EPA  Superfund
       Record of Decision:
       Moffett Naval Air Station
       (O.U. 2), Sunnyvale, CA
       12/22/1994
                                 PB95-964502
                                 EPA/ROD/R09-95/131
                                 March 1995

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 Comprehensive Long-Term
 Environmental Action Navy
          (CLEAN)
      Department of the Navy
        Western Division
Naval Facilities Engineering Command
    San Bruno, California 94066-2402

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        MOFFETT FEDERAL AIRFIELD
        FINAL OPERABLE UNIT 2-EAST
            RECORD OF DECISION

(Pursuant to the Comprehensive Environmental Response,
         Compensation, and Liability Act)
                October 28, 1994
                   Issued By:

  U.S. Department of the Navy - Western Division
       Naval Facilities Engineering Command

                      and

       U.S. Environmental Protection Agency
        Region 9 - San Francisco, California

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                                                                   PRO Environmental Management, Inc.
                                                                   1099 18th Street, Suite 1960
                                                                   Denver, CO 80202
                                                                   303-295-1101
                                                                   Fax 303-295-2818
 December 28, 1994                                                *  m^^mr
 Mr.Stephen Chao/Mr. Hubert Chan
 Department of the Navy
 Engineering Field Activity West
 Naval Facilities Engineering Command
 900 Commodore Way, Building 101
 San Bruno, California 94066-2402

 CLEAN Contract Number N62474-88-D-5086
 Contract Task Order 0236

 Subject:      Final (signed) Operable Unit 2 - East Record of Decision

 Dear Messrs. Chao and Chan:

 Enclosed please find  one original signature copy and three additional copies of the above referenced
 report prepared by PRC Environmental Management, Inc. (PRC).  Four original signature copies of
 the report were returned to PRC for copying, binding, and distribution.  The enclosed original
 signature copy is for  the administrative record; the remaining three original signature copies have
 been returned to the appropriate signatories.

 If you have any questions or comments, please call us at (303) 295-1101.


 Sincerely,
Brian Werle                                Michael N. Young
Project Engineer                            Project Manager

Enclosures

cc:    Distribution List
                                                                   o

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          FINAL (signed) OPERABLE UNIT 2 - EAST
                  RECORD OF DECISION

              MOFFETT FEDERAL AIRFIELD

                   DISTRIBUTION LIST
Distribution                                  Number of Copies

Mr. Michael GUI, EPA                         2 (1 original and 1 copy)
Mr. Joseph Chao, DTSC                        2 (1 original and 1 copy)
Mr. Michael Bessette, RWQCB                   2 (1 original and 1 copy)
Ms. Joan'Davis, ATSDR                              1
Lt. Susanne Openshaw, EFAWEST                      1 Getter only)
Mr. Don Chuck, EFAWEST                           1
Ms. Sandy Olliges, NASA                             2
Mr. Ted Smith, SVTC                                1 Getter only)
Mr. Peter Strauss, MHB                               1
Mr. Eric Madera, Raytheon                            1
Mr. Dennis Curran, Canonie                           1
Mr. V. Thomas Jones, Schlumberger                     1
Dr. James McClure, HLA                             1
Dr. Joseph LeClaire, Montgomery                       1

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                               CONTENTS


Section                                                              Page

1.0  DECISION SUMMARY FOR OPERABLE UNIT 2-EAST		  1

     1.1   SITE NAME, LOCATION, AND DESCRIPTION	  1
     1.2   SITE HISTORY AND ENFORCEMENT ACTIVITIES	  4
     1.3   HIGHLIGHTS OF COMMUNITY PARTICIPATION	  9
     1.4   SCOPE AND ROLE OF NO ACTION  	 10
     1.5   SITE CHARACTERISTICS	 11
     1.6   SUMMARY OF SITE RISKS  	 16
     1.7   EXPLANATION OF SIGNIFICANT CHANGES	 20

2.0  RESPONSIVENESS SUMMARY	 20

3.0  REFERENCES  	 23


                               FIGURES

Figure                                                              Page

I     REGIONAL LOCATION MAP .  .	  2

2     OU2-EAST LOCATION MAP	  7


                               TABLES

Table                                                               Page

1     OU2-EAST CHEMICALS OF CONCERN	 12

2     OU2-EAST SUMMARY OF SITE RISKS 	 17

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       DECLARATION STATEMENT FOR NO ACTION AT OPERABLE UNIT 2-EAST

 Site Name and Location

 Moffett Federal Airfield
 Mountain View, California

 This federal facility is on the National Priorities List (NPL).  Moffett Federal Airfield (Moffett Field)
 has been closed as an active military facility under the Base Realignment and Closure (BRAC)
 program.  The facility is currently operated by the National Aeronautics and  Space Administration
 (NASA).

 Statement of Basis and Purpose

 This decision document presents the selected remedial  action (no action) for Operable Unit 2-East
 (OU2-East) at Moffett Field in Mountain View, California, which was chosen in accordance with the
 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended
 by the Superfund  Amendments and Reauthorization Act (SARA), and to the extent practicable the
 National Oil and Hazardous Substances Pollution Contingency Plan (NCP).  This no-action decision is
 supported by information contained in the administrative record for the sites. The U.S.
 Environmental Protection Agency (EPA) and the State of California also concurred with the decision.

 Assessment of Site

 There are seven sites within OU2-East.  The identified contaminants of concern at these sites do not
 present any current or potential human health risks and, therefore, no action  is necessary.  A
 station-wide ecological assessment is being conducted and the results of it will be considered in the
 station-wide ROD.  The station-wide ROD will be the final ROD for the entire base.

Description of the Selected Remedy

 A no action site is a site where remedial action is not necessary to protect human health and the
 environment. No action (that is, no treatment, engineering controls, or institutional controls such as
groundwater monitoring) would be warranted under the following general sets of circumstances
 applicable to sites found in OU2-East:


                                              i                CM*-0236rRU2FS\mofT«l\ou2\fncrtrod.ta\lC>-28-M'vcm«

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               •     Where the baseline risk assessment concluded that conditions at the site pose
                     no unacceptable risks to human health and the environment
               •     Where a release involved only petroleum product mat is exempt from remedial
                     action under CERCLA Section 101
               •     Where a previous response eliminated existing and potential risks to human
                     health and the environment such mat no further action is necessary

U.S. Department of the Navy, the EPA, Region 9, and the California Environmental Protection
Agency (Cal EPA) have selected no action for the following sites hi OU2-East:

        •       Site 3 - Marriage Road Ditch
        •       Site 4 - Former Wastewater Holding Pond
        •       Site 6 - Runway Apron
        •       Site 7 - Hangars 2 and 3
        •       Site 10 (eastern portion only) - Runways
        •       Site 11 - Engine Test Stand Area
        •       Site 13 - Equipment Parking Area (Building  142)

Selection of the remedy for OU2-East is consistent with overall remedial investigation/feasibility study
(RI/FS) activities at Moffett Field. Other Moffett Field sites where RI/FS activities are being
conducted include OU1 (soil and groundwater at landfill Sites 1 and 2),  OU5 (east side aquifers),
OU6 (wetiand areas), and station-wide. Additionally, similar activities are being conducted through
source control measures for the west side aquifers and soils and through corrective measures for the
Installation Restoration Program petroleum sites.  Many of these activities are concurrent.  Therefore,
the Navy is coordinating all investigations, remedial designs, and schedules to provide an overall
basewide management strategy.

Declaration Statement
        •
Based on the evaluation of analytical data and other information, the Navy, EPA Region 9,  and CAL
EPA have determined that no remedial action is necessary to ensure protection of human health (risks
to ecological receptors are being evaluated under the station-wide ecological assessment) at the
following sites at Moffett Field:

        •       She 3 - Marriage Road Ditch
        •       Site 4 - Former Wastewater Holding Pond

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        •      Site 6 - Runway Apron
        •      Site 7 - Hangars 2 and 3
        •      Site 10 (eastern portion only) - Runway
        •      Site 11 - Engine Test Stand Area
        •      Site 13 - Equipment Parking Area (Building 142)


 Soils from these sites were evaluated for potential impacts to groundwater and none were found to
 exist.  Aquifers located beneath soils on the eastern side of Moffett Field are being addressed as part
 ofOU5.


 Although hazardous substances remain at these sites, they pose no risk to human health and no
 remedial action will be implemented.  One of these substances, beryllium, is outside the acceptable
 risk range; however, it does not pose a risk to human health based on the results of a statistical
 analysis that determined beryllium was naturally occurring.  A 5-year review, therefore, is not
 required for OU2-East.
Stephen G. Chap                                                        Date
BRAC Environmental Coordinator
Navy EFA-West
John Wise/                                                             Date
Deputy Regional Administrator
EPA Region 9
                       ll
Anthony J. Landis j>   ,
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1.0 DECISION SUMMARY FOR OPERABLE UNIT 2-EAST
Provided below is information regarding site description and history, community participation, scope
and role of Operable Unit 2-East (OU2-East), site characteristics and risks, and explanation of .
signific~t changes.
1.1
SITE NAME, WCATION, AND DESCRIPI10N
Moffett Federal Ajrfield (Moffett Field) is located near the southwes~rn edge of San Francisco Bay in
Santa Clara County, California (Figure 1). The address of the facility is:
Moffett Federal Airfield
Moffett Field, California 94035
Moffett Field is bounded by salt evaporation ponds to the north, Stevens Creek to the west, U.S.
Highway 101 to the south, and Lockheed Missile and Space Company's Lockheed Aerospace Center
(Lockheed} to the east.
Moffett Field also borders the cities of Mountain Vi~w and Sunnyvale, California. The City of
Sunnyvale is located east of Mountain View and both are adjacent to the southern portion of Moffett
Field. Lockheed is the eastern neighbor and the National Aeronautics and Space Administration.
(NASA) Ames Research Center is located to the west and north of Moffett Field.
Ground surface elevations at Moffett Field range from approximately 36 feet above mean sea level
(msl) to 2 feet below msl. A sizable portion of Moffett Field is situated on previously submerged
land or marshlands that have been filled to their existing elevations with backfill material.
Wetlands located along the northern portion of Moffett Field are the only natural surface water
features at the station. The wetlands on Moffett Field are approximately 40 acres in size; all of the
wetland area is below sea level. An area of wetlands consisting of approximately 80 acres lies
between Moffett Field and Stevens Creek. About half of this area is below sea level. The portion
above sea level 15 a critical habitat for a variety of mammals and birds. Approximately 1 mile
beyond the northern boundary of Moffett Field is the San Francisco Bay. Coyote Creek and
Guadalupe Slough drain into San Francisco Bay to the east of Moffett Field, and Stevens Creek drains
into the San Francisco Bay to the west.
1
~U2fS\moIfclllaoo2\'-trod.Q1\lo.28-941cm&

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s
V.
£
                                               EVAPORATORS-   -   - .
                                 OU2-WEST
                         750'	.0.     TStf    1500'

                             SCALE: T  «  1500'
OU2-EAST
     LEGEND
                     TYPE OF WASTE

                   MARRIAGE ROAD DITCH
                   SOLVENTS, FUELS. AND PAINT

                   FORMER INDUSTRIAL WASTEWATER
                   SURFACE IMPOUNDMENTS
                   SOLVENTS. FUELS. AND OILS

                   FUEL FARM FRENCH DRAINS
                   VOLATILE ORGANIC COMPOUNDS

                   RUNWAY APRON
                   SOLVENTS. OILS. FUELS. PAINTS

                   UNPAVED AREAS SURROUNDING
                   HANGARS 2 AND 3
                   PAINTS. OILS. SOLVENTS. FUELS

                   WASTE OIL TRANSFER AREA
                   TRANSFORMER OIL. AND
                   SOLVENTS

                   OLD FUEL FARM
                   PAINTS. OILS. SOLVENTS
                                                                           10  RUNWAY (AND CHASE PARK AREA)
                                                                               OILS. FUELS.  SOLVENTS
                                                                               ENGINE TEST STAND AREA
                                                                               OILS. METALS

                                                                               EQUIPMENT PARKING AREA
                                                                               (B-142)
                                                                               FUELS, OILS.  SOLVENTS

                                                                               ABANDONED TANKS (NOS. 19, 20.
                                                                               67 AND 6B)
                                                                               TANKS 19.  20. AND 67 HAVE
                                                                               ALREADY BEEN REMOVED
                                                                           15  NINE SUMPS AND OIL/WATER
                                                                               SEPARATORS
                                                                               OILS. NEUTRALIZED BATTERY ACID
               11
                13
               14
                                                                           16
                                                                           17
                                                                           1B
                                                                           19
                   PW STEAM RACK SUMP NO. 60
                   PETROLEUM HYDROCARBONS
                   (REMOVED)

                   PAINT SHOP SUMP NO. 61
                   PAINTS,  SOLVENTS
                   (REMOVED)

                   DRY CLEANERS  SUMP NO.  66
                   SOLVENTS
                   (REMOVED)

                   LEAKING TANKS NOS. Z 14. 43.
                   AND S3  (ALL  REMOVED)
                   FUELS, SOLVENTS, OILS. PAINT.
                   BATTERY ACID
               OU2-EAST  SITES
               (SITES 3. 4, 6. 7. 10 [RUNWAYS], 11 AND 13)
                       FIGURE  1
               NAS MOFFETT FIELD
                      OU2  SITES

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San Francisco Bay is California's largest estuary. Historically, tidal salt marsh and mud flats covered
extensive areas of the southern portion of the bay; however, most of these wetlands have been
eliminated or greatly altered. The large area. to the north and northeast of Moffett Field was diked
and is no~ used as commercial salt evaporation ponds. There are no streams on Moffett Field,
although several streams are present to the east and west. No other surface water features are present
at Moffett Field, with the exceptions of several small ponds maintained on the Moffett Field golf
course as water hazards, stormwater drainage ditches, standing water after floodings or rainfall, and
the wetlands described above.
The northern Santa Clara Valley groundwater basin is part of the down-dropped structural trough

. .
lying between the San Andreas and Hayward Faults. The erosion of the uplifted Santa Cruz
Mountains has contributed sediment that has been transported by northward-flowing streams. Moffett
Field lies on the San Jose alluvial plain near the toe of alluvial fans emanating from the Santa Cruz
Mountains. On a regional scale, the overall sediment grain size becomes finer northward away from
the mountains. On a local scale, alluvial processes have juxtaposed clay, silt, sand, and gravel in
adjacent depositional environments.
. The hydrogeologic setting at Moffett Field consistS of alluvial sand aquifers or sand and gravel
aquifers separated by low permeability silt and clay aquitards. In the interior part of the Santa Clara
VaHey, the numerous aquifers have been divided into two broad zones or sequences: the upper-aquifer
sequence (A and B aquifers) and the lower-aquifer sequence (C aquifer) (pRC 1992). The distin~ion
. between the two aquifer sequences is that the upper-aquifer sequence is generally unconfined,
although in places it is semiconfined. The lower-aquifer sequence is confined under a laterally
extensive clay aquitard at depths of 140 to 200 feet below land surface (bls). Aquifers in the upper
zone are generally thin and discontinuous. Aquifer materials range from silty to fine sand to coarse
gravel. The A and B aquifers are not presently used. The C aquifer, however, is used as a source of
municipal drinking water for the nearby communities of Mountain View and Sunnyvale.
The water table at Moffett Field is not a static boundary, but fluctuates.in response to changes in
evaporation, precipitation, and groundwater pumping. The water table at Moffett Field ranges from
approximately 5 to 15 feet bls. Tidal influence on the water table elevation is thought to be
negligible.
3
ow.o236IRU2FS\moffell~.II1\ID-2&-94\cma

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 Current and potential beneficial uses applicable to the main groundwater basins in the San Francisco
 Bay region are outlined in the San Francisco Bay Region Water Quality Control Plan (basin plan) and
 include municipal supply, industrial service, industrial process water supply, and agricultural supply.
 With the exception of the northern portion of the A aquifer, the aquifers at Moffett Field (A, B,
 and C) meet the state standards for yield (200 gallons per day) and total dissolved solids (less than
 3,000 milligrams per liter).  Therefore, the A, B,  and C aquifers are considered potential drinking
 water sources.  Surface water replenishment, provided by the upper aquifers, helps maintain wildlife
 habitats associated with the nearby wetlands.

 \2    SITE HISTORY AND ENFORCEMENT ACTIVITIES

 Moffett Field has been continuously operated by the U.S. military since it was  commissioned in 1933
 to support the West Coast dirigibles (blimps) of the lighter-than-air (LTA) program. In 1935, the
 station was transferred to the U.S. Army Air Corps, which used it for training purposes.  In 1939, a
 permit was granted to Ames Aeronautical Laboratory to use part of the station.

 In 1942,  the station was returned to Navy control and was named Moffett Field.  In late 1942, the
 heavier-than-air (HTA) program was initiated and  began to take precedence over the LTA program.
 In 1945,  the HTA program was moved to Half Moon Bay Field and Moffett Field was used as a
 major overhaul and repair base.  The LTA program was discontinued at Moffett Field in 1947.
 In 1949,  the station became home to the Military Air Transport Service Squadron.

 By 1950, Moffett Field was the largest naval air transport base on the West Coast and became the
 first all-weather naval air station.  In 1953, the station became home to all Navy fixed-wing,
 land-based antisubmarine efforts.  A weapons department was formed on  the base in 1954, and in
 February  1966  the base activated its high-speed refueling facilities.  During the station reorganization
 in 1973,  it became the headquarters of the Commander Patrol Wings, U.S. Pacific Fleet.

 During the 1980s and early 1990s, the mission of Moffett Field was to  support antisubmarine warfare
training and patrol squadrons. The station supported more than 70 tenant units, including the
 Commander Patrol Wings, U.S. Pacific Fleet,  and the California Air National Guard.  Moffett Field
was the largest  P-3 Orion patrol aircraft base in the world, with nearly  100 aircraft.  These aircraft
were assigned to nine squadrons supported by 5,500 military, 1,500 civilian, and 1,000 reservist
personnel. No  heavy manufacturing or major aircraft maintenance was conducted at Moffett Field,
but a significant amount of unit- and intermediate-level maintenance occurred.

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1---
In April 1991, Moffett Field was designated for closure as an active miJitary base under the
Depanment of Defense Base Realignment and Closure (BRAC) program. On July 1, 1994,
Moffett Field was closed and control of the base was transferred to NASA, which operates the

~ . -
Ames Research Center on the northwestern side of Moffen Field. The Navy, however, will continue
with environmental restoration activities and remain responsible for remediating Navy contaminant
sources.
Wastes have been generated at Moffen Field through maintenance operations, fuel management, and
fire training since the early 1930s. Chemicals of potential concern (COPCs) include waste oils and jet
fuels; solvents and cleaners; washing compounds; and lesser amounts of gasoline, hydraulic fluids,
asbestos, paints, pesticides, battery acid, and polychlorinated biphenyls (PCBs). Wastes were
disposed of in unlined landfills, drained through drainage ditches and unpaved areas, and stored
temporarily in unlined wastewater ponds. In addition, some underground storage tanks (USTs) and
sumps (many of them now removed) were found to have leaked petroleum hydrocarbons and fuels,
and lesser amounts of waste oils and solvents.
Environmental studies were initiated at Moffett Field in 1984. The Navy began conducting these
environmental restoration activities as part of the Installation Restoration Program (IRP). The Navy
conducted an initial assessment study (IAS) in 1984 to gather data on the past use and disposal of
hazardous materials at Moffett Field (NEESA 1984). Nineteen sites were identified as potential
sources of wastes, including nine sites identified in the !AS and 10 sites added during subsequent
investigations (ESA and AR 19800, 1986b; ERM 1987; ESA and JMM 1986). The U.S.
Environmental Protection Agency (EPA) proposed Moffen Field as a National Priorities List (NPL)
site in June 1986 and placed it on the NPL in 1987. Placement on the NPL initiated the remedial
investigation/feasibility study (RIIFS) process under Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). Data collected during the initial studies were used to
plan the RIIFS. The RIIFS work is coordinated through the August 1990 federal facilities agreement
(FFA) with EPA and the California Environmental Protection Agency (Cal EPA) (inCluding the
Depanment of Toxic Substances Control and the Regional Water Quality Control Board).
Tbe RI was implemented in two phases. During Phase I, the types and concentrations of chemical
contaminants at 19 sites were identified. The Phase I characterization was completed in August 1990.
The Phase n investigations were initiated in 1990 to provide more detailed, site-specific data.
Phase n investigations revealed a need to organize the RIIFS process into separate au studies.
Subsequently, Moffett Field was divided into the six OUs listed below to help expedite the RIIFS
process.
5
CM4-0236IRU2FS\moffel1~.tI1\IG-28-941cmg

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               OU1   -      Soils at Sites 1 and 2 landfills
               OU2   -      Soils at Sites 3 through 11, 13, 14, and 16 through 19
               OU3   -      Soils at Sites 12 and 15
               OU4   -      Aquifers on the western side of Moffett Field
               OU5   -      Aquifers on the eastern side of Moffett Field
               OU6   -      Wetland areas

In October 1992, however, EPA determined that the aquifers on the western side of Moffett Field
were affected by a regional volatile organic compound (VOC) plume emanating from the Middlefield-
Ellis-Whisman (MEW) Superfund site south of Moffett Field. EPA determined that these aquifers
were subject to the 1989 record of decision (ROD) already written for the MEW site.  Consequently,
OU4 was deleted and OUS was modified to include all aquifers not part of the regional VOC plume.
OU2 was separated into OU2-West (Sites 8, 16,  17, 18, and the western portion of Site 10, which
overlie the regional VOC plume) and  OU2-East (Sites 3, 4, 6, 7, 11, 13, and the eastern portion of
Site 10, which do not overlie the regional VOC plume).  OU2-East is the focus of this ROD.

In February 1993, the Navy recommended to the regulatory agencies that all sites containing
petroleum and petroleum constituents  be removed from the CERCLA process (CERCLA contains an
exclusion for  petroleum  and petroleum constituents). The Navy also recommended that these sites be
addressed in a manner consistent with the Resource Conservation and Recovery Act (RCRA) Subtitle
I and appropriate state regulations for underground storage tanks. The agencies agreed to the
modification and corrective actions at petroleum sites are underway.  Therefore, OUS (which
contained petroleum contaminated Sites 12 and 15) was removed, and Sites 5, 9, 14, and 19, which
also contain petroleum-contamination, have been  deferred to the IRP petroleum sites program and will
not be addressed through RODs.

The following text contains site-specific histories for the sites included in  OU2-East (IT 1993).
Figure 2 depicts the locations of the OU2-East sites at Moffett Field. The medium of concern at all
OU2-East sites is unsaturated soils.

       Marriage Road Ditch  (Site 3): Marriage Road Ditch extends for approximately 2,000 feet
       along the eastern side of Marriage Road and is 5 to 6 feet below msl.  The ditch discharges to
       the Navy Channel. Portions of the ditch  are lined with concrete.  Storm drains in and around
       Hangars 2 and 3 (Site 7) discharge wastes into the ditch.  An estimated 150,000 to
                                              g               044-023<5IRU2FS\moff«l\ou2\fnoitrod.oa\10-28-*l\ciB«

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p
~
- - - - - -a
:3
c:::J
$
7
JP
10
~
!
400' 0 400' 800'
L....' I
SCALE: ,. = 800'
:a
~
: LE.GE1iQ.
....
~ .
! - OU2-EAST SITES .
~ (SITES 3. 4. 6. 7. 10 [RUNWAYS1" AND 13)
..
co
FIGURE 2
NAS MOFFETT FIELD
QU2-EAST SITES
7
..

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750,000 gallons of mixed wastes containing waste oils, solvents, fuels, detergents, paints,
paint strippers, and hydraulic fluids were discharged into the storm drains from the 1940s to
the 1970s.

Former Wastewater Holding Pond (Site 4):  The former wastewater holding pond was
removed,  closed, and replaced by the existing holding ponds. Most of the information
regarding the former pond was lost in a facility fire during the late 1970s.  The former pond
was unlined and received approximately 15 million gallons of wastewater from aircraft
washing, equipment maintenance, and operations in Hangars 2 and 3 (Site 7) from 1968 to
1978.  The wastewater was held in the pond, treated, and discharged to the sanitary sewer.
As much as 35,000 gallons of waste materials, including toluene, methyl ethyl ketone (MEK),
dry cleaning solvents, paint sludge, paint strippers, Freon 113, trichloroethene (TCE),
trichloroethane (TCA), carbon remover, ethylene glycol, fuel, and oil were discharged to the
pond either directly or as components of wastewater.

Runway Apron (Site 6):  The runway apron disposal  site consists of a gravel area that was
paved in 1979 and is now used mainly  for car parking. An estimated 120,000 to 600,000
gallons  of wastes from aircraft maintenance,  including solvents,  oils, fuels, paints, and paint
strippers,  may have been disposed  of in liquid  form at this site from the  1940s to 1970s.

Hangars 2 and 3 (Site 7); Site  7  consists of Hangars 2 and 3 and the paved and unpaved
areas surrounding the hangars. Unpaved  areas at each corner of the hangars were used to
dispose of an estimated 120,000  to 600,000 gallons of paint, paint strippers, oils, solvents,
fuels, hydraulic fluids, and other wastes.  At a power plant shop in the northeastern corner of
Hangar 3, chlorinated solvents, including TCE, were disposed of in barrels, through deck
drains, and on unpaved areas around Hangar 3. The hangars were constructed in 1942, and
until 1978 wastes that accumulated in barrels on the unpaved area surrounding the hangars
may have flowed into the Marriage Road Ditch (Site 3).

Runways (Site 10 - Eastern Portion Only):  OU2-East includes only the runway portion of
Site 10  (Figure 1).  Site 10 also  includes  Chase Park, which  is located between U.S.
Highway 101 and Girard Road near the southern end of Moffett Field. The Chase Park area
of Site 10 is included in OU2-West and is not part of this ROD.  A primary source of
potential soil contamination at the runway is precipitation runoff' that may have carried spilled
fuels and lubricants to adjacent drains and ditches.
                                                         0«4-O236IRU2FS\iDoffea\ou2\fn««tr«l.oa\10-28-94\ctng

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Engine Test Stand Area (Site 11): This area was used to test aircraft engines under power.
The site is fenced and covered by concrete and asphalt and comprises an approximately 200-
by--200-foot square pad. A small drainage depression drains waste oils, hydraulic fluids: and
fuels to the southern edge of the pad. A stain south of the pad suggestS that fluids may have
run onto the adjacent soils. The stained area is approximately 4S by 7S feet.
Equipment Parking Area; Building 142 (Site 13): The equipment parking area, which is a
concrete and asphalt vehicle parting 101, covers approximately 7,500 square feet east of
Building 142. Industrial wastewater from spills, leaks, and equipment .washing were flushed
into the surface drainage ditch adjacent to the concrete/asphalt parking area. The ditch flows
to the main storm sewer.
1.3
IDGHLIGHTS OF COMMUNITY PARTICIPATION
In May 1989, the Navy developed a Moffett Field community relations plan (CRP). The CRP
outlined specific activities based on concerns voiced by the community. Since 1993, the EPA
provid~ a technical assistance grant (TAG) to the Silicon Valley Toxics Coalition, a local concerned
environmental group. The TAG allowed the Coalition to hire a consultant to assist in reviewing.
Moffett Field environmental documents. In addition, the Navy formed a technical review committee
(TRC), which has been meeting quarterly to discuss environmental progress at the site. The Navy is
currently forming a restoration advisory board (RAB), which will take the place of the TRC. The
RAB will be made up of mem~ of the TRC and community and wiJI hold regular public meetings
to discuss environmenta! progress at Moffett Field. .
The aU2 RI report (including all the aU2-East sites) was released.in May 1993 (IT 1993). The
proposed plan for the no-action sites at aU2-East was released to the public in May 1994. The
proposed plan and RI report were made available to the public through both the administrative record
and the information repository. The notice of availability for the proposed plan and related
.

documents was published in the San Jose Mercury News and San Francisco Chronicle on May 9,
1994. A public comment period was held from May 4, 1994, through June 22, 1994. A public
meeting was held on Tuesday, May 24, 1994. At this meeting, representatives from the Navy, EPA,
and the State of California answered questions about OU2-East and supplied the basis for proposing
no action for each of the individual sites. A response to the comments received during the public
meeting and the public comment period is included in the responsiveness summary, which is in this
ROD. These community participation activities fulfill the- requirements of Sections 113(k)(2)(B)(i-v)
and I 17(a)(2) of CERCLA.
9
O44-0236IRU2FS\moffell~.IXI\I~28-941cm&

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1.4     SCOPE AND ROLE OF NO ACTION

The scope of the no action process is to address categories of sites where remedial action is not
necessary to protect human health and the environment, or CERCLA does not provide the appropriate
authority to take any remedial action at the site.

Moffett Field is a large federal facility containing numerous potential sources of contamination. To
date, 23 sites at Moffett Field have been identified and are in some phase of the assessment process.
However, several of these sites have been removed from the Moffett Field CERCLA process, as
discussed in the previous  section.  Sites 5, 9, 12, 14, IS, and 19 contain petroleum contamination and
are, therefore, excluded from CERCLA actions.  Operable unit 3 (OU3) originally included Sites  12
and 15, but is not longer considered a separate OU.  These sites, however, are undergoing corrective
action under the State of California's underground storage tank  (UST) program. Source control
activities for Sites 9, 12, and 14 are currently underway.  Sites  16, 17, 18, and the western portion of
Site 10 are located on the western portion of Moffett Field and are included with the MEW ROD.
Groundwater beneath the  western portion of Moffett Field, formerly OU4, also is covered by the
MEW ROD.  The remaining sites planned to be addressed by RODs, therefore, are as follows:

              OU Designation       OU Description              ROD Schedule
              OU1                  Soil and Groundwater at      September 5, 1995
                                    Landfill Sites 1 and 2
              OU2-East             Soil at Sites 3, 4, 6, 7,  11     October 14, 1994
                                    13, and the runway portion
                                    of Site 10
              OU5                  East Side Aquifers            June 1, 1995
              OU6                  Wetland Areas               will be covered by
                                                                station-wide ROD
              Station-wide          Station-wide                 September 15, 1996
Risks to ecological receptors located within OU2-East are being evaluated under the station-wide
ecological assessment.  If ecological risks are identified at OU2-East, they will be addressed through
the station-wide RI/FS and ROD.  This ROD will not need to be amended based on the results of the
ecological assessment.

                                              ]Q               ()44-(K36IRU2FS\n>ofrca\ou2\fDenrod.m\10-2g-W\OTg

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The installation management strategy is to accelerate actions at the OUs while identifying and closing
out assessment activities at sites not requiring action. This strategy, which utilizes the use of no
action RODs, allows resources to be concentrated on the OUs requiring action and meets the
Presidenfs goal of quickly identifying parcels of property that can be transferred to the community or
other agencies under the BRAC program.
The unsaturated soils at the OU2-East sites is the onJy medium included in this no-action ROD. The
groundwater under these sites is being addressed under separate OUs and actions.
1.5
SITE CHARACTERISTICS
Interpretation of the nature and extent of soil contamination at the Moffett Field OU2-East sites is
based on the phase I and phase II data compiled and presented in the OU2 RI report (IT 1993).
Phase I and II OU2 RI soil samples were generally collected at 1, 3, and 5 feet bls in each soil
boring. A fourth sampJe was collected at either a Io-foot depth or just above the water table (when
the water table was encountered at less than 10 feet bls). The soil samples co))ected during the phase
I and II investigations were analyzed for VOCs, semivolatile organic compounds (SVOCs), PCBs,
total petroleum hydrocarbons (TPH), and inorganic constituents. Additional information, sampling
methods, and chemical analysis procedures followed during the phase I and n sampling events are
described in the OU2 RI report.
Results of the phase I and II soil contamination data contained in the OU2 RI report indicate that the
categories of compounds detected in soils at the OU2-East sites include VOCs, SVOCs, TPH as
diesel, TPH as gasoline, TPH as JP-S, and TPH as oil and grease. Most of these chemicals of
interest are organic compounds. However, some inorganic chemicals were identified at the sites, but
were eliminated from the list of hazardous site-related chemicals based on background concentrations
or negligible risks. Additionally, no sources for inorganic chemicals were identified.
Table 1 contains information on the primary compounds detected at each site. A complete list of all
compounds detected at each site and a comprehensive discussion of the nature and extent of
. contamination appears in the OU2 RI report (IT 1993). The quality of data for the sampling and
analysis at this site was considered in the selection of remedies for OU2-East in accordance with the .
quality assurance plan in the Moffett Field Final Work Plan for Remedial Investigations (IT 1988).
11
OoW4236IRU2FS\moffCII~.IXI\I()'~1cm&

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TABLE 1
MO"'..~n FEDERAL AIRFIELD
OU2.EAST RECORD OF DECISION
CHEMICALS OF CONCERN
CONCENTRATIONS IN SOIL
 ~ec' ConcmtratioD. M . ~'P.rC:~nu;
 .:.....i: . an :::.::::)::<
Chemical ~n..::: RangeCA2/k CoMmtrationc
 .. . H/. ... Site3>.....: ..:.::,..::, ':::::': :.:.:::::: . /:}:::::,:: ::.:'. :;::/: .:::':::'> :::::i:: ::>:.::. :.:... .:.
 .... ::...   . . ..::<.:.::.:.:.
Organics (JL21k2)     
2-Butanone 3/53  3-6 5 5
Acetone 10/53  5.72 9 13
Bis(2 -eth ylhex yl )phthal ate 18/53  53 - 41,000 1,242 2,835
ButvlbenzlDhthaiate 3/53  165 - 850 190 223
Diethylphthalate 3/53  64 - 510 169 183
Aroclor-1260 4/53  80 - 630 102 128
Tetrachloroethene 3/53  1 - 4 2 3
Toluene 14/53  1 - 8 3 3
Inol"2anics (m2fk2)     
Antimonv 17/53  3-9 4 5
Beryllium 50/53  0.25 - 6.5 2 2
Manganese 53/53  26.5 - 1,470 512 571
Nickel 53/53  32.9 - 107 66 70
Silver 19/53  0.5 - 4,8 1 1
   .. Site 4 ...... 
Organics (JL21k2)     
1 ,2-Dichlorobenzene 3/42  120 - 230,000 5,912 17,230
2-Butanone 7142  2 - 52 7 10
2-Meth ylnaphthal ene 6/42  165 - 22,000 1,868 3,540
Acetone 11/42  4 - 140 19 29
Bis(2-eth ylhexyl )phthalate 15/42  38 - 6,000 492 827
Diethvlphthalate 5/42  47 - 290 164 175
Naphthalene 6/42  . 165 - 36,000 1,880 3,821
Phenanthrene 6/42  68 - 330 170 183
Tetrachloroethene 4/42  2-5 3 3
Toluene 13/42  1 - 380 12 31
Total Xylenes 5/42  2.5 - 1,300 36 98
12
OoI4-0236IRU2FS\moffelt~.IXI\lo.28-941cmi

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TABLE 1 (Continued)
MO}c}ct;"l"l FEDERAL AIRFIELD
OU2-EAST RECORD OF DECISION
CHEMICALS OF CONCERN
CONCENTRATIONS IN SOIL
 ..<:/ &equency~r ..Concentration. . . ?tipPer95% ....\
 ..'H'.'.'.."M .....,...
 ... .... . .
 ""}'(.~.:':~i.. ean... .:,:"..',>':""
Chemical..  . ..Detection . .:" Range ClL2lk2r Coueentrationc.' COOfidt!QCe Limite.
Inorganics (mglkg)       
Antimony  18/40 3 - 57.2 10  15 
Beryllium  37/40 0.23 - 2.5 1  1 
Copper  40/40 25.9 - 96 44  49 
Man2anese  40/40 302 - 725 501  536 
Nickel  40/40 43.2 - 82 66  69 
Silver  19/40 0.5 - 4.8 1  2 
 . ... ..,."...,.: .Site 6 ...:H..,.,. ., :....:....'.)\H ..:
~anics 11~1k~       
1 ,2-Dichloroethene  1/8 1 - 2.5 2  3 
(Total)       
2-Butanone  1/8 5 - 27 8  14 
2-Methylnaphthalene  2/8 93 - 960 255  488 
4- Methylphenol  2/8 165 - 2,000 431  955 
Acetone  8/8 14 - 150 64  103 
Bis(2 -ethylhexyl )phthalate 3/8 90 - 1,000 256  502 
Diethvlphthalate  4/8 61 - 250 144  193 
Ethylbenzene  2/8 2.5 - 29 8  16 
Fluorene  1/8 130 - 165 161  171 
Naphthalene  1/8 165 - 560 214  328 
Phenanthrene  2/8 40 - 260 161  210 
Toluene  8/8 2 - 90 20  45 
Total Xylenes  2/8 2.5 - 290 59  149 
Inorganics (mg/kg)       
Antimonv  2/8 3 - 9.9 4  6 
Nickel  8/8 55.1 - 81.1 65  72 
Silver  8/8 1.3-2.4 2  2 
13
O44-0236IRU2FS\mofrel1\0u2\fDe81toc1.tX1\l~28-94\cmg
-;r;-:r
iF/..:
.. -, ,-

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TABLE 1 (Continued)
MOJ:.  Frequency .of ... ... . . .., : (Ywer95'% . :'. :.:'.,:
  ConcentratiOn M..........."...
 ..  ,::.:: .i:::" . eai:I ....:.o: He,:,:,:
 Chemical .. '.' Vetection.. '.) RanEe:" -~ .Conceotrationc ConfidenCe Limite
    .,.,..., .. ..  .,."",.,   ..".,.'..'."~:,.,.,. 
    ,.. ..,.... ., ." , ,',....::.,. .. .".':."'" .'''. .
Orpnics Ut21k2)          
2-Butanone  7/26  2 - 11  5   6 
Acetone   5/26  3 -72  12   20 
Bis(2-ethylh ex yl )phthal ate 21/26  64 - 2,000 422   624 
Ethylbenzene  2/26  2-3  3   3 
Toluene   8/26  2-7  3   3 
. Total Xvlenes  2/26  2.5 - 16  3   5 
Iri0F2anics (m~!IqU          
Antimony  7/26  3 - 24  5   7 
Beryllium  15/26  0.25 - 3.4  1   2 
Copper    26/26  19.8 - 20,500 831   2,448 
Manganese  26/26  250 - 1,010 490   550 
Nickel    26/26  34.4 - 85.7 62   67 
Silver    10/26  0.5 - 12.4  2   3 
Thallium  4/26  0,42 - 0.57 1   1 
Zinc    26/26  44.1 - 8,660 393   1,073 
      Site 10  ..'/ '... ..,..' ......'.........'..>
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. Chemical
Or2anjcs (J.&e1k2)
1,1,1- Trichloroethane
Acetone
Bis(2-ethvlhex vI )phthalate
Carbon disulfide
Di-n-butvlphthalate
N-Nitrosodiphenylamine
I Inorganics (mg/kg)
Antimony
Copper
Manganese
Nickel
Silver
Organics (JLglkg)
Bis(2 -ethv Ih ex vJ )phtha!ate.
Di-n-buty1phthalate
Toluene
Inorganics (mglkg)
Antimony
Cadmium
Copper
Lead
Manganese
Nickel
Silver
Zinc
Notes:
TABLE 1 (Continued)
MOI"I'~n FEDERAL AIRFIELD
OU2-EAST RECORD OF DECISION
CHEMICAlS OF CONCERN
CONCENTRATIONS IN SOIL
Freq.DetU~f!nOf"~~~~e tra~on, ."Con""'.":""':"'~~t".I'."o"'.'n.'...:;:,:.,Vppei9S% '. ".".
~ AAlI,.. ~~a .HC~denceUmjfc

:Site 11,./ .""."'. "'.," ,.,.,H '..'.,"
7/21
5/21
24/49
2/21
5/49
3/48
18/49
49/49
49/49
49/49
17/49
8/8
2/8
5/8
-
5/8
5/8
8/8
8/8
8/8
8/8
3/8
8/8
'I - 16 3 4    
5 - 200 34 61    
49 - 4,500 313 499    
2.5 - 5 3 3    
33 - 840 170 199    
84 - 165 162 166    
  I ,.  :1.
3 - 21, 6 7   .- 
29.9 - 109 48 53 .. --," h
315 - 957 536 571   ._~... '..
   .._~
36.3 - 90.9 68 72    
0.5 - 3.2 1 1    
Site 13   .1 ,~  :..
   . .   ',,,;
84 - 650 258 416 . ,. ':-=;,
40 - 165 137 180    
2-3 2 3    
3-9 6 8    
0.25 - 6.8 3 5    
33 - 55.8 42 49    
11 - 462 123 258    
416 - 700 577 653    
70.7 - 92.2 79 85    
0.5 - 1.6 1 1    
57.6 - 198 107 145    
c
Arithmetic mean and upper 95 percent confidence limit using 1/2 the det~ion limit for
nondetectS (rounded).
15
o.w.o236IRU2FS\mofl'dI~.IXI\l~23-94\cmg

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 1.6    SUMMARY OF SITE RISKS

 As part of the OU2 RI, the Navy prepared a baseline human health risk assessment (BRA) for the -
 unsaturated soils at the OU2-East sites. The OU2-East BRA evaluated the potential effects to  human
 health as a result of exposure to the chemicals identified at the sites. The BRA evaluated the COPCs,
 exposure pathways, potential human receptors, and the risks of exposure to the COPCs.  Risks to
 ecological receptors are being reviewed in the station-wide ecological assessment.

 Moffett Field has been decommissioned and transferred to NASA. NASA is expected to continue
 using the facility for flight, industrial, and commercial operations. Accordingly, future receptors
 were identified with the understanding that the facility will continue to be operated as an industrial
 facility, and, therefore, future receptors will most likely be the same as current receptors. However,
 in the event that Moffett Field is considered for residential development in the future, .residential
 scenarios were considered hi the BRA for the OU2-East sites. Table 2 includes the receptors and
 potential exposure pathways evaluated for the OU2-East sites.

 The overall screening criterion for a no action site is an acceptable level of protection for human
 health and the environment. This acceptable level of protection requires that the reasonable maximum
 risk of exposure for a person to site-related chemicals results in an estimated additional risk of
 developing cancer  of less than  one-in-one million, and is without appreciable risk of deleterious
 noncancer health effects.  This is in accordance with the National Oil and Hazardous Substances
 Contingency  Plan (NCP) and CERCLA guidance.

 As a means of estimating the human health risks caused by exposure to site contaminants, EPA has
 established an acceptable range of risk  levels, which are presented as incremental lifetime cancer risks
 (ILCRs) for carcinogens and hazard indices (His) for noncarcinogens. EPA generally considers an
 ILCR greater than 1  x KT* to be unacceptable. If concentrations of chemicals  at a site are within this
 risk range, no action would need to be taken to protect human health and the environment. Risk
 management  decisions are considered for an ILCR range of 1 x 10* to  1  x 10~*.  However, the
project team  can use discretion, within bounds, when making risk management decisions on how to
proceed to a  ROD  at a particular site.

Table 2 summarizes the overall sites risks for each OU2-East site from the BRA.  The results of the
OU2-East BRA indicate that all current and future risks at the OU2-East sites are within EPA's
acceptable risk  range, with the exception of risks caused by beryllium, a  metal. The OU2-East RI

                                               16                W4-023
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TABLE 2
MO....~IT FEDERAL AIRFIELD
OU2-EAST RECORD OF DECISION
SUMMARY OF SITE RISKS
    . . .' . . .. 
    TotslSite Rlsk.ci ~ Ail Pathwa; s 
   ILeRI ILCRI .....m2 .812.
Site Exposure Scenario EXpOsure Pathways (Mean) . (RME) (Mean) . (RME)
3 Recreational (Current) Soil ingestion 5.09 x ICt6 1.28 x 10"' 0.008 0.026
  Dermal contact    
 Occupational (Current) Soil ingestion 3.26 x ICt6 3.98 x ICt6 0.020 0.023
  Dermal contact    
  Inhalation of volatites    
 Residential (Future) Soil ingestion 1.34 x 10"3 5.40 X 10"3 1.69 .2.36
  Dermal contact    
  Inhalation of volatiles    
  Ingestion of homegrown vegetables    
  Domestic water use    
4 Occupational (Current) Soil ingestion 3.87 x 1()"4 6.20 x 1()"4 0.385 0.460
  Dermal contact    
  Inhalation of dust    
  Inhalation of volatiles    
 Residential (Future) Soil ingestion 6.82 x 1()"4 2.74 x 10,3 2.54 4.33
  Dermal contact    
  Inhalation of volatiles    
  Ingestion of homegrown vegetables    
  Domestic water use    
6 Occupational (Current) Soil i~estion 1.50 x 10-10 2.95 X 10,10 0.001. 0.010
  Derm contact    
 , Inhalation of volatiles    
 Residential (Future) Soil ingestion 6.96 x 10"8 4.75 X 10"7 0.894 1.61
  Dermal contact    
  Inhalation of volatiles    
  Ingestion of-homegrown vegetables    '
  Domestic water use    
17
~'\III""etlIou2\drootrod.b
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TABLE :1 (Continued)
MOFFK8'" FEDERAL AIRFIELD
OU2-EAST RECORD OF DECISION
SUMMARY OF SITE RISKS
    Totlll Site Risks" All Pathwa]s. 
 Exposure.Scenario .  ILCR. ILCR. Hf' Dr
Site I!:xDOsure Pathways (Mean).... (RME) (Mean) .. . (RM£) .
7 Occupational (Current) Soil ingestion 1.89 x I~ 2.57 x I~ 0.030 0.055
  Dermal contact    
  Inhalation of volatiles    
 Residential (Future) Soil infestion 7.74 x 1()"4 3.49 x 10-3 8.06 29.1
  Derma contact    
  Inhalation .of volatiles    
  Ingestion of homegrown vegetable. II     
  Domestic water use    
10 Occupational (Current) Soil ingestion 3.98 x 1()"4 6.92 x I ()"4 0.326 0.432
  Dermal contact    
  Inhalation of dust    
  Inhalation of volatiles    
 Residential (Future) Soil ingestion 7.02 x 1()"4 3.05 x Ht' 1.78 2.99
  Dermal contact    
  Inhalation of volatiles    
  Ingestion of homegrown vegetables    
  Domestic water use    
11 Occupational (Current) SoH ingestion 5.11 x lO"l 9.86 X 10.8 0.028 0.047
  Dermal contact    
  Inhalation of volatiles    
 Residential (Future) Soil ingestion 1.93 x 10-1 9.72 X 10-' 1.74 2.69
  Dermal contact    
  Inhalation of volatiles    
  Ingestion of homegrown vegetables    
  (No drinking water source -    
  groundwater is not potable at this site)    ,
18
~.\moffell\ou2\drtlltrod.txI\lo-21.!N\CIIII

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TABLE 2 (Continued)

MOFFE'IT FEDERAL AIRFIELD
OU2-EAST RECORD OF DECISION
SUMMARY OF SITE RISKS
    Total SitedRisk8~Ail Pathwa1S 
   I LCR'  iLCRI Hf 'Hr
Site, ,ExPCJ5ureScenario' .,' Exposure Pathways , (Mean)' (RME) ., (Meao) (RME)
13 Occupational (Current) Soil ingestion 2.03 x 10"6 3.64 x 1
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:
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i
I
i.
A written transcript of the public meeting was used to prepare the responsiveness summary. The
Navy summarized the appropriate comments or questions from the transcript and provided written
responses. The comments and questions from the transcript have been edited to provide a better
understanding of each specific issue.
i
a
.~
Summary of Public Comments
."
Comment 1:
Response:
Comment 2:
Response:
Comment 3:
A member of the public asked if beryllium was the only element or compound present
at OU2-East that was above EP A acceptable health risk levels.
Based on the results of the OU2 Rl BRA for human health, beryllium was the only
chemical of concern (COC) at the OU2-East sites that was found to be present at
levels above the EPA risk level threshold of 1 x I~. However, the Navy conduCted a
spatial analysis of the beryllium data to determine if beryllium was naturally occurring
or ifk was derivelifrom an undiscovered source. The results of this analysis
indicated that beryllium was naturally occurring since no localized high
concentrations were found. In other words, the distribution of beryllium
concentrations in soils both laterally and vertically does not vary significantly.
A member of the public asked what chemicals were detected at Marriage Road Ditch
(Site 3).
According the OU2 Rl BRA, the COCS at Marriage Road Ditch (Site 3) include.
acetone, polychlorinated biphenyls (PCBs) (arochlor 1260), bis(2-ethylhexyl)phthalate,
2-buranone, burylbenzylphthalate, diethylphthalate, tetrachloroethene, toluene,
antimony, beryllium, cobalt, manganese, nickel, and silver. The BRA concluded that,
with the exception of beryllium, concentrations associllJed with these constituents are
low and do not exceed EPA acceptable human health risk levels. Specific
concentrations associated with these constituents are presented in the OU2 Rl report.
A consultant for the Silicon Valley Toxies Coalition (SVTC) noted that the OU2-East
no-action decision was based.only on risks to human health and that risks to
ecological receptors were not cOnsidered.
21
O44-0236IRU2FSImoffOll\~.a1\1G-:zs:941cmg .

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Response:     The Navy acknowledges that risks to ecological receptors were not considered in the
               OU2-East no-action decision. Risks to ecological receptors are currently being
               evaluated in a SWEA.  Unfortunately, the schedule for completion of the SWEA did
               not coincide with the OU2-East schedule.  However, should the SWEA conclude that
               any of the OU2-East sites require remediation to protect ecological receptors,
               remediation will occur through the station-wide RI/FS process.

Comment 4:   A consultant for the SVTC asked why all  of the OU2-East sites were considered for a
               residential risk scenario, with the exception of Sites 5 and 19.

Response:     Site 5 consists of the USTs at the active fuel farm at Mqffett Field, and Site 19
               consists of four former USTs on both the eastern and western sides of Mqffett Field.
               The OU2 BRA evaluated the risks from these sites under an industrial scenario.  The
               rationale was that these are UST sites in industrial areas, and it is unlikely that they
               could be developed for residential use.  The results of the BRA indicated that, under
               this scenario, risks to human health are within EPA acceptable levels.

               Furthermore, most of the USTs at these sites either contain or contained petroleum
               products.  Petroleum products (and any contamination resulting from them) are
               excluded from actions under CERCLA.  Petroleum products and the cleanup of
               petroleum contamination, however, are regulated by the Col EPA under its UST
               program.  The Navy and DTSC have recently negotiated cleanup levels for petroleum
               sites based on (1) total petroleum hydrocarbon levels that are protective of human
               health and groundwater quality, (2) groundwater maximum contaminant levels, and
               (3) EPA preliminary remediation goals for industrial scenarios.

Comment 5:   A consultant for the SVTC asked for clarification regarding the detections of
               beryllium in the OU2-East soils and if the detections are related to operations at the
               Lockheed Aerospace facility located directly east of Moffett Field.
Response:     As discussed in the response to comment 1, the Navy conducted a spatial analysis of
              the beryllium detections to evaluate if they were at naturally occurring levels or if they
              were related to unknown sources.  The beryllium analysis considered approximately
              100 samples taken throughout Moffett Field, including some from the wetlands area.

                                              22

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The results indicated that there was no statistically #gnificanr variation in the
beryllium concentrations. either vertically or laterally. This lack of variation indicates
that the beryllium concentrations are naturally occurring. Therefore. it is unlikely

. . . -
that beryllium was released from the Lockheed A.erospace facility 01110 Moffen Field.
3.0 REFERENCES
Earth Sciences Associates, Inc., and James M. Montgomery, Consulting Engineers, Inc. (ESA and
JMM). 1986. Confirmation Study (Verification Step), Moffett Naval Air Station, California.
ERM-West, Inc. (ERM) and Aqua Resources, Inc. (AR), Joint Venture. 1986a. Final Report
Industrial Waste Engineering Study, Naval Air Station Moffett Field, California. April.
ERM and AR. 1986b. Hazardous Materials Underground Storage Tank Study, Naval Air Station
Moffett Field, California. April.
ERM. 1987. Investigation of Potential Soil and Groundwater Contamination near Tanks 19 and 20,
Tank 66 (sump), and Tanks 67 and 68, Moffett Naval Air Station, California. May.

IT Corporation (IT). 1988. Final Work Plan for Remedial Investigation at NAS Moffett Field,
California, Volumes I through V. Prepared by HAZWRAP Support Contractor Office,
Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee for the U.S. Department of .
Energy. March. .
IT. 1993. Final Remedial Investigation Report Operable Unit 2, Volumes 1 - 4, Naval Air Station
Moffett Field, California. May
Naval Energy and EnviroIlIDtDtaJ Support Activity (NEESA). 1984. Initial Assessment Study of.
Nava1 Air Station Moffett Field, Sunnyvale, California. March
PRC Environmental Management, Inc. (PRC). 1992. Geology and Hydrogeology Technical
Memorandum, Naval Air Station Moffett Field, California. February
PRC and JMM. 1992. Quality Assurance Project Plan, Naval Air Station Moffett Field, California.
July.
PRC and IT. 1994. Final Statistical Analysis of the Occurrence of Beryllium in Soils Technical
Report. Naval Air Station Moffett Field, California. January.
23
~U2FS\mofTdilou2lfDMtrod.tIt\lo.28-941cm&

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