorporates
          State Water Resources Control Board Resolution No. 68-16,
          "Statement  of  Policy with Respect to Maintaining High
          Quality of Waters in California."  Resolution No. 68-16
          requires maintenance  of existing  State water quality
          unless it is demonstrated that a change will benefit the
          people  of   California,   will  not  unreasonably  affect
          present or potential uses,  and will not result in water
          quality  less  than  that  prescribed  by  other  State
          policies.

     Temporary Discharges to Surface Water

     EPA  anticipates  that  there may be short-term  discharges of
treated water to the flood control channel or storm drains during
the  initial operation of the VOC treatment plant  and  on certain
other limited occasions.  The ARAR for  any  treated water that is
discharged,  on a  short term  basis, to  surface  waters  is  the
National  Pollutant Discharge Elimination System  (NPDES) Program
which is  implemented by the  SARWQCB.   In  establishing effluent
limitations for such  discharges,  the SARWQCB  considers the Water
Quality Control Plan  for the Santa  Ana River Basin,  Bunker Hill
Sub-basins (the "Basin Plan"), which incorporates Resolution 68-16,
the  Inland  Surface Water Plan  and Temperature Plan  for Surface
Waters,  and the best available technology economically achievable
(BAT).  See. Cal.  Water Code § 13263.

     Since  the  RWQCB  did  not  identify  specific  substantive
discharge requirements or technology standards for such temporary
discharges,   EPA  has  reviewed  the  Basin  Plan  (with  related
documents) and considered BAT and has made certain determinations
for  the  short-term discharges  to surface waters.   In  order to
comply with this ARAR, any  groundwater that will be discharged, on
a short-term basis, to  surface waters on-site must be treated to
meet  Federal  MCLs  or  State  MCLs for  VOCs, whichever is  more
stringent.

10.3.3  Secondary Drinking Water Quality Standards

     The State of California's Secondary Drinking Water  Standards
(SOWS) which are more  stringent than the  Federal  Secondary Drinking
Water Standards shall be ARARs for the Newmark OU if the  final use
option involves serving treated groundwater as drinking water.  22
CCR §64471.  The-.Calif ornia SOWS are selected as  ARARs because they

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NEWMARK Record of Decision	28	August 3, 1993

are promulgated State standards and are relevant and appropriate to
the  action of  supplying  the  treated  water  to  a  public  water
supplier.   Although California SDWS  are not  applicable  to non-
public water system suppliers, the California SDWS are relevant and
appropriate since the treated water under this  action would be put
into the public drinking water  system.   Since the  Federal SWDS are
not enforceable limits  and are  intended as guidelines only, they
are not ARARs for this action.   Furthermore, since the State SDWS
are more stringent than the Federal SDWS, EPA has  not selected the
Federal SDWS as requirements for this action.  In summary, if the
treated water is to be served as drinking water, the treated water
at the point  of  delivery must  meet the  California SDWS.   If the
treated water is recharged or (temporarily)  discharged to the flood
control channel,  the water will not be required to  meet State SDWS.

     The Safe Drinking Water Act provides  Federal authority over
injection wells.  The Federal Underground Injection Control Plan is
codified in Part  144 of 40 C.F.R and prohibits injection wells such
as those  that would  be  located  at the  Site from (1)  causing a
violation of primary MCLs in the receiving waters and  (2) adversely
affecting  the  health of persons.   40  C.F.R.  §144.12.   Section
144.13 of the Federal Underground Injection Control Plan provides
that  contaminated   ground  water that  has  been  treated  may  be
reinjected into the  formation from which it is withdrawn  if such
injection is conducted pursuant to a CERCLA  cleanup and is approved
by EPA.  40 C.F.R.  §144.13.  These regulations are applicable to
any  Newmark  OU  treated  water  that  is   reinjected  into  the
groundwater on the Newmark site.

10.3.4 Resource Conservation and Recovery Act (RCRA) and Hazardous
Solid Waste Amendment (HSWA) Standards. 42  U.S.C.  SS6901-6987.

     RCRA, passed by Congress in 1976 and amended  by the Hazardous
and Solid  Waste  Amendments of  1984,  contains  several  provisions
that are ARARs for  the Newmark OU.   The State of California has
been authorized  to  enforce  its  own  hazardous  waste regulations
(California Hazardous Waste  Control  Act) in lieu of the  Federal
RCRA Program administered by the EPA.  Therefore, State regulations
in the California  Code of Regulations  (CCR),  Title  22,  Division
4.5,  Environmental Health Standards for the  management of Hazardous
Wastes (hereinafter the State HWCA Regulations), are now cited as
ARARs instead of the Federal RCRA Regulations.

     Since the source of  the contaminants  in  the groundwater is
unclear,  the contaminated groundwater is not a listed RCRA waste.
However,  the contaminants are sufficiently similar to RCRA wastes
that  EPA  has  determined   that  portions   of  the  State's  HWCA
Regulations  are  relevant  and  appropriate.    Specifically,  the
substantive requirements of the following general hazardous waste
facility  standards  are  relevant  and  appropriate  to  the  VOC
treatment  plant for Alternatives  2  through  5:   Section 66264.14
(security requirements),  Section 66264.15 (location standards) and
Section 66264.25 (precipitation standards).

     In addition, an air stripper or GAC contactor would qualify as
a RCRA miscellaneous unit if the contaminated water constitutes

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NEWMARK Record of Decision	29	August 3. 1993

RCRA  hazardous  waste.   EPA has  determined  that the substantive
requirements  for  miscellaneous  units  set  forth  in  Sections
66264.601 -.603  and  related substantive closure requirements set
forth in 66264.ill-.115  are relevant and appropriate for the air
stripper or  GAC contactor.   The miscellaneous  unit and related
closure requirements are  relevant  and appropriate because the water
is  similar  to  RCRA  hazardous  .waste,  the  air  stripper or  GAC
contactor appear to  qualify as  a  miscellaneous  unit, and the air
stripper or GAC contactor should be designed, operated, maintained
and closed in  a  manner that will ensure the protection of human
health or the environment.

     The land disposal restrictions (LDR), 22 CCR Section 66268 are
relevant and appropriate to discharges of contaminated or treated
groundwater to land.   The  remedial alternatives presented do not
include land disposal of untreated groundwater.   Because of  the
uncertainty in the levels of contamination  and volumes of water to
be derived from monitoring and extraction wells at this site, these
waters must be treated to meet Federal and  State  MCLs  for VOCs,
whichever is  more  stringent,  prior  to discharge  to  land.   By
meeting the Federal  and  State MCLs  for  VOCs before reinjection,
Alternative 5 will satisfy the RCRA LDRs.

     The  container  storage  requirements  in  22  CCR  Sections
66264.170 -.178  are  relevant and appropriate for  the  storage of
contaminated groundwater over 90 days.

     On-site storage or  disposal of the  spent carbon  from  the
treatment system  could trigger the  State HWCA  requirements  for
storage  and  disposal  if  the  spent  carbon contains  sufficient
quantities  of hazardous constituents that cause the  spent carbon to
be classified as a characteristic hazardous  waste.   If  the spent
carbon is determined to be a hazardous waste under HWCA  (Sections
66261 and 66262),  the requirements  for handling  such  waste  set
forth in Sections 66262 and 66268 are applicable.

     Certain other portions of the: State's HWCA's regulations are
considered  to be relevant but not  appropriate to the VOC treatment
plant.  EPA has  determined that  the  substantive requirements of
Section  66264.15   (general  inspection  requirements),  Section
66264.15  (personnel  training)   and  Sections  66264.30-66264.56
(Preparedness and  Prevention and Contingency Plan and  Emergency
Procedures)  are relevant  but not appropriate  requirements for this
treatment system.   EPA  has made  this  determination because  the
treatment plant will  be  required  to  have health and safety plans
and -"operation  and  maintenance  plans  under  CERCLA  that  are
substantively equivalent  to the  requirements  of Sections 66264.15,
66264.30-66264.56.

10.3.5  California Water Well Standards.

     Substantive standards for construction of public water supply
wells have been published by the State as the California Water Well
Standards.    While  these  standards  have  not  been  specifically
promulgated as  an enforceable  regulation  and  are  therefore  not
ARARs, all groundwater facilities designed,  located  and constructed

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NEWMARK Record of Decision	30	 August 3, 1993

to produce  drinking water must be constructed in accordance with
these standards.  Since the remedy involves delivery of the treated
water to  the public  supply  system,  EPA has  determined that the
action  will  comply with  substantive Water  Well  Standards  for
construction  of water supply  wells, such  as sealing  the  upper
annular space to prevent surface contaminants  from entering the
water supply.  Standards for location of the extraction wells are
not appropriate, since the effectiveness of the remedy  is dependent
upon the well locations.   Additionally,  wells constructed solely
for treatment and reinjection with no delivery to the public supply
system  would not  be  subject  to these  water  well  construction
standards.
10.4  Summary of ARARs for the Newmark OU.Interim Remedy

     EPA has determined a number of chemical-, and action-specific
ARARs for the Newmark OU interim remedy.  All of the alternatives
that involve groundwater extraction and treatment could achieve the
chemical-specific treatment standards  for the  groundwater at the
point of delivery.  However, Alternative 4 which uses an advanced
oxidation process is a  less certain  technology than liquid-phase
GAC adsorption or air stripping for  such  a large volume of water
and therefore  is somewhat  less likely to achieve  the  chemical-
specific ARARs.

     Requirements of nonenvironmental laws, such as California OSHA
regulations  (8 CCR 5192)  are not considered as ARARs and all such
requirements applicable at the time of the activity would have to
be satisfied.

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NEWMARK Record of Decision	31	August 3, 1993

11.0  THE SELECTED REMEDY

     Based upon consideration  of  the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, EPA has
determined that Alternative  2:  Extraction,  Treatment of VOCs by
liquid phase  GAC   (or air stripping  with Best Available Control
Technology  for emissions),  and  Conveyance  to  a  public  water
distribution  system,  in  combination  with Alternative  5  (as  a
contingency): Extraction, Treatment  of  VOCs,  and Recharge to the
aquifer, is the most appropriate interim remedy for the Newmark OU.

     Alternative  2  involves  grbundwater  extraction  (pumping)  of
8,000 gallons  per minute  (gpm) in  the vicinity  of  14th Street,
between Arrowhead and Waterman  Avenues,  at the  leading edge of the
contaminant plume,  and an  additional  4,000  gpm  at  the Newmark
wellfield (near 48th  Street  and Little Mountain Drive)  where the
contamination  enters  the eastern part of  the valley.   Various
locations  and  scenarios  for  extraction  wells  and  rates  of
extraction  are proposed  in  the  FS  report  for the  Newmark OU;
however, all design decisions for  this interim  remedy will be made
during the remedial design phase.  During the remedial design phase
the locations proposed for extraction wells and scenarios  for rates
of extraction per individual well may be selected  or new ones may
be selected.  The exact number,  location and other design specifics
of new  extraction wells  will  be  determined during  the  remedial
design  phase  of  the project  to  inhibit the  migration of the
contaminant plume  most effectively. Wherever appropriate, existing
water production  wells will  be utilized  for the  remedy,  and new
wells will be  constructed  as necessary, as  discussed in the Newmark
OU FS Report.

     All the extracted contaminated groundwater shall  be treated to
remove  VOCs  by  either  of  two  proven  treatment technologies:
granular activated carbon (GAC) filtration or air  stripping.  EPA
determined during the Feasibility Study  (March 1993)  that these
treatment technologies are equally effective.at removing VOCs and
are similar in cost at this OU.   Both  technologies  have been proven
to be reliable in similar applications.   It is acceptable to use
one technology for the northern  (Newmark  wellfield)  facility and
the other at the southern treatment .facility.  Existing treatment
facilities  (e.g.,  the  air  stripping  towers  at  the  Newmark
wellfield) may  be modified  and  incorporated into the  remedy as
appropriate.  As  a result of comments received during the public
comment period,  EPA  may  use a modification of  liquid  phase GAC
(Advanced Oxidation pretreatment)  if this modification proves to be
effective and economical  during design phase testing  and analysis.
The VOC treatment  technology which best meets the objectives  of the
remedy for the Newmark OU will be determined during the remedial
design phase,  when more detailed information is available  to assess
effectiveness and cost.

     The treated water exiting the treatment plant shall meet all
MCLs  and  secondary drinking water  standards.    If air stripping
treatment is  selected,  air emissions shall  be treated using the
best  available  control technology  (e.g.,  vapor phase GAC  or an
acceptable innovative technology)  to ensure that all  air emissions

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NEWMARK Record of Decision	32	August 3, 1993

meet ARARs.

     The treated water will be piped to  the  public water supply
system  for distribution.   Groundwater  monitoring wells  will be
installed and sampled regularly to help evaluate the effectiveness
of the remedy.  More specifically, groundwater monitoring will be
conducted no less frequently than quarterly to obtain information
needed  to:  1)  evaluate  influent  and effluent water  quality,  2)
determine and evaluate the capture zone of the  extraction wells, 3)
evaluate  the  vertical  and  lateral  (including  downgradient)
migration of contaminants,  4)  (if the contingency alternative is
implemented) to evaluate the effectiveness of the  recharge well
system and  its  impact on the remedy and  5) to monitor any other
factors associated  with the effectiveness of the interim remedy
determined  to  be  necessary  during  remedial design.   Monitoring
frequency may be decreased to less than quarterly if EPA determines
that conditions warrant such a decrease.

     EPA has selected Alternative  5  as a contingency if the public
water supply system does  not accept any or all  of the treated water
(possibly due to water supply needs).  Any remaining portion of
water will be recharged into the aquifer via reinjection wells near
the edge of the plume.  The number, location and  design  of the
reinjection wells will be  determined during  the  remedial design
phase to best meet the objectives of  the remedy and meet applicable
or relevant and appropriate requirements.  With  the  exception of the
need to meet  secondary MCLs and final use of the treated water,
Alternative 5 is identical to Alternative 2 above.

     The total duration of the Newmark OU interim remedy will be 33
years, with the  first three years for design and construction.  EPA
will review this action  every  five  years throughout this interim
remedy period and again at the conclusion of this period.

     The VOC  treatment  plant  of  the Newmark OU  interim remedy
(whether  it be Alternative 2, Alternative  5  or  a  combination.
thereof) shall  be  designed and  operated so as  to ' prevent the
unknowing entry, and minimize the possible effect of unauthorized
entry,  of  persons   or  livestock into the active portion  of the
facility.   A perimeter fence  shall be  erected  around  the VOC
treatment plant if  an adequate fence or  other  existing security
system  is  not already  in  place at  the  plant site.   This fence
should be in place prior to initiation of the remedial action and
should remain in place throughout  the duration of  the  remedy.  The
VOC treatment plant shall  also be designed and  operated so as to
prevent releases of contaminated groundwater from the plant.

     The selected remedy for the Newmark OU meets  all of EPA's nine
evaluation criteria.  The selected remedy is equally  effective as
the other alternatives in the short-term and long term  reduction of
risk to human health and the environment by removing  contaminants
from the aquifer,  by inhibiting further downgradient migration of
the contaminant plume, and by reducing the toxicity, mobility and
volume of contaminants in the aquifer.

     The VOC treatment technologies  selected  (liquid  phase GAC or

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NEWMARK Record of Decision	33	August 3. 1993

air stripping with best available control technology for emissions)
are technically feasible and proven effective at meeting ARARs for
VOCs in the treated groundwater.

     Alternative  2,  in  combination with Alternative  5,  could be
implemented, both technically and administratively.

     In a  letter dated July  29,  1993, the  State  concurred with
EPA's selected remedy.  EPA received several public  comments during
the public comment period,  the majority of which expressed support
for EPA's preferred alternative,.  These comments, along with EPA's
responses are presented  in Part III of this  ROD, the Responsiveness
Summary.

     The selected remedy is  protective of human  health  and the
environment,   meets  ARARs,    and   provides   beneficial   uses
(distribution to  a  public  water  supply  and/or recharge)  for the
treated  water.    The  selected  remedy is  cost-effective.    The
estimated  cost  of  Alternative  2  has a total  present worth  of
$49,900,000, which  is in  the middle  of the range for  all five
alternatives.   The  estimated  total  cost  of Alternative   5  .is
$48,100,000.

12.0  STATUTORY DETERMINATIONS

     As required under Section 121 of CERCLA, the selected interim
remedial action is protective of human health and the environment,
complies with  Federal  and State  requirements  that  are  legally
applicable  or  relevant  and  appropriate to the  interim remedial
action,  and is  cost effective.    The selected remedy  utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment to reduce toxicity,  mobility,
and volume as a principal element.

     The selected interim  remedial action  is protective of human
health  and the environment  in that  it removes  significant VOG
contaminant mass from the upper zones of the aquifer and inhibiting
further  downgradient  and  vertical  migration  of  contaminated
groundwater.

     The VOC treatment technologies selected (liquid phase GAC or
air stripping with best available control technology for emissions)
are technically feasible and proven effective at meeting ARARs for
VOCs in the treated groundwater and the air.

     The selected remedy permanently and significantly reduces the
toxicity,  mobility  and  volume  of hazardous  substances in the
aquifer as well as the extracted  groundwater.

     Because  this  remedy  will  result  in  hazardous  substances
remaining  on-site above  health-based levels,  EPA shall conduct a
review, pursuant to CERCLA Section 121, 42  U.S.C. Section 9621, at
least once every  five years after commencement of  remedial action
to ensure that the remedy continues to provide adequate protection
of human health .and the environment.

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NEWMARK Record of Decision	34	August 3, 1993

13.0  DOCUMENTATION OF SIGNIFICANT CHANGES

     The only significant change to the Newmark OU interim remedy
proposed  in  the Proposed  Plan  fact  sheet  dated March,  1993,
involves the possible use of a modification to the liquid phase GAC
treatment technology.

     As a  result of comments received during the public comment
period, EPA further evaluated  the  use of an advanced oxidation
system as pretreatment for liquid-phase GAC.   Additional research
on  system  effectiveness  and revised cost  estimates  based vendor
reports  can  be  found  in  the  following  technical  memorandum:
Analysis of  "Hybrid"  Advanced  Oxidation  Pretreatroent  / Activated
Carbon Alternative for the Newmark  Operable  Unit (June 25,  1993)
included  in  the  Administrative  Record  for  the  Newmark  OU.
Pretreatment  with  a destructive  technology  has  the  theoretical
advantage  of  reducing  contaminant  mass  while  enhancing  the
operation of a reliable conventional technology.   EPA may use this
modification of liquid phase GAC if this modification proves to be
effective and economical  during design phase testing and analysis.

     The impact of this potential change is  that the reliability of
the conventional liquid phase GAC technology is retained and some
desirable destruction  of contaminants is  realized.    Since this
option would only be a modification of the conventional technology,
the advanced  oxidation  system would not  need to be  designed  to
achieve full treatment  of  the VOCs,  reducing  the  cost of  the
innovative component of the treatment.  The  cost of  operation of
the liquid phase  GAC would also be reduced,  offsetting a portion of
the increased capital costs.

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