PB98-964504
EPA 541-R98-030
October 1998
EPA Superfund
Record of Decision:
Tracy Defense Depot (USArmy)
2 Volumes
Tracy, CA
4/14/1998
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SFUND RECORDS CTR
3096-00230
Defense Distribution Depot San Joaquin (DDJC),
•racy Site, Tracy, California
Site-Wide Comprenensiv<
Record of Decisioji
Volume 1 of 2 - Text
FINAL
April 1998
U.S. Army Corps.
^"Engineers
Pnguieehng and
Support Center, Huntsville
-' '••*-«' i-^t?qjt*fi-''ii?lf4&.~£
,• ;,:,,. ^••i^^^^^t^^if^
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RCN: 602214.02
FINAL
DEFENSE DISTRIBUTION DEPOT SAN JOAQUDM (DDJC), TRACY SITE
TRACY, CALIFORNIA
SITE-WIDE COMPREHENSIVE RECORD OF DECISION
VOLUME 1 OF 2
(TEXT)
Prepared for:
U.S. Army Corps of Engineers
Engineering and Support Center
Huntsville (CEHNC)
4820 University Square
Huntsville, Alabama 35 816-1822
Attn: CEHNC-PM-ED
Prepared by:
Radian International
10389 Old Placerville Road
Sacramento, California 95827
April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD
DECLARATION FOR THE RECORD OF DECISION D-
D.l Site Name and Location D-
D.2 Statement of Basis and Purpose D-
D.3 Assessment of the Site D-
D.4 Description of the Remedy D-
D.5 Statutory Determinations D-
DS.O DECISION SUMMARY DS-1
DS.l SECTION 1.0: SITE DESCRIPTION DS-1
DS.2 SECTION 2.0: SITE HISTORY AND ENFORCEMENT ACTIVITIES DS-1
DS.3 SECTION 3.0: HIGHLIGHTS OF COMMUNITY PARTICIPATION DS-1
DS.4 SECTION 4.0: SCOPE AND ROLE OF THE RESPONSE ACTION DS-1
DS.5 SECTION 5.0: SUMMARY OF SITE CHARACTERISTICS DS-1
DS.6 SECTION 6.0: SUMMARY OF SITE RISKS DS-2
DS.7 SECTION 7.0: DESCRIPTION OF ALTERNATIVES DS-2
DS.8 SECTION 8.0: COMPARATIVE ANALYSIS OF ALTERNATIVES DS-2
DS.8.1 Threshold Criteria DS-2
DS.8.2 Primary Balancing Criteria DS-2
DS.8.3 Modifying Criteria DS-2
DS.9 SECTION 9.0: SELECTED REMEDY DS-2
DS.10 SECTION 10.0: STATUTORY DETERMINATIONS DS-2
DS.l 1 SECTION 11.0: REFERENCES DS-3
DS.12 SITE-SPECIFIC CROSS REFERENCES DS-3
1.0 SITE DESCRIPTION 1-1
1.1 Site Location 1-1
1.2 Facility Description 1-1
1.3 Meteorology 1-1
1.4 Geology/Hydrology 1-1
1.5 Land and Water Use 1-2
1.6 Cultural and Historic Resources 1-2
2.0 SITE HISTORY AND ENFORCEMENT ACTIVrnES 2-1
2.1 Preliminary Environmental Investigations, Records Search, and Initial Investigations. 2-1
2.1.1 Soil Gas and Groundwater Sampling 2-1
2.1.2 Industrial Waste Lagoons and IWPL Investigations 2-1
2.2 CERCLA Activities 2-2
2.2.1 Operable Unit 1 Remedial Investigation/Feasibility Study 2-2
2.2.2 OU1 Record of Decision 2-3
2.2.3 OU 1 Well Monitoring Program 2-3
2.2.4 OU 1 Well Abandonment Program 2-4
2.2.5 OU 1 Remedial Action 2-4
2.2.6 Comprehensive Remedial Investigation/Feasibility Study 2-4
2.2.7 Selection of Sites for Feasibility Study 2-5
2.2.8 Sites Studied for Feasibility of Remedial Action 2-5
TOC.DOC i 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
2.2.9 Sites Recommended for No Further Action 2-5
2.2.10 Day Care Center 2-6
2.2.11 Proposed Plan 2-6
2.3 Non-CERCLA Investigations 2-6
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 3-1
4.0 SCOPE AND ROLE OF THE RESPONSE ACTION 4-1
5.0 SUMMARY OF SITE CHARACTERISTICS 5-1
5.1 Background 5-1
5.2 Groundwater 5-2
5.3 Soil 5-3
5.4 Group A 5-4
5.4.1 SWMU I/Area 2—Old Sewage Lagoon/Drum Storage Area (Group A) 5-4
5.4.2 Area 1 Building 237 (Group A) 5-6
5.4.3 Area 3—Drum Storage Area (Group A) 5-8
5.5 Group B .- 5-10
5.5.1 SWMU 4—Storm Drain Lagoon (Group B) 5-10
5.5.2 SWMU 6—Building 28 Sump (Group B) 5-13
5.5.3 SWMU 7—Burn Pit No. 1 (Group B) 5-15
5.5.4 SWMU 8—Bum Pit No. 2 (Group B) 5-17
5.5.5 SWMU 20: Aboveground Solvent Tank and Area 1 Building 10 (Group B).. 5-19
5.5.6 SWMU 24—Petroleum Waste Oil Tank (Group B) 5-21
5.5.7 SWMU 27—Building 206 Roundhouse Sump/Area 1 Building 206
(Group B) 5-23
5.5.8 Building 30 Drum Storage Area (Group B) 5-25
5.5.9 Surface and Near-Surface Soils—Northern Depot Area (Group B) 5-27
5.6 Group C 5-29
5.6.1 SWMU 2—Sewage Lagoons and SWMU 3—Industrial Waste Lagoons 5-29
5.6.2 SWMU 3—Industrial Waste Lagoons 5-31
5.6.3 SWMU 33—Industrial Waste Pipeline (Group C) 5-33
5.7 No Further Action 5-35
5.7.1 SWMU 5—Old Industrial Lagoon, Building 255 (No Further Action) 5-35
5.7.2 SWMU 9—Subsistence Waste Pit (No Further Action) 5-37
5.7.3 SWMU 10—Medical Waste Burial Pit (No Further Action) 5-38
5.7.4 SWMU 10A—Possible Medical Waste Burial Pit (No Further Action) 5-39
5.7.5 SWMU 11—Burial of Lime/Foot Bath (No Further Action) 5-41
5.7.6 SWMU 12—Embalming Fluid Dump (No Further Action) 5-42
5.7.7 SWMU 14—Lube Oil Dump (No Further Action) 5-43
5.7.8 SWMU 15—Pesticide Waste Trench (No Further Action) 5-44
5.7.9 SWMU 16—Possible Waste Disposal Area (No Further Action) 5-45
5.7.10 SWMU 21—Battery Acid Dump (No Further Action) 5-46
TOC.DOC it 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
5.7.11 SWMU 22—Previous Hazardous Materials Storage Area
(No Further Action) 5-47
5.7.12 SWMU 23—Building 26 Recoup Operations (No Further Action) 5-48
5.7.13 SWMU 25—Boundary Roads (No Further Action) 5-49
5.7.14 SWMU 29—Used Motor Oil Pit (No Further Action) 5-50
5.7.15 SWMU 30—Salvage Area (No Further Action) 5-51
5.7.16 SWMU 31—Wood Preservation Area (No Further Action) 5-52
5.7.17 SWMU 64—Waste Oil Pit (No Further Action) 5-53
5.7.18 Areal Building 236 (No Further Action) 5-54
5.7.19 Building 15 Drum Storage Area (No Further Action) 5-55
5.7.20 Building 22 Drum Storage Area (No Further Action) 5-56
5.7.21 Building 23 (No Further Action) 5-57
5.8 Day Care Center (Excavation and Disposal—Time Critical Removal Action) 5-58
6.0 SUMMARY OF SITE RISKS 6-1
6.1 BRA Methodology 6-1
6.2 Identification of COPCs for Humans 6-1
6.2.1 Current and Future Land Use 6-1
6.2.2 COPCs and Media of Concern 6-2
6.3 Human Exposure Assessment 6-2
6.3.1 Human Receptors and Exposure Pathways 6-2
6.3.2 Exposure Concentrations 6-2
6.3.3 Assumptions Used to Calculate Chemical Exposure 6-2
6.4 Human Toxicity Assessment Associated with COPCs 6-3
6.5 Human Risk Characterization 6-3
6.6 Ecological Risk Assessment 6-6
6.6.1 Background 6-6
6.6.2 Identification of COPECs 6-6
6.6.3 Exposure Assessment 6-6
6.6.4 Toxicity Assessment 6-7
6.6.5 Risk Characterization 6-7
6.7 Evaluation of Threats to Groundwater Quality 6-8
6.8 Conclusion 6-8
7.0 DESCRIPTION OF ALTERNATIVES 7-1
7.1 General Overview 7-1
7.2 Applicable or Relevant and Appropriate Requirements 7-1
7.2.1 Background 7-1
7.2.2 Definition of ARARs and Other Criteria or Guidelines to be Considered 7-1
7.2.3 Identification of ARARs 7-2
7.2.4 Chemical-Specific ARARs 7-2
7.2.5 Location-Specific ARARs 7-3
7.2.6 Action-Specific ARARs 7-3
7.2.7 Identification of Other Guidance and Criteria to be Considered 7-6
7.3 Operable Unit 1 Groundwater 7-7
7.3.1 Background 7-7
7.3.2 Remedial Action Objectives 7-10
TOC.DOC iii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
Page
7.3.3 Remedial Alternatives 7-10
7.4 Group A Sites 7-10
7.4.1 Remedial Action Objectives 7-10
7.4.2 Remedial Alternatives 7-10
7.5 Group B Sites 7-10
7.5.1 SWMU 4 - Storm Drain Lagoon 7-11
7.5.2 SWMU 6 - Building 28 Sump 7-11
7.5.3 SWMU 7 - Bum Pit No. 1 7-11
7.5.4 SWMU 8 - Bum Pit No. 2 7-12
7.5.5 SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and
Area 1 Building 10 7-12
7.5.6 SWMU 24 - Petroleum Waste Oil Tank 7-13
7.5.7 SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206 7-13
7.5.8 Building 30 Drum Storage Area 7-14
7.5.9 Surface and Near-Surface Soils - Northern Depot Area 7-14
7.6 Group C Sites 7-14
7.6.1 SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons 7-15
7.6.2 SWMU 33 - Industrial Waste Pipeline 7-15
7.7 No Further Action Sites 7-15
8.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 8-1
8.1 Background 8-1
8.2 Analysis of Remedial Alternatives forOU 1 Groundwater 8-1
8.2.1 Remedial Alternatives 8-1
8.2.2 Overall Protection of Human Health and the Environment 8-2
8.2.3 Compliance with ARARs 8-2
8.2.4 Long-Term Effectiveness 8-3
8.2.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-3
8.2.6 Short-Term Effectiveness 8-3
8.2.7 Implementability 8-3
8.2.8 Cost 8-3
8.2.9 State and Community Acceptance 8-3
8.3 Analysis of Remedial Alternatives for the Group A Sites 8-4
8.3.1 Remedial Alternatives 8-4
8.3.2 Overall Protection of Human Health and the Environment 8-4
8.3.3 Compliance with ARARs 8-4
8.3.4 Long-Term Effectiveness 8-5
8.3.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-5
8.3.6 Short-Term Effectiveness 8-5
8.3.7 Implementability 8-5
8.3.8 Cost 8-5
8.3.9 State and Community Acceptance 8-5
8.4 Analysis of Remedial Alternatives for SWMU 4—Storm Drain Lagoons 8-6
8.4.1 Remedial Alternatives 8-6
8.4.2 Overall Protection of Human Health and the Environment 8-6
8.4.3 Compliance with ARARs 8-6
TOC.DOC iv 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
8.4.4 Long-Term Effectiveness 8-6
8.4.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-6
8.4.6 Short-Term Effectiveness 8-7
8.4.7 Implementability 8-7
8.4.8 Cost 8-7
8.4.9 State and Community Acceptance 8-7
8.5 Analysis of Remedial Alternatives for SWMU 6—Building 28 Sump 8-7
8.5.1 Remedial Alternatives 8-7
8.5.2 Overall Protection of Human Health and the Environment 8-8
8.5.3 Compliance with ARARs 8-8
8.5.4 Long-Term Effectiveness 8-8
8.5.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-8
8.5.6 Short-Term Effectiveness 8-8
8.5.7 Implementability 8-8
8.5.8 Cost 8-8
8.5.9 State and Community Acceptance 8-9
8.6 Analysis of Remedial Alternatives for SWMU 7—Bum Pit No. 1 8-9
8.6.1 Remedial Alternatives 8-9
8.6.2 Overall Protection of Human Health and the Environment 8-9
8.6.3 Compliance with ARARs 8-10
8.6.4 Long-Term Effectiveness 8-10
8.6.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-10
8.6.6 Short-Term Effectiveness 8-10
8.6.7 Implementability 8-10
8.6.8 Cost 8-10
8.6.9 State and Community Acceptance 8-11
8.7 Analysis of Remedial Alternatives for SWMU 8—Bum Pit No. 2 8-11
8.7.1 Remedial Alternatives 8-11
8.7.2 Overall Protection of Human Health and the Environment 8-11
8.7.3 Compliance with ARARs 8-11
8.7.4 Long-Term Effectiveness 8-12
8.7.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-12
8.7.6 Short-Term Effectiveness 8-12
8.7.7 Implementability 8-12
8.7.8 Cost 8-12
8.7.9 State and Community Acceptance 8-12
8.8 Analysis of Remedial Alternatives for SWMU 20—Aboveground
Solvent Tank/Building 26 Recoup Operations and Area 1 Building 10 8-13
8.8.1 Remedial Alternatives 8-13
8.8.2 Overall Protection of Human Health and the Environment 8-13
8.8.3 Compliance with ARARs 8-13
8.8.4 Long-Term Effectiveness 8-14
8.8.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-14
8.8.6 Short-Term Effectiveness 8-14
8.8.7 Implementability 8-14
8.8.8 Cost 8-14
TOC.DOC v 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
Page
8.8.9 State and Community Acceptance 8-14
8.9 Analysis of Remedial Alternatives for SWMU 24—Petroleum Waste Oil Tank 8-14
8.9.1 Remedial Alternatives 8-14
8.9.2 Overall Protection of Human Health and the Environment 8-15
8.9.3 Compliance with ARARs 8-15
8.9.4 Long-Term Effectiveness 8-15
8.9.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-16
8.9.6 Short-Term Effectiveness 8-16
8.9.7 Implementability 8-16
8.9.8 Cost 8-16
8.9.9 State and Community Acceptance 8-16
8.10 Remedial Alternatives for SWMU 27—Building 206 Roundhouse Sump/Area 1
Building 206 8-17
8.10.1 Remedial Alternatives 8-17
8.10.2 Overall Protection of Human Health and the Environment 8-17
8.10.3 Compliance with ARARs 8-17
8.10.4 Long-Term Effectiveness 8-17
8.10.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-17
8.10.6 Short-Term Effectiveness 8-18
8.10.7 Implementability 8-18
8.10.8 Cost 8-18
8.10.9 State and Community Acceptance 8-18
8.11 Analysis of Remedial Alternatives for Building 30 Drum Storage Area 8-18
8.11.1 Remedial Alternatives 8-18
8.11.2 Overall Protection of Human Health and the Environment 8-18
8.11.3 Compliance with ARARs 8-19
8.11.4 Long-Term Effectiveness 8-19
8.11.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-19
8.11.6 Short-Term Effectiveness 8-19
8.11.7 Implementability 8-19
8.11.8 Cost 8-19
8.11.9 State and Community Acceptance 8-19
8.12 Analysis of Remedial Alternatives for Surface and Near-Surface Soil—Northern
Depot Area 8-20
8.12.1 Remedial Alternatives 8-20
8.12.2 Overall Protection of Human Health and the Environment 8-20
8.12.3 Compliance with ARARs 8-20
8.12.4 Long-Term Effectiveness 8-20
8.12.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-21
8.12.6 Short-Term Effectiveness 8-20
8.12.7 Implementability 8-21
8.12.8 Cost 8-21
8.12.9 State and Community Acceptance 8-21
TOC.DOC vi 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
8.13 Remedial Alternatives for SWMUs 2 and 3—the Sewage and Industrial
Waste Lagoons 8-21
8.13.1 Remedial Alternatives 8-21
8.13.2 Overall Protection of Human Health and the Environment 8-22
8.13.3 Compliance with ARARs 8-22
8.13.4 Long-Term Effectiveness 8-22
8.13.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-22
8.13.6 Short-Term Effectiveness 8-22
8.13.7 Implementability 8-22
8.13.8 Cost 8-22
8.13.9 State and Community Acceptance 8-22
8.14 Analysis of Remedial Alternatives for SWMU 33—Industrial Waste Pipeline 8-23
8.14.1 Remedial Alternatives 8-23
8.14.2 Overall Protection of Human Health and the Environment 8-23
8.14.3 Compliance with ARARs 8-23
8.14.4 Long-Term Effectiveness 8-23
8.14.5 Reduction of Toxicity, Mobility, and Volume through Treatment 8-24
8.14.6 Short-Term Effectiveness 8-24
8.14.7 Implementability 8-24
8.14.8 Cost 8-24
8.14.9 State and Community Acceptance 8-24
9.0 SELECTED REMEDIES 9-1
9.1 Monitoring Program 9-1
9.2 No Further Action Sites 9-2
9.3 Day Care Center 9-2
9.4 Cleanup Standards 9-2
9.5 OU 1 Groundwater 9-2
9.6 Group A Sites 9-5
9.7 Group B Sites 9-7
9.7.1 SWMU 4 - Storm Drain Lagoon 9-7
9.7.2 SWMU 6 - Building 28 Sump 9-11
9.7.3 SWMU 7 - Burn Pit No. 1 9-12
9.7.4 SWMU 8 - Burn Pit No. 2 9-14
9.7.5 SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and
Area 1 Building 10 9-16
9.7.6 SWMU 24 - Petroleum Waste Oil Tank 9-18
9.7.7 SWMU 27 - Building 206 Roundhouse Sump and Area 1 Building 206 9-20
9.7.8 Drum Storage Area - Building 30 9-22
9.7.9 Surface and Near-Surface Soil - Northern Depot Area 9-23
9.8 Group C Sites 9-24
9.8.1 SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons 9-24
9.8.2 SWMU 33 - Industrial Waste Pipeline (IWPL) 9-26
9.9 Five-Year Review Process 9-28
9.10 Post-ROD Documents 9-28
TOC.DOC vii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
10.0 STATUTORY DETERMINATIONS 10-1
10.1 Sites Recommended for No Further Action 10-1
10.2 Statutory Requirements 10-1
10.3 Operable Unit (OU) 1 Groundwater 10-1
10.3.1 Protection of Human Health and the Environment 10-1
10.3.2 Compliance With ARARs 10-1
10.3.3 Cost-effectiveness 10-2
10.3.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-2
10.3.5 Preference for Treatment as a Principal Element 10-2
10.4 Group A Sites 10-2
10.4.1 Protection of Human Health and the Environment 10-2
10.4.2 Compliance With ARARs 10-2
10.4.3 Cost-effectiveness 10-3
10.4.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-3
10.4.5 Preference for Treatment as a Principal Element 10-3
10.5 SWMU 4—Storm Drain Lagoon 10-3
10.5.1 Protection of Human Health and the Environment 10-3
10.5.2 Compliance With ARARs 10-4
10.5.3 Cost-effectiveness 10-4
10.5.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-4
10.5.5 Preference for Treatment as a Principal Element 10-4
10.6 SWMU 6—Building 28 Sump 10-4
10.6.1 Protection of Human Health and the Environment 10-4
10.6.2 Compliance With ARARs 10-5
10.6.3 Cost-effectiveness 10-5
10.6.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-5
10.6.5 Preference for Treatment as a Principal Element 10-5
10.7 SWMU 7—Burn Pit No. 1 10-5
10.7.1 Protection of Human Health and the Environment 10-6
10.7.2 Compliance With ARARs 10-6
10.7.3 Cost-effectiveness 10-6
10.7.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-6
10.7.5 Preference for Treatment as a Principal Element 10-7
10.8 SWMU 8—Burn Pit No. 2 10-7
10.8.1 Protection of Human Health and the Environment 10-7
10.8.2 Compliance With ARARs 10-7
10.8.3 Cost-effectiveness 10-7
10.8.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-7
10.8.5 Preference for Treatment as a Principal Element 10-8
TOC.DOC viii 2ApriI1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
10.9 SWMU 20 Aboveground Solvent Tank Building 26 Recoup Operations
and Area 1 Building 10 10-8
10.9.1 Protection of Human Health and the Environment 10-8
10.9.2 Compliance With ARARs 10-8
10.9.3 Cost-effectiveness 10-8
10.9.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-8
10.9.5 Preference for Treatment as a Principal Element 10-9
10.10 SWMU 24—Petroleum Waste Oil Tank 10-9
10.10.1 Protection of Human Health and the Environment 10-9
10.10.2 Compliance With ARARs 10-9
10.10.3 Cost-effectiveness 10-9
10.10.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-9
10.10.5 Preference for Treatment as a Principal Element 10-10
10.11 SWMU 27—Building 206 Roundhouse Sump/Area 1 Building 206 10-10
10.11.1 Protection of Human Health and the Environment 10-10
10.11.2 Compliance With ARARs 10-10
10.11.3 Cost-effectiveness 10-10
10.11.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-10
10.11.5 Preference for Treatment as a Principal Element 10-11
10.12 Building 30 Drum Storage Area 10-11
10.12.1 Protection of Human Health and the Environment 10-11
10.12.2 Compliance With ARARs 10-11
10.12.3 Cost-effectiveness 10-11
10.12.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-12
10.12.5 Preference for Treatment as a Principal Element 10-12
10.13 Surface and Near-Surface Soils—Northern Depot Area 10-12
10.13.1 Protection of Human Health and the Environment 10-12
10.13.2 Compliance With ARARs 10-12
10.13.3 Cost-effectiveness 10-12
10.13.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-12
• 10.13.5 Preference for Treatment as a Principal Element 10-13
10.14 SWMUs 2 and 3—Sewage and Industrial Waste Lagoons 10-13
10.14.1 Protection of Human Health and the Environment 10-13
10.14.2 Compliance With ARARs 10-13
10.14.3 Cost-effectiveness 10-13
10.14.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-13
10.14.5 Preference for Treatment as a Principal Element 10-14
TOC.DOC ix 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
TABLE OF CONTENTS - TRACY ROD (Continued)
10.15 SWMU 33—Industrial Waste Pipeline (IWPL) 10-14
10.15.1 Protection of Human Health and the Environment 10-14
10.15.2 Compliance With ARARs 10-14
10.15.3 Cost-effectiveness 10-14
10.15.4 Utilization of Permanent Solutions, Alternative Treatment,
and Resource Recovery 10-14
10.15.5 Preference for Treatment as a Principal Element 10-15
11.0 REFERENCES 11-1
APPENDICES
Appendix A - Administrative Record File Index
Appendix B - Figures
Appendix C - SWMU 4 Technical Memoranda
Appendix D - Risk Calculations for SWMU 4
Appendix E - Well Monitoring Program
Appendix F - Analytical Methods and Reporting Limits Proposed for DDJC-Tracy Site-Wide
Comprehensive Record of Decision
Appendix G - DI-WET Results and Recommendations for the Former Sewage and Industrial Waste
Lagoons at DDJC-Tracy
TOC.DOC x 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF TABLES
Page
D-l Selected Remedies for Each Site at DDJC-Tracy D-3
D-2 Detailed Components of Selected Remedies for Sites Requiring Action D-4
DS-1 Major Topics by Site DS-4
1-1 DDJC-Tracy, Stratigraphic and Hydrostratigraphic Nomenclature 1-3
2-1 Background of Solid Waste Management Units and Soil Areas 2-7
2-2 Summary of Current Site Status, DDJC-Tracy 2-10
2-3 Status of the UST Sites, DDJC-Tracy, Comprehensive RI/FS and UST Site Investigations .... 2-15
3-1 DDJC-Tracy Public Meeting Attendees 3-2
5-1 Summary of Fate and Transport and Risk Data for SWMU I/Area 2 5-5
5-2 Estimated Volume and Mass of COCs in Soil for SWMU I/Area 2 5-5
5-3 Summary of Fate and Transport and Risk Data for Area 1 Building 237 5-7
5-4 Estimated Volume and Mass of COCs in Soil for Area 1 Building 237 5-7
5-5 Summary of Fate and Transport and Risk Data for Area 3 5-9
5-6 Estimated Volume and Mass of COCs in Soil for Area 3 5-9
5-7 Summary of Fate and Transport and Risk Data for SWMU 4 5-12
5-8 Estimated Volume and Mass of COCs in Soil for SWMU 4 5-12
5-9 Summary of Fate and Transport and Risk Data for SWMU 6 5-14
5-10 Estimated Volume and Mass of COCs in Soil for SWMU 6 5-14
5-11 Summary of Fate and Transport and Risk Data for SWMU 7 5-16
5-12 Estimated Volume and Mass of COCs in Soil for SWMU 7 5-16
5-13 Summary of Fate and Transport and Risk Data for SWMU 8 5-18
5-14 Estimated Volume and Mass of COCs in Soil for SWMU 8 5-18
5-15 Summary of Fate and Transport and Risk Data for SWMU 20 5-20
5-16 Estimated Volume and Mass of COCs in Soil for SWMU 20 5-20
5-17 Summary of Fate and Transport and Risk Data for SWMU 24 5-22
5-18 Estimated Volume and Mass of COCs in Soil for SWMU 24 5-22
5-19 Summary of Fate and Transport and Risk Data for SWMU 27 and Area 1 Building 206 5-24
5-20 Estimated Volume and Mass of COCs in Soil for SWMU 27 an Area 1 Building 206 5-24
5-21 Summary of Fate and Transport and Risk Data for Building 30 Drum Storage Area 5-26
5-22 Estimated Volume and Mass of COCs in Soil for Building 30 Drum Storage Area 5-26
5-23 Summary of Fate and Transport and Risk Data for Northern Depot Soils 5-28
5-24 Estimated Volume and Mass of COCs in Soil for Northern Depot Area 5-28
5-25 Summary of Fate and Transport and Risk Data for SWMU 2 5-30
5-26 Summary of Fate and Transport and Risk Data for SWMU 3 5-32
5-27 Estimated Volume and Mass of COCs in Soil for SWMU 2 and 3 5-32
5-28 Summary of Fate and Transport and Risk Data for SWMU 33 5-34
5-29 Estimated Volume and Mass of COCs in Soil for SWMU 33 5-34
5-30 Summary of Fate and Transport and Risk Data for SWMU 5 5-36
5-31 Summary of Fate and Transport and Risk Data for SWMU 9 5-37
5-32 Summary of Fate and Transport and Risk Data for SWMU 10 5-38
5-33 Summary of Fate and Transport and Risk Data for SWMU 10A 5-40
TOC.DOC xi 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF TABLES (Continued)
Page
5-34 Summary of Fate and Transport and Risk Data for SWMU 11 5-41
5-35 Summary of Fate and Transport and Risk Data for SWMU 12 5-42
5-36 Summary of Fate and Transport and Risk Data for SWMU 14 5-43
5-37 Summary of Fate and Transport and Risk Data for SWMU 15 5-44
5-38 Summary of Fate and Transport and Risk Data for SWMU 16 5-45
5-39 Summary of Fate and Transport and Risk Data for SWMU 21 5-46
5-40 Summary of Fate and Transport and Risk Data for SWMU 22 5-47
5-41 Summary of Fate and Transport and Risk Data for SWMU 23 5-48
5-42 Summary of Fate and Transport and Risk Data for SWMU 25 5-49
5-43 Summary of Fate and Transport and Risk Data for SWMU 29 5-50
5-44 Summary of Fate and Transport and Risk Data for SWMU 30 5-51
5-45 Summary of Fate and Transport and Risk Data for SWMU 31 5-52
5-46 Summary of Fate and Transport and Risk Data for SWMU 64 5-53
5-47 Summary of Fate and Transport and Risk Data for Area 1 Building 236 5-54
5-48 Summary of Fate and Transport and Risk Data for Building 15 Drum Storage Area 5-55
5-49 Summary of Fate and Transport and Risk Data for Building 22 Drum Storage Area 5-56
5-50 Summary of Fate and Transport and Risk Data for Building 23 5-57
5-51 Summary of Fate and Transport and Risk Data for Day Care Center 5-58
6-1 Exposure Units, DDJC-Tracy 6-10
6-2 Summary of Current Pathways Evaluated in Detail 6-11
6-3 Summary of Potential Future Pathways Evaluated in Detail 6-12
6-4 Summary of Human Health Risks to Current Receptors, DDJC-Tracy 6-14
6-5 Summary of Potential Health Risks to Future Receptors, DDJC-Tracy 6-16
6-6 Summary of Cancer Risks at EU 8 6-18
6-7 Summary of Risks at EU 10 6-19
6-8 COCs That Require Remediation for the Protection of Human Health 6-20
6-9 Basis for Soil Cleanup Standards to Protect Groundwater 6-21
7-1 Groundwater Chemicals of Concern: Detection Frequency, Remedial Decision Rationale, and
Risk Characterization, DDJC-Tracy 7-17
7-2 Remedial Alternatives for OU 1 Groundwater 7-35
7-3 Remedial Alternatives for SWMU I/Area 2, Area 1 Building 237 and Area 3 7-38
7-4 Remedial Alternatives for SWMU 4 - Storm Drain Lagoon 7-41
7-5 Remedial Alternatives for SWMU 6 - Building 28 Sump 7-43
7-6 Remedial Alternatives for SWMU 7 - Burn Pit No. 1 7-45
7-7 Remedial Alternatives for SWMU 8 - Bum Pit No. 2 7-48
7-8 Remedial Alternatives for SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup
Operations and Area 1 Building 10 7-51
7-9 Remedial Alternatives for SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank. 7-54
7-10 Remedial Alternatives for SWMU 27 - Building 206 Roundhouse Sump/Area 1
Building 206 7-58
7-11 Remedial Alternatives for Building 30 Drum Storage Area 7-60
7-12 Remedial Alternatives for Surface and Near Surface Soil - Northern Depot Area 7-62
7-13 Remedial Alternatives for SWMUs 2/3 7-64
7-14 Remedial Alternatives for SWMU 33 7-66
TOC.DOC xii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF TABLES (Continued)
Page
7-15 No Further Action Sites 7-69
8-1 National Contingency Plan (NCP) Evaluation Criteria 8-25
8-2 Comparative Analysis of Alternatives by Site 8-26
9-1 Selected Remedies 9-29
9-2 Performance Monitoring Network 9-31
9-3 Dieldrin in OU 1 Groundwater, Alternative 3 - Ground water Extraction and Treatment 9-36
9-4 SWMU I/Area 2 - Aboveground Solvent Tank/Building 26 Recoup Operations
Alternative 3 - Soil Vapor Extraction 9-38
9-5 Area 1 Building 237 Alternative 3 - Soil Vapor Extraction 9-39
9-6 Area 3 Alternative 3 - Soil Vapor Extraction 9-40
9-7 Groundwater Monitoring Requirements (flg/L) for DDJC-Tracy 9-41
9-8 SWMU 4 - Storm Drain Lagoon Alternative 3 - Limited Excavation and Disposal of
Sediments 9-46
9-9 SWMU 6 - Building 28 Sump Alternative 4A - Excavation and Class n Disposal 9-47
9-10 SWMU 6 - Building 28 Sump Alternative 4B - Excavation and Class I Disposal 9-48
9-11 SWMU 7 - Bum Pit No. 1 Alternative 2 - Institutional Controls 9-49
9-12 SWMU 8 - Burn Pit No. 2 Alternative 4 - Excavation and Class I Disposal 9-50
9-13 SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and Area 1
Building 10 Alternative 3 - SVE, Excavation and Class I Disposal 9-52
9-14 SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Alternative 3 - Bioventing 9-54
9-15 SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206 Alternative 3 - Excavation
and Class I Disposal 9-55
9-16 Drum Storage Area - Building 30 Alternative 2 - Institutional Controls 9-56
9-17 Surface and Near-Surface Soils - Northern Depot Area Alternative 3 - Asphalt Cover
DDJC-Tracy 9-57
9-18 SWMUs 2/3 - Sewage and Industrial Waste Lagoons Alternative 3 - Excavation and Class I
Disposal 9-58
9-19 SWMU 33 - Industrial Waste Pipeline Alternative 3 - Excavation, Grouting, and Institutional
Controls 9-59
10-1 Compliance with Location-Specific ARARs 10-16
10-2 Compliance with Action-Specific ARARs for OU 1 Groundwater Remediation 10-17
10-3 Compliance with Action-Specific ARARs for Soil Remediation 10-30
10-4 Determination of Soil Cleanup Standards for SWMU I/Area 2, DDJC-Tracy 10-56
10-5 Determination of Soil Cleanup Standards for Area 1 Building 237 10-57
10-6 Determination of Soil Cleanup Standards for Area 3 10-58
10-7 Determination of Soil Cleanup Standards for SWMU 4 10-59
10-8 Chemical-Specific Requirements for Disposal of Soil/Sediment, DDJC-Tracy 10-60
10-9 Determination of Soil Cleanup Standards for SWMU 6 10-61
10-10 Determination of Soil Cleanup Standards for SWMU 7 10-62
10-11 Determination of Soil Cleanup Standards for SWMU 8 : 10-63
10-12 Determination of Soil Cleanup Standards for SWMU 20 and Area 1 Building 10 10-64
10-13 Determination of Soil Cleanup Standards for SWMU 24 10-65
TOC.DOC xiii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF TABLES (Continued)
Page
10-14 Determination of Soil Cleanup Standards forSWMU 27 10-66
10-15 Determination of Soil Cleanup Standards for Drum Storage Area Building 30 10-67
10-16 Determination of Soil Cleanup Standards for SWMU 2 and SWMU 3 10-68
10-17 Determination of Soil Cleanup Standards for SWMU 33 10-69
B-l Summary of Data Flags and Figure Abbreviations B-l
TOC.DOC xiv 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF FIGURES
1-1 Site Location, Defense Depot San Joaquin - Tracy Site
1-2 Facility Map, Defense Depot San Joaquin - Tracy Site
1-3 On-Site Surface Water, Defense Depot San Joaquin - Tracy Site
2-1 Solid Waste Management Units Investigated During the Comprehensive RI/FS, Defense Depot
San Joaquin - Tracy Site
2-2 Soil Contamination and Drum Storage Areas Investigated During the Comprehensive RI/FS,
Defense Depot San Joaquin - Tracy Site
2-3 Approximate Locations of Underground Storage Tank Sites Investigated During the
Comprehensive RI/FS, Defense Depot San Joaquin - Tracy Site
2-4 CERCLA Process
5-1 S WMUs and TCE Contamination at DDJC-Tracy
5-2 SWMUs and PCE Contamination at DDJC-Tracy
5-3 SWMUs and Dieldrin Contamination at DDJC-Tracy
9-1 Operable Unit #1 (OU-1) Groundwater Treatment System, Existing and Proposed Facilities,
Defense Depot San Joaquin - Tracy Site
9-2 Proposed Locations of Extraction Wells for Remediation of Dieldrin in Groundwater, Defense
Depot San Joaquin - Tracy Site
9-3 SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area Conceptual Site Layout of Full-
Scale SVE System, Defense Depot San Joaquin - Tracy Site
9-4 Area 1 - Building 237 Conceptual Site Layout of Full-Scale SVE System, Defense Depot San
Joaquin - Tracy Site
9-5 Area 3 - Conceptual Site Layout of Full-Scale SVE System, Defense Depot San Joaquin - Tracy
Site
9-6 SWMU - 4 Conceptual Excavation Footprint, Defense Depot San Joaquin - Tracy Site
9-7 SWMU 6 - Building 28 Sump Conceptual Excavation Footprint, Defense Depot San Joaquin -
Tracy Site
9-8 SWMU - 8 Conceptual Excavation Footprint, Defense Depot San Joaquin - Tracy Site
9-9 SWMU 20 - Conceptual Excavation Footprint and Full-Scale SVE System, Defense Depot San
Joaquin - Tracy Site
9-10 SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank Conceptual Site Layout for
Bioventing System, Defense Depot San Joaquin - Tracy Site
9-11 SWMU - 277Area 1 Conceptual Excavation Footprint Defense Depot San Joaquin - Tracy Site
9-12 Soil Contamination in the Northern Depot Investigated During the Comprehensive RI/FS,
Defense Depot San Joaquin - Tracy Site
9-13 Selected Alternative for SWMUs 2 and 3, Defense Depot San Joaquin - Tracy Site
B-l SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area TCE Concentrations Detected in
Soil-Gas Samples, Defense Depot San Joaquin - Tracy Site
B-2 SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area VOCs, Metals, and Petroleum
Hydrocarbons Detected in Soil and Groundwater Samples, Defense Depot San Joaquin - Tracy
Site
B-3 SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area SVOCs and Pesticides/PCBs
Detected in Soil Samples, Defense Depot San Joaquin - Tracy Site
TOC.DOC xv 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF FIGURES (Continued)
B-4 SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area Site Location Map, Defense Depot
San Joaquin - Tracy Site
B-5 Area 1 - Building 237 Constituents Delected in Soil, Soil Gas, and Groundwater Samples,
Defense Depot San Joaquin - Tracy Site
B-6 Constituents Detected in Soil and Groundwater Samples, Defense Depot San Joaquin - Tracy
Site
B-7 Area 3 - Distribution of PCE and TCE in Soil, Defense Depot San Joaquin - Tracy Site
B-8 SWMU 4 - Storm Drain Lagoon Organic Constituents and Metals Detected in Soil and Sediment
Samples, Defense Depot San Joaquin - Tracy Site
B-9 SWMU 4 - Storm Drain Lagoon Constituents Detected in Surface Water and Groundwater
Samples, Defense Depot San Joaquin - Tracy Site
B-10 SWMU 4 - Storm Drain Lagoon Analytes Detected in Soil at Depth, Defense Depot San
Joaquin - Tracy Site
B-l 1 SWMU 6 - Building 28 Sump Constituents Detected in Soil and Groundwater Samples, Defense
Depot San Joaquin - Tracy Site
B-l2 SWMU 7 (North Area) - Burn Pit No. 1 Organic Constituents Detected in Surface Soil and
Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-l3 SWMU 7 - (South Area) - Bum Pit No. 1 Constituents Detected in Soil and Groundwater
Samples, Defense Depot San Joaquin - Tracy Site
B-l4 SWMU 8 - Burn Pit No. 2 Constituents Detected in Soil and Groundwater Samples, Defense
Depot San Joaquin - Tracy Site
B-l5 SWMU 8 - Trench 8-1 Organic Constituents and Metals Detected in Soil Samples, Defense
Depot San Joaquin - Tracy Site
B-l6 SWMU 8 - Trench 8-2 Organic Constituents and Metals Detected in Soil Samples, Defense
Depot San Joaquin - Tracy Site
B-l7 SWMU 20 - Above Ground Solvent Tank, SWMU 23 - Building 28 Recoup Operation, and Area
1 Building 10 Constituents Detected in Groundwater, Surface Water, and Sludge Samples,
Defense Depot San Joaquin - Tracy Site
B-l8 SWMU 20 - Above Ground Solvent Tank SWMU 23 - Building 28 Recoup Operation and Area 1
Building 10 Constituents Detected in Soil Samples, Defense Depot San Joaquin - Tracy Site
B-l9 SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank Organic Constituents and
Metals Detected in Soil and Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-20 SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building 206 Constituents Detected in
Surface Soil and Soil Boring Samples, Defense Depot San Joaquin - Tracy Site
B-21 SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building 206 Constituents Detected in
Soil Boring Samples, Defense Depot San Joaquin - Tracy Site
B-22 SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building 206 Constituents Detected in
Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-23 Building 30 - Drum Storage Area Constituents Detected in Soil Samples, Defense Depot San
Joaquin - Tracy Site
B-24 Surface Soil Results (0-0.5 Feet bgs), Defense Depot San Joaquin - Tracy Site
B-25 Near Surface Soil Results (0.5-1.5/2.0 Feet bgs), Defense Depot San Joaquin - Tracy Site
B-26 SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Organic Constituents
Detected in Soil and Sediment Samples, Defense Depot San Joaquin - Tracy Site
B-27 SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Metals Detected in Soil and
Sediment Samples, Defense Depot San Joaquin - Tracy Site
TOC.DOC xvi 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF FIGURES (Continued)
B-28 SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Constituents Detected in
Surface Water and Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-29 SWMU 33 - Industrial Waste Pipeline Constituents Detected in Soil Samples, Defense Depot
San Joaquin - Tracy Site
B-30 SWMU 5 - Old Industrial Lagoon, Building 255 Constituents Detected in Soil and Groundwater
Samples, Defense Depot San Joaquin - Tracy Site
B-31 SWMU 9 - Subsistence Waste Pit Organic Constituents and Metals Detected in Soil and
Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-32 SWMU 10 - Medical Waste Burial Pit Organic Constituents and Metals Detected in Soil and
Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-33 SWMU 10A - Possible Medical Waste Burial Pits Site Location Map, Defense Depot San
Joaquin - Tracy Site
B-34 SWMU 11 - Burial of Lime/Foot Bath Site Location, Defense Depot San Joaquin - Tracy Site
B-35 SWMU 12 - Embalming Fluid Dump Constituents Detected in Soil and Groundwater Samples,
Defense Depot San Joaquin - Tracy Site
B-36 SWMU 14 - Lube Oil Dump Organic Constituents and Metals Detected in Soil Samples, Defense
Depot San Joaquin - Tracy Site
B-37 SWMU 15 - Pesticide Waste Trench Constituents Detected in Soil and Groundwater Samples,
Defense Depot San Joaquin - Tracy Site
B-38 SWMU 16 - Possible Hazardous Waste Disposal Area Site Location Map and Constituents
Detected in Soil and Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-39 SWMU 21 - Battery Acid Dump Constituents Detected in Soil and Hydropunch Samples,
Defense Depot San Joaquin - Tracy Site
B-40 SWMU 21 - Previous Hazardous Material Storage Area Constituents Detected in Soil and
Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-41 SWMU 25 - Boundary Roads Constituents Detected in Soil Samples, Defense Depot San
Joaquin - Tracy Site
B-42 SWMU 29 - Used Motor Oil Disposal Pit Site Location Map, Defense Depot San Joaquin - Tracy
Site
B-43 SWMU 30 - Salvage Area Site Location Map, Defense Depot San Joaquin - Tracy Site
B-44 SWMU 30 - Salvage Area Organic Constituents and Metals Detected in Soil Samples, Defense
Depot San Joaquin - Tracy Site
B-45 SWMU 31 - Wood Preservation Area Constituents Detected in Soil and Groundwater Samples,
Defense Depot San Joaquin - Tracy Site
B-46 SWMU 64 - Waste Oil Pit Constituents Detected in Soil and Groundwater Samples, Defense
Depot San Joaquin - Tracy Site
B-47 Area 1 - Building 236 Constituents Detected in Soil Samples, Defense Depot San
Joaquin - Tracy Site
B-48 Drum Storage Area Building 15 Constituents Detected in Soil Samples, Defense Depot San
Joaquin - Tracy Site
B-49 Building 22 - Drum Storage Area Constituents Detected in Soil and Groundwater Samples,
Defense Depot San Joaquin - Tracy Site
B-50 Day Care Center Organic Constituents and Metals Detected in Soil Samples, Defense Depot San
Joaquin - Tracy Site
TOC.DOC xvii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF RGURES (Continued)
C-l Storm Water Detention Pond, Defense Depot San Joaquin - Tracy Site
C-2a Cross Section of Soil and Sediment Sampling Results for SWMU 4 Organic Constituents,
Defense Depot San Joaquin - Tracy Site
C-2b Cross Section of Soil and Sediment Sampling Results for SWMU 4 Organic Constituents,
Defense Depot San Joaquin - Tracy Site
E-l Groundwater Monitoring Well Sampling Frequency Decision Flowchart
E-2 SWMUs and Well Locations, DDJC-Tracy
E-3 New and Pre-Existing Monitoring Wells Intended for Downgradient Monitoring at SWMUs 7
and 8 and Drum Storage, Building 30
TOC.DOC xviii 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF ACRONYMS
CFR Code of Federal Regulations
COC Chemical of Concern
COPC Chemical of Potential Concern
COPEC Chemical of Potential Ecological Concern
DCC Day Care Center
1,1-DCE 1,1-dichloroethene
1,2-DCE 1,2-dichloroethene
ODD Dichlorodiphenyldichloroethane
DDE Dichlorodephenyldichloroethene
DDJC Defense Distribution Depot San Joaquin
DDRW Defense Distribution Region West
DDT Dichlorodephenyltrichloroethane
DDTR DDD, DDE, and DDT
DHS Department of Health Services
DI WET De-Ionized Water-Waste Extraction Tests
DLA Defense Logistics Agency
DoD Department of Defense
DSERTS Defense Site Environmental Reporting and Tracking System
DTSC Department of Toxic Substances Control
EE/CA Engineering Evaluation/Cost Analysis
EQP Equilibrium Partitioning
ERA Ecological Risk Assessment
ESD Explanation of Significant Differences
EU Exposure Unit
FFA Federal Facilities Agreement
FS Feasibility Study
GAC Granular Activated Carbon
gpm gallons per minute
HHRA Human Health Risk Assessment
HI hazard index
ILCR Increased Lifetime Cancer Risk
IRM Interim Remedial Measure
IRP Installation Restoration Program
IWPL Industrial Waste Pipeline
LOEL Lowest Observable Effect Level
LUFT Leaking Underground Fuel Tank
MCL maximum contaminant level
MEK methyl ethyl ketone
TOC.DOC
XIX
2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF ACRONYMS (Continued)
mg/Kg milligrams per kilogram
mg/kg/day milligrams per kilogram per day
mph miles per hour
msl mean sea level
NC not calculated
NCP National Contingency Plan
NFA No Further Action
NOAEL no observable adverse effect level
NOEL no observable effect level
NPL National Priorities List
O&M operations and maintenance
OP organophosphorus
PAH polycyclic aromatic hydrocarbon
PCB polychlorinated biphenyl
PCE tetrachloroethene
PCP pentachlorophenol
POW Prisoner of War
ppb parts per billion
ppbv parts per billion volume
ppm parts per million
RAGS Risk Assessment Guidance for Superfund
RAO Remedial Action Objective
RAWP Remedial Action Work Plan
RCRA Resource Conservation and Recovery Act
RfD reference dose
RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
RI/RA Remedial Investigation/Risk Assessment
ROD Record of Decision
RWQCB Regional Water Quality Control Board
SAL state action level
SARA Superfund Amendments and Reauthorization Act
SCFM standard cubic feet per minute
SL slope factor
STLC soluble threshold limit concentration
SVE soil vapor extraction
SVOCs semivolatile organic compounds
SWMU Solid Waste Management Unit
TOC.DOC
2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
LIST OF ACRONYMS (Continued)
SWRCB State Water Resources Control Board
TCE trichloroethene
TCPA temporary children's play area
TPH total petroleum hydrocarbons
TPHD total petroleum hydrocarbons as diesel
TPHG total petroleum hydrocarbons as gasoline
TPH-MO total petroleum hydrocarbons as motor oil
U.S. EPA United States Environmental Protection Agency
UCL upper confidence limit
p.g/dl micrograms per deciliter
[ig/L micrograms per Liter
USAGE U.S. Army Corps of Engineers
USAEHA U.S. Army Environmental Hygiene Agency
USATHAMA U.S. Army Toxic and Hazardous Materials Agency
USC United States Code
UST Underground Storage Tank
VOC volatile organic compound
WCC Woodward Clyde Consultants
WDR Waste Discharge Requirements
WMP Well Monitoring Program
WQSA Water Quality Site Assessment
TOC.DOC
2 Apnl 1998
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DECLARATIO
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
DECLARATION FOR THE RECORD
OF DECISION
D.1 Site Name and Location
Defense Depot San Joaquin (DDJC)-Tracy,
Tracy, California.
D.2 Statement of Basis and
Purpose
D.2.1 This decision document presents the
selected remedial action for the DDJC-Tracy
Site in Tracy, California, developed in
accordance with the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization
Act (SARA). The selected action is also in
compliance with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP)
(40 CFR Part 300) and Chapter 6.8 of the
California Health and Safety Code (Section
25300 ei seq.). Further, these actions are being
taken in response to the California Water Code
(Section 13300 et seq.). The selection of
remedies is based on the administrative record
for this site.
D.2.2 The U.S. Environmental Protection
Agency (U.S. EPA) and the State of California
concur on the selected remedies.
D.3 Assessment of the Site
Actual or threatened releases of hazardous
substances from this site, if not addressed by
implementing the response actions selected in
this Record of Decision (ROD), may present an
imminent and substantial endangerment to
public health, welfare, or the environment.
D.4 Description of the Remedy
D.4.1 This Comprehensive ROD is the final
action for DDJC-Tracy. An earlier ROD,
covering Operable Unit 1 (OU 1), involved
remediation of volatile organic compounds
(VOCs) in groundwater. This ROD includes a
comprehensive evaluation of all groundwater
issues and addresses all sites with soil
contamination.
D.4.2 Twenty-one sites are recommended for
no further action. Sixteen on-depot sites were
considered for further action in the feasibility
study (Montgomery Watson, 1996a). The
selected remedies for each of the sites are
summarized in Table D-l. A description of the
selected remedies for sites requiring action is
provided in Table D-2.
D.5 Statutory Determinations
D.5.1 The selected remedies are protective of
human health and the environment, comply with
federal and state requirements that are legally
applicable or relevant and appropriate to the
remedial action, and are cost-effective. These
remedies use permanent solutions where
possible and satisfy, to the extent practicable, the
statutory preference for remedies that employ
treatment and reduce toxicity, mobility, or
volume as a principal element. The remedies for
SWMUs 2/3, SWMU 4, SWMU 6, SWMU 7,
SWMU 8, SWMU 27, SWMU 33, Drum
Storage Area/Building 30, the Day Care Center,
and Northern Depot Area soils do not include
treatment. Because treatment of the principal
threats at these sites was not found to be
practicable, the remedies for these sites do not
satisfy the statutory preference for treatment.
Institutional Controls were selected for
SWMU 7 and Drum Storage Area/Building 30
because potential threats to groundwater quality
have not been confirmed through historical
modeling. Paving was selected as a remedy for
Northern Depot Area soils to prevent depot
workers in this active storage area from being
exposed to contaminated surface soils.
D.5.2 Five-year reviews will be conducted in
accordance with CERCLA Section 121(c). The
five-year review is required for sites with
institutional controls that restrict use and for
sites (i.e., groundwater) where cleanup standards
will not be attained within five years. Five-year
reviews will also be required for sites where
contaminants remain in place, unless it can be
shown that they pose no further threat to human
health and the environment.
DECIARA.DOC
17 February 1998
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DDJC-Tracv Site Whse Comprehensive Record of Decision
GLENN M. MELTON
Colonel. USA
Commander. DDJC
Date
DAN OPALSKI
Chief. Federal Facilities Cleanup Office •
United States Environmental Protection Agency
Region IX
Date
ANTHONY J. U
Chief. Northern California Operations
Office of Military Facilities
Site Mitigation Program
Department of Toxic Substances Control
Date
M. £#RLTt)N
Executive Officer. Central Valley Regional
Water Qualm- Control Board
Date
DECLARA.DOC
17Fefaroan 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table D-1. Selected Remedy for Each Site at DDJC-Tracy
DSERTS Solid Waste Management
Number Area/Soil Area
Selected Remedy
31 OU 1 Groundwater
1 SWMU I/Area 2
2/3 SWMU 2/3
4 SWMU 4
5 SWMU 5
6 SWMU 6
7 SWMU 7
8 SWMU 8
9 SWMU 9
10 SWMU 10
33 SWMU 10A
11 SWMU 11
12 SWMU 12
14 SWMU 14
15 SWMU 15
16 SWMU 16
20 SWMU 20
21 SWMU 21
22 SWMU 22
23 SWMU 23
24 SWMU 24
25 SWMU 25
27 SWMU 27/Area 1
29 SWMU 29
30 SWMU 30
70 SWMU 31
65 SWMU 33
64 SWMU 64
N/A Area 1 Building 236
66 Area 1 Building 237
68 Area 3
N/A Building 15 Drum Storage Area
N/A Building 22 Drum Storage Area
N/A Building 23
69 Building 30 Drum Storage Area
67 Depot Wide Surface and Near
Surface Soils, Northern Depot
Area
N/A Day Care Center
Groundwater Extraction, Treatment, Injection and Monitoring
Soil Vapor Extraction and Monitoring
Excavation with Off-Site Disposal and Monitoring
Excavation with Off-Site Disposal of Sediments, Installation
of Sediment Controls and Monitoring
No Further Action
Excavation with Off-Site Disposal and Monitoring
Institutional Controls and Monitoring
Excavation with Off-Site Disposal and Monitoring
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
Soil Vapor Extraction, Limited Excavation with Off-Site
Disposal, Natural Attenuation, and Monitoring
No Further Action
No Further Action
No Further Action
Bioventing and Monitoring
No Further Action
Excavation with Off-Site Disposal and Monitoring
No Further Action
No Further Action
No Further Action
Pipe Grouting, Limited Excavation, Institutional Controls,
and Monitoring
No Further Action
No Further Action
Soil Vapor Extraction and Monitoring
Soil Vapor Extraction and Monitoring
No Further Action
No Further Action
No Further Action
Monitoring
Asphalt Cover
Excavation with Off-Site Disposal
DDJC = Defense Depot San Joaquin
DSERTS = Defense Site Environmental Reporting and Tracking System
SWMU = Solid Waste Management Unit
N/A = not applicable
DECLARA.DOC
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table D-2. Detailed Components of Selected Remedies for Sites Requiring Action
Solid Waste Management
Area/Soil Area
Components
OU 1 Groundwater
SWMU I/Area 2
SWMUs 2/3
SWMU 4
SWMU 6
SWMU 7
SWMU 8
SWMU 20
SWMU 24
SWMU 27/Area 1
SWMU 33
Area 1 Building 237
Area 3
Building 30 Drum Storage Area
Northern Depot Area
Extraction wells (including 7 new wells to capture dieldrin)
Air stripper for VOC removal
Wellhead granular activated carbon for pesticides
Injection facilities
Compliance monitoring
Soil vapor extraction (approximately 10 wells)
Compliance monitoring of groundwater
Excavation (approximately 10,000 cubic yards)
Off-site disposal
Supply 3 inches of clean backfill and a geofabric material to protect
ecological receptors (pending additional risk assessment)
Compliance monitoring of groundwater
Excavation (approximately 2,500 cubic yards)
Off-site disposal
Supply 3 inches of clean backfill and a geofabric material to protect
ecological receptors (pending additional risk assessment)
Construct overflow weir and install sediment trap on northern pond inlet
Compliance monitoring of groundwater and surface water
Excavation (approximately 100 cubic yards)
Compliance monitoring
Land-Use Restrictions for Buildings 19 and 21
Two additional monitoring wells
Compliance monitoring
Excavation (approximately 8,000 cubic yards)
One additional monitoring well
Compliance monitoring
Soil vapor extraction (approximately 2 wells)
Excavation (approximately 510 cubic yards)
Off-site disposal
Compliance monitoring
Bioventing (approximately 1 well)
Compliance monitoring
Excavation (approximately 130 cubic yards)
Off-site disposal
Compliance monitoring
Limited excavation (approximately 10 cubic yards)
Off-site disposal
Pipe grouting
Institutional controls
Compliance monitoring
Soil vapor extraction (approximately 5 wells)
Compliance monitoring
Soil vapor extraction (approximately 8 wells)
Compliance monitoring
Compliance monitoring
Asphalt cover ^^
DECLARA.DOC
2 April 1998
-------
DECISION SUMMARY
--
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
DS.O DECISION SUMMARY
The Decision Summary is the second and main
component of the Record of Decision. It
discusses the site characteristics, the alternatives
evaluated, and the selected remedy. The
Decision Summary also explains how the
selected remedy fulfills statutory requirements.
The Decision Summary comprises eleven
sections:
• Section 1.0: Site Description;
• Section 2.0: Site History and Enforcement
Activities;
• Section 3.0: Highlights of Community
Participation;
• Section 4.0: Scope and Role of the Response
Action;
• Section 5.0: Summary of Site
Characteristics;
• Section 6.0: Summary of Site Risks;
• Section 7.0: Description of Alternatives;
• Section 8.0: Comparative Analysis of
Alternatives;
• Section 9.0: Selected Remedies;
• Section 10.0: Statutory Determinations; and
• Section 11.0: References.
The purpose of each of these sections is briefly
described below. All tables and figures are
provided at the end of each section.
DS.1 SECTION 1.0: SITE
DESCRIPTION
This section provides a general overview of the
site. Major surface and subsurface features, the
local geography, and topography are
summarized. The adjacent land use and nearby
populations are also discussed.
DS.2 SECTION 2.0: SITE HISTORY
AND ENFORCEMENT
ACTIVITIES
A phased approach was used by Defense Depot
San Joaquin (DDJC)-Tracy to address issues
under the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA). This section summarizes the
various investigations and corrective actions that
have taken place (see Figure 2-4). Table 2-1
summarizes the past waste handling and disposal
practices at DDJC-Tracy. Table 2-2 summarizes
the present status of each of the sites.
DS.3 SECTION 3.0: HIGHLIGHTS OF
COMMUNITY PARTICIPATION
This section documents public notices and
participation in the CERCLA process. The
notice and public meeting regarding the
Proposed Plan (Montgomery Watson, 1997a) are
discussed in particular. Further details are
provided in the Responsiveness Summary.
DS.4 SECTION 4.0: SCOPE AND
ROLE OF THE RESPONSE
ACTION
This section defines the scope and role of this
Record of Decision. This is a comprehensive
Record of Decision that addresses all
contaminants in all media. The decision of a
previous Record of Decision for Operable Unit 1
(groundwater) is modified and reaffirmed in this
Record of Decision. All soil issues are also
addressed.
DS.5 SECTION 5.0: SUMMARY OF
SITE CHARACTERISTICS
This section summarizes the nature and extent of
contamination at each of the sites. Areas of
groundwater contamination are identified along
with their suspected sources. Each Solid Waste
Management Unit (SWMU) and soil area is
described; contaminants are identified; and
impacts to groundwater, human health, and
ecological receptors are identified.
DECSUMM.DOC
DS-1
12 December 1997
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
DS.6 SECTION 6.0: SUMMARY OF
SITE RISKS
This section discusses how contaminants of
concern (COCs) were identified and provides
the basis for determining appropriate cleanup
standards. Sections 6.1 through 6.5 summarize
the human health risk assessment. Both
carcinogenic and non-carcinogenic health risks
are discussed. Section 6.6 discusses risks to
ecological receptors (plants and animals). In
Section 6.7, impacts to beneficial uses and
background groundwater quality are discussed.
Sites that require remediation to address threats
to human health, ecological receptors, and water
quality are identified in each of the respective
subsections outlined above.
DS.7 SECTION 7.0: DESCRIPTION
OF ALTERNATIVES
This section begins with a general discussion of
Applicable or Relevant and Appropriate
Requirements (ARARs) and other non-
promulgated guidance To Be Considered
(TBCs). These regulations and guidance were
used in the development of alternatives to
address the sites at DDJC-Tracy. Remedial
action objectives are identified for each site and
alternatives are developed in this section.
Table 7-1 summarizes the screening of
chemicals of potential concern (COPCs) in
groundwater and the remedial decision for these
chemicals. The treatment components,
containment or storage components,
groundwater components, general components,
and major ARARs are identified in Tables 7-2
through 7-14. Table 7-15 provides the rationale
for soil sites where no further action is
recommended.
DS.8 SECTION 8.0: COMPARATIVE
ANALYSIS OF ALTERNATIVES
Nine evaluation criteria are used to evaluate
alternatives for CERCLA sites. These criteria
are:
DS.8.1 Threshold Criteria
• Overall protection of human health and the
environment; and
• Compliance with ARARs.
DS.8.2 Primary Balancing Criteria
• Long-term effectiveness and permanence;
• Reduction of toxicity, mobility, or volume
through treatment;
• Short-term effectiveness;
• Implementability; and
• Cost.
DS.8.3 Modifying Criteria
• State support and agency acceptance; and
• Community acceptance.
Each alternative was evaluated against these
nine criteria. This evaluation is summarized in
Section 8.0.
DS.9 SECTION 9.0: SELECTED
REMEDIES
This section describes the selected remedies.
Points of compliance and remediation goals (i.e.,
cleanup standards) are identified, along with the
basis for the remediation goals. The capital and
operation and maintenance cost for each selected
action is provided.
DS.10 SECTION 10.0: STATUTORY
DETERMINATIONS
CERCLA Section 121 has five statutory
requirements. The selected remedy selected by
the lead agency must:
• Be protective of human health and the
environment;
• Comply with ARARs (or justify a waiver);
DECSUMM.DOC
DS-2
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
• Be cost effective;
• Utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent
practicable; and
• Satisfy the preference for treatment that
reduces toxicity, mobility, or volume as a
principal element, or provide an explanation
as to why this preference was not satisfied.
Each selected remedy was compared to these
requirements and a detailed evaluation of
ARARs is provided in Section 10.0.
DS.11 SECTION 11.0: REFERENCES
This section provides a list of references.
DS.12 SITE-SPECIFIC CROSS
REFERENCES
Table DS-1 is designed to assist the reader who
is only interested in one or a few sites at DDJC-
Tracy. The reader should first locate the site of
interest in the table rows. The columns specify
the major topics addressed in the ROD and the
specific sections and tables that the reader
should consult for information on those topics.
DECSUMM.DOC DS-3 12 December 1997
-------
Site
OU1
Groundwater
Past Site
Activities
Sections
2.2.1-2.2.5
Site
Characterization
Summary
Section 5.2
Table
Human Risks
Table 2-2. 6-8
DS-1. Major Topics by Site
Ecological
Risks
Table 2-2
Threats to
Groundwater
Sections 2.2.1-
2.2.5
Remedial
Alternatives
Section 7.3,
Table 7- 1.7-2
Comparison
of Remedial
Alternatives
Section 8.2.
Table 8-2
How Selected
Remedy Meets
Selected Statutory
Remedy Requirements
Section 9.5 Section 10.3
GROUP A
SWMU I/ Area 2
Area 1 Building.
237
Area 3 Drum
Storage Area
Section 5.4.1
Table 2-1
Section 5.4.2
Table 2-1
Section 5.4.3
Table 2-1
Section 5.4.1
Section 5.4.2
Section 5.4.3
Section 5.4.1
Table 2-2. 6-4.
6-5
Section 5.4.2
Tables 2-2, 6-5,
6-6
Section 5.4.3
Tables 2-2, 6-7
Section 5.4.1
Section 5.4.2
Section 5.4.3
Section 5.4.1
Table 6-9
Section 5.4.2
Table 6-9
Section 5.4.3
Table 6-9
Section 7.4,
Table 7-3
Section 7.4,
Table 7-3
Section 7.4,
Table 7-3
Section 8.3,
Table 8-2
Section 8.3,
Table 8-2
Section 8.3,
Table 8-2
Section 9.6 Section 10.4
Section 9.6 Section 10.4
Section 9.6 Section 10.4
GROUP B
SWMU 4 - Storm
Drain Lagoon
SWMU 6-
Building 28
Sump
SWMU 7 - Bum
Pit No. 1
SWMU 8 - Burn
Pit No. 2
SWMU 20 -
Aboveground
Solvent
Tank/Bldg. 26
Recoup
Operations
Section 5.5.1
Table 2-1
Section 5.5.2
Table 2-1
Section 5.5.3
Table 2-1
Sections 5.5.4
Table 2-1
Section 5.5.5
Table 2-1
Section 5.5.1
Section 5.5.2
Section 5.5.3
Section 5.5.4
Section 5.5.5
Section 5.5.1
Tables 2-2, 6-4,
6-5
Section 5.5.2
Tables 2-2, 6-7
Section 5.5.3
Table 2-2
Section 5.5.4
Tables 2-2, 6-7,
6-8
Section 5.5.5
Tables 2-2, 6-6
Section 6.6.5.4
Section 5.5.2
Section 5.5.3
Section 5.5.4
Section 5.5.5
Section 5.5.1
Table 6-9
Section 5.5.2
Table 6-9
Section 5.5.3
Table 6-9
Section 5.5.4
Table 6-9
Section 5.5.5
Table 6-9
Section 7.5.1,
Table 7-4
Section 7.5.2,
Table 7-5
Section 7.5.3.
Table 7-6
Section 7.5.4,
Table 7-7
Section 7.5.5,
Table 7-8
Section 8.4.1,
Table 8-2
Section 8.5,
Table 8-2
Section 8.6,
Table 8-2
Section 8.7,
Table 8-2
Section 8.8
Section 9.7.1 Section 10.5
Section 9.7.2 Section 10.6
Section 9.7.3 Section 10.7
Section 9.7.4 Section 10.8
Section 9.7.5 Section 10.9
O
9
H
0
50
§
a.
o
ri
X
5'
0
-------
Table DS-1. (Continued)
Site
SWMU 24 -
Petroleum Waste
Oil Tank
SWMU 27 -
Area 1 BIdg. 206
Bldg. 30 Drum
Storage Area
Northern Depot
Area
Past Site
Activities
Section 5.5.6
Table 2-1
Section 5.5.7
Table 2-1
Section 5.5.8
Table 2-1
Section 5.5.9
Table 2-1
Site
Characterization
Summary Human Risks
Section 5.5.6 Section 5.5.6
Tables 2-2, 6-4,
6-5. 6-8
Section 5.5.7 Section 5.5.7
Tables 2-2, 5-6,
6-8
Section 5.5.8 Section 5.5.8
Table 2-2
Section 5.5.9 Section 5.5.9
Tables 2-2, 6-4,
6-5, 6-8
Ecological Threats to
Risks Groundwater
Section 5.5.6 Section 5.5.6
Table 6-9
Section 5.5.7 Section 5.5.7
Table 6-9
Section 5.5.8 Section 5.5.8
Table 6-9
Section 5.5.9 Section 5.5.9
Table 6-9
Comparison
Remedial of Remedial
Alternatives Alternatives
Section 7.5.6. Section 8.9
Table 7-9
Section 7.5.7. Section 8.10
Table 7- 10
Section 7.5.8, Section 8. 1 1
Table 7- 11
Section 7.5.9, Section 8.12
Table 7- 12
How Selected
Remedy Meets
Selected Statutory
Remedy Requirements
Section 9.7.6 Section 10.10
Section 9.7.7 SectionlO.il
Section 9.7.8 Section 1 0. 1 2
Section 9.7.9 Section 1 0. 1 3
GROUP C
SWMUs 2/3 -
Sewage Lagoons
and Ind. Waste
Lagoon
SWMU 33 - Ind.
Waste Pipeline
No Further
Action Sites
Day Care Center
Sections
2.1.2,5.6.1,
5.6.2
Table 2-1
Section 5.6.3
Table 2-1
Sections
5.6.1-5.6.20
Table 2-1
Sections
2.2.10, 5.6.21
Table 2-1
Section 5.6. 1 , 5.6.2 Section 5.6. 1 ,
5.6.2
Tables 2-2. 6-4.
6-5
Section 5.6.3 Section 5.6.3
Tables 2-2. 6-5
Sections 5.7.1- Sections 5.7.1 -
5.7.20 5.7.20 Table 2-2
Section 5.7.21 Section 5.7.21
Tables 6-4, 6-5
Section 6.6.5.3 Section 5.6.1.
5.6.2
Table 6-9
Section 5.6.3 Section 5.6.3
Table 6-9
Sections 5.7.1- Sections 5.7.1 -
5.7.20 5.7.20
Section 5.7.21 Section 5.8
Section 7.6.1 Section 8.13
Table 7-1 3
Section 7.6.2, Section 8.14
Table 7- 14
Section 7.7,
Table 7- 15
Section 9.8.1 Section 10.14
Section 9.8. 2 Section 10.15
Section 9.2 Section 10.1
Section 9.3 Section 10.1
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
1.0 SITE DESCRIPTION
1.1 Site Location
Defense Depot San Joaquin (DDJC)-Tracy is
located in an unincorporated area of San
Joaquin County, 1.5 miles southeast of Tracy,
California; approximately 20 miles southwest of
Stockton, California; and 60 miles east of San
Francisco, California (Figure 1-1).
1.2 Facility Description
DDJC-Tracy is primarily a storage and
distribution facility for various supplies
common to U.S. military services in the western
U.S. and throughout the Pacific. The operating
portion of the depot covers a 448-acre triangular
parcel, and the recently added Tracy Annex
consists of 460 acres of agricultural land north
of the operating portion. The topography at
DDJC-Tracy is gently downward to the north-
northwest from an elevation of about 115 feet
above mean sea level (msl) at the southern
comer to an elevation of 45 feet above msl at
the northern edge of the Tracy Annex
(Figure 1-1). South Chrisman Road borders the
west edge of the facility, Banta Road borders the
east, and Eleventh Street borders the north.
About 75 percent of the operating portion is
covered with buildings (primarily warehouses),
asphalt, or concrete. Numerous smaller
buildings in the northwest corner of the depot
house administration and operations
(Figure 1-2). A large storm water pond and two
sewage lagoons are also located in the
northwestern portion of the depot. The storm
water pond receives runoff from the depot's
storm drain system. The sewage lagoons receive
treated wastewater from the depot's wastewater
treatment plant (Figure 1-3). The only
landscaped area is in the northwest corner near
Building 100. All other unpaved surfaces
contain weeds and grass, which historically have
been removed regularly with herbicides (types
and quantities were not recorded) and/or by
grading.
1.3 Meteorology
DDJC-Tracy has an average annual rainfall of
approximately 14 inches; over 90 percent of the
rain falls between November and April. Summer
temperatures commonly exceed 100 degrees
Fahrenheit (°F) during the day and drop to as
low as 60°F at night. Winter temperatures range
from 30 to 50°F. The average wind speed is
10 miles per hour and blows primarily from the
west in the summer and from the southeast in
the winter. Dense fog often forms at night
during the fall and winter.
1.4 Geology/Hydrology
1.4.1 The uppermost sedimentary deposits at
DDJC-Tracy consist of the Tulare Formation
and the overlying Quaternary alluvium
(Table 1-1). The top of the Tulare Formation is
eroded and overlain by essentially horizontal
sandy and gravelly Pleistocene and Recent
alluvium. The Tulare Formation is separated
into three roughly horizontal zones: the Lower
and Upper Tulare and the Corcoran Clay layers.
The relatively impermeable Corcoran Clay
separates (and forms an aquitard between) the
poorly sorted alluvial and fluvial sediments in
the Lower and Upper Tulare. The Upper Tulare
and Lower Tulare layers are primary sources of
fresh, inexpensive groundwater in the San
Joaquin Valley, so they will hereafter be called
the Upper Tulare and Lower Tulare aquifers
(Montgomery Watson, 1996a).
1.4.2 The Upper Tulare aquifer has been the
primary focus of remedial investigations. The
water table lies approximately 10 feet below
ground surface (bgs) in the northern portion of
the annex and 45 feet bgs in the southern corner
of the depot. The potentiometric surface (water
table elevation) slopes gently toward the north-
northeast. Generally, the average linear velocity
of groundwater in the aquifer is an estimated 15
to 500 ft/year toward the north-northeast. The
Upper Tulare Aquifer is approximately 200 feet
thick near Tracy and contains fresh water under
semi-confined and unconfmed conditions. Some
locally confined pockets exist.
SEC-i.DOC
1-1
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
1.5 Land and Water Use
1.5.1 The land surrounding DDJC-Tracy (and
the Tracy Annex) is used primarily for
agricultural purposes, including both irrigated
cropland and pasture for livestock grazing.
1.5.2 Common farming practices in these areas
include regular applications of fertilizers and
pesticides. Across Chrisman Road to the west,
there are five single family homes and a peach
orchard. Immediately east of the depot, two
major railroad lines intersect. The Northern
Pacific track runs along the northern boundary
of the operating portion of the site, and the
Union Pacific track runs along the southeastern
boundary. There are more orchards south of the
depot across the tracks, and land to the east is
designated for general industrial use. Some rural
residential developments exist within a three-
mile radius with small areas of commercial and
industrial land use (Figure 1-1).
1.5.3 The unincorporated areas of Tracy, the
unincorporated community of Banta, and other
rural neighborhoods are within a three-mile
radius of DDJC-Tracy. In many of these areas,
private wells and septic tanks provide drinking
water and sewage disposal, respectively. The
community of Banta, located two miles
nonheast of the site, includes an elementary
school, about 30 residences, and commercial
and industrial businesses. Another rural
residential development (Stoneridge) 2.5 miles
northeast of the site contains 60 residences.
1.5.4 At DDJC-Tracy, three water supply wells
provide all potable water, process water, and
fire water for the depot.
1.6 Cultural and Historic
Resources
Southern Pacific Railroad founded the city of
Tracy in 1878 and developed it as a
maintenance and supply facility for trains
moving to and from the San Francisco Bay area.
During the 1940s, agriculture slowly became the
primary industry, displacing rail transportation.
The oldest buildings at DDJC-Tracy were built
in 1942. During World War II, a German
prisoner of war (POW) camp existed in the
southern corner of the depot, but only written
records, including plan drawings, of this POW
camp remain. No building or location at the site
is being considered for the National Registry of
Historic Sites.
SEC-1.DOC
1-2
12 December 1997
-------
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Table 1-1. Defense
Depot San Joaquin-Tracy
Stratigraphic and Hydrostratigraphlc Nomenclature
Age Stratigraphic Units Description
Quaternary Alluvium
(Pleistocene &
Holoccnc) Holocenc fan and terrace deposits Unconsolidalcd clay.
sand, and gravel.
Levee deposits Unconsolidalcd sand.
soil, and gravel
Gravel quarry spoils and disturbed ground Gravel and sand.
Tertiary and Tulare Formation
Quaternary
(Piloccnc and
Pleistocene)
Upper Tulare Member Interceded gravel,
sand, sill, and clay.
Deposited in alluvial
and fluvial
environments.
Regional
Hydrostratigraphic Geologic
Zones Horizons
Above Upper Horizon
Upper Tulare Aquifer- Upper Horizon
Upper waterbearing zone;
contains water under
semiconfincd and
unconfincd conditions.
Upper/Middle Aquilard
Middle Horizon
Middle/Lower Aquitard
Horizon
Description Thickness
Fine-grained deposits from 0-35'
the ground surface to a
depth of 25 or 35 feel
below ground surface
Relatively coarse-grained 5'-35'
deposits found between
depths of 25 and 60 feel
below ground surface
Relatively fine-grained I0'-40'
deposits found at 50 to 70
feel below ground surface
Relatively coarse-grained 5'-30'
deposits found between
the depths of 55 and 85
feet below ground surface
in northern portions of the
depot and between the
depths of 75 and 115 feet
below ground surface in
southern portions of the
depot.
Relatively Pine-grained !5'-35'
deposits found at 85 to
1 1 5 feel below ground
surface
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Table 1-1
Age Stratigraphic Units Description
Tertiary and Tularc Formation
Quaternary (Continued)
(Pilocene and
Pleistocene)
(Continued)
Corcoran Clay Sandy, clay, silly clay.
Member sill, and clay
intcrbedded with fine-
grained sand.
Deposited in a
lacustrine
environment.
Lower Tularc Member Lenticular and
inicrfmgcring beds of
gravel, sand, and clay.
Deposited in alluvial
and fluvial
environments.
. (Continued)
Regional
Hydrostratlgraphlc Geologic
Zones Horizons
Lower Horizon
Geologic Unit below
Lower Horizon
Regional confining layer Corcoran Clay
between the up|>cr and lower
water-bearing zones.
Lower Tularc Aquilcr-Luwcr Lower Tularc
waicr-bcaring zone; contains
freshwater under confined
conditions to an estimated
depth of 490 feet below round
surface in the DUJC-Tracy
Area.
Horizon
Description Thickness
The top of these relatively 30'
coarse-grained deposits
ore found at 110 feel
below ground surface in
northern portions of the
depot and at 135 feet
below ground surface in
southern portions of the
depot.
Relatively fine-grained 50'-60'
deposits found below 170
feel below ground surface.
Found at 220 feel below 220'-250'
ground surface at the
depot.
Found at 430 feet to 500 301)'- 1 400'
feet below ground surface
at the depot.
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= DDJC-Tracy Property
= Light Industrial
= Residential
= Orchards
All other areas outside DDJC-Tracy
are Agricultural.
TRACY
ANNEX
»•••*•*
?«*•»*»
**•••*•
• •«•• ••
••*••••
*»*v« *•
••**•••
••»*•••
DEFENSE
*•*«. •*»•»*•••*•*»•»*••••»•••
^»«»«»•**•*»*»•*•»•»*»•
JOAQUIN
»••••!«••{•••••••••••»
•••«•••••*••••••••••••
••••••••»•••«•••••••••
SAN JOAQUIN *
«••••*. •• **_•*•••»•»*•••
•••*• ••• ^>*«* **••»*•
k»«»t* • !««.
'•••»•»•*•••••
••*•••
:*•**••••••
*•••••••••
v 0 1000 2000
SOURCE: USGS 7.5 Minute Topographic Map, Tracy. CA Quadrangle . - N
SCALE IN FEET
THACY\ROLT«1 -1 COB - VMG 12/5/97 SAC 1
Figure 1-1. Site Location, Defense Depot San Joaquin - Tracy Site
-------
MCf 1000
Figure 1-2.
Facility Map
Defence Depot San Jonquin • Tracy Site
-------
r
Consdidatad
Subsistence
Facility
Railroad Tracks
Fence Line
== Agricultural Area Dirt Access Road
[ ] Location of Surface Water Impoundment
Figure 1-3.
On-Site Surface Water
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson, 1996a
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
2.0 SITE HISTORY AND
ENFORCEMENT ACTIVITIES
The Defense Logistics Agency (DLA) has
operated Defense Depot San Joaquin (DDJC)-
Tracy since 1942. DDJC-Tracy is a storage and
distribution depot for various supplies common
to U.S. military services in the western U.S. and
throughout the Pacific. In late 1992, the DLA
purchased approximately 460 acres north of the
operating portion of DDJC-Tracy, called the
Tracy Annex.
2.1 Preliminary Environmental
Investigations. Records
Search, and Initial
Investigations
In early 1980, a records search by the U.S. Army
Toxic and Hazardous Materials Agency
(USATHAMA) first identified 25 waste sites
(solid waste management units [SWMUs], 1
through 23, 2A, and 10A) at DDJC-Tracy that
contained contaminants that could migrate to
off-depot locations (Figure 2-1). The study
concluded that past waste disposal practices
between 1940 and the mid-1970s—including the
use of burning sites, underground sumps/ tanks,
and unlined drainage and sewage leaching
ponds—caused the contamination. The available
information on geology and potential contami-
nant sources indicated a potential for
contaminants to migrate to the water table and
downgradient into the sand layers of the
uppermost aquifer (USATHAMA, 1980).
Because of the potential for contaminants to
migrate to groundwater, 12 monitoring wells
(LM001AU through LM012AU) were installed
in July 1980 and sampled for metals and general
water quality parameters (USATHAMA, 1980).
Additional analytical parameters (for example,
volatile organic compounds [VOCs]) were
included in subsequent sampling, and in May
1984, the Central Valley Regional Water Quality
Control Board (RWQCB) was advised that
trichloroethene (TCE) and tetrachloroethene
(PCE) concentrations in three monitoring wells
exceeded the California Department of Health
Services (DHS) action level of 5 micrograms per
liter (Hg/L). Ultimately, a remedial investigation/
feasibility study (RI/FS) was conducted to
address the groundwater plume (see
Section 2.2.1).
2.1.1 Soil Gas and Groundwater
Sampling
In 1985, Radian Corporation was contracted to
determine the following:
• Existence of any off-depot migration of
contaminated groundwater;
• Location of contaminant sources on the
depot; and
• Additional work required to assess the
environmental impacts of groundwater
contamination.
Radian identified six contaminant areas (Radian.
1986), which were later confirmed by
Woodward Clyde Consultants (WCC, 1992a).
These were Areas 1 through 6 (Figure 2-2).
Additional SWMUs were identified in a
Resource Conservation and Recovery Act
(RCRA) Assessment Report (U.S. EPA, 1990a).
Thirty-two active or inactive underground
storage tanks (USTs) were also identified during
environmental investigations (Figure 2-3).
2.1.2 Industrial Waste Lagoons and
IWPL Investigations
2.1.2.1 In October 1988 and January 1989,
before removing and disposing of industrial
waste, samples were collected from each of the
two lined industrial wastewater lagoons
(SWMU 3) (Canonic, 1989). Numerous metals,
including barium, chromium, copper, lead, and
zinc, were detected above Soluble Threshold
Limit Concentrations (STLCs) in the sludge
samples. Of those analyzed, the only organics
detected were chlordane from the sludge and
diazinon in the sludge and the liquid.
2.1.2.2 In 1991, Advanced Engineering and
Planning Corp., Inc. (AEPCO) conducted an
industrial process system assessment to identify
waste treatment and disposal operations,
processes, and techniques at the depot to
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DDJC-Tracy She-Wide Comprehensive Record of Decision
minimize waste generation and/or eliminate
compliance problems. During the associated
investigations, soil and water samples were
collected from the current wastewater
management system, the industrial waste
pipeline (IWPL), and the lined waste lagoons
(SWMU 3). Concentrations of heavy metals,
pesticides, and solvents exceeded regulatory
levels (AEPCO, 1991).
2.2 CERCLA Activities
In 1991, DDJC-Tracy was listed on the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
National Priorities List (NPL) as a Superfund
site. On 27 June 1991, DDJC-Tracy, the U.S.
EPA Region IX, and the California Department
of Toxic Substances Control (DTSC) signed a
Federal Facilities Agreement (FFA) for DDJC-
Tracy. This FFA has enforceable schedules and
ensures that environmental impacts from past
and present operations are thoroughly
investigated and that appropriate cleanup actions
are taken to protect human health, welfare, and
the environment. The U.S. EPA, DTSC, and the
RWQCB provide regulatory oversight consisting
of technical support, review, and comment on all
investigative work and cleanup work at DDJC-
Tracy. The following sites were identified as
potential threats to human health and the
environment:
• 36 SWMUs;
• 10 drum storage areas with soil
contamination;
• 28 UST sites;
• Contaminated groundwater associated with
Operable Unit (OU) 1;
• The Day Care Center; and
• Other areas with surface and near-surface
soil contamination.
Past practices at these sites are shown in
Table 2-1. The CERCLA process is summarized
in Figure 2-4.
2.2.1 Operable Unit 1 Remedial
Investigation/Feasibility Study
2.2.1.1 The contaminated groundwater within
the upper Tulare Formation was considered the
most pressing concern and was identified as
OU 1. The first phase of the DDJC-Tracy
CERCLA program focused on OU 1.
2.2.1.2 Between 1986 and 1992, WCC was
under contract to conduct an RI/FS at DDJC-
Tracy as required by CERCLA (and subsequent
Superfund Amendments and Reauthorization
Act [SARA] guidelines). In 1992, as a result of
the WCC investigation, the OU 1 plume was
identified as an area of contaminated
groundwater emanating from DDJC-Tracy. The
OU 1 plume affected groundwater both on and
off depot. Chemicals of concern (COCs)
included VOCs, pesticides, and potentially
metals; TCE and PCE were detected most
extensively in the groundwater.
2.2.1.3 The maximum TCE concentration in
the groundwater was 560 ug/L, and the
maximum PCE concentration was 410 M-g/L. The
TCE and PCE plumes are moving north-
northeast at approximately 80 and 40 ft/year,
respectively. During the OU 1 Remedial
Investigation/Risk Assessment (RI/RA), WCC
concluded that past solvent storage, handling,
and use practices at DDJC-Tracy led to TCE and
PCE contamination; however, specific source
areas were not identified.
2.2.1.4 The baseline human health risk
assessment (WCC, 1992b) found that the OU 1
plume posed insignificant risks to depot
personnel, off-depot agricultural workers, and
consumers of agricultural crops. The risk
assessment also found that residents
downgradient of the depot may have been at risk
because they used well water and were close to
the OU 1 groundwater plume. Unless remedial
action was taken, the risk for nearby residents
was expected to increase with time as
contaminants in groundwater continued to
migrate off site. The ecological risk assessment
concluded that the primary potential exposure
pathway for plants and animals from the OU 1
groundwater plume would be through flood
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
irrigation water supplied by the agricultural
wells located on the private property
immediately north of the depot.
2.2.1.5 The OU 1 Feasibility Study (FS)
(WCC, 1992c) included background information
used to develop and screen remedial
technologies for OU 1 groundwater
contamination. Remediation goals were health-
risk based. Water quality requirements were also
considered, especially for defining discharge
requirements. Several technologies for
groundwater treatment were evaluated based on
effectiveness, implementability, and relative
cost.
2.2.2 OU 1 Record of Decision
2.2.2.1 In August 1993, the final OU 1 Record
of Decision (ROD) (WCC, 1993) was signed.
The ROD stated that the OU 1 remedial action
would address "the principal threat posed by the
(groundwater contaminant) plume by
prioritizing action at OU 1 over any additional
cleanup associated with other potential sources
of contamination at the depot" (WCC, 1993).
The impact to a residential drinking water well
and the potential impact to a second residential
well by TCE and PCE were the principal threats
posed by the groundwater contamination. To
eliminate these threats and to protect human
health and the environment, the ROD prioritized
the remediation of TCE, PCE, and 1.1-
dichloroethene (1,1-DCE) in the groundwater.
Extraction wells were to be strategically
placed to:
• Remediate "hot spots" (the portions of the
plume with the highest concentrations);
• Minimize contaminant transport off depot;
and
• Minimize plume migration and clean up the
plume to the federal Maximum Contaminant
Levels (MCLs) for TCE and PCE and the
California MCL for 1,1-DCE (WCC. 1993).
2.2.2.2 As the OU 1 ROD describes, the
selected alternative was to extract, treat, and
reinject the contaminated groundwater. In
addition, the OU 1 ROD set aquifer cleanup
levels of 5 u,g/L for TCE and PCE and 6
for 1,1-DCE. The OU 1 ROD also specified
effluent treatment standards for carbon
tetrachloride, chloroform, 1,1-DCE, dieldnn,
PCE. TCE, and total VOCs (halogenated
hydrocarbons).
2.2.2.3 In addition to the effluent treatment
standards specified in the OU 1 ROD, the
RWQCB specifies effluent treatment standards
in a Waste Discharge Requirements (WDR)
permit based on the State Water Resources
Control Board (SWRCB) Resolution 92-49
("Policies and Procedures for Investigation and
Cleanup and Abatement of Discharge"). The
effluent treatment standards for several VOCs
and pesticides not included in the OU 1 ROD
were adopted into the OU 1 ROD through an
Explanation of Significant Difference (ESD)
(Montgomery Watson, 1995). An ESD is
required as documentation when significant
changes are made to the final ROD. The WDR
permit prescribes effluent standards for the
following compounds: carbon tetrachloride,
chloroform, total chromium, 1,1-DCE, PCE,
TCE, dieldrin, DDD, DDE, DDT. chlordane,
monuron. diuron, and total VOCs.
2.2.2.4 The OU 1 ESD also modified the
technology for removing VOCs from the aquifer
to include dispersion (encompassing metabolism
and volatilization). This modification resulted
from a comparative analysis of the most cost-
effective approaches for achieving ROD-
stipulated objectives while minimizing capture
of an off-site chloroform and carbon
tetrachloride plume and eliminating off-site
extraction facilities. This particular off-site
chloroform and carbon tetrachloride plume
appears to be emanating from an off-site source
(other than DDJC-Tracy); however, this ROD
does address additional chloroform
contamination attributed to the depot.
2.2.3 OU 1 Well Monitoring Program
The Well Monitoring Program (WMP), which
has been conducted at DDJC-Tracy since May
1991, provides complete and current
groundwater data from wells throughout the
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
depot and vicinity. These data allow seasonal
variations of groundwater levels to be evaluated:
t''e data also allow the nature and extent of
groundwater quality variations to be determined.
2.2.4 OU 1 Well Abandonment Program
Drinking water wells 1 (in Area 1) and 2 (near
SWMU 2) were previously abandoned to
eliminate exposure to contaminated groundwater
and to control contaminant migration. The OU 1
RI/FS also identified three agricultural supply
wells (AG-1, AG-2. and AG-3) that may have
served as conduits and created a vertical
hydraulic gradient for contaminants to migrate
downward. Eleven wells had a history of turbid
samples, were suspected of being damaged or
improperly installed, or had been dry for several
years. The OU 1 RI/FS recommended that these
wells be abandoned. The Filial Well
Abandonment Work Plan provides general
procedures for well abandonment (Montgomery
Watson, 1994a). Abandonment of the above
wells was completed from October 1994 to June
1995. The abandonment of the wells is
documented in the DDRW-Tracy Final Well
Abandonment Engineering Report (Montgomery
Watson, 1996f).
2.2.5 OU 1 Remedial Action
2.2.5.1 Starting in 1990, ENSOTECH, Inc.
installed the OU 1 interim remedial measure
(IRM) system. The IRM system controls the
migration of the contamination, reduces levels of
VOCs, and provides data to evaluate the
effectiveness and potential use of the selected
remedial technology for the full-scale design.
The system includes six extraction wells, an air
stripper, three injection wells, two piezometers,
and 10 monitoring wells (ENSOTECH, 1991).
Later, DDJC-Tracy expanded the IRM to
increase the influent flow from the contaminated
portion of the TCE and PCE plumes from
125 gallons per minute (gpm) to greater than
350 gpm, and constructed two infiltration
galleries (injection wells performed poorly) for
discharging treated water. The modified IRM
system will be integrated with the final full-scale
groundwater remediation system for OU 1.
2.2.5.2 The design of the full-scale OU 1
pump-and-treat system was completed in April
1996. The full-scale OU 1 groundwater
remediation system is presently being
constructed.
2.2.5.3 The full-scale system design includes
liquid-phase granular activated carbon (GAC)
wellhead treatment for removing pesticides at
existing extraction wells EW-2 and EW-5 to
comply with waste discharge requirements
(Montgomery Watson, 1996c).
2.2.6 Comprehensive Remedial
Investigation/Feasibility Study
2.2.6.1 The comprehensive Remedial
Investigation/Feasibility Study (RI/FS) report
reevaluated and reaffirmed the OU 1 ROD and
ESD and addresses all areas that were not
addressed as part of the OU 1 RI/FS.
Montgomery Watson performed the
Comprehensive Site-Wide RI/FS (Final RI/FS)
as part of the Department of Defense's
Installation Restoration Program (IRP). The
purpose of the Comprehensive RI/FS was to
investigate potential sources of environmental
contamination at DDJC-Tracy and to collect
data to support the following activities:
• The evaluation and selection of remedial
alternatives;
• The baseline human health risk assessment:
• The ecological assessment; and
• The design of the selected remedy.
2.2.6.2 The Comprehensive RI/FS at DDJC-
Tracy was conducted from 1993 through 1995
(Montgomery Watson, 1995a). The following
sites were investigated:
• OU 1;
• 66 sites;
- 28 SWMUs,
- 10 Soil Contamination Areas, and
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
- 28 UST sites;
• The Day Care Center; and
• Surface and near-surface soils
(Montgomery Watson, 1996a).
2.2.6.3 The history of waste disposal practices
at the SWMUs and other contaminated sites is
summarized in Table 2-1. Table 2-2 summarizes
the status of all sites investigated in the RJ/FS.
Table 2-3 summarizes the status of the UST
sites.
2.2.6.4 The following eight SWMUs were not
investigated in the comprehensive RI/FS
because they were recommended and approved
for no further remedial investigation in the Final
Comprehensive RI/FS Work Plan (WCC, 1992a;
Montgomery Watson, 1993):
• SWMU 2A, Sewage Treatment Plant;
• SWMU 13, Construction Material Landfill;
• SWMU 17, Active Wells;
• SWMU 18, Inactive Wells, properly
abandoned;
• SWMU 19, Aboveground Waste Tank;
• SWMU 26, Storage Area for Contaminated
Waste;
• SWMU 28, Phostoxin Waste Storage Area;
and
• SWMU 32, Pesticide Sinks.
2.2.6.5 Past practices and preliminary
screening indicated that these sites were not
sources of contamination (see Table 2-2).
2.2.7 Selection of Sites for Feasibility
Study
After the RI was completed, sites were selected
to proceed to the FS if concentrations detected at
the site indicated the presence of COCs. A COC
was identified on the basis of one of the
following criteria:
• Actual or potential threats to beneficial uses
of ground water or background water quality;
• Increased lifetime cancer risks (ILCR)
greater than IxlO'6 to installation
employees, construction workers, or
children on the installation;
• Noncancer health risks (or hazard indices)
greater than 1.0 to employees, construction
workers, or children on the installation; or
• Potential risks to ecological receptors.
2.2.8 Sites Studied for Feasibility of
Remedial Action
The sites recommended for the FS are divided
into three groups: A, B, and C. The rationale for
the grouping was:
• Group A: VOCs in the soil and soil gas at
these sites pose threats to groundwater;
• Group B: Multiple COCs at these sites pose
threats to groundwater or risks to human or
ecological receptors;
• Group C: These sites received or conveyed
industrial wastewater and have been
evaluated for a non-time-critical removal
action through an engineering
evaluation/cost analysis (EE/CA).
2.2.9 Sites Recommended for No
Further Action
2.2.9.1 Fifteen sites were recommended to
proceed to the FS based on a site-specific data
evaluation and a baseline risk assessment. If the
evaluation of the nature and extent, fate and
transport, and risk assessment indicated that a
COC at a site exceeded certain criteria, the site
was evaluated in the FS. Sites without COCs
meeting these criteria were recommended for no
further action (Table 2-2). Each of the following
criteria were used to identify the no further
action sites:
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
• No COCs pose actual or potential threats to
groundwater beneficial uses or exceed
background concentrations;
• No COCs pose an excess cancer risk greater
than 1x10 to depot workers, construction
workers, or children on the installation;
• No COCs have a noncancer hazard index
greater than 1.0 for depot workers,
construction workers, or children on the
installation; and
• There is no ecological risk.
2.2.9.2 The sites where no water quality site
assessment was performed are discussed in
Section 6.7. SWMU 10A was identified as a No
Further Action site, although vadose zone
modeling indicated a potential threat to
groundwater quality (see Table 7-15).
2.2.10 Day Care Center
2.2.10.1 The day care center (DCC), located in
the northwest portion of DDJC-Tracy, adjacent
to the main entrance on Chrisman Road, consists
of the DCC building and a fenced play yard
approximately 200 feet by 300 feet. The
temporary children's play area (TCPA), an
outside play area, is located north of Building
100, approximately a quarter mile north of the
DCC.
2.2.10.2 After site investigations by
Montgomery Watson from 1992 to 1995 and
Radian in 1996, it was determined that
contaminant levels detected in the soil at the
DCC posed a minimal health risk. Specifically,
they posed a potential cancer risk of 2xlO"5
(primarily from dieldrin) and a hazard index of
0.3 for children attending the DCC. The
compounds detected at the DCC included
polycyclic aromatic hydrocarbon (PAH)
compounds (at less than 10 parts per billion
[ppb]) and pesticides (above background
threshold levels). At one location, lead was
detected at a concentration of 20.3 parts per
million (ppm), which is above the background
threshold level of 14.8 ppm. Because the
pesticides at these levels had the long-term
potential to impact children, DDJC-Tracy
executed a time-critical removal action and
replaced the soil and playground pea gravel at
the DCC with new clean fill, sod, and pea
gravel. The public was notified concerning the
removal and an action memorandum was
prepared that documents the removal decision.
No action was performed at the TCPA because
the pesticide levels detected there were all below
the background threshold levels (Radian,
1996b).
2.2.11 Proposed Plan
A Final Proposed Plan was prepared to provide
information to the public about planned actions
at the sites listed above and to seek public input
prior to making final decisions. The proposed
plan for DDJC-Tracy presents remedial
alternatives and the preferred alternative for each
site with rationale for the selection
(Montgomery Watson, 1997a). The Remedial
Design/Remedial Action schedule to implement
the selected alternatives must be submitted
within 21 days after this ROD is signed.
2.3 Non-CERCLA investigations
Thirty-one of the 32 UST sites were included in
the comprehensive RI. All of these 31 UST sites
are inactive. The only UST site that was not
investigated in the RI was UST 16, which was
active. Twenty-eight sites were transferred out
of the RI to the Tri-Regional Guideline program
managed by the RWQCB. Three UST sites (8,
21, and 31) were maintained within the RI as
SWMUs 64, 6, and 24, respectively, because
nonfuel hydrocarbon compounds were identified
in the soil or groundwater near the three USTs.
These sites are all adjacent to SWMUs, The
remainder of the USTs are not subject to
CERCLA. Fifteen sites have been closed. Nine
other sites will be further characterized. The
other four will be remediated. Table 2-3 shows
the current status of the UST sites. Figure 2-3
shows the locations of the UST sites.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 2-1. Background of Solid Waste Management Units and Soil Areas
SWMU I/Area 2
SWMUs 2/3
SWMU 4
SWMUS
SWMU 6
SWMU 7
SWMUS
SWMU 9
SWMU 10
SWMU 10A
SWMU 11
SWMU 12
SWMU 14
SWMU 15
Old Sewage Lagoon and Former Drum Storage Area—This area was used as a drum storage
area from 1957 through 1984. Chemicals in drums possibly leaked or were discharged
accidentally.
Sewage (SWMU 2) and Former Industrial Waste Lagoons (SWMU 3)—The waste water
treatment plant has a permitted discharge to the sewage lagoons. SWMU 3 formerly
received discharge from the industrial waste pipeline (SWMU 33). The lagoons have been in
operation since 1942. Sometime between 1971 and 1979, industrial wastes from SWMU 3
overflowed into SWMU 2.
Storm Pond Lagoon—Storm water has been discharged to the lagoon since 1971. The storm
drain lagoon reportedly received rinse water from paint-stripping, degreasing, and steam
cleaning operations. The area was used for open storage before 1952. Manganese ore was
stockpiled northeast of the lagoon area from 1957 to 1968.
Old Industrial Lagoon, Building 255—The site was constructed by 1952. The lagoon
received rinse water from the paint-spraying and paint-stripping operations in Building 255.
The lagoon was enlarged in 1963 and existed until at least 1971.
Building 28 Sump—The sump operated from 1968 to 1977. A portion of Building 28 was
used for repackaging. Wastes from the repackaging operations collected in the sump. The
sump was initially abandoned in place and then removed in 1988. Former UST Site 21 was
also in this area.
Burn Pit No. 1—Site of seven former burn pits (Pits A-G) that were used between 1942 and
1954 to dispose of medical supplies, narcotics, pharmaceuticals, radiological supplies, and
electron tubes. The pits are partially or completely covered by Buildings 15, 19, and 21.
Burn Pit No. 2—A single large burn pit was operated between 1942 and 1971. Various
containers, crates, wooden pallets, trash, unknown liquids and solids, and narcotics were
burned in the pit. Explosions attributed to intermixing liquid chemicals or burning
pressurized containers were reported.
Subsistence Waste Pit—Subsistence waste, primarily food, was buried in the pit beginning
in 1947. Packaging materials were also buried.
Medical Waste Burial Pit—Former medical waste and burial pit. Outdated medical supplies,
narcotics, mercury compounds, and phosphate compounds were buried. The pit operated
from approximately 1949 until 1965. Since 1967, this area has been used for the storage of
truck trailers.
Possible Medical Waste Burial Pit—A former pit was reportedly used to bury medical
wastes. Possible trenches are visible in aerial photographs from 1945 to 1967.
Burial of Lime/Foot Bath—Site was reportedly used to dispose of lime materials associated
with lime foot baths. Area is currently covered with asphalt.
Embalming Fluid Dump—An unknown, but substantial quantity of embalming fluid
containing formaldehyde was buried just east of Building 30.
Lube Oil Dump—Reported site of a former lube oil dump. Reportedly 150 drums of new
lube oil were emptied into a trench in 1976. The trench was backfilled in 1976. Oil seepage
was visible in aerial photographs. A black viscous surface was reported by construction
workers in 1992.
Pesticide Waste Trench—Former pesticide waste trench from 1977 or 1978 until 1979.
Rodenticide, crushed cans that formerly contained pesticides, phosgene (or phostoxin)
slurry, and empty DDT containers may have been buried. Between 1979 and 1980, the
trench was excavated and the contents were disposed off site.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 2-1. (Continued)
SWMU 16
SWMU 20/23
SWMU 21
SWMU 22
SWMU 24
SWMU 25
SWMU 27
SWMU 29
SWMU 30
SWMU 31
SWMU 33
SWMU 64
Area 1 Building 236
Area 1 Building 237
Area 3
Building 15
Possible Waste Disposal Area—Possible waste disposal area from 1952 till 1967. Possible
wastes include asbestos, mercury, fluorescent bulbs, and medical supplies.
Aboveground Solvent Tank and Building 26 Recoup Operations—A 500-gallon
aboveground TCE degreasing unit was located inside Building 10. Building 10 was
constructed in 1950. According to warehouse plans, several cleaning facilities were used
between 1950 and 1974. A spray paint booth and cleaning operations were reportedly
connected to the Manhole W-l of the industrial wastewater pipeline (SWMU 33). A 2,000
gallon tank of No. 2 fuel oil was previously located at former UST Site 13. Building 26 was
used to repackage petroleum products. A wash rack was also present at this site.
Battery Acid Dump—Neutralized solution from the battery shop was discharged to the
ground and a sump behind Building 201.
Previous Hazardous Materials Storage Area—Former storage area from 1979 until 1985.
Leaking containers of hazardous materials (i.e., ammonium thiosulfate) were stored here
prior to repackaging or off-site disposal. The holding area was lined with bentonite clay.
Petroleum Waste Oil Tank—A 500-gallon tank stored petroleum wastes from the materials
testing in Building 247. The tank was used from 1961 until it was removed in 1988.
Boundary Roads—Waste motor oil may have been used as a dust suppressant in the 1940s
and 1050s. Most of the roads are presently paved.
Building 206 Roundhouse Sump, Building 206—Fluids used to clean locomotives were
reportedly drained into the sump. Pesticides were reportedly stored in Building 206. A
service pit in Building 206 may have been used to transfer fuel oil from UST Site 7 to the
boiler room.
Used Motor Oil Pit—Former motor disposal pit. Period of operation is uncertain.
Salvage Area—Former salvage area. No information regarding the types or volumes of
wastes is available.
Wood Preservation Area—Site was used for wood preservation operations from the mid-
1950s until 1960. Wood products were dipped into vats of phenolic compounds and carbolic
acid to prevent the wood from rotting. The vats were covered with canvas tarps. Spills from
the vats were reported.
Industrial Waste Pipeline (IWPL)—The IWPL was constructed in 1972. Discharges to the
IWPL included paint spray wastewater, phosphoric acid and sodium hydroxide from
strippers and rinse tanks, pesticide wastewaters, cleaning tank washwaters, steam cleaner
washwater, and acid washwater.
Waste Oil Pit—A 1,000-gallon metal tank that contained waste oils from the automotive
maintenance shop was located at this location. The tank was installed in 1975 and removed
in 1988.
Solvent Storage Area.
Former Solvent Storage Area—Now used for cleaning asphalt application tools and
equipment.
Drum Storage Area—Former drum storage area. Some drums may have leaked or spills may
have occurred.
Drum Storage Area—Petroleum hydrocarbons and metals wastes were previously stored at
this site. The site includes a concrete slab where materials are stored.
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Table 2-1. (Continued)
Building 22 Drum Storage Area—Site includes a paved area where materials are stored. Drums of
solvents may have been stored here in the past.
Building 23 Area is adjacent to several open storage areas. Previously called Containment Area 5.
Building 30 Drum Storage Area—Petroleum hydrocarbons and metals wastes were previously stored at
this site. Solvents may have been stored here. The site is partially covered by the
Consolidated Subsistence Facility (constructed in 1992).
Surface and Near This nonvegetated area of bare soil in the northern depot was used as a storage area for the
Surface Soils National Stockpile of Strategic Metals. From 1980 to 1986. lead ballast was stored here.
From shortly after World War II until the 1980s, ferrous chromium was stored in Quadrants
VII and VIII. Manganese ore was also stored here from shortly after World War II until the
1970s.
Day Care Center A 1,200-gallon UST containing No. 2 fuel oil was previously located at this site from 1956
until 1988. Pesticide contamination was also found in soil samples.
SEC-2.DOC 2-9 17 February 1998
-------
n
0
-
5
1
vD
•O
00
Table 2-2. Summary of Current Site Status, DDJC-Tracy
Nature and Extent
Impacted
Site Medium
Oil 1 Soil.
Gioundwjter:
Potential Chemicals of
Concern
VOCs. Pests. SVOCs. Melali
Fate and
Transport
Threat to
Groundwater
Quality
VOCs. I'cits
HHRA Highest
Potential Risk
Cancer Hazard
Risk Index
10' IO" >l»
-------
Table 2-2. (Continued)
Site
Solid Wusle
SWMU IDA
SWMU 1 1
SWMU 12
SWMU 13
SWMU 14
SWMU IS
SWMU 16
SWMU 17
SWMU 18
SWMU 19
SWMU 2tV
Nature and Extent
Impacted Potential Chemicals of
Medium Concern
Management Units (SWMUs) (Continued)
Soil: SVOCs. Mcials
Groundwalcr:
Soil: -•
Groundwalcr: NA
Soil: --
Groundwalcr:
Soil: -•
Groundwalcr:
Soil: SVOCs. TPH. Pests. Metals
Groundwatcr:
Soil: -
Groundwalcr:
Soil: -
Groundwalcr:
Soil: •-
Groundwaier:
Soil: -
Groundwalcr:
Soil: --
Groundwalcr
Soil: VOCs. SVOCs. Pests. Herbs.
Area 1 Bldg 10 Groundwalcr: TPI!l Melals
VOCs, Pests
Fate and
Transport
Threat to
Groundwater
Quality
SVOCs
N/A
None
N/A
N/A
None
None
None
N/A
N/A
N/A
N/A
N/A
N/A
VOCs. SVOCs,
Pests, Herbs,
TPII
i r ii
HHRA Highest
Potential Risk
Cancer
Risk
n
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CL
n
n
O
3
3
S"
a
VI
n
n
s
5.
a,
J?
r>
O
a
-------
Table 2-2. (Continued)
Site
Solid W:i*fc
SWMU 21
SWMU 22
SWMU 23
SWMU 24
SWMU 25
SWMU 26
SWMU 27/
Area 1
Building 206
SWMU 28
SWMU 29
SWMU 30
SWMU 31
Nature and Extent
Impacted Potential Chemicals of
Medium Concern
Muniiifcnivnt Units (SWIM Us) (Continued)
Soil: --
Groundwuicr: NA
Soil: -
Groundwaler:
Soil: --
Groundwaler:
Soil: VOCs. SVOCs. Pcsls. PCBs,
TPtl
Groundwaler
TPH
Soil: --
Groundwater:
Soil: -
Gruundwatcr:
Soil: VOCs. SVOCs. Pesls. PCBs.
Groundwaler: TPH. Meld,
..
Soil: ••
Groundwaler:
Soil: --
Groundwaler: NA
Soil: ••
Groundwaler:
Soil: ••
Groundwater:
Fate and
Transport
Threat to
Groundwater
Quality
None
None
None
VOCs. SVOCs.
Pcsls. PCBs.
TPH
N/A
N/A
N/A
VOCs. Pests.
TPH
N/A
N/A
N/A
None
None
HHRA
Highest
Potential Risk
Cancer
Risk
NC<
l* ^
NC1 '
N/A N/A
N/A N/A
>!' '
N/A N/A S
N/A N/A (RCRA
pcnnillcd
storage area.
No spills)
NC1 '
NC1 /
NC1 '
O
2
n
i?
X
C/l
f»
3?
n
P
3
a
n
3-
f»
a
s
R
o
Q.
O
D
R.
o'
-------
Table 2-2. (Continued)
Site
Solid Waste
SWMU 32
SWMU 33
SWMU 64
Nature and Extent
Impacted Potential Chemicals of
Medium Concern
Management Units (SWMUs) (Continued)
Soil: --
Groundwalcr:
Soil: VOCs. SVOCs. Pests. Herbs.
Groundwater. ™. Metal,
VOCs'. Pests
Soil: --
Groundwalcr:
Fate and
Transport
Threat to
Groundwater
Quality
N/A
N/A
VOCs. SVOCs.
Pests. TPH
N/A
HHRA Highest
Potential Risk
Recommended Recommended
Cancer Hazard Ecological Dropped for No Further for Early Evaluated
Risk Index Risks from Rl Action Action In FS
N/A N/A N/A /
N/A N/A N/A (Drains
plugged.
Drained to
SWMU 33)
•"•' >lw • '
NC1 NC1 '
Soil Contamination Areas
Area 1
Building 236
Area 1
Building 237
Area 3
Building 15
Drum Storage
Area
Building 22
Drum Storage
Area
Building 23
Building 30
Drum Storage
Area
Soil: --
Groundwater: NA
Soil: VOCs, SVOCs. Metals
Groundwalcr: VOCs
Soil: VOCs
Groundwalcr: VOCs
Soil: -
Groundwater NA
Soil: --
Groundwalvr:
Soil: ••
Groundwaler: NA
Soil: SVOCs
Groundwater: NA
N/A
VOCs
VOCs
None
None
None
SVOCs
NC* NC1 /
•clff4* >!' '
NC1 NC4 S
NC* NC* '
NC1 NC' '
!' /
NC1 NC* /
-------
Table 2-2. (Continued)
Nature and Extent
Impacted Potential Chemicals of
Site Medium Concern
Soil Contamination Areas (Continued)
Depot- Wide Soil: Metals. Pests
Surf and Near Croundwalcr: NA
Surf Soils
Olhtr Sites
Day Care Soil: Pesls. Herbs
CeM" Groundwalcr: NA
Notes:
' Depot worker as receptor with highest potential risk.
' Construction worker as receptor.
' Site is a suspected former source of VOCs.
Fate and HHRA Highest
Transport Potential Risk
Threat to Recommended Recommended
Groundwater Cancer Hazard Ecological Dropped for No Further for Early Evaluated
Quality Risk Index Risks from Rl Action Action In FS
None l' «'
N/A
-------
Table 2-3. Status of the UST Sites, DDJC-Tracy, Comprehensive
Number
Site of Tanks Removal
UST 1 1 1988
UST 2 1 1988
UST 3 1 e
UST 4 1 1973
UST 5 1 1988
UST 6 2 1988
UST 7 2 1988
UST 8 1 1988
UST 9 1 1988
UST 10 1 1989
UST II 1 1988
UST 12 1 1988
Number of
RI/FS
Phase 1
Borings
3
3
3
3
3
6
6
NA
3
6
3
2
Soil
Contaminants
ND
ND
ND
ND
ND
TI'H-G. UTEX.
EDO
TPII-D.
TPI1-MO
NA
ND
TI'II-D.UTEX
ND
ND
Findings
Groundwater Tank Location
Contaminants Not Found
ND
ND
ND
ND
ND
TI'H-0. BTEX
TPII-MO
TI'll-D, BTEX
NA
TPII-0 X
TI'II-D.UTLX
ND
ND
Regulated
Under Trl
Regional
Guidelines/
CERCLA
Tri-Rcgiona!
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
CERCLA
Tri-Regional
Guidelines
Tri-Rcgional
Guidelines
Tri-Rcgional
Guidelines
Tri-Regional
Guidelines
RI/FS and UST Site Investigations
Recommendations
No
Additional Removal Further
Characterization* Action/Remediation11 Action' Current Status
X Sile Closed1
X Sile Closed*
X Site Closed*
X Sile Closed*
X Sile Closed*
X X Additional
Investigation
Planned
Characterization
Complete11
Identified and
Investigated as
SWMU64
Characlcriution
Complete"
Characterization
Complete*
X Site Closed*
X Sile Closed*
-------
Table 2-3. (Continued)
Number
Site ol Tanks Removal
UST 13 1 1988
UST 14 1 1988
UST 15 1 1988
UST 16 1 NA
UST 17 1 1988
UST 18 1 1988
UST 19 1 1988
UST 20 1 1988
UST 21 1 1988
UST 22 1 1988
UST 23 2 1988
Number of
RI/FS
Phase 1
Borings
3
3
2
NA
3
3
3
3
NA
2
6
Sol)
Contaminants
TCE. Pest
TI'll-G. UTEX
ND
NA
1 TPH-D
TPH-D.
TPII-MO.
UTEX
TI'll-D, UTEX
TPH-D
NA
Toluene
Toluene, Xylcne
Findings
Regulated
Under Tri
Regional
Groundwater Tank Location Guidelines/
Contaminants Not Found CERCLA
TCA, TCE, Pest Tri-Regional
Guidelines
ND Tri -Regional
Guidelines
ND Tri -Regional
Guidelines
NA Tri-Regional
Guidelines
ND Tri-Regional
Guidelines
ND Tri-Rcgional
Guidelines
ND Tri-Regional
Guidelines
TI'IID X Tri-Rcgional
Guidelines
NA CERCLA
Nl) Tri-Rcgional
Guidelines
Nl) Tri-Rcgional
Guidelines
Recommendations
No
Additional Removal Further
Characterization* Action/Remediation* Action' Current Status
X* Continued
Investigation as
SWMU 20
X X Additional
Investigation
X Site Closed1
Active and
permitted UST
X Site Closed*
X X Additional
Investigation
X X Additional
Investigation
Characterization
Complete'
Identified and
investigated as
SWMU 6
X Site Closed1
X Site Closed1
O
O
n
1
3
o
^1
n
EL
n
n
o
3
"•j
3-
i
n
70
R
o
Q.
O
5
n
I?'
5'
-------
Table 2-3. (Continued)
Number
Site of Tanks
UST 24 1
UST 25 1
UST 20 1
UST 27 1
UST 28 1
UST 29 1
UST 30 1
UST 31 1
UST 32 1
Removal
19X8
1988
1988
1988
1988
1988
1988
1988
1988
Number of
Rl/FS
Phase 1
Borings
3
3
3
3
3
3
3
NA
4
Soil
Contaminants
TI'll-D
THII. UTEX
ND
TPH-D, Xylene,
TPH-MO
ND
NO
NO
NA
TPH-D.
Elhylbenzene
Findings
Groundwater Tank Location
Contaminants Not Found
TI'll-D
TPH-D,
Benzene
ND
Xylene
ND
ND
ND
NA
Toluene
Regulated
Under Trl
Regional
Guidelines/
CERCLA
Tri-Rcgional
Guidelines
Tri-Rcgional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
CERCLA
Tri-Regional
Guidelines
Recommendations
No
Additional Removal Further
Characterization* Action/Remediation" Action' Current Status
X X Additional
Investigation
X X Additional
Investigation
X Site Closed1
X X Additional
Investigation
X Site Closed*
X Site Closed1
X Site Closed1
Identified and
investigated as
SWMU 24
X Additional
Investigation
-------
Table 2-3. (Continued)
' Continue with characterization unilcr llic Tri-Rcgional Guidelines program.
b Removal uclion performed by Sacramento District USAGE under Prc-placcJ Remedial Action Contracts (PRAC). Sites requiring no further action under Tri-Kegional Guidelines will be coordinated with KWQCB for
closure.
' Nu further action necessary under the Tri Regional Guidelines program.
0 UST 13 Closure Kcpon submitted due to no evidence of fuel-related contamination However. non-fucl-rclatcd constituents will continue lo be investigated as SWMU 20, located adjacent to the former UST 13 site.
Additional sampling will be conducted along llic IWPL10 confirm that nearby diesel hits along the pipeline are not related to this UST.
' UST 3 was abandoned in place in 1972.
' Additional investigations were performed in 1995 and 1996. A detailed description of the results is provided in thermal UST Site Investigation Field Work Keparl (Radian. 1996c); potential remedial alternatives arc
currently being assessed.
1 Approved for closures by RWQCB (Letter from Karen Bessette dated IS Aug 1996)
b Natural attenuation is recommended at this site.
' Biovenling combined with natural attenuation is recommended at this site.
BTEX = benzene, toluene, elhylbenzcne, and xylcncs
CERCLA = Comprehensive Environmental Response. Compensation, and Liability Act
EDB = elhylcne dibromidc
IWPL = Industrial Waslcwatcr Pipeline
NA = not applicable
Nl) = not delected
Pest = pesticides
RWQCB = Regional Water Quality Control Board
SWMU = Solid Waste Management Unit
TCA = trichloroethanc
TCC = irichloroclhene
TI'll-U = total petroleum hydrocarbons as diesel
THII-G = total petroleum hydrocarbons as gasoline
TPII-MO = total petroleum hydrocarbons as motor oil
USAGE = U.S. Army Corps of Engineers
O
2
9
if
»<
V)
o.
n
O
I
•o
3
n
a
o
a.
VI
5'
-------
Depot :
Boundary I \
I / xX
i •'
iV^"
Railroad Tracks
Fence Line
Agricultural Area Dirt Access Road
n Approximate Location of Solid Waste
Management Unit (SWMU)
Locations of SWMU Monitoring Wells
•*• Sampled During the Phase I and
Phase II Rl
SWMU 33 Industrial Waste Pipeline
(IWPL)
Figure 2-1.
Solid Waste Management Units Investigated
During the Comprehensive RI/FS
Defense Distribution San Joaquin -
Tracy Site
Source. Montgomery Watson
-------
Sewage
- . Lagoons
Storm Drain
Lagoon
Northern
Depot
Soils
100; -"•• Area 1
1UU i *• " "ic** 't ATQo 1, I
: Bldg. 206 ^Bfdg-237
a •'
x Area 2V" v
Day Care '
c ... Center
—
D' —
Bldg.236 t-
cc
c
r — i i
I I
.. •_• -• ••. -• -.4 . =... __.—^.. ; : " "'•.-.. "\
i [-iArca-1 r '-':- '- " x, . Area 3\
U8ldg iu I Drum Storage Area, ' xx /N
-- .;.] LjBdg.15 j^_, "•'';,"--X
:i il-; If : i i ;
1/1
: 01
J ra
$2
Jtr>
IB.
15
iittisi:
i i^nr
Depot- : i
Boundary j "
:J1S I
1T28
23QBIdg.23
.;' 5
§5 ';'•
Jf> •
11
16
16
I
1 Drum Storage
Area. Bldg. 22
19
21 ; :. 22
;:l ; f
i
]
; 9 '. "•! 12 t i 13
t;
20
r ~
_ 'J) [ "1 12 [ j 13 j ! 14
. nl I1 Drum Storage Area.
J: Bldg. 30
17
" Consolidated
\ Subsistence^
• Facility
EXPLANATION
Railroad Tracks
i 30
29
= Agricultural Area Dirt Access Road
n Approximate Location of Possible Soil Contamination or Drum
Storage Area Identified by WCC in the Comprehensive RI/PS
Work Plan
Work Plan
Approximate Location of Day Care Center
Investigation During the Baseline Risk Assessment
Figure 2-2.
-------
_ "~ . . j Sewage
^- ^. J Lagoons
/ Storm Dram ''V » .--v.
USJ4 ./ Lagoon J* -
1100 i ;-'^. ! 1
UST 3 ' . .• ..-.-^u.-
* (• '•• .UST 7 '
O ; UST 6 ^
-pj-— -------- - - _oB UST27' ,.
USTi12a UST 22
'
' - UST 2 : _3 •
,.| . rbr1 _ll .UST.15 -.~i-_^_. _ ^^.-.UST-ZS^.:-
, ----- -•-• .=^ ___ - ~_*T-"lf " ' ' '
III,
\
, V;
! i I- .
t ::
UST 1
f
ti
12 I I 13
I UST 20
UST 28 \ |l :
UST 30
J I .
I '
19 '.21
UST 32
22 j
UST1
UST 23 I
EXPLANATION
' Consolidated [ \
.Subsistence -
| Faabty -
UST 11
Railroad Tracks
Fence Line
= Agricultural Area Dirt Access Road
• Approximate Location of Former
Underground Storage Tank (UST) Site
Figure 2-3.
Approximate Locations of Underground
Storage Tank Sites Investigated
During the Comprehensive RI/FS
Defense Depot San Joaquin - Tracy Site
Source. Montgomery Watson. 1996a
-------
Operable Unit 1 identified as I „
the principal threat (1 992) P""
1 *
Tracy Placed on National
Priorities List as a "Superrund"
Site (1991)
1
initia, Remedial Investigation |-* R?™^
OU,FS(1992) | Wi±SffiST
J
OUI ROD August, 1993 1
I
i
EE/CA Process
1 *
OUI Remedial Design
April, 1996
|
EE/CA for SWMUs
2,3, and 33 (1996)
\ \
OUI Full-Scale System
Construction (1997)
Action Memorandum
{
Design Removal Action
Implement
Removal Action
|
Document Final Decision
in Comprehensive Record
of Decision
1
i
Yes ^-" Do
|J2^-""^ the site
^^.^remova
'
es^^^~-~^^
justify a ~^~>
I action^^^^^
, No
Comprehensive
RI/FS Process
Develop rerr
objectives a
the ability of a
to meet tries
.
'
ledial action
nd evaluate
II alternatives
e objectives
•
Comprehensive RI/FS
and Proposed Plan
November, 1996
Prepare Remedial Design and
Implement Remedial Action
Annual Assessment of
Containment and Capture
in Well Monitoring Annual
Report
T
5 year Review
TBACWROOIZ-4.FH5.VMG I2W97
Figure 2-4. CERCLA Process
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
3.0 HIGHLIGHTS OF COMMUNITY
PARTICIPATION
3.1 A Proposed Plan summarizing the
alternatives considered in the DDJC-Tracy
Comprehensive Remedial Investigation/
Feasibility Study (RI/FS) was released in
November 1996 and was made available to the
public in the Administrative Record located at
DDJC-Tracy's Environmental Protection
Division, Building S-108 Sharpe Facility,
Lathrop, California, and in the Information
Repository maintained at the same address. The
Proposed Plan was also mailed to the
installation's 1,200-address mailing list on
31 January 1997. The 30-day public comment
period on the Proposed Plan ran from
5 February to 6 March 1997. A Public Notice
appeared on 4, 14, and 18 February 1997 in the
Tracy Press, and on 4, 16, and 18 February in
the Stockton Record to announce the Proposed
Plan's public comment period and to invite the
community to attend a public meeting held on
19 February 1997, at the City of Tracy
Community Center, Tracy, California. Comment
responses are provided in the Responsiveness
Summary.
3.2 The 19 February public meeting was held
to answer the community's questions about the
Proposed Plan and to solicit public input on the
selected remedial alternatives presented in the
Proposed Plan. Meeting attendees are listed in
Table 3-1.
3.3 The document was made available to the
public in the Administrative Record located at
DDJC-Tracy's Environmental Protection
Division, Building S-108 Sharpe Facility,
Lathrop, California, and in the Information
Repository maintained at the same address.
3.4 The DDJC-Tracy ROD and the related
Proposed Plan are based on the site's
Administrative Record and were developed in
accordance with applicable federal and state
laws, regulations and codes, including 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 Contingency
Plan (NCP).
SEC-3.DOC
3-1
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 3-1. DDJC-Tracy Public Meeting* Attendees
Name
Affiliation
Art Dohrman
Bruce Whisenant
John Crow
Mike Eisenzimmer
Steve Glover
Steve Light
Capt. Casey
Col. Melton
Doug Imberi
Fred Green
John S. Green
RoxanneYonn
John Guzman
Peter Kalush
Victoria Shankel
Wes Harris
Bruce McCarry
Jim Pinasco
Karen Bessette
Michael Work
Deborah Hirsch
JeffHerrin
Graham Sharpe
Rob Owens
Rose Newman
John Lamb
Bert Heffner
Donald Springer
Glenn Robertson
Jeff Stewart
Marjorie Hannon
Phil Martin
Robert Raspo
Stephen Reid
U.S. Army Corps of Engineers (CEHNC-ED-CS-G)
U.S. Army Corps of Engineers (CEHNC-ED-CS-P)
U.S. Army Corps of Engineers (CEHNC-ED-ME-H)
U.S. Army Corps of Engineers (CEHNC-ED-ME-E)
U.S. Army Corps of Engineers (CEHNC-ED-CS-P)
U.S. Army Corps of Engineers (CEHNC-PM-ED)
DDJC
DDJC
DDJC
DDJC
DDJC
DDJC
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Office of Counsel
CAL EPA (DTSC)
CAL EPA (RWQCB)
US EPA, Region DC
Radian International
Radian International
Radian International
CAL EPA (DTSC)
Lawrence Livermore National Laboratory
Remedial Resources/Prime Environmental
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
1 Meeting held on 19 February 1997
SEC-3.DOC
3-2
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
4.0 SCOPE AND ROLE OF THE
RESPONSE ACTION
4.1 As with many Superfund sites, the
environmental issues at Defense Depot San
Joaquin (DDJC)-Tracy are complex. As a result,
DDJC-Tracy organized the environmental
response program into two phases. Operable
Unit (OU) 1 was defined in the first phase as the
contaminated groundwater within the Upper
Tulare Formation, both on- and off-depot, that is
emanating from DDJC-Tracy. The OU 1
contamination was addressed first because the
concerns associated with OU 1 were considered
the most urgent. Remedies have already been
selected for OU 1 (see Section 2) , and the
Record of Decision (ROD) (WCC, 1993) for
this operable unit was signed in August 1993. A
pump-and-treat system has been installed to
treat groundwater. The expanded OU 1
treatment system will begin operation in the first
quarter of 1998.
4.2 This ROD is the second phase of the
DDJC-Tracy environmental response program
and addresses all of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA) issues. This ROD will
serve as the Final Remedial Action Plan for
DDJC-Tracy.
4.3 All contaminated media at the depot are
addressed in this ROD. The objectives of this
comprehensive ROD are as follows:
• Reaffirm or modify as appropriate the
selected remedy from the OU 1 ROD. The
OU 1 ROD specifically indicated that all
groundwater chemicals of concern and
pathways would be reevaluated in the
Comprehensive RJ/FS (OU 1 ROD,
Section 4.2.2) and that the feasibility of a
more stringent aquifer cleanup standard
would be evaluated (OU 1 ROD,
Section 4.2.4).
• Address the sites of soil/vadose zone
contamination identified in the comprehen-
sive remedial investigation program (see
Table 2-1).
• Document the selected remedial actions and
document that they are protective of human
health and the environment.
4.4 The sites addressed in this ROD are
identified in Table 2-1. Each of the Solid Waste
Management Units (SWMUs) and soil areas
was investigated for potential surface and near-
surface soil contamination. Impacts to
groundwater from these sites were identified
and evaluated through monitoring and modeling.
A risk assessment was also performed to
identify threats to human health and ecological
receptors. This ROD identifies the sites selected
for no further action (NFA) and selects remedies
for the remainder of the sites. By addressing all
contaminated media, this ROD completes the
identification of appropriate remedies for
DDJC-Tracy.
SEC-4.DOC
4-1
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.0 SUMMARY OF SITE
CHARACTERISTICS
5.1 Background
5.1.1 Several phases of Remedial Investigation/
Feasibility Study (RI/FS) have been conducted
at DDJC-Tracy. The results of these RI/FSs
have been reported in the following:
• Operable Unit 1 Field Sampling Report
DDRW-Tracy, California (Woodward-
Clyde Consultants, 1992)
• DDRW-Tracy, California, Final
Comprehensive Site Wide RI/FS: Phase I
Site Characterization Report (Montgomery
Watson, 1994b).
• DDRW-Tracy Draft Comprehensive RI/FS:
Phase II Technical Memorandum
(Montgomery Watson, 1995a).
• DDRW-Tracy, California: Final
Comprehensive Remedial Investigation/
Feasibility Study, Vols. I and II
(Montgomery Watson, 1996a).
5.1.2 The goals of the Comprehensive RI/FS
were to identify and investigate potential
sources of contamination at DDJC-Tracy and to
collect data to support the evaluation and
selection of remedial alternatives, the baseline
risk assessment (BRA), the ecological risk
assessment (ERA), and the design of the
selected remedies (Montgomery Watson,
1996a). The RI/FSs were comprehensive in that
these goals were met. A summary of the human
health risks may be found in Sections 6.1
through 6.5, and a summary of the ecological
risks may be found in Section 6.6.
5.1.3 The remainder of this section presents
summaries of the sites investigated at DDJC-
Tracy. Section 5.2 presents a site characteriza-
tion summary of the contaminants in the
Operable Unit (OU) 1 groundwater at DDJC-
Tracy. Section 5.3 introduces the site
characterization summaries of the contaminants
in the soil at DDJC-Tracy. Sections 5.4, 5.5, 5.6,
and 5.7 present brief summaries of the Group A
sites, the Group B sites, the Group C sites, and
the No Further Action sites, respectively.
Section 5.8 presents the Time Critical Removal
Action Site.
5.1.4 Soil, groundwater, sediment, and surface
water are present at DDJC-Tracy. Soils at the
depot consist of shale-pebble conglomerates of
the Tulare Formation and the overlying
Quaternary alluvium. The Tulare Formation,
which composes most of the geologic column at
DDJC-Tracy, has been divided into the Above
Upper, the Upper, the Middle, and the Lower
Horizons.
5.1.5 The Above Upper Horizon is the
uppermost 25 to 35 feet of clays, silts, silty
sand, and clayey sand. This interval is saturated
only from the northern portion of the depot to
the central portion of the annex. The Upper
Horizon is a coarse-grained interval (predomi-
nantly sand and gravel, with lenses of silt, silty
sand, and clay) ranging between the depths of
approximately 25 to 60 feet below ground
surface (bgs). The Middle Horizon is another
coarse-grained interval (silty sand, sand, and
gravel) separated from the Upper Horizon by the
Upper/Middle Aquitard. The Middle Horizon
occurs in the depth interval between approxi-
mately 55 to 85 feet bgs. The top of the Lower
Horizon occurs at a depth of approximately
110 feet bgs and consists primarily of sand and
gravel. Fine-grained materials are present at a
depth of approximately 170 feet bgs. Surface
water and sediment occur locally at DDJC-
Tracy only as part of the storm drain lagoon
(SWMU 4) and the sewage and former
industrial waste lagoons (SWMUs 2/3).
5.1.6 Each of the media present at DDJC-Tracy
(soil, groundwater, sediment, and surface water)
has been impacted by contaminants originating
from past practices at the depot. The
contaminants of concern (COCs) were identified
using the following criteria:
• The concentration of the COC in the
groundwater exceeds the criteria for
beneficial uses of groundwater or
background groundwater quality;
SEC-5.DOC
5-1
17 February 1998
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DDJC-Tracy She-Wide Comprehensive Record of Decision
• The concentration of the COC in the surface
water, sediment, or soil has the potential to
exceed the criteria for beneficial uses of
groundwater or background groundwater
quality as indicated by the fate and transport
(F&T) modeling conducted as part of a
water quality site assessment (WQSA); or
• The COC exceeds the risk criteria for either
human or ecological receptors.
5.2 Groundwater
5.2.1 The groundwater at DDJC-Tracy has
been impacted by a variety of contaminants. The
primary classes of groundwater COCs are
volatile organic compounds (VOCs), pesticides,
and herbicides. Contaminated groundwater is
present in plumes, several of which are
migrating off site to the north. Operable Unit 1
was designated in 1992 as a separate entity from
the soil and shallower contaminants so that the
OU 1 groundwater contamination could be
addressed before soil problems. The final OU 1
Record of Decision (ROD) (WCC, 1993) was
signed in August 1993.
5.2.2 Operable Unit 1 is defined as the
contaminated groundwater plume, on and off
depot, that is emanating from DDJC-Tracy. This
plume is primarily characterized by
tetrachloroethene (PCE) and trichloroethane
(TCE). The distribution of these two
contaminants is shown in Figures 5-1 and 5-2.
The identified sources of VOCs to the
groundwater are:
• SWMU I/Area 2;
• SWMU 6;
• SWMU 8 (possible);
• SWMU 20 and Area 1 Building 10;
• SWMU 33;
• Area 1 Building 237; and
• Area 3.
5.2.3 The selected remedy for OU 1 is
groundwater extraction and treatment.
Groundwater is being extracted from the Upper,
Middle, and Lower Horizons. Extracted
groundwater is being treated by air stripping.
The groundwater from two wells is also being
treated using liquid-phase granular activated
carbon (GAC) to remove pesticides. Treated
groundwater is being reinjected into the Upper
Tulare Formation using infiltration galleries. A
small portion of the plume is being allowed to
attenuate naturally as described in the
Memorandum of Significant Differences, dated
20 December 1995.
5.2.4 The OU 1 ROD established cleanup
levels of maximum contaminant levels (MCLs)
for TCE, PCE, and 1,1-DCE. Other VOCs
detected in groundwater, including bromoform,
carbon disulfide, cis-l,2-DCE, trans-1,2-DCE,
methylene chloride, benzene, toluene, and
xylenes, have been detected only sporadically
and at low concentrations, so cleanup levels
were not established for them.
5.2.5 Chloroform has also been detected
sporadically in groundwater in a group of
installation monitoring wells (LM003A,
LM030AU, LM101 A, and LM094AU) and two
off-depot wells (LM055B and LM056C). The
maximum detected concentration of chloroform
is 16 Hg/L. The probable source of chloroform
is the transformation of chlorine from the
wastewater treatment plant or potable water
leaked from water mains at the facility. The
locations of the wells where chloroform was
detected are too far to the west and across
gradient to be attributed to off-site sources.
However, these sporadic detections do not
constitute a plume that requires additional
cleanup limits in the OU 1 remedy. The
concentrations of chloroform will continue to be
monitored as part of the ongoing Groundwater
Monitoring Program at DDJC-Tracy.
5.2.6 The occurrence of chloroform, bromo-
dichloromethane, and dibromochloromethane
concentrations in LM003AA and the
"disappearance" of consistently detected TCE
and PCE in the fourth quarter 1996 sample
suggest that treated water was the "source" of
contamination at that location. All of the
chloroform occurrences have been downgradient
from SWMU 2 and SWMU 3, which have
SEC-5.DOC
5-2
17Februaiy 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
received chlorinated effluent from the waste-
water treatment plant for a number of years.
5.2.7 A separate discussion of a remedy for
chloroform is not necessary in this document
because:
• There is no defined chloroform plume
associated with depot activities;
• Chloroform concentrations are less than
10% of the California Action Level for
trihalomethanes in drinking water supplies;
and
• All chloroform concentrations have been
reported within the outer boundaries of
Upper, Middle, or Lower Horizon TCE
plumes.
5.2.8 Pesticides and herbicides have been
detected in OU 1 groundwater. Detected
contaminants include dieldrin, chlordane, DDD,
DDE, DDT, monuron, and diuron. These
contaminants have primarily been identified in
the northwestern portion of the depot. The
primary sources of these contaminants to the
groundwater are the sewage and industrial waste
lagoons, burn pit No. 2 (SWMU 8), and the
industrial waste pipeline (SWMU 33).
Figure 5-3 shows the distribution of dieldrin in
groundwater. A dieldrin plume can be observed
to emanate from the sewage and industrial waste
lagoons (SWMUs 2 and 3). The other pesticides
and herbicides do not display a geographic
distribution that can be characterized as a
plume.
5.3 Soil
5.3.1 The soil at many of the sites at DDJC-
Tracy has been contaminated by past activities
at the installation. The primary classes of
contaminants in the soil include VOCs (also
identified in soil gas), semivolatile organic
compounds (SVOCs), and pesticides. Metals
and SVOCs are minor contaminants in the soil.
For the most part, COCs in the soil are those
with the potential to exceed the criteria for
beneficial uses of groundwater or background
groundwater quality—primarily VOCs, and
pesticides but also occasional SVOCs.
5.3.2 Sections 5.4 through 5.7 present brief site
characterization summaries (SCSs) of the results
of the RIs at each of the sites at DDJC-Tracy.
These sections summarize the Final
Comprehensive Remedial Investigation/
Feasibility Study Vols. I and JJ (Montgomery
Watson, I996a). The SCSs present information
that was relevant to the decision about whether
or not to include a site in the FS. The SCSs
present the following data:
• A brief summary of the past activities at a
site that may have caused contaminants to
be released to the environment;
• A brief summary of RI/FS activities
conducted at a site;
• A tabulation of those contaminants that
were identified as COCs based on the
criteria presented in Section 5.2. The
tabulation includes a presentation of the
criteria exceeded (e.g., risk to human health,
threat to beneficial uses of groundwater);
• The identification of the criteria exceeded;
and
• The calculated volume of contaminated soil
and the mass of the contaminants in the soil
at that site.
5.3.3 Soil volume and contaminant mass data
were generated by averaging the concentrations
of contaminants in each affected area and
multiplying the average concentration by the
soil volumes provided in the RI/FS. These
calculations are presented in a table in each SCS
in Section 5.4, 5.5, and 5.6.
5.3.4 Section 5.4 comprises the SCSs for the
Group A sites, the sites where a potential threat
to groundwater exists because of the presence of
VOC contamination in the soil. Section 5.5
comprises the SCSs for the Group B sites and
other sites with soil contamination. Section 5.6
comprises the SCSs for the Group C sites, the
sites associated with past and present DDJC-
Tracy industrial waste systems that were
evaluated in an Engineering Evaluation/Cost
Analysis. Section 5.7 comprises the SCSs for
the sites recommended for No Further Action.
SEC-5.DOC
5-3
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.4 Group A
5.4.1 SWMU 1/Area 2—Old Sewage
Lagoon/Drum Storage Area (Group A)
5.4.1.1 Volatile organic compounds and PCBs have
contaminated soil as the result of past site activities.
SWMU 1 and Area 2 were a source of TCE and PCE to
groundwater. SWMU 1 and Area 2 were evaluated
together because of their geographic proximity. Table 5-
1 summarizes those contaminants that pose a risk to
either the groundwater or human/ecological receptors.
Table 5-2 summarizes the volume and mass of the
contaminants in the soil at this site. Figures B-l, B-2, B-
3, and B-4 show sampling locations and analytical
results from SWMU I/Area 2. This combined site was
evaluated in the FS because groundwater was impacted.
This site also poses a potential future threat to beneficial
uses of groundwater and background groundwater
quality because the contaminants have the potential to
migrate to groundwater. In addition, the soil poses a
potential risk to depot workers.
** \ Location of
swMT,\ SWMU 1, Area 2
Area 2 N
\
5IS&*
Site Characteristics
Past Site Activities
SWMU 1 - Old Sewage Lagoon
• Sanitary sewage effluent was discharged to the lagoon until 1942.
• Lagoons were abandoned and backfilled in 1944.
• Site is the reported location of old sewage lagoons.
• Site is the reported location of a former Area 2 Drum Storage Area.
• Chemicals stored in drums possibly leaked or were discharged accidentally.
• Area 2 was used from 1957 until 1984.
RI/FS Activities
• Site investigation activities at SWMU I/Area 2 included soil gas surveys, soil sampling, well
installation, and groundwater monitoring.
• A WQSA, a fate and transport (F&T) analysis, and a BRA were performed for SWMU I/Area 2.
Summaries of the WQSA and the BRA are presented in Section 6.0.
SEC-5.DOC
5-4
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Conclusions
• SWMU I/Area 2 was a source of PCE to the OU 1 groundwater plume.
• Contaminant F&T modeling indicated that PCE in the soil is a potential ongoing threat to beneficial
uses of groundwater and to background groundwater. F&T modeling also indicated that TCE in the
soil gas is a potential future threat to beneficial uses of groundwater and to background groundwater
quality.
• F&T modeling indicated that Aroclor 1260 may be a potential future threat to beneficial uses of
groundwater; however, Aroclor 1260 was detected in only one soil sample.
Table 5-1. Summary of Fate and Transport and Risk Data for SWMU 1/Area 2
Impacted
Medium
Soil
Threat to
Beneficial Uses of
Groundwater
VOCs (TCE, PCE),
potentially PCBs
(Aroclor 1260)
Threat to
Background
Groundwater Quality
VOCs (TCE, PCE)
Cancer
Risk
IxlO"5 depot
worker
Hazard
Index
<1 construction
worker
Ecological
Risks
None
Table 5-2. Estimated Volume and Mass of COCs in Soil for SWMU 1/Area 2
Volume of Impacted Soil (yd )
Mass of COCs (pounds)
39,000
PCE: 3.2
TCE: 1.7
SEC-5.DOC
5-5
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Area 1
Building 237 x
Location of
Area 1, Building 237
\
i /
I SWMU rSs ffv=,;:i
' ," i* ij- '£»«.>;']
i
5.4.2 Area 1 Building 237 (Group A)
5.4.2.1 Tetrachloroethene (PCE) has contaminated soil
as the result of past site activities. Area 1 Building 237
was a source of PCE to groundwater. Table 5-3 summar-
izes the risk of PCE to groundwater and human and
ecological receptors. Table 5-4 summarizes the volume
and mass of the contaminants in the soil at the site.
Figure B-5 shows sampling locations and analytical
results from Area 1 Building 237. This site was
evaluated in the FS because groundwater was impacted
by past site activities. This site also poses a potential
future threat to groundwater.
Site Characteristics
Past Site Activities
• Area is north of Building 237. Site is also close to
UST 12 and SWMU 33.
• Site is used for cleaning asphalt tools and equipment.
• Solvents were formerly used and stored in this area.
• Site is covered with gravel and asphalt.
RI/FS Activities
• Site investigation activities at Area 1 Building 237 included soil gas surveys, soil sampling, and
groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for Area 1 Building 237. Summaries of the
WQSA and the BRA are presented in Section 6.0.
Conclusions
• Area 1 Building 237 is a source of PCE to the OU 1 groundwater plume.
• Contaminant F&T modeling indicated that PCE in the soil is a potential ongoing threat to beneficial
uses of groundwater and to background groundwater quality.
• Compounds other than PCE were detected in soil, soil gas, and groundwater. However, none
exceeded risk criteria or represented a potential or actual threat to beneficial uses of groundwater or
background groundwater quality. Thus, these compounds are not considered COCs.
SEC-5.DOC
5-6
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-3. Summary of Fate and Transport and Risk Data for Area 1 Building 237
Threat to Beneficial
Uses of Groundwater
VOCs (PCE)
Threat to Background
Groundwater Quality
VOCs (PCE)
Cancer Risk
1 x 1 0'4 * construction
worker
Hazard Index
<1 construction
worker
Ecological
Risks
None
Table 5-4. Estimated Volume and Mass of COCs in Soil for Area 1 Building 237
Volume of Impacted Soil (yd )
Mass of COCs (pounds)
8,300
PCE: 6.3
SEC-5.DOC
5-7
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
\
Area 3
Drum Storage
Location of .
Area 3, Drum Storage
.
»
^
5.4.3 Area 3—Drum Storage Area (Group A)
5.4.3.1 Trichoroethene (TCE) and PCE have
contaminated soil as the result of past site activities.
Area 3 is potentially a continuing source of these
contaminants to groundwater. Table 5-5 summarizes
those contaminants that pose a risk to either the
groundwater or to human/ ecological receptors. Table 5-
6 summarizes the volume and mass of the contaminants
in the soil at this site. Figures B-6 and B-7 show
sampling locations and analytical results from Area 3.
This site was evaluated in the FS because groundwater
was impacted. This site also poses a potential future
threat to groundwater quality.
Site Characteristics
Past Site Activities
• Site was used as a drum storage area.
• Stored drums may have leaked or accidentally spilled.
• Site is covered with asphalt.
• No other sites are near Area 3.
RI/FS Activities
• Site investigation activities at Area 3 included soil-gas surveys, soil sampling, and groundwater
monitoring.
• An F&T analysis and a BRA were performed for Area 3. A summary of the BRA is presented in
Section 6.0.
Conclusions
• Area 3 is a source of PCE and TCE to the OU 1 groundwater plume.
• Contaminant F&T modeling indicated that PCE and TCE in the soil represent a potential ongoing
threat to beneficial uses of groundwater and to background groundwater quality.
SEC-5.DOC
5-8
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-5. Summary of Fate and Transport and Risk Data for Area 3
Impacted
Medium
Soil
Threat to
Beneficial Uses
of Groundwater
VOCs (PCE, TCE)
Threat to Background
Groundwater Quality
VOCs (PCE, TCE)
Cancer Risk
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5 Group B
5.5.1 SWMU 4—Storm Drain Lagoon (Group B)
5.5.1.1 Semivolatile compounds, pesticides, herbicides,
and metals have contaminated surface sediment as the
result of past site activities. Pesticides (simazine, diuron,
monuron, and dieldrin) may have contaminated
groundwater (see analysis in Appendix C). Surface
water and sediment pose a potential threat to ecological
receptors. Table 5-7 summarizes those contaminants that
pose a risk to either the groundwater or human/
ecological receptors. Monitoring data suggest that the
model has overestimated the threat to groundwater
quality from this site. Table 5-8 summarizes the volume
and mass of the contaminants in the soil at this site. .
Figures B-8, B-9, and B-10 show sampling locations and
analytical results from SWMU 4. Soil/sediment and
surface water pose a potential risk to ecological
receptors.
I i..-jf
I SWMU 4
I
I
\
Location of
SWMU 4
\
X
X
Site Characteristics
Past Site Activities
• Storm water from DDJC-Tracy has accumulated in the storm drain lagoon since 1971.
• The storm drain lagoon is unlined and bounded by soil berms that are approximately 6 feet high.
• The storm drain lagoon contains water nearly year-round, and waterfowl inhabit the area.
• The storm drain lagoon reportedly received rinse water from paint-stripping, degreasing, and steam-
cleaning operations.
• This area was used for open storage before 1952.
• A stockpile of manganese ore was located northeast of the lagoon area from 1957 to 1968.
RI/FS Activities
• Site investigation activities at SWMU 4 included a soil-gas survey, surface water and sediment
sampling, soil sampling, and groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were conducted for SWMU 4. A summary of the WQSA and
BRA are presented in Section 6.0.
Conclusions
• Dichlorodifluoromethane, chloromethane, and toluene in groundwater are part of the OU 1
groundwater plume; SWMU 4 is not a source of these compounds.
SEC-5.DOC
5-10
17 Febniary 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
The pesticides and herbicides simazine, diuron, monuron, and dieldrin cannot be clearly attributed to
SWMU4.
Contaminant F&T modeling indicated that the pesticides and herbicides carbaryl, carbofuran,
chlordane, 2,4-D, and dieldrin in soil or sediment pose a potential future threat to groundwater.
Monitoring data (see Appendix C) indicate that an impact is unlikely.
F&T modeling indicated that the SVOCs bis(2-ethylhexyl)phthalate, fluoranthene, phenanthrene, and
pyrene in soil or sediment pose a potential future threat to groundwater. Monitoring data (see
Appendix C) indicate that an impact is unlikely.
The compounds DDD, DDE, and DDT in soil, sediment, or surface water pose a potential risk to
ecological receptors. The estimated risk for the metals zinc and selenium in soil or sediment are
above the benchmark level for ecological receptors; however, these risks are considered conservative
because of the biases in the analytical data.
Compounds other than those listed above were detected in soil, sediment, surface water, or
groundwater; however, none exceeded the risk criteria or represented a potential or actual threat to
beneficial uses of groundwater or background groundwater quality. Thus, these compounds are not
considered COCs.
SEC-5.DOC 5-11 17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-7. Summary of
Impacted
Medium
Soil
Surface Water
* See Appendix C
" Not calculated.
Threat to
Beneficial Uses of
Groundwater
None'
None*
Fate and Transport and
Threat to Background
Groundwater Quality
Risk Data
Cancer
Risk
None1 < IxlO"6
depot
worker
None1
NC"
for SWMU
Hazard
Index
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.2 SWMU 6—Building 28 Sump (Group B)
5.5.2.1 As the result of past site activities, pesticides
and herbicides have contaminated soil. Lindane
(a pesticide) has been released to groundwater, and
SWMU 6 is probably a former source of TCE and PCE
to groundwater. Table 5-9 summarizes those contami-
nants that pose a potential threat to the groundwater at
SWMU 6. Table 5-10 summarizes the volume and mass
of the contaminants in the soil at this site. Figure B-l 1
shows sampling locations and analytical results for
SWMU 6. This site was evaluated in the FS because
groundwater was impacted and because contaminants in
the soil pose a potential future threat to groundwater.
Site Characteristics
Past Site Activities
• This site is the former location of UST 21 and a
250-gallon concrete sump.
\
SWMU 6
Location of
SWMU 6
'
• A portion of Building 28 was used for repackaging.
• Wastes from repackaging were collected in the sump.
• The sump operated from approximately 1968 to 1977.
• The sump was initially abandoned in place; it was removed in 1988.
RI/FS Activities
• Site investigation activities at SWMU 6 included soil sampling, a soil gas survey, and groundwater
monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 6. Summaries of the WQSA and
the BRA are presented in Section 6.0.
Conclusions
• SWMU 6 was a source of PCE and TCE to the OU 1 groundwater plume.
• The pesticide lindane has impacted groundwater at SWMU 6.
• Contaminant F&T modeling indicated that the pesticides and herbicides dicamba, dieldrin, endrin,
heptachlor, lindane, and 2,4,5-T in the soil pose a potential future threat to groundwater.
SEC-5.DOC
5-13
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-9. Summary of Fate and Transport and Risk Data for SWMU 6
Impacted
Medium
Soil
Threat to Beneficial
Uses of Groundwater'
Pesticides and herbicides
(dicamba, dieldrin,
heptachlor, lindane)
Threat to Background
Groundwater Quality
Pesticides and herbicides
(dicamba, dieldrin, endrin,
heptachlor, iindane, 2,4,5-T)
Cancer
Risk
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.3 SWMU 7—Burn Pit No. 1 (Group B)
5.5.3.1 As the result of past site activities, VOCs,
SVOCs, pesticides, herbicides, dioxins/furans, and
petroleum hydrocarbons have contaminated soil.
Dioxins/furans were found to be extremely immobile in
the analytical leaching model and have not been
detected in groundwater to date. SVOCs (bis[2-
ethylhexyl]phthalate) and pesticides (octachlorocioxin)
may have been released to groundwater. Table 5-11
summarizes those contaminants that pose a threat to
groundwater at SWMU 7. Table 5-12 summarizes the
volume and mass of the contaminants in the soil at this
site. Figures B-12 and B-13 show sampling locations
and analytical results for SWMU 7. This site was
evaluated in the FS because groundwater was impacted
and because the contaminants in the soil pose a potential
future threat to groundwater.
Site Characteristics
Past Site Activities
Location of
SWMU 7
o
\
SWMU 7'
• SWMU 7 is the site of seven pits (Pits A-G) now partially or completely beneath Buildings 15, 19,
and 21.
• The pits may have been up to 16 feet deep.
• The pits were reportedly used between 1942 and 1954 for disposing of medical supplies containing
mercury and phosphate compounds, narcotics, Pharmaceuticals, radiological supplies, and electron
tubes.
• Solids and liquids stored or used at the depot may have been buried or burned in the pits.
RI/FS Activities
• Site investigation activities at SWMU 7 included a geophysical survey, soil gas surveys,
radionuclide, screening, soil sampling, trenching, monitoring well installation, and groundwater
monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for this site. Summaries of the WQSA and
the BRA are presented in Section 6.0.
Conclusions
• Groundwater has been impacted by bis(2-ethylhexyl)phthalate and octachlorocioxin.
• Contaminant F&T modeling indicated that contaminants in the soil pose a potential future threat to
groundwater. These contaminants are:
SEC-5.DOC
5-15
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Pit F: VOCs (1,2-DCE, TCE)
Pit C: SVOCs (bis[2 ethylhexyl]phthalate)
Pesticides and herbicides (dieldrin, linuron)
Pit D: Pesticides and herbicides (2,4-D, dieldrin, linuron, simazine)
Petroleum hydrocarbons (TPH-diesel)
Table 5-11. Summary of Fate and Transport and Risk Data for SWMU 7
Impacted
Medium
Threat to
Beneficial Uses of
Groundwater
Threat to
Background Cancer Hazard Ecological
Groundwater Quality Risk Index Risks
Soil Pit F: VOCs (1,2-DCE,
TCE)
Pit C: Pesticides and
herbicides (dieldrin,
linuron)
Pit D: Pesticides and
herbicides (dieldrin,
linuron, simazine),
petroleum
hydrocarbons (TPH as
diesel)
Pit F: VOCs (1,2-DCE,
TCE)
Pit C: Pesticides and
herbicides (dieldrin,
linuron), SVOCs (bis[2-
ethylhexy!]phthalate)
Pit D: Pesticides and
herbicides (2,4-D,
dieldrin, linuron,
simazine), petroleum
hydrocarbons (TPH as
diesel)
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
h^
i " \ Location of
I s \ SWMU 8
i >•
i \
1 \
1 SWMU 8 i
If \
' '
\ '
\
\
\ '
\ s
1 /
V'
x
-^SOlwu::--* : ::!-!t: •:.;-
^^^-^s r-r-'v/
•^S-S-^ -\ v / • • • ' • *' •'•
« ;'1-'^^sV4i»''-vs .'&'-'•'.'.* W'.*
V^s Xv"-> \ •-.'•-•-; \^'-. t- ••'
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%f ^*! Jt.nr. sloin5jAr«.
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-
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ILH...V - ^f
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5.5.4 SWMU 8—Burn Pit No. 2 (Group B)
5.5.4.1 Semivolatile organic compounds (SVOCs),
pesticides and herbicides, dioxins/furans, and petroleum
hydrocarbons have contaminated soils as the result of
past site practices. Dioxins/furans are present in soil just
above groundwater, but the toxicity equivalent value in
groundwater was extremely low (about 10"7 ug/L) and
two orders of magnitude below the federal MCL for
2,3,7,8-tetrachlorodibenzo-p-dioxin. Pesticides
(chlordane, DDD, DDE, and DDT) have been released
to groundwater, and SWMU 8 is probably a former
source of VOCs (PCE and TCE) to groundwater. Table
5-13 summarizes those contaminants that pose a
potential threat to the groundwater and a potential risk to
construction workers at SWMU 8. Table 5-14
summarizes the volume and mass of the contaminants in
the soil at the site. Figures B-14, B-15, and B-16 show
sampling locations and analytical results for SWMU 8.
This site was evaluated in the FS because groundwater
was impacted, because contaminants in the soil pose a
potential future threat to groundwater, and because
contaminants in the soil pose a potential risk to
construction workers.
Site Characteristics
Past Site Activities
• SWMU 8 is a single large bum pit that reportedly operated between 1942 and 1971.
• Various containers, crates, wooden pallets, trash, unknown solids and liquids, and narcotics were
bumed in the pit.
• Explosions, attributed to intermixing liquid chemicals or burning pressurized containers, were
reported (in interviews) as common in the bum pit.
RI/FS Activities
• Site investigation activities at SWMU 8 included geophysical surveys, soil-gas surveys, soil
sampling, radionuclide screening, trenching, monitoring well installation, and groundwater
monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for this site. Summaries of the WQSA and
the BRA are provided in Section 6.0.
Conclusions
• SWMU 8 is a possible source of PCE and TCE to the OU 1 groundwater plume.
SEC-5.DOC
5-17
HFebniaiy 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
• Groundwater at SWMU 8 has also been adversely impacted by the pesticides chlordane, ODD, DDE,
and DDT.
• Contaminant F&T modeling indicated that the contaminants bis(2-ethylhexyl)phthalate,
diethylphthalate, 2,4-dinitrotoluene, naphthalene, chlordane, 2,4-D, DDD, DDE, DDT, dieldrin,
lindane, linuron, MCPA, simazine, TPH as gasoline, TPH as diesel, and TPH as motor oil in the soil
pose a potential future threat to groundwater.
• The contaminants dieldrin, DDD, and DDE also pose a potential risk to construction workers at the
site.
Table 5-13. Summary of Fate and Transport and Risk Data for SWMU 8
Impacted
Medium
Soil
Threat to Beneficial
Uses of Groundwater
SVOCs
(2,4-dinitrotoluene,
naphthalene)'
Threat to Background
Groundwater Quality
SVOCs
(bis[2-ethylhexyl]phthalate,
diethylphthalate,
2,4-dinitroutoIuene,
naphthalene)'
Cancer Risk
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.5 SWMU 20: Aboveground Solvent Tank
and Area 1 Building 10 (Group B)
5.5.5.1 Volatile organic compounds (VOCs), SVOCs,
pesticides and herbicides, and petroleum hydrocarbons
have contaminated soil as the result of past site
activities. PCE, TCE, and various pesticides and
herbicides (monuron, diuron, alpha-BHC, methiocarb,
and 2,4-D) may have contaminated groundwater. Table
5-15 summarizes those contaminants that pose a threat
to groundwater at SWMU 20. Table 5-16 summarizes
the volume and mass of the contaminants in the soil at
this site. Figures B-17 and B-18 show sampling
locations and analytical results for SWMU 20. This site
was evaluated in the FS because groundwater was
impacted and because contaminants in the soil pose a
potential future threat to groundwater.
Site Characteristics
Past Site Activities
SWMU 20 - Aboveground Solvent Tank
\
Location of
SWMU 20
SWMU 20
\
i! ii:ti \ - ii .=}• Mh-*^
i: r
• SWMU 20 included a 500-gallon aboveground solvent (TCE) degreasing unit located inside
Building 10.
• Building 10 was constructed in 1950. According to warehouse plans, several cleaning facilities were
used at various times from 1950 to 1974.
• A spray paint booth and cleaning operations were reportedly connected to a sump (Manhole W-l of
the IWPL [SWMU 33]).
• UST Site 13 is close to SWMU 20. This site reportedly contained a 2,000-gallon No. 2 fuel oil tank,
which was removed in 1987.
RI/FS Activities
• Site investigation activities at SWMU 20 included soil-gas surveys, soil sampling, sump sampling,
pipeline inspection, monitoring well installation, and groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 20. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Conclusions
• SWMU 20 was a source of TCE and PCE to the OU 1 groundwater plume.
• Groundwater has also been impacted by monuron, diuron, alpha-BHC, methiocarb, and 2,4-D.
SEC-5.DOC
5-19
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
• Contaminant fate and transport modeling indicated that TCE, ethylbenzene, xylenes,
diethylphthalate, 2,4-dinitrophenol, pentachlorophenol, 2,4,6-trichlorophenol, dieldrin, methiocarb,
MCPA, linuron, and TPH-diesel in soil pose a potential future threat to groundwater.
Table 5-15. Summary of Fate and Transport and Risk Data for SWMU 20
Impacted Threat to Beneficial Threat to Background Hazard Ecological
Medium Uses of Groundwater Groundwater Quality Cancer Risk Index Risks
Soil
VOCs (TCE)
VOCs (TCE,
ethylbenzene, xylenes)
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.6 SWMU 24—Petroleum Waste Oil Tank
(Group B)
5.5.6.1 Volatile organic compounds (VOCs), SVOCs,
pesticides, PCBs, and petroleum hydrocarbons have
contaminated soil as the result of past site activities.
TPH as gasoline may have been released to the
groundwater at SWMU 24. Table 5-17 summarizes
those contaminants that pose a threat to groundwater or
a risk to human receptors. Table 5-18 summarizes the
volume and mass of the contaminants in the soil at this
site. Figure B-19 shows sampling locations and
analytical results for SWMU 24. This site was evaluated
in the FS because contaminants in the soil pose a
potential future threat to groundwater and because there
is a potential risk to future depot workers.
Site Characteristics
Past Site Activities
• A 500-gallon underground steel tank stored
petroleum wastes from materials testing in Building 247.
\
Location of
SWMU 24
SWMU 24
v
• The tank was used from 1961 until it was removed in 1988.
• A visual inspection conducted during tank removal revealed pin holes in the base of the tank.
RI/FS Activities
• Site investigation activities at SWMU 24 included soil sampling, monitoring well installation,
groundwater monitoring, and air monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 24. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Conclusions
• SWMU 24 is located within the OU 1 groundwater plume; however, it is not a source of
contaminants to OU 1.
• TPH as gasoline may have been released to groundwater; however, its extent is extremely limited.
• The contaminants acetone, 2-butanone, ethylbenzene, 2-hexanone, 4-methyl-2-pentanone, toluene,
xylenes, 2,4-dimethylphenol, fluoranthene, 2-methylnaphthalene, 4-methylphenol, naphthalene,
phananthrene, phenol, pyrene, TPH-gasoline, TPH-diesel, PCBs (Aroclor -1260), carbofuran,
lindane, phorate, and ronnel in the soil pose a potential future threat to groundwater.
• There is a potential risk to future depot workers from manganese.
SEC-5.DOC
5-21
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-17. Summary of Fate and Transport and Risk Data for SWMU 24
Impacted
Medium
Threat to
Beneficial Uses of
Groundwater
Threat to Background Cancer Hazard Ecological
Groundwater Quality Risk Index Risks
Soil VOCs (Acetone, 2-
butanone,
ethylbenzene, 2-
hexanone, toluene,
xylenes)
SVOCs (2,4-
dimethylphenol,
2-melhylnaphthalene,
4-meihylphenol,
naphthalene,
phenanthrene,
phenol, pyrene)
Pesticides and PCBs
(Aroclor 1260,
carbofuran, lindane,
phorate)
Petroleum
hydrocarbons (TPH
as diesel, TPH as
gasoline)
VOCs (Acetone, 2-bulanone,
ethylbenzene, 2-hexanone, 4-
methyl-2-pentanone [MIBK],
toluene, xylenes)
SVOCs (2,4-dimethylphenol,
fluoranthene, 2-
methylnaphthalene, 4-
methylphenol, naphthalene,
phenanthrene, phenol, pyrene)
Pesticides and PCBs (Aroclor
1260, carbofuran, lindane,
phorate, ronnel)
Petroleum hydrocarbons
(TPH as diesel, TPH as
gasoline)
< IxlO'6
construction
worker
10 future
depot worker
(manganese)
None
Table 5-18. Estimated Volume and Mass of COCs in Soil for SWMU 24
Volume of Impacted Soil (ydj)
Mass of COCs (pounds)
244
SVOCs: 0.2
VOCs: 205
TPH: 545
Pesticides/PCBs: 0.1
SEC-5.DOC
5-22
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.7 SWMU 27—Building 206 Roundhouse
Sump/Area 1 Building 206 (Group B)
5.5.7.1 Volatile organic compounds (VOCs), SVOCs,
herbicides. PCBs, and petroleum hydrocarbons have
contaminated soil as the result of past site activities.
Groundwater has not been impacted. VOCs, herbicides,
and petroleum hydrocarbons pose a potential threat to
the beneficial uses of groundwater and the background
groundwater quality. Table 5-19 summarizes those
contaminants that pose a potential threat to the
groundwater at SWMU 27 or a potential risk to human
receptors. Table 5-20 summarizes the volume and mass
of the contaminants in the soil at this site. Figures B-20,
B-21, and B-22 show sampling locations and analytical
results for SWMU 27. This site was evaluated in the FS
because contaminants in the soil pose a potential threat
to groundwater and because there is a potential risk to
depot workers.
Site Characteristics
SWMU 27
\
Location of
SWMU 27
\
I X
•TN^
' — I "*''^>v '-*• •<->>'• •—•~—~-=^
•* I -.-i -Vi: i-,.,,.,,'.
"ISllB^1*--\tiEi'-'-i":-=.
•Sli
Past Site Activities
• SWMU 27 includes the waste oil sump for the Area 1 Building 206 railroad roundhouse.
• Aerial photographs indicate that Building 206 existed in 1945.
• Fluids from cleaning the exteriors of locomotives reportedly drained into the sump.
• Pesticides were reportedly applied inside Building 206.
• A service pit in Building 206 may have been used to transfer fuel oil from UST Site 7 to the boiler
room located in Building 206.
RI/FS Activities
• Site investigation activities at SWMU 27 included soil sampling, sludge sampling, monitoring well
installation, and groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 27. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Conclusions
• Contaminant F&T modeling indicated that the compounds TCE, benzo(a)pyrene, total PAHs, 2,4-D,
MCPA, PCBs (Aroclor 1260), 2,4,5-T, and TPH as motor oil in the soil pose a potential future threat
to groundwater.
• The compounds benzo(a)pyrene and PCBs (Aroclor 1260) pose a potential risk to depot workers.
SEC-5.DOC
5-23
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-19. Summary of Fate and Transport and Risk Data for
SWMU 27 and Area 1 Building 206
Impacted
Medium
Soil
Threat to Beneficial Threat to
Uses of Background
Groundwater Groundwater Quality
VOCs (TCE)
Cancer
Risk
3x10"" depot
worker
(benzo[a],
pyrene, total
PAHs, and
PCBs)
Ecological
Hazard Index Risks
> I depot None
worker
Herbicides (MCPA)
Herbicides (2,4-D,
MCPA, 2,4,5-T)
Petroleum Petroleum hydrocarbons
hydrocarbons (TPH as (TPH as motor oil)
motor oil)
Table 5-20. Estimated Volume and Mass of COCs in Soil for
SWMU 27 and Area 1 Building 206
Volume of Impacted Soil (yd )
Mass of COCs (pounds)
130
SVOCs: 10.5
TPH: 1,512
Herbicides: 0.6
SEC-5.DOC
5-24
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.8 Building 30 Drum Storage Area
(Group B)
5.5.8.1 Semivolatile organic compounds (SVOCs) have
contaminated soil as the result of past site activities.
These compounds pose a potential threat to the
beneficial uses of groundwater and the background
groundwater quality; however, groundwater is not
currently impacted. Table 5-21 summarizes those
contaminants in soil that pose a potential threat to
groundwater at the Building 30 Drum Storage Area.
Table 5-22 summarizes the volume and mass of the
contaminants in the soil at this site. Figure B-23 shows
sampling locations and analytical results for Building 30
Drum Storage Area. This site was evaluated in the FS
because contaminants in the soil pose a potential threat
to groundwater.
Site Characteristics
Past Site Activities
Location of
\ Drum Storage Area,
Building 30
Drum
1 Storage
| Area
'
;h
. .<._Jj
y Drum Storage^j- -£•
Area — "^*
30
• The site is partially covered by the Consolidated
Subsistence Facility (which was constructed in 1992) and is located in the southern portion of DDJC-
Tracy.
• Solvents were reportedly stored in drum storage areas at DDJC-Tracy.
• The site history indicates that petroleum hydrocarbons or metal-containing wastes were stored at
Building 30.
Rl/FS Activities
• Site investigation activities at the Building 30 Drum Storage Area included soil sampling. No
groundwater samples were collected at this site.
• An F&T analysis and a BRA were performed for this site. A summary of the results of the BRA is
presented in Section 6.0.
Conclusions
• Contaminant F&T modeling indicated that the compounds benzyl alcohol, bis(2-ethylhexyl)
phthalate, diethylphthalate, and di-n-butylphthalate in the soil pose a potential future threat to
groundwater.
SEC-5.DOC
5-25
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-21. Summary of Fate and Transport and Risk Data for
Building 30 Drum Storage Area
Threat to Background Cancer Hazard Ecological
Groundwater Quality Risk Index Risks
Impacted Threat to Beneficial
Medium Uses of Groundwater
Soil SVOCs (bis[2-ethylhexylj
phthalate, di-n-
butylphthalate)
SVOGs (benzyl alcohol,
bis[2-ethylhexyl]phthalate,
dieihylphthalate,
di-n-butylphthalate)
depot
worker
<1 'depot
worker
None
1 Site does not contribute to overall risk levels for the exposure unit.
Table 5-22. Estimated Volume and Mass of COCs in Soil for
Building 30 Drum Storage Area
Volume of Impacted Soil (yd )
Mass of COCs (pounds)
2,780
SVOCs: 311
SEC-5.DOC
5-26
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.5.9 Surface and Near-Surface Soils—
Northern Depot Area (Group B)
5.5.9.1 Pesticides and metals have contaminated soils
as the result of past site activities. Table 5-23
summarizes those contaminants that pose a potential
threat to human receptors. Table 5-24 summarizes the
volume and mass of the contaminants at this site.
Figures B-24 and B-25 show sampling locations and
analytical results for the Northern Depot soils. This site
was evaluated in the FS because of the potential risk to
human receptors.
Site Characteristics
Past Site Activities
• The northern depot is a nonvegetated area of bare
soil.
• The site was reportedly used as a storage area for
the National Stockpile of Strategic Metals.
• From 1980 to 1986, lead ballast was stored in this area.
x
| surface and \
Near Surface Soil.
Location of
Surface and
Northern Depot Area
"i
Surface and
Near Surface
• From shortly after World War II until the 1980s, ferrous chromium ore was stored in Quadrants Vn
andVm.
• From shortly after World War n until the 1970s, manganese ore was also stored in this area.
RI/FS Activities
• Site investigation activities in the Northern Depot Area included soil sampling (surface and near
surface) and respirable dust level measurements.
• An F&T analysis and a BRA were conducted for this site. A summary of the BRA is presented in
Section 6.0.
Conclusions
• Contaminant F&T modeling indicated that none of the contaminants in the soil poses a potential
threat to groundwater.
• The metals arsenic and manganese pose a potential risk to a grader operator.
• The pesticides and herbicides DDD, DDE, DDT, chlordane, dieldrin, endrin, and lindane were
detected in the soil at concentrations that exceeded established background threshold levels;
however, none of the concentrations exceeded the risk criteria or posed a potential future risk to
groundwater.
SEC-5.DOC
5-27
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-23. Summary of Fate and Transport and Risk Data for Northern Depot Soils
Impacted
Medium
Soil
Threat to
Beneficial Uses
of Groundwater
None
Threat to
Background
Groundwater Quality
None
Cancer Risk
1 grader
operator (arsenic
and manganese)
Ecological
Risks
None
Table 5-24. Estimated Volume and Mass of COCs in Soil for Northern Depot Area
Volume of Impacted Soil (yd3)
Mass of COCs (pounds)
60,820
Metals: 62,827
SEC-5.DOC
5-28
17 February 1998
-------
DDJC-Tracyjite-Wide Comprehensive Record of Decision
5.6 Group C
5.6.1 SWMU 2—Sewage Lagoons and SWMU
3—Industrial Waste Lagoons
SWMU 2
Location o(
SWMU 2
\
5.6.1.1 SWMU 2 and SWMU 3 were investigated
concurrently. SVOCs, pesticides and herbicides, and
metals have contaminated soil as the result of past site
activities. Pesticides and herbicides are also present in
surface water. In addition, pesticides and herbicides
(dieldrin, monuron, diuron, aldrin, chlordane, 2,4-D,
ODD, DDE, DDT, delta-BHC, endosulfan, sulfate,
endrin, heptachlor epoxide, linuron, and simazene) have
been released to groundwater; VOCs in groundwater are
part of the OU 1 plume. Both soil and surface water
pose a threat to ecological receptors. Table 5-25
summarizes those contaminants that pose a risk either to
the groundwater or to human/ecological receptors at
SWMU 2. Table 5-26 summarizes those contaminants
that pose a risk to either the groundwater or
human/ecological receptors at SWMU 3. Table 5-27
summarizes the volume and mass of the contaminants in -—-^—
the soil at SWMU 2 and SWMU 3. Figures B-26, B-27,
and B-28 show sampling locations and analytical results from SWMU 2 and SWMU 3. These sites were
evaluated in the FS because groundwater was impacted, because these sites pose a future potential threat
to groundwater, there is also a potential risk to ecological receptors from soil, sediment, and surface
water.
Site Characteristics of SWMU 2
Past Site Activities
• The site consists of two active sewage lagoons that have been in operation since 1942.
• The lagoons are unlined and bounded by earthen berms.
• The northern lagoon supports abundant vegetation and animal life; this lagoon is cleared annually,
sometimes by burning. The southern lagoon contains grassy vegetation and reeds.
• The lagoons currently receive treated effluent discharged from the sewage treatment plant.
• The lagoons previously received effluent from the motor pool wash rack.
• Sometime between 1971 and 1979 industrial wastes from SWMU 3 (Industrial Waste Lagoons)
overflowed into the southern lagoon of SWMU 2.
RI/FS Activities
• Site investigation activities at SWMU 2 included soil/sediment sampling, surface water sampling,
evaluation of hexavalent chromium in soils, well installation, and groundwater monitoring.
SEC-5.DOC
5-29
17 Febroaiy 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
• A WQSA, an F&T analysis, and a BRA were performed for SWMUs 2 and 3. Summaries of the
WQSA and the BRA are presented in Section 6.0.
Conclusions
• PCE and TCE detected in groundwater are part of the OU 1 groundwater plume; SWMUs 2 and 3 are
not a source of these compounds.
• The pesticides and herbicides dieldrin, monuron, diuron, aldrin, chlordane, 2,4-D, DDD, DDE, DDT,
delta-BHC, endosulfan, sulfate, endrin, heptachlor epoxide, linuron, and simazine have impacted
groundwater at SWMUs 2 and 3; dieldrin, monuron, and diuron are the most prevalent.
Table 5-25. Summary of Fate and Transport and Risk Data for SWMU 2
Impacted
Medium
Soil
Threat to Beneficial
Uses of Groundwater
SVOCs (bis[2-ethylhexyl]
phthalate, 4-methylphenol),
pesticides and herbicides
(aldrin, dieldrin, diuron,
lindane, monuron,
heptachlor)
Threat to Background
Groundwater Quality
SVOCs (bis[2-ethylhexyl]
phthalate, 2,4-dimethyl-
phenol, di-n-butylphthalate,
4-methylphenol)
Pesticides and herbicides
Cancer
Risk
< 1x10-*
depot
worker
Hazard
Index
> 1 depot
worker
(chlordane,
DDX)
Ecological
Risks
Pesticides
(DDD, DDE,
DDT),
metals
(selenium,
lead)
Surface Pesticides and herbicides
Water (DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofbs)
(aldrin, total chlordane,
DDD, DDE, DDT, dieldrin,
diuron, endrin, lindane,
monuron, 2,4-D, heptachlor)
Pesticides and herbicides
(DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
NC
NC
Pesticides
(DDD, DDE.
DDT)
SEC-5.DOC
5-30
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.6.2 SWMU 3—Industrial Waste Lagoons
Site Characteristics of SWMU 3
Past Site Activities
• The site consists of two lined industrial waste
lagoons that are situated within a larger sanitary
sewage lagoon (SWMU 2).
• The smaller lagoon was installed in 1972 and was
unlined during its first year of use.
• The larger lagoon was installed between 1975 and
1979 and was lined at time of construction.
• Historically, the lagoons received wastewater from
the IWPL that included effluent from the recoup
operations from Building 26 (wastewater from
repackaging of petroleum products) and effluent
from Building 10 (wastewater from paint-stripping,
degreasing, and steam-cleaning operations).
wmf X
SWMU 3
Location of
SWMU 3
\
/
• Phostoxin (an insecticide and rodenticide) was released into the lagoon several times between 1975
and 1979.
• Currently, no effluent is entering the lagoons.
Conclusions
• Contaminant F&T modeling indicated that the pesticides and herbicides aldrin, chlordane, ODD,
DDE, DDT, dieldrin, diuron, endrin, lindane, monuron, 2,4-D, and heptachlor epoxide in the soil,
sediment, and surface water pose a potential future risk to groundwater.
• The pesticides and herbicides listed in the previous bullet point also pose a potential risk to
ecological receptors in the surface water and soil. In addition, the estimated risk for selenium in soil,
sediment, or surface water is above the benchmark level for ecological receptors; however, this risk
is considered conservative because of the biases in the analytical data.
• Compounds besides those listed above were detected in soil, sediment, and groundwater; however,
none exceeded the risk criteria or represented a potential or actual threat to beneficial uses of
groundwater or background groundwater quality. Thus, these compounds are not considered COCs.
• Contaminant F&T modeling indicated that the SVOCs bis(2-ethylhexyl)phthalate, 2,4-
dimethylphenol, di-n-butylphthalate, and 4-methylphenol in the soil or sediment pose a potential
future risk to groundwater.
SEC-S.DOC
5-31
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-26. Summary of Fate and Transport and Risk Data for SWMU 3
Impacted Threat to Beneficial
Medium Uses of Groundwater
Threat to Background Cancer Hazard Ecological
Groundwater Quality Risk index Risks
Soil
Surface
Water
SVOCs (bis[2-ethylhexyl]
phthalate, 4-methylphenol)
Pesticides and herbicides
(aldrin, dieldrin, diuron,
lindane, monuron,
heptachlor), metals
(mercury)
Pesticides and herbicides
(ODD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
SVOCs (bis[2-ethylhexyl] 3xlO'6 <1 depot Pesticides
phthalate, depot worker
2,4-dimethylphenol, worker
di-n-butylphthalate, 4- (chlordane,
methylphenol) DDX)
Pesticides and herbicides
(aldrin, total chlordane,
ODD, DDE. DDT, DDX,
dieldrin, diuron, endrin,
lindane, monuron, 2,4-D,
heptachlor)
Pesticides and herbicides NC NC Pesticides
(ODD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron, (DDD, DDE,
oxamyl, simazine, stirofos) DDT)
NC = not calculated
Table 5-27. Estimated Volume and Mass of COCs in Soil for SWMU 2 and 3
Volume of impacted Soil (yd )
Mass of COCs (pounds)
10,000
Pesticides and herbicides: 102
SEC-5.DOC
5-32
17 February 1998
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DDJC-Tracy Sile-Wide Comprehensive Record of Decision
5.6.3 SWMU 33—Industrial Waste Pipeline
(Group C)
5.6.3.1 Volatile organic compounds ^VOCs), SVOCs,
pesticides, herbicides, and petroleum hydrocarbons have
contaminated soil as the result of past site activities.
SWMU 33 was also a source of VOCs (xylenes, TCE,
PCE< 1,1-DCE, 1,1-TCA. 1.1-DCA.and l,2-DCE)and
pesticides (ODD, DDE, DDT, monuron, diuron, alpha-
BHC, and dieldrin) to groundwater. Ethylbenzene has
also been detected in soil at this site. Table 5-28
summarizes those contaminants that pose a risk to either
the groundwater or human/ecological receptors at
SWMU 33. Table 5-28 summarizes the volume and
mass of the contaminants in the soil at SWMU 33.
Figure B-29 shows sampling locations and analytical
results from SWMU 33. This site was evaluated in the
FS because groundwater was impacted and because
there is a potential future threat to groundwater from
contaminants in the soil.
Site Characteristics
Past Site Activities
\
Location of
SWMU 33
SWMU 33
\
• Historically, wastestreams from various shops performing unit operations have been routed to the
industrial waste lagoons (SWMU 5) via the industrial waste pipeline (rWPL).
• The IWPL was constructed in 19"2.
• The IWPL is buried approximately 2 to 4 feet below ground surface.
• The IWPL is constructed of various materials, including transite, vitrified clay pipe, and polyvinyl
chloride (PVC).
• There are two major lines from the IWPL. Both the south IWPL and its branches and the east IWPL
and its branches are approximately 1,200 feet in length.
RI/FS Activities
• Site investigation activities at SWMU 33 included soil-gas surveys, soil sampling, well installation
groundwater monitoring, surface water and sediment sampling, a pipeline assessment, video
inspection, air and smoke testing, and sump sampling. A removal action is proposed for this site.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 33. A summary of the WQSA
and the BRA are presented in Section 6.0.
SEC-5DOC
5-33
12 December 1997
-------
DDJC-Tracy Sue-Wide Comprehensive Record of Decision
Conclusions
• SWMU 33 was a probable source of TCE, PCE, chloroform, 1.1 -DCA, and 1,2-DCE in the OU 1
groundwater plume.
• SWMU 33 was also a source of ODD, DDE, DDT, monuron, diuron, alpha-BHC, and dieldrin to
groundwater.
• Contaminant F&T modeling indicated that xylenes, diethylphthalate, di-n-butylphthalate,
naphthalene, aldrin, carbaryl, dieldrin, methiocarb, and TPH as diesel in the soil are potential threats
to groundwater.
• Compounds besides those listed above were detected in soil, soil gas, and groundwater; however,
none exceeded the risk criteria or represented a potential or actual threat to beneficial uses of
groundwater or background groundwater quality. Thus, these compounds are not considered COCs.
Table 5-28. Summary of Fate and Transport and Risk Data for SWMU 33
Threat to Beneficial Threat to
Impacted Uses of Background Cancer Hazard Ecological
Medium Groundwater Groundwater Quality Risk Index Risks
Soil
SVOCs (naphthalene)
Pesticides (carbaryl.
methiocarb)
VOCs (xylenes)1
SVOCs
(diethylphthalate,
di-n-ibutylphthalate,
naphthalene)
Pesticides (aldrin,
carbaryl, dieldrin,
methiocarb)
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7 No Further Action Sites
5.7.1 SWMU 5—Old Industrial Lagoon,
Building 255 (No Further Action)
5.7.1.1 Soil and groundwater have not been adversely
impacted; therefore, this site is recommended for no
further action. Groundwater beneath this site is within
the area of OU 1 groundwater contamination; however,
the source of TCE in groundwater was not SWMU 5.
Table 5-30 summarizes the F&T and risk- data for
SWMU 5. Figure B-30 shows sampling locations and
analytical results from SWMU 5.
Site Characteristics
Past Site Activities
• The site is located north of Building 255 and south
of the railroad tracks.
• The site was constructed by 1952 based on aerial
photographs.
Location of
SWMU 5
SWMU 5
\
-V .vi. - SWMU 5
• The lagoon received rinse water from paint-spraying and paint-stripping operations in Building 255.
• The lagoon was enlarged in 1963 and existed until at least 1971.
• In 1972 or 1973, the unlined lagoon was cleaned and backfilled.
• The area is not paved and contains slight topographic depressions where water ponds during the
rainy season.
RI/FS Activities
• Site investigation activities included a geophysical survey, a soil-gas survey, soil sampling, and
groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 5. Summaries of the WQSA and
the BRA are presented in Section 6.0.
SEC-5.DOC
5-35
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-30. Summary of Fate and Transport and Risk Data for SWMU 5
Threat to
Background
Threat to Beneficial Groundwater
Uses of Ground water Quality Cancer Risk Hazard Index Ecological Risks
None None < 1 x 10"6 depot < I depot worker None
worker
SEC-5.DOC 5-?6 12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.2 SWMU 9—Subsistence Waste Pit
(No Further Action)
5.7.2.1 Soil and groundwater have not been adversely
impacted by past practices at SWMU •?: therefore, this
site is recommended for no further action. Table 5-31
summarizes the F&T and risk data for SWMU 9. Figure
B-31 shows sampling locations and analytical results
from SWMU 9.
Site Characteristics
Past Site Activities
• The site is located in the eastern portion of DDJC-
Tracy.
• Subsistence waste, primarily food, was reported to
have been buried in the pit beginning in 1947.
Packaging materials were also buried.
RI/FS Activities
\
Location of
SWMU 9
\
SWMU 9
I
I
I
I
I X
X
X
SWMU 9
.'
5 • /;•• j . . •"". ': ; :''.' .'
I ''•'•*-'''"'"fiF'"
Site investigation activities included a geophysical survey, soil sampling, well installation, and
groundwater monitoring.
A WSQA, an F&T analysis, and 2. BRA were performed for SWMU 9. Summaries of the WQSA and
the BRA are presented in Section 6.0.
Table 5-31. Summary of Fate and Transport and Risk Data for SWMU 9
Threat to Threat to
Beneficial Uses Background
of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< IxlO'6
construction worker
< 1 construction
worker
None
SEC-5.DOC
5-37
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.3 SWMU 10—Medical Waste Burial Pit
(No Further Action)
5.7.3.1 Soil and groundwater have not been adversely
impacted by past practices at SWMU 10; therefore, the
site is recommended for no further action. Table 5-32
summarizes the F&T and risk data for SWMU 10.
Figure B-32 shows sampling locations and analytical
results from SWMU 10.
Site Characteristics
Past Site Activities
• The site is located in the open area south of
Buildings 21 and 22 along the southeastern margin
of DDJC-Tracy.
• The site is a former medical waste burial pit.
• Outdated medical supplies, including narcotics,
mercury, and phosphate compounds, were buried at
this site.
x
Location of
SWMU 10
\
SWMU 10
,W
• Aerial photographs show that the pit operated from approximately 1949 until 1965.
• Since 1967, this area has been used for storing truck trailers.
RI/FS Activities
• Site investigation activities included a geophysical survey, soil-gas surveys trench excavations, soil
sampling, and groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 10. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-32. Summary of Fate and Transport and Risk Data for SWMU 10
Threat to Beneficial
Uses of Threat to Background
Groundwater Groundwater Quality
Cancer Risk Hazard Index
Ecological
Risks
None
None
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.4 SWMU 10A—Possible Medical Waste
Burial Pit (No Further Action)
5.7.4.1 Although soil has been contaminated with
SVOCs and metals, the groundwater has not been
adversely affected by this contamination. Therefore, the
site is recommended for no further action. Table 5-33
summarizes the F&T and risk data for SWMU IDA.
Figure B-33 shows sampling locations and analytical
results from SWMU 10A.
5.7.4.2 Appendix T.3 of the RI/FS »Montgomery
Watson, 1996a) evaluated the feasibility of remediating
diethylphthalate and di-n-butylphthalate at this site.
Excavation of the contaminated soil was estimated to
cost $2.047,000. Because these phthalates were
suspected lab contaminants, the expenditure to
remediate this site was not considered justified.
Site Characteristics
\
Location of
SWMU 10A
\
I SWMU IDA
I /
I /
SWMU 10A
Past Site Activities
• The site is located in an open area south of Buildings 13 and 14 in the southern portion of DDJC-
Tracy.
• The pit was reportedly used to bury medical supplies.
• A 1945 aerial photograph shows three large strips of disturbed ground, possibly trench scars. These
scars are evident in photographs through 1967.
• The 1969 photographs show undisturbed surface and a parking lot on the north side of the area. The
area in the immediate vicinity is slightly vegetated.
RI/FS Activities
• Site investigation activities included a geophysical survey, a trench investigation, soil-gas surveys,
soil sampling, and groundwater monitoring.
• A WQSA, an F&T analysis, and a BRA were performed for SWMU 10A. Summaries of the WQSA
and the BRA are presented in Section 6.0.
SEC-5.DOC
5-39
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 5-33. Summary of Fate and Transport and Risk Data for SWMU 10A
Impacted
Medium
Threat to
Beneficial Uses
of Groundwater
Threat to
Background
Groundwater
Quality
Cancer Risk Hazard Index
Ecological
Risks
Soil SVOCs
(diethylphthalate.
di-n-butylphthalate)
SVOCs
i.di:thylphthalate,
di-n-butylphthalate)
Pesticides
(ODD. DDE, DDT)
Metals
(Antimony)
< IxlO6
construction
worker
< 1 construction
worker
None
SEC-5.DOC
5-40
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
\
Location of
SWMU 11
\
SWMU 11
SWMU 11
H
5.7.5 SWMU 11—Burial of Lime/Foot Bath (No
Further Action)
5.7.5.1 No evidence of disposal activities has been
identified; therefore, the site is recommended for no
further action. Table 5-34 summarizes the F&T and risk
data for SWMU 11. Figure B-34 shows sampling
locations and analytical results from SWMU 11.
Site Characteristics
Past Site Activities
• The site is located along the west side of Building
13 in the southern portion of DDJC-Tracy.
• The site was reportedly a burial site for disposing of
lime materials associated with lime/foot baths.
• The area is currently covered with asphalt.
• No evidence of disposal activities was identified
based on Phase I RI activities.
RI/FS Activities
Site investigation activities included a soil-gas survey and a geophysical survey. Because no
anomalies were detected during the geophysical survey, soil sampling and groundwater sampling
were not conducted.
A WQSA was not conducted at SWMU 11. It is likely that the materials reportedly disposed of at
SWMU 11 were actually disposed of at SWMU 10A. Thus, SWMU 11 may have been misidentified.
A BRA was performed for SWMU 11. A summary of the BRA is presented in Section 6.0.
Table 5-34. Summary of Fate and Transport and Risk Data for SWMU 11
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"* depot < 1 depot worker
worker
None
SEC-5.DOC
5-41
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Location of
SWMU 12
\
SWMU 12
SWMU 121
5.7.6 SWMU 12—Embalming Fluid Dump
(No Further Action)
5.7.6.1 Soil and groundwater have not been adversely
impacted by past practices at SWMU 12; therefore, the
site is recommended for no further action. Table 5-35
summarizes the F&T and risk data for SWMU 12.
Figure B-35 shows sampling locations and analytical
results from SWMU 12.
Site Characteristics
Past Site Activities
• The site is located on the southern portion of DDJC-
Tracy, just east of Building 30, Consolidated
Subsistence Facility.
• The site operated between 1945 and 1946.
• An unknown but substantial quantity of embalming
fluid containing formaldehyde was buried just east
of Building 30, Consolidated Subsistence Facility.
• Surface drainage is to a topographic low west of the site.
• The area is not paved.
RI/FS Activities
Site investigation activities included a geophysical survey, a soil-gas survey, soil sampling, and
groundwater sampling from a HydroPunch sample (HP28), and groundwater monitoring.
A WQSA, an F&T analysis, and a BRA were performed for SWMU 12. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-35. Summary of Fate and Transport and Risk Data for SWMU 12
Threat to
Threat to Beneficial Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.7 SWMU 14—Lube Oil Dump (No Further
Action)
5.7.7.1 Semivolatile organic compounds (SVOCs),
pesticides, TPH, and metals have been released to the
soil, but do not pose a threat to groundwater.
Groundwater has not been adversely impacted by past
activities at SWMU 14; therefore, the site is
recommended for no further action. Table 5-36
summarizes the F&T and risk data for SWMU 14.
Figure B-36 shows sampling locations and analytical
results from SWMU 14.
Site Characteristics
Past Site Activities
• The site is located on the southern end of DDJC-
Tracy, just east of Building 30, Consolidated
Subsistence Facility.
• The site was reportedly a former lube oil dump.
Location of
SWMU 14
\
i
I
i
.SWMU14/
I : /»
I
SWMU 14
• Reportedly, 150 drums of new lube oil were emptied into a trench in 1976. The trench was backfilled
with soil.
• A 1980 aerial photograph shows oil seepage visible on the surface.
• During the installation of a water line across the site in 1992. workers reported a black, viscous
substance in the west wall of the trench.
• The area is unpaved.
RI/FS Activities
• Site investigation activities included geophysical surveys, soil-gas surveys, soil sampling, trenching
investigations, well installations, and groundwater monitoring.
• An F&T analysis, a WQSA and a BRA were performed for SWMU 14. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 14
Threat to Beneficial
Uses of Threat to Background
Groundwater Groundwater Quality
Cancer Risk
Hazard Index Ecological Risks
None
None
< 1x10* < 1 construction
construction worker worker
None
SEC-5.DOC
5-43
12 December 1997
-------
DDJC-Tracy Siie-Wjde Comprehensive Record of Decision
I
\
I Drum Storage \
1 Area, Building 15
Location of
Drum Storage Area,
Building 15
i
I
. _
Drum Storage
rea. Building 15
. •-:. T*v- >
"k '-.'•-' '•>*
5.7.8 SWMU 15—Pesticide Waste Trench
(No Further Action)
5.7.8.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 15; therefore, the
site is recommended for no further action. Table 5-37
summarizes the F&T and risk data for SWMU 15.
Figure B-37 shows sampling locations and analytical
results from SWMU 15.
Site Characteristics
Past Site Activities
• The site is located on the southern end of DDJC-
Tracy, just east of Building 30. Consolidated
Subsistence Facility.
• The site was a pesticide waste trench from
approximately 1977 until late 1978 or early 1979.
• Rodent bait, crushed cans that previously contained
pesticides, or phosgene (phostoxin) slurry may have
been buried in the trench.
• Empty DDT containers may have been disposed of in this trench.
• Between 1979 and 1980 the trench was excavated and its contents were disposed of off-site.
• Two underground water lines run through the middle of the former trench.
• The area is currently unpaved.
Rl/FS Activities
• Site investigation activities included a geophysical survey, soil-gas surveys, soil sampling, well
installation, and groundwater monitoring.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 15. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-37. Summary of Fate and Transport and Risk Data for SWMU 15
Threat to Beneficial
Uses of
Groundwater
Threat to
Background
Groundwater Quality
Cancer Risk Hazard Index Ecological Risks
None
None
•clxlCTdepot
worker
< 1 depot worker
None
SEC-5.DOC
5-44
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.9 SWMU 16—Possible Waste Disposal
Area (No Further Action)
5.7.9.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 16; therefore, the
site is recommended for no further action. Groundwater
beneath this site is located in the vicinity of known OU
1 groundwater contamination. However. SWMU 16 is
not the source of this contamination. Table 5-38
summarizes the F&.T and risk data for SWMU 16.
Figure B-38 shows sampling locations and analytical
results from SWMU 16.
Site Characteristics
Past Site Activities
• The site is located on the northern portion of DDJC-
Tracy, just south of Building 26.
• The site was possibly a waste disposal area that
operated between 1952 and 1967.
Location of
SWMU 16
SWMU 16
'
SWMU 16
• Reportedly, the following items may have been buried at this site: asbestos; mercury; fluorescent
bulbs; and medical supplies containing narcotics, mercury, and phosphate compounds.
• The area is currently unpaved and unused.
Rl/FS Activities
• Site investigation activities included a geophysical survey, soil-gas surveys, soil sampling, well
installation, and groundwater monitoring.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 16. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-38. Summary of Fate and Transport and Risk Data for SWMU
Impacted
Medium
Soil
Threat to
Beneficial Uses of
Groundwater
None
Threat to
Background
Groundwater Quality
None
Cancer Risk
< IxlO'6
construction
worker
Hazard
Index
< l
construction
worker
16
Ecological
Risks
None
SEC-5.DOC
5-45
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.10 SWMU 21—Battery Acid Dump
(No Further Action)
5.7.10.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 21; therefore, the
site is recommended for no further action. Groundwater
beneath this site is within the vicinity of OU 1
groundwater contamination: however, the source of this
contamination in the groundwater is not SWMU 21.
Table 5-39 summarizes the F&T and risk data for
SWMU 21. Figure B-39 shows sampling locations and
analytical results from SWMU 21.
Site Characteristics
Past Site Activities
• The site is located on the northern portion of DDJC-
Tracy, just west of Building 201.
• The site was a battery acid dump area.
SWMU 21
\
Location of
SWMU 21
\
c'
SWMU 21
• The neutralized solution from the battery shop waste
was discharged onto the ground and later into a sump behind Building 201 and allowed to evaporate
or seep into the ground.
• The area surrounding SWMU 21 is paved with asphalt.
RI/FS Activities
• Site investigation activities included a soil-gas survey, soil sampling, groundwater sampling from a
HydroPunch device (HP29), and groundwater monitoring.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 21. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-39. Summary of Fate and Transport and Risk Data for SWMU 21
Impacted
Medium
Soil
Threat to
Beneficial Uses
of Groundwater
None
Threat to
Background
Groundwater Quality
None
Cancer Risk
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.11 SWMU 22—Previous Hazardous
Materials Storage Area
(No Further Action)
5.7.11.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 12: therefore, the
site is recommended for no further action. Table 5-40
summarizes the F&T and risk data for SWMU 22.
Figure B^tO shows sampling locations and analytical
results from SWMU 22.
Site Characteristics
Past Site Activities
• The site is located east of Building 22 in the eastern
portion of DDJC-Tracy.
• The site was the previous location for hazardous
materials storage for DDJC-Tracy from 1979 until
1985.
Location of
SWMU 22
\
SWMU 22 <
I /
. x
; SWMU 22
J:
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.12 SWMU 23—Building 26 Recoup
Operations (No Further Action)
5.7.12.1 Volatile organic compounds (PCE, TCE)
formerly impacted ground water at SWMU 23. No
continuing threats to groundwater, human health, or
ecological receptors were identified at the site. Table 5-
41 summarizes the fate and transport and risk data for
SWMU 23.
Site Characteristics
Past Site Activities
• SWMU 23 includes Building 26 and was used for
repackaging petroleum products, including oils,
solvents, and ethylene glycol.
• The site was originally a wash rack constructed in
1950.
• A small floor drain in Building 126 was reportedly
connected to the industrial wastewater system via
SWMU 33.
\
Location of
SWMU 23
SWMU 23
\
X
X
::. r «•:.-.. 7H :,
Table 5-41. Summary of Fate and Transport and Risk Data for SWMU 23
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
construction
worker
<1 construction
worker
None
SEC-5.DOC
5-48
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.13 SWMU 25—Boundary Roads (No Further
Action)
5.7.13.1 Soil has not been adversely impacted by past
activities at SWMU 25; therefore, the site is
recommended for no further action. Table 5-42
summarizes the F&T and risk data for SWMU 25.
Figure B-41 shows sampling locations and analytical
results for SWMU 25.
Site Characteristics
Past Site Activities
• This site includes the boundary roads of DDJC-
Tracy.
• Waste motor oil may have been used as a dust
suppressant on the boundary roads in the 1940s and
1950s.
\
Location of
SWMU 25
SWMU 25
ii
SWMU 25
—.:• *.'
• Most of the roads are currently paved. The unpaved
portions located along the southern depot boundary
were investigated during the Phase I RI. The unpaved portions are coated with a bituminous (oil and
gravel) surface.
RI/FS Activities
• Site investigation activities included soil sampling.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 25. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-42. Summary of Fate and Transport and Risk Data for SWMU 25
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-49
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
SWMU 29
Location of
SWMU 29
\
5.7.14 SWMU 29—Used Motor Oil Pit
(No Further Action)
5.7.14.1 No evidence of disposal activities has been
identified; therefore, the site is recommended for no
further action. Table 5-43 summarizes the F&T risk data
for SWMU 29. Figure B-42 shows sampling locations
and analytical results from SWMU 29.
Site Characteristics
Past Site Activities
• The site is located north of Building 225 and west of
SWMU 2 in the northern portion of DDJC-Tracy.
The actual location is uncertain.
• The site is a former used motor oil disposal pit.
• The period of operation is uncertain.
• The area in the immediate vicinity of the site has
been extensively excavated for underground utilities
and is currently covered with asphalt.
RI/FS Activities
• Site investigation activities included a geophysical survey and soil-gas surveys.
• Because there was no evidence of disposal activities at SWMU 29, no F&T analysis, WQSA, or
BRA was conducted.
••i 29
Table 5-43. Summary of Fate and Transport and Risk Data for SWMU 29
Threat to Beneficial Threat to Background
Uses of Groundwater Ground water Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-50
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5 7 15 3WIUIII an— Salvage Area
(No Further Action)
5.7.15.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 30; therefore, the
site is recommended for no further action. SWMU 30 is
located within the area of the known OU 1 plume;
however, the source of contamination is not SWMU 30.
Table 5-44 summarizes the F&T and risk data for
SWMU 30. Figures B-43 and B-44 show sampling
locations and analytical results from SWMU 30.
Site Characteristics
Past Site Activities
• The site is located south of Building 22 in the
eastern portion of DDJC-Tracy.
• The site is a former salvage area.
• No information is available on the history or type of
h^
i "* \ Location of
I x \ SWMU 30
i \
i \
1 s
, SWMU 30 .T" 1
1 >
1 /
|
1
I^r
,'
\ /
L"
s
- '.^^ -V; , - \ \ ^
^ ~^x~':.xX\
!'• -,' V'.:\t. •:•:.'• ••• ::
•jLj/'"--V" ; ; "V-7*,
• : V,- ^^>^r ; ; ' "i-
' "ir1 — \> v : .•:•.
?* *^JT'/> [V-!?[J/,--
;; SWMU 30
; --.- ' f*
~"j*=-±.
.*•?•?.. :- •••"•• :- _.-'
waste disposal practices in this area.
• The area in the immediate vicinity of the site is unpaved.
RI/FS Activities
• Site investigation activities included soil-gas sampling, soil sampling, and groundwater monitoring
from various wells.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 30. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-44. Summary of Fate and Transport and Risk Data for SWMU 30
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-51
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.16 SWMU 31—Wood Preservation Area
(No Further Action)
5.7.16.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 31; therefore, the
site is recommended for no further action. SWMU 31 is
located within the area of the known OU 1 groundwater
contamination, but is not considered a potential source
area. Table 5-45 summarizes the F&T and risk data for
SWMU 31. Figure B-45 shows the sampling locations
and analytical results from SWMU 31.
Site Characteristics
Past Site Activities
• The site is located east of Building 247.
• The site was used for wood preservation operations
from the mid-1950s until 1960.
Location of
x v SWMU 31
SWMU 31
\
\,'
• Wood products, primarily pallets, were reportedly ^^^^^^^^^^^^^^^^^^^^^m
dipped into large vats containing phenolic
compounds and carbolic acid to prevent the wood from rotting.
• The vats sat in the open and were covered with canvas tarps. Liquid was reportedly spilled from the
vats during operation.
• The area in the immediate vicinity is paved.
RI/FS Activities
• Site investigation activities included soil sampling and groundwater monitoring.
• An F&T analysis, a WQSA, and a BRA were performed for SWMU 31. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Table 5-45. Summary of Fate and Transport and Risk Data for SWMU 31
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-52
12 December 1997
-------
DDJC-Tr.icy Siie-Wide Comprehensive Record of Decision,
5.7.17 SWMU 64— Waste Oil Pit
(No Further Action)
5.7.17.1 Soil and groundwater have not been adversely
impacted by past activities at SWMU 64; therefore, the
site is recommended for no further action. SWMU 64 is
located on the upgradient edge of the known area of OU
1 groundwater contamination, but is not considered a
potential source. Table 5-46 summarizes the F&T and
risk data for SWMU 64. Figure B-46 shows the
samplins locations and analytical results from SWMU
64.
Site Characteristics
Past Site Activities
• The site is located on the northern side of Building
201.
• This site included a 1,000-gallon metal tank that
contained waste oils generated by the automotive
maintenance shop in Building 201.
SWMUM\
Location of
SWMU 64
\
I ,'
i /
••»<
~ .-•• >v.
'-??-.swMy_64i.^-r .J]_'4 ^4
• Waste oils were stored in the tank temporarily, pending off-site disposal.
• The tank was installed in 1975 and removed in 1988.
• The excavated area is covered with asphalt, and the area in the immediate vicinity of SWMU 64 is
covered with concrete.
RI/FS Activities
• Site investigation activities included soil sampling, well installation, and groundwater monitoring.
• An F&T analysis and a BRA were performed for SWMU 64. A WQSA was not performed for
SWMU 64 because only a few samples (metals) exceeded background concentrations and then only
marginally. A summary of the BRA is presented in Section 6.0.
Table 5-46. Summary of Fate and Transport and Risk Data for SWMU 64
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10"6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-53
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.18 Area 1 Building 236
(No Further Action)
5.7.18.1 Soil has not been adversely impacted by the
past activities at this site; therefore, the site is
recommended for no further action. Area 1 Building 236
is located within the known area of OU 1 groundwater
contamination, but is not considered a potential source
of the contamination. Table 5-47 summarizes the F&T
and risk data for Area 1 Building 236. Figure B-47
shows the sampling locations and analytical results from
Area 1 Building 236.
Site Characteristics
Past Site Activities
• The site is located in the northern portion of DDJC-
Tracy in the central shops and maintenance area
directly east of Building 236.
• Solvents have historically been used or stored in this
area.
Area 1,
Building 236
Location of
\ Area 1, Building 236
N
v
I
I /
t'
• The area is covered with asphalt.
RI/FS Activities
• Site investigation activities included soil sampling.
• A BRA was performed for Area 1 Building 236. A WQSA was not performed because the methylene
chloride detected in the soil was determined to probably be the result of laboratory contamination. A
summary of the BRA is presented in Section 6.0.
Table 5-47. Summary of Fate and Transport and Risk Data for Area 1 Building 236
Threat to Beneficial
Uses of Groundwater
Threat to Background
Groundwater Quality
Cancer Risk Hazard Index Ecological Risks
None
None
<\K\Q-6 depot
worker
< 1 depot worker
None
SEC-5.DOC
5-54
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.19 Building 15 Drum Storage Area
(No Further Action)
5.7.19.1 Soil has not been adversely impacted by past
activities at the Building 15 Drum Storage Area;
therefore, the site is recommended for no further action.
Table 5-48 summarizes the F&T and risk data for the
Building 15 Drum Storage Area. Figure B-48 shows the
sampling locations and analytical results from the
Building 15 Drum Storage Area.
Site Characteristics
Past Site Activities
• The site is located in the central portion of DDJC-
Tracy between A and B Streets.
• The site includes a concrete slab on which various
materials are currently stored.
• Solvents were stored at drum storage areas at DDJC-
Tracy.
N
Location of
SWMU15
\
I SWMU 15
I V
I /
V,'
SWMU 15
• Site history indicates that petroleum hydrocarbons or wastes containing metals were stored at this
site.
• Infiltration galleries for the OU 1 IRM system were recently constructed at the site.
• The site is not near other RI sites.
RI/FS Activities
• Site investigation activities included soil sampling.
• Because no contaminants of potential concern were identified, the F&T analysis, the WQSA, and the
BRA were not conducted for the Building 15 Drum Storage Area.
Table 5-48. Summary of Fate and Transport and Risk Data for
Building 15 Drum Storage Area
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None
None
IxlO'6 depot
worker
<1 depot
worker
None
SEC-5.DOC
5-55
12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decisior.
5.7.20 Building 22 Drum Storage Area
(No Further Action)
5.7.20.1 Soil and groundwater have not been adversely
impacted by past activities at the Building 22 Drum
Storage Area; therefore, the site is recommended for no
further action. Table 5-49 summarizes the F&T and risk
data for the Building 22 Drum Storage Area.
Figure B-49 shows the sampling locations and analytical
results from the Building 22 Drum Storage Area.
Site Characteristics
Past Site Activities
• The site is located on the eastern edge of DDJC-
Tracy at the easternmost end of B Street.
• The site includes a paved area on which pallets of
materials are currently stored.
• Solvents were stored at drum storage areas at DDJC-
Tracv.
^ Location of
x \ Drum Storage Area,
s Building 22
1 Drum Storage
I Area, Building 22 '-: A I
I
I
I /
V,'
Drum Storage Area,
Bldg. 22
• The area is paved with asphalt.
Rl/FS Activities
• Site investigation activities included soil sampling and groundwater monitoring.
• An F&T analysis and a BRA were performed for the Building 22 Drum Storage Area. A WQSA was
not performed because the Phase IRI activities indicated that there has not been a release of
contaminants from the Building 22 Drum Storage Area. A summary of the BRA is presented in
Section 6.0.
Table 5-49. Summary of Fate and Transport and Risk Data for
Building 22 Drum Storage Area
Threat to Beneficial
Uses of Groundwater
Threat to Background
Groundwater Quality
Cancer Risk Hazard Index Ecological Risks
None
None
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.7.21 Building 23 (No Further Action)
5.7.21.1 Soil has not been adversely impacted by past
activities at this site; therefore, the site is recommended
for no further action. Table 5-50 summarizes the F&T
and risk data for Building 23. Figure B-50 shows the
sampling locations and analytical results from Building
23.
Site Characteristics
Past Site Activities
• The site is located in the central portion of DDJC-
Tracy, between B and C Streets. The site is to the
east of Building 23 and adjacent to a number of
open storage areas.
• This site is within a larger area identified in
previous investigations as being an area containing
potential soil contamination.
• The area in the immediate vicinity of Building 23 is
covered with asphalt.
RI/FS Activities
Location of
\ Building 23
\
0 Building 23
I
Building 23
Site investigation activities included soil-gas surveys and soil sampling.
Neither an F&T analysis nor a WQSA was conducted for Building 23 because no chemicals of
potential concern were identified. A BRA was performed. A summary of the BRA is presented in
Section 6.0.
Table 5-50. Summary of Fate and Transport and Risk Data for Building 23
Threat to Beneficial
Uses of Groundwater
Threat to Background
Groundwater Quality
Cancer Risk Hazard Index Ecological Risks
None
None
< 1 x 10'6 depot < 1 depot worker
worker
None
SEC-5.DOC
5-57
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
5.8 Day Care Center (Excavation and
Disposal—Time Critical Removal
Action)
5.8.1 Soil contaminated with SVOCs (PAHs),
pesticides, and metals was removed in October 1995. No
threat to groundwater or risks to children remain.
Table 5-51 summarizes the F&T and risk data for the
Day Care Center. Figure B-51 shows the sampling
locations and analytical results from the Day Care
Center.
Site Characteristics
Past Site Activities
• The site is located on the west side of the depot,
north of and adjacent to the main depot entrance on
Chrisman Road.
• A 1,200-gallon metal UST containing No. 2 fuel oil
was located at this site.
•m Day Car*
I Center
Location of
Day Care Center
\,'
\
• The UST was installed prior to 1956 and removed in 1988.
• All soil in the lawn area was removed to a depth of 1 foot and replaced with 3 inches of clean soil
over 9 inches of clean fill.
RI/FS Activities
• Site investigation activities included soil sampling and groundwater sampling from a HydroPunch
(PH002).
• An F&T analysis and a BRA were performed for the Day Care Center. A WQSA was not performed
because metals and pesticide concentrations at the Day Care Center only slightly exceeded
background levels. A summary of the BRA is presented in Section 6.0.
Table 5-51. Summary of Fate and Transport and Risk Data for Day Care Center
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality
Cancer Risk
Hazard Index
Ecological
Risks
None
None
IxlO'6'children < 1* children
None
' After remedial activity was complete in October 1995. Prior to remedial activity cancer risk was > 1 xlO"6 and hazard index was
> 1.0 for children. The increased incremental cancer risk following the action at the Day Care Center is zero.
SEC-5.DOC
5-58
17 February 1998
-------
AG-1
Figure 5-1.
SWMUs and TCE Contamination
at DDJC-Tracy
AG-2
Rose
Residence
SWMUaOCll 0
SWMU
SWg.201 23
nDrum Storage Area
Building 30
Consolidated
Subiotinc* Facdrty
0 300 600
SCALE IN FEET
LEGEND
Railroad Tracks
Fence Line
Agricultural Area
Dirt Access Road
Abandoned
Agricultural Well
Approximate Location of SWMUs II
and Possible Soil Contamination Areas I '
Approximate Location of Potential Off-site *
Groundwater Contamination Source Areas
• AG-2
Approximate Location of t .>•-•••
Potential TCE Source Areas I- '.••'
Removal Actions (Completed)
Location of >5 micrograms per litei (pg/L| TCE
Above Upper Horizon:
Location of >5 micrograms per liter (pg/L) TCE
Upper Horizon:
Taken From
3rd Quarter. 1996
Taken From
3rd Quarter. 1996
-------
AG-1
Figure 5-2.
SWMUs and PCE Contamination
at DDJC-Tracy
AG-2
ROM
Residence
SWUU4 f
BUg. 201
Con*olid«Ml
Subaounci Facility
nDrum Storage Are
Building 30
0 300 600
SCALE IN FEET
LEGEND
Railroad Tracks
Fence Line
Agricultural Area
Dirt Access Road
Abandoned
Agricultural Well
> AG-2
Approximate Location ol SWMUs and
Possible Soil Contamination Areas
Approximate Location of Potential Off-site f
Groundwater Contamination Source Areas
Approximate Location of
Potential PCE Source Areas
Removal Actions (Completed)
Location of >5 micrograms per liter U/g. U PCE
Above Upper Horizon:
Location of >5 micrograms per liter (pg. LJ PCE
Upper Horizon:
Taken From
3rd Quarter. 1996
Taken From
3rd Quarter. 1996
=C=S«
-.CT M 18 97 SAC
-------
AG-1
Figure 5-3.
SWMUs and Dieldrin Contamination
at DDJC-Tracy
AG-2
ROM
Residence
a Drum Storage Area
BunOina 30
Con«olidited
SuMotcnc* Ficrtity
0 300 600
SCALE IN FEET
Railroad Tracks
Fence Line
Agricultural Area
Dirt Access Road
Abandoned
Agricultural Well
LEGEND
• AG-2
Approximate Location of SWMUs I I
and Possible Soil Contamination Areas ' I
Approximate Location of Potential Off-site 'IIIIII
Groundwater Contamination Source Areas 'fl IIII
Approximate Location of
Potential Pesticide Source Areas
Removal Actions (Completed)
Location o) >O.S micrograms per liter (jjg.L) Dieldrin
Upper Horizon:
Taken From 1996
-." 1211 57 SAC
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
6.0 SUMMARY OF SITE RISKS
A baseline risk assessment (BRA) was
conducted at Defense Depot San Joaquin
(DDJC)-Tracy (Montgomery Watson, 1996f).
The BRA was conducted to determine if
remedial action is required given the potential
risks to humans, plants, and animals at DDJC-
Tracy. Risks that could exist if no action is
taken at DDJC-Tracy were estimated in the
BRA. In addition to identifying potential risks to
human health and ecological receptors, the
Comprehensive RI/FS (Montgomery Watson,
1996a) also identified threats to background
groundwater quality and beneficial uses (these
threats do not necessarily pose unacceptable risk
to human health). The protection of water
quality, the protection of human health, and the
protection of ecological receptors were the
major criteria for determining contaminants of
concern and whether sites required remediation.
6.1 BRA Methodology
6.1.1 Because DDJC-Tracy is a Superfund site,
the BRA was conducted using methods from the
United States Environmental Protection Agency
(U.S. EPA) Risk Assessment Guidance for
Superfund (U.S. EPA, 1989a and b; U.S. EPA,
199la and b). Other applicable supplements
were used, including relevant regional U.S. EPA
(Region DC) and state risk assessment guidance
(Department of Toxic Substances Control
[DTSC], 1992). The BRA used a conservative
and protective approach that included the
following five components:
1. Identification of chemicals of potential
concern (COPCs) (also known as hazard
identification);
2. Exposure assessment, including identifying
and characterizing the exposure pathways,
and estimating chemical intakes;
3. Toxicity assessment of the COPCs;
4. Risk characterization; and
5. Development of cleanup criteria.
6.1.2 The BRA grouped the solid waste
management units (SWMUs), the underground
storage tanks (USTs), and soil contamination
areas at DDJC-Tracy into 15 exposure units
(EUs) based on location and similarities in
contaminants and pathways. The Tracy Annex,
OU 1, and property north of the depot were
evaluated as three separate EUs to evaluate
groundwater impacts. It is reasonable to
evaluate risks for groups of source areas (EUs)
rather than for individual sources because the
sources are close together and receptors may be
exposed to contaminants from multiple sources.
The potential for risks from separate EUs to
combine and create a larger risk than the sum of
the risks of the individual EUs was considered
in an analysis of site-wide risk. A list of the EUs
and associated sites is presented in Table 6-1.
6.2 Identification of COPCs for
Humans
The chemicals that were present at a site at
levels above background threshold
concentrations but not considered essential
nutrients (i.e., the metals sodium, potassium,
magnesium, calcium, and iron) were identified
as COPCs. If a chemical was present above the
relevant background threshold in at least one
sample within an EU, that compound was
evaluated as a COPC for that EU. The COPCs
were evaluated in the toxicity assessment (see
Section 6.4) to identify the chemicals of concern
(COCs) that require remediation to protect
human health (see Section 6.5).
6.2.1 Current and Future Land Use
Current and future land use at DDJC-Tracy was
examined as part of the risk evaluation. DDJC-
Tracy is primarily a storage and distribution
facility for various supplies in common use by
the U.S. military services in the western U.S.
and throughout the Pacific. In addition, the
depot has residential buildings and a day care
center, all of which add potential receptors to
the exposure assessment. The site is also used to
train grader operators. The land use surrounding
DDJC-Tracy and the Tracy Annex is primarily
agricultural, consisting of irrigated row crops
SEC-6.DOC
6-1
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
and orchards. Numerous rural residential
developments exist within a 3-mile radius,
including small areas of commercial and
industrial land use. The land use at DDJC-Tracy
and in the region surrounding the site is
expected to remain the same for the foreseeable
future; however, construction may occur on site
or in nearby areas. No known Defense Logistics
Agency plan exists to sell or change the current
use of the DDJC-Tracy operations area.
6.2.2 COPCs and Media of Concern
The COPCs at DDJC-Tracy include volatile
organic compounds (VOCs), semivolatile
organic compounds, herbicides, PCBs,
petroleum hydrocarbons, metals, and pesticides.
These COPCs exist in surface soil/sediment (0
to 9 inches depth), near-surface soil/sediment (0
to 10 feet depth), surface water, and
groundwater.
6.3 Human Exposure Assessment
The exposure assessment included identifying
the following:
• The populations or subpopulations (e.g.,
children) that may be exposed to COPCs;
• The exposure pathways (i.e., how the
COPCs could reach sensitive populations);
and
• The magnitude of exposure for these
populations (i.e., the amount of a COPC a
population could be exposed to).
An exposure pathway is complete only if all
four of the following elements are present:
• A COPC must be present in the
environment;
• The COPC must have a way to be
transported through the environment (i.e.,
through soil, water, or air);
• Humans must be exposed to the COPC; and
• A potential human exposure route (e.g.,
inhalation and ingestion) must exist at the
point of exposure.
6.3.1 Human Receptors and Exposure
Pathways
Human receptors evaluated in the BRA include
depot workers, visitors, children attending the
on-depot day care center, local residents,
agricultural workers, potential future on-depot
residents, construction workers, and grader
operators who train at DDJC-Tracy. ("On-
depot" refers to the activities "occurring within
the operating portion of DDJC-Tracy.) The
environmental transport media that act as
pathways for exposure include groundwater,
soil, sediment, and surface water. Table 6-2
summarizes the existing pathways for exposure
and Table 6-3 summarizes potential future
pathways for exposure.
6.3.2 Exposure Concentrations
Evaluating exposure requires the assessment of
an exposure point concentration, or the COPC
concentration that someone may contact. For
this assessment, the exposure point concentra-
tion was either the 95% Upper Confidence Limit
(UCL) of the mean, or the maximum concentra-
tion detected, whichever was highest. All
analytical data from the sampling effort were
used in calculating exposure point concentra-
tions. A concentration equal to one-half the
detection limit was used when chemicals were
not detected.
6.3.3 Assumptions Used to Calculate
Chemical Exposure
Exposure was estimated in units of milligrams
of chemical per kilogram of body weight per
day (mg/kg-day). For example, the milligrams of
a chemical entering the body could be calculated
as a water ingestion rate multiplied by the
chemical concentration in the water, or an air
inhalation rate multiplied by the chemical
concentration in the air. The exposure doses
were estimated using values for input
SEC-6.DOC
6-2
HFcbniary 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
parameters that were conservative and likely to
overestimate exposure.
6.4 Human Toxicitv Assessment
Associated with COPCs
6.4.1 The toxicity assessment describes the
potential harmful effects associated with
exposure to COPCs. Three different methods
were used to quantify the toxicity of the COPCs.
6.4.2 Noncarcinogenic effects are charac-
terized by a reference dose (RfD) which is a
threshold below which no effects occur. The
U.S. EPA establishes reference doses for
ingestion and inhalation routes (dermal toxicity
is based on the oral RfD) with a margin of
safety for sensitive individuals. Reference doses
are derived from human epidemiological studies
or chronic animal studies from which extrapola-
tions are made to humans using uncertainty
factors. The uncertainty factor helps to ensure
that the extrapolation of experimental data does
not underestimate the potential for noncarcino-
genic effects to occur.
6.4.3 Carcinogens are classified into groups A
through E by U.S. EPA based on what the
weight of evidence says about the chemical
causing human cancer. Carcinogenicity is
quantified with a slope factor (SF), or the cancer
risk per unit daily intake of the chemical,
expressed in units of mg/kg-day. The SF
represents the upper 95% confidence interval of
the slope of the dose-response curve. The SF
times the exposure dose equals the upper-bound
estimate of the risk of developing cancer from
exposure to the compound of interest. "Upper-
bound" refers to a conservative estimate of the
risks that is calculated from the cancer SF to
ensure that actual cancer risks are not under-
estimated. As in the reference dose, uncertainty
factors allow for the extrapolation of chronic
animal studies to humans. For this risk assess-
ment, the risks from multiple COPCs were
assumed to be additive; neither synergistic nor
antagonistic effects were considered.
6.4.4 The potential concentration of lead in
blood was used to characterize the health risks
caused by exposure to lead. The Cal-EPA Lead
Toxicity Model (Leadspread) was used to
estimate the blood-lead levels associated with
lead concentrations in soil. A blood-lead level
(from intakes of all sources) of as low as 10
micrograms per deciliter (|ig/dl) has been shown
to decrease attention spans and reduce
intelligence quotients in children. According to
the model, blood lead concentrations remained
below 10 |ig/L when lead concentrations in the
soil were below 130 mg/kg (based on the 95%
UCL). Therefore, lead concentrations in the soil
of less than 130 mg/kg were eliminated from
evaluation by the model and assumed to be
harmless.
6.4.5 A summary of the toxicological proper-
ties, potential health effects, and the toxicity
criteria values of the COPCs is included in the
risk assessment (Montgomery Watson, 1996d).
6.5 Human Risk Characterization
6.5.1 Risk characterization integrates and
summarizes the toxicity and exposure assess-
ment information. The results of risk characteri-
zation are carcinogenic and noncarcinogenic
quantitative risk estimates for each medium for
each pathway.
6.5.2 Risks for noncancer effects were
quantified as a hazard index (HI), the ratio of
the exposure dose to the reference dose. If the
sum of the His for all noncarcinogens is less
than 1.0, then no chronic health effects are
expected. If the HI is greater than 1.0, adverse
health effects are possible. There is some
latitude in these conclusions depending on the
potential for underestimating or overestimating
the exposure dose.
6.5.3 For carcinogens, risk estimates are the
incremental probability that an individual will
develop cancer over a lifetime as a result of
exposure to a particular carcinogen or set of
carcinogens, that is, the excess lifetime cancer
risks (U.S. EPA, 1989a). According to the
revised National Contingency Plan (NCP) (U.S.
EPA, 1990b), carcinogenic risks from exposures
at a Comprehensive Environmental Response,
SEC-6.DOC
6-3
17 Febmary 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Compensation, and Liability Act (CERCLA)
site are in a potentially acceptable range if they
are between IxlO"4 and IxlO"6. It is generally
accepted that risks above this range require
attention, and risks below this range do not
require attention.
6.5.4 There is little potential for the depot to
become a residential development in the
foreseeable future. Potential future residents
were evaluated solely to provide benchmarks for
evaluating receptors with lower potential risk
and to fully inform the depot about suitable uses
for different parcels of land.
6.5.5 Summaries of the results of the baseline
human health risk assessment are shown in
Table 6-4 (for current receptors) and Table 6-5
(for potential future receptors). Risks to
potential future residents on the depot and annex
are summarized in the tables, but were not
considered in determining whether remediation
is required. Under existing conditions, these are
not considered to be potentially completed
pathways. If the use of the depot unexpectedly
changes, it will be necessary to reevaluate the
selected remedies for any area designated for
residential use.
6.5.6 EUs 8, 10, and 11 consist of multiple
sites and, therefore, required additional analysis
to identify risks on a site-by-site basis. For
EU 11, the HI for depot and construction
workers was less than 1 and the cancer risk was
less than IxlO"6; therefore, no remediation was
required for this EU (Montgomery Watson,
1997b).
6.5.7 At EU 8, the cancer risk to the depot
worker from ingestion, inhalation, and dermal
contact with surface soils was estimated at
SxlO"4. SWMU 27/Area 1 was the only site
within EU 8 where surface soil samples were
collected and analyzed (no concerns at other
sites were identified in the work plan) so the
cancer risk to the current depot worker is
attributed to this site (Montgomery Watson,
1997b). The surface and near-surface soil
exposure scenario for the depot worker and the
risk to a future construction worker are
summarized in Table 6-6. The exceedances are
associated with SWMU 27/Area 1 Building 206
and with Area 1 - Building 237. Area 1 -
Building 237 is not recommended for
remediation because the cancer risk (l.SxlO"6) is
associated with arsenic, which is present in
concentrations that are considered typical in the
western United States (Shacklette and
Boemgen, 1984).
6.5.8 At EU 10, the risks to a construction
worker from carcinogenic polycyclic aromatic
hydrocarbons (PAHs), chlordane, dieldrin,
DDD, DDE, DDT, polychlorinated biphenyls
(PCBs), dioxins/furans, aluminum, antimony,
barium, beryllium, and manganese account for
99% of the total cancer risk and 99.2% of the
hazard index (Montgomery Watson, 1997b).
The risk for each of these chemicals was
evaluated at each of the sites and is summarized
in Table 6-7. Exceedances of the benchmark
level were calculated at SWMUs 7, 8, and 30.
At SWMUs 7 and 24, the hazard index was
estimated at 9 and is associated with manganese.
The concentrations of manganese are typical of
those throughout the western United States
(Shacklette and Boerngen, 1984). Manganese
concentrations in the west range from <300 to
5,000 mg/kg. At SWMU 30, the cancer risk of
1.3xlO"6 was associated with beryllium. The
concentrations of beryllium were within the
normal range for beryllium in the western
United States (Shacklette and Boerngen, 1984),
and SWMU 30 is not considered to require
remediation. Beryllium concentrations in the
west range from <1 to 15 mg/kg.
6.5.9 Seven of the sites were identified as
requiring remediation to reduce the increased
lifetime cancer risk (ILCR) to no greater than
IxlO'6 and the hazard index to less than 1.0 for
current and likely potential future receptors
(off-depot residents, grader operators, day care
center children, depot workers, and construction
workers). These sites include:
• EU 1 (the on-depot groundwater portion of
OU 1) has dieldrin and VOCs in concentra-
tions that could present a potential, but
SEC-6.DOC
6-4
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
unlikely risk to depot workers if a well were
installed into the contaminant plume;
• EU 3 (the off-depot groundwater portion of
OU 1) has trichloroethene (TCE) that
presents risks to potential future annex
residents, who could be exposed through
ingestion or inhalation;
• SWMU 24 at EU 9 presents potential future
risks if a building with poor ventilation is
located on top of the area with the highest
concentrations of COPCs;
• SWMU 8 at EU 10 presents potential future
risks to construction workers who may be
exposed to organochlorine pesticides in the
soils;
• SWMUs 2 and 3 (EUs 4 and 5) present
potential risks to depot workers who may be
exposed to pesticides;
• Near surface soils in the northern comer of
the depot (EU 8) present potential future
risks to grader operators; and
• SWMU 27 in EU 8 presents potential risks
to depot workers if the foundation of
Building 206 is removed. PAHs and PCBs
are present in the soils underneath this
foundation.
6.5.10 The cancer risk for a depot worker
exposed to constituents (primarily polyaromatic
hydrocarbons, or PAHs) in surface soil at
SWMU I/Area 2 was estimated to equal IxlO'5.
This risk, while above the point of departure of
IxlO"6, is within the potentially acceptable range
of IxlO"6 to IxlO"4. Therefore, additional factors
need to be examined to determine whether
remediation of PAHs is appropriate for this site.
6.5.11 One of the factors is the potential for
exposure to occur. There is a degraded asphalt
pavement/compacted layer at the surface of this
area, and the risk assessment considered all
samples above 3.5 feet bgs as surface samples
when calculating worker risks. The shallowest
depth at which PAHs were detected was 2.0 feet
bgs (PAHs were the chemicals responsible for
most of the risk). However, workers typically
only come in contact with the top few inches of
soil. Consequently, unless the workers excavate
down two feet, there will not be a complete
pathway between the workers and the PAHs at
this site. The potential for workers to be
exposed to PAHs at this site is considered low.
6.5.12 It should also be noted that the
concentrations of carcinogenic PAHs at
SWMU I/Area 2 are typical of what people are
exposed to in their everyday lives. The average
total concentration of carcinogenic PAHs from
surface soil samples at SWMU I/Area 2 was
0.3 mg/kg. This compares favorably with the
median concentration of 1.1 mg/kg found by
Menzie, Potocki, and Santodonato (1992) in
urban background soils, and is in the range of
0.01 to 1.01 mg/kg that was found in rural soils.
Thus, even if exposure pathways are completed
at this site, workers will not be exposed to
greater concentrations of PAHs than what
people are exposed to on a daily basis in the
United States.
6.5.13 In summary, the risks to workers are in
an acceptable range; the exposure pathways for
which the risks were calculated are unlikely to
be completed, and the calculated risks are based
on PAH concentrations that are typically
encountered in the United States. Consequently,
no action is an appropriate risk management
decision for PAHs at SWMU I/Area 2.
6.5.14 The estimated cancer risk for a worker
at SWMU 4 was 1x10"*. This risk represents a
de minimis risk. It should also be noted that the
greatest risk associated with any individual
chemical is only 5xlO"7. No action is an
appropriate risk management decision with
respect to human health risks at this site.
6.5.15 Cancer risks at the Day Care Center
were previously estimated at IxlO"5. The
contaminated soil was removed from this site as
a time-critical removal action. The fill material
brought in to the Day Care Center had no
detectable concentrations of volatile organics,
semivolatile organics, pesticides, PCBs, or
SEC-6.DOC
6-5
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
petroleum hydrocarbons. All metals detected
were either below the EPA Region DC
preliminary remediation goal (PRO) for
residential soil or well below the background
threshold level for the site. The incremental risk
associated with soils remaining at the Day Care
Center was reduced to zero. No other areas
within DDJC-Tracy, as analyzed individually or
as part of the site-wide risk, required remedia-
tion to protect human health. Table 6-8
identifies the CoCs that require remediation and
the concentrations that are protective of human
health.
6.6 Ecological Risk Assessment
6.6.1 Background
6.6.1.1 The ecological risk assessment (ERA)
evaluated the actual or potential effects of a site
on plants and animals. The objective of the ERA
was to estimate the chemical risks to wildlife on
a site for those areas where wildlife habitat
currently exists and contamination has been
documented. DDJC-Tracy contains very few
areas suitable for wildlife habitat because of the
industrial/commercial land use at the facility.
Approximately 75% of the depot is covered with
buildings, roadways, and paved parking areas.
No known rare or endangered species of wildlife
have been documented at the depot. The depot is
within the historic range of the San Joaquin kit
fox (endangered), the giant garter snake
(threatened), Swainsons hawk (threatened), the
western yellow-billed cuckoo (threatened), and
the valley elderberry longhom beetle
(threatened). However, none of these species
has been sited during site visits. No critical
habitats or habitats of endangered species have
been identified. There are no sensitive habitats,
such as natural high quality wetlands, or aquatic
or terrestrial natural areas that provide habitat
for wildlife species on site. However, three on-
site areas, though they are man-made, can
provide habitat to wildlife. The three areas are:
• Depot-wide surface soil;
• Surface water and sediment in the SWMU 2
sewage lagoons, referred to as EU 4 in the
BRA (Montgomery Watson, 1996d); and
• Surface water and sediment in the SWMU 4
storm drain lagoon, referred to as EU 6 in
the human health risk assessment.
6.6.1.2 The approach used for the ERA
involves identifying chemicals of potential
ecological concern and conducting an exposure
assessment, a toxicity assessment, and a risk
characterization.
6.6.2 Identification of COPECs
Chemicals of potential ecological concern
(COPECs) are compounds that might have been
released to the environment through site
activities that have the potential to pose a health
risk to plants and animals. COPECs are
analogous to the COPCs that were identified for
their potential impacts to human health. The
following criteria were used to screen the list of
COPECs:
• The concentration of the COPEC was
compared with background levels;
• The toxicity of the COPEC to plants and
animals was assessed;
• The frequency of detection of the COPEC in
the samples was determined;
• The COPEC was compared with toxicity
benchmarks (e.g., Ambient Water Quality
Criteria [AWQC]); and
• Professional judgment was used.
6.6.3 Exposure Assessment
6.6.3.1 The exposure assessment for ecological
receptors was in many ways similar to the
identification of pathways and receptors for
human exposures. The assessment included:
• Defining those species or groups of species
that exist in each area that could be exposed
to the chemically affected media;
SEC-6.DOC
6-6
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
• Selecting the receptors of concern for which
to assess risks within each area;
• Determining the complete exposure
pathways for the selected receptors of
concern;
• Selecting the assessment and measurement
endpoints for each area; and
• Estimating the level of chemical exposure
based on the type of measurement endpoint
selected for each receptor of concern for
each complete exposure pathway.
6.6.3.2 Assessment endpoints are formal
expressions of environmental values to be
protected and refer to the characteristics of
populations and ecosystems defined over large
scales (e.g., maintenance of diverse population).
The assessment endpoint for the depot-wide
surface soil is to protect the terrestrial habitat at
DDJC-Tracy. The assessment endpoint for the
industrial and sewage lagoons (SWMUs 2
and 3) and storm drain lagoon (SWMU 4) is to
protect avian species that use these habitats
regardless of how the lagoons are managed.
6.6.4 Toxicity Assessment
Toxicity values, such as lowest observable
effects levels, no observable effects levels, and
no observable adverse effects levels were used
for the COPECs to define "acceptable" levels of
exposure for the receptors of concern.
6.6.5 Risk Characterization
6.6.5.1 The risk characterization integrates the
exposure into a quantitative characterization of
risk posed by the COPEC to each ecological
receptor. Only noncarcinogenic health effects
were assessed in the ERA because in the
environment the incidence of chemically
induced cancer is insignificant.
6.6.5.2 The only chemical risks to ecological
receptors at DDJC-Tracy are the adverse effects
of the industrial and sewage lagoons (SWMUs 2
and 3) and storm drain lagoon (SWMU 4) on
bird species, such as the spotted sandpiper and
the great blue heron (storm drain lagoon only).
The primary COPECs of concern in the lagoons
are DDD, DDT, and DDE (referred to
collectively as DDTR) and selenium. The
DDTR concentrations may reflect background
pesticide use in the area of the depot, rather than
use by the depot.
6.6.5.3 Additional monitoring will be
performed at SWMUs 2 and 3 to obtain site-
specific data that will be used to refine the risk
assessment and cleanup standards. The
following preliminary concentrations (see
Appendix D for calculations) are considered
protective of ecological receptors at SWMUs 2
and 3.
Concentration Protective of
Chemical Ecological Receptors (tig/kg)
Total DDX 241
Lead 28,300
Selenium 616
DDX = DDT + DDE + DDD
6.6.5.4 At SWMU 4, zinc has a hazard index
of 70, but this appears to be anomalously high
as it is derived from a sediment concentration of
350 mg/kg. This result implies a hazard at a
concentration as low as 5 mg/kg, whereas the
geometric mean soil concentration in the
western United States has been estimated at
55 mg/kg (Shacklette and Boemgen, 1984).
Additional monitoring will be performed at
SWMU 4 to obtain site-specific data that will be
used to refine the risk assessment and cleanup
standards. The following concentrations (see
Appendix D for calculations) are considered
protective of ecological receptors at SWMU 4
(the lead concentration is lower because
bioaccumulation has a greater impact on
herons).
Chemical
Concentration Protective of
Ecological Receptors (Mg/kg)
Total DDX
Lead
Selenium
241
5,130
616
DDX = DDT + DDE + DDD
SEC-6.DOC
6-7
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
6.6.5.5 Concentrations of ecological receptors
were conservatively estimated using literature
intake benchmarks. The total DDX
concentrations are based on values from Heath
et al. 1969 and Anderson et al. 1975.
Concentrations of selenium that are protective
of ecological receptors based on intake values
reported by Heir et al. 1989 and lead
concentrations are based on Edens et al. 1976
and Edens and Garlich 1983.
6.7 Evaluation of Threats to
Groundwater Quality
6.7.1 If any of the following criteria were met
for a constituent, it was suspected of posing a
potential threat to groundwater and was
included in the initial list of COPCs:
• The constituent was associated with
historical practices at the site and was
present at the site above the background soil
concentration; and
• The constituent has been detected in .
groundwater;
6.7.2 To evaluate the fate and transport of
these COPCs, a phased approach was used to
determine the potential future impacts of site
contaminants on groundwater. The phased
approach consisted of:
1. Screening-level analytical modeling to
assess the potential for migration of
contaminants in the vadose zone.
2. A water quality site assessment (WQSA) for
metals and pesticides to evaluate the
potential threat to beneficial uses and
background groundwater quality.
3. Equilibrium partitioning of vadose zone
contaminants to determine the maximum
theoretical concentration in soil water.
4. Approximate one-dimensional modeling in
the vadose zone to determine the likely site-
specific concentration in soil water.
5. Three-dimensional groundwater flow and
contaminant transport modeling to assess
the impact of contaminants reaching
groundwater at soil-water concentrations in
excess of beneficial use limits.
6.7.3 This analysis was applied to all sites with
the exception of the following:
• SWMU 11: Wastes previously believed to
have been associated with SWMU 11 were
instead disposed of at SWMU 10A.
• SWMU 64: Only a few samples marginally
exceeded background concentrations for
some metals.
• Area 1 Building 236: Methylene chloride
was detected at this site, but was determined
to be a laboratory contaminant. No other
COPCs were identified at the site.
• Day Care Center: Metals and pesticide
concentrations only marginally exceeded
background concentrations.
6.7.4 The potential for contaminants to migrate
through the vadose zone to groundwater was
first assessed using an analytical leachate model
(ALM). The model was applied to each site to
determine which COPCs might migrate down-
ward through the soil to groundwater within a
period of 100 years. The constituents that would
not reach groundwater within 100 years were
determined not to pose a threat to the beneficial
uses of groundwater or background groundwater
quality and were eliminated from further
consideration as COPCs.
6.7.5 A WQSA was also performed on the
metals and pesticides at each of the sites to
determine the potential for groundwater
contamination. Site-specific data, generic
factors, and background reference values were
used to calculate the relative attenuation
required to protect groundwater. Either the
Waste Extraction Test was run on the samples
with the highest concentrations of pesticides and
metals or the extract concentration was back-
calculated assuming the reaction of soils extract
SEC-6.DOC
6-8
17 Febniary 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
to total metals concentration was consistent. The
extract concentrations were used to determine
the attenuation required to protect beneficial
uses and background groundwater.
6.7.6 All organic COPCs were further
evaluated by equilibrium partitioning analysis
(this approach is less effective than the WQSA
for metals). The equilibrium partitioning
calculations used site-specific maximum
concentrations of COPCs in the soil to
determine the distribution of contaminants in the
soil, the soil water, and the soil gas. The
resulting equilibrium-based concentrations were
then compared with beneficial-use limits,
background threshold values, and practical
quantitation limits to determine if the theoretical
concentrations were in excess of these values.
COPCs with soil-water concentrations less than
the applicable background levels were
determined not to pose a threat to groundwater
and were eliminated from further consideration.
6.7.7 One-dimensional modeling further
evaluated the potential impacts of compounds
that were detected frequently or had already
impacted groundwater. The more exact results
of the numerical vadose zone modeling effort
replaced the preliminary screening analytical
modeling results. Numerical models were also
used to evaluate the fate and transport of
contaminants in groundwater and the response
of the simulated contaminant plumes to the
various design alternatives.
6.7.8 The results of the background threshold
evaluation, the ALM, the WQSA, the equili-
brium partitioning assessment, numerical vadose
zone modeling, and three-dimensional ground-
water modeling were combined to quantitatively
evaluate the overall threat to groundwater
quality at each site. Fate and transport modeling
was performed at sites identified as having data
gaps in the remedial investigation to
characterize the lateral and vertical extent of
contamination. The results of this assessment
for each site are noted in the site characteriza-
tion summaries in Section 5 and are summarized
in Table 6-9 for all COCs.
6.8 Conclusion
Actual or threatened released of hazardous
substances from this site, if not addressed by
implementing the response actions selected in
this ROD, may present an imminent and
substantial endangerment to public health,
welfare, or the environment.
SEC-6.DOC
6-9
17 February 1998
-------
53
£
Exposure Units SWMUs
EU1
EU2
EU3
EU4 2
EU5 3
EU6 4
EU7 I
EU8 5,20,21,23,27.29,
31,64
EU9 24
EU10 6,7,8,9,10,16,
22,30
EU11 10A, 11, 12, 14, 15
EU 12
EU 13 25
EU 14 33
EU15
EU = Exposure Unit
OU = Operable Unit
SWMU = Solid Waste Management Unit
UST = Underground Storage Tank
Table 6-1. Exposure Units, DDJC-Tracy
USTs Other Areas of Concern
On-depot ground water (OU I)
Tracy Annex groundwater (OU I)
Off-depot ground water (OU 1)
Area 2
2, 3, 4, 5. 6, 7. 9, 10, 12, 13, 14, Soil Contamination Area 1 - Bldg. 10, Bldg. 206, Bldg. 236, Bldg.
15, 18, 19, 22, 24, 25, 26. 27, 29 237; Bldg. 15 Drum Storage Area
28, 30, 32 Soil Contamination Area 3, Bldg. 22 Drum Storage Area
1 , 1 1 , 20, 23 Bldg. 30 Drum Storage Area
17 Bldg. 23
17 Bldg. 23
Day Care Center
I
S
i
D
a
n
5"
n
GO
n
k
a!
n
70
n
n
I
O
•n
O
n
-------
DC
to
Table 6-2. Summary of Current Pathways Evaluated in Detail
Exposure Unit Description
Off-depot Ground water (OU 1)
SWMU 2 - Present Sewage Lagoons
SWMU 3 - Industrial Waste Lagoons
SWMU 4 - Storm Drain Lagoon
SWMU 1 ; Area 2 - northern area of
the depot
Multiple SWMUs, USTs, and soil
contamination areas - northern area
of the depot
SWMU 24 - Building 247 Petroleum
Laboratory Waste Oil Tank
Day Care Center
Unvegetated and unpaved areas in
the southern, eastern, and northern
portions of the depot
1 Soil exposure includes sediment.
b Evaluated using soil-gas data modeled from
EU = Exposure Unit
OU = Operable Unit
SWMU = Solid Waste Management Unit
VOC = volatile organic compound
Detailed Evaluation
Inhalation of Inhalation of
Ground- Surface Inhalation VOCs, VOCs,
Receptor water Water Soil of Dust Outdoor Air Indoor Air
EU 3 Off-depot resident S
EU 4 Depot worker »"
EU 5 Depot worker ^*
EU 6 Depot worker •*
EU 7 Depot worker ^ S
EU 8 Depot worker S ^
EU9 Depot worker ^ ^
EU 15 Day Care Center ^ ^ ^b
children
Depot- Grader operator S S
Wide
EU 7 for the contaminated OU 1 groundwater.
D
a
n
i
I
^5
??
i
^
•Si
S.'
n
0
D
3
'y
n
a
r>
i'
70
t
n
O
^L.
o
"*•)
D
n
•5
n
5'
-------
Table 6-3. Summary of Potential Future Pathways Evaluated in Detail
Detailed Evaluation
Exposure Unit Description
Receptor
Ground- Surface
water Water
Soil
Inhalation Inhalation
Inhalation of VOCs, of VOCs,
of Dust Outdoor Air Indoor Air
On-dcpot ground water (OU 1)
Multiple SWMUs, USTs, and soil
contamination areas - northern area
of the depot
SWMU 24 - Building 247 Petroleum
Laboratory Waste Oil Tank
Multiple SWMUs, USTs, and Soil
Contamination Areas - eastern area
of the depot
UST 17 and soil contamination area
Building 23 - central part of the
depot
SWMU 33 - Industrial Waste
Pipeline
EU 1
Tracy Annex ground water (OU 1) EU 2
SWMU 2 - Present Sewage Lagoons EU 4
SWMU 3 - Industrial Waste Lagoons EU 5
SWMU 4 - Storm Drain Lagoon EU 6
Potential future depot
worker
Potential Annex resident
Potential on-dcpol resident
Potential on-dcpot resident
Potential on-dcpot resident
SWMU 1; Area 2 - northern area of EU 7
(he depot
Teenage swimmer
Construction worker
Potential on-dcpot resident
Construction worker
Potential on-dcpol resident
Construction worker
Potential on-dcpot resident
EU 10 Construction worker
EU8
EU9
EU 12
Potential on-depot resident
Construction worker
Potential on-depot resident
EU 14 Construction worker
Potential on-depot resident
•/*
s
s
/
-------
Table 6-3. (Continued)
Detailed Evaluation
Inhalation Inhalation
Ground- Surface Inhalation of VOCs, of VOCs,
Exposure Unit Description Receptor water Water Soil of Dust Outdoor Air Indoor Air
Day Care Center EU 15 Potential on-dcpol resident / /
UnvcgcUitcd and unpavcd ureas in the Depot- Potential on-dcpol resident S •/
southern, eastern, and northern ends Wide
of the depot
' Soil exposure includes sediment.
EU = Exposure Unit
OU = Operable Unit
SWMU = Solid Waste Management Unit
UST = Underground Storage Tank
VOC = volatile organic compound
a
o
n
H
a
n
•5
3
n
3
n
i
i
O
}
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-4. Summary of Human Health
Risks to Current Receptors, DDJC-Tracy
Cancer Risk
Hazard Index
Between
1x10*and
1x10* 21X10"4
Off-Depot Groundwater (Exposure Unit 3)
Off-Depot Resident 1 x 103
SWMU 2 - Sewage Lagoons (Exposure Unit 4)
Depot Worker 2xlO'7
SWMU 3 - Industrial Waste Lagoons (Exposure
UnitS) 3xlQ-(
Depot Worker
SWMU 4 - Storm Drain Lagoon (Exposure Unit 6)
Depot Worker 1x10"*
SWMU I/Area 2 - Old Sewage Lagoon/Drum Storage
Area (Exposure Unit 7)
Depot Worker 1x10
Sites in Northern Portion of the Depot (Exposure
Unit 8)
Depot Worker
SWMU 24 - Building 247 Petroleum Laboratory
(Exposure Unit 9)
Depot Worker - Indoor Air NA
Depot Worker - Outdoor Air NA
Sites in the Eastern Portion of the Depot (Exposure to 3xlO'7
Unit 10)
Sites in the Southern Portion of the Depot (Exposure 1 x 108
Unit 11)
SWMU 33 - Industrial Waste Pipeline (Exposure 1 x 108
Unit 14)
Day Care Center (Exposure Unit 15)
Day Care Center Children 1 x 10':
Depot-Wide Surface/Near-Surface Soil
Grader Operator - Eastern 2xlO'7
Grader Operator - Southern 4xlO'8
Sa.b
0.9
0.003
0.07
0.01
0.07
3x10^ 0.9
0.71
0.06
0.005
0.00001
0.0007
0.3"
0.6
0.3
SEC-6.DOC
6-14
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-4. (Continued)
' Risk estimates are for soil contamination that has since been remediated. There is also a hazard index potentially greater than one
or a cancer risk potentially greater than IxlO'6 from indoor air if a building is constructed directly over the area of greatest
contamination.
h The cancer risk is likely between IxKT4 and 1x10'* if polycyclic aromatic hydrocarbons are substantially more carcinogenic via
dermal than via oral exposure.
c The cancer risk likely exceeds UK)"4 if polycyclic aromatic hydrocarbons are substantially more carcinogenic via dermal than via
oral exposure.
d Risk estimates are for soil contamination that has since been remediated.
NA = Not applicable; no exposure to carcinogens by this receptor.
SWMLJ = Solid Waste Management Unit
SEC-6.DOC 6-15 17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-5. Summary of Potential Human Health Risks to Future Receptors,
DDJC-Tracy, California
Cancer Risk Hazard Index
Between
IxlO"6 and
•clxlO"6 1x10"* S1x10~* <1 >1
On-Depot Groundwater (Exposure Unit 1)
Depot Worker 2xlO"2
Exposure Unit 2 (Annex Groundwater)
Annex Resident0 IxlO"4 2
SWMU 2-Sewage Lagoons (Exposure Unit 4)
On-Depot Residents0 SxlO"5 2
SWMU 3-Industrial Lagoons (Exposure Unit 5)
On-Depot Residents0 4x10"* 10
SWMU 4-Storm Drain Lagoon (Exposure Unit 6)
On-Depot Residents0 9x10"s 3
Teenage Swimmer0 IxlO"6 0.05
SWMU I/Area 2-Old Sewage Lagoon/Drum
Storage Area (Exposure Unit 7)
Construction Worker IxlO"6 10
On-Depot Residents0 SxlO5 1
Sites in Northern Portion of the Depot (Exposure
UnitS)
Construction Worker SxlO"6 0.3
On-Depot Residents0 2x10^ 1
SWMU 24-Building 247 Petroleum Laboratory
(Exposure Unit 9)
Construction Worker 1 x 10"6 10
On-Depot Residents0 6xlO"5 6
Sites in Eastern Portion of the Depot (Exposure
Unit 10)
Construction Worker 2xlO"6 9
On-Depot Residents0 6xlO"5 3
Sites in Southern Portion of the Depot (Exposure
Unit 11)
Construction Worker 9xlO"7 0.3
On-Depot Residents0 2xlO'5 0.8
Building 23 and UST 17 (Exposure Unit 12)
Construction Worker IxlO"9 0.0003
On-Depot Residents0 SxlO"8 0.001
SWMU 33-Industrial Waste Pipeline (Exposure
Unit 14)
Construction Worker 9xlO"9 0.2
On-Depot Residents0 4xlO"7 0.4
SEC-6.DOC 6-16 17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-5. (Continued)
Cancer Risk Hazard Index
Between
1X10"4 £1x10"* £1 >1
Day Care Center (Exposure Unit 15)
On-Depot Residents 3x105b 0.5b
Depot-Wide Surface/Near-Surface Soil
Construction Worker (Grader Operator) - Northern 9x 10'7 30
On-Depot Residents - Northern 3x10"* 20
On-Depot Residents - Eastern 9xlO"5 2
On-Depot Residents - Southern 2xlO'5 0.9
* The potential cancer risk would likely exceed IxlO"4 if polyaromatic hydrocarbons are substantially more carcinogenic via
dermal than via oral exposure.
h Risk estimates are for soil contamination that has since been remediated.
c Not considered a potentially completed pathway or used as a basis for remediation.
SWMU = Solid Waste Management Unit
UST = Underground Storage Tank
SEC-6.DOC 6-17 17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
SWMU5
SWMU 20/23
SWMU21
SWMU 27/Area 1
SWMU 29
SWMU 31
SWMU 64
Area 1 Bldg. 236
Area 1 Bldg. 237
Building 15
UST2
UST3
UST4
UST5
UST6
UST7
UST9
UST10
UST12
UST13
UST14
UST15
UST18
UST19
UST22
UST24
UST25
UST 26
UST27
UST 29
Table 6-6. Summary of
Depot Worker
Surface Soil
N/A
N/A
N/A
Bldg. 206 3x10^
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Cancer Risks at EU 8
Depot Worker
Near-Surface Soil
0
2.2x1 0'7
0
1.7x10'"
0
0
0
0
9.6x1 0'7
0
0
0
0
0
0
0
0
0
0
0
1.8x10^
0
0
0
0
0
5.6xlO'6
0
0
0
Construction Worker
Surface and Near-
Surface Soil
l.SxlQ-7
0
0
2.1xl05
0
l.SxlO'7
0
0
1.3xlQ-6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
SEC-6.DOC
6-18
17 Febniaiy 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-7. Summary of Risks at EU 10
Construction Worker
Cancer Risk
Hazard Index
SWMU6
SWMU7
SWMU8
SWMU9
SWMU 10
SWMU 16
SWMU 22
SWMU 30
Area 3
BWg. 22DSA
UST28
UST30
UST32
8.8xlO'8
4.2x10'7
2.7x10'5
6.0x10'7
0
8.7xlQ-7
8.7xlO'7
1.3xlO'6
0
0
0
0
0
2.7xlO'2
9.2
17
l.OxlO'1
l.OxlO'1
S.OxlO3
1.7xlO'3
2.5xlO'3
0
0
0
0
0
SEC-6.DOC
6-19
17 Febmaiy 1998
-------
Table 6-8. COCs That Require Remediation for the Protection of Human Health
Site/COC
Concentration Protective
Media of Human Receptors
Basis
Pathway
OU 1 Groundwalcr*
Trichloroethene Groundwater
1,1-Dichloroelhcnc Groundwalcr
Tctrachlorocthcnc Groundwalcr
Dicldrin Groundwater
SWMU 24
Toluene Soil
SWMU 8
Total DDX Soil
Dicldrin Soil
Near-Surface Soils in Northern
Corner of Depot
Arsenic Soil
Manganese Soil
SWMU 27
Benzo(a)pyrene Soil
Total PAHs Soil
PCBs (Arochlor - 1260) Soil
5.0ng/L
6.
5.0
0.05 ug/L
16,000 ug/L
30,000 ug/kg
600 ug/kg
48 ug/kg
l,000ug/kg
l.OOOng/kg
15,000 ug/kg
1.000 ug/kg
Federal MCL
California MCL
Federal MCL
California Action Level
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure
Inhalation
Dermal
Ingestion
Inhalation, Ingestion
Inhalation, Ingestion
Dermal, Ingestion
Dermal, Ingestion
Dermal. Ingestion
' The estimated ILCR for on-depot workers exposed to MCL concentrations of CoCs is approximately 4xlO'4. Chloroform and 1,1-dichloroethene contribute approximately 75
percent and 18 percent, respectively, to the total risk at MCL concentrations.
DDX = Sum of DDD, DDE, and DDT concentrations
MCL = maximum contaminant level
C
r
V
I
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-9. Summary of Fate and Transport and Water Quality Site Assessment Results
Slte/COC
SWMU I/Area 2
VOCs(jig/kg)
Tetrachloroethcne (PCE)
Trichloroethene (TCE)
Threat to
Beneficial
Uses In
Groundwater
Yes
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses*
2.4
1.3
Equilibrium
Partitioning Umit
Protective of
Background Water
Quality6
0.2
0.3
Model Level'
14
NE
Area 1 Building 237
VQCs (ug/kg)
tetrochloroethene (PCE)
Yes
Yes
2.4
0.2
IS
Area 3
VOCs(ug/kg)
Tetrachloroethene (PCE)
Trichloroethylene (TCE)
SWMU 4
SVOCs (ng/kg)
bis(2-Etylhexyl)phthalatc
Huoranthene
Phcnanthrene
Pyrcne
Pesticides (ug/kg)
Carbaryl
Caibofuran
Chlordane, total
2,4-D
Dieldtin
SWMU 6
Pesticides and Herbicides (ug/kg)
Dicamba
Dicldrin
Endrin
Heptachlor
Lindane
2.4.5-T
SWMU 7
VOCs (ug/kg) - Pit F only
1,2-DCE
Trichloroethene (TCE)
SVOCs (Jig/kg) - Pit C only
bis(2-Ethylhexyl)phthp'«'c
Pesticides (jig/kg) - P" c on'y
Diclcf"-
ijnuron
Pesticides and Herbicides (ug/kg) -
Pit D only
2.4-D
Dieldrin
Linuron
Simazine
TfetcoleuniHydrocarbons (mg/kg) •
Pit D only —
TPH as diesel
Y«s
Yes
Yes
No
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Ye*
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
2.4
1.3
244
8.023
14
5.610
24
4
10
11
0.1
1.3
0.1
21
0.1
0.2
14
1.2
1.3
244
0.1
1
11
0.1
1
1
NE
0.2
0.3
122
27
14
27
0.2
0.2
10
0.02
0.01
0.01
0.0 1
0.1
0.04
<0.01
0.02
0.2
0.3
122
0.01
0.1
0.01
0.01
0.01
0.1
NE
22
32
NR
NR
NR
NR
NR
NR
NR
NR
NR
NE
3d
NE
NE
5
NE
NE
NE
NR
3
NE
NE
3
3
NE
NE
SEC-6.DOC
6-21
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-9. (Continued)
Constituent
SWMU8
SVOCs (ug/kg)
bis(2-Elhylhexyl)phthalate
Diethylphthalaie
2,4-Dinilrololuene
Naphthalene
Pesticides and Herbicides (Jig/kg)
Chlordane, total
2,4-D
ODD
DDE
DDT
DDX, total
Dieldrin
Lindane
Linuron
MCPA
Simazine
Petroleum Hydrocarbons (rag/kg)
TPH as gasoline
TPH as diesel
TPH as motor oil
SWMU 20 and Area 1
VOCsGig/kg)
Trichloroethene (TCE)
Ethylbenzene
Xylenes
SVOCs (ug/kg)
Diethylphthalate
2,4-Dmilrophenol
Pentachlorophenol
2,4.6-Trichlorophenol
Pesticides and Herbicides (ug/kg)
Dieldrin
Mcthiocarb
MCPA
Linuron
Petroleum Hydrocarbons (mg/kg)
TPH as diesel
SWMXJ24
VOCs (ug/kg)
Acetone
2-Butanone (MEK)
Ethylbenzene
2-Hexanone
4-Methyl-2-pentanone
(MffiK)
Toluene
Xylenes
SVOCs (Mg/kg)
2,4-DimethylphenoI
Fluoranthene
2-Methylnaphthalene
4-Melhylphenol
Naphthalene
Threat to
Beneficial
Uses in
Groundwater
No
No
Yes
Yes
Yes
Yes
Yes
No
No
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses*
244
1.222
9
21
10
11
81
NA
7
NA
O.I
0.2
1
1
1
NE
NE
NE
1.3
653
582
1.222
11
227
10
0.1
1
1
1
NE
89
30
653
0.3
436
56
582
34
8,023
6
17
21
Equilibrium
Partitioning Umlt
Protective of
Background Water
Quality"
122
0.2
0.4
21
10
0.02
3
15
1
NA
0.01
0.004
0.1
0.1
0.1
NE
NE
NE
0.3
1
0.3
0.2
5
7
7
0.01
1
O.I
0.1
NE
0.4
0.3
1
3
6
1
21
Model Level'
NR
NE
NE
NE
NE
NE
NR
NR
NR
NE
2
NE
NE
NE
NE
NE
NE
NE
36
NE
NE
NE
NE
NE
NE
27
NE
NE
NE
NE
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
SEC-6.DOC
6-22
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-9. (Continued)
Threat to Threat to
Beneficial Background
Uses In Ground water
Constituent Groundwater Quality
SWMU 24 (cont.)
SVOCs (ug/kg)
Phenanthrene
Phenol
Pyrene
Petroleum Hydrocarbons (mg/kg)
TPH as gasoline
TPH as diesel
Pesticides and PCBs (Mg/kg)
PCBs(Aroclorl260)
Carboruran
Undone
Phorate
Ronnel
SWMU27
VOCs (ug/kg)
Trichloroethcne (TCE)
SVOCs (Mg/kg)
Benzo(a)pyrene
Total PAHs
Pesticides, Herbicides, and PCBs (Ug/kg)
2,4-D
MCPA
PCBs (Aroclor 1260)
2.4.5-T
Petroleum Hydrocarbons (mg/kg)
TPH as motor oil
Building 30 Drum Storage Area
SVOCs (ug/kg)
Benzyl alcohol
bis(2-Ethylhexyl)phthalate
Diethylphthalate
di-n-Burylphthalate
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
Yes
No
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses*
14
1
5,610
NE
NE
182
4
0.2
17
1.038
1.3
NA
NA
11
1
NA
14
NE
1.618
244
1.222
83,401
Equilibrium
Partitioning Limit
Protective of
Background Water
Quality"
14
0.3
27
NE
NE
45
0.2
0.004
2
1
0.3
NA
NA
0.02
O.I
NA
0.02
NE
0.3
122
0.2
119
Model Level0
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
36e
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
Surface and Near-Surface Soils Northern Depot Area
Metals (ug/kg)
Arsenic
Manganese
SWMU 2 and SWMU 3
SVOCs (ug/kg)
bis(2-Ethylhexyl)phthalate
2.4-Dimelhylphenol
di-n-Burylphihalate
4-Methylphenol
Pesticides (Ug/kg)
Aldrin
Chlordane. total
ODD
DDE
DDT
DDX. total
Dieldrin
Diuron
Endrin
No
No
Yes
No
No
Yes
Yes
No
No
No
No
No
Yes
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
244
34
83,401
17
3
10
81
484
7
NA
0.1
4
21
NA
NA
122
1
119
1
0.3
10
3
15
1
NA
0.01
0.1
0.1
NE
NE
NE
NE
NE
NE
NE
NR
NR
NR
NR
NR
0.1(11)'
NE
120(120)
SEC-6.DOC
6-23
17 Febniary 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 6-9. (Continued)
Threat to
Beneficial
Uses In
Constituent Groundwater
Threat to
Background
Groundwater
Quality
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses'
Equilibrium
Partitioning Limit
Protective of
Background Water
Quality1'
Model Level0
SWMU 2 and SWMU 3 (cont.)
SVOCs (Hg/kg)
Undone (Camma-BHC)
Monuron
2.4-D
Heptachlor epoxide
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
0.2
0.04
11
0.004
0.004
0.01
0.2
0.002
NE
NE
NE
NE
SWMU 33
VOCs(ug/kg)
Xylenes No
SVOCs (Ug/kg)
Diethylphthalate No
di-n-Butylphthalate No
Naphthalene Yes
Pesticides (Mg/kg)
Aldrin No
Caibaryl Yes
Dieldrin No
Methiocarb Yes
Petroleum Hydrocarbons (mg/kg)
TPH as diesel Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
582
1,222
83,401
21
3
24
0.1
1
NE
0.3
0.2
119
21
0.3
0.2
0.01
1
NE
NE
NE
NE
NE
NE
NE
27
NE
NE
' Equilibrium partitioning limit based on comparison of MCLs to soil-water concentrations.
* Equilibrium partitioning limit based on comparison of detection limit to soil-water concentrations.
c Model level derived using vadose zone and groundwater modeling, and based on predicted achievement of MCL in groundwater at the
source area.
d Model levels derived using vadose zone and groundwater modeling, and based on predicted achievement of numerical beneficial use
limit in groundwater at the source area.
e Model level extrapolated from Area 1 Bldg. 10. which has similar concentrations and distribution of TCE.
' The value in parentheses represents the dieldrin cleanup level if the soil management cell is constructed at SWMU 3.
NE = not evaluated
NR = not required
NA = not applicable
SEC-6.DOC
6-24
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
7.0 DESCRIPTION OF
ALTERNATIVES
7.1 General Overview
7.1.1 Applicable or relevant and appropriate
requirements (ARARs) and remedial action
objectives (RAOs) were developed for each site
that requires remedial action at Defense Depot
San Joaquin (DDJC)-Tracy, In most cases, the
RAOs were location-specific. Cleanup
standards, if not already dictated by regulatory
requirements, were defined to meet the ARARs
and RAOs for each site. Several remedial
alternatives were developed and evaluated for
each site. ARARs, RAOs, cleanup standards,
and remedial alternatives are discussed in the
following sections.
7.2 Applicable or Relevant and
Appropriate Requirements
7.2.1 Background
7.2.1.1 ARARs are federal and state environ-
mental and facility siting requirements that
remedial actions at Superfund sites must comply
with. The Comprehensive Environmental
Response, Compensation, and Liability Act of
1980, as amended by the Superfund
Amendments and Reauthorization Act (SARA)
of 1986 (collectively, CERCLA), and the
National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) require
compliance with ARARs. Only those state
requirements that are more stringent than federal
ARARs and are legally enforceable and
consistently enforced statewide may be ARARs.
7.2.1.2 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. In addition to ARARs,
guidance documents and other nonpromulgated
criteria can be considered in evaluating remedial
alternatives. These nonpromulgated guidance or
criteria are referred to as criteria or guidelines to
be considered (TBCs). For selected remedies,
appropriate TBCs are identified as Performance
Standards in Section 10.0.
7.2.2 Definition of ARARs and Other
Criteria or Guidelines to be
Considered
7.2.2.1 An ARAR is an "applicable" or
"relevant and appropriate" requirement.
According to the NCP (40 CFR Part 300),
"applicable requirements," "relevant and
appropriate requirements," and "criteria or
guidelines TBC" are defined as follows:
7.2.2.2 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 in a timely manner and that are
more stringent than federal requirements may be
applicable.
7.2.2.3 Relevant and Appropriate Require-
ments are those cleanup standards, standards of
control, and other substantive environmental
protection requirements, criteria, or limitations
promulgated under federal or state environ-
mental 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.
7.2.2.4 Advisories, Criteria, Guidance, or
Proposed Standards TBCs consist of
nonpromulgated advisories, criteria, or guidance
documents that were developed by the U.S.
EPA, other federal agencies, or states that may
SEC-7.DOC
7-1
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
be useful in developing CERCLA remedies. The
TBC criteria and guidelines may be used as the
agencies deem appropriate.
7.2.3 Identification of ARARs
7.2.3.1 Neither CERCLA nor the NCP
provides across-the-board standards for
determining whether a particular remedy effects
an adequate cleanup at a particular site. Rather,
the process recognizes that each site has unique
characteristics that must be evaluated and
considered against the requirements that apply
under the given circumstances. Therefore, the
identification of ARARs is done on a
site-specific basis.
7.2.3.2 The ARARs are identified and
considered at the following points in the
remedial process:
• As part of the RI/FS scoping;
• During the site characterization phase of the
RI;
• During the development of remedial
alternatives;
• During the detailed analysis of the remedial
alternatives;
• When an alternative is selected (see Section
10 of this document); and
• During the remedial design.
7.2.3.3 CERCLA actions may have to comply
with three different types of ARARs: chemical
specific, location specific, and action specific. A
detailed analysis of ARARs for the selected
remedies is provided in Section 10. The
following discussion of ARARs identifies the
ARARs used in the development and evaluation
of alternatives.
7.2.4 Chemical-Specific ARARs
7.2.4.1 Chemical-specific ARARs are health-
or risk-based concentration limits or limits
specified by treatment methodologies for
various environmental media (i.e., groundwater,
surface water, air, soil, and sediment) that are
established for a specific chemical that may be
present in a specific medium at the site or that
may be discharged to the site during remedial
activities. The following discussion summarizes
the ARARs for each environmental medium of
concern at the sites.
7.2.4.2 Soil. California has promulgated
standards for the disposal of waste soil under
Division 4.5 of Title 22 of the California Code
of Regulations (CCR) (22 CCR). Under Title
22, a waste is hazardous if it contains any metals
at concentrations exceeding the total threshold
limit concentrations (TTLCs). A waste is also
hazardous if it contains extractable concentra-
tions exceeding soluble threshold limit
concentrations (STLCs). The extractable
concentrations are determined by performing the
Waste Extraction Test (WET) on samples of the
waste soil. The WET is used to determine
whether a waste soil is hazardous. If the
concentration (in milligrams per liter) of any of
the listed metals is greater than the STLC value
the waste is hazardous. It is also hazardous if the
concentration equals or exceeds the TTLC
value. These chemical-specific requirements are
ARARs for remedial activities involving the
disposal of waste soil. Thus, these ARARs are
also action specific.
7.2.4.3 Sediment. No federal or California
chemical-specific ARARs have been established
for sediment. TTLCs and STLCs promulgated
under Title 22 are action-specific ARARs for
the disposal of sediment.
7.2.4.4 Surface Water. The federal Clean
Water Act (CWA) requires the establishment of
guidelines and standards to control the direct or
indirect discharge of pollutants to waters of the
United States. Section 303 of the CWA requires
each state to develop water quality standards
based on federal water quality criteria to protect
existing and attainable uses of the receiving
waters (U.S. EPA, 1988b). In California, water
quality standards are a combination of the
designated beneficial uses of water and water
SEC-7.DOC
7-2
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
quality objectives (numerical or narrative limits)
to protect those uses. In California, water quality
standards are promulgated by the State and
Regional Water Boards in Water Quality
Control Plans or "Basin Plans." DDJC-Tracy is
included in the Basin Plan for the Central Valley
Region-Sacramento River and San Joaquin
River Basins (CVRWQCB, 1994).
7.2.4.5 According to California State Water
Resources Control Board (SWRCB) Resolution
No. 88-63, all surface waters in California are
considered to be suitable, or potentially suitable,
for municipal or domestic water supply unless
exempted. Surface water systems designed or
modified to collect or treat storm-water runoff
are exempt; thus, municipal and domestic water
supplies are not considered beneficial uses for
the storm drain lagoon at SWMU 4. The
percolation area at SWMU 2 is part of the
wastewater treatment system and is also exempt.
The lined ponds (SWMU 3) have been removed
and incorporated into the percolation area.
7.2.4.6 Groundwater. Drinking water
standards (California and Federal) Maximum
Contaminant Levels (MCLs) are chemical-
specific ARARs for contaminants in
groundwater at DDJC-Tracy. Cleanup standards
were developed consistent with the MCLs.
According to SWRCB Resolution No. 88-63, all
groundwater in California is considered suitable,
or potentially suitable, for municipal or
domestic water supply.
7.2.5 Location-Specific ARARs
7.2.5.1 Federal, state, and regional location-
specific ARARs are restrictions placed on the
constituent concentration or the activities to be
conducted at a site based on the location of the
site. Examples of special locations with
potential ARARs include flood plains, fault
zones, wetlands, historic places, and sensitive
ecosystems or habitats. DDJC-Tracy is not
located within any floodplains or wetlands;
therefore, ARARs specific to these types of
locations are not discussed further.
7.2.5.2 National Historic Preservation Act.
No buildings or locations at DDJC-Tracy have
been or are being considered for the National
Registry of Historic Sites (WCC, 1992a).
Hence, the National Historic Preservation Act is
not a location-specific ARAR for DDJC-Tracy.
7.2.5.3 Federal and California Endangered
Species Act. These acts requires that all federal
agencies carry out programs for the conservation
of listed endangered or threatened wildlife
species by ensuring that actions authorized,
funded, or carried out by federal agencies are
not likely to jeopardize the endangered or
threatened species. No known rare or
endangered species of wildlife have been
documented within the depot. However, the
depot is located within the historic range of five
sensitive species (see Section 6.6.1). Both
statutes require consultation with the
Department of the Interior and the California
Department of Fish and Game. The Endangered
Species Act is a location-specific ARAR for
DDJC-Tracy.
7.2.5.4 Aquatic Habitats. The California Fish
and Game Code (Division 6, Part 1, Chapter 6)
prohibits the deposition of any substance
deleterious to fish, plant, or bird life. This code
applies to the storm drain lagoon (SWMU 4)
located in the northern portion of DDJC-Tracy.
Therefore, this code is a location-specific
ARAR for DDJC-Tracy.
7.2.6 Action-Specific ARARs
7.2.6.1 Action-specific ARARs are
technology- or activity-based requirements or
limitations for actions conducted at a site during
remediation. Tables 10-2 and 10-3 provide a
complete listing of action-specific ARARs. The
following subsections summarize the key action-
specific ARARs used in the screening of
alternatives.
7.2.6.2 Hazardous Waste Management. The
Resource Conservation and Recovery Act
(RCRA), as codified in 40 CFR 262, 263, and
264, outlines the requirements for the
transportation, storage, and disposal of
SEC-7.DOC
7-3
2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
hazardous wastes. The State of California has its
own hazardous waste regulations, which are
presented in Division 4.5 of Title 22 of the
CCR, entitled "Environmental Health Standards
for the Management of Hazardous Wastes."
Hazardous wastes generated in California must
comply with both the California and the federal
hazardous waste programs, although the
California program is generally more stringent
and expansive than the federal program. Some
of the wastes that may be handled during
remedial activities conducted for DDJC-Tracy
may be considered hazardous wastes. The
specific requirements that may be ARARs will
depend on the types of wastes handled and the
specific remedial activities performed at
DDJC-Tracy.
7.2.6.3 Title 23, Division 3, Chapter 15 of the
CCR and Title 27, Division 2, Subdivision 1 of
the CCR outlines ARARs that must be satisfied
for investigating, monitoring, and selecting all
remedial alternatives for landfills and all other
source contaminant sites involving a discharge
to land. Activities included in this program are
the issuance of waste discharge requirements
(WDRs) by the Regional Water Quality Control
Board (RWQCB) for the discharge of
hazardous, designated, and nonhazardous solid
wastes to land and the oversight of corrective
actions at leaking waste management units.
Articles 2 and 3 cover waste management unit
classification, management, and siting. Article 5
covers water quality monitoring and response
programs and Articles 8 and 9 cover closure and
compliance procedures.
7.2.6.4 Landfarming. RCRA and CCR
Title 22 regulations regarding landfarming are
applicable to on-site bioremediation for
DDJC-Tracy. These regulations require owners
of landfarming operations to ensure that no
migration of hazardous constituents occurs.
Title 27, Division 2, Subdivision 1 of the CCR,
which prescribes standards for discharges of
wastes to land, stipulates design requirements
for landfarming treatment pads. In addition, the
San Joaquin County Air Pollution Control
District limits the organic content of soils
treated with landfarming to below 5,000 mg/kg.
7.2.6.5 Discharge to Surface Water. The
CWA regulates the discharge of pollutants into
surface water. The National Pollutant Discharge
Elimination System (NPDES) provides the
permit requirements for a point-discharge into
marine or surface waters. The NPDES
requirements implemented by the State Water
Resources Control Board Order No. 92-08
DWQ (specifically, general permit
5B39SO13143) are applicable to storm water
discharges to the West Side Irrigation District
Canal which discharges to Sugar Cut at the Old
River. The narrative toxicity water quality
objective for inland surface waters, as set forth
in the Basin Plan for the Central Valley Region
(Cal-EPA CVRWQCB, 1994), apply as an
ARAR for SWMU 4.
7.2.6.6 Discharge to Publicly Owned
Treatment Works. The general pretreatment
regulations for existing and new sources of
pollution (40 CFR 403) establish standards for
the control of pollutants passing through and
interfering with treatment processes in publicly
owned treatment works (POTWs). These
regulations are not applicable because remedial
actions at DDJC-Tracy will not involve the
discharge of process water to a POTW.
7.2.6.7 The Clean Air Act. The Clean Air Act
(CAA) regulates air emissions; certain titles of
the CAA and its amendments are ARARs for
CERCLA response actions or technologies.
Under Section 110 of the CAA (Title I), each
state has primary responsibility for ensuring air
quality within its geographic area. Through the
state implementation plan (SIP), the state
establishes a program for regulating stationary
and mobile sources that maintains and achieves
the national ambient air quality standards
(NAAQS). SJPs include emission standards,
monitoring, record keeping enforcement, and
other measures (e.g., economic incentives). The
emission standards and monitoring requirements
are substantive requirements and are relevant
and appropriate for DDJC-Tracy for activities
such as dust control, air stripping, and carbon
adsorption treatment. The record keeping,
enforcement, and other measures are
administrative requirements and therefore are
not ARARs.
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7.2.6.8 New Source Performance Standards.
Under Section 111 of the CAA, new source
performance standards (NSPS) are defined, as
are nationally uniform emission standards for
major new stationary sources, particularly for
industrial source categories. At present, the
NSPS source categories coincide with only a
few of the air pollutant emission sources
typically found at CERCLA sites. Thus, the
NSPS are not usually considered "applicable" to
CERCLA activities. However, they may be
"relevant and appropriate" to the CERCLA
action if the pollutant emitted and the
technology employed during the cleanup action
are sufficiently similar to the pollutant and
source category regulated by an NSPS. For
CERCLA municipal landfill remediations (i.e.,
bioremediation), these requirements would be
ARARs after the rule's promulgation. Until
these requirements are promulgated, they are
TBCs.
7.2.6.9 National Emission Standards for
Hazardous Air Pollutants. Section 112 of the
CAA and Section 301 (Title IE) of the 1990
CAA amendments required the U.S. EPA to set
uniform national emission standards for
hazardous air pollutants. These standards
address new and existing sources, and are
oriented toward particular hazardous pollutants
at their point of emission from specific sources.
The U.S. EPA has established a list of the major
area source categories that emit or may emit any
of the 189 listed hazardous air pollutants.
Treatment standards will be ARARs and they
could apply to emissions from tanks and
containers, municipal landfills, or surface
impoundments.
7.2.6.10 Operating Permits. The 1990 CAA
amendments (Title V, Sections 501 and 502)
require every major source (and certain other
sources) regulated under the CAA to obtain an
operating permit. CERCLA on-site actions are
not subject to the administrative procedures and
permit requirements. However, these actions
must comply with any substantive standards
associated with the permit programs that are
determined to be ARARs. At DDJC-Tracy, the
standards could apply to some of the waste
management units, or to the soil containment or
removal technology, or the leachate and
groundwater control technology.
7.2.6.11 RCRA Standards. Regulations under
RCRA address air pollutant emissions from
several activities that may occur at CERCLA
sites (e.g., incineration, or air stripping). These
RCRA regulations are ARARs.
7.2.6.12 California Air Regulations.
California has generally adopted more stringent
air standards and regulations than the CAA.
DDJC-Tracy is under the supervision of the San
Joaquin County Unified Air Pollution Control
District. The District does not have any
prohibitory rules that would apply to remedial
activities at DDJC-Tracy; however, the District
requires that a minimum of 95 percent of the
contaminants released to the air during any
remedial action be controlled the best available
technology has been used. The CAA and any
rules promulgated by the local air quality
management district may be ARARs for some of
the activities and emissions at DDJC-Tracy.
7.2.6.13 Groundwater Extraction,
Treatment, and Discharge. California's
SWRCB Resolution No. 68-16 (the state's
Antidegradation Policy) requires that high-
quality waters be maintained to the maximum
extent possible. This resolution applies most
often at CERCLA cleanups that involve
extracting, treating, and discharging treated
groundwater. Any activities that result in
discharges (including injection) to high-quality
water are required to use the best practicable
treatment or method of control of the discharge
necessary to avoid a pollution or nuisance and to
maintain water quality. Best practicable
treatment takes into account technical and
economic feasibility. Also, hydraulic control of
the contaminant plume will be maintained
during extraction and injection.
7.2.6.14 The Basin Plan for the Central Valley
Region, Sacramento River and San Joaquin
River Basins, has designated groundwater at
DDJC-Tracy with the following beneficial uses:
municipal and domestic supply, agricultural
supply, industrial service supply, and industrial
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
process supply. These beneficial uses apply to
all groundwater.
7.2,6.15 California SWRCB Resolution 92-49
establishes policies and procedures for the
oversight of investigations and cleanup and
abatement activities resulting from discharges
(including injection) that affect or threaten water
quality. SWRCB Resolution 92-49 requires
actions for cleanup and abatement to conform to
SWRCB Resolution 68-16 and state and
regional water board basin plans and policies.
Cleanup levels are not required to be more
stringent than background levels. Cleanup levels
and effluent discharge limitations need not be
identical for the same site.
7.2.6.16 Part C of the Federal Safe Drinking
Water Act (SDWA) set up Underground
Injection Control (UIC) program requirements
that are specified in 40 CFR Part 144. These
regulations define a classification system,
discharge prohibitions, and a permitting system
for wells that inject fluids into groundwater.
Any water that is injected into the groundwater
at DDJC-Tracy must meet these UIC program
requirements and potentially require UIC
permitting.
7.2.7 Identification of Other Guidance
and Criteria to be Considered
7.2.7.1 Other TBCs in evaluating remedial
alternatives are federal, state, or local advisories
or guidance documents that have not been
promulgated. Since TBCs are not promulgated,
they are not legally binding. If there are no
specific federal, state, or regional ARARs for a
particular chemical or remedial action, or if
existing ARARs are not considered sufficiently
protective, then guidance or advisory criteria
should be identified and used to ensure public
health and environmental protection. TBCs may
provide health effect information with a high
degree of credibility, technical information on
performing or evaluating site investigations or
remedial actions, and useful policies for dealing
with hazardous substances.
7.2.7.2 Soil. In general, there are no
promulgated cleanup levels available for soil.
No numerical chemical-specific ARARs were
identified for contamination in soil; to protect
human health and the environment, chemical-
specific TBCs were developed from Water
Quality Goals (CVRWQCB, 1994) (see
Section 6.7). There are also some guidelines for
the allowable levels of total petroleum
hydrocarbons (TPH) in soil that are based on
recommendations from the Tri-Regional Board
(California RWQCB, 1996). These guidelines
do not constitute final cleanup goals, but rather
target levels that should prevent existing TPH
soil contamination from becoming a source of
constituents to underlying groundwater.
7.2.7.3 Aquatic Habitat and Sediment.
According to the Basin Plan, freshwater habitat
is potentially a beneficial use for surface water
at SWMU 4. Thus, federal ambient water
quality criteria (AWQC) are chemical-specific
TBCs for surface water at SWMU 4. Of the
consitituents detected in surface water at
SWMU 4 (primarily pesticides), only DDT and
dieldrin have AWQC for the protection of
aquatic life (U.S. EPA, 1988b). The freshwater
chronic AWQC for DDT is l.OxlO'3 jjg/L. The
freshwater chronic AWQC for dieldrin is
1.9xlO'3 ug/L. There are no established
California or federal sediment quality criteria
(SQC) for the protection of aquatic life,
however interim SQC have been proposed by
the U.S. EPA for 17 nonpolar hydrophobic
organic contaminants, including six polycyclic
aromatic hydrocarbons (PAHs), seven
pesticides, aniline, and polychlorinated
biphenyls (PCBs) (Aroclor 1254). The current
approach to developing sediment criteria
involves partitioning the constituent to the water
phase and evaluating bioavailability. Because
there is still discussion regarding the choice of
partition coefficients and the methods for
determining uncertainty in the interim SQC
values, the final values will differ from these
interim values, though not substantially (U.S.
EPA, 1989b). A number of other predictive
models and methods are being investigated for
constituents, but no one approach has been
accepted to develop sediment-based criteria
(Shea, 1988; Chapman, 1989; NOAA, 1990; Di
Toro et al., 1991; Burton, 1991; U.S. EPA,
1989b).
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
7.2.7.4 National Oceanic and Atmospheric
Administration (NOAA) effects-based sediment
quality values are available for evaluating the
potential for constituents in sediment to cause
adverse biological effects. These values are not
standards or criteria. NOAA effects range low
(ER-L) values are concentrations equivalent to
the lower 10 percentile of available data
screened by NOAA. These values indicate the
low end of the range of concentrations in
specific sediments at which adverse biological
effects were observed or predicted in sensitive
species and/or sensitive life stages.
7.2.7.5 The effects range-median (ER-M)
values are concentrations based on the median
values of the NOAA-screened data at which
adverse biological effects were observed or
predicted. The ER-L and ER-M values are used
by U.S. EPA as sediment screening values to
indicate the potential for adverse ecological
effects. The ER-L and ER-M values do not
allow observed toxicity concentrations to be
readily extrapolated from one sediment location
to another. Sediment characteristics greatly
influence the contaminant toxicity; thus, the ER
(L and ER-M values cannot be used as direct
indicators of adverse effects to aquatic
organisms. U.S. EPA generally recommends
further ecological testing and evaluation (when
these values are exceeded) to determine the site-
specific risks. The ER-L and ER-M values for
constituents detected in sediment at SWMU 4
are considered chemical-specific TBCs for
sediment at SWMU 4.
7.2.7.6 Groundwater. The non-promulgated
water quality criteria were identified as TBCs
for dieldrin in groundwater. Water quality
criteria were also developed for monuron and
diuron.
7.3 Operable Unit 1 Groundwater
7.3.1 Background
7.3.1.1 Operable Unit (OU) 1 is defined as the
contaminated groundwater plume, on and off
depot. The plume is characterized by PCE and
TCE. The OU 1 ROD (WCC, 1993) established
aquifer cleanup standards for TCE, PCE, and
1,1 -DCE. As described in the OU 1 ROD, the
selected remedy for VOCs in OU 1 groundwater
is groundwater extraction and treatment.
7.3.1.2 TheOU 1 ROD documents the
development and evaluation of four alternatives
to address VOCs in groundwater at DDJC-
Tracy. Alternative 1 considered no action to
address TCE, PCE, and 1,1-DCE. Alternative 2,
institutional controls, included restrictions on
drinking water wells and future residential
development, an Interagency Management
Agreement to manage future groundwater use at
the depot, continued groundwater monitoring,
and the supplying of drinking water to affected
families. Alternative 3 included a system of
approximately 40 extraction wells, the treatment
of 1,000 gallons of groundwater per minute by
air stripping, vapor-phase carbon adsorption, the
injection of treated water, and continued
monitoring. Alternative 4 consisted of approxi-
mately 40 extraction wells, the treatment of
1,000 gallons of groundwater per minute by air
stripping, vapor-phase carbon adsorption, in situ
biological treatment, the injection of treated
water, and continued monitoring.
7.3.1.3 Alternative 3 was the selected alterna-
tive. Alternatives 1 and 2 were not preferred
because they did not remediate the contaminated
aquifer, did not protect human health and the
environment, did not meet the ARARs, and
would not be accepted by the community or the
state. Alternative 4 was not preferred because it
is untried at full scale and would therefore
require significant advance testing and
experimentation. As a result it would be
significantly more costly than Alternative 3.
Acceptance of Alternative 4 by the agencies and
the public was expected, but not certain.
7.3.1.4 The selected remedy for TCE, PCE,
and 1,1-DCE is presently under construction.
The conceptual design (i.e., flow rate and
number of wells) of the alternative presented in
the ROD has been refined in the design process
(see Section 9.5). In addition to the alternatives
described above, reductive dechlorination was
considered as a possible remedy during the
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
design phase. However, given the size of the
contaminant plume, the cost of installing a
subsurface reductive dechlorination system was
prohibitive. Alternative 3 remains the preferred
alternative to address VOCs in groundwater at
DDJC-Tracy, and the selection of Alternative 3
is reaffirmed in this ROD.
7.3.1.5 An Explanation of Significant
Differences (ESD) (Montgomery Watson,
1996g) was approved that allows a small portion
of the plume to be remediated by natural
attenuation.
7.3.1.6 Studies to assess the technical and
economic feasibility of achieving "background"
(i.e., detection limits) for TCE, PCE, and 1,1-
DCE were performed and are reported in the 3-
D Groundwater Model Technical Evaluation
(Montgomery Watson, 1995). It was estimated
that remediation to detection limits would
require approximately 50 percent more time
than the time needed to attain MCLs. This
would significantly increase the cost per unit
removal of contaminants from the aquifer.
Furthermore, strict adherence to a detection-
limit remediation goal would require installation
of more extensive extraction and infiltration
facilities both on and off depot. Additional
property acquisition and easements would be
necessary. Remediation to MCLs enables the
extraction and infiltration systems to be limited
to government property and avoids the high
incremental cost of treatment to detection limits.
Therefore, this ROD reaffirms the selected
remedy of extraction and treatment to MCLs
with the natural attenuation of a small portion of
the plume.
7.3.1.7 Other VOCs (see Table 7-1) detected
in samples from various monitoring wells at
DDJC-Tracy during the groundwater monitoring
program include bromoform, carbon disulfide,
chloroform, 1,1 -DCE, cis-l,2-DCE, trans-1,2-
DCE, methylene chloride, benzene, toluene, and
xylenes. However, the concentrations of these
VOCs were an order of magnitude less than the
concentrations of TCE and PCE and were
detected intermittently in only a few wells. The
nature and extent of chloroform is discussed in
Sections 5.2.2 and 5.2.7.
7.3.1.8 The Lower Tulare Aquifer was
sampled when wells AG-1 and AG-3 were
abandoned. No VOCs were reported. No
sample could be collected from AG-2 because
the well had collapsed above the Lower Tulare
contaminants may have migrated through the
Corcoran Clay prior to the well collapse at 375
feet bgs. However, the date of the collapse is
unknown and may have occurred before the OU
1 plume migrated to this area. Concentrations
of TCE and PCE within the Lower Horizon and
below the Lower Horizon are relatively low.
Attenuation and dilution effects are also
expected to additionally reduce concentrations
of TCE and PCE, if present, as groundwater
transport processes continued across the
Corcoran Clay and Lower Tulare Aquifer.
Because over 200 feet of find-grained silty and
clayey sediments (including the Corcoran Clay)
are present below the permeable zone at 180 feet
bgs, significant vertical migration TCE and PCE
to the Lower Tulare Aquifer in locations other
than connecting production wells is considered
unlikely.
7.3.1.9 Based on the contamination observed
below the Lower Horizon in well LM57D and
the concentrations of TCE and PCE detected in
the deep CPT samples collected in the vicinity
of AG-2, OU 1 contaminants have migrated
vertically to the water-bearing zone at 180 feet
bgs. Because this zone is adjacent to the bottom
of the perforated intervals observed in well AG-
2, it is not known whether contaminants have
migrated any deeper. However, the absence of
TCE or PCE in the sample collected from AG-1,
which is located directly downgradient of AG-2
in the Lower Tulare Aquifer, provides a
reasonable level of certainty that the Lower
Tulare Aquifer has not been contaminated.
7.3.1.10 Additional investigation of the Lower
Tulare Aquifer would require drilling into and
possibly through the Corcoran Clay, which may
open new conduits from contaminated zones in
the Upper Tulare Aquifer to uncontaminated
zones. Additional groundwater sampling in the
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DDJC-Tracy She-Wide Comprehensive Record of Decision
Corcoran Clay and Lower Aquifer is therefore
not recommended. Based on all available data,
the risk of contributing to deep aquifer
contamination as a result of drilling and
installing well materials through the Corcoran
Clay and overlying contaminated aquifer is not
warranted to obtain additional data to support
this assessment.
7.3.1.11 Several pesticides and herbicides
(primarily dieldrin, chlordane, DDD, DDE,
DDT, monuron, and diuron) have also been
detected in groundwater at DDJC-Tracy (see
Table 7-1). Pesticides have been predominantly
detected in wells in the northwestern portion of
the depot. On the basis of analytical modeling
results (Montgomery Watson, 1996a), the
primary source areas for pesticides and
herbicides are SWMUs 2 and 3. In particular,
the dieldrin plume appears to emanate from the
lagoons and extends into the Tracy Annex.
Monuron and diuron occur in a similar
distribution. There is insufficient groundwater
data to confirm the shape of the monuron and
diuron plume; however, the occurrence of
monuron and diuron in groundwater at DDJC-
Tracy has been interpreted as the result of the
source areas at SWMUs 2 and 3. The occurrence
of all other pesticides and herbicides in
groundwater is intermittent. In addition, the
concentrations of other pesticides are generally
below numerical beneficial use limits.
7.3.1.12 Dieldrin has historically been
detected at low concentrations in groundwater
from 26 monitoring wells (Montgomery Watson,
1996a). Monuron and diuron have been detected
in 24 and 14 wells, respectively. The majority of
consistent monuron, diuron, and dieldrin
detections are in the Above Upper or Upper
Horizon wells downgradient from SWMU 2.
Isolated detections of dieldrin have also
occurred in the Above Upper Horizon Wells
downgradient from the Storm Drain Lagoon
(SWMU 4), Bum Pit No. 2 (SWMU 8), and the
IWPL (SWMU 33). The background threshold
values for dieldrin, monuron, and diuron are
0.005 ug/L, 0.163 ug/L, and 0.144 ug/L,
respectively. These background levels were
based upon detection limits derived from use of
a modified method as part of an initial
background study These detection limits were
not reproducible. The numerical beneficial use
limit (Cal/EPA and USEPA Cancer Potency
Factor) for dieldrin is 0.002 (ig/L. No federal or
California MCLs have been established for
dieldrin, monuron, or diuron. The California
Action Level for dieldrin is 0.05 ug/L
(RWQCB, 1995). The numerical beneficial use
limit (SNARL) for monuron and diuron is
10 ug/L.
7.3.1.13 Total concentrations of arsenic (see
Table 7-1) have consistently been detected at
values slightly greater than background in two
Above Upper and Upper horizon wells with
elevated turbidity. Arsenic has also been
detected intermittently in nine other Above
Upper and Upper Horizon wells in the northwest
corner of the depot and downgradient from
SWMUs 2 and 3. The maximum detected value
of total arsenic is 7.4 ug/L compared to the
MCL of 50 ug/L and the background threshold
value of 3 ug/L. Manganese has been
consistently detected above the background
threshold value in LM27AA. The maximum
concentration of manganese was 1,640 ug/L,
compared to a background threshold value of
338 ng/L. The source of manganese in this
location is the former manganese ore stockpiles
that were previously located along the northern
fenceline at DDJC-Tracy. Contaminant transport
occurred as rainwater leached through the
stockpiles and became acidic because of sulfides
in the ore. The ore may also have been a source
for arsenic. The source for manganese in
groundwater is no longer present. Manganese
and barium have also been detected
downgradient from SWMUs 2, 3,4, and 33. The
detected concentrations of barium are only
slightly greater than background and have never
exceeded the MCL. No dissolved concentrations
of any other metal were detected consistently
above background in samples collected from
wells at DDJC-Tracy.
7.3.1.14 Based on a review of historical
groundwater monitoring data, dieldrin
contamination in groundwater warrants
remediation. The analysis of all groundwater
COPCs is summarized in Table 7-1. The general
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
response actions developed for dieldrin are
discussed below.
7.3.2 Remedial Action Objectives
As explained in Section 7.3.1, the selected
remedy for VOC contamination in groundwater
was reevaluated and determined to be the most
viable remedy. As a result, RAOs are presented
for dieldrin, the only remaining chemical of
concern (COC) in groundwater. The RAOs for
the dieldrin in groundwater in OU 1 are:
• Remediate hot spots (i.e., areas with the
highest levels of dieldrin contamination in
groundwater);
• Minimize contaminant transport off-depot;
and
• Minimize dieldrin migration and remediate
to the aquifer cleanup level of 0.05
micrograms per liter (ug/L) based on a
California Action Level.
7.3.3 Remedial Alternatives
Remedial alternatives for VOCs are discussed in
Section 7.3.1. Four modifications of the selected
remedial alternative for VOCs were evaluated to
address dieldrin in OU 1 groundwater.
Currently, three areas of groundwater are
contaminated with dieldrin levels above the
California Action Level of 0.05 ng/L. One area
is located near SWMUs 2 and 3, one is near
SWMU 8, and one is within the Tracy Annex.
These areas all lie within the OU 1 VOC plume.
The full-scale OU 1 groundwater remediation
system includes two extraction wells with
liquid-phase carbon to treat dieldrin at the
wellhead. Table 7-2 describes the four
alternatives that would modify the OU 1
groundwater remedy:
• No Further Action;
• Institutional Controls (land use restrictions
and groundwater monitoring);
• Groundwater Extraction and Treatment -
Option 1 (wellhead pretreatment with GAC
at nine extraction wells and air stripping to
remove VOCs); and
• Groundwater Extraction and Treatment —
Option 2 (wellhead pretreatment with
granular activated carbon (GAC) at three
extraction wells and air stripping to remove
VOCs).
7.4 Group A Sites
7.4.1 Remedial Action Objectives
Prevent the migration of the following VOCs in
soil that could cause groundwater
contamination:
• SWMU I/Area 2 - PCE and TCE;
• Area 1 Building 237 - PCE; and
• Area 3 - PCE and TCE.
To reach this RAO, site-specific soil cleanup
levels were developed that are protective of the
background groundwater quality,
7.4.2 Remedial Alternatives
Four remedial alternatives -were evaluated at the
Group A sites (SWMU I/Area 2, Area 1
Building 237, and Area 3). These sites are
characterized mainly by soil contaminated with
VOCs and are considered potential sources to
OU 1 groundwater contamination. PCE and
TCE are present at SWMU I/Area 2 and Area 3.
PCE is present at Area 1 Building 237.
Table 7-3 describes the four remedial actions
considered for these sites:
• No Further Action;
• Institutional Controls;
• Soil Vapor Extraction (SVE); and
• Excavation and Disposal.
7.5 Group B Sites
There are nine Group B sites (SWMUs 4, 6, 7,
8, 20/23, 24, 27, the Building 30 Drum Storage
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Area and the surface and near-surface soils in
the North Depot Area). Specific RAOs and
alternatives were developed for each site and are
discussed separately. To reach these RAOs, site-
specific soil cleanup standards were developed
for each chemical of concern. The cleanup
standards will leave a residual cancer risk that is
no greater than IxlO"6, a residual hazard index
that is no greater than 1.0, and will be protective
of the background groundwater quality.
7.5.1 SWMU 4 - Storm Drain Lagoon
7.5.1.1 Remedial Action Objectives. The
RAOs for SWMU 4 are:
• Prevent release of COCs (DDT and dieldrin)
from sediments that would cause surface
water concentrations that exceed federal
AWQC for protection of aquatic life;
• Prevent ecological receptors from being
exposed to COCs (DDT, lead, and PCBs) in
surface water above aquatic standards; and
• Prevent ecological receptors from being
exposed to COCs in sediment.
7.5.1.2 Remedial Alternatives. Three
remedial alternatives were evaluated for
SWMU 4, a storm drain lagoon that collects all
storm water runoff from DDJC-Tracy. Table 7-4
describes the three remedial actions considered
for this site:
• No Action;
• Upstream Source Control (remove sediment
periodically from storm drain conduits); and
• Limited Excavation and Disposal of
Sediments (excavate sediment from the
storm drain lagoon, dewater sediment and
soil, and transport soil to an off-site facility
for disposal) and Evaluation of Storm Water
Discharge.
7.5.2 SWMU 6 - Building 28 Sump
7.5.2.1 Remedial Action Objective. The
RAO for SWMU 6 is:
• Prevent the migration of pesticides
(dicamba, dieldrin, endrin, heptachlor,
lindane, and 2,4,5-T) in the soil that could
cause groundwater contamination.
7.5.2.2 Remedial Alternatives. Four remedial
alternatives were evaluated for SWMU 6, which
is located on the west side of Building 28 in the
eastern portion of DDJC-Tracy. Table 7-5
describes the four remedial actions considered
for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
• In Situ Stabilization (immobilize
contaminated materials); and
• Excavation and Disposal (excavate
contaminated soil and transport it to a
Class I or n disposal facility).
7.5.3 SWMU 7 - Burn Pit No. 1
7.5.3.1 Remedial Action Objectives. The
RAO for SWMU 7 is:
Prevent the migration of the following COCs in
the soil that could cause groundwater
contamination:
• Pesticides and herbicides (2,4-D, linuron,
dieldrin, and simazine);
• SVOCs (bis[2-ethylhexyl]phthalate);
• VOCs (1,2-dichloroethene [ 1,2-DCE] and
TCE); and
• Petroleum hydrocarbons (diesel).
7.5.3.2 Remedial Alternatives. Four
remedial alternatives were evaluated for
SWMU 7, which consists of seven pits that
operated before warehouse buildings 15, 19, and
21 were constructed. These pits were used for
disposing of medical supplies containing
mercury and phosphate compounds, narcotics.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
radiological supplies, etc. In addition, other
materials (both solid and liquid) that were stored
or used at DDJC-Tracy may have been burned
and/or buried at SWMU 7. The ashes were
removed and transported to off-site landfills
during the later years of operation. Table 7-6
describes the four remedial actions considered
for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and ground water monitoring);
• In Situ Stabilization with Institutional
Controls (immobilize the contaminated
materials); and
• Excavation and Disposal with Institutional
Controls (excavate the contaminated soils
and transport to a Class I disposal facility).
7.5.4 SWMU 8 - Burn Pit No. 2
7.5.4.1 Remedial Action Objectives. The
RAOs for SWMU 8 are:
• Prevent future construction workers from
being exposed to the following COCs in the
soil that would cause an excess cancer risk
greater than 10"6 or a hazard index greater
than 1.0:
- Pesticides (total DDX and dieldrin);
• Prevent the migration of the following
COCs in the soil that could cause
groundwater contamination;
- SVOCs (diethylphthalate, bis[2-
ethylhexyl]phthalate, 2,4-dinitrotoluene,
and naphthalene);
- Pesticides and herbicides (chlordane,
2,4-D, DDT, DDD, dieldrin, lindane,
linuron, MCPA, and simazine); and
- Petroleum hydrocarbons (diesel, motor
oil, and gasoline).
7.5.4.2 Remedial Alternatives. Four remedial
alternatives were evaluated for SWMU 8, a
single large bum pit approximately 16 feet deep,
250 feet long, and 30 feet wide. Petroleum
hydrocarbons were detected in deep soils
extending to the water table (21 feet below
ground surface at maximum concentrations of
2,600 mg/kg (TPH as diesel), 70 mg/kg (TPH as
gasoline), and 5,600 mg/kg (TPH as motor oil).
Table 7-7 describes the four remedial actions
considered for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
• Bioventing (enhance biodegradation in the
subsurface by installing a blower and three
air-injection well clusters); and
• Excavation and Disposal (excavate the
contaminated soil and transport it to a
Class I or other disposal facility in
compliance with state and federal laws and
regulations).
7.5.5 SWMU 20 - Aboveground Solvent
Tank/Building 26 Recoup
Operations and Area 1 Building 10
7.5.5.1 Remedial Action Objectives. The
RAO for SWMU 20:
• Prevent the migration of the following
COCs in the soil that could cause
groundwater contamination that exceeds
appropriate regulatory standards and health-
based concentrations:
- VOCs (TCE, ethylbenzene, and
xylenes);
- SVOCs (diethylphthalate, 2,4-
dinitrophenol, pentachlorophenol [PCP],
and 2,4,6-trichlorophenol);
- Pesticides and herbicides (dieldrin,
methiocarb, MCPA, and linuron); and
- Petroleum hydrocarbons (diesel).
SEC-7.DOC
7-12
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
7.5.5.2 Remedial Alternatives. Four remedial
alternatives were evaluated for SWMU 20, an
aboveground solvent tank located in Area 1
Building 10. Table 7-8 describes the four
remedial actions considered for this site:
• No Action;
• Institutional Controls;
• SVE, Excavation and Disposal, and Natural
Attenuation (excavate the contaminated soil
from SWMU 20 and SWMU 26 and
transport it to a Class I disposal facility;
install an SVE system near soil boring [SB]
108 [Area 1 Building 6] and SB431
[SWMU 23]); and
• Excavation and Disposal (excavate the
contaminated soil and transport it to a
Class I disposal facility).
7.5.6 SWMU 24 - Petroleum Waste Oil
Tank
7.5.6.1 Remedial Action Objectives. The
RAOs for SWMU 24 are:
• Prevent future depot workers from being
exposed to toluene in the soil that would
cause a hazard index greater than 1.0.
• Prevent the migration of the following
COCs in the soil that could cause
groundwater contamination that exceeds
appropriate regulatory standards and health-
based concentrations:
- VOCs (acetone, 2-butanone [MEK],
ethylbenzene, 2-hexanone, 4-methyl-2-
pentanone, toluene, and xylenes);
- SVOCs (2,4-dimethylphenol,
fluoranthene, 2-methylnaphthalene, 4-
methylphenol, naphthalene,
phenanthrene, phenol, and pyrene);
- PCBs (Aroclor 1260);
- Pesticides (carbofuran, lindane, phorate,
and ronnel); and
- Petroleum hydrocarbons (diesel and
gasoline).
7.5.6.2 Remedial Alternatives. Five remedial
alternatives were evaluated for SWMU 24, a
500-gallon underground storage tank (UST) that
was used to store petroleum wastes between
1961 and 1988. The average biodegradable
hydrocarbon concentration detected at
SWMU 24 is 3,000 mg/kg. Table 7-9 describes
the five remedial actions considered for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
• Bioventing (install air-injection well and
blower);
• Excavation and Disposal (excavate the
contaminated soil and transport it to a
Class I disposal facility); and
• Excavation and On-Site Bioremediation
(excavate the soil exceeding the cleanup
standards and treat aboveground with on-
site bioremediation method such as
landfarming or a slurry-phase reactor).
7.5.7 SWMU 27 - Building 206
Roundhouse Sump/Area 1
Building 206
7.5.7.1 Remedial Action Objective. The
RAOs for SWMU 27 are:
• Prevent future depot workers from being
exposed to the following COCs in the soil
that would cause an excess cancer risk
greater than IxlO'6:
- PAHs (benzo[a]pyrene,
benzo[a]anthracene,
benzo[b]fluoranthene,
benzo[k]fluoranthene, and indeno[ 1,2,3-
cd]pyrene); and
SEC-7.DOC
7-13
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
- PCBs (Aroclor 1260).
• Prevent the migration of the following
COCs in the soil that could cause
groundwater contamination that exceeds
appropriate regulatory standards and health-
based concentrations:
- VOCs (TCE);
- Herbicides (2,4-D, MCPA, and 2,4,5-T);
and
- Petroleum hydrocarbons (motor oil).
7.5.7.2 Remedial Alternatives. Three
remedial alternatives were evaluated for
SWMU 27, which consists of the waste oil
sump, the service pit, the locomotive pit, and the
area around the floor drain in Building 206.
Table 7-10 describes the three remedial actions
considered for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
and
• Excavation and Disposal (excavate the
contaminated soil and transport it to a Class
I disposal facility).
7.5.8 Building 30 Drum Storage Area
7.5.8.1 Remedial Action Objectives. The
RAO for the Building 30 Drum Storage Area is:
• Prevent the migration of benzyl alcohol,
bis(2-ethylhexyl)phthalate, diethylphthalate,
and di-n-butylphthalate in the soil that could
cause groundwater contamination that
exceeds appropriate regulatory standards
and health-based concentrations.
7.5.8.2 Remedial Alternatives. Three
remedial alternatives were evaluated for the
Building 30 Drum Storage Area which is located
in the southern portion of the depot, on the south
side of D Street. Table 7-11 describes the three
remedial actions considered for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
and
• Excavation and Disposal (excavate
contaminated soil and transport to Class I or
n disposal facility).
7.5.9 Surface and Near-Surface Soils -
Northern Depot Area
7.5.9.1 Remedial Action Objectives. The
RAO for the Northern Depot Area is:
• Prevent future depot workers from being
exposed to arsenic and manganese in the
surface and near-surface soils that would
cause a hazard index greater than 1.0.
7.5.9.2 Remedial Alternatives. Four remedial
alternatives were evaluated for the remediation
of metals in shallow soils. The data from the
surface and near-surface soils indicate that
arsenic and manganese in the soil pose a threat
to human health in the northern area of the
depot. Table 7-12 describes the four remedial
actions considered for this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
• Asphalt Cover (install an asphalt cover over
the soil with elevated levels of arsenic and
manganese); and
• Excavation and Disposal (excavate the
contaminated soil and transport it to a Class
n or IK disposal facility).
7.6 Group C Sites
There are two Group C sites: SWMUs 2 and 3,
and SWMU 33. Specific RAOs and alternatives
SEC-7.DOC
7-14
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
were developed for each site and are discussed
separately. To develop these RAOs, site-specific
soil cleanup standards were developed for each
constituent of concern.
7.6.1 SWMUs 2 and 3 - Sewage and
Industrial Waste Lagoons
7.6.1.1 Remedial Action Objectives. The
RAO for SWMUs 2 and 3 is:
• Prevent the migration of dieldrin, DDT,
ODD, DDE, di-n-butylphthalate, and bis(2-
ethylhexyl)phthalate in post-removal-action
soil that could cause groundwater
contamination that exceeds appropriate
regulatory standards and health-based
concentrations.
7.6.1.2 Remedial Alternatives. Three
remedial alternatives were evaluated for
SWMUs 2 and 3, which are located in the north
part of the depot west of and adjacent to the
sewage treatment plant. Table 7-13 describes the
three additional remedial actions considered for
this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
and
• Excavation and Disposal (a geofabric filter
and backfill will be used to isolate
ecological receptors from contaminants left
in place).
7.6.2 SWMU 33 - Industrial Waste
Pipeline
7.6.2.1 Remedial Action Objective. The
RAO for SWMU 33 is:
• Prevent the migration of aldrin, dieldrin,
diethylphthalate, and di-n-butylphthalate in
the postremoval-action soil that could cause
groundwater contamination that exceeds
appropriate regulatory standards and health-
based concentrations.
7.6.2.2 Remedial Alternatives. Three
remedial alternatives were evaluated for
SWMU 33, a 4-inch- to 7-inch-diameter
industrial waste pipeline buried 2 feet below
grade. These remedial alternatives were
developed assuming that the removal actions
recommended in the January 1996 EE/CA
would be completed. Table 7-14 describes the
three additional remedial actions considered for
this site:
• No Action;
• Institutional Controls (implement land use
restrictions and groundwater monitoring);
• Limited Excavation and Disposal (excavate
the contaminated soil and transport it to a
Class I disposal facility), grouting, and
institutional controls (groundwater
monitoring); and
• Excavation and Disposal (excavate contami-
nated soil and transport it to a Class I
disposal facility).
7.7 No Further Action Sites
7.7.1 Twenty-one sites have been identified as
"No Further Action (NFA)" sites based on site
specific data developed in the RI/FS. These sites
are categorized as NFA sites because they meet
the following criteria:
• No COCs pose actual or potential threats to
groundwater beneficial uses or exceed
background concentrations;
• No COCs pose an excess cancer risk greater
than IxlO'6 to depot workers, construction
workers, or children on the installation;
• No COCs have a non-cancer hazard index
greater than 1.0 for depot workers,
construction workers, or children on the
installation; and
• There is no ecological risk.
SEC-7.DOC
7-15
17 February 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
7.7.2 One NFA site, SWMU 10A, does not
fully meet the above criteria. Soil contamination
at SWMU 10A does pose a potential threat to
background groundwater quality. Remediation
was not recommended because of the cost, the
limited number of detections, and questions
regarding the reliability of the data
(Montgomery Watson, 1996a). Therefore, the
site has been designated as an NFA site.
7.7.3 ARARs would not be violated by not
taking action on these NFA sites. No chemical
specific ARARs or TBCs for soil would be
exceeded. All concentration of contaminants in
soil are below such ARARs as the Designated
Level Methodology (DLM) values for
sediments, surface soils, and subsurface soils
specified by the RWQCB, State and federal
hazardous waste criteria (22 CCR 66261 and 40
CFR 261), and the USEPA Toxic Substance
Control Act (TSCA).
7.7.4 Similarly, no groundwater ARARs or
TBCs would be violated by not taking action at
these sites. No National or State MCLs (40 CFR
141) would be exceeded and beneficial uses of
groundwater specified in the RWQCB Basin
Plan would not be affected. No requirements of
the Porter-Cologne Water Quality Act or
SWRCB Resolution 68-16 would be violated by
not taking action at these sites.
7.7.5 These sites are identified in Table 7-15,
along with the rationale for their NFA
designation.
SEC-7.DOC 7-16 17 February 1998
-------
Table 7-1 . Groundwater Chemicals of
Maximum Background
Detected Threshold
Chemical of Concentration* Values"
Concern (ug/L) (H9/L)
Volatile Organic 560 NC
Compounds
Trichloroelhene
(TCE)
Telrachloroelhene 457 NC
(PCE)
U-Dichloroethene 37 NC
(DCE)
Carbon 5 NC
Tctrachloridc
Chloroform 5 NC
Concern: Detection Frequency, Remedial
DDJC-Tracy
Frequency
Beneficial Use Detected
Numerical Versus
Limits6 Frequency Remedial
(jig/L) Analyzed Decision
2.3 770/I465 Aquifer cleanup level
established
Effluent treatment
standard established
0.7 661/I465 Aquifer cleanup level
established
Effluent treatment
standard established
6 55/1465 Aquifer cleanup level
established
Effluent treatment
standard established
5 1/1465 NFA; effluent
treatment standard
established
1.0 78/1465 NFA; effluent
treatment standard
established
Decision Rationale, and Risk Characterization,
Excess
Remedial Decision Cancer Risk" Hazard
Rationale (x-4) Quotient"
Prevalent depot-related chemical 0.37 NC
of concern
Contributes significantly to
human health risk
Risk based on maximum
concentration in 1994 (130 ug/L)
Prevalent depot-related chemical 0.50 NC
of concern
Contributes significantly to
human health risk
Risk based on maximum
concentration in 1994 (120 ug/L)
Depot-related chemical of 3.71 NC
concern
Contributes significantly to
human health risk
Detected levels may not be 0. 10 0.62
depot-related
Constituent detected infrequently
Depot-related chloroform 0.14 NC
concentrations are an order of
magnitude below the MCL
-------
a
r;
§
7"
oo
^
V
a-
1
^^
3
00
Table 7-1. (Continued)
Frequency
Maximum Background Beneficial Use Detected
Detected Threshold Numerical Versus
Chemical of Concentration* Values" Limits0 Frequency Remedial
Concern (|ig/L) (i*g/L) (ug/l) Analyzed Decision
Benzene 10 NC 1 9/1276 NFA
cis-1.2- 39 NC 6 10/905 NFA
Dichloroethene
trans- 1,2- 10 NC 10 6/1341 NFA
Dichloroethene
Toluene 19 NC 42 56/1276 NFA
1,1,1- 16 NC 200 21/1465 NFA
Trichlorocthane
Remedial Decision
Rationale
Constituent detected
infrequently (less than 1 %
frequency)
Constituent detected
infrequently (1% frequency of
detections)
Constituent detected below
beneficial use limit (MCL)
Constituent detected
infrequently (less than 1%
frequency)
Constituent detected
infrequently (less than 5%
frequency)
Constituent detected well
below beneficial use limit
(MCL)
Constituent detected
infrequently (less than 2%
frequency)
Constituent detected well
below beneficial use limit
(MCL)
Excess
Cancer Riskd Hazard
(x-4) Quotient"
e e
e e
e e
NA 0.002*
e e
a
2
n
;jj
3
o
*<
C/3
n
k
a.
O
o
a
3
re
is
f
0
0.
"*>
?
"ft
o'
3
-------
w
r
Table 7-1. (Continued)
Chemical of
Concern
Xylenes (m,p + o)
Maximum
Detected
Concentration*
(U9/L)
10
Background
Threshold
Values"
(ug/L)
NC
Beneficial Use
Numerical
Limits0
(U9/L)
17
Frequency
Detected
Versus
Frequency
Analyzed
11/909
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk"
(x-4)
NA
Hazard
Quotient11
0.000071
infrequently (less than 2%
frequency)
Constituent detected well
below beneficial use limit
(MCL)
Pesticides and Herbicides
2.4-D 2.78
0.101'
70
18/284
2.4-DB
0.209
0.101'
290
2/284
AlJrin
0.02
0.005f
0.002
4/574
NFA Constituent detected
infrequently (less than 30%
frequency)
Constituent detected well
below beneficial use limit
(MCL) and only slightly above
background threshold value
Source areas will be removed
(SWMU 2)
NFA Constituent detected
infrequently (only once in 2
wells)
Constituent detected well
below beneficial use limit
(PRO) and only slightly above
background threshold value
NFA Constituent detected
infrequently (only once in 4
wells)
Constituent delected well
below the beneficial use limit
(CA action level)
0
O
n
31
n
*<
in
a.
n
£>
3
3"
n
70
rt
n
O
o
O
o
-------
OJ
r
Table 7-1. (Continued)
Chemical of
Concern
Alpha-BHC
Maximum
Detected
Concentration*
(ug/L)
0.008
Background
Threshold
Values"
(H9/L)
0.005'
Beneficial Use
Numerical
Limits0
(H9/L)
0.15
Frequency
Detected
Versus
Frequency
Analyzed
1/573
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk"
(x-4)
e
Hazard
Quotient"
c
Carbaryl (Sevin)
2.75
0.382r
60
1/185
NFA
Chlordanc
0.7
0.104'
0.03
25/574
NFA; effluent
treatment standard
established
infrequently (delected once in
one well)
Constituent detected below
beneficial use limit
(Proposition 65 regulatory
level)
Constituent detected
infrequently (only once in one
well)
Constituent detected below
beneficial use limit (CA action
level)
Constituent delected
intermittently (less than 50%
frequency) in 11 wells.
The source areas will be
removed (SWMUs 2, 3. and 8)
Constituent generally detected
below beneficial use limit
(MCL)
NA
0.00021
0.0611
NC
D
D
n
a.
n
Dclta-BIIC
0.282
0.005'
500
6/573
NFA Constituent delected
infrequently (only once in 6
wells)
1
IJ
•a
s
00
73
n
r>
I
O
3
-------
Table 7-1. (Continued)
Maximum
Detected
Chemical of Concentration1
Concern (M9/L)
ODD 0.052
Background
Threshold
Values"
(H9/L)
0.005'
Beneficial Use
Numerical
Limits0
(U9/L)
0.15
Frequency
Detected
Versus
Frequency
Analyzed
16/574
Remedial
Decision
NFA; effluent
treatment standard
established
Remedial Decision
Rationale
Constituent detected
infrequently in 9 wells (less
than 25% frequency). The
source areas will be removed
(SWMUs 2. 8, and 33)
Constituent detected below
beneficial use limit (CA/EPA
cancer potency factor)
Excess
Cancer Risk" Hazard
(x-4) Quotient"
c c
DDE
0.116
0.005*
0.1
25/574
NFA; effluent
treatment standard
established
DDT
0.262
0.005'
0.1
23/574
NFA; effluent
treatment standard
established
Diazinon
0.347
1.00'
0.6
1/236
NFA
Constituent detected
infrequently in 9 wells (less
than 25% frequency). The
source areas will be removed
(SWMUs 2,3,8, and 33)
Constituent detected below
beneficial use limit (CA/EPA)
cancer potency factor)
Constituent detected
intermittently in 7 wells (less
than 25% frequency). The
source areas will be removed
(SWMUs 2,3, and 33)
Constituent generally detected
below beneficial use limit
(NAS drinking water standard)
Constituent delected
infrequently (less than 25%
frequency in only one well)
Constituent detected below
beneficial use limit (SNARL)
O
O
U_t
o
CO
o
a.
n
n
o
a
3
n
n
70
5
o
00
O
-------
Table 7-1. (Continued)
Chemical of
Concern
Dicamba (Banvcl)
Maximum
Detected
Concentration*
(H9/L)
0.024
Background
Threshold
Values"
(U9/L)
0.091'
Beneficial Use
Numerical
Limits'
(H9/L)
210
Frequency
Detected
Versus
Frequency
Analyzed
1/284
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk"
(x-4)
c
Hazard
Quotient"
c
infrequently (less than 25%
frequency; detected only once
in one well)
Constituent detected well
below beneficial use limit
(EPA-SNARL)
Dichlorvos (DDVP)
0.325
1.00f
1.00
1/236
NFA
Dieldrin
0.569
0.005f
0.002
114/574
Diuron
3.31
0.144r
14
26/185
Aquifer cleanup level
established
Effluent treatment
standard established
NFA; effluent
treatment standard
established
Constituent detected
infrequently (less than 20%
frequency; detected only once
in one well).
Constituent detected below
background threshold value
Constituent detected in 26
wells (20% to 100%
frequency)
The source areas will be
removed (SWMUs 2, 3.6,8,
20, and 33)
Constituent detected in 14
wells. Plume has been
identified downgradient of
SWMU 2/3 wilhOU 1 capture
zone and will be treated by
dicldrin treatment system.
Constituent detected below
beneficial use limit (EPA-
SNARL)
0.62
NC
NA
0.005
o
2
n
C/)
CX
o
n
o
I
Jf
3
\
o
1
i
00
-------
Table 7-1. (Continued)
Maximum Background Beneficial Use
Detected Threshold Numerical
Chemical of
Concern
Concentration*
(ug/L)
Values"
Limits'
(H9/L)
Frequency
Detected
Versus
Frequency
Analyzed
Remedial
Decision
Remedial Decision
Rationale
Excess
Cancer Risk*1
(x-4)
Hazard
Quotient*1
Endosulfan A
0.166
0.005
0.93/2.0
4/573
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 4 wells)
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)
Constituent detected well
below water quality criterion
Endosulfan B
0.07
0.005'
0.93/2.0
2/573
Endosulfan Sulfale
0.295
0.005f
0.93/2.0
5/574
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 2 wells)
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)
Constituent detected well
below water quality criterion
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 5 wells)
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)
Constituent detected well
below water quality criterion
D
2
n
5."
n
n
o
n
n
70
n
n
3
o
-------
a)
r
Table 7-1. (Continued)
Chemical of
Concern
Maximum
Detected
Concentration"
(ug/L)
Background Beneficial Use
Threshold Numerical
Values" Limits0
(ug/L)
rvnnel
Frequency
Detected
Versus
Frequency
Analyzed
Remedial
Decision
Remedial Decision
Rationale
Excess
Cancer Risk*
(x-4)
Hazard
Quotient"
Endrin
0.066
13/573
NPA Constituent detected
intermittently (less than 50%
frequency; detected only in 4
wells)
The source areas will be
removed (SWMU 2/3)
Constituent detected well
below water quality criterion
NA
0.0008
Hcplachlor
0.025
0.005f
0.006
3/574
llcpludilor Gpuxidc
0.029
0.005'
0.003
9/574
M
|
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 3 wells) and data validation
indicates that the presence of
this compound is unconfirmed
Constituent not detected in site
soils.
Originates from off-site source
area (agricultural non-point
sources)
Constituent detected at or
below beneficial use limit
(MCL)
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 9 wells) and data validation
indicates that the presence of
this compound is unconfirmed
The source area will be
removed (SWMU 6)
a
2
n
t/5
a
k
a.
O
o
n
3
73
n
-------
Table 7-1. (Continued)
Chemical of
Concern
Lindane (Gamma-
BHC)
Maximum
Detected
Concentration*
(H9/L)
0.046
Background
Threshold
Values"
(U9/L)
0.005'
Beneficial Use
Numerical
Limits0
(H9/U
0.03
Frequency
Detected
Versus
Frequency
Analyzed
4/573
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
infrequently (less than 25%
Excess
Cancer Risk"
(x-4)
e
Hazard
Quotient11
e
frequency; detected only once
in 5 wells)
The source area will be
removed (SWMU 6)
Constituent detected at or
below beneficial use limit
(MCL)
Linuron
23.8
0.157'
1.4
6/185
NFA Constituent detected
infrequently (less than 25%
frequency; detected only once
in 5 wells)
Constituent originates from
off-site source area
(agricultural non-point sources)
Constituent generally detected
below beneficial use limit
(EPA RFD)
NA
0.09
o
I
Mcthiocarb
4.57
1.36r
1.36
3/185
NFA Constituent detected
intermittently (detected once in
only 3 wells)
Constituent originates from
off-site source area
(agricultural non-point sources)
13
NR
NR
a.
n
O
o
I
o
3
n
70
r>
3
O
-------
Table 7-1. (Continued)
Chemical of
Concern
Mclhoxychlor
Maximum
Detected
Concentration1
(Wl/L)
0.044
Background
Threshold
Values"
(H9/L)
0.005'
Beneficial Use
Numerical
Limits0
(H9/L)
40
Frequency
Detected
Versus
Frequency
Analyzed
1/569
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk"
(x-4)
e
Hazard
Quotient"
c
Monuron
3.14
0.163'
10
40/185
NFA; effluent
treatment standard
established
Sima/.inc
2.07
0.492'
7/236
NFA
infrequently (less than 25%
frequency; detected only once
in one well)
Constituent detected below
beneficial use limit (MCL)
Constituent detected
inconsistently in 24 wells
Plume has been identified
downgradient of SWMU 2/3
within OU 1 capture zone and
will be treated by dieldrin
treatment system.
Constituent detected below
beneficial use limit (SNARL)
Constituent detected
intermittently in only 4 wells
The source areas will be
removed (SWMUs 2, 3, and 4)
Constituent detected below
beneficial use limit (MCL)
NA
0.007
0.02
NC
D
2
o
H
I
C/)
EL'
3
3
3-
n
3
re
70
n
O
o
O
-------
Table 7-1. (Continued)
Chemical of
Concern
Dioxins/Furans
Maximum
Detected
Concentration*
(U9/L)
2.7x10"'
Background
Threshold
Values"
(U9/L)
1x10-*
Beneficial Use
Numerical
Limits'
(H9/L)
2.7x1 0'7
Frequency
Detected
Versus
Frequency
Analyzed
2/17
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected below
beneficial use limit.
Excess
Cancer Risk"
(x-4)
I
Hazard
Quotient"
1
Metals
Arsenic (total)
7.4
50
40/804
Arsenic (dissolved)
7.5
50
15/594
Only the least toxic congener
(OCDD) was detected at
concentrations well below the
background threshold value
Technical economic evaluation
indicates that it is economically
infcasible to remediate
dioxins/furan in groundwalcr
NFA Constituent detected
intermittently in 10 wells;
frequency of detections may be
due to elevated turbidity
The source areas will be
removed (SWMUs 2/3)
Constituent detected well
below beneficial use limit
(MCL) and only slightly above
background threshold value
NFA Constituent detected
intermittently in only 4 wells
Constituent detected well
below beneficial use limit
(MCL) and slightly above
background threshold value
0.4
NC
0.4«
i
-------
CO
r.
Table 7-1. (Continued)
Chemical of
Concern
Antimony (total)
Antimony
(dissolved)
Maximum
Detected
Concentration*
(U9/L)
250
3.9
Background
Threshold
Values"
(ug/L)
3
3.9
Beneficial Use
Numerical
Limits0
(U9/L)
6
6
Frequency
Detected
Versus
Frequency
Analyzed
7/803
3/498
Remedial
Decision
NFA
NFA
Remedial Decision
Rationale
Constituent detected
intermittently in 5 wells (less
than 25% frequency)
Constituent detected
intermittently in only 3 wells
Excess
Cancer Risk"
(x-4)
NA
NA
Hazard
Quotient"
i
e
(other detections are due to
niter contamination)
Constituent detected below
beneficial use limit (MCL) and
slightly above background
threshold value
Barium (total)
572
145
1.000
63/791
NFA Constituent detected in 1 2
wells; other detections are due
to elevated turbidity
Constituent detected well
below beneficial use limit
(MCL) and only slightly above
background threshold value
The pattern of detections is not
suggestive of site
contamination. Most
detections ranged from 50-150
Mg/L
NA
D
2
9
to
n
k
1
rt
70
i
Q.
O
i?
-------
Table 7-1. (Continued)
Chemical of
Concern
Maximum
Detected
Concentration*
(H9/L)
Background
Threshold
Values"
(H9/L)
Beneficial Use
Numerical
Limits0
(H9/L)
Frequency
Detected
Versus
Frequency
Analyzed
Remedial
Decision
Remedial Decision
Rationale
Excess
Cancer Riskd
(x-4)
Hazard
Quotient"
Barium (dissolved)
763
99.8
1,000
60/473
NFA Constituent detected in 14
wells
Constituent detected below
beneficial use limit (secondary
MCL)
The pattern of detections is not
suggestive of site
contamination. Most
detections ranged from 50-
150ug/L
NA
Beryllium (total)
0.1
O.I
2/804
Boron (total)
7,090
2,590
600
18/643
Boron (dissolved)
3,380
2360
600
5/315
NFA Constituent detected
intermittently in only 2 wells
(less than 20% frequency);
dissolved beryllium not
detected above background
threshold value
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
NFA Constituent detected
intermittently in 14 wells (less
than 50% frequency)
Detections may be due to
elevated turbidity
Constituent originates from
off-siic source area
(agricultural non-point sources)
NFA Constituent detected
intermittently in only 4 wells
(less than 25% frequency)
NA
NA
O
2
n
C/5
W
k
%
f
70
n
n
o
-------
Table 7-1. (Continued)
Chemical of
Concern
Cadmium (total)
Maximum
Detected
Concentration*
(U9/L)
40
Background
Threshold
Values"
(U9/L)
4.4
Beneficial Use
Numerical
Limits0
(H9/L)
5
Frequency
Detected
Versus
Frequency
Analyzed
6/804
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk*
(x-4)
NA
Hazard
Quotient"
e
intermittently in only 6 wells
(less than 20% frequency);
dissolved cadmium not
detected above background
threshold value
Constituent generally detected
below beneficial use limit
(MCL)
Chromium (total)
44.7
35.7
50
23/810
NFA; effluent
treatment standard
established
Chromium
(dissolved)
43
30
50
14/595
NFA
Copper (total)
90
12.9
1,000
17/814
Constituent detected
intermittently in 17 wells (less
than 25% frequency)
Detections may be due to
elevated turbidity
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Constituent detected
intermittently in 8 wells (less
than 50% frequency)
Constituent detected below
beneficial use limit (MCL)
NFA Constituent detected
intermittently in 14 wells (less
than 25% frequency); other
detections arc due to elevated
turbidity
Constituent detected below
beneficial use limit (secondary
MCL)
NA
O
2
9
H
3
o
C/5
n
a.
n
9
I
3
ut
<'
o
3.
o
o
-------
Dri
G
Table 7-1. (Continued)
Chemical of
Concern
Maximum
Detected
Concentration*
Background
Threshold
Values"
(tig/L)
Beneficial Use
Numerical
Limits0
(U9/L)
Frequency
Detected
Versus
Frequency
Analyzed
Remedial
Decision
Remedial Decision
Rationale
Excess
Cancer Risk" Hazard
(x-4) Quotient"
Copper (dissolved)
70
20.2
1,000
9/595
NFA Constituent detected
intermittently in 8 wells (less
than 30% frequency)
Constituent detected below
beneficial use limit (secondary
MCL)
NA
Lead (total)
20.4
21.2
15
14/875
NFA Most detections are due to
elevated turbidity; exceeds
back-ground threshold value in
5 wells intermittently. Not
related to site contamination.
Dissolved lead not detected
NA
Manganese (total)
1.640
338
50
13/723
NFA Constituent detected
consistently in only one well
(less than 25% frequency)
Most detections are due to
elevated turbidity
Technical and economic
evaluation indicates that it is
economically infeasible to
remediate manganese in
groundwatcr
NA
D
S
2
I
in
rt
O
3
rt
73
\
f
o
D
o
-------
Table 7-1. (Continued)
Chemical of
Concern
Manganese
(dissolved)
Maximum
Detected
Concentration*
(H9/L)
880
Background
Threshold
Values"
(H9/L)
17.5
Beneficial Use
Numerical
Limits0
(H9/L)
50
Frequency
Detected
Versus
Frequency
Analyzed
41/407
Remedial Remedial Decision
Decision Rationale
NFA Constituent delected
intermittently in 13 wells
(consistently detected in 3
wells)
Excess
Cancer Risk"
(x-4)
NA
Hazard
Quotient"
e
Mercury (total)
6.62
0.2
6/799
Mercury,
(dissolved)
1.95
0.2
3/407
Trend of decreasing
concentrations observed
Constituent detected above
beneficial use limit (secondary
MCL)
Technical and economic
evaluation indicates that it is
economically infcasiblc to
remediate manganese in
groundwalcr
NFA Constituent detected
intermittently in 5 wells (less
than 25% frequency). Other
detections may be due to
elevated turbidity
Constituent generally detected
below beneficial use limit
(MCL)
NFA Constituent detected
intermittently in 5 wells
Constituent detected above
beneficial use limit (MCL)
NA
NA
o
D
§
CO
o
C/3
ft
o.
n
n
3
73
n
t
-------
Table 7-1. (Continued)
Chemical of
Concern
Nickel (tolal)
Maximum
Detected
Concentration*
(ug/L)
25.8
Background
Threshold
Values"
(H9/L)
21.2
Beneficial Use
Numerical
Limits'
(H9/L)
100
Frequency
Detected
Versus
Frequency
Analyzed
2/804
Remedial
Decision
NFA
Remedial Decision
Rationale
Constituent detected
Excess
Cancer Risk"
(x-4)
NA
Hazard
Quotient"
e
intermittently in 2 wells (less
than 20% frequency);
dissolved nickel not detected
above background threshold
value
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Nitrate, as N
Selenium (total)
Selenium
(dissolved)
26.3
7.87
9.1
25.1
12.1
6.0
45
50
50
4/232
6/804
4/594
NFA Constituent generally delected NA
below beneficial use limit
(state MCL) and background
threshold value
NFA Constituent detected NA
infrequently in 5 wells (less
than 25% frequency)
NFA Constituent detected NA
intermittently in 3 wells (less
than 35% frequency)
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Vanadium (total)
43.1
30.2
50
17/785
i
00
NFA Constituent detected
intermittently in 17 wells (less
than 25% frequency). Other
detections may be due to
elevated turbidity.
Constituent detected below
beneficial use limit (MCL)
NA
-------
Table 7-1. (Continued)
Chemical of
Concern
Vanadium
(dissolved)
Maximum
Detected
Concentration*
(M-9/L)
20
Background
Threshold
Values"
(H9/L)
16.2
Beneficial Use
Numerical
Limits0
(M-g/L)
50
Frequency
Detected
Versus
Frequency
Analyzed
10/467
Remedial Remedial Decision
Decision Rationale
NFA Constituent detected
intermittently in 8 wells (less
than 30% frequency)
Constituent detected below
beneficial use limit (MCL)
Excess
Cancer Risk"
(x-4)
NA
Hazard
Quotient"
c
* Database includes quarterly monitoring results from January 1987 to June 1995; results obtained in earlier sampling events were not used in the statistics provided for metals
because the quality of these data is lower than the quality of data collected after 1991. Samples with elevated turbidity were not counted in the statistics provided for metals.
Additionally, unconfirmed outliers were eliminated from the statistical data provided on this table.
b Background threshold values arc presented for the "A" horizon.
c Beneficial use numerical limits and the types of water quality goals that these values represent arc presented in Appendix P. Table P-10 of the RI/FS (Montgomery Watson,
1996a). Numerical limits were updated based on input from the CVRWQCB.
J Risk numbers arc based on maximum concentrations reported in the monitoring well database unless otherwise noted.
c Chemical not reported as a contaminant in the Phase I RI/RA (WCC, 1992b), the OU 1 ROD, or in wells located on the Annex or off-depot; therefore, risks were not calculated.
' No monuron or diuron has been delected in the background wells. The value cited is the lowest detection limit from a modified method that was previously used. These detection
limits have not been reproducible.
NA = not applicable; chemical is not an oral carcinogen.
NC = not calculated; applies to cither the risk assessment (Section 5.2.15 of Appendix R of the RI/FS [Montgomery Watson, 1996a|) or background threshold values.
NFA = No Further Action
-------
Table 7-2. Remedial Alternatives for OU 1 Groundwater
c
8
Alternatives
Description of
Details
No Further Action
Institutional Controls
Groundwater Extraction and
Treatment-Option 1
Groundwater Extraction
and Treatment-Option 2
Treatment Process
Description
• No treatment in addition
to the full-scale OU I
groundwatcr remediation
system.
No treatment in addition to
the full scale OU 1
ground water remediation
system.
Use wellhead pretreatment
(GAC) at the nine extraction
wells to remove dicldrin.
Treat water at OU 1
treatment plant (air stripping)
to remove VOCs.
• Use wellhead pretreatment
(GAC) at three wells to
remove dieldrin.
• Treat water at OU I
treatment plant (air
stripping) to remove VOCs.
Containment or
Storage
Components
• None.
Impose land use restrictions
for areas where elevated
concentrations of dieldrin in
the groundwatcr have been
detected.
None.
• None.
Groundwatcr
Components
Groundwater monitoring •
is included in Well
Monitoring Program.
Extraction wells for the •
OU I groundwatcr
remediation system are
located in the vicinity of
the greatest dieldrin
concentrations detected in
groundwatcr. •
Per CERCLA guidance,
five-year reviews
involving further
groundwater sampling
will be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Extraction wells for the OU I
groundwater remediation
system are located in the
vicinity of the greatest
dieldrin concentrations
detected in groundwater.
Per CERCLA guidance, five-
year reviews involving
further groundwater sampling
will be conducted.
Additional groundwatcr
extraction wells arc installed
in the Above Upper Horizon
in the following locutions:
SWMUs 2 and 3 (three
wells), SWMUS (two
wells), and the Tracy Annex
(four wells). Estimated flow
rate at each extraction well is
5 gallons per minute (gpm).
Treated groundwater (no
VOC contamination) is
rcinjected from SWMU 8
using injection facilities.
Groundwater monitoring is
included in Well Monitoring
Program.
• Three additional ground-
water extraction wells are
installed in the Above
Upper Horizon near
SWMUs 2 and 3. Estimated
How rate at each extraction
well is 5 gpm.
• Treated water is discharged
to infiltration gallery.
• Groundwater monitoring is
included in Well Monitoring
Program.
-------
ta
r
o
R
Table 7-2. (Continued)
Alternatives
Description of
Details
No Further Action
Institutional Controls
Groundwater Extraction and
Treatment-Option t
Groundwater Extraction
and Treatment-Option 2
Iniplcmcntability
Risk Reduction
No action is required to
implement provided an
annual ground water
monitoring program is
implemented us planned.
This alternative does not
reduce the risk of human
or environmental
exposure.
• Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
• The land use restriction
affects ground water use, but
allows the annex and off-base
areas to remain in productive
agricultural use.
This alternative reduces the
risk of human exposure to
dieldrin. However, it does
not actively reduce the risk to
the environment.
• It is feasible to install
groundwater extraction wells
with pad-mounted liquid-
phase GAC systems and
conveyance piping for each
well.
• Coordination with regulatory
agencies is required for
installation of any wells and
operation of the groundwater
treatment system.
This alternative is protective
of both human health and the
environment because
groundwater is extracted and
treated at all three areas of
contamination.
Groundwater modeling
predicts that in 50 years the
dicldrin concentration may be
reduced below the aquifer
cleanup standard (California
Action Level) of 0.05 ug/L at
SWMUs 2 and 3 and SWMU
8. At the Tracy Annex, the
cleanup standard will not be
met in 50 years.
I
It is feasible to install
groundwater extraction
wells with pad-mounted
liquid-phase GAC
systems and conveyance
piping for each well.
Coordination with
regulatory agencies is
required for installation of
any wells and operation of
the groundwater treatment
system.
This alternative is
protective of both human
health and the
environment at the area
where groundwater is
extracted and (rented.
Ground water modeling
predicts that in 50 years
the dicldrin concentration
can possibly be reduced
below the aquifer cleanup
standard (California
Action Level) of 0.05
ug/L at SWMUs 2 and 3.
The dieldrin concentration
will not be actively
reduced at the DDJC-
Tracy Annex or
SWMU 8.
-------
Table 7-2. (Continued)
Alternatives
Description of
Details
No Further Action
Institutional Controls
Groundwater Extraction and
Treatment-Option 1
Groundwater Extraction
and Treatment-Option 2
Major ARARs and
TUCs
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Chemical-specific TDCs
were developed from Water
Quality Goals (CVRWQCB,
1993).
• No chemical-specific or
location-specific ARARs are
identified. Chemical-specific
TBCs were developed from
Water Quality Goals
(CVRWQCB, 1993).
• Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
• Spent GAC can only be
stored on-site for 90 days.
No chemical-specific or
location-specific ARARs
are identified. Chemical-
specific TBCs were
developed from Water
Quality Goals
(CVRWQCB, 1993).
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
Spent GAC can only be
stored on-site for 90 days.
Estimated Cost
(Present Worth)
$9,561,600 ($49,000 for
additional reviews)
$9,601,000 ($99,000 for
additional monitoring)
$ 12,040,000 ($2,528,000 to
address dieldrin)
$10,909,000 ($1,396,000
to address dieldrin)
ARARS = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CCRCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CiAC = Granular Activated Carbon
OU = Operable Unit
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United Slates Environmental Protection Agency
ug/L = microgram per Liter
VOC = volatile organic compound
-------
X
[-
n
Table 7-3. Remedial Alternatives for SWMU 1/Area 2, Area 1 Building 237, and Area 3
Description of
Details
Alternatives
No Action
Institutional Controls
Soil Vapor Extraction
Excavation and Disposal
Treatment Process
Description
None.
Containment or
Storage
Components
Groundwutcr
Components
None.
Groundwatcr monitoring is •
included in Well
Monitoring Program.
Per CERCLA guidance, •
five-year reviews
involving minimal
ground water sampling will
be conducted.
None.
Impose land use restrictions
for areas where elevated
concentrations of TCE and
PCE in the soil have been
detected.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance,
five-year reviews involving
minimal groundwater
sampling will be conducted.
In situ SVE system installed in
the area of highest
contamination at each site.
Each SVE well has an
approximately 40-foot range
of influence.
Wells are screened from
approximately 5 feet bgs to
approximately 3 feet above the
water table.
Extracted air treated by vapor
phase GAC.
Treated air discharged to
atmosphere.
None.
Groundwatcr monitoring is
included in Well Monitoring
Program.
Soil contaminated with VOCs
excavated from each site:
- 30,100 yd3 at SWMU I/
Area 2,
- 8,500 yd3 at Area I Dldg.
237.
- 25,200 yd3 at Area 3.
Soil transported to a Class I
off-depot disposal facility.
Clean soil imported from off-
depot to backfill the excavated
areas.
None.
Groundwulcr monitoring is
included in Well Monitoring
Program.
I
-------
CD
r
o
8
Table 7-3. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Soil Vapor Extraction
Excavation and Disposal
Impknicntaliility
Risk Reduction
Miijor AKARsand
TltCs
Estimated Cost
(Present Worth)
S?
No action is required to
implement provided annual
groundwater monitoring
program is implemented us
planned.
Tills alternative docs not
reduce the risk of human or
environmental exposure to
PCE and TCE.
• Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
$15,000 (for each site)
Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
This alternative reduces the
risk of human exposure to
TCE and PCE. However.it
does not actively reduce the
risk to the environment
(groundwater).
Chemical-specific TBCs
were developed from Water
Quality Goals
(CVRWQCB, 1993).
$65,000 (for each site)
It is feasible to install and
maintain the SVE system.
This alternative is protective of
human health and (lie
environment.
It is expected (hat continuous
operation of the SVE system
for 6 months will remove the
threat of VOC migration to
groundwater.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management, California
requirements for groundwater
protection, and air quality
management district
requirements lor air emissions
from GAC.
$266,000 (SWMU I/Area 2)
$140.000 (Area I Bldg. 237)
$242,000 (Area 3)
It is feasible to excavate and
landfill the contaminated soil.
This alternative is protective
of human health and the
environment.
The threat of VOC migration
to groundwater is removed
immediately on completion of
excavation.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements fur
groundwater protection.
$19,785,000 (SWMU I/Area
2)
$5,607,000 (Area I Bldg. 237)
$16.662.000 (Area 3)
-------
CD
r
Table 7-3. (Continued)
ARARs = Applicable or Relevant and Appropriate Requirements
hgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CCRCLA = Comprehensive Environmental Response, Compensation, and Liability Act
GAC = Granular Activated Carbon
PCE = tctrachlorocthcnc
SVE = Soil Vapor Extraction
SWMU = Solid Waste Management Unit
TUC = to be considered
TCE = trichlorocthcnc
U.S. EPA = United States Environmental Protcclion Agency
VOCs = volatile organic compounds
yd1 = cubic yards
D
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I
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-------
Table 7-4. Remedial Alternatives for SWMU 4 - Storm Drain Lagoon
Alternatives
Description of
Details
No Action
Upstream Source Control
Limited Excavation and Disposal of
Sediments
Treatment Process
Description
Containment or
Storage
Components
Ground water
Components
Implementability
Risk Reduction
• None.
None.
Groundwater monitoring is included
in Well Monitoring Program.
Per CERCLA guidance, five-year
reviews involving minimal sediment,
surface water, and groundwater
sampling will be conducted.
No action is required to implement
provided annual groundwater moni-
toring program is implemented as
planned.
There is no potential risk of human
exposure at SWMU 4. However, this
alternative does not actively reduce
the potential risk posed to ecological
receptors or groundwater.
• Remove sediment periodically (2,300
yd3 every five years) from storm water
conduits upstream of the storm drain
lagoon.
• Dewater and transport the sediment to
an off-site Class I disposal facility.
• None.
Groundwater monitoring is included in
Well Monitoring Program.
This alternative is easy to implement.
There is no potential risk of human
exposure at SWMU 4. However, this
alternative docs not directly, imme-
diately reduce the potential risk posed
to ecological receptors.
This alternative prevents the potential
threat to groundwater and surface water
from increasing.
Excavate sediment contaminated with metals
and pesticides.
Dewater and transport the sediment to a
Class III (municipal) facility for disposal.
Temporarily stockpile excavated material on-
silc.
Groundwater monitoring is included in Well
Monitoring Program.
It is difficult to implement this alternative due
to the logistics required to drain the lagoon
prior to sediment removal.
This alternative is protective of human health
and the environment. However, the
excavation of contaminated sediment could
have a much larger negative impact on the
lagoon ecosystem and the aquatic biota than
the ecological risks posed by the
contaminants.
-------
Table 7-4. (Continued)
Alternatives
Description of
Details
No Action
Upstream Source Control
Limited Excavation and Disposal of
Sediments
Risk Reduction
(Continued)
Major ARARs and
TBCs
Federal ambient water quality criteria
for protection of aquatic life is a
chemical-specific ARAR for surface
water.
Chemical-specific TBCs for
groundwater protection were
developed from Water Quality Goals
(CVRWQCB, 1993).
California Fish and Game Code is a
location-specific ARAR.
No action-specific ARARs are
identified.
Federal ambient water quality criteria
for protection of aquatic life is a
chemical-specific TBC for surface
water.
Chemical-specific TBCs for
groundwater protection were developed
from Water Quality Goals
(CVRWQCB, 1993).
California Fish and Game Code is a
location-specific ARAR.
Action-specific ARARs include
California and federal requirements for
hazardous waste management and
California requirements for groundwater
protection.
The threat posed to ecological receptors is
removed by isolating the receptors from
contaminants in subsurface soils.
Federal ambient water quality criteria for
protection of aquatic life is a chemical-
specific TBC for surface water.
Chemical-specific TBCs for groundwater
protection were developed from Water
Quality Goals (CVRWQCB, 1993).
California Fish and Game Code is a
location-specific ARAR.
Action-specific ARARs include California
and federal requirements for hazardous
waste management and California
requirements for groundwater protection.
Estimated Cost • $25,000 • $1,158,000
(Present Worth)
• $ 552,000
ARARs = Applicable or Relevant and Appropriate Requirements
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVOC = scmivolalilc organic compound
SWMU = Solid Waste Management Unit
TBC = to be considered
yd3 = cubic yards
-------
Table 7-5. Remedial Alternatives for SWMU 6 - Building 28 Sump
Description of
Details
Alternatives
No Action
Institutional Controls
In Situ Stabilization
Excavation and Disposal
Treatment Process
Description
None.
None.
• Mix contaminated soils
with pozzolanic materials
using an auger and well
head system to physically
and chemically
immobilize pesticide
contamination.
Excavate soil contaminated with
pesticides (100 yd3) from SWMU 6.
Transport 60 yd3 of soil to a Class I or
Class II off-site disposal facility
depending on the level of
contamination.
Import clean soil from off site to
backfill the excavated areas.
Containment or
Storage
Components
Groundwater
Components
None.
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling will
be conducted.
Impose land use
restrictions for area
where elevated
concentrations of
pesticides have been
detected.
Groundwater monitoring
is included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling
will be conducted.
• Capture vapors or dust
produced during the
stabilization process.
Groundwater monitoring
is included in Well
Monitoring Program.
Temporarily stockpile excavated
material on-site.
• Groundwater monitoring is included
in Well Monitoring Program.
O
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n
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k
ex
n
Implcmenlubility
I
• No action is required to
implement provided annual
groundwater monitoring
program is implemented as
planned.
Cooperation is required
among the Army, the
U.S. EPA, San Joaquin
County, and Cal-EPA to
enact the land use
restrictions.
This alternative is
technically feasible and
commercially available.
It is feasible to excavate, transport,
and landfill the contaminated soil.
3
»
D
O
*
O
-------
Table 7-5. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
In Situ Stabilization
Excavation and Disposal
Risk Reduction
Major ARARs and
TUCs
Estimated Cost
(Present Worth)
There is no potential risk to
human exposure at SWMU
6. This alternative does
not reduce the risk of
environmental exposure to
pesticides.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993)
$15,000
There is no potential risk
to human exposure at
SWMU 6. This
alternative does not
actively reduce the risk
of environmental
exposure to pesticides.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993)
$ 65,000
This alternative is
protective of human
health and the
environment.
The potential threat to
groundwater is
significantly reduced.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993)
$ 169,000
This alternative is protective of human
health and the environment.
The threat of contamination migrating
to groundwater is removed
immediately on completion of
excavation.
Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993)
$ 65,000 for Class I disposal or
$ 45.000 for Class II disposal
ARARs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response. Compensation, and Liability Act
SWMU = Solid Waste Management Unit
TUC = lo be considered
U.S. liPA = United Stales Environmental Protection Agency
yd3 = cubic yards
-------
H
CE
Table 7-6. Remedial Alternatives for SWMU 7 - Burn Pit No. 1
Alternatives
Description of
Details
No Action
Institutional Controls
In Situ Stabilization with
Institutional Controls
Excavation and Disposal with
Institutional Controls
Treatment
Process
Description
None.
• None.
Mix contaminated soils with
pozzolanic materials using an
auger system fur mixing and
an injector head system to
apply stabilization agents.
Excavate 3,600 yd3 (4,700 tons)
of contaminated soil and debris.
Transport (he contaminated soil
to a Class I off-site disposal
facility.
Import clean soil from off-site
to backfill the excavated areas.
Containment or
Storage
Components
None.
Impose land use restrictions
for areas where elevated
concentrations of VOCs,
SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons in the soil have
been detected.
Capture vapors or dust
produced during the
stabilization process.
None.
Groundwatcr
Components
j?
n
I
Ground water
monitoring is included
in Well Monitoring
Program.
Per CliRCLA guidance,
five-year reviews
involving minimal
groundwater sampling
will be conducted.
Install two additional
monitoring wells
downgradient of the site.
Monitor the two wells for OP
pesticides, OC pesticides,
chlorinated herbicides,
carbon/urea pesticides, and
dioxins/furans semiannually
for one year.
Monitor one well for SVOCs
annually for four years.
Groundwatcr monitoring is
included in Well Monitoring
Program.
Groundwatcr monitoring is
included in Well Monitoring
Program.
Ground water monitoring is
included in Well Monitoring
Program.
-------
CD
r
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Table 7-6. (Continued)
Alternatives
Description of
Details
No Action
Institutional Controls
In Situ Stabilization with
Institutional Controls
Excavation and Disposal with
Institutional Controls
Implcmcntubility
• No action is required to
implement provided
annual groundwatcr
monitoring program is
implcnentcd us planned.
Cooperation is required among
the Army, the U.S. EPA, San
Joaquin County, and Cal-EPA
to enact the land use
restrictions.
This is a technically feasible
and commercially available
technology. Materials
required lor implementing this
alternative arc readily
available.
It is feasible to excavate,
transport, and landfill the
contaminated soil.
Risk Reduction
Major ARARs
and TIJCs
• This alternative docs
not reduce the risk of
human or
environmental exposure
to VOCs, SVOCs,
pesticides and
herbicides, petroleum
hydrocarbons.
• Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCU,
1993).
• This alternative reduces the
risk of human exposure to
VOCs, SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons. However, it
does not actively reduce the
risk to the environment or
ground water.
• Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Estimated Cost
• $ 15.000
$ 208.0CX)
This alternative is protective
of human health and the
environment.
This alternative significantly
reduces the threat posed to the
groundwater.
Chemical-specific TBCs were •
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs •
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
$ 822,0(K) •
This alternative is protective of
human health and the
environment.
The potential threat of SVOC,
pesticide and herbicide, and
petroleum hydrocarbon
migration to groundwatcr
would be eliminated.
No chemical-specific or
location-specific ARARs are
identified.
Action-specific ARARs include
California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
$ 2,605.000
I?
0
-------
o AKAUs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CliRCLA = Comprehensive Environmental Response, Compensation, and Liability Act
OP = organophosphorus
OC = organochlorinc
SVOCs = scmivolatilc organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. liPA = United Stales Environmental Protection Agency
VOCs = volatile organic compounds
Table 7-6. (Continued)
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Table 7-7. Remedial Alternatives for SWMU 8 - Burn Pit No. 2
Description of
Details
Alternatives
No Action
Institutional Controls
Bloventlng
Excavation and Disposal
Treatment
Process
Description
Containment or
Storage
Components
Groundwatcr
Components
• None.
None.
install a new monitoring
well between the two
existing monitoring
wells.
Monitor the new well
and the two existing
wells for OC pesticides
over four quarters for
one year.
Groundwater monitoring
is included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwatcr sampling
will be conducted.
None.
• Impose land use restrictions for
areas where elevated
concentrations of SVOCs,
pesticides and herbicides, and
petroleum hydrocarbons in the
soil have been detected.
• Install a new monitoring well
between the two existing
monitoring wells.
• Monitor the new well and the
two existing wells for OC
pesticides over four quarters for
one year.
• Groundwater monitoring is
included in Well Monitoring
Program.
• Per CERCLA guidance, five-
year reviews involving
minimal groundwater sampling
will be conducted.
• Groundwater monitoring is
included in Well Monitoring
Program.
Install three air-injection well
clusters to oxygenate the
subsurface.
Install a pad-mounted blower
adjacent to the air-injection
well to supply air necessary to
enhance biodegradation in the
subsurface.
None.
Install one new monitoring
well between the two existing
monitoring wells.
Monitor the new well and (he
two existing wells for OC
pesticides over four quarters
for one year.
Groundwater monitoring is
included in Well Monitoring
Program.
• Excavate 4,500 yd' (5,800
tons) of contaminated soil and
debris.
• Transport 3,400 tons of
contaminated soil to a Class I
off-site disposal facility.
• Transport 2,400 tons of debris
to a Class III off-site disposal
facility.
• Import clean soil from off-site
to backfill the excavated areas.
• Temporarily stockpile
excavated materials on-site.
Install one new monitoring
well between (he two existing
monitoring wells.
Monitor the new well and the
two existing wells for OC
pesticides over four quarters
for one year.
Groundwatcr monitoring is
included in Well Monitoring
Program.
-------
w
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n
Table 7-7. (Continued)
Description of Alternatives
Details No Action Institutional Controls
Bioventing
Excavation and Disposal
Implenicntuhility
Risk Reduction
Major ARARs
and TBCs
No action is required to
implement provided
annual groundwatcr
monitoring program is
implemented as planned.
New monitoring wells
can be easily installed.
This alternative does not
reduce the risk of human
or environmental
exposure to SVOCs,
pesticides and
herbicides, or petroleum
hydrocarbons.
Additional monitoring
will help clarify actual
exposure potential and
risk to groundwatcr.
Chemical-specific TBCs
were developed from
Water Qualtiy Goals
(CVRWQCB, 1993).
Cooperation is required among
the Army, the U.S. EPA, San
Joaquin County, and Cal-EPA
to enact the land use
restrictions.
This alternative reduces the
risk of human exposure to
SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons. However, it
docs not actively reduce the
risk to the environment.
Additional monitoring will help
clarify actual exposure potential
and risk to groundwater.
Chemical-specific TUCs were
developed from Water Qualtiy
Goals (CVRWQCB, 1993).
Estimated Cost
(Present Worth)
$ 15,000
$65.000
It is feasible to install and
maintain the biovcnting
system. However, air-
injection wells may be
difficult to install and operate
due to construction debris.
This alternative is protective
of human health and the
environment.
The petroleum hydrocarbons
and SVOCs should be reduced
below the cleanup standard in
two years.
This alternative docs not
reduce the threat posed to the
groundwater by pesticides in
(he soil.
Chemical-specific TBCs were
developed from Water Qualtiy
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for ha/.ardous
waste management and
California requirements for
groundwutcr protection.
$ 246,000
Excavation may be difficult at
SWMU 8 due to construction
debris. The debris must be
separated from the
contaminated soil before
disposal.
This alternative is protective
of human health and the
environment.
The potential threat of SVOC,
pesticide and herbicide, and
petroleum hydrocarbon
migration to groundwater
would be eliminated.
Chemical-specific TBCs were
developed from Water Qualtiy
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwatcr protection.
$ 2,823,000
I
-------
o
n
Table 7-7. (Continued)
AKAKs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CEUCLA = Comprehensive Environmental Response, Compensation, and Liability Act
OC = organochlorinc
SWMU = Solid Waste Management Unit
"I'UC = to be considered
U.S. liPA = United Stales Environmental Protection Agency
SVOCs = scniivolatilc organic compounds
yd3 = cubic yards
O
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n
Q.
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n
3
3
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n
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3
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Table 7-8. Remedial Alternatives for SWMU 20 - Aboveground Solvent Tank/Building 26
Recoup Operations and Area 1 Building 10
Alternatives
Description of
Details
No Action
Institutional Controls
SVE, Excavation and Disposal,
and Natural Attenuation
Excavation and Disposal
Treatment Process • None.
Description
• None.
Containment or
Storage
Components
Ground water
Components
None.
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling will
be conducted.
Impose land use restrictions
lor areas where elevated
concentrations of
contaminants in the soil have
been detected.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, II vc-
year reviews involving
minimal groundwater
sampling will be conducted.
Excavate the contaminated soil
(250 yd5) from SWMU 20.
Transport soil to a Class I off-site
disposal facility.
Import clean soil from off-site to
backfill the excavated areas.
Install in situ SVE system in the
vicinity of SB 108 at Area I
Building 10 and SB431 to reduce
TCE concentrations below
cleanup standard.
Soil contaminated with 2,4,6-
trichlorophenol is expected to
naturally attenuate before it
reaches groundwater.
None.
Groundwater monitoring is
included in Well Monitoring
Program.
Excavate soil (500 yd3)
contaminated with VOCs,
SVOCs, pesticides, and
petroleum hydrocarbons from
SWMU 20 and Area 1
Building 10.
Transport soil to a Class I off-
site disposal facility.
Import clean soil from off-site
to backfill the excavated
areas.
• Temporarily stockpile
excavated materials on-siic.
• Groundwater monitoring is
included in Well Monitoring
Program.
O
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n
3
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70
t
D
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-------
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8
Table 7-8. (Continued)
Alternatives
Description of
Details
No Action
Institutional Controls
SVE, Excavation and Disposal,
and Natural Attenuation
Excavation and Disposal
Implcincntability
Risk Reduction
Major ARARsand
TBCs
No action is required to
implement provided
annual groundwater
monitoring program is
implemented as planned.
This alternative does not
reduce the risk of human
or environmental exposure
to VOCs, SVOCs, and
pesticides and herbicides.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Estimated Cost
(Present Worth)
$ 15,000
Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
This alternative reduces the
risk of human exposure to
VOCs, SVOCs, and
pesticides and herbicides.
However, it does not reduce
the risk to the environment.
Chemical-specific TBCs
were developed from Water
Qualtiy Goals (CVRWQCB,
1993).
$65,000
It is feasible to install and
maintain the SVE system.
It is feasible to excavate,
transport, and dispose of the
contaminated soil.
This alternative is protective of
human health and the
environment.
The threat of contaminant
migration to groundwater would
be eliminated.
Chemical-specific TBCs were
developed from Water Qualliy
Goals (CVRWQCB, 1993).
Action-specific ARARs include
California and federal
requirements for hazardous waste
management, California
requirements for groundwatcr
protection, and AQMD
requirements for air discharges
from the SVE system.
$ 293,000
It is feasible to excavate,
transport, and dispose of the
contaminated soil.
This alternative is protective
of human health and the
environment.
The threat of contaminant
migration to groundwater
would be removed
immediately on completion of
excavation.
Chemical-specific TBCs were
developed from Water Qualtiy
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
$ 355,000
I'
cr
-------
H
33
r
Table 7-8. (Continued)
ARAKS = Applicable or Rclcvani and Appropriate Requirements
Cal-GPA = California Environmental Protection Agency
CliKCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVE = Soil Vapor Extraction
SVOCs = scmivolaiilc organic compounds
SWMU = Solid Waste Management Unit
TUC = to be considered
TCE = trichlorocthcnc
U.S. EPA = United States Environmental Protection Agency
VOCs = volatile organic compounds
D
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n
'Si
I
I
3
CL
I
3-
n
I
S
70
t
5
o
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-------
Table 7-9. Remedial Alternatives for SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank
•o
0
O
n
Alternatives
Description of
Details
No Action
Institutional Controls
Bioventing
Excavation and
Disposal
Excavation and On-Site
Bloremediation
Treatment Process •
Description
None.
None.
Install an air-injection
well and a pad-
mounted blower
system.
The well should be
screened from 6 feet
bgs to 16 feet bgs.
Excavate 240 cubic
yards (320 tons) of
contaminated soil
and debris.
Transport the
contaminated soil to
a Class I off-site
disposal facility.
Import clean soil
from off site to
backfill the
excavated areas.
Excavate the soil with
contaminant levels above
cleanup standards.
Treat the soil
aboveground using on-
site bioremcdiaiion, such
as landfarming, slurry-
phase reactors,
composting, or biopiles.
The actual remediation
process chosen to
remediate this site will be
determined during (lie
remedial design phase.
The treated soil will be
backfilled at the site.
Containment or • None.
Storage
Components
• Impose land use • None.
restrictions for areas
where elevated
concentrations of
contaminants in the soil
have been detected.
• None. • None.
-------
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ra
s
3
1
Table 7-9.
(Continued)
Alternatives
Description of
Details No Action
(iruundwalcr • Monitor well
Components LM 1 1 8A A for TPH as
gasoline and TPH as
dicsel quarterly for
three quarters.
• Groundwater
monitoring is included
in Well Monitoring
Program.
• Per CEIICLA
guidance, five-year
reviews involving
minimal groundwatcr
sampling will be
conducted. Analytical
data will be reviewed
to assess the potential
threat to groundwater
contamination.
luipkincntul)ility • There arc no
implementation issues.
Institutional Controls
• Monitor well •
LMIISAAforTPHas
gasoline and TPH as
diescl on a quarterly
basis for three quarters.
• Groundwatcr •
monitoring is included
in Well Monitoring
Program.
• Per CERCLA
guidance, five-year
reviews involving
minimal groundwatcr
sampling will be
conducted. Analytical
data will be reviewed to
assess the potential
threat to groundwater
contamination.
• Cooperation is required •
among the Army, U.S.
EPA, San Joaquin
County, and Cal-EPA
to enact the land use
restrictions.
Bioventing
Monitor well •
LMI ISA A for TPH as
gasoline and TPH as
dicsel quarterly for three
quarters.
Groundwalcr
monitoring is included •
in Well Monitoring
Program.
It is feasible to install •
and maintain the
biovcnting system.
Excavation and
Disposal
Monitor well
LM 11 BAA for TPH
as gasoline and TPH
as dicsel on a
quarterly basis for
three quarters.
Groundwater
monitoring is
included in Well
Monitoring
Program.
Excavation of soil
beneath Building
247 may be difficult
due to excavation
depth of 17 feet.
Excavation and On-Siti
Bioremedlation
• Monitor well
LMIlSAAforTPH
as gasoline and TPH
as diesel quarterly for
three quarters.
• Groundwater
monitoring is
included in Well
Monitoring Program.
• Excavation of soil
beneath Building 247
may be difficult due
to excavation depth of
17 feet.
-------
00
r
D
O
n
Table 7-9. (Continued)
Alternatives
Description of
Details No Action Institutional Controls
Bioventing
Excavation and
Disposal
Excavation and On-Siti
Bioremediation
Risk Reduction
• This alternative does
not reduce the risk of
human or
environmental
exposure to
contaminants.
This alternative reduces
the risk of human
exposure to
contaminants, but does
not reduce the risk to
ground water.
This alternative is
protective of human
health and the
environment.
The VOCs, SVOCs, and
petroleum hydrocarbons
are reduced below the
cleanup standard in two
years.
This alternative
permanently reduces the
threat posed lo the
groundwalcr by
biodcgrading the
primary soil
contaminants (VOCs,
SVOCs, and petroleum
hydrocarbons).
Although PCBs and
pesticitlcs arc present in
(he soil at SWMU 24,
the groundwater threat
posed by these
compounds is
considered low.
This alternative is
protective of human
health and the
environment.
The potential threat
of contaminant
migration to
groundwater would
be eliminated.
This alternative is
protective of human
health and the
environment.
The potential threat of
contaminant
migration to
groundwater would
be eliminated.
sr
-------
5)
Table 7-9. (Continued)
Alternatives
Description of
Details No Action Institutional Controls Bioventlng
Major ARARs • Chemical-specific • Chemical-specific • Chemical-specific TBCs •
and TBCs TBCs were developed TBCs were developed were developed from
from Water Quality from Water Quality Water Quality Goals
Goals (CVRWQCB, Goals (CVRWQCB, (CVRWQCB, 1993).
1993). 1993). . Action-specific ARARs
include California and
federal requirements for •
hazardous waste
management and
California requirements
for groundwatcr
protection.
Excavation and Excavation and On-Siti
Disposal Bloremediation
Chemical-specific •
TBCs were
developed from
Water Quality Goals
(CVRWQCB,
1993). .
Action-specific
ARARs include
California and
federal requirements
for hazardous waste
management and
California
requirements for
groundwater
protection.
Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993).
Action-specific
ARARs include
California and federal
requirements for
hazardous waste
management and
California
requirements for
groundwater
protection.
Estimated Cost • $15,000 • $65,000 • $166,000 • $214,000 • $263,000
(Present Worth)
ARARs
bgs
Ca!-EPA
CERCLA
PCB
SVOCs
SWMU
TBC
Tl'll-D
TPII-G
U.S. EPA
VOCs
s
=
=
=
=
=
=
=
=
=
=
s
Applicable or Relevant and Appropriate Requirements
below ground surface
California Environmental Protection Agency
Comprehensive Environmental Response, Compensation, and Liability Act
polychlorinatcd biphcnyl
semivolatile organic compounds
Solid Waste Management Unit
(o he considered
loliil petroleum hydrocarbons us dicscl
total petroleum hydrocarbons as gasoline
United States Environmental Protection Agency
volatile organic compounds
i
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I
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n
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n
•7)
\
I
o
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cc
r
Table 7-10. Remedial Alternatives for SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
Treatment Process
Description
None.
None.
Excavate soil contaminated to 16 I'cct bgs
around the sump and to 5 feet bgs in (he
other areas based on the nature and extent of
contamination.
Transport 130 yd3 (170 tons) of contaminated
soil and concrete to a Class I off-site disposal
Import clean soil from off-depot to backfill
the excavated areas.
Containment or
Storage
Components
None.
Impose lund use restrictions for area
where elevated concentrations of VOCs,
SVOCs, and PCBs in the soil have been
detected.
None.
Ground water
Components
Groundwater monitoring is included
in Annual Well Monitoring Program.
Per CERCLA guidance, five-year
reviews involving minimal
groundwalcr sampling will be
conducted.
Groundwalcr monitoring is included in
Annual Well Monitoring Program.
Per CERCLA guidance, five-year reviews
involving minimal groundwatcr sampling
will be conducted.
Groundwater monitoring is included in
Annual Well Monitoring Program.
O
2
to
Implcnicnlability
Risk Reduction
No action is required to implement
provided annual groundwater
monitoring program is implemented
as planned.
This alternative docs not reduce the
risk of human or environmental
exposure to VOCs, SVOCs, and
PCBs.
Cooperation is required among the Army,
the U.S. EPA, San Joaquin County, and
Cal-EPA to enact the land use
restrictions.
This alternative reduces the risk of human
exposure to VOCs. SVOCs, and PCDs.
However, it docs not actively reduce the
risk to the environment.
It is feasible to excavate, transport, and
dispose of the contaminated soil.
This alternative is protective of human health
and the environment.
The threat of contaminant migration to
groundwater is removed immediately on
completion of the excavation.
a.
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3
8
o
3.
o
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a
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n
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o
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Table 7-10. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
Major ARARs
and TUCs
Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993).
Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
Estimated Cost
(Present Worth)
$ 15,000
$ 65,000
Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
Action-specific ARARs include California
and federal requirements for hazardous waste
management and California requirements for
groundwater protection.
$ 112,000
ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation and Liability Act
PCBs = polychlorinated biphenyls
SVOCs = semivolatile organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United Stales Environmental Protcciion Agency
VOCs = volatile organic compounds
yd3 = cubic yards
-------
Table 7-11. Remedial Alternatives for Building 30 Drum Storage Area
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
o
Treatment Process
Description
None.
None.
Excavate contaminated soil to 18 feet bgs.
Transport 2,800 yd' (3,600 tons) of
contaminated soil to a Class I or Class II
off-site disposal facility based on the level
of contamination.
Import clean soil from off-depot to backfill
the excavated areas.
Containment or
Storage
Components
• None.
Groundwater • Groundwater monitoring is included
Components in Well Monitoring Program.
• Per CERCLA guidance, five-year
reviews involving minimal
groundwater sampling will be
conducted.
Impose land use restrictions for areas
where elevated concentrations of benzyl
alcohol and phthalates in (he soil have
been detected.
Install a monitoring well downgradient of
the Building 30 Drum Storage Area.
Monitor quarterly for one year for
SVOCs.
Groundwater monitoring is included in
Well Monitoring Program.
Per CERCLA guidance, five-year reviews
involving minimal groundwater sampling
will be conducted.
None.
Groundwater monitoring is included in Well
Monitoring Program.
Implemcntability
• Site reviews are very easy to
implement.
• Cooperation is required among the Army,
the U.S. EPA, San Joaquin County, and
Cal-EPA to enact the land use
restrictions.
It is feasible to excavate, transport, and
dispose of the contaminated soil.
Risk Reduction
I?
8
I
i
• This alternative does not reduce the
risk of human or environmental
exposure to benzyl alcohol and
phthalnies.
This alternative reduces the risk of human •
exposure to benzyl alcohol and
phthalates. However, it does not actively •
reduce the risk to the environment.
This alternative is protective of human
health and the environment.
The threat of contaminant migration to
groundwater is removed immediately on
completion of ihe excavation.
-------
3
Table 7-11. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
Major ARARs
and TUCs
Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993).
Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
Estimated Cost
(Present Worth)
$10,000
$87,000
Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
Action-specific ARARs include California
and federal requirements for hazardous
waste management and California
requirements for groundwater protection.
$ 907,000 (Class II disposal), or
$ i.860.000 (Class I disposal)
ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVOCs = semivolalile organic compounds
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd3 = cubic yards
-------
8
n
Table 7-12. Remedial Alternatives for Surface and Near-Surface Soil - Northern Depot Area
Description ol
Details
Alternatives
No Action
Institutional Controls
Asphalt Cover
Excavation and Disposal
Treatment
Process
Description
None.
None.
None.
Excavate 3,000 yd3 (4,000
tons) of soil containing
elevated levels of arsenic
and manganese.
Transport the contaminated
soil to a Class II or Class HI
off-site disposal facility
depending on the level of
contamination.
Containment or
Storage
Components
Ground water
Components
Implementability
None.
• Per CERCLA guidance,
five-year reviews will be
conducted.
• Site reviews are very easy to
implement.
• No action is required to
implement provided annual
groundwater monitoring
program is implemented as
planned.
Impose land use restrictions
for areas where elevated
concentrations of
contaminants in the soil have
been detected.
Per CERCLA guidance, five-
year reviews will be
conducted.
Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
Install an asphalt cover
over the soils with
elevated levels of arsenic
and manganese.
Per CERCLA guidance
five-year reviews will be
conducted.
It is easy to implement
this alternative.
None.
Per CERCLA guidance five-
year reviews will be
conducted.
Excavation, transportation,
and disposal of soil are
easily implementable.
a
2
n
n
GO
a.
n
T3
3
3-
n
70
n
n
o
I
i
o
-------
Table 7-12. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Asphalt Cover
Excavation and Disposal
Risk Reduction
• This alternative does not
reduce the risk of human
or environmental
exposure to contaminants.
Major ARARs
and TOCs
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Estimated Cost
(Present Worth)
15,000
This alternative reduces the
risk of human exposure to
arsenic and manganese.
However, it does not
actively reduce the risk to
the environment.
This alternative is
protective of human health
under current and future
land use conditions.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
$ 17,000
An asphalt cover provides
a reliable barrier and
reduces the exposure to
soil contaminants via
dermal contact, ingestion,
and/or inhalation.
The risk to the
environment will nol be
actively reduced; however
the asphalt cap may
reduce potential transport
of contaminants to the
groundwater.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
$ 504,000
This alternative is protective of
human health and the
environment.
The threat of contaminant
migration to groundwater is
removed immediately on
completion of the excavation.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs include
California and federal
requirements for hazardous waste
management and California
requirements for groundwater
protection.
• $ 995,000 (Class II disposal), or
$ 769.000 (Class III disposal)
I
ARARs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
TBC = to be considered
U.S. EPA = United Slates Environmental Protection Agency
yd3 = cubic yards
-------
CO
Table 7-13. Remedial Alternatives for SWMUs 2 and 3
n
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
Treatment Process
Description
Containment or
Storage
Components
Groundwater
Components
None.
• None.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving minimal
soil and groundwater sampling
will be conducted.
None.
Impose land use restrictions for
areas around the lagoons.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving minimal
soil and groundwater sampling
will be conducted.
Excavate soil above cleanup standards identified to
protect groundwater quality.
- 10,000 yd3 estimated to be removed.
Transport soil to a Class III off-depot disposal
facility.
Import clean soil from off-depot to backfill the
excavated areas.
Install geofabric filter and apply additional clean
backfill to protect ecological receptors.
None.
Groundwater monitoring is included in Well
Monitoring Program.
O
a
n
if
•<
C/J
Implementability
Site reviews are very easy to
implement.
No action is required to
implement provided annual
groundwater monitoring
program is implemented as
planned
Cooperation is required among
the Army, the U.S. EPA, San
Joaquin County, and Cal-EPA
to enact the land use
restrictions.
Difficult to implement because of the large volume of
soil/sediment to be excavated.
Excavation will disrupt DDJC-Tracy operations as
the lagoons would not be available for discharge of
effluent from the nearby sewage treatment plant.
Q.
n
n
o
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3
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3
f?
o
O
I
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o
-------
Table 7-13. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation and Disposal
Risk Reduction
This alternative does not reduce
the risk of human or
environmental exposure to
dieldrin, ODD, DDE, DDT, di-
n-butylphthalate, and bis(2-
ethylhexyl)phthalate.
• This alternative reduces the risk
of human exposure to dieldrin,
ODD, DDE, DDT. di-n-
butylphthalate, and bis(2-
ethylhexyl)phthalate. However,
it does not actively reduce the
risk to the environment.
This alternative is protective of human health and the
environment.
The threat of contamination migrating to groundwater
is removed immediately on completion of excavation.
Risks to ecological receptors are mitigated by
isolating receptors from exposure to contaminants.
Major ARARs and
TBCs
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Chemical-specific TBCs were developed from Water
Quality Goals (CVRWQCB, 1993).
Action-specific ARARs include California and federal
requirements for hazardous waste management and
California requirements for groundwater protection.
Estimated Cost • $ 15,000 • $ 65,000 • $2,100,000
(Present Worth)
ARARs
Cal-EPA
CERCLA
EE/CA
SWMU
TBC
U.S. EPA
yd3
= Applicable or Relevant and Appropriate Requirements
= California Environmental Protection Agency
= Comprehensive Environmental Response, Compensation, and Liability Act
= Engineering Evaluation/Cost Analysis
= Solid Waste Management Unit
= to be considered
= United States Environmental Protection Agency
= cubic yards
I
-------
Table 7-14. Remedial Alternatives for SWMU 33
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation, Grouting,
Institutional Controls
Excavation
Treatment Process
Description
None.
Containment or
Storage
Components
None.
Groundwatcr
Components
I?
n
I
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal soil and
groundwater sampling will
be conducted.
• None.
Impose land use restrictions
for areas where elevated
concentration of aldrin,
dieldrin, diethylphthalate,
and di-n-butylphthalate have
been detected.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving
minimal soil and
groundwater sampling will be
conducted.
• Excavate approximately
200 yd3 of soil at
SB464.SB462, and
SB204
Pressure grout •
manholes and laterals to
eliminate discharges.
Groundwater
monitoring is included
in Well Monitoring
Program.
Excavate the entire IWPL and
surrounding soil where aldrin,
dieldrin, diethylphthalate, and di-n-
butylphthalate concentrations are
above the revised soil cleanup
standards.
- 6,700 yd3 estimated to be
removed.
- Depth of excavation 15 feet bgs
and 3 feet on each side of the
pipeline along the entire IWPL.
Transport soil to a Class I off-
depot disposal facility.
Import clean soil from off-depot to
backfill the excavated areas.
None.
Groundwater monitoring is
included in Well Monitoring
Program.
D
2
n
C/3
Q.
n
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o
73
3
n
n
70
n
n
I
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G
t.
Table 7-14. (Continued)
Description of
Details
Alternatives
No Action
Institutional Controls
Excavation, Grouting,
Institutional Controls
Excavation
Implcmcntability • Site reviews are very easy to
implement.
Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
Excavation and
grouting are
implementable.
Difficult to implement excavation
because of utilities and building in
the area and the required
excavation depth at same location.
Excavation will disrupt DDJC-
Tracy operations.
Risk Reduction
Major AKARs and
TIJCs
I?
n
I
This alternative does not
reduce the risk of
environmental exposure to
aldrin, dieldrin,
diethylphthalate, and di-n-
butylphthalate.
Chemical-specific TBCs
were developed from Water
Quality Goals
(CVRWQCB, 1993).
This alternative reduces the
risk of environmental
exposure to aldrin, dieldrin,
diethylphthalate, and di-n-
butylphthalate. However, it
does not actively reduce the
risk to the environment.
Chemical-specific TBCs
were developed from Water
Quality Goals (CVRWQCB.
1993).
Estimated Cost
(Present Worth)
$ 15,000
$ 65,000
Contaminants would be
removed or contained.
Groundwaier
monitoring required to
ensure any future
impacts are addressed.
Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993).
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
$ 242,600
This alternative is protective of
human health and the environment.
The threat of contamination
migrating to groundwater is
removed immediately on
completion of excavation.
Revised FS cleanup standards for
aldrin, dieldrin, diethylphthalate,
and di-n-butylphthalate are met.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB. 1993).
Action-specific ARARs include
California and federal
requirements for hazardous waste
management and California
requirements for groundwater
protection.
$ 4,708,000
-------
Table 7-14. (Continued)
ARARS = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
FS = Feasibility Study
IWPL = Industrial Waste Pipeline
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd3 = cubic yards
I
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o
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5
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3
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Table 7-15. No Further Action Sites
SWMU Number/Site
Description
Comments
SWMU 5
Old Industrial Lagoon
SWMU 9
Subsistence Waste Pit
SWMU
Medical Waste Burial Pit
SWMU l()A
SWMU 11
SWMU 12
Possible Medical Waste Burial Pit
Lime/Foot Bath Burial
Embalming Fluid Dump
VOCs, SVOCs, pesticides, petroleum hydrocarbons and metals have not been released to
the soil from disposal activities. Additionally, the Phase I WQSA showed that
concentrations of metals in site soils do not pose a possible threat to background water
quality or beneficial uses of groundwater at SWMU 5. Low concentrations of TCE are
present in groundwater downgradient of SWMU 5, but the concentrations of TCE are
consistent with concentrations detected in this area of the OU 1 groundwater plume.
No evidence of any buried disposal pit has been found. Metals were detected in site
soils at concentrations that slightly exceeded background thresholds. However, the
Phase I WQSA showed that concentrations of metals in site soils do not pose a possible
threat to background water quality or beneficial uses of groundwater. Samples from
monitoring wells adjacent to SWMU 9 do not indicate any groundwater contamination
associated with the site.
Very little information is available concerning disposal activities at SWMU 9, and it is
possible that the suspected subsistence waste pit reported at this site may instead be the
disposal area identified at SWMU 8.
There has not been a release of contaminants associated with SWMU 10 to soil or
groundwater. No evidence of any subsurface disposal feature was found. No evidence
of disposal or backfilling was observed during trenching and soil boring activities. The
Phase I and Phase II WQSA showed that concentrations of metals in site soils do not
pose a possible threat to background water quality or beneficial uses of groundwater.
SWMU 10A is recommended for no further action because there is no adverse human
health risk posed by COPCs in site soils and the COPCs that have been released to site
soils (bis[2-ethylhexyl]phthalate, dieldrin, and metals) were seldom detected in soil
samples and have not been detected in groundwater above background levels.
No disposal activities have been identified at SWMU 11. Additionally, no potential
source of soil or groundwater contamination has been identified at this site.
No contaminants have been released to the soil or groundwater from the disposal
activities associated with SWMU 12. None of the soil and groundwater samples had
detectable concentrations of formaldehyde or methanol. The Phase I WQSA showed
that concentrations of metals in site soils do not pose a possible threat to background
water quality or beneficial uses of groundwater at SWMU 12. COPCs at SWMU 12
pose a cancer risk below Ixl06and a hazard index of less than 1 for the construction
worker.
-------
Table 7-15. (Continued)
SWMU Number/Site
Description
Comments
SWMU 14
Lube Oil Dump
SWMU 15
Pesticide Waste Trench
SWMU 16
Possible Hazardous Waste Ston>;>e
Area
I
i
SVOCs, pesticides, petroleum hydrocarbons, and metals have been released to vadose
zone soils at SWMU 14. Groundwater has not been impacted by activities at
SWMU 14. COPCs at SWMU 14 do not pose a threat to background grOundwater
quality based on the WQSA and analytical modeling. COPCs at SWMU 14 result in a
cancer risk that is below 1x10
worker.
and a hazard index of less than I for the construction
There has not been a release of contaminants from the former pesticide waste trench to
the soil and groundwater. During drilling activities, no subsurface evidence of a
disposal area was identified. The presence of DDT in one soil sample at a low
concentration is most likely related to a minor isolated spill or chronic use of these
chemicals in the vicinity of DDJC-Tracy, and is not interpreted as indicative of a single
identifiable contaminant source. The isolated occurrence of metals detected above
background is not indicative of an identifiable contamination source. The presence of
two metals in one sample at concentrations only slightly exceeding background may be
related to the inherent natural variability in the environment. The results of the Phase I
WQSA showed that concentrations of metals in site soils do not pose a possible threat to
background water quality or beneficial uses of groundwater. Based on the results of the
analytical modeling, the constituents detected in site soils at SWMU 15 do not pose a
threat to groundwater.
There was no evidence of a disposal area at SWMU 16 based on the results of the Phase
I RI sampling and field observations made during drilling. Metals were detected at
concentrations only slightly greater than DDJC-Tracy background levels in deep soil
samples collected at SWMU 16. Beryllium was the only metal detected in deep soil
samples at a concentration greater than two times its background threshold value. The
low levels of metals exceeding DDJC-Tracy background levels may be related to the
inherent natural variability in the environment, specifically, the presence of expansive
clays at depth beneath the site. All detected concentrations are less than the range of
background values compiled for California and the San Joaquin Valley. The low levels
of OC pesticides, dioxins, and radionuclides are limited in occurrence and are also
interpreted to represent natural conditions at DDJC-Tracy. The WQSA and analytical
modeling performed for SWMU 16 indicate that constituents detected in site soils do not
pose a threat to groundwater. COPCs at SWMU 16 most likely result in a cancer risk
that is below IxlO6 and a hazard index of less than 1 for the construction worker.
O
2
n
8
a.
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o
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n
3
8
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n
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O
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Table 7-15. (Continued)
a.
8
SWMU Number/Site
Description
Comments
SWMU 21
Baltery Acid Dump
SWMU 22
Previous Hazardous Material
Storage Area
SWMU 23
Building 26 Recoup Operations
SWMU 25
Boundary Roads
SWMU 29
Used Motor Oil Disposal Pit
I
No contaminants have been released to the soil and groundwater from the battery shop
activities at SWMU 21. The isolated detection of beryllium in soil at a concentration
only slightly above the background reference levels is attributed to the natural variability
in the environment. Although total barium and iron were detected at concentrations
slightly above background in groundwater, these metals were not detected in site soils
above background levels. It was determined that beryllium does not have the potential
to reach the groundwater within 100 years.
There has been no release of contaminants to the soil from disposal activities associated
with SWMU 22. There are no historical data to suggest that metal-containing wastes
were stored at this site, and the low concentrations of COPCs (beryllium, chromium, and
molybdenum) detected are not distributed in any identifiable spatial pattern that would
be indicative of an anthropogenic source. Additionally, these three metals have not been
detected above background in four quarters of groundwater monitoring from
downgradient monitoring wells. Low levels of TCE and metals (copper and manganese)
have been inconsistently detected in groundwater samples collected at SWMU 22;
however, these constituents may be attributed to another source (SWMU 8), because
these compounds were not detected in soil above the background threshold at
SWMU 22.
Low levels of contaminants were detected in sludge from SL001. None of the
contaminants were present above concentrations that would impact human health,
ecological receptors, or groundwaler quality. The sludge has been removed. The floor
drain connects into the industrial wastewater pipeline (IWPL) and contamination in the
IWPL is being addressed under SWMU 20 and SWMU 33.
There has not been a release of contaminants associated with SWMU 25 dust control
activities to site soils. OC pesticides were not delected above background threshold
levels and petroleum hydrocarbons in the form of TPHD and TPHG were not detected.
In addition, the results of the Phase 1 WQSA showed that concentrations of metals in site
soils do not pose a possible threat to background water quality or beneficial uses of
groundwater at SWMU 25.
No potential source of soil and groundwater contamination was identified at SWMU 29.
No other evidence indicates the presence or location of the used motor oil pit. Because
no evidence of any disposal area or contamination was found within SWMU 29, there
are no known risks associated directly with the site.
-------
Table 7-15. (Continued)
CL
8
SWMU Number/Site
Description
Comments
SWMU 30
Salvage Area
SWMU31
Wood Preservation Area
SWMU 64
Waste Oil Pit
Area I Building 236
Past Solvent Storage and Use
I
Low levels of VOCs were detected in soil-gas samples, however, no spatial pattern of
distribution was observed, and the presence of VOCs was not confirmed by soil samples
collected at SWMU 30. Isolated low concentration of PAHs and phenols were detected
in soil samples. Based on all analytical data collected at the site, no release of
contamination has occurred at SWMU 30. The results of the Phase I WQSA showed
that concentrations of metals in site soils do not pose a threat to background water
quality or beneficial uses of ground water at SWMU30. Phenols and benzene pose a
potential threat to groundwater at SWMU 30 based on the results of the analytical
model. However these constituents are not considered a threat to groundwater because
detections of phenols are not considered representative of current site conditions and
benzene was not detected in site soil samples. COPCs at SWMU 30 do not contribute to
the human health risk calculated for the exposure unit associated with this site.
No contaminants have been released to the soil and groundwater from the wood
preservation activities at SWMU 31. The occurrence of isolated concentrations of
nickel, manganese, and barium at levels only slightly above the background reference
levels in two of four samples from one soil boring location are attributed to the natural
variability in the environment or minor spills. The results of the Phase I WQSA showed
that concentrations of metals in site soils do not pose a possible threat to background
water quality or beneficial uses of groundwater at SWMU 31.
The isolated occurrence of metals detected above background is not indicative of a
identifiable contaminant source. The presence of metals at concentrations only slightly
exceeding background may be related to the inherent variability of background
concentrations expected under naturally occurring conditions. Metals were not
consistently detected in the six quarters of groundwater samples. Based on the results of
the Phase I RI activities, no contaminants have been released to the soil and groundwater
from the former storage tank at SWMU 64.
There has not been a release of contaminants associated with solvent storage activities at
Area 1 Building 236. Although methylene chloride was detected in site soils during
previous investigations, the results of the Phase I investigation did not confirm the
presence of methylene chloride contamination in the soil at Building 236. In addition,
23 soil borings were drilled during investigations near Building 236 and methylene
chloride contamination in soil was not found. There has not been a release of
contaminants to the subsurface in association with drum storage in this area.
a
2
n
n
.
o
o
3
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Table 7-15. (Continued)
SWMU Number/Site
Description
Comments
Drum Slonige Area
Building IS
Drum Storage Area
Building 22
Drum Storage Area
Drum Storage Area
Building 23
Storage Areas
Day Care Center
I
i
No VOC or SVOC constituents were detected in any of the soil samples collected in the
vicinity of Building 15. Because no chemicals were detected in soil samples from (he
Drum Storage Area Building 15, there are no known risks associated with this site.
There has not been a release of contaminants associated with drum storage at Building
22. VOCs were not detected above the reporting limits in soil samples. Phthalate
compounds were detected sporadically, and were attributed to field or laboratory related
contamination. VOC contamination in nearby wells is believed to be related to disposal
activities at other sites. The results of the analytical modeling indicated that bis(2-
cthylhexyOphthalate posed a threat to groundwater; however, recharge at the site was
not sufficient to mobilize di-n-butyl phthalate to groundwater. Numerical modeling
results from other sites which had similar site conditions and concentrations of
phthalates were applied to Drum Storage Area Building 22, to further evaluate
contaminant fate and transport. Based on this final assessment, bis(2-
ethylhexyOphthalate does not pose a threat to groundwater at Drum Storage Area
Building 22.
There has not been a release of contaminants at Building 23. VOCs were not detected in
soil samples above the reporting limit. A phthalate compound was detected in one
sample, but was attributed to laboratory-related contamination. COPCs at Building 23
result in a cancer risk that is below 1x10
construction worker.
and a hazard index of less than I for the
PAHs, pesticides, and lead were present in site soils as a result of nearby operations or
vehicular emissions in the vicinity of the Day Care Center. COPCs at the Day Care
Center posed a cancer risk that was greater than IxlO6 and a hazard index that was less
than I for children. Additional soil sampling was performed by Radian on August 31,
1995 in support of the corrective action proposed for the Day Care Center. The results
of this investigation confirmed the results of the Phase II investigation conducted by
Montgomery Watson in 1994 The corrective action was performed by Davy
International in September and October 1995. All soil within the lawn areas was
excavated to a depth of I foot. Approximately 9 inches of clean fill were placed and
compacted, and then a 3-inch soil cover was laid down. The corrective action resulted in
a reduction of the incremental cancer risks associated with the Day Care Center to zero
by removing the highest concentrations of pesticides, PAHs, and metals and eliminating
the potential for contact with contaminated surface soil.
SWMU = Solid Waste Management Unit
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.0 COMPARATIVE ANALYSIS OF
ALTERNATIVES
8.1 Background
8.1,1 The nine National Contingency Plan
(NCP) evaluation criteria were developed to
provide decision makers with sufficient
information to adequately compare the remedial
alternatives for a site and to select an appro-
priate remedy. These criteria fall into three
groups: threshold criteria, primary balancing
criteria, and modifying criteria. The threshold
criteria must be met for an alternative to be
eligible for selection. The balancing criteria are
used to compare the relative strengths and
weaknesses of the different alternatives. The
modifying criteria are taken into account after
public and regulatory comments are received.
The NCP evaluation criteria are summarized in
Table 8-1.
8.1.2 In the Feasibility Study (FS), the
remedial alternatives presented for each site, or
group of sites, were evaluated using the
following seven NCP criteria:
• Overall protection of human health and the
environment;
• Compliance with Applicable or Relevant
and Appropriate Requirements (ARARs);
• Long-term effectiveness and permanence;
• Reduction of toxicity, mobility, and volume
through treatment;
• Short-term effectiveness;
• Implementability; and
• Cost.
8.1.3 Two additional NCP criteria, state
acceptance and community acceptance, are
addressed based on comments received on the
final RI/FS report and the Proposed Plan. State
acceptance has also been addressed by
incorporating state comments on the draft ROD
into the final ROD. During the public comment
period for the Proposed Plan, only one written
public comment was received (see
Responsiveness Summary).
8.1.4 In this section, the remedial alternatives
presented for each site (or group of sites) are
compared with each other in regard to all nine
criteria to highlight their relative strengths and
weaknesses (see Table 8-2). For all sites, the No
Action (or No Further Action) alternative is
evaluated to provide a baseline for comparison
with the other remedial alternatives. Five-year
reviews are typically part of the No Action
alternative, as contaminants will remain on site.
Institutional Controls, which include land use
restrictions, restrictive covenants, and/or
fencing, are also part of each comparative
evaluation.
8.1.5 Per Section 6.5, the potential future
resident scenario was not considered in the
evaluation of the protection of human health
because this scenario is highly unlikely.
8.2 Analysis of Remedial
Alternatives for OU 1
Groundwater
8.2.1 Remedial Alternatives
8.2.1.1 This ROD modifies the selected
remedy for Operable Unit (OU) 1 groundwater
(WCC, 1993) to address dieldrin. The selection
of the remedy for OU 1 groundwater is
discussed in Section 7.3. As noted in Section 7.3
and Table 7-1, no additional contaminants of
concern other than dieldrin were identified for
OU 1 groundwater. The remedy selected in the
OU 1 ROD addressed TCE, PCE, and 1,1-DCE.
The remedy included groundwater extraction,
treatment, and injection. The location and
number of extraction wells has been optimized
in the design process and new wells are included
in the alternatives to address dieldrin. Treatment
by air stripping remains appropriate for VOCs
(no non-aqueous phase contamination has been
encountered and no VOC concentrations have
been encountered that exceed the design
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
capabilities of the air stripping systems), but is
not adequate to address pesticides in
groundwater. Therefore, the selected remedy
was reevaluated and modified in the OU 1 ESD
(Montgomery Watson, 1996g) to include well-
head treatment to remove pesticides. No metals
or other contaminants have been identified in
the RI/FS (see Table 7-1) or operation of the
interim groundwater treatment system that
require treatment to meet discharge
requirements. Injection remains the preferred
method of discharge, although infiltration
galleries have proven more effective than
injection wells. The capture of the VOC plume
was also reevaluated in the OU 1 ESD
(Montgomery Watson, 1996g) and the selected
remedy was modified to include dispersion of
TCE and PCE east of Banta Road. Four
modifications of the selected remedial
alternative were developed for dieldrin in OU 1
groundwater. They are:
Alternative 1 - No Further Action
Alternative 2 - Institutional Controls
Alternative 3 - Groundwater Extraction
and Treatment Option 1
Alternative 4 - Groundwater Extraction
and Treatment Option 2
8.2.1.2 Alternative 1 provides a baseline for
comparison with other alternatives. It includes
existing extraction, treatment, and injection to
address VOCs in groundwater; five-year site
reviews; and long-term groundwater monitoring.
Alternative 2 includes the components of
Alternative 1 as well as land use restrictions in
the areas where elevated levels of dieldrin in
groundwater have been detected.
8.2.1.3 Future water rights restrictions would
be written into the land property deed as
necessary if ownership of the depot were
transferred to private or non-DoD entities.
Alternative 3 consists of groundwater extraction
and treatment with liquid-phase granular
activated carbon (GAC) in all three areas of
dieldrin-contarninated groundwater (near solid
waste management units [SWMUs] 2, 3, and 8).
Alternative 4 consists of groundwater extraction
and treatment with GAC in the vicinity of
SWMUs 2 and 3. The contaminated ground-
water near SWMU 8 would not be treated under
this alternative.
8.2.2 Overall Protection of Human
Health and the Environment
The off-depot groundwater risk to residents is
estimated at IxlO"5 and the hazard index is
estimated at 0.9. These risks are associated with
exposure to VOCs. Future risks to depot
workers were estimated at 2xlO"2 in the unlikely
event that a drinking water well is installed in
the contaminant plume. Alternative 1 (No
Further Action) does not address the human
health risks associated with dieldrin for the
future depot worker. Institutional Controls
provided in Alternative 2, reduce the potential
for direct contact with contaminated
groundwater for both current and future land use
conditions. Alternative 3 (Groundwater
Extraction and Treatment Option 1) provides
greater overall protection of human health and
the environment than Alternative 2 because
groundwater is extracted and treated in all three
areas of dieldrin contamination. Alternative 4
(Groundwater Extraction and Treatment Option
2) provides more overall protection than
Alternative 2 but less than Alternative 3 because
groundwater near SWMU 8 would not be
treated.
8.2.3 Compliance with ARARs
There is a California Action Level of 0.05
micrograms per liter (pg/L) for dieldrin in
groundwater, which is a chemical-specific TBC
(to be considered). This TBC would be met by
Alternative 3 (Groundwater Extraction and
Treatment Option 1) only. The ARARs
concerning groundwater protection (27 CCR
Division 2, Subdivision 1 et seq., SWRCB
Resolution No. 68-16, and SWRCB Resolution
No. 92-49) apply to all alternatives but are only
be met by Alternative 3 (Groundwater Extrac-
tion and Treatment Option 1). The action-
specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 et seq., and 40 CFR 262, 263,
and 264) only apply to Alternatives 3 and 4
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
(Groundwater Extraction and Treatment Option
2). All hazardous wastes generated are managed
in compliance with these ARARs.
8.2.4 Long-Term Effectiveness
Alternatives 1 (No Further Action) and 2
(Institutional Controls) are not protective of
human health and the environment, as dieldrin
contamination in groundwater remains.
Alternative 3 (Groundwater Extraction and
Treatment Option 1) provides long-term
effectiveness and permanence by using ground-
water extraction and treatment to reduce dieldrin
concentrations to below the California Action
Level of 0.05 ug/L. However, treatment would
take approximately 50 years to achieve this
level. Alternative 4 (Groundwater Extraction
and Treatment Option 2) is similar to
Alternative 3 for the areas near SWMUs 2 and
3; however, the groundwater near SWMU 8
would not be treated so the action level may not
be met in that area.
8.2.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Further Action) and 2
(Institutional Controls) do not actively reduce
the toxicity, mobility, or volume of dieldrin in
groundwater at OU 1. Alternatives 3 (Ground-
water Extraction and Treatment Option 1) and 4
(Groundwater Extraction and Treatment Option
2) remove dieldrin from the groundwater and
treat it, thereby reducing the toxicity, mobility,
and volume of this constituent. Alternative 4
results in less reduction than Alternative 3, as
the contaminated groundwater near SWMU 8
will not be treated in Alternative 4.
8.2.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Further Action) and 2 (Institutional Controls)
does not pose any new risks to the community or
any new environmental impacts. Under
Alternatives 3 (Groundwater Extraction and
Treatment Option 1) and 4 (Groundwater
Extraction and Treatment Option 2), remedial
workers could be exposed to contaminated soils
during drilling to install extraction wells and/or
during the operation of the groundwater treat-
ment systems. However, dust control and
protective measures could be taken to minimize
these risks. Remedial activities would continue
for approximately 50 years.
8.2.7 Implementability
There is no action associated with Alternative 1
(No Further Action). The land use restrictions in
Alternative 2 (Institutional Controls) are easily
implementable. Alternatives 3 (Groundwater
Extraction and Treatment Option 1) and 4
(Groundwater Extraction and Treatment Option
2) are also readily implementable. Conventional
drilling equipment can be used to install
extraction wells because the wells would be less
than 50 feet deep. Few difficulties are expected
during construction and operation of the
groundwater extraction and treatment systems.
GAC treatment of groundwater that contains
pesticides/VOCs containing groundwater is well
understood and has been implemented at other
sites.
8.2.8 Cost
The estimated present worth for Alternative 1
(No Further Action, $9,561,000), Alternative 2
(Institutional Controls, $9,611,000), and
Alternative 3 (Groundwater Extraction and
Treatment Option 1, $12,040,000) increases
successively due to the subsequent addition of
component technologies. The present worth of
Alternative 4 (Groundwater Extraction and
Treatment Option 2, $10,909,000) is lower than
for Alternative 3 because less dieldrin-
contaminated groundwater is remediated in
Alternative 4.
8.2.9 State and Community Acceptance
The state is not expected to accept Alternatives
1 (No Further Action), 2 (Institutional Controls)
or 4 (Groundwater Extraction and Treatment
Option 2) because of the potential health threats
associated with dieldrin to potential future
residents of the annex. Alternative 3 (Ground-
water Extraction and Treatment Option 1) is
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
protective of human health and the environment
because pesticides are removed from the
groundwater and the treated groundwater is
returned to the aquifer for future use. Therefore,
state and community acceptance of Alternative 3
is anticipated. One written public comment
addressing the capacity of the reinjection wells
and the cost of the groundwater treatment was
received (see Responsiveness Summary).
8.3 Analysis of Remedial
Alternatives for the Group A
Sites
8.3.1 Remedial Alternatives
8.3.1.1 The Group A sites (SWMU I/Area 2,
Area 1 Building 237, and Area 3) are charac-
terized by tetrachloroethene (PCE) and
trichloroethene (TCE) contamination in soil.
The remedial alternatives developed for the
Group A sites are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Soil Vapor Extraction
Alternative 4 - Excavation and Disposal
8.3.1.2 Alternative 1 includes five-year site
reviews and long-term monitoring. Alternative 2
includes the components of Alternative 1, plus
land use restrictions around areas where
elevated concentrations of volatile organic
compounds (VOCs) have been detected at the
Group A sites. Restrictive land use covenants
can be written into the property deed if
ownership of the installation were transferred to
private or nonfederal agencies in the future.
Alternative 3 treats VOC-contaminated soil in
situ by installing a soil vapor extraction (SVE)
system in the area of highest contamination at
each Group A site. Alternative 4 involves
excavating approximately 63,800 cubic yards of
VOC contaminated soil at the Group A sites and
disposing of the soil off site.
8.3.2 Overall Protection of Human
Health and the Environment
If polycyclic aromatic hydrocarbons are
substantially more carcinogenic via dermal than
via oral exposure, the cancer risk for the current
depot worker is estimated at IxlO"5, the cancer
risk for the future construction worker is
estimated at 1x10 , and the hazard index is
0.07. However, as noted in Tables 6-4 and 6-5,
the actual risk is likely to be one category lower
due to bias in the risk estimate (see
Paragraph 6.5.10 for discussion). Therefore, all
alternatives are considered protective of human
health. Alternative 2 reduces the potential for
direct contact with contaminated soils and is
therefore protective of the current depot worker.
Neither Alternative 1 (No Action) nor
Alternative 2 (Institutional Controls) addresses
the migration of VOCs to groundwater.
Alternatives 3 (SVE) and 4 (Excavation) remove
the VOC contamination and eliminate the
potential threat to groundwater and are therefore
protective of human health and the environment.
8.3.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for PCE and TCE in soil at the Group
A sites. Since Alternatives 1 (No Action) and 2
(Institutional Controls) do not involve any
treatment or removal actions, they do not
comply with these chemical-specific TBCs.
Alternatives 3 (SVE) and 4 (Excavation) meet
these TBCs through treatment (Alternative 3) or
by excavating and disposing of the contaminated
soils off site (Alternative 4). The action-specific
ARARs for hazardous waste management (22
CCR, Division 4, Chapter 30, Section 66001 et
seq., and 40 CFR 262, 263, and 264) that apply
to Alternatives 3 and 4 are met, as are the air
emission controls (best available technology)
that apply to Alternative 3.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.3.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of VOCs
in soil to groundwater because VOC-
contaminated soils remain on site. Alternative 3
(SVE) and Alternative 4 (Excavation) provide
long-term effectiveness and permanence by
reducing VOC concentrations in soil or
removing VOC-contaminated soils from the site,
respectively.
8.3.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of TCE
or PCE in soils at the Group A sites through
treatment. The toxicity, mobility, and volume of
these contaminants in soil is reduced through
treatment in Alternative 3 (SVE).
8.3.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Remedial workers could
be exposed to contaminated soils during drilling
(Alternative 3 - SVE) or excavation and disposal
(Alternative 4). However, dust control and
protective measures could be taken to minimize
these risks. The heavy truck traffic associated
with transporting excavated soils off site in
Alternative 4 (Excavation) may impact the
surrounding community. Following construction
of the SVE system in Alternative 3, remedial
workers could be exposed to extracted vapors
during operation and maintenance. Remediation
under Alternative 3 is estimated to take
approximately six months. Alternative 4 would
take approximately three months to implement.
8.3.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are easily
implementable. Alternative 3 (SVE) is also
readily implementable. Conventional drilling
equipment can be used to install SVE wells, as
the wells are relatively shallow (i.e., less than 20
feet deep). SVE is a commercially available
technology, and SVE systems are generally easy
to install and maintain. For Alternative 4
(Excavation), conventional equipment can be
used to excavate the soil. However, due to the
depths of soil contamination, shoring is required
during excavation.
8.3.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000 for each Group A site.
Alternative 2 (Institutional Controls) is expected
to cost $65,000 per site. These costs assume that
five-year site reviews will be discontinued after
ten years because soil contamination is expected
to be reduced below levels of concern within
that time frame. The costs to implement SVE at
the Group A sites in Alternative 3 are estimated
at $266,000 for SWMU I/Area 2, $140,000 for
Area 1 Building 237, and $242,000 for Area 3.
The costs of Alternative 4 (Excavation) include
excavation and off-site disposal at a Class I
facility. These costs are estimated at
$19,785,000 for SWMU I/Area 2, $5,607,000
for Area 1 Building 237, and $16,662,000 for
Area 3.
8.3.9 State and Community Acceptance
The state is not expected to accept Alternative 1
(No Action) or Alternative 2 (Institutional
Controls) because they are not protective of the
environment. Alternatives 3 (SVE) and 4
(Excavation) are protective of human health and
the environment because contaminants are
permanently removed from the soils at the
Group A sites. Therefore, state and community
acceptance is anticipated. One written public
comment expressing concern over the potential
exposure and high cost of excavation was
received (see Responsiveness Summary).
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.4 Analysis of Remedial
Alternatives for SWMU A—
Storm Drain Lagoon
8.4.1 Remedial Alternatives
8.4.1.1 SWMU 4 is a storm drain lagoon.
Lagoon sediments have shown elevated concen-
trations of pesticides and metals that pose a
possible threat to ecological receptors. In
addition, surface water concentrations of
dieldrin and DDT exceed federal ambient water
quality criteria (AWQC) for protection of
aquatic wildlife. The remedial alternatives
developed for SWMU 4 are:
Alternative 1 - No Action
Alternative 2 - Upstream Source
Control
Alternative 3 - Excavation and Disposal of
Sediments, Evaluate
Discharge Concentrations
8.4.1.2 Five-year reviews and long-term
sediment, surface water, and groundwater
monitoring are included in Alternative 1.
Alternative 2 consists of periodically (every five
years) removing sediment from storm water
conduits upstream of the lagoon, and dewatering
and transporting those sediments to an off-site
disposal facility. Alternative 3 consists of
excavation of the sediment in the storm drain
lagoon that is contaminated with metals and
pesticides. The excavated sediments would be
dewatered and transported to an off-site disposal
facility.
8.4.2 Overall Protection of Human
Health and the Environment
The cancer risk estimated for the current depot
worker is IxlO"6; however, as noted in
Table 6-4, the actual risk is likely to be one
category lower due to bias in the risk estimate.
The hazard index was estimated at 0.01.
Therefore, all alternatives are considered
protective of human health. The threat to
ecological receptors is not addressed by
Alternative 1 (No Action). By removing
contaminated sediments upstream, Alternative 2
(Source Control) reduces the potential future
threats to ecological receptors. Alternative 3
(Excavation) would remove the soil with
contaminants. It is uncertain if the
concentrations of dieldrin and DDT in the storm
water discharged to the canal exceed the
AWQC. Alternative 3 requires monitoring of the
storm water discharge to determine if the
AWQC are complied with.
8.4.3 Compliance with ARARs
Federal ambient water quality criteria for the
protection of aquatic wildlife are considered
chemical-specific ARARs for surface water
discharged to the local irrigation canal. The
action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 et seq., and 40 CFR 262, 263,
and 264) that apply to Alternatives 2 and 3 are
met. For all alternatives, the California Fish and
Game Code is a location-specific ARAR.
8.4.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Source
Control) do not prevent the exposure of
ecological receptors to constituents in the
sediment. Alternative 3 relies on excavation to
address the threat to ecological receptors. With
proper storm water pollution prevention
measures, the long-term effectiveness is
considered high. The long-term effectiveness
will be assessed in the 5-year review to ensure
there is no continuing source. Sediment
excavation could have a much larger negative
impact on the lagoon ecosystem and aquatic
biota than the ecological risks posed by the
contaminants detected in the sediment.
8.4.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action) and 2 (Source
Control) do not actively reduce the toxicity,
mobility, and volume of SVOCs and pesticides
in lagoon sediments through treatment.
However, Alternative 2 reduces further
deposition of contaminated sediments into the
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
lagoon. Alternative 3 (Excavation) removes
contaminated sediment from the storm drain
lagoon, but does not provide treatment.
8.4.6 Short-Term Effectiveness
The implementation of Alternative 1 (No
Action) does not pose any new risks to the
community or any new environmental impacts.
Under Alternatives 2 (Source Control) and 3
(Excavation), remedial workers could be
exposed to contaminated sediments during
excavation. However, protective measures could
be taken to minimize these risks. Sediment
excavation activities in Alternative 3 could
potentially impact the sensitive nesting and
breeding habitats of various waterfowl by
disturbing the shoreline and shallow water.
8.4.7 Implementability
There is no action associated with Alternative 1
(No Action). With Alternative 2 (Source
Control), conventional soil excavation equip-
ment can be used to remove contaminated
sediment from the open storm drain ditches.
Alternative 3 (Limited Excavation) may be
difficult to implement given the previous
problems with draining the lagoon (due to
clogging) and a high water table.
8.4.8 Cost
The present worth of Alternative 1 (No Action)
is $25,000. This cost assumes that five-year site
reviews will be conducted for a 30-year period.
The present worth cost for Alternative 2 (Source
Control), which includes sediment excavation,
dewatering, and off-site disposal, is $1,158,000.
The present worth for Alternative 3
(Excavation), which includes excavation of
lagoon sediment with dewatering and off-site
disposal, is $552,600.
8.4.9 State and Community Acceptance
The state is not expected to accept
Alternatives 1 (No Action) or 2 (Source
Control) because they are not protective of
ecological receptors. Alternative 3 (Limited
Excavation) is protective of both human health
and the environment because most of the
contaminants in the sediment will be
permanently removed from the lagoon. The
remainder of the contaminants will be covered
with clean fill to isolate them from ecological
receptors. Therefore, state and community
acceptance of Alternative 3 is anticipated. One
written public comment expressing concern over
the potential exposure and high cost of
excavation was received (see Responsiveness
Summary).
8.5 Analysis of Remedial
Alternatives for SWMU 6—
Building 28 Sump
8.5.1 Remedial Alternatives
8.5.1.1 SWMU 6 is the former location of a
250-gallon concrete sump that was removed in
1988. Pesticide and herbicide contamination in
soil has been detected immediately adjacent to
the sump excavation at depths from below the
sump excavation to directly above the water
table. The pesticides dicamba, dieldrin,
heptachlor, 2,4,5-T, and lindane detected at the
site could potentially pose a threat to
background groundwater quality. The remedial
alternatives developed for SWMU 6 are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - In Situ Stabilization
Alternative 4 - Excavation and Disposal
8.5.1.2 Alternative 1 includes five-year site
reviews and long-term monitoring. Alternative 2
includes the components of Alternative 1 plus
land use restrictions around areas where
elevated levels of contaminants have been
detected at the site. Alternative 3 consists of
using in situ stabilization to physically and
chemically immobilize the pesticides detected in
the soil. Alternative 4 consists of excavating
approximately 60 cubic yards of pesticide-
contaminated soil and disposing of it off site at
either a Class I or a Class n disposal facility,
depending on the level of contamination.
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8.5.2 Overall Protection of Human
Health and the Environment
The cancer risk to future construction workers at
SWMU 6 was estimated at 8.8x10'8 and the
hazard index was 2.7xlO~2. All alternatives are
protective of human health. In Alternatives 1
(No Action) and 2 (Institutional Controls),
pesticides in the soil could potentially pose a
threat to groundwater. With Alternative 3
(Stabilization), pesticides are immobilized in
situ, significantly reducing their threat to
groundwater. In Alternative 4 (Excavation), the
threat to groundwater is eliminated because
pesticide-contaminated soils are permanently
removed from the site.
8.5.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the pesticides detected in the soil
at SWMU 6. Alternatives 1 (No Action) and 2
(Institutional Controls) do not comply with
these chemical-specific TBCs, as pesticide-
contaminated soil remains at the site.
Alternatives 3 (Stabilization) and 4 (Excavation)
meet these TBCs by either immobilizing or
permanently removing the contaminated soil.
The action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 et seq., and 40 CFR 262, 263,
and 264) that apply to Alternatives 3 and 4 are
also will met.
8.5.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of
constituents in soil to groundwater because the
pesticides remain on site. Alternative 3
(Stabilization) significantly reduces the threat to
groundwater because the pesticides are
immobilized through the stabilization process.
Alternative 4 (Excavation) provides long-term
effectiveness and permanence through
excavation and off-site disposal of pesticide-
contaminated soils.
8.5.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of
contaminants at the site through treatment.
Alternative 3 (Stabilization) reduces the
mobility of contaminants in the soil through
stabilization, but does not reduce their toxicity
or volume.
8.5.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(Stabilization) and 4 (Excavation), remedial
workers could be exposed to contaminated soil
during stabilization and excavation. Also, under
Alternative 3 remedial workers could be
exposed to the chemicals used for stabilization.
Dust control and protective measures could be
taken to minimize these risks. Alternative 4
(Excavation) can be completed in approximately
three months.
8.5.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. The in situ stabilization in
Alternative 3 is a technically feasible,
commercially available technology. The
materials required for implementing this
alternative are readily available. In
Alternative 4, conventional earthmoving
equipment can be used to excavate the soil.
Transporting soils for off-site disposal is also
easily implementable.
8.5.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume that five-year site reviews will be
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
discontinued after ten years because contamina-
tion is expected to be reduced below levels of
concern within that time frame. The present
worth cost for the in situ stabilization process in
Alternative 3 is $169,000. In Alternative 4,
excavation with off-site disposal to a Class n
landfill has a present worth cost of $45,000. If
disposal at a Class I facility is required, the cost
would increase to $65,000.
8.5.9 State and Community Acceptance
The state is not expected to accept
Alternatives 1 (No Action) or 2 (Institutional
Controls) because they are not protective of the
groundwater beneath the site. Alternatives 3
(Stabilization) and 4 (Excavation) are protective
of both human health and the environment
because contaminants in soil will be
permanently immobilized or removed from the
site. Therefore, state and community acceptance
of Alternatives 3 and 4 is anticipated. One
written public comment was received that
expressed concern over the potential exposure
and high cost of excavation. It also expressed
interest in the encapsulation (stabilization)
process (see Responsiveness Summary).
8.6 Analysis of Remedial
Alternatives for SWMU 7—Burn
Pit No. 1
8.6.1 Remedial Alternatives
8.6.1.1 SWMU 7 (Burn Pit No. 1) comprises
seven former burn pits that were used between
1942 and 1954 for disposing of medical supplies
containing mercury and phosphate compounds,
narcotics, general pharmaceuticals, radiological
supplies, and electron tubes. Remedial Investi-
gation (RI) results indicate that pesticides in
soils at three of the pits (Pits C, D, and F) may
pose a threat to groundwater quality. The
remedial alternatives developed for SWMU 7
are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - In Situ Stabilization with
Institutional Controls
Alternative 4 - Excavation and Disposal
with Institutional Controls
8.6.1.2 Alternative 1 consists of five-year site
reviews and long-term groundwater monitoring.
Alternative 2 includes these components and
adds land use restrictions around the disposal
pits where elevated levels of contaminants have
been detected. If ownership of the depot is
transferred to private or nonfederal entities,
restrictive covenants could be written into the
property deed. Alternative 3 consists of using in
situ stabilization to physically and chemically
immobilize the contaminants detected in the soil
at Pits C, D, and F. Alternative 4 involves
excavating approximately 3,600 cubic yards of
contaminated soils from these three pits and
disposing of them off site at a Class I disposal
facility. Both Alternatives 3 (Stabilization) and
4 (Excavation) also include institutional controls
because portions of the pits are covered by
buildings.
8.6.2 Overall Protection of Human
Health and the Environment
The cancer risk to future construction workers at
SWMU 7 was estimated at 4.2x10"7 and the
hazard index was estimated at 9.2. However, the
hazard index was elevated because of
manganese concentrations that are typical of
those throughout the western United States. All
alternatives are protective of human health
under the scenarios considered. However,
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not mitigate the threat to ground-
water posed by contaminants in the soil.
Alternative 3 (Stabilization) immobilizes
pesticides in situ, significantly reducing the
potential threat to groundwater. Alternative 4
(Excavation) provides the greatest protection to
human health and the environment because
contaminated soils are permanently removed
from the site.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.6.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in the
soil at SWMU 7. The potential threats to
background water quality have not yet been
confirmed through monitoring. Alternative 1
(No Action) does not comply with the chemical-
specific TBCs. If long-term monitoring in
Alternative 2 (Institutional Controls) identifies a
concern, the implementation of Alternative 2
would be modified to ensure the protection of
the groundwater. Therefore, Alternative 2 is
considered to comply with these chemical-
specific TBCs. Alternatives 3 (Stabilization) and
4 (Excavation) also meet these TBCs by either
immobilizing or permanently removing the
contaminated soil. The action-specific ARARs
for hazardous waste management (22 CCR,
Division 4, Chapter 30, Section 66001 et seq.,
and 40 CFR 262, 263, and 264) that apply to
Alternatives 3 and 4 are also met.
8.6.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the potential migration
of soil constituents to groundwater because the
pesticides remain on site. Alternative 2 does
include long-term monitoring to evaluate the
long term effectiveness. Alternative 3 (Stabiliza-
tion) significantly reduces the threat to ground-
water because the pesticides are immobilized
through the stabilization process. Alternative 4
(Excavation) provides long-term effectiveness
and permanence through excavation and off-site
disposal of pesticide-contaminated soils.
8.6.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of
contaminants at the site through treatment.
Alternative 3 (Stabilization) reduces the
mobility of pesticides and other contaminants in
the soil through stabilization, but does not
reduce their toxicity or volume.
8.6.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(Stabilization) and 4 (Excavation), remedial
workers could be exposed to contaminated soil
during stabilization and excavation. Under
Alternative 3, remedial workers could be
exposed to stabilization chemicals. However,
dust control and protective measures could be
taken to minimize these risks. Alternative 4 can
be completed in approximately three months.
8.6.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. The in situ stabilization in
Alternative 3 (Stabilization) is a technically
feasible, commercially available technology.
The materials required for implementing this
alternative are readily available. In Alternative 4
(Excavation), conventional earthmoving
equipment can be used to excavate the soil.
Transporting soils for off-site disposal is also
easily implementable.
8.6.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $208,000. These costs
assume two five-year site reviews. The present
worth cost for the in situ stabilization process
and institutional controls in Alternative 3
(Stabilization) is $822,000. The present worth
cost for Alternative 4 (Excavation), which
combines excavation with off-site disposal and
institutional controls, is $2,605,000.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.6.9 State and Community Acceptance
The state is not expected to accept Alternative 1
(No Action) because it may not be protective of
future land use conditions or groundwater
beneath the site. The land use restrictions in
Alternative 2 (Institutional Controls) and the
long-term groundwater monitoring ensure
protection of groundwater. (There is a potential
threat to groundwater quality that has not been
confirmed through historical monitoring.)
Therefore Alternative 2 is expected to be
acceptable to both the state and the public.
Alternatives 3 (Stabilization) and 4 (Excavation)
are protective of both human health and the
environment because contaminants in the soil
are permanently immobilized or removed from
the site. Therefore, state and community
acceptance is anticipated for Alternatives 3 and
4 as well. One written public comment was
received that expressed concern over the
potential exposure and high cost of excavation.
It also expressed interest in the encapsulation
(stabilization) process (see Responsiveness
Summary).
8.7 Analysis of Remedial
Alternatives for SWMU 8—Burn
Pit No. 2
8.7.1 Remedial Alternatives
8.7.1.1 SWMU 8 is a single large burn pit.
Polynuclear aromatic hydrocarbons (PAHs),
phthalates, pesticides, dioxins/furans, metals,
and petroleum hydrocarbons were detected in
soils in the pit. The site contaminants potentially
pose a threat to groundwater. The remedial
alternatives developed for SWMU 8 are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Bioventing
Alternative 4 - Excavation and Disposal
8.7.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the disposal pits. If ownership of the
depot is transferred to private or nonfederal
agencies in the future, restrictive covenants
could be written into the property deed.
Alternative 3 consists of injecting air into the
subsurface to enhance natural aerobic
degradation processes in the vadose zone. Three
air injection well clusters are needed, and a pad-
mounted blower would be installed adjacent to
the injection wells. Alternative 4 involves
excavating contaminated soil (approximately
2,600 cubic yards) and debris (approximately
1,900 cubic yards) and transporting them off site
to Class I and Class in disposal facilities,
respectively.
8.7.2 Overall Protection of Human
Health and the Environment
All alternatives are protective of human health
under the current depot worker exposure
scenario. Alternative 1 (No Action) is not
protective of the future construction worker.
The estimated cancer risk associated with
organochlorine pesticides is between IxlO"4 and
IxlO"6, and the hazard index is greater than 1 for
this scenario. The land use restrictions in
Alternative 2 (Institutional Controls) provide
some protection for the future construction
worker. However, neither Alternative 1 nor
Alternative 2 mitigate the threat to groundwater
posed by contaminants in the soil. Alternative 3
(Bioventing) involves the biodegrading
petroleum hydrocarbons and some SVOCs in
situ; however, pesticides, PCBs, and
dioxin/furans are not readily biodegraded and
the potential threat to groundwater from
pesticides, PCBs, and dioxin/furans would
remain. Alternative 4 (Excavation) provides the
greatest protection to human health and the
environment because contaminated soils are
permanently removed from the site.
8.7.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in the
soil at SWMU 8. Alternatives 1 (No Action) and
2 (Institutional Controls) do not comply with
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
these chemical-specific TBCs, as the
constituents of concern would remain in the soil
at the site. Alternative 3 (Bioventing) also may
not comply with this TBC for all contaminants
of concern because pesticides in the soil would
not be treated through bioventing. Alternative 4
(Excavation) meets these TBCs by permanently
removing the contaminated soil from the site.
The action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 et seq., and 40 CFR 262, 263,
and 264) that apply to Alternatives 3
(Bioventing) and 4 (Excavation) are met.
8.7.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of
constituents in the soil to groundwater because
contaminants remain on site. Alternative 3
(Bioventing) eliminates the threat to
groundwater from petroleum hydrocarbons and
SVOCs, but it does not reduce the potential
threat to groundwater from pesticides because
these constituents are not amenable to
biodegradation. Alternative 4 (Excavation)
provides long-term effectiveness and
permanence through the excavation and off-site
disposal of pesticide-contaminated soils.
8.7.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of
contaminants at the site through treatment.
Alternative 3 (Bioventing) reduces the toxicity,
mobility, and volume of petroleum hydrocar-
bons and SVOCs at SWMU 8, but does not
reduce the toxicity, mobility, or volume of
pesticides, PCBs, or dioxin/furans at the site.
8.7.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(Bioventing) and 4 (Excavation), remedial
workers could be exposed to contaminated soil
during drilling and excavation. However,
various dust control and protective measures
could be taken to minimize these risks.
Following the installation of the bioventing
system, it will take approximately two years to
biodegrade petroleum hydrocarbons in the soil.
Alternative 4 (Excavation) can be completed in
. approximately three months or less.
8.7.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3 (Bioventing),
conventional drilling equipment can be used to
install bioventing wells because they will are
relatively shallow; however, installing the wells
may be difficult because of the construction
debris buried in the former bum pit. The system
might also short-circuit because of the debris. In
Alternative 4 (Excavation), conventional
earthmoving equipment can be used to excavate
the soil. Transporting soils for off-site disposal
is also easily implementable.
8.7.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume two five-year site reviews. The present
worth cost of the bioventing system in
Alternative 3 is $246,000. The cost for
Alternative 4, which includes excavation and
off-site disposal, is $2,823,000.
8.7.9 State and Community Acceptance
The state is not expected to accept Alternative 1
(No Action) because it is not protective of
human health for the future construction worker
or protective of groundwater beneath the site.
State acceptance is also not expected with
Alternatives 2 (Institutional Controls) and 3
(Bioventing) because of the potential future
threat to groundwater. Alternative 4
(Excavation) is protective of both human health
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
and the environment because contaminants in
the soil are permanently removed from the site.
Therefore, state and community acceptance is
anticipated for this alternative. One written
public comment was received that expressed
concern over the potential exposure and high
cost of excavation (see Responsiveness
Summary).
8.8 Analysis of Remedial
Alternatives for SWMU 20—
Aboveqround Solvent
Tank/Building 26 Recoup
Operations and Area 1
Building 10
8.8.1 Remedial Alternatives
8.8.1.1 SWMU 20 consists of two sumps
associated with an aboveground solvent tank
located at Building 10 and contaminated soils at
Area 1 Building 10. Modeling results indicate
that TCE, SVOCs, pesticides, and herbicides
detected in the soil at these sites pose a potential
threat to beneficial uses of groundwater. The
remedial alternatives developed for SWMU 20
are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - SVE with Excavation and
Disposal and Natural
Attenuation
Alternative 4 - Excavation and Disposal
and Natural Attenuation
8.8.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the areas of contamination. If ownership
of the depot is transferred to private or
nonfederal agencies in the future, restrictive
covenants could be written into the property
deed. Alternative 3 involves excavating the
SWMU 20 sumps and the floor drain at
Building 26. The excavated material would be
transported and disposed of off site. SVE would
be performed in Area 1 Building 10 to reduce
the TCE concentrations to below the cleanup
level. Soil contaminated with 2,4-dinitrophenol
and 2,4,6-trichlorophenol at 15 feet bgs would
be allowed to attenuate naturally. Alternative 4
is the same as Alternative 3, except that the
TCE-contaminated soils are excavated and
transported off site rather than treated by SVE.
8.8.2 Overall Protection of Human
Health and the Environment
The risk to depot workers at SWMU 20 was
estimated at 2.2xlO"7 and the hazard index at
0.3. All alternatives are protective of human
health. However, Alternatives 1 (No Action)
and 2 (Institutional Controls) do not mitigate the
threat to groundwater posed by VOCs and
phthalates in the soils. Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4
(Excavation/Natural Attenuation) permanently
remove contaminated soils and sludges
associated with the sumps and the floor drain,
thereby eliminating the potential threat to
groundwater at those locations. TCE at Area 1
Building 10 is removed through SVE in
Alternative 3 and excavation and off-site
disposal in Alternative 4. The removal TCE
eliminates the threat to groundwater at that
location.
8.8.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in the
soil at SWMU 20 and Area 1 Building 10.
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not comply with these chemical-
specific TBCs, as the constituents of concern
remain in the soil at the site. Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4
(Excavation/Natural Attenuation) meet these
TBCs by permanently removing the contami-
nants from the site. The action-specific ARARs
for hazardous waste management (22 CCR,
Division 4, Chapter 30, Section 66001 et seq.,
and 40 CFR 262, 263, and 264) that apply to
Alternatives 3 and 4 are met.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.8.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of
constituents in the soil to groundwater because
the contaminants remain on site. Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4
(Excavation/Natural Attenuation) provide long-
term effectiveness and permanence because
contaminated soils are excavated and disposed
of off site or treated via SVE.
8.8.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls) and 4 (Excavation/Natural
Attenuation) do not actively reduce the toxicity,
mobility, or volume of contaminants at the site
through treatment. Alternative 3 (SVE/
Excavation/Natural Attenuation) reduces the
toxicity, mobility, and volume of TCE at Area 1
Building 10 through SVE.
8.8.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4
(Excavation/Natural Attenuation), remedial
workers could be exposed to contaminated soil
during drilling and excavation activities.
However, dust control and protective measures
could be taken to minimize these risks.
Alternatives 3 and 4 could each be completed in
less than three months.
8.8.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3 (SVE/
Excavation/Natural Attenuation), conventional
equipment can be used to install and maintain
the SVE system. Conventional earthmoving
equipment can be used to excavate and transport
soils in Alternatives 3 and 4 (Excavation/
Natural Attenuation).
8.8.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume two five-year site reviews. The present
worth cost for the SVE system and the excava-
tion and off-site disposal in Alternative 3
(SVE/Excavation/Natural Attenuation) is
$293,000. The present worth cost for excavation
and off-site disposal in Alternative 4
(Excavation/Natural Attenuation) is $355,000.
8.8.9 State and Community Acceptance
The state is not expected to accept Alternatives
1 (No Action) or 2 (Institutional Controls)
because they are not protective of groundwater
beneath the site. Alternatives 3 (SVE/
Excavation/Natural Attenuation) and 4
(Excavation/Natural Attenuation) are protective
of both human health and the environment
because contaminants in the soil are
permanently removed from the site either by
treatment or by excavation. Therefore, state and
community acceptance is anticipated for these
alternatives. One written public comment was
received that expressed concern over the
potential exposure and high cost of excavation
(see Responsiveness Summary).
8.9 Analysis of Remedial
Alternatives for SWMU 24—
Petroleum Waste Oil Tank
8.9.1 Remedial Alternatives
8.9.1.1 SWMU 24 was a 500-gallon
underground storage tank (UST) that was used
to store petroleum wastes derived from
materials testing in Building 247. During UST
removal, visibly contaminated soil from the
excavation was disposed of off site. The
remaining soil contamination is limited to soils
within and immediately surrounding the tank
excavation. The VOCs, SVOCs, petroleum
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
hydrocarbons, PCBs, and pesticides remaining
in the soil at the site may pose a threat to
background groundwater quality. The remedial
alternatives developed for SWMU 24 are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Bioventing
Alternative 4 - Excavation and Disposal
Alternative 5 - Excavation and On-Site
Bioremediation
8.9.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the area of contamination. If ownership
of the depot is transferred to private or
nonfederal agencies in the future, restrictive
covenants could be written into the property
deed. Alternative 3 consists of injecting air into
the subsurface to enhance natural aerobic
degradation processes in the vadose zone. Due
to the limited aerial extent of the VOC
contamination, only one air injection well is
needed. Alternative 4 involves excavating
approximately 240 cubic yards of contaminated
soil and transporting it off site to a Class I
disposal facility. Alternative 5 involves
excavating the contaminated soil and treating it
aboveground using on-site bioremediation. This
treatment involves spreading and tilling soil on a
treatment pad to enhance the natural
biodegradation of hydrocarbon compounds.
8.9.2 Overall Protection of Human
Health and the Environment
The cancer risk estimated for the future con-
struction worker at this site is IxlO"6, and the
hazard index was estimated to be 10. The risk is
associated with exposure to PAHs and
manganese (see Section 6.5). Remediation of
these compounds was not deemed necessary.
The risk associated with exposure to VOCs in
indoor air was estimated at 0.7. Alternatives 1
(No Action) and 2 (Institutional Controls) do
not mitigate the threat to groundwater posed by
the contaminants in the soil. Alternatives 3
(Bioventing) and 5 (Excavation/Bioremediation)
involve biodegrading VOCs, SVOCs, and
petroleum hydrocarbons in situ but pesticides
and PCBs do not biodegrade. However, the
potential threat to groundwater from these
pesticides and PCBs is considered low relative
to the threat posed by other contaminants of
concern. Alternative 4 (Excavation/Disposal)
provides the greatest protection to human health
and the environment because contaminated soils
are permanently removed from the site.
8.9.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in the
soil at SWMU 24. Alternatives 1 (No Action)
and 2 (Institutional Controls) do not comply
with these chemical-specific TBCs, as the
constituents of concern remain in the soil at the
site. Alternatives 3 (Bioventing), 4 (Excavation/
Disposal), and 5 (Excavation/Bioremediation)
meet these TBCs by treating the contaminated
soil through bioventing (Alternative 3),
bioremediation (Alternative 5), or excavation
and off-site disposal (Alternative 4). Although
bioventing and bioremediation do not address
the PCB or pesticide soil contamination at
SWMU 24, the groundwater threat posed by
these compounds is considered low. Pesticide
detections were infrequent and none of the
pesticides or PCBs in soil have been detected in
groundwater near the site. PCBs were only
detected in one boring (SB-192) and the
concentrations of both PCBs and pesticides
decreased with increasing depth. Removing
these compounds from underneath existing
buildings was not considered justified at this
time. The action-specific ARARs for hazardous
waste management (22 CCR, Division 4,
Chapter 30, Section 66001 et seq., and 40 CFR
262, 263, and 264) that apply to Alternatives 3
through 5 are also met.
8.9.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of soil
constituents to groundwater because contami-
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nants remain on site. Alternatives 3 (Bioventing)
and 5 (Excavation/Bioremediation) eliminate
the threat to groundwater from VOCs, SVOCs,
and petroleum hydrocarbons; however, they do
not reduce the potential threat to groundwater
from pesticides and PCBs because these
constituents are not amenable to biodegradation.
Alternative 4 (Excavation/Disposal) provides
long-term effectiveness and permanence through
excavation and off-site disposal of contaminated
soils.
8.9.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
Alternatives 1 (No Action), 2 (Institutional
Controls), and 4 (Excavation/Disposal) do not
actively reduce the toxicity, mobility, or volume
of contaminants at the site through treatment.
Alternatives 3 (Bioventing) and 5 (Excavation/
Bioremediation) reduce the toxicity, mobility,
and volume of VOCs, SVOCs, and petroleum
hydrocarbons at SWMU 24, but do not treat the
PCBs and pesticides at the site.
8.9.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(Bioventing), 4 (Excavation/Disposal), and 5
(Excavation/Bioremediation), remedial workers
could be exposed to contaminated soil during
drilling, excavation, and operation of the
aboveground bioremediation cell. However, dust
control and protective measures could be taken
to minimize these risks. Following the construc-
tion of the bioventing system in Alternative 3, it
will take approximately two years to biodegrade
the constituents of concern in the soil.
Alternative 4 (Excavation) can be completed in
approximately three months.
8.9.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3 (Bioventing),
conventional drilling equipment can be used to
install the bioventing well, as it is relatively
shallow. Alternatives 4 (Excavation/Disposal)
and 5 (Excavation/Bioremediation) may be
difficult to implement because they require the
excavation of soil beneath Building 247. In
addition, some shoring is required because soils
need to be excavated to a depth of 17 feet bgs.
The transportation and off-site disposal of soil
in Alternative 4 (Excavation/Disposal) are
readily implementable. The chemicals and
equipment needed for biotreatment in
Alternative 5 are also readily available. The
treatment pad could be easily constructed on
land available in the southern portion of the
base.
8.9.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume two five-year site reviews. The present
worth cost for the bioventing system in
Alternative 3 (Bioremediation) is $166,000. The
present worth cost for Alternative 4
(Excavation/Disposal), which includes
excavation and off-site disposal, is $214,000.
The present worth cost of Alternative 5
(Excavation/Bioremediation), excavation with
on-site bioremediation, is estimated at $263,000.
8.9.9 State and Community Acceptance
The state is not expected to accept Alternatives
1 (No Action) or 2 (Institutional Controls)
because they do not mitigate the threat to the
groundwater beneath the site. Alternatives 3
(Bioremediation), 4 (Excavation/Disposal), and
5 (Excavation/Bioremediation) reduce the threat
to groundwater from VOCs, SVOCs, and
petroleum hydrocarbons and are protective of
human health. Therefore, state and community
acceptance is anticipated for these alternatives.
One written public comment was received that
expressed concern over the potential exposure
and high cost of excavation (see Responsiveness
Summary).
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8.10 Remedial Alternatives for
SWMU 27—Building 206
Roundhouse Sump/Area 1
Building 206
8.10.1 Remedial Alternatives
8.10.1.1 SWMU 27 consists of the waste oil
sump, the service pit, the locomotive pit, and the
area around the floor drain in the demolished
Building 206. Elevated levels of PAHs and
PCBs were detected at shallow depths at this
site. Exposure to these constituents in soil could
cause a cancer risk greater than 10~6 to potential
future depot workers. Also, VOCs, herbicides,
and petroleum hydrocarbons in the soil pose a
potential threat to groundwater quality. The
remedial alternatives developed for SWMU 27
are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal
8.10.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the area of contamination. If ownership
of the depot is transferred to private or
nonfederal agencies in the future, restrictive
covenants could be written into the property
deed. Alternative 3 involves excavating the
waste oil sump that has been filled with sand,
the contaminated soil beneath the railroad
tracks, and the contaminated soil at SB469. The
excavated material, approximately 130 cubic
yards, is transported off site to a Class I disposal
facility.
8.10.2 Overall Protection of Human
Health and the Environment
The cancer risk estimated for the future
construction worker at this site is SxlO"6.
Alternative 1 (No Action) is not protective of
human health for the current depot worker. The
estimated cancer risk is SxlO"4 for this scenario.
By reducing the potential for direct contact of
contaminated soils through land use restrictions,
Alternative 2 (Institutional Controls) is protec-
tive of the current depot worker. Because
contaminants remain on site, neither Alternative
1 nor Alternative 2 mitigates the threat to
groundwater posed by contaminants in the soil.
Alternative 3 (Excavation) permanently removes
contaminated soil from the site, thereby
eliminating the potential threat to future depot
workers and the potential threat to groundwater
quality at this location.
8.10.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific ARARs
that are protective of groundwater were
developed for the constituents of concern in the
soil at SWMU 27. Alternatives 1 (No Action)
and 2 (Institutional Controls) do not comply
with these chemical-specific TBCs, as the
constituents of concern remain in the soil at the
site. Alternative 3 (Excavation) meets these
TBCs by permanently removing the contami-
nated soils from the site. The action-specific
ARARs for hazardous waste management (22
CCR, Division 4, Chapter 30, Section 66001 et
seq., and 40 CFR 262, 263, and 264) that apply
to Alternative 3 (Excavation) are also met.
8.10.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of
constituents in the soil to groundwater because
contaminants remain on site. In addition,
Alternative 1 does not prevent adverse human
exposure under a future construction worker
exposure scenario. Alternative 3 (Excavation)
provides long-term effectiveness and
permanence because contaminated soils are
permanently removed from the site.
8.10.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
None of the alternatives actively reduces the
toxicity, mobility, or volume of contaminants at
the site through treatment.
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8.10.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternative 3
(Excavation), remedial workers could be
exposed to contaminated soil during excavation
activities. However, dust control and protective
measures could be taken to minimize these risks.
Alternative 3 could probably be implemented in
less than three months.
8.10.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3,
conventional earthmoving equipment can be
used to excavate and transport soils to an off-
site disposal facility.
8.10.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume two five-year site reviews. The present
worth cost for the excavation and off-site
disposal described in Alternative 3 (Excavation)
is $112,000.
8.10.9 State and Community Acceptance
The state is not expected to accept Alternatives
1 (No Action) and 2 (Institutional Controls)
because they do not mitigate the potential threat
to groundwater beneath the site, and Alternative
1 is not protective of human health for the
current depot worker. Alternative 3
(Excavation) eliminates the threat to
groundwater and is protective of human health.
Therefore, state and community acceptance is
anticipated for Alternative 3. One written public
comment was received that expressed concern
over the potential exposure and high cost of
excavation (see Responsiveness Summary).
8.11 Analysis of Remedial
Alternatives for Building 30
Drum Storage Area
8.11.1 Remedial Alternatives
8.11.1.1 The Building 30 Drum Storage Area
is located near the Consolidated Subsistence
facility. Buried drums (removed in 1991) were
discovered during construction of the Consoli-
dated Subsistence facility. Phthalate compounds
and benzyl alcohol were detected in the soil at
concentrations that could pose a threat to
background groundwater quality. The remedial
alternatives developed for the Building 30 Drum
Storage Area are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal
8.11.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the area of contamination. If ownership
of the depot is transferred to private or
nonfederal agencies in the future, restrictive
covenants could be written into the property
deed. Alternative 3 involves excavating
approximately 2,800 cubic yards of
contaminated soil at the site. Depending on the
level of contamination, soils will be disposed of
off site at either a Class I or a Class n disposal
facility.
8.11.2 Overall Protection of Human
Health and the Environment
The cancer risk to future construction workers at
the Building 30 Drum Storage Area was
estimated at 9xlO"7 and the hazard index as 0.3.
All alternatives are protective of human health.
However, since contaminants remain on site,
neither Alternative 1 (No Action) nor
Alternative 2 (Institutional Controls) mitigates
the threat to groundwater posed by contaminants
in the soil. Alternative 3 (Excavation)
permanently removes contaminated soil from
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
the site, thereby eliminating the potential threat
to ground water quality at this location.
8.11.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of ground water were
developed for the constituents of concern in the
soil at the Building 30 Drum Storage Area.
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not comply with these chemical-
specific TBCs, as the constituents of concern
remain in the soil at the site. Alternative 3
(Excavation) meets these TBCs by permanently
removing the contaminated soils from the site.
The action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 et seq., and 40 CFR 262, 263,
and 264) that apply to Alternative 3
(Excavation) are also met.
8.11.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the potential migration
of soil constituents to groundwater because
contaminants remain on site. Alternative 2 does
include groundwater monitoring to evaluate the
long-term effectiveness. By removing contami-
nated soils from the site, Alternative 3
(Excavation) eliminates any threat to ground-
water and provides long-term effectiveness and
permanence.
8.11.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
None of the alternatives actively reduces the
toxicity, mobility, or volume of contaminants at
the site through treatment.
8.11.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternative 3
(Excavation), remedial workers could be
exposed to contaminated soil during excavation
activities. However, dust control and protective
measures could be implemented to minimize
these risks. Alternative 3 could probably be
implemented in less than three months.
8.11.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3, conven-
tional earthmoving equipment can be used to
excavate and transport soils to an off-site
disposal facility. However, excavation may be
difficult to implement because soil excavation
could disrupt robotics operations in Building 30.
8.11.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $87,000. These costs
assume two five-year site reviews and
installation of a downgradient monitoring well
in Alternative 2. The present worth cost for
excavation and off-site disposal to a Class n
disposal facility in Alternative 3 is $907,000. If
disposal at a Class I facility is required, the cost
increases to $1,860,000.
8.11.9 State and Community Acceptance
The state is not expected to accept Alternative 1
(No Action) because it does not mitigate the
potential threat to groundwater beneath the site.
State acceptance of Alternative 2 (Institutional
Controls) is anticipated because of the proposed
monitoring program to identify and respond to
any groundwater impacts. Alternative 3
(Excavation) eliminates the threat to ground-
water and is protective of human health;
therefore, state and community acceptance is
anticipated. One written public comment was
received that expressed concern over the
potential exposure and high cost of excavation
(see Responsiveness Summary).
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.12 Analysis of Remedial
Alternatives for Surface and
Near-Surface Soil—Northern
Depot Area
8.12.1 Remedial Alternatives
8.12.1.1 Pesticides and metals are present in
shallow soils at locations not associated with
any particular point source at the depot. Based
on sampling results, a hazard index of 30 from
arsenic and manganese was calculated in the
northern area of the depot. This result concerns
a potential exposure scenario for a depot worker
being trained as a grader operator. The remedial
alternatives developed for surface soils and
near-surface soils in the Northern Depot
Area are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Asphalt Cover
Alternative 4 - Excavation and Disposal
8.12.1.2 Alternative 1 includes five-year site
reviews and long-term groundwater monitoring.
Alternative 2 includes restricting access (posting
signs) to the areas where elevated
concentrations of arsenic and manganese have
been detected and two five-year site reviews.
Alternative 3 consists of installing an asphalt
cover over the soils with elevated levels of
arsenic and manganese. The area requiring an
asphalt covering is estimated at 140,000 square
feet. Alternative 4 involves excavating
approximately 3,000 cubic yards of soils with
elevated arsenic and manganese concentrations
and transporting them off site to a Class n or
Class HI disposal facility, depending on the
level of contamination.
8.12.2 Overall Protection of Human
Health and the Environment
The northern depot area soils pose a cancer risk
of 9x 10"7 to future grader operators and the
estimated hazard index is 30. Soil contaminants
in the surface and near-surface soils are not
considered to pose a potential threat to
groundwater in any of the alternatives.
Alternative l(No Action) may not be protective
of human health for the future grader operators,
as the hazard index for this scenario exceeds 30.
Alternative 2 (Institutional Controls) provides
some protection to human health by reducing
the potential for grader operators to be exposed
to contaminated soils. Alternative 3 (Asphalt
Cover) significantly reduces exposure by
covering the soils with asphalt. Alternative 4
(Excavation) provides the greatest protection to
human health and the environment because
contaminated soils are permanently removed
from the site.
8.12.3 Compliance with ARARs
No chemical-specific ARARs are identified for
the constituents of concern in the surface and
near-surface soils in the Northern Depot Area.
The chemicals of concern in surface and near
surface soils in the Northern Depot Area are not
considered to pose a threat to groundwater,
therefore, chemical-specific TBCs do not need
to be developed in accordance with Water
Quality Goals. Also, location-specific ARARs
are identified for this site. The action-specific
ARARs for hazardous waste management
(22 CCR, Division 4, Chapter 30, Section 66001
et seq., and 40 CFR 262, 263, and 264) that
apply to Alternatives 3 (Asphalt Cover) and 4
(Excavation) are met.
8.12.4 Long-Term Effectiveness
Alternative 1 (No Action) does not control
exposure to contaminated soil, nor does it
provide a long-term management measure.
Alternative 2 (Institutional Controls) provides
control measures to reduce the potential for
contact by depot workers at the site. Alternative
3 (Asphalt Cover) provides a reliable barrier to
human contact and thus prevents depot workers
from being exposed to arsenic and manganese in
the soil. However/since contaminants remain on
site, some long-term potential for exposure
continues to exist. Alternative 4 (Excavation)
provides long-term effectiveness and
permanence through excavation and off-site
disposal of contaminated soils.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.12.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
None of the alternatives actively reduces the
toxicity, mobility, or volume of contaminants at
the site through treatment.
8.12.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternatives 3
(Asphalt Cover) and 4 (Excavation), remedial
workers could be exposed to contaminated soil
during capping and soil excavation. However,
dust control and protective measures could be
taken to minimize these risks. Alternative 4
(Excavation) can be completed in approximately
three months.
8.12.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. The asphalt cover in Alternative
3 is relatively easy to install. Standard
techniques, equipment, and materials for the
asphalt cover could be employed. In Alternative
4 (Excavation), conventional earthmoving
equipment can be used to excavate the soil. The
transportation of soils and off-site disposal are
also easily implementable.
8.12.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $17,000. These costs
assume two five-year site reviews. The present
worth cost for the asphalt cover in Alternative 3
is $504,000. The present worth cost for
Alternative 4, which includes excavation with
off-site disposal, is $769,000 for disposal at a
Class En facility. The cost would increase to
$995,000 if disposal at a Class El facility is
required.
8.12.9 State and Community Acceptance
The state is not expected to accept
Alternatives I (No Action) and 2 (Institutional
Controls) because they do not mitigate the
potential threat to the future construction
worker. Alternatives 3 (Asphalt Cover) and 4
(Excavation) eliminate the threat to human
health and are protective of the environment;
therefore, state and community acceptance is
anticipated. One written public comment was
received that expressed concern over the
potential exposure and high cost of excavation.
It also expressed interest in the asphalt-capping
alternative (see Responsiveness Summary).
8.13 Remedial Alternatives for
SWMUs 2 and 3—the Sewage
and Industrial Waste Lagoons
8.13.1 Remedial Alternatives
8.13.1.1 SWMUs 2 and 3 are located in the
northern part of the depot, adjacent to the
Sewage Treatment Plant. According to the
Engineering Evaluation/Cost Analysis (EE/CA)
that was prepared for SWMUs 2, 3, and 33, the
recommended alternative for the lagoons is
excavation with off-site disposal. The remedial
alternatives developed for SWMUs 2 and 3 are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal
8.13.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the lagoons. Alternative 3 (selected in
the EE/CA) involves excavating approximately
10,000 cubic yards of soil with contaminant
concentrations above soil cleanup standards. It
is assumed that these soils can be disposed of at
a nearby Class HI (municipal) facility.
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
8.13.2 Overall Protection of Human
Health and the Environment
The maximum cancer risk estimated for the
current depot worker at these sites is 3xlO"6. The
risk hazard index was estimated at 0.07. Neither
Alternative 1 (No Action) nor Alternative 2
(Institutional Controls) mitigates the threat to
groundwater posed by contaminants in the soil.
Alternative 3 (Excavation) permanently removes
contaminated soil from the site, thereby
eliminating the potential threat to groundwater
quality at this location. Threats to ecological
receptors will be addressed by installation of a
geofabric filter and bringing in clean fill to
isolate receptors from contaminants.
8.13.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in soil
at SWMUs 2 and 3. Alternatives 1 (No Action)
and 2 (Institutional Controls) are not expected to
comply with these chemical-specific ARARs, as
the constituents of concern remain at the site.
Alternative 3 (Excavation) meets these ARARs
by permanently removing the contamination
through excavation and off-site disposal. The
action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30,
Section 66001 el seq., and 40 CFR 262, 263,
and 264) that apply to Alternative 3
(Excavation) are also met.
8.13.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of
constituents in the soil to groundwater because
contaminants remain on site. By removing
contaminated soils from the site, Alternative 3
(Excavation) eliminates any threat to
groundwater and provides long-term
effectiveness and permanence.
8.13.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
None of the alternatives actively reduces the
toxicity, mobility, or volume of contaminants at
the site through treatment.
8.13.6 Short-Term Effectiveness
The implementation of Alternatives 1 (No
Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new
environmental impacts. Under Alternative 3
(Excavation), remedial workers could be
exposed to contaminated soil during excavation.
However, dust control and protective measures
could be taken to minimize these risks.
Alternative 3 (Excavation)could probably be
implemented in less than three months.
8.13.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. With Alternative 3
(Excavation), conventional earthmoving
equipment can be used to excavate and transport
soils to an off-site disposal facility. However, it
may not be possible for the municipal landfills
in the vicinity of DDJC-Tracy to accept the
large quantity of soil that would need to be
excavated.
8.13.8 Cost
The estimated ten-year present worth for
Alternative 1 (No Action) is $15,000.
Alternative 2 (Institutional Controls) is expected
to have a present worth cost of $65,000. These
costs assume that five-year site reviews are
completed for 30 years. The present worth cost
for excavation and off-site disposal to a Class EH
disposal facility (Alternative 3) is $2.1 million.
8.13.9 State and Community Acceptance
The state is not expected to accept Alternatives
1 (No Action) and 2 (Institutional Controls)
because they do not mitigate the potential threat
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
to groundwater posed by contaminants in the
soil. Alternative 3 (Excavation) eliminates the
threat to groundwater and is protective of human
health; therefore, state and community
acceptance is anticipated. One written public
comment was received that expressed concern
over the potential exposure and high cost of
excavation (see Responsiveness Summary).
8.14 Analysis of Remedial
Alternatives for SWMU 33—
Industrial Waste Pipeline
8.14.1 Remedial Alternatives
8.14.1.1 SWMU 33 is an industrial waste
pipeline (IWPL) buried 2 feet bgs. The IWPL is
no longer used. According to the EE/CA for
SWMUs 2, 3, and 33 (Radian, 1996) the
removal action for the IWPL involves pressure-
grouting the laterals and sumps and excavating
the most contaminated soils. Following this
removal action, all soil cleanup levels will be
attained except those for aldrin, dieldrin,
diethylphthalate, and di-n-butylphthalate.
SWMU 33 is considered a source area for VOCs
and pesticides. The remedial alternatives
developed for SWMU 33 are:
Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Grouting, Limited
Excavation, and Disposal
(removal action)
Alternative 4 - Excavation and Disposal
8.14.1.2 Alternative 1 includes five-year
reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-
term monitoring, and land use restrictions
around the areas of contamination. Alternative 3
involves grouting inlets to the entire IWPL,
limited excavation, and institutional controls
including monitoring potential impacts to water
quality. It is assumed that the excavated soils
need to be disposed of at a Class I disposal
facility. The entire IWPL and all associated soil
contamination would be excavated under
Alternative 4.
8.14.2 Overall Protection of Human
Health and the Environment
Current cancer risks associated with SWMU 33
are estimated at IxlO'8 and the hazard index at
0.0007. All alternatives are protective of human
health. Alternatives 1 (No Action) and 2 do not
address any of the contamination that could
potentially impact groundwater. Alternative 3
(Grouting, Limited Excavation, Institutional
Controls) includes excavation of portions of the
IWPL, but a potential, though unconfirmed,
threat to groundwater quality would remain at
this location. Monitoring would be used to
identify any impacts to groundwater quality.
Alternative 4 would remove confirmed and
unconfirmed threats to the environment.
8.14.3 Compliance with ARARs
In compliance with Water Quality Goals
(CVRWQCB, 1993), chemical-specific TBCs
that are protective of groundwater were
developed for the constituents of concern in soil
at SWMU 33. Alternatives 1 (No Action) and 2
(Institutional Controls) do not comply with
these chemical-specific TBCs, as the
constituents of concern remain at the site.
Contaminants also remain in place in
concentrations above cleanup standards for
Alternative 3 (Grouting, Limited Excavation/
Institutional Controls). Alternative 3 removes a
portion of the contamination and reduces the
potential for the migration of these contami-
nants. The action-specific ARARs for hazardous
waste management (22 CCR, Division 4,
Chapter 30, Section 66001 et seq., and 40 CFR
262, 263, and 264) that apply to Alternatives 2
and 3 are also met. Alternative 4 satisfies all
ARARs.
8.14.4 Long-Term Effectiveness
Alternatives 1 (No Action) and 2 (Institutional
Controls) do not prevent the migration of soil
contaminants to groundwater because
contaminants remain on site. Alternative 3
(Grouting, Limited Excavation/Institutional
Controls) removes a portion of the contami-
nants, reduces the mobility of the contaminants,
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and relies on groundwater monitoring to
indicate potential threats to groundwater from
the contaminants left in place. Alternative 4 has
the highest long-term effectiveness because all
contaminants would be removed.
8.14.5 Reduction of Toxicity, Mobility,
and Volume through Treatment
None of the alternatives actively reduces the
toxicity, mobility, or volume of contaminants at
the site through treatment.
8.14.6 Short-Term Effectiveness
The implementation of Alternatives 1 and 2 (No
Action) do not pose any new risks to the
community or any new environmental impacts.
Under Alternatives 2, 3 (Grouting, Limited
Excavation, Institutional Controls), and 4
(Excavation and Disposal), remedial workers
could be exposed to contaminated soil during
excavation. However, dust control and
protective measures could be taken to minimize
these risks.
8.14.7 Implementability
There is no action associated with Alternative 1
(No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily
implementable. Alternative 3 (Grouting, Limited
Excavation, Institutional Controls) would use
conventional earthmoving equipment to
excavate and transport soils to an off-site
disposal facility. Alternative 4 (Excavation and
Disposal) would be difficult to implement
because of the number of subsurface utilities
and would impact the mission of DDJC-Tracy
by interrupting traffic.
8.14.8 Cost
The estimated present worth for Alternative 1
(No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a
present worth cost of $65,000. These costs
assume that five-year site reviews will be
completed for 30 years. In Alternative 3
(Grouting, Limited Excavation, Institutional
Controls) the present worth cost for excavation
and off-site disposal to a Class I disposal facility
is $242,600. Alternative 4 (Excavation and
Disposal) has a present worth cost of
$4,708,000.
8.14.9 State and Community Acceptance
The state is not expected to accept Alternative 1
(No Action) because it does not mitigate the
threats to groundwater at the site. Alternative 2
(Institutional Controls) is not expected to be
acceptable because it doesn't address potential
threats to groundwater quality. Alternative 3
(Grouting, Limited Excavation, and Institutional
Controls) is expected to be acceptable if the
groundwater monitoring program has adequate
provisions to address potential threats to
background groundwater quality from
contaminants left in place. Alternative 4
(Excavation and Disposal) is expected to be
acceptable to the state. One written public
comment was received that expressed concern
over the potential exposure and high cost of
excavation (see Responsiveness Summary).
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-1. National Contingency Plan (NCP) Evaluation Criteria
Category
Evaluation Criterion
Criterion Definition
Threshold
Criteria
Balancing
Criteria
Overall Protection of Human Health
and the Environment
Compliance with ARARs
Long-Term Effectiveness and
Permanence
Reduction of Toxicity, Mobility, or
Volume through Treatment
Short-Term Effectiveness
Implementability
Modifying
Criteria
Cost
State Acceptance
Community Acceptance
Addresses whether a cleanup alternative provides
adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or
controlled.
Addresses whether a remedy will meet all federal and
state environmental laws and/or provide grounds for a
waiver.
Refers to the ability of a remedy to provide reliable
protection of human health and the environment over
time.
Refers to the preference for a remedy that reduces health
hazards, the movement of contaminants, or the quantity of
contaminants at the site through treatment of the
contaminated media.
Addresses the period of time needed to complete the
remedy, and any adverse effects to human health and the
environment that may be caused during the construction
and implementation of the remedy.
Refers to the technical and administrative feasibility of a
remedy. This includes the availability of materials and
services needed to carry out a remedy. It also includes
federal, state, and local governments working together to
clean up the site.
Evaluates capital, operation, and maintenance costs of
each alternative in comparison to other equally protective
alternatives.
Indicates whether the state agrees with, opposes, or has no
comment on the preferred alternatives.
Includes determining which components of the
alternatives interested persons in the community support,
have reservations about, or oppose. This assessment may
not be completed until public comments on the Proposed
Plan are received.
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. Comparative Analysis of Alternatives by Site
Site: Dieldrin in Operable Unit 1 Groundwater
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
No Action
Low
Low
Low
Low
High
High
$49,000
Low
Low
Alternative 2
Institutional
Controls
Medium
Low
Medium
Low
High
High
$99,000
Low
Medium
Alternative 3
Groundwater
Extraction and
Treatment
Option 1
High
High
High
High
Medium
High
$2,528,000
High
Medium
Alternative 4
Groundwater
Extraction and
Treatment
Option 2
Medium
Medium
Medium
Medium
Medium
High
$1,396,000
Medium
Medium
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Table
Site:
Alternative 1
No Action
Low
Low
Low
Low
High
High
$45,000
Low
Low
8-2. (Continued)
Group A Sites
Alternative 2
Institutional
Controls
Medium
Low
Medium
Low
High
High
$195.000
Low
Medium
Alternative 3
Soil Vapor
Extraction
High
High
High
High
Medium
High
$648,000
High
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
Medium
$42,054,000
Medium
Medium
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. (Continued)
Site: SWMU 4 - Storm Drain Lagoon
Alternative 1
Alternative 2
Alternative 3
Criteria
No Action
Upstream Source
Control
Excavation and
Sediment Disposal
Overall Protection of Human Health
and the Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity, Mobility, and
Volume through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Medium
Low
Low
Low
Low
High
$25,000
Low
Low
Medium
Low
Medium
Low
Medium
Medium
$1,158,000
Low
Medium
Medium
Medium
Medium
Low
High
High
$552,000
Medium
High
Table 8-2. (Continued)
Site: SWMU 6 - Building 28 Sump
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Criteria
No Action
Institutional
Controls
In Situ
Stabilization
Excavation and
Off-site
Disposal
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
Slate Acceptance
Community Acceptance
Medium
Low
Low
Low
High
High
$15,000
Low
Low
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
High
High
High
High
Medium
High
$169,000
High
Medium
High
High
High
Low
Medium
High
$45,000 -$65,000
High
Medium
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. (Continued)
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Site: SWMU
Alternative 1
No Action
Medium
Low
Low
Low
High
High
$15,000
Low
Low
7 - Burn Pit No.
Alternative 2
Institutional
Controls
Medium
High
Medium
Low
High
High
$208,000
High
Medium
1
Alternative 3
In Situ
Stabilization
High
High
High
High
Medium
High
$822,000
High
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
High
$2,605,000
High
Medium
Table 8-2. (Continued)
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Site: SWMU
Alternative 1
No Action
Low
Low
Low
Low
High
High
$15,000
Low
Low
8 - Burn Pit No.
Alternative 2
Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
2
Alternative 3
Bioventing
Medium
Medium
Medium
Medium
Medium
Medium
$246,000
Low
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
High
$2,823,000
High
Medium
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. (Continued)
Site: SWMU 20 - Area 1, Building 10/Building 26
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
No Action
Medium
Low
Low
Low
High
High
$15,000
Low
Low
Alternative 2
Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
Alternative 3
SVE with
Excavation and
Disposal
High
High
High
High
Medium
High
$293,000
High
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
High
$355,000
High
Medium
Table 8-2. (Continued)
Site: SWMU 24 - Petroleum Waste Oil Tank
Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5
Criteria
No Action
Institutional
Controls
Bioventing
Excavation
and Off-site Excavation and
Disposal Bioremediation
Overall Protection of
Human Health and
the Environment Medium Medium Medium High Medium
Compliance with
ARARs Low Low High High High
Long-Term
Effectiveness Low Medium Medium High Medium
Reduction of
Toxicity, Mobility,
and Volume
through Treatment Low Low Medium Low Medium
Short-Term
Effectiveness High High Medium Medium Medium
Implementability High High High Medium Medium
Cost $15.000 $65.000 $166,000 $214,000 $263,000
State Acceptance Low Low High High High
Community
Acceptance Low Medium Medium Medium Medium
SEC-8.DOC
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17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Table 8-2
Site: SWMU
Alternative 1
No Action
Low
Low
Low
Low
High
High
$15,000
Low
Low
. (Continued)
27 - Building 206
Alternative 2
Institutional Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
Alternative 3
Excavation and Off-
site Disposal
High
High
High
Low
Medium
High
$112,000
High
Medium
Table 8-2
. (Continued)
Site: Drum Storage Area - Building 30
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
No Action
Medium
Low
Medium
Low
High
High
$15,000
Low
Low
Alternative 2
Institutional Controls
Medium
Low
Medium
Low
High
High
$87.000
High
Medium
Alternative 3
Excavation and Off-
site Disposal
High
High
High
Low
Medium
Medium
$907,000
High
Medium
SEC-8.DOC
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17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. (Continued)
Site: Surface and Near Surface Soil
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Criteria
No Action
Institutional
Controls
Asphalt Cover
Excavation and
Off-site
Disposal
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
Low
High
Low
Medium
High
Medium
High
High
Medium
High
High
High
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Low
High
High
$15,000
Low
Low
Low
High
High
$17,000
Low
Medium
Low
Medium
High
$504,000
High
Medium
Low
Medium
High
$769,000 -
$995,000
High
Medium
Table 8-2. (Continued)
Site: SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons
Criteria
Alternative 1
Alternative 2
Alternative 3
No Action
Institutional Controls
Excavation and Off-
site Disposal
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Medium
Low
Medium
Low
High
High
$15,000
Low
Low
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
High
High
High
Low
Medium
Medium
$2,100,000
High
Medium
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 8-2. (Continued)
Site: SWMU 33 - Industrial Waste Pipeline
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Criteria
No Action
Institutional
Controls
Limited
Excavation
Excavation and
Off-Site Disposal
Overall Protection of
Human Health and the
Environment Medium
Compliance with ARARs Low
Long-Term Effectiveness Medium
Reduction of Toxicity,
Mobility, and Volume
through Treatment Low
Short-Term Effectiveness High
Implementability High
Cost $15,000
State Acceptance Low
Community Acceptance Low
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
High
High
High
Low
Medium
Medium
$242,600
High
Medium
High
High
High
Low
Medium
Low
$4,708,000
High
Medium
SEC-8.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
9.0 SELECTED REMEDIES
Defense Depot San Joaquin (DDJC)-Tracy, the
United States Environmental Protection Agency
(U.S. EPA), the Department of Toxic Substances
Control (DTSC), and the Central Valley
Regional Water Quality Control Board
(RWQCB) have selected remedies for each site
at DDJC-Tracy. These remedies were selected
based on the requirements of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA), information in the
Comprehensive Remedial Investigation/
Feasibility Study (RI/FS) (Montgomery Watson,
1996a), a detailed analysis of alternatives, and
public comments. Twenty-two sites are
recommended for no further action (addressed in
Section 9.2). Remedial actions will be taken at
the other sites. Designs will be implemented
after DDJC-Tracy, U.S. EPA, DTSC, and the
RWQCB sign this Record of Decision (ROD).
The selected remedies for all sites are
summarized in Table 9-1.
9.1 Monitoring Program
9.1.1 There are 104 monitoring wells, 11
extraction wells, and 6 potable water supply
wells that are presently being sampled for
analysis on a quarterly to annual basis at
DDJC-Tracy. Twenty-four extraction wells have
been designed and emplaced for the Operable
Unit (OU) 1 groundwater remediation effort and
seven new wells are identified in this ROD as
part of the selected remedy. The success of the
selected remedies identified in this ROD will be,
in part, evaluated through the Well Monitoring
Program.
9.1.2 The monitoring wells that will initially be
used to monitor the performance of the selected
remedies are summarized in Table 9-2. The Well
Monitoring Program will undergo annual review
to ensure that the well locations, monitoring
frequency, water level measurements, and
analytes are optimized for the long term (see
Appendix E for monitoring well locations and
the decision logic that will be used to modify the
program in response to the monitoring results).
Each of the sites (not necessarily every well at
each site) recommended for further action in this
ROD (see Table 9-1) will be monitored for the
analytes identified in this section of the ROD
(see specific subsections for each individual site)
for no less than three years after soil and
groundwater cleanup standards have been
attained (per 27 CCR, Section 20410).
Furthermore, if wastes remain in place (e.g.,
under institutional controls), the site will be
monitored until cleanup standards are met or
until it can be demonstrated that no further threat
to water quality remains (27 CCR,
Section 20400).
9.1.3 Wastes will remain in place at
SWMU I/Area 2, SWMU 7, SWMU 24,
SWMU 33, and Drum Storage Area/Building 30
that could impact groundwater quality at some
future date. Monitoring will continue at these
sites until an acceptable rationale (e.g., based on
additional DI-WET analysis, data from the well
monitoring program, or revised vadose zone
modeling) demonstrates to the satisfaction of the
signatory parties that there is no further threat to
groundwater quality.
9.1.4 The Well Monitoring Program will be
modified to incorporate all of the site-specific
monitoring requirements identified in this
section. The following discussions of the
selected remedies identify specific monitoring
requirements that are part of the selected
remedies. The monitoring requirements
specified in this ROD are summarized in
Table 9-2. The Annual Well Monitoring Report
is a primary document. This report will identify
and include a qualitative evaluation of all
groundwater results and trends that exceed
background concentrations (see Table 7-1). This
evaluation may include recommendations for
additional sampling, additional monitoring
wells, or reevaluation of the selected remedy.
Each selected remedy of this ROD identifies
water quality objectives to protect the beneficial
uses of groundwater. If any of these water
quality objectives are exceeded, the
appropriateness of the selected remedy will be
evaluated in the Annual Well Monitoring
Report. Groundwater concentrations requiring
evaluation are not intended to serve as aquifer
cleanup standards. Per the Federal Facilities
Agreement (FFA), any party to the agreement
SEC-9.DOC
9-1
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
may submit a written proposal for additional
work or modification of the selected remedy on
the basis of the Annual Well Monitoring Report
results. DDJC-Tracy and the agencies will
jointly determine if any additional remedial
action is warranted.
9.2 No Further Action Sites
9.2.1 Twenty-two sites are recommended for no
further action (Table 9-1). The Comprehensive
RI/FS (Montgomery Watson, 1996a)
documented all sites recommended for no
further action along with the rationale
supporting that decision (see Table 7-15). All
sites were carried through to the feasibility study
process if the baseline risk assessment results
indicated that chemicals of concern (COCs)
posed a significant potential risk to humans,
plants, or animals. A site was also carried
through if it was determined that COCs posed a
threat to background groundwater quality or
beneficial uses. If neither of these conditions
was met, the site was determined to pose no
threat to human health and the environment and
recommended for no further action. No further
action sites were not typically considered in the
development of the Well Monitoring Program.
9.2.2 Three sites with COCs were also
recommended for no further action. Low levels
of COCs were identified at Solid Waste
Management Unit (SWMU) 10A, SWMU 14,
and SWMU 23 at DDJC-Tracy. Groundwater
has not been impacted to date by activities at
SWMU 10A. The fate and transport evaluation
conducted for SWMU 10A showed that the
diethylphthalate and di-n-butylphthalate present
in site soils pose a potential threat to background
groundwater quality. Both compounds were
detected in deep soils, but were suspected
laboratory contaminants (Montgomery Watson,
1996a). The cost to excavate possible phthaJate
contamination was estimated at $2 million to
$4.3 million (depending on type of disposal
required). Although technically feasible,
remediation was not recommended because of
the cost, the limited number of detections, and
questions regarding the reliability of the data.
This site will be assessed through the Well
Monitoring Program to determine if
groundwater has been impacted by COCs at this
site.
9.2.3 The fate and transport evaluations for
SWMU 14 and SWMU 23 showed that
constituents in soils do not pose a threat to water
quality. The baseline risk assessment
(Montgomery Watson, 1996e) showed that
COCs at SWMU 10A, SWMU 14, and SWMU
23 do not pose unacceptable risk to human
health or ecological receptors.
9.3 Day Care Center
The time-critical removal action at the Day Care
Center eliminated the incremental cancer risk
above background concentrations for surface
soils. No further threat to human health,
ecological receptors, or background groundwater
quality remains at this site. No additional actions
are anticipated at the Day Care Center.
9.4 Cleanup Standards
Cleanup standards were established to protect
human health, ecological receptors, background
groundwater quality, and beneficial uses.
Cleanup standards protective of human health
are risk-based standards to reduce the
incremental risk at a site to IxlO"6. Cleanup
standards to protect ecological receptors were
developed with input from the U.S. EPA.
Cleanup standards for groundwater are based on
beneficial use limits (e.g., Maximum
Contaminant Levels [MCLs]). Cleanup
standards to protect background water quality
were developed through vadose zone modeling
and equilibrium partitioning limits developed in
the RI/FS (Montgomery Watson, 1996a). This
water quality assessment is summarized in
Table 6-9. Appendix F documents the review of
analytical laboratories to identify the lowest
concentrations that can be reproducibly detected
as verified by the use of a low-level standard.
Where appropriate these concentrations were
adopted as cleanup standards.
9.5 OU 1 Groundwater
9.5.1 The selected remedy for OU 1 includes
extraction wells, air stripping to remove VOCs,
wellhead carbon treatment to remove dieldrin,
SEC-9.DOC
9-2
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
and reinjection. The primary disposal method is
to discharge extracted and treated groundwater
to shallow aquifers utilizing injection wells and
infiltration galleries located on the main base
property. DDJC-Tracy will construct additional
subsurface disposal facilities in these areas or on
the northern Annex property, as necessary, to
optimize the capacity of the groundwater
recharge disposal method. DDJC-Tracy will also
install a blind flange in the discharge piping so
that continued discharge to the storm water
detention pond is no longer possible. As a
backup disposal method after optimization of all
available subsurface disposal systems, treated
groundwater may be discharged to the on-site
wastewater evaporation/percolation ponds in
cases of emergency. An "emergency" is defined
as conditions such as failure of piping or
capacity problems such that discharge to
groundwater is not possible, as jointly
determined by DDJC-Tracy and the regulatory
agencies. The remedy addresses groundwater
contaminated with TCE, PCE, 1,1 -DCE, and
dieldrin.
9.5.2 OU 1 is defined as the contaminated
groundwater plume, on and off the depot, that is
emanating from DDJC-Tracy. This plume of
contamination is primarily identified by
concentrations of PCE and TCE. In August
1993, the final OU 1 ROD (WCC, 1993b) was
signed to implement the remedial alternatives
presented in the OU 1 RI/FS (WCC, 1992b).
The OU 1 ROD established aquifer cleanup
standards for PCE, TCE, and 1,1-DCE.
Groundwater from the OU 1 plume is currently
being extracted and treated by the Interim
Remedial Measure (IRM) system (Figure 9-1).
The present worth cost to construct and operate
the IRM system to address volatile organic
compounds (VOCs) is estimated at $9.5 million.
9.5.3 As part of the OU 1 full-scale design, the
feasibility of decreasing the OU 1 cleanup
standards to detection limits was analyzed. This
analysis was required by the OU 1 ROD (WCC,
1993). Modeling results showed that it is
technically and economically infeasible to
reduce OU 1 cleanup standards from aquifer
cleanup standards to detection limits. This
conclusion was documented in the Explanation
of Significant Differences (ESD) to the OU 1
ROD, which was approved by parties to the FFA
on 29 January 1996 (Montgomery Watson,
1996g). The ESD modified the selected remedy
for OU 1 from extraction, treatment, and
reinjection to a combination of extraction,
treatment, reinjection, and dispersion (dispersion
is limited to the TCE and PCE plume east of
Banta Road).
9.5.4 The OU 1 ROD deferred remedial
decisions for other constituents detected in
groundwater to the Comprehensive RI/FS.
Table 7-1 lists minimum and maximum
concentrations detected, the frequency of
detection, the remedial decision, the remedial
decision rationale, and the potential risks for
each constituent detected in groundwater at
DDJC-Tracy. Table 7-1 shows that except for
TCE, PCE, 1,1-DCE, and dieldrin, groundwater
contaminants do not warrant remedial action
because they were detected infrequently and/or
below beneficial use limits (e.g., MCLs) or
background levels. Dieldrin concentrations
above the California Action Level of 0.05 u.g/L
were detected near SWMUs 2, 3, and 8, and
within the Tracy Annex. Concentrations of
monuron and diuron in OU 1 groundwater are
well below the numerical beneficial use limit
(Table 7-1) of 10 Hg/L. Removal actions have
been performed to excavate contaminated soils
from the primary source area for monuron and
diuron (SWMUs 2 and 3). Neither compound
was detected in confirmation soil samples.
9.5.5 A thorough analysis of the Applicable or
Relevant and Appropriate Requirements
(ARARs) is presented in Section 10.3. All
chemical-specific ARARs were reviewed and
the most stringent were adopted as cleanup
standards for the aquifer. The cleanup standard
for dieldrin is based on the California Action
Level (a chemical-specific performance
standard). Attainment of background levels is
not technically or economically feasible. Aquifer
cleanup standards for groundwater at
DDJC-Tracy are provided in the in-text table,
below.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Analytes
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Dieldrin
Aquifer
Cleanup
Standards
(ug/L)
6.0
5.0
5.0
0.05
Basis
California MCL
Federal MCL
Federal MCL
California Action Level
9.5.6 The OU 1 ESD revised and expanded the
ROD-specified effluent treatment standards to
include total chromium, ODD, DDE, DDT.
chlordane, monuron and diuron. The effluent
treatment standards for monuron and diuron
were based on limited data from the initial
background study. No monuron or diuron has
been detected in the background wells at
DDJC-Tracy. The prior monthly median values
of 0.17 ug/L for monuron and 0.15 ng/L for
diuron were derived from the detection limits for
the A Horizon during the background study.
This study employed a modified method and the
detection limits for the A and B Horizons varied
(Radian. 1997) because the detection limits were
not reproducible. Therefore, this ROD proposes
raising the effluent treatment standard for these
compounds to the minimum concentration that
can be reproducibly detected, as verified by the
use of a low-level standard (see Appendix F).
Modified effluent treatment standards are
provided in the in-text table, below.
9.5.7 The existing OU 1 groundwater treatment
system includes 11 extraction wells, an air
stripper, and an infiltration gallery. The system
operates at a capacity of 350 to 470 gallons per
minute (gpm). The system is presently being
expanded to add 24 new extraction wells, a
larger treatment plant (air stripper), and nine
new infiltration galleries. The operating capacity
of the expanded system is estimated to be
1,250 gpm (Montgomery Watson, 19960- To
address pesticide contamination, the current
OU 1 design includes wellhead treatment at
extraction wells EW-02 and EW-05 with liquid-
phase carbon.
Analytes
Carbon Tetrachloride
Chloroform
Chromium (total)
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Dieldrin
4,4-DDD
4.4-DDE
4,4-DDT
Chlordane
Monuron
Diuron
Total Volatile Organic
Compounds (VOCs)
Treated
Effluent
Monthly
Median
(ug/L)
0.5
0.5
50
0.5
0.5
0.5
0.05
0.15
0.1
0.1
0.104
1.0
1.0
1.0
Treated
Effluent
Daily
Maximum
(ug/U
0.5
5.0
50
5.0
5.0
5.0
0.1
1.0
1.0
1.0
0.25
1.0
1.0
5.0
9.5.8 Alternative 3 (groundwater extraction and
treatment) is the selected remedy for dieldrin in
groundwater in OU 1. The components of the
selected remedy for dieldrin will be added to the
remedy of the OU 1 ROD to address all COCs in
groundwater. The area recommended for
remediation contains dieldrin concentrations
near SWMUs 2, 3, and 8, and within the
DDJC-Tracy Annex north of SWMUs 2 and 3.
The selected aquifer cleanup standard for
dieldrin is consistent with the effluent treatment
standard for dieldrin selected for the full-scale
OU 1 groundwater treatment system.
9.5.9 Groundwater modeling was performed to
prepare the conceptual design. The groundwater
model assumed that the removal actions will be
completed at SWMUs 2 and 3, and a remedial
action (Section 9.6.4) will be completed at
SWMU 8. The groundwater modeling indicates
that it is not technically feasible to meet the
aquifer cleanup standard for dieldrin within 30
years. The modeling predicts that the aquifer
cleanup standard can possibly be attained at
SWMUs 2 and 3 within 50 years, and at SWMU
8 in 30 to 50 years. However, the groundwater
modeling predicts that aquifer cleanup standards
cannot be attained at the Annex within 50 years.
The use of additional extraction wells is not
expected to reduce the time required to reach the
aquifer cleanup standard because dieldrin is
relatively immobile and the capture of
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
concentrations above the proposed cleanup
standard is difficult to achieve. Although the
cleanup standard of 0.05 pg/L cannot be
achieved within a 30 year time frame (in
accordance with Interim Final Guidance for
conducting Feasibility Studies Under CERCLA
[U.S. EPA, 1988]), DDJC-Tracy will take
action.
9.5.10 The selected remedy for dieldrin
consists of installing groundwater extraction
wells in the following areas: SWMUs 2 and 3
(one well), SWMU 8 (two wells), and the Annex
(at least four wells). Two existing extraction
wells at SWMUs 2 and 3 (EW02 and EW05)
will also be used to remediate dieldrin. Figure 9-
2 shows proposed extraction well locations and
the area of groundwater to be remediated. Each
extraction well will be completed in the Above
Upper Horizon and is expected to produce
approximately 5 gpm. Extracted water will be
treated with liquid phase granular activated
carbon (GAC) to remove dieldrin, VOCs, and
semivolatile organic compounds
(SVOCs)/pesticides in the extracted
groundwater.
9.5.11 Given the relatively low groundwater
extraction rates expected from the additional
extraction wells, it is anticipated that the
infiltration galleries included in the OU 1 full-
scale design will be sufficient to handle the
additional groundwater flows from SWMUs 2
and 3 and within the Tracy Annex. Because
SWMU 8 is located approximately 1,500 feet
from the nearest OU 1 infiltration gallery, it is
proposed that treated groundwater at this site be
injected. Although fouling of injection wells has
previously occurred, properly designed injection
systems (i.e., galleries), combined with
operation and maintenance (O&M) (including
regularly scheduled re-development), are
proposed as an appropriate and cost-effective
means for managing treated water.
9.5.12 A five-year policy site review will be
required for the OU 1 groundwater treatment
system because it will take more than five years
to attain the aquifer cleanup standard for
dieldrin. However, the five-year policy review for
the OU 1 treatment system will be postponed to
correspond with the review of all other sites at
DDJC-Tracy. This postponement will put all
decision-making on a single five-year cycle. Five-
year reviews will evaluate the performance of the
selected remedy and be continued for as long as
cleanup standards are exceeded. Groundwater
sampling within the plume areas will be
conducted as part of the Well Monitoring
Program (see Table 9-2).
9.5.13 The selected remedy is protective of
human health and the environment because
dieldrin, other pesticides, and VOCs are
removed from the groundwater, and because the
treated groundwater is returned to the aquifer for
use. Future risk to off-depot residents and depot
workers is addressed by the selected remedy.
The risk to off-depot residents is from carbon
tetrachloride (71%) and TCE (29%). Carbon
tetrachloride has been detected infrequently in
on-depot wells. Most of the carbon tetrachloride
in groundwater was not related to depot
activities (Montgomery Watson, 1996a). TCE
will be removed by the selected remedy. On
depot, the remedy will address dieldrin, which is
responsible for 55 percent of the cancer risk. The
remedy also addresses 1,1-dichloroethene (38%
of the cancer risk ) and chloroform (7% of the
cancer risk). The potential incremental cancer
risk above background to future depot workers
will be reduced to 3.83x10"* (this is equivalent to
the risk associated with the COCs at their
corresponding MCLs). The estimated present
worth of the selected remedy for dieldrin is
$2,528,000. The basis for this cost estimate is
included in Table 9-3. The total cost to address
all COCs in groundwater (VOCs and dieldrin)
has a 30-year present worth cost of
approximately $12 million.
9.6 Group A Sites
9.6.1 The selected remedy (Alternative 3 -
SVE) for the Group A sites addresses VOCs
(TCE and PCE) in soils. The remedy focuses on
VOCs at the following sites:
• SWMU I/Area 2;
• Area 1 Building 237; and
• Area 3.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
In addition to these sites, the northern portion of
the Industrial Waste Pipeline (IWPL) (SWMU
33) in the immediate vicinity of Area 1 Building
237 (between manhole W-5 and SB463) will be
further evaluated for VOCs in the predesign soil-
gas sampling effort as part of the remedial
design/remedial action effort. The soil-gas
investigation will be extended from the specified
locations as needed to identify the lateral and
vertical extent of contamination above the
numerical cleanup standards. The selected
remedy will be implemented concurrently with
the SVE system for SWMU 20, which addresses
VOCs at SWMU 20, Area 1 Building 10, and
the portion of the IWPL near Building 10.
9.6.2 The Group A sites do not pose potential
risks to human health under the depot or
construction worker exposure scenarios. No
risks to ecological receptors have been
identified. Vadose zone modeling (Montgomery
Watson, 1996b) and groundwater data suggest
that SWMU I/Area 2, Area 1 Building 237, and
Area 3 are continuing sources of VOCs to
groundwater that would require the OU 1
treatment system to operate beyond 30 years.
9.6.3 A thorough analysis of ARARs for the
selected remedy is provided in Section 10.4. The
cleanup standards for the Group A sites are as
follows:
Group A Site Soil-Gas
Analytes Cleanup Standards (yg/L)
Tetrachloroethene
Trichloroethene
5.4 (780 ppbv)
1.9(350ppbv)
Although TCE has not been detected in soils at
Area 1 Building 237, groundwater results
suggest that this area could be a potential source
area. Therefore, a cleanup standard for TCE was
retained at this site. The SVE systems will
address VOC concentrations above the cleanup
standards.
9.6.4 PCBs (Aroclor 1260) were detected at a
concentration of 140 mg/kg at 14.5 feet bgs in
SB 145 at SWMU I/Area 2. Aroclor 1260 was
not detected in any other soil samples collected
at the site. Fate and transport modeling results
show that the PCBs in soil at SB 145 pose a
threat to beneficial uses of groundwater. A
hypothetical cost estimate was prepared
assuming that the area of soil around boring
SB 145 where the PCBs were detected is to be
remediated by excavation and disposal
(Montgomery Watson, 1996a). The excavation
would be approximately 15 feet by 15 feet by
15 feet for a total soil volume of 125 cy
(165 tons). The total present worth cost for a
removal action with Class I disposal of soil is
$108,000. Although excavation and disposal is
technically feasible, the cost expenditure
required to remediate the small area of PCB-
contaminated soil at SWMU I/Area 2 is not
considered justified given the relatively low
level of contamination and the fact that PCBs
were detected in only one soil sample.
9.6.5 The vadose zone cleanup will be
achieved when:
1. The concentrations of PCE and TCE
present in soil gas are equal to or less
than the cleanup standard;
2. It is demonstrated that the remaining
TCE and PCE can no longer cause
leachate concentrations to exceed the
aquifer cleanup standards; and
3. TCE and PCE have been removed to the
extent technically and economically
feasible. This evaluation will include, at
a minimum, the following factors:
a) The total cost and duration of
continued operation of the SVE
system until aquifer cleanup
standards are met.
b) The total cost and duration of
continued groundwater treatment to
meet aquifer cleanup standards
without continued SVE operation.
c) The incremental cost (cost benefit)
of continued operation of the SVE
system on the basis of a cost per
pound of contaminant removal if the
underlying groundwater has not
attained aquifer cleanup standards.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
9.6.6 The signatory parties to the ROD will
jointly decide when the cleanup of volatile
organic COCs in the vadose zone has been
achieved and when the SVE system will be shut
off permanently. The evaluation of technical and
economic feasibility that will serve as the basis
for this decision will be a primary document.
9.6.7 The signatory parties to the FFA agree
that DDJC-Tracy may cycle the SVE system on
and off to optimize the SVE operation and/or
evaluate all feasibility analysis factors.
9.6.8 The selected alternative requires an SVE
system to be installed in the area of
contamination at each Group A site. Conceptual
site layouts of the SVE systems for
SWMU I/Area 2, Area 1 Building 237, and
Area 3 are shown in Figures 9-3, 9-4, and 9-5,
respectively. Predesign soil-gas sampling will be
performed at the areas designated for SVE
remediation. This investigation will be expanded
as needed to define the lateral and vertical extent
of contamination above the soil-gas cleanup
standard. The SVE systems will remove VOCs
from the vadose zone. Depending on the extent
of VOC contamination at each Group A site, an
array of extraction wells will be installed and
screened in the vadose zone. Approximately ten
extraction wells will be required for
SWMU I/Area 2, five for Area 1 Building 237,
and eight for Area 3 (Montgomery Watson
1996a). The radius of influence of the SVE wells
is estimated to be 40 feet based on the soil
lithology. The number of SVE wells will be
modified as necessary to address the extent of
contamination associated with the northern
portion of the IWPL (centered between manhole
W-5 and SB-463), SWMU I/Area 2, Area 1
Building 237, and Area 3. Additional SVE wells
or optimization techniques will be used to
address all soil-gas concentrations above the
cleanup standard.
9.6.9 An SVE system, including a treatment
pad and piping to connect the wells to a mobile
blower system, will be installed at each Group A
site. Air extracted from the SVE wells will be
treated with vapor-phase GAC before discharge
to the atmosphere. Techniques other than
cycling the system will be evaluated as needed
to achieve the cleanup standard. It is assumed
that each SVE system will operate continuously
for only six months because of the low mass of
VOC contamination.
9.6.10 The selected remedy includes continued
groundwater monitoring to evaluate the
performance of the selected remedy (see
Section 9.1 and Table 9-2).
9.6.11 Conventional drilling equipment can be
used to install the SVE wells. Treatability
studies may be required before full-scale
implementation to increase the accuracy of the
design parameters (e.g., SVE well radius of
influence and blower specifications).
9.6.12 The estimated costs to implement SVE
and to achieve soil-gas cleanup levels at each
Group A site include installing air extraction
vents, renting mobile SVE systems (including
vapor-phase GAC treatment units), piping, and
soil-gas confirmation sampling (less expensive
and more accurate than soil sampling). The
present worth of the treatment systems for the
Group A sites is $266,000 (SWMU I/Area 2),
$140,000 (Area 1 Building 237), and $242,000
(Area 3). The total cost for all Group A sites is
$648,000. The basis for these cost estimates is
included in Tables 9-4, 9-5, and 9-6,
respectively.
9.7 Group B Sites
9.7.1 SWMU 4 - Storm Drain Lagoon
9.7.1.1 Alternative 3 (Limited Excavation and
Disposal) is the selected remedy for SWMU 4.
SWMU 4 is a storm water detention pond that
collects all storm water runoff from DDJC-
Tracy through a network of underground storm
drains and open surface drainage ditches.
SVOCs (PAHs), pesticides, and metals have
been detected in the lagoon sediment and
subsurface soil (see Appendix C). Selenium,
lead, and OC pesticides pose a threat to
ecological receptors. Human health is not
threatened under the depot worker or
construction worker scenario.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
9.7.1.2 Because the concentrations of
contaminants in the sediment and the soil
beneath the storm water pond do not indicate a
current threat to groundwater quality, no further
action to protect groundwater quality is
warranted at SWMU 4. Four points support this
conclusion.
9.7.1.3 First, the October 1996 subsurface
sampling results (not included in the RI/FS)
show that migration from the surface sediment
to the subsurface soil is minimal. The analysis of
these results modifies the conclusions of the
RI/FS (Montgomery Watson, 1996a). The
concentrations and numbers of analytes that
exceed background or cleanup concentrations
are much lower in the soil samples collected at 1
to 1.5 feet below the bottom of the pond than in
the sediment samples collected from 0 to 6
inches below the bottom of the pond. The
compounds that are present in the soil at
concentrations greater than background levels
(ODD and the PCB Arochlor 1260) have not
been detected in groundwater samples from
downgradient monitoring wells (LM004AU and
LM027AUA). Dieldrin was detected above the
practical quantitation limit (3 Hg/kg) in only one
soil sample collected from deeper than 6 inches.
9.7.1.4 The data from fourteen surface
sediment samples (0 to 6 inches below the
bottom of the pond) collected during the
remedial investigation (Montgomery Watson,
1996) and 18 subsurface soil samples collected
above the water table (1 to 1.5 feet below the
bottom of the pond) (Radian, 1996e) indicate
that the number of compounds and their
concentrations decrease with depth beneath the
storm water pond (see Appendix C). The surface
sediment samples had one to five SVOCs
reported; however, no SVOCs were reported in
the subsurface soil samples. One PCB (Arochlor
1260) was detected in eight surface sediment
samples at concentrations of 41 to 459 Hg/kg;
however, this contaminant was only detected in
1 of the 18 subsurface soil samples (at a
concentration of 160 |ig/kg).
9.7.1.5 No urea-carbonate pesticides or
chlorinated herbicides were reported in the
subsurface soil samples. The pesticide DDD was
detected in all the surface sediment samples at
concentrations of 31 to 2,310 Hg/kg. Although
this compound was detected in 14 of the 18
subsurface soil samples from 1 to 1.5 feet below
the bottom of the pond, the concentrations
ranged from 1.5 to 380 Hg/kg, and only four
samples had concentrations above background
soil concentrations (28.1 Jig/kg). The
concentrations of DDT, which were detected in
four subsurface soil samples, and DDE, detected
in ten subsurface soil samples, were all less than
the background soil concentrations of
2,565 |ig/kg and 1,284 ng/kg, respectively.
Dieldrin was reported in four surface sediment
samples and four subsurface soil samples;
however, the highest reported concentration in
the subsurface soil (6.5 ug/kg) was lower than
the lowest concentration in the surface sediment
samples.
9.7.1.6 Second, the de-ionized water waste
extraction test (DI-WET) results for subsurface
soils do not indicate any confirmed impacts to
water quality. One subsurface soil sample that
had measurable concentrations of DDE
(73 ng/kg), DDD (380 ng/kg), DDT (1.1 ^g/kg),
and dieldrin (2.7 u,g/kg) was subjected to the DI-
WET to determine what fraction of the
compounds may be teachable. Analyses of the
leachate from the sample only showed
reportable concentrations of DDE (0.13 Hg/L)
and DDD (1.1 u.g/L). DDT and dieldrin
concentrations were below reporting limits in
the leachate. Although the leachate results
suggest that there is potential for the frequently
reported DDD and DDE to affect groundwater
adversely, neither DDD nor DDE has been
reported in any groundwater samples collected
from LM004AU and LM027AUA, the
downgradient monitoring wells.
9.7.1.7 Third, only dieldrin has been detected
in both surface sediment and subsurface soil
samples and in downgradient monitoring wells.
Only dieldrin (one of six samples from
LM004AU and one of 11 samples from
LM027AUA), monuron (two of four samples
from LM027AUA, and none from LM004AU),
diuron (one of two samples from LM004A, and
three of four from LM027AA), simazine (one of
SEC-9.DOC
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2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
one from LM027AUA), and manganese (one of
one from LM027AUA) detections have
indicated any adverse impact on groundwater.
However, dieldrin is the only one of these
compounds reported in the groundwater samples
that was also reported above background levels
in the surface sediment or subsurface soil
samples from the pond.
9.7.1.8 Finally, dieldrin has not been measured
in downgradient monitoring wells since 1994.
Oieldrin has been detected in one of six
LM004AU groundwater samples and one of 11
LM027AUA samples. In July 1993, a dieldrin
concentration of 0.011 ng/L was measured at
LM004AU. In 1995 and 1996, all dieldrin
results were below the reporting limit of
0.10 ug/L. Between 1987 and 1993, dieldrin
concentrations at LM027AUA ranged from less
than 0.005 u.g/L (detection limit) to 0.11 u.g/L.
All dieldrin results were less than the reporting
limit (0.1 ng/L) in 1995 and 1996.
9.7.1.9 In conclusion, the surface sediment,
subsurface soil, soil leachate, and groundwater
results suggest that SWMU 4 is not now, and is
unlikely to be in the future, a source of
groundwater contamination. Although there has
been an almost constant downward driving force
of standing storm water in the pond,
contaminants have not been leached into the
groundwater at levels that would cause
groundwater concentrations to exceed
background levels during the 25 years that the
pond has been used. The groundwater analyses
do not indicate conclusively that the dieldrin,
monuron, and diuron detected in the
groundwater samples can be attributed to the
storm water pond. There is no clear evidence
that the remediation of the soil at this site would
have any effect on groundwater quality. This
analysis modifies the conclusions of the RI/FS.
9.7.1.10 The cost of excavating all surface
sediment and subsurface soils with analyte
concentrations that could potentially impact
background groundwater quality (based on
equilibrium partitioning limits) is estimated as
5700,000. The above analysis shows that the
benefits associated with excavation to protect
groundwater quality at SWMU 4 are doubtful,
and funding excavation to address unlikely
groundwater impacts is not warranted at this
site. Therefore, the selected remedy is based on
cleanup standards to protect ecological
receptors.
9.7.1.11 A thorough analysis of ARARs is
provided in Section 10.5.2. Sediment cleanup
standards for SWMU 4 were developed from
ecological assessment results (see Appendix D).
The cleanup standards are:
SWMU 4 Cleanup
Analytes Standards (\tg/kg)
Total DDX
Lead
Selenium
241
5,130
616
Preliminary standards: see discussion below.
9.7.1.12 Cleanup standards for total DDX,
lead, and selenium are risk-based concentrations
(see Section 6.6.5). These standards were
estimated using literature values rather than site-
specific bioaccumulation factors. Additional
data will be collected to obtain site-specific
bioaccumulation factors, and to evaluate the
effects of the sediment on surface water. These
cleanup standards and the extent of excavation
will be evaluated and revised as jointly
determined by DDJC-Tracy and the agencies.
Any modification of the cleanup standards will
be made through an explanation of significant
differences to this ROD.
9.7.1.13 In addition to the cleanup standards
identified for sediments, any discharge from
SWMU 4 to the local irrigation canal must meet
the freshwater chronic ambient water quality
criteria (AWQC) for protection of aquatic life
(U.S. EPA, 1988). Samples collected in early
October 1994 exceeded the freshwater chronic
AWQC for DDT (1.0 x 10'J ng/L) and dieldrin
(1.9 x 10"3 |ag/L). The following standards for
storm water discharge will be applied.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Analytes
Storm Water
Discharge
Standards
DDT
Dieldrin
O.I*
0.05*
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as trace
amounts and will be evaluated. Cases where the actual
detection limit differs significantly from the estimated
detection limit because of matrix or other effects will be
flagged.
9.7.1.14 The storm water pond will only
receive storm water. It is uncertain if the storm
water discharge will exceed the AWQC;
however, the concentrations will be confirmed
by sampling (under the storm water pollution
prevention program) at least two discharge
events per year (the first event of the year and
one other) for the next five years and evaluated
in the first five-year review. The potential
carryover of sediment from the pond will also be
evaluated. If contaminants (filtered and
unfiltered water samples) exceeding the
discharge standard or contaminated sediment are
found in the discharge, DDJC will evaluate and
identify an appropriate modification of the
selected remedy (e.g., additional excavation,
sediment traps, etc.) to achieve the discharge
requirements.
9.7.1.15 The selected remedy includes
dewatering the storm drain lagoon, construction
of a sediment trap at the northern inlet and an
overflow weir for discharge to surface water at
the outlet, excavating sediment contaminated
with pesticides and selenium (Figure 9-6), and
transporting the sediment to a disposal facility
(Class II municipal facility is anticipated) for
disposal. The need for additional sediment
controls on the southern inlet will be evaluated.
Sediment samples will be collected for analysis
during the remedial action to ensure that
sediment remaining across the bottom of the
lagoon does not exceed the risk-based
concentrations for ODD, DDE, DDT, and
selenium that are protective of ecological
receptors or cause any discharge from SWMU 4
to exceed the AWQC for the protection of
aquatic life. The excavated sediment should not
be considered a listed hazardous waste under
RCRA.
9.7.1.16 Groundwater sampling for SVOCs
and pesticides/herbicides will be performed as
part of the Well Monitoring Program (see
Table 9-2) to evaluate the effectiveness of the
selected remedy. Lead and selenium are
potential threats to ecological receptors only and
do not post a threat to groundwater quality. As
stated in Section 9.1, concentrations of COCs
exceeding the following concentrations will be
evaluated in the Annual Well Monitoring
Reports.
Groundwater
Concentrations
Requiring
Analytes Evaluation (pg/L)
Bis(2-ethylhexyl)phthalate 10*
Carbaryl 60
Carbofuran 18
Chlordane 0.1*
2,4-D 70
Dieldrin 0.05*
Fluoranthene 280
Phenanthrene 10
Pyrene 2K)
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as trace
amounts and will be evaluated. Cases where the actual
detection limit differs significantly from the estimated
detection limit because of matrix or other effects will be
flagged.
9.7.1.17 At a date to be agreed upon, far
enough in advance of the 5-year CERCLA
review meeting so that relevant information can
be presented, DDJC Tracy will collect and
analyze sediment samples from SWMU 4 for the
pesticides of concern. If pesticide levels are not
found to be protective of the ecological
receptors, DDJC Tracy will take action to
restore the ecological protectiveness level in the
sediment. This action, depending on the
consensus of the group, could be performed
under CERCLA or some other program, such as
the Storm Water Protection Program. In either
case DDJC would agree to install sediment traps
on the inlet to the storm water detention pond to
prevent any future buildup of sediments if the
selected remedy does not demonstrate adequate
permanence.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
9.7.1.18 The selected remedy reduces the
toxicity and volume of sediment and surface
water COCs at the site because it removes the
contaminated sediment from the storm drain
lagoon. The selected remedy is protective of
human health and the environment. Because the
storm drain lagoon will remain in service as part
of the DDJC-Tracy storm water system, the
appropriate best management practices, as
identified in the DDJC-Tracy Storm Water
Pollution Prevention Plan, will be used to ensure
that future storm water pollution is minimized.
The present worth cost of this alternative is
estimated at $855,520. The basis for this cost
estimate is included in Table 9-8.
9.7.1 SWMU 6 - Building 28 Sump
9.7.2.1 Alternative 4 (Excavation and
Disposal) is the selected remedial alternative for
SWMU 6. SWMU 6 consisted of a 250-gallon
concrete sump located on the west side of
Building 28; this building was used to repackage
materials from damaged containers. Wastes from
this recoup operation were collected in the
concrete sump, pumped into 55-gallon drums, and
then removed to a Class I or other disposal site.
The sump was removed in 1977; an asphalt patch
at the site marks the location of the excavation. RI
results indicate that pesticide and herbicide
contamination in the soil is limited to the area
immediately adjacent to the sump excavation and
from depths below the sump excavation to directly
above the water table. The Baseline Risk
Assessment (BRA) results show no potential
human health or ecological risks at SWMU 6.
Vadose zone modeling results indicate that
pesticides (dicamba, dieldrin, endrin, heptachlor,
2,4,5-T, and lindane) pose a potential threat to
background groundwater quality. Thus, the
recommended alternative will permanently
remove the potential threat posed to groundwater
by pesticides in the soil.
9.7.2.2 A thorough evaluation of ARARs is
provided in Section 10.6.2. Cleanup standards
for SWMU 6 were developed from vadose zone
modeling (Montgomery Watson, 1996a), which
identified potential threats to background
groundwater quality at this site. The cleanup
standards were developed to protect background
groundwater quality to levels consistent with
Water Quality Goals (CVRWQCB, 1993). The
proposed cleanup standards are:
Analytes
SWMU 6
Cleanup standards
Dicamba
Dieldrin
Endrin
Heptachlor
Lindane
2.4.5-T
10
3
3
1.5
1.7
5
9.7.2.3 The equilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for
summary) provided very conservative estimates
of the soil concentrations required to protect
background groundwater quality. These limits
correspond to the maximum concentration
expected in soil pore water and do not account
for an expected decrease in concentration
resulting from migration through less
contaminated or clean soils to groundwater (see
Figure B-l 1). Furthermore, only lindane has
impacted groundwater at SWMU 6 to date.
Because of these factors, it was considered
appropriate to use a laboratory reporting limit
corresponding to the lowest concentration that
can be reproducibly detected as verified by the
use of a low-level standard (Appendix F). This
analysis modifies the cleanup standards
presented in the RI/FS (Montgomery Watson,
1996a).
9.7.2.4 The selected remedy includes
excavating approximately 100 cy of soil
contaminated with pesticides from SWMU 6
(Figure 9-7). Confirmation samples will be
collected to ensure that cleanup standards will be
achieved. A natural gas line at the site must be
taken out of service during the excavation.
Approximately 60 cy of soil will be transported
to a Class I or Class II off-site disposal facility,
depending on the level of contamination. Clean
soil imported from off-site will be used to
backfill the excavated areas.
9.7.2.5 Groundwater sampling for SVOCs and
pesticides/herbicides will be performed as part
of the Well Monitoring Program (see Table 9-2)
to evaluate the effectiveness of the selected
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
remedy. As discussed in Section 9.1.
concentrations of COCs exceeding the following
levels will be evaluated in the Annual Well
Monitoring Reports.
Groundwater
Concentrations
Requiring Evaluation
Analytes
Dieldrin
Dicamba
Endrin
Heptachlor
Lindane
2.4.5-T
(M9/L)
0.05*
210
->
0.01*
0.03
70
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as trace
amounts and will be evaluated. Cases where the
actual detection limit differs significantly from the
estimated detection limit because of matrix or other
effects will be flagged.
9.7.2.6 This alternative is protective of human
health and the environment. It removes the
threat to groundwater posed by the contaminated
soil. The present worth of this alternative is
$45,000 for Class II disposal or $65,000 for
Class I disposal. The basis for these cost
estimates is included in Tables 9-9 and 9-10.
9.7.3 SWMU 7 - Burn Pit No. 1
9.7.3.1 Alternative 2 (Institutional Controls) is
the selected remedy for SWMU 7. SWMU 7
consists of a total of seven reported pits that
were operated before the construction of the
warehouse and buildings at the site. The pits
were used for the disposal of medical supplies,
narcotics, general pharmaceuticals, radiological
supplies, and electron tubes. The pits may have
been up to 16 feet deep; ashes were removed and
transported to off-site landfills during the later
years of operation (WCC, 1992a). BRA results
show no potential risks to human or ecological
receptors. Vadose zone modeling results indicate
that total petroleum hydrocarbons as diesel
(TPHD) in Pit D, VOCs in Pit F, SVOCs in
Pit C, and pesticides and herbicides (2,4-D,
linuron, dieldrin, and simazine) detected in
SWMU 7 soils may pose a threat to background
groundwater quality uses at two of the pits;
however, this threat has not been confirmed by
the results of groundwater monitoring conducted
to date. Because portions of the seven pits are
covered by buildings and groundwater
contamination is not present at the site,
institutional controls appear warranted as the
recommended alternative. By covering portions
of the pits, the building foundations prevent
adverse exposure to receptors and mitigate
groundwater threats by reducing rainwater
infiltration.
9.7.3.2 A thorough evaluation of ARARs is
provided in Section 10.7.2. Cleanup standards
for SWMU 7 were developed from vadose zone
modeling (Montgomery Watson, 1996a), which
identified potential threats to background
groundwater quality at this site. The cleanup
standards were developed to protect background
groundwater quality to levels consistent with
Water Quality Goals (CVRWQCB, 1993). The
proposed cleanup standards are:
Analytes
1.2-Dichloroethene (Pit F)
Trichloroethene (Pit F)
Bis(2-ethylhexyl)phthalate (Pit C)
2,4-D
Dieldrin (Pit C and D)
Linuron (Pit C and D)
Simazine (Pit D)
TPH as diesel (Pit D)
SWMU 7
Cleanup
standards
(ug/kg)
10
5
330
25
3
200
10
100,000
9.7.3.3 The TPHD cleanup standard was
developed from the Tri-Regional Guidelines.
The equilibrium partitioning limits developed in
the RI/FS (see Table 6-9 for summary) provided
very conservative estimates of the soil
concentrations required to protect background
groundwater quality. These limits correspond to
the maximum concentration expected in soil
water and do not account for an expected
decrease in concentration resulting from
migration through less contaminated or clean
soils to groundwater (Figures B-12 and B-13).
Furthermore, of the COCs, only bis(2-
ethylhexyl)phthalate has been detected in
groundwater at SWMU 7 to date. Because of
these factors, it was considered appropriate to
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
use a laboratory reporting limit corresponding to
the lowest concentration that can be
reproducibly detected as verified by the use of a
low-level standard (Appendix F). This analysis
modifies the cleanup standards presented in the
RI/FS (Montgomery Watson, 1996a).
9.7.3.4 The selected remedy includes the
following components:
• The real property records for Buildings 19
and 21 will be modified such that the
signatory parties to the ROD must be
contacted at least one month before any
demolition or construction activities that
could expose contaminated soil. The DDJC-
Tracy Master Plan designates this area for
industrial use only.
• Two additional monitoring wells will be
installed downgradient from SWMU 7 (see
Figure E-2).
• Groundwater will be monitored for as long
as contaminants remain in place with
concentrations that could threaten
groundwater quality or until it can be
demonstrated that no further threat to
groundwater quality exists.
9.7.3.5 The selected remedy includes land use
restrictions around the disposal pits (at Buildings
19 and 21) where concentrations of pesticides
and other COCs have been detected. If
ownership of the installation is transferred to
private or nonfederal entities in the future,
restrictive covenants, written into the land
property deed, could be established that would
prevent schools, playgrounds, hospitals, and
housing from being built at the sites until COCs
are below levels of concern. Cooperation among
the U.S. Army, San Joaquin County, and Cal-
EPA will be required to enact the restrictions on
access and land use.
9.7.3.6 Two new wells will be installed as part
of the selected remedy (Figure E-2). One of the
additional wells will be monitored for SVOCs
and both wells will be monitored for
Organophosphorus (OP) pesticides, OC
pesticides, chlorinated herbicides, and
carbamate/urea pesticides annually. In addition,
both new wells will be monitored for
dioxins/furans (unconfirmed chemicals of
potential concern) semiannually for one year.
Monitoring for dioxins/furans in the two new
wells was incorporated into the selected remedy
in lieu of performing additional investigation
activities at SWMU 7. The new wells will be
sufficient to assess any groundwater
contamination emanating from the burn pits
without performing additional monitoring of
LM43A. Monitoring of LM095AU will be
continued as part of the selected remedy.
9.7.3.7 Groundwater sampling for SVOCs and
pesticides/herbicides will be performed as part
of the Well Monitoring Program (see Table 9-2)
to evaluate the effectiveness of the selected
remedy. As discussed in Section 9.1,
concentrations of COCs exceeding the following
levels will be evaluated in the Annual Well
Monitoring Reports.
Groundwater
Concentrations
Requiring
Evaluation
Analytes (pg/L)
1,2-Dichloroethene (Pit F)
Trichloroethene (Pit F)
Bis(2-ethylhexyl) phthalate (Pit C)
Linuron
2,4-D
Simazine
Dieldrin (Pit C and D)
TPH as diesel
Total dioxins/furans
6
2.3
10*
2*
70
4
0.05*
100
0.01*
* For these compounds, results above the estimated detection
limit (see Table 9-7) will be reported as trace amounts and
will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit
because of matrix or other effects wilt be flagged.
9.7.3.8 At least two additional consecutive
rounds of groundwater monitoring for
dioxins/furans are required as part of the
selected remedy. This monitoring and
interpretation was agreed upon as a substitute for
extending the remedial investigation. The
potential threat to groundwater from
dioxins/furans will be reevaluated in the first
five-year CERCLA review.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record or Decision
9.7.3.9 Five-year site reviews are required by
the CERCLA guidance because contaminants
will be left in place.
9.7.3.10 Institutional controls do not reduce
the toxicity, mobility, or volume of the COCs in
the soils. The selected remedy is protective of
human health under current land use conditions,
and because it implements land use restrictions,
it is also protective of human health under future
land use conditions. The present worth of this
alternative is $208,000. The basis for this cost
estimate is included in Table 9-11.
9.7.4 SWMU 8 - Burn Pit No. 2
9.7.4.1 Alternative 4 (Excavation and
Disposal) is the selected remedy for SWMU 8.
SWMU 8 is a single large burn pit that is
approximately 16 feet deep, 250 feet long, and
30 feet wide. Phthalates, PAHs, pesticides,
petroleum hydrocarbons, dioxin/furans, and
metals have been released to the soil from
disposal activities associated with SWMU 8. In
general, the elevated concentrations of these
constituents are limited to the middle fill horizon
(starting at approximately 4 feet below ground
surface [bgs]) and the lower fill horizon (down
to groundwater) of the central and northern
portion of the pit. The BRA results indicate that
OC pesticides (chlordane, DDD, DDE, DDT,
and dieldrin) detected in soil at SWMU 8 could
pose potentially significant risks to future
construction workers. The selected remedy
would remove the contaminated soils that
contribute to a risk in excess of IxlO"6. The
hazard index at this site would be approximately
8 following remediation, but this level reflects
that the presence of manganese (upper
confidence limit [UCL] is 630 mg/kg) is below
the background threshold concentration
(805 mg/kg). The selected remedy is therefore
considered protective of human health under
current and future land use conditions.
9.7.4.2 The vadose zone modeling results for
SWMU 8 indicate that SVOCs,
pesticides/herbicides, and petroleum
hydrocarbons detected in deep soils could
migrate to groundwater and potentially threaten
background groundwater quality. SWMU 8 is
considered a primary source area of dieldrin
contamination in groundwater. In addition, the
levels of total petroleum hydrocarbons as
gasoline (TPHG), TPHD and total petroleum
hydrocarbons as motor oil (TPH-MO) in soil at
SWMU 8 are above the State Water Resources
Control Board (SWRCB) Tri-Regional
Guidelines of 1,000 Hg/kg, 10,000 ng /kg, and
10,000 ng /kg, respectively, for TPH within five
feet of groundwater.
9.7.4.3 A thorough evaluation of ARARs is
provided in Section 10.8.2. Cleanup standards
for SWMU 8 were developed using risk-based
concentrations and vadose zone modeling
(Montgomery Watson, 1996a), which identified
potential threats to background groundwater
quality at this site. The cleanup standards
developed to protect background groundwater
quality are consistent with Water Quality Goals
(CVRWQCB, 1993) and SWRCB Tri-Regional
Guidelines. The proposed cleanup standards are:
SWMU 8 Cleanup
Analytes Standards (ug/kg)
Total chlordane
2,4-D
DDD
DDT
Total DDX
Dieldrin
Lindane
Linuron
MCPA
Simazine
bis(2-elhylhexyl)phthalate
Diethylphthalate
2.4-Dinilrotoluene
Naphthalene
TPH as gasoline
TPH as diesel
TPH as motor oil
10
25
81
7
30,000
2
1.7
200
5,000
10
330
330
330
330
1,000
10.000
10,000
9.7.4.4 The basis for the soil cleanup standards
for DDD and DDT is the calculated equilibrium
partitioning limit developed in the RI/FS (see
Table 6-9 for summary) that is protective of
beneficial uses. The cleanup standard for total
DDX is a risk-based concentration
corresponding to increased lifetime cancer risk
of IxlO'6. The soil cleanup standards for TPHG,
TPHD, and TPH-MO were determined using the
scoring criteria of the Tri-Regional guidance.
SEC-9.DOC
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2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
The basis for the soil cleanup standards for
2,4-D. bis(2-ethylhexyl)phthalate, naphthalene,
total chlordane, dieldrin, lindane, linuron,
MCPA. simazine, diethylphthalate, and 2,4-dini-
trotoluene is the analytical method reporting
limit. The equilibrium partitioning limits
provided very conservative estimates of the soil
concentrations required to protect background
groundwater quality. These limits correspond to
the maximum concentration expected in soil
water and do not account for an expected
decrease in concentration resulting from
migration through less contaminated or clean
soils to groundwater (Figures B-14 through
B-16). Chlordane, ODD, DDE, and DDT have
been detected in groundwater at SWMU 8 to
date. The disposal area for these compounds is
well defined, and soil will be excavated to the
water table so all COCs will be addressed.
Therefore, it was considered appropriate to use a
laboratory reporting limit corresponding to the
lowest concentration that can be reproducibly
detected as verified by the use of a low-level
standard (Appendix F). This analysis modifies
the cleanup standards presented in the RI/FS
(Montgomery Watson, 1996a).
9.7.4.5 The selected alternative includes
excavating approximately 8,000 cy (10,400 tons)
of contaminated soil and debris from the burn pit
at SWMU 8 (Figure 9-8). The soil and debris
will be excavated to approximately 14 feet bgs
(the limits of the disposal area are well defined).
Soil will be removed to the approximate depth
of the water table. From the COCs detected in
SWMU 8 soils, it is assumed that 3,400 tons of
contaminated soil will be disposed of at a Class I
or other disposal facility in compliance with
state and federal laws and regulations.
Approximately 2,400 tons of debris (concrete,
wood, etc.) will be disposed of at a Class HI
facility. Clean soil imported from off-site will be
used to backfill the excavated areas. Excavation
and disposal will permanently remove all known
soil with contaminant concentrations above
cleanup standards. Therefore, the selected
alternative permanently prevents migration of any
known soil constituents to groundwater
(confirmation sampling is included in the remedy
for VOCs to address remaining data gaps). Given
the relatively high levels of contaminants in the
former bum pit, construction workers should take
necessary precautions to ensure worker health
protection during soil excavation activities. In
addition, the presence of buried debris in the
former burn pit can make the excavation of the
contaminated material difficult.
9.7.4.6 Confirmation sampling for the COCs
and VOCs (soil gas) will be performed during
site remediation. Sampling for VOCs has been
agreed to by the signatory parties as a substitute
for extending the remedial investigation at this
site. The results of the confirmation sampling for
VOCs will be included in the construction
report. Further actions at SWMU 8 will depend
on the magnitude of any VOCs reported. If VOC
concentrations in soil-gas exceed the soil-gas
cleanup standard, an explanation of significant
differences will be required to evaluate remedial
options.
9.7.4.7 Also included in the selected remedy
for SWMU 8 is the installation of one new
monitoring well (see Table 9-2). This well and
the two existing wells (LM97A and LM119A)
near the site will be monitored for OC pesticides
over four quarters. This monitoring is included
in the selected remedy because the dieldrin
plume predicted to be in groundwater
downgradient of the site by groundwater
modeling has not been confirmed by historical
groundwater monitoring results. It is assumed
that the new monitoring well will be installed in
the zone of highest concentrations of dieldrin at
SWMU 8, approximately halfway between
monitoring wells LM97A and LM119A. The
new monitoring well will also be monitored for
dioxins/furans semiannually for one year. If the
dioxin/furan levels are above the water quality
objectives, the Annual Well Monitoring Report
will be used to develop a strategy for continued
monitoring or further action, as needed.
9.7.4.8 Groundwater sampling for SVOCs and
pesticides/herbicides will be performed as part
of the Well Monitoring Program (see Table 9-2)
to evaluate the effectiveness of the selected
remedy. As stated in Section 9.1, concentrations
of COCs exceeding the following levels will be
evaluated in the Annual Well Monitoring
Reports.
SEC-9.DOC
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2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Analytes
Groundwater
Concentrations
Requiring
Evaluation (ug/L)
Bis(2-eihylhexyl) phthalate
Diethylphthalate
2,4-Dinitrotoluene
Naphthalene
Chlordane
2,4-D
ODD
DDE
DDT
Dieldrin
Lindane
Linuron
MCPA
Simazine
Total dioxins/furans
TPH as gasoline
TPH as diesel
TPH as motor oil
10*
5,600
10*
20
0.1*
70
0.15
0.1
0.1
0.05*
0.03
2*
380*
4
0.01*
50*
100
100
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where the
actual detection limit differs significantly from the
estimated detection limit because of matrix or other
effects will be flagged.
9.7.4.9 The selected alternative reduces the
toxicity and volume of all COCs in the soil at
the site and is therefore protective of human
health and the environment. The alternative also
removes the threat posed to groundwater by the
COCs in the soil. The present worth of this
alternative is $2,823,000. The basis for this cost
estimate is included in Table 9-12.
9.7.5 SWMU 20 - Aboveground Solvent
Tank/Building 26 Recoup
Operations and Area 1 Building 10
9.7.5.1 Alternative 3 (SVE, Excavation and
Disposal, Natural Attenuation) is the selected
remedy for SWMU 20 and Area 1 Building 10.
SWMU 20 was an aboveground solvent tank
located in Building 10. SWMU 20 also contains
a 4-foot-by-5-foot sump (at Manhole W-l)
located outside the northwestern comer of
Building 10 and a 2-foot-by-3-foot sump (at
Manhole W-3) located outside the northeastern
corner of Building 10. VOCs and SVOCs were
detected in sludges collected from the two
sumps, the floor drain, and soil samples
collected beneath these features. Area 1 of
Building 10 is also located near the northeast
comer of Building 10. Due to the proximity of
Area 1 Building 10 to SWMU 20 and the
similarity of the COCs at both locations, these
sites were evaluated together in the RI/FS. The
selected remedy also addresses potential VOCs
associated with the southern portion of the
IWPL in the immediate vicinity of SWMU 20
(between manholes W-l and W-3 and the area
between SB430 and SB432). The SVE portion
of the remedy will be coordinated with the
remedy for the Group A sites.
9.7.5.2 BRA results indicate that SWMU 20
and Area 1 Building 10 do not pose potential
risks to human health under either the current
depot worker or the future construction worker
exposure scenarios. In addition, there are no
ecological receptors at SWMU 20 and Area 1
Building 10. Thus, Alternative 3 is protective of
human health under current and future land use
conditions. Vadose modeling results show that
VOCs, SVOCs, TPHD, and pesticides/
herbicides could pose a threat to groundwater at
the site.
9.7.5.3 The recommended alternative includes
the excavation and disposal of the two sumps (at
manholes W-l and W-3) in the vicinity of
Building 10 and the floor drain at Building 26
(Figure 9-9). Confirmation samples will be
collected to ensure that cleanup standards are
achieved. The soil beneath the sumps and the
floor drain will also be excavated and disposed
of. The excavated soil will be transported to a
Class I or other off-site disposal facility. Clean
soil imported from off-site will be used to
backfill the excavated areas. Geotechnical
concerns should be considered when excavating
soils adjacent to Building 10. In addition, this
alternative may disrupt underground utilities.
9.7.5.4 A thorough evaluation of ARARs is
provided in Section 10.9.2. Cleanup standards
for SWMU 20 were developed using vadose
zone modeling (Montgomery Watson, 1996a),
which identified potential threats to background
groundwater quality at this site. The cleanup
standards developed to protect background
groundwater quality are consistent with Water
Quality Goals (CVRWQCB, 1993) and the
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
SWRCB Tri-Regional Guidelines. The proposed
soil cleanup standards are:
SWMU 20 Cleanup
Analytes Standards (ug/kg)
Trichloroeihene
Ethylbenzene
Xylenes
Oiethylphihalate
2,4-Dinitrophcnol
Pentachlorophenol
2,4,6-trichlorophenol
Dieldrin
Methiocarb
Linuron
MCPA
TPH as diesel
5
5
5
330
830
830
330
2
500
200
5.000
10.000
9.7.5.5 The soil cleanup standard forTPHD
was developed using the Tri-Regional
Guidelines. The equilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for
summary) provided very conservative estimates
of the soil concentrations required to protect
background groundwater quality. These limits
correspond to the maximum concentration
expected in soil water and do not account for an
expected decrease in concentration resulting
from migration through less contaminated or
clean soils to groundwater (Figures B-17 and
B-18). Monuron, diuron, alpha-BHC,
methiocarb, and 2,4-D have also impacted
groundwater quality. These pesticides/herbicides
were detected in sludges, but were not
encountered at depth (Figure B-18). Significant
dilution is therefore anticipated. Because of
these factors, it was considered appropriate to
use a laboratory reporting limit corresponding to
the lowest concentration that can be
reproducibly detected as verified by the use of a
low-level standard (Appendix F). This analysis
modifies the cleanup standards presented in the
RI/FS (Montgomery Watson, 1996a).
9.7.5.6 Groundwater sampling for VOCs,
SVOCs, and pesticides/herbicides will be
performed as part of the Well Monitoring
Program (see Table 9-2) to evaluate the
effectiveness of the selected remedy. As stated
in Section 9.1, concentrations of COCs
exceeding the following levels will be evaluated
in the Annual Well Monitoring Reports.
9.7.5.7 SVE will be performed to remediate the
TCE-contaminated soil detected at Area 1
Building 10 (near SB 108) and near SB431. SVE
is expected to be effective in reducing TCE
concentrations at these locations. Predesign soil-
gas sampling will be conducted at the areas
designated for SVE remediation at SWMU 20,
the adjacent portion of the IWPL, and Area 1
Building 10. The investigation will be expanded
from the identified areas as needed to define the
lateral and vertical extent of contamination
above the specified soil-gas cleanup standard.
Additional SVE wells will be added as needed to
address soil-gas concentrations in excess of the
soil-gas cleanup standard.
9.7.5.8 The cleanup standard for TCE in soil
gas is:
Analyte
Trichloroethene
SWMU 20
Soil Gas Cleanup
Standard (ug/L)
1.9(350ppbv)
9.7.5.9 This concentration will also be used to
determine if it is necessary to evaluate further
action to address the TCE associated with the
IWPL between manholes W-l and W-3 and
between SB430 and SB432 (this area will be
expanded as required to attain the soil-gas
cleanup standard). The SVE systems will
address VOC concentrations above the cleanup
standards.
9.7.5.10 The vadose zone cleanup will be
achieved when:
1. The concentrations of TCE present in
soil gas are equal to or less than the
cleanup standard;
2. It is demonstrated that the remaining
TCE can no longer cause leachate
concentrations to exceed the aquifer
cleanup standards; and
3. TCE has been removed to the extent
technically and economically feasible.
This evaluation will include, at a
minimum, the following factors:
a) The total cost and duration of
continued operation of the SVE
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
system until aquifer cleanup
standard are met.
b) The total cost and duration of
continued groundwater treatment to
meet aquifer cleanup standards.
c) The incremental cost (cost benefit)
of continued operation of the SVE
system on the basis of a cost per
pound of contaminant removal if the
underlying groundwater has not
attained aquifer cleanup standards.
9.7.5.11 The signatory parties to the ROD will
jointly decide when the cleanup of VOCs in the
vadose zone has been achieved and when the
SVE system be shut off permanently. The
evaluation of technical and economic feasibility
that will serve as the basis for this decision will
be a primary document.
9.7.5.12 The signatory parties to the FFA agree
that DDJC-Tracy may cycle the SVE system on
and off to optimize the SVE operation and/or
evaluate all feasibility analysis factors.
9.7.5.13 Phenols detected in the soil
(SB432/432b) are anticipated to attenuate as
they migrate to groundwater. The maximum
concentration of phenols measured in the RI/FS
(Montgomery Watson, 1996a) is less than five
times the equilibrium partitioning limit. This
limit does not account for any dilution of the soil
water as a result of migration through less
contaminated or clean soil. To date, phenols
have not been detected in groundwater, although
they are very mobile in sandy soils. They are
known to form extremely stable complexes with
clay particles, and these complexes could retard
their mobility.
9.7.5.14 This alternative reduces the toxicity
and volume of all COCs in the soil at the site.
The threat of COC migration to groundwater
will be removed immediately on completion of
the excavation. The present worth of this
alternative is $293,000. The basis for this cost
estimate is included in Table 9-13.
Analytes
Groundwater
Concentrations
Requiring Evaluation
(ug/L)
Ethylbenzene
Xylenes
Trichloroclhene
Tetrachloroethene
Dieihylphthalate
2,4-Dinitrophenol
Pentachlorophenol
2,4,6-Trichlorophenol
Dieldrin
Methiocarb
MCPA
Linuron
TPH as diesel
29
17
2.3
2*
5,600
50*
50*
10*
0.05*
5
380*
2*
100
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where the
actual detection limit differs significantly from the
estimated detection limit because of matrix or other
effects will be flagged.
9.7.6 SWMU 24 - Petroleum Waste Oil
Tank
9.7.6.1 The selected remedy for SWMU 24 is
Alternative 3 (Bioventing). SWMU 24 was a
500-gallon Underground Storage Tank (UST)
that was used to store petroleum wastes from
materials testing in Building 247 from 1961 to
1988. The UST was removed in 1988, and
visibly contaminated soil from the excavation
was disposed of off-site. During the Phase I and
n investigations, xylenes, 2-butanone, MEBK,
petroleum hydrocarbons, and other organic
compounds were detected in soils in the vicinity
of the tank excavation.
9.7.6.2 BRA results indicate that there is a
potential health threat to future depot workers
exposed to toluene at SWMU 24. The hazard
index associated with indoor air is presently
estimated at 0.7; however, if a building with
poor ventilation were constructed over the
contamination, the hazard index could
potentially exceed 1.0. Bioventing will reduce
toluene levels in soil and therefore is protective
of human health under current and future land
use conditions. Vadose zone modeling results
for SWMU 24 show that VOCs, SVOCs,
petroleum hydrocarbons, PCBs, and pesticides
pose a threat to background water quality. Also,
TPHG and TPHD levels in the soil are above the
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
SWRCB Tri-Regional Guidelines of 1 mg/kg
and 10 mg/kg, respectively, for TPH within five
feet of groundwater.
9.7.6.3 A thorough evaluation of ARARs is
provided in Section 10.10.2. Cleanup standards
for SWMU 24 were developed using vadose
zone modeling (Montgomery Watson, 1996a),
which identified potential threats to background
groundwater quality at this site. The cleanup
standards developed to protect background
groundwater quality are consistent with Water
Quality Goals (CVRWQCB, 1993) and the
SWRCB Tri-Regional Guidelines. The cleanup
standards are:
SWMU 24 Cleanup
Analytes Standards (pg/kg)
Acetone
2-butanone
Ethylbenzene
2-hexanone
4-methyl-2-pentanone
Toluene
Xylenes
2,4-dimethylphenol
Fluoranthene
2-methyInaphthalene
4-methylphenol
Naphthalene
Phenanthrene
Phenol
Pyrene
Carbofuran
Lindane
Phorate
Ronnel
Aroclor 1260
TPH as gasoline
TPH as diesel
10
10
10
10
10
5
5
330
330
330
330
330
330
330
330
500
1.7
20
35
30
1,000
10.000
9.7.6.4 Soil cleanup standards for TPHG and
TPHD were developed using the scoring criteria
of the Tri-RegionaJ guidance. The equilibrium
partitioning limits developed in the RI/FS (see
Table 6-9 for summary) provided very
conservative estimates of the soil concentrations
required to protect background groundwater
quality. These limits correspond to the
maximum concentrations expected in soil water
and do not account for an expected decrease in
concentrations resulting from migration through
less contaminated or clean soils to groundwater
(Figure B-19). Soil sampling data indicate that
the concentrations and numbers of analytes
detected generally decrease with increasing
sampling depth. Significant dilution is therefore
anticipated. Because of these factors, it was
considered appropriate to use a laboratory
reporting limit corresponding to the lowest
concentration that can be reproducibly detected
as verified by the use of a low-level standard
(Appendix F) as a basis for all other cleanup
standards. This analysis modifies the cleanup
standards presented in the RI/FS (Montgomery
Watson, 1996a).
9.7.6.5 Bioventing (Figure 9-10) is expected to
biodegrade the COCs that pose the greatest
threat to groundwater. Therefore, the
recommended alternative reduces the potential
for migration of soil constituents to the
groundwater and is protective of beneficial uses.
PCBs and pesticides are not fully remediated
during bioventing treatment because these
compounds are not amenable to aerobic
biodegradation. However, the threat to
groundwater posed by PCBs and pesticides is
considered low relative to the threat posed by
the other COCs. Pesticide detections were
infrequent, and none of the pesticides or PCBs
detected in soil has been detected in
groundwater near the site. PCBs were only
detected in one boring (SB-192), and the
concentrations of both PCBs and pesticides
decreased with depth. Removing these
compounds through excavation beside and under
Building 247 would be expensive
(approximately $263,000), and the threat to
groundwater is questionable at this site.
Therefore, groundwater monitoring for PCBs
and pesticides is considered adequate to address
the remaining threat to groundwater.
Groundwater will be monitored as long as
contaminants remain in place or until it can be
demonstrated that no further threat to
groundwater exists.
9.7.6.6 The extent of soil contamination is very
limited at SWMU 24; thus, only a bioventing
system consisting of one air injection well is
necessary. The conceptual site layout for the
bioventing system is shown in Figure 9-9. The
selected alternative includes installing one air
injection well and a pad-mounted blower system
at SWMU 24. The well would be screened from
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
6 feet bgs to 16 feet bgs. An air injection rate of
0.5 pore volumes per day (Dupont, 1993) was
assumed for the conceptual design. With this air
injection rate, the total operating flow rate for
the bioventing system will be approximately 4
standard cubic feet per minute (scfm). The
bioventing system will be operated until the
cleanup standards provided above have been
achieved. Predesign soil-gas sampling will be
conducted; pending the results of the soil-gas
sampling, bioventing may be preceded by SVE
(if VOCs resistant to biodegradation are
measured). The immediate implementation of
SVE will be evaluated before bioventing if the
following cleanup standards are exceeded.
Analytes
SWMU 24 Soil
Gas Action
Levels (ug/L)
Tetrachloroethene
Trichloroethene
5.4 (780 ppbv)
1.9(350ppbv)
9.7.6.7 Groundwater sampling for VOCs,
SVOCs, and pesticides/herbicides will be
performed as part of the Well Monitoring
Program (see Table 9-2) to evaluate the
effectiveness of the selected remedy. As stated
in Section 9.1, concentrations of COCs
exceeding the following levels will be evaluated
in the Annual Well Monitoring Reports.
9.7.6.8 The selected remedy for SWMU 24
also includes the quarterly monitoring of well
LM118A for TPHG and TPHD for at least three
quarters (Table 9-2). The purpose of this
monitoring is to assess the natural attenuation of
petroleum hydrocarbons in the groundwater.
Analytes
Groundwater
Concentrations
Requiring Evaluation
(ug/U
Acetone
2-Butanone
Elhylbenzene
2-Hexanone
4-Methyl-2-Pentanone
Toluene
Xylenes
Trichloroethene
Tetrachloroethene
TPH as gasoline
TPH as diesel
Fluoranthene
2-Meihy 1 naphthalene
4-Methylphenol
2,4-Dimethylphenol
Naphthalene
Phenol
Pyrene
PCBs(Arochlorl260)
Carbofuran
Lindane
Phorate
Ronnel
700
4,200
29
10
40
42
17
2.3
2*
50*
100
280
10
10
140
20
4,200
210
0.5
18
0.03
0.5
0.5
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where the
actual detection limit differs significantly from the
estimated detection limit because of matrix or other
effects will be flagged.
9.7.6.9 The selected remedy reduces the
toxicity, mobility, and volume of COCs in the
soil at the site. This remedy is protective of
human health and the environment. The threat
posed by the migration of VOCs, SVOCs, and
petroleum hydrocarbons to groundwater will be
removed through the biodegradation of these
constituents. The present worth of this
alternative is $166,000. The basis for this cost
estimate is included in Table 9-14.
9.7.7 SWMU 27 • Building 206
Roundhouse Sump and Area 1
Building 206
9.7.7.1 Alternative 3 (Excavation and
Disposal) is the selected remedy for SWMU 27
and Area 1 Building 206. SVOCs, herbicides,
PCBs, petroleum hydrocarbons, and metals have
been released to soils as a result of activities
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DDJC-Tracy Sile-Widc Comprehensive Record of Decision
associated with SWMU 27. The distribution of
these constituents is primarily confined to the
area within Building 206, mainly around the
former service pit, the former waste oil sump,
and the former floor drain located within
Building 206. Building 206, which is part of
SWMU 27, is no longer in use and was
demolished in April 1995. The floor slab
remains and the locomotive pit, service pit, and
sump were filled with concrete.
9.7.7.2 BRA results indicate that there is a
potential cancer risk greater than IxlO"6 under
the depot and construction worker exposure
scenarios. The potential cancer risk is based on
exposure to PAHs and PCBs. The selected
remedy would reduce these risks to 1x10 ~* by
excavating contaminated soils to the specified
cleanup standards for total PAHs and Arochlor
1260. No ecological receptors were identified at
SWMU 27. TCE, 2,4-D, MCPA, 2,4,5-T, and
TPH-MO are potential threats to groundwater
quality.
9.7.7.3 A thorough evaluation of ARARs is
provided in Section 10.10.2. Cleanup standards
for SWMU 27 were developed using risk-based
concentrations and vadose zone modeling
(Montgomery Watson, 1996a), which identified
potential threats to background groundwater
quality at this site. The cleanup standards
developed to protect background groundwater
quality are consistent with Water Quality Goals
(CVRWQCB, 1993) and the Tri-Regional
Guidelines. The cleanup standards are:
Analytes
Benzo[a]pyrene
Total PAHs
Arochlor 1260
TCE
2,4-D
MCPA
2,4,5-T
TPH as motor oil
SWMU 27 Cleanup
Standards (ug/kg)
1,000
15,000
1,000
5
25
5,000
5
10,000
9.7.7.4 The basis for the soil cleanup standards
for benzo(a)pyrene, total PAHs, and Arochlor
1260 is the Risk Based Concentration (RBC)
where the cancer endpoint is IxlO"6. The cleanup
standard for TPH-MO was determined from the
Tri-Regional Guidelines. Cleanup standards for
other COCs are based on laboratory reporting
limits. The equilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for
summary) provided very conservative estimates
of the soil concentrations required to protect
background groundwater quality. These limits
correspond to the maximum concentrations
expected in soil water and do not account for an
expected decrease in concentrations resulting
from migration through less contaminated or
clean soils to groundwater (Figures B-20 and
B-21). Soil sampling data indicate that the
concentrations and numbers of analytes detected
generally decrease with increasing sampling
depth (none of the COCs was detected at a depth
of greater than 10 feet). Significant dilution is
therefore anticipated. Because of these factors, it
was considered appropriate to use laboratory
reporting limits corresponding to the lowest
concentrations that can be reproducibly detected
as verified by the use of low-level standards
(Appendix F) as a basis for all other cleanup
standards. This analysis modifies the cleanup
standards presented in the RI/FS (Montgomery
Watson, 1996a).
9.7.7.5 The recommended alternative
(Figure 9-11) involves excavating the former
waste oil sump, which is presently filled with
sand and capped with concrete; excavating soil
contaminated with PAHs, PCBs, petroleum
hydrocarbons, and herbicides (2,4-D, MCPA,
and 2,4,5-T) from beneath the railroad tracks
(between SB471 and SB470); and excavating
soil contaminated with MCPA (a herbicide) at
SB469 (the area of a suspected herbicide spill).
Soils will be excavated to 16 feet bgs around the
former waste oil sump and to 5 feet bgs in the
vicinity of SB469, SB470, and SB471. A total of
approximately 130 cy (170 tons) of soil and
concrete will be excavated and transported to an
off-depot disposal facility. The level of soil
contamination at SWMU 27 indicates that the
excavated material will be disposed of at a
Class I or other disposal facility. Confirmation
samples will be collected to ensure that the
cleanup standards are attained. Clean soil,
imported from off-depot, will be backfilled to
replace the excavated material. The former
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
service pit is not recommended for excavation
and disposal because contaminated sludge was
previously removed from the pit, and the pit was
filled with concrete.
9.7.7.6 Groundwater sampling for VOCs,
SVOCs, and herbicides will be performed as
part of the Well Monitoring Program (see
Table 9-2) to evaluate the effectiveness of the
selected remedy. Compounds with risk-based
cleanup standards to protect human health do not
threaten ground water quality and are not
included in the monitoring program. As stated in
Section 9.1, concentrations of COCs exceeding
the following levels will be evaluated in the
Annual Well Monitoring Reports.
Groundwater
Concentrations Requiring
Evaluation
Analytes (ug/l.)
Trichloroethene
2,4-D
MCPA
2,4,5-T
TPH motor oil
2.3
70
380*
70
100
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where
the actual detection limit differs significantly from
the estimated detection limit because of matrix or
other effects will be flagged.
9.7.7.7 This alternative reduces the toxicity and
volume of all COCs in the soil at the site. This
alternative is protective of human health and the
environment. The threat of COC migration to
groundwater will be removed by excavation.
The present worth of this alternative is
$112,000. The basis for this cost estimate is
included in Table 9-15.
9.7.8 Drum Storage Area - Building 30
9.7.8.1 Alternative 3, institutional controls, is
the selected remedy for the Drum Storage Area
Building 30. The Drum Storage Area Building
30 is located in the southern portion of the
depot, near the Consolidated Subsistence
Facility. The original area of the site was much
larger, but is now partially covered by the
Consolidated Subsistence Facility, which was
constructed in 1992. During construction of the
facility, buried drums were discovered in the
vicinity of the Drum Storage Area Building 30.
The site now encompasses a relatively small
area between a forklift ramp and the central
office on the north side of the Consolidated
Subsistence Facility. Bis(2-ethylhexyl)phthalate,
and di-n-butylphthalate were detected several
times in soil samples collected at the site. Benzyl
alcohol and diethylphthalate were detected in
only one sample. Although phthalates are
commonly introduced into environmental
samples as part of laboratory analytical
procedures, the distribution and magnitude of
the concentrations indicate that these detected
concentrations may be representative of site
conditions.
9.7.8.2 A thorough evaluation of ARARs is
provided in Section 10.12.2. Cleanup standards
were developed from vadose zone modeling
(Montgomery Watson, 1996a) of potential
threats to background groundwater quality at
this site. Groundwater data were not available
for use as a basis for selecting the remedy. The
cleanup standards developed to protect
background groundwater quality are consistent
with Water Quality Goals (CVRWQCB, 1993).
The proposed soil cleanup standards are:
Analytes
Building 30
Cleanup
Standards
(ug/kg)
Benzyl Alcohol
Bis(2-ethyihexyl) phthalate
Diethylphthalate
di-n-Butylphthalatc
330
330
330
330
9.7.8.3 All cleanup standards correspond to the
laboratory reporting limit (Radian, 1997). The
equilibrium partitioning limits developed in the
RI/FS (see Table 6-9 for summary) provided
very conservative estimates of the soil
concentrations required to protect background
groundwater quality. These limits correspond to
the maximum concentration expected in soil
water and do not account for an expected
decrease in concentrations resulting from
migration through less contaminated or clean
soils to groundwater (Figure B-23). Benzyl
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alcohol and diethylphthalate were only detected
in one sample. Because of these factors, it was
considered appropriate to use laboratory
reporting limits corresponding to the lowest
concentrations that can be reproducibly detected
as verified by the use of low-level standards
(Appendix F) as a basis for all other cleanup
standards. This analysis modifies the cleanup
standards presented in the RI/FS (Montgomery
Watson, 1996a).
9.7.8.4 The selected remedy includes the
installation of one monitoring well downgradient
of the site. This well will be monitored for
SVOCs to confirm that benzyl alcohol,
bis(2-ethylhexyl)phthalate, diethylphthalate, and
di-n-butylphthalate do not pose a threat to
background groundwater quality. Four rounds of
monitoring for pesticides was agreed upon as a
substitute for extending the remedial
investigation. The selected remedy will be
reevaluated if groundwater concentrations
exceed the concentrations of VOCs or SVOCs
indicated below or if increasing concentration
trends are observed, as discussed in Section 9.1.
Four rounds of groundwater sampling for
pesticides/herbicides will be performed (see
Table 9-2).
Groundwater
Concentrations
Requiring Evaluation
Analytes (ug/L)
Benzyl Alcohol
Bis(2-ethylhexyl)phthalate
Diethylphthalate
Di-n-butyl phthalate
Trichloroethene
Tetrachloroethene
10
10*
5,600
700
2.3
2*
* For these compounds, results above the estimated detection
limit (see Table 9-7) will be reported as trace amounts and
will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit
because of matrix or other effects will be flagged.
9.7.8.5 Five-year site policy reviews are
included in the selected remedy. The reviews are
required because contaminants will be left in
place.
9.7.8.6 This alternative does not actively
reduce the toxic ity, mobility, or volume of the
COCs in the soil. The selected remedy is
protective of human health and the environment.
The present worth of this alternative is $87,000.
The basis for this cost estimate is included in
Table 9-16.
9.7.9 Surface and Near-Surface Soil -
Northern Depot Area
9.7.9.1 Alternative 3, an asphalt cover, is the
selected remedy for the surface and near-surface
soils in the Northern Depot Area. Several
nonvegetated areas of bare soil are present on
the depot. These areas are located at the southern
end, the northern end, and near the northwestern
comer of the depot. These areas are periodically
graded to bare dirt.
9.7.9.2 The results of surface and near-surface
soil sampling in the Northern Depot Area
indicate that arsenic and manganese are present
at levels that pose potential noncarcinogenic
risks to grader operators and construction
workers. The elevated arsenic and manganese
levels are related to ore stockpiles previously
located in the Northern Depot Area. The
selected remedy consists of installing an asphalt
cover over the soils that have elevated levels of
arsenic and manganese (approximately
138,000 square feet of soil). The cover will
provide a barrier to prevent grader operators or
construction workers from coming in contact
with surface soils containing elevated levels of
arsenic and manganese. The depot requires the
use of this area as an active storage area.
Therefore, institutional controls were not
considered an acceptable remedy for this site.
9.7.9.3 A thorough evaluation of ARARs is
provided in Section 10.13.2. Cleanup standards
correspond to risk-based concentrations that
would reduce the hazard index to 1.0. These
standards will be used as a benchmark to
reassess the need for continued controls in the
first five-year site review. The proposed soil
cleanup standards are:
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Analytes
Northern Depot Area
Cleanup Standards
(ug/kg)
Arsenic
Manganese
48
1.000
9.7.9.4 The asphalt cover will be maintained
for as long as soil concentrations exceed the
established cleanup standard. The selected
remedy will have to be reevaluated before
initiating any construction that would impact the
asphalt cap.
9.7.9.5 Five-year site reviews are included in
the selected remedy. The reviews are required
for both statutory and policy reasons. The
containment provided by the asphalt cap must be
periodically reviewed and wastes will be left in
place for more than five years.
9.7.9.6 This alternative does not reduce the
toxicity or volume of arsenic or manganese, but
it reduces their mobility in the surface and near-
surface soils. The selected remedy is protective
of human health and the environment because
direct contact with soils containing elevated
arsenic and manganese levels is significantly
reduced by covering the soil with asphalt. The
present worth of this alternative is $504,000.
The basis for this cost estimate is included in
Table 9-17.
9.8 Group C Sites
9.8.1 SWMUs 2 and 3 - Sewage and
Industrial Waste Lagoons
9.8.1.1 Alternative 3 (Excavation and
Disposal) is the selected remedy for SWMUs 2
and 3. SWMU 2 (Sewage Lagoons) and
SWMU 3 (Industrial Lagoons) are located in the
northern part of the depot, west of and adjacent
to the Sewage Treatment Plant. The industrial
lagoons are lined and are no longer in use. The
DDJC-Tracy wastewater treatment plant
discharges treated water to the sewage lagoons.
In January 1996, an EE/CA was prepared to
evaluate alternatives and select a
non-time-critical removal action for SWMUs 2
and 3 (Radian, 1996a). The recommended
removal action is the selected remedy for
SWMUs 2 and 3.
9.8.1.2 A thorough evaluation of ARARs is
provided in Section 10.13.2. Cleanup standards
were developed from vadose zone modeling
(Montgomery Watson, 1996a), which identified
potential threats to background groundwater
quality at this site. The cleanup standards were
developed to protect human health and
ecological receptors. The cleanup standard to
protect background groundwater quality are
consistent with Water Quality Goals
(CVRWQCB, 1993). The proposed cleanup
standards are:
SWMUs 2 and 3
Cleanup
Analytes Standards (ug/kg)
Selenium 616"
Lead 28,300b
Dieldrin 370
ODD 1,600
DDE 1,800
DDT 1,700
Total DDX 24 lb
Aldrin 3
Chlordane 10
Diuron 260
Endrin 3
Lindane (Gamma-BHC) 1.7
Monuron 260
2,4-D 47
Heptachlor epoxide 1.5
2,4-Dimethylphenol 330
4-Methy!phenol 330
Bis(2-ethylhexyl)phthalate' 330
di-n-butylphthalate* 330
1 SWMU 2 only.
b Preliminary standard.
9.8.1.3 The cleanup standards for total DDX,
lead, and selenium are risk-based standards to
protect ecological receptors (see Section 6.6.5).
These standards are considered preliminary
because they were estimated using literature
values rather than site-specific bioaccumulation
factors. Additional data will be collected to
obtain site-specific bioaccumulation factors, and
the cleanup standards and extent of excavation
will be revised accordingly through an
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DDJC-Tracy Sile-Wide Comprehensive Record of Decision
explanation of significant differences to this
ROD.
9.8.1.4 The cleanup standards for ODD, DDE,
DDT, dieldrin, and 2,4-D were revised on the
basis of DI-WET results obtained during the
excavation of SWMUs 2 and 3. These results
demonstrated that these pesticides would
attenuate in the vadose zone at higher
concentrations than were estimated in the RI/FS
(Montgomery Watson, 1996a). All other cleanup
standards are consistent with laboratory reporting
limits. The equilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for
summary) provided very conservative estimates
of the soil concentrations required to protect
background ground water quality. These limits
correspond to the maximum concentrations
expected in soil water and do not account for an
expected decrease in concentration resulting
from migration through less contaminated or
clean soils to groundwater (Figures B-24
through B-27). The numbers and concentrations
of analytes in soil generally decreases with
increasing depth. Because of these factors, it was
considered appropriate to use laboratory
reporting limits corresponding to the lowest
concentration that can be reproducibly detected
as verified by the use of low-level standards
(Appendix F) as a basis for all other cleanup
standards. This analysis modifies the cleanup
standards presented in the RI/FS (Montgomery
Watson, 1996a).
9.8.1.5 The existing industrial waste lagoon
liners and partitions are presently being
excavated (Figure 9-12). The entire footprint of
the lagoons has been excavated to a depth of
1 foot. Pockets of additional pesticide
contamination will be excavated until cleanup
standards are attained. Confirmation sampling
will be performed to ensure that the cleanup
standards are met. The total volume of material
to be excavated will be approximately 10,000 cy
(15,000 tons). The nonhazardous excavated soil
will be stockpiled and transported to a Class I or
other disposal facility in compliance with state
and federal laws and regulations. The initial
excavation activities attempted to provide clean
closure. The cleanup standards were modified to
protect water quality and are expected to achieve
clean closure. Clean closure is expected to be
verified through groundwater monitoring.
9.8.1.6 Groundwater sampling for SVOCs and
pesticides/herbicides will be performed as part
of the Well Monitoring Program (see Table 9-2)
to evaluate the effectiveness of the selected
remedy. Lead and selenium do not threaten
groundwater quality and are not included in the
monitoring program. As stated in Section 9.1,
concentrations of COCs exceeding the following
levels will be evaluated in the Annual Well
Monitoring Reports.
Groundwater
Concentrations
Requiring
Analytes Evaluation (ug/L)
Bis(2-ethylhexyl)phthalate
2,4-Dimethylphenol
Di-n-butylphthalate
4-Methylphenol
Aldrin
Chlordane
ODD
DDE
DDT
Dieldrin
Endrin
Lindane (Gamma-BHC)
Diuron
Monuron
2,4-D
Heptachlor epoxide
10*
140
700
10
0.05*
0.1*
0.15
0.1
0.1
0.05*
2
0.03
14
1.0
70
0.01*
For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where the
actual detection limit differs significantly from the
estimated detection limit because of matrix or other
effects will be flagged.
9.8.1.7 Contaminants will be permanently
removed from the site through excavation. The
selected remedy is protective of human health at
the site under current and future land use
conditions. The present worth of this alternative
is approximately $2,200,000. The basis of the
cost estimate is included in Table 9-18.
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9.8.2 SWMU 33 - Industrial Waste
Pipeline (IWPL)
9.8.2.1 Alternative 3 (Grouting, Limited
Excavation, and Institutional Controls) is the
preferred alternative for SWMU 33. In 1 972, an
existing pipeline and a storm drain line were
interconnected to form the IWPL at SWMU 33.
The IWPL is constructed of 4-inch to 7-inch
diameter pipe of varying composition (transite,
vitrified clay, polyvinyl chloride) and is buried
to a depth of approximately two to four feet
below grade. Eight manholes are located along
the pipeline. The pipeline consists of two major
segments referred to as the south industrial
waste pipeline (SIWPL) and the east industrial
waste pipeline (EIWPL). The total length of the
SIWPL and its branches is approximately 1,200
lineal feet. The total length of the EIWPL and its
branches is also approximately 1,200 lineal feet.
Use of the IWPL has been discontinued.
9.8.2.2 A thorough evaluation of ARARs is
provided in Section 10.14.2. Cleanup standards
were developed from vadose zone modeling
(Montgomery Watson, 1996a), which identified
potential threats to background groundwater
quality at this site. The cleanup standards
developed are consistent with Water Quality
Goals (CVRWQCB, 1993) and the Tri-Regional
Guidelines. The proposed cleanup standards are:
Analytes
SWMU 33
Cleanup
Standards
Xylenes
Diethylphthalate
Di-n-butylphthalate
Naphthalene
Aldrin
Carbaryl
Dieldrin
Meihiocarb
TPH as diesel
5
330
330
330
1.7
400
2
500
100,000
9.8.2.3 The soil cleanup standard for TPHD
was developed using the Tri-Regional
Guidelines. The equilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for
summary) provided very conservative estimates
of the soil concentrations required to protect
background groundwater quality. These limits
correspond to the maximum concentration
expected in soil water and do not account for an
expected decrease in concentration resulting
from migration through less contaminated or
clean soils to groundwater (Figure B-29).
Excavation will be performed at SB461, SB204,
and SB462. At other locations the concentrations
of COCs in soil decrease with increasing depth.
Because of these factors, it was considered
appropriate to use a laboratory reporting limit
corresponding to the lowest concentration that
can be reproducibly detected as verified by the
use of a low-level standard (Appendix F) as a
basis for all other cleanup standards. This
analysis modifies the cleanup standards
presented in the RI/FS (Montgomery Watson,
1996a).
9.8.2.4 An engineering evaluation/cost analysis
(EE/CA) (Radian, 1996) has been prepared to
expedite the action for SWMU 33 (Radian,
1996). According to the EE/CA, the
recommended removal action alternative for
SWMU 33 involves pressure grouting the
laterals and sumps in the IWPL and excavating
the most contaminated soils (approximately
10 cy). It should be noted that the sumps at
manholes W-l and W-3 are interpreted as being
part of SWMUs 20. As discussed in
Section 9.5.5, excavation and disposal are
recommended for the sumps and surrounding
soils at manholes W-l and W-3. In addition,
SVE is recommended for VOC contamination at
SB 108 (Area 1 Building 10) and SB431
(SWMUs 20/23).
9.8.2.5 These excavations will not address all
areas of the IWPL where contaminants are
present above cleanup standards. Aldrin,
dieldrin, diethylphthalate, and di-n-
butylphthalate will be present above the cleanup
standards and pose a potential threat to
background groundwater quality. However, the
contaminants are generally below buildings or
other paved areas, so the threat of migration to
groundwater is considered low. Therefore, the
selected remedy supplements the grouting and
excavation with groundwater monitoring and
institutional controls. Groundwater sampling for
VOCs, SVOCs, and pesticides/herbicides will be
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
performed as part of the Well Monitoring
Program (see Table 9-2). As stated in
Section 9.1, concentrations of COCs exceeding
the following concentrations will be evaluated in
the Annual Well Monitoring Reports.
Groundwater
Concentrations
Requiring Evaluation
Analytes (M9/L)
Xylenes
Diethylphthalate
Di-n-butylphthalate
Naphthalene
TPH as diesel
Aldrin
Carbaryl
Dieldrin
Melhiocarb
17
5,600
700
20
100
0.05*
60
0.05*
5
* For these compounds, results above the estimated
detection limit (see Table 9-7) will be reported as
trace amounts and will be evaluated. Cases where
the actual detection limit differs significantly from
the estimated detection limit because of matrix or
other effects will be flagged.
9.8.2.6 The selected remedy also includes land
use restrictions around the IWPL. Buildings and
pavement greatly reduce the effects of
percolation along the pipeline. Any construction,
excavation, or demolition along the IWPL will
require an evaluation of potential impacts to the
selected remedy. This evaluation will be
provided to the signatory parties of the ROD for
approval before construction activities. Land use
restrictions are currently documented at DDJC-
Tracy in a Master Plan. In this Master Plan,
SWMU 33 is presently designated for industrial
use only. This restriction is required as part of
the selected remedy. If ownership of the
installation is transferred to private or nonfederal
entities in the future, restrictive covenants will
be written into the land property deed to prevent
schools, playgrounds, hospitals, and housing
from being built at the site until COCs are below
levels of concern. Cooperation among the U.S.
Army, San Joaquin County, and Cal-EPA will
be required to enact the access and land use
restrictions.
9.8.2.7 Five-year site reviews are included in
the selected remedy as specified in the CERCLA
guidance. Statutory and policy reviews are
required because wastes will be left in place and
the use of the site will be limited by institutional
controls. Site reviews may include literature
searches, site walks, interviews, and minimal
sampling. Groundwater sampling at these sites
will be conducted as part of the Well Monitoring
Program.
9.8.2.8 Some of the contaminants will be
permanently removed from the site through
excavation. The grouting of the pipe will further
reduce the mobility of the contaminants by
preventing water from entering or leaking from
cracks in the IWPL. The selected remedy is
protective of human health and the environment.
The present worth of this alternative is
$242,600. The basis of this cost estimate is
included in Table 9-19.
9.9 Five-Year Review Process
9.9.1 Every five years, the success of the
selected remedies will be evaluated using the
most current knowledge and site information.
The five-year reviews provide an opportunity to
reexamine past decisions. Statutory reviews are
required for sites that will not allow for
unlimited use and unrestricted exposure on
attainment of ROD cleanup levels. Policy
reviews are required for sites that require more
than five years to attain ROD cleanup levels.
Policy reviews must be completed within five
years of the initiation of the remedial action. The
five-year reviews will evaluate the performance
of the selected remedy and be continued for as
long as cleanup standards are exceeded or soil
contaminants remain in place. DDJC-Tracy will
document the review as a secondary document.
As specified in the FFA, any party to the
agreement may submit a written proposal for
additional work or modification of the selected
remedy.
9.9.2 The results of the DDJC-Tracy Well
Monitoring Program will provide key
information for evaluating the sites in the review
process. Groundwater monitoring will be
conducted in accordance with Title 27 of the
California Code of Regulations. Specifically,
Section 20430 requires monitoring to determine
the effectiveness of corrective actions.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Sections 20410. 20950, 22207(a), 22212(a), and
22222 identify monitoring requirements for the
closure, post-closure, and compliance periods.
Pursuant to Title 27, Section 20410(c),
monitoring is required for three consecutive
years following the date that ROD cleanup
standards are achieved. Pursuant to Title 27,
Section 20950(a), the post-closure maintenance
period lasts as long as water quality is threatened
by the COCs.
9.10 Post-ROD Documents
9.10.1 DDJC-Tracy will submit a schedule for
all post-ROD primary documents within 30
calendar days of the issuance of the Site-Wide
Comprehensive Record of Decision. The
following post-ROD documents will be
submitted as primary documents:
• Remedial Design Work Plan (to include
sampling and analysis plan);
• Remedial Design (to include institutional
controls);
• Remedial Action Work Plan (to include
sampling and analysis plan);
• Construction Quality Assurance Plan;
• Construction Quality Control Plan;
• Construction Completion Report; and
• Project Closure Plan.
9.10.2 Separate design packages are planned
for the SVE sites (Group A sites and SWMU 20)
and the remaining soil sites. For each of these
sites, the Construction Quality Assurance and
Construction Quality Control Plans will be
combined into a single document. All documents
except for the Project Closure Plan will be
modified primary documents that have a 30-day
review period.
9.10.3 Technical and economic evaluations of
the SVE sites will be prepared before treatment
is discontinued. These evaluations will be
primary documents.
SEC-9.DOC 9-28 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-1. Selected Remedies
SWMU
Number/Site
Description
Comments
OU1 Groundwater
SWMU I/Area 2
SWMUs 2/3
SWMU 4
SWMUS
SWMU 6
SWMU 7
SWMU 8
SWMU 9
SWMU 10
SWMU 10A
SWMU 11
SWMU 12
SWMU 14
SWMU 15
SWMU 16
SWMU 20
SWMU 21
SWMU 22
Extraction, Treatment (Air Stripping, Carbon),
Injection
Soil Vapor Extraction
Excavation with Off-Site Disposal
Excavation and Off-Site Disposal of
Sediments
No Further Action
Excavation with Off-Site Disposal
Institutional Controls (modify property records
of Buildings 19 and 21, two additional
monitoring wells, and groundwater
monitoring) /
Excavation with Off-Site Disposal
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
Soil Vapor Extraction, Limited Excavation
with Off-Site Disposal, and Natural
Attenuation
No Further Action
No Further Action
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No adverse human health risk.
Remediation to address potential
threat to groundwater would require
$2 million to $4 million.
No contamination identified at this
site.
No contamination identified at this
site.
No threat to groundwater and no
adverse human health risk from
chemicals of potential concern in
soils.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-1. (Continued)
SWMU
Number/Site
Description
Comments
SWMU 23
SWMU 24
SWMU 25
SWMU 27/Area 1
SWMU 29
SWMU 30
SWMU 31
SWMU 33
SWMU 64
No Further Action
Bioventing
No Further Action
Excavation with Off-Site Disposal
No Further Action
No Further Action
No Further Action
Pipe Grouting, Limited Excavation, and
Institutional Controls (land use restrictions
along IWPL and groundwater monitoring)
No Further Action
Area 1 Building 236 No Further Action
Area 1 Building 237
Area 3
Building IS Drum
Storage Area
Building 22 Drum
Storage Area
Building 23
Soil Vapor Extraction
Soil Vapor Extraction
No Further Action
No Further Action
No Further Action
Building 30 Drum
Storage Area
Institutional Controls (groundwater
monitoring)
Depot Wide Surface Asphalt Cover
and Near-Surface
Soils, Northern Depot
Area
Day Care Center
Excavation and Disposal (Corrective Action
Completed)
No threat to groundwater and no
adverse human health risk from
chemicals of potential concern in
soils.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
No contamination identified at this
site.
SWMU = Solid Waste Management Unit
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-2. Performance Monitoring Network
Well ID
Rationale
Existing Monitoring Wells—OU 1
LM025AUA
LM055B
LM056C
LM058AU
LM063A
LM064B
LM065C
LM066A
LM067B
LM070C
LM076A
LM077A
LM081C
LM083A
LM084B
LM089C
LM093AU
Monitor VOC cleanup performance of extraction well EW-37AU
Monitor VOC cleanup performance of extraction well EW-27B
Monitor VOC cleanup performance of extraction well EW-31C
Monitor VOC cleanup performance of extraction well EW-34AU
Monitor groundwater quality in the Upper Horizon north of the northern infiltration
galleries and confirm that the Upper Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
Monitor groundwater quality in the Middle Horizon north of the northern infiltration
galleries and confirm that the Middle Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
Monitor groundwater quality in the Lower Horizon north of the northern infiltration
galleries and confirm that the Lower Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
Monitor VOC cleanup performance of extraction well EW-21A
Monitor VOC cleanup performance of extraction well EW-26B
Monitor VOC cleanup performance of extraction well EW-13C
Monitor VOC cleanup performance in the Upper Horizon directly south of the Banta
Road Extraction Wellfield (OU 1 Remedial Design)
Monitor VOC concentrations directly east of the northern galleries
Monitor VOC cleanup performance of extraction well EW-30C
Monitor groundwater quality in the Upper Horizon northwest of the northern infiltration
galleries and confirm that the Upper Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
Monitor groundwater quality in the Middle Horizon northwest of the northern infiltration
galleries and confirm that the Middle Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
Monitor groundwater quality in Lower Horizon cross-gradient of extraction well
(EW-31C).
Monitor VOC cleanup performance of extraction well EW-36AU
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-2. (Continued)
Well ID
Rationale
Existing Monitoring Wells—OU 1 (continued)
LM143AU
LM145AU
LM146A
LM148C
LM053A
LM028A
LM101A
LM094AU
Monitor VOC cleanup performance of extraction well EW-22A
Evaluate if off-site chloroform plume is migrating toward DDJC-Tracy as a result of the
reinjection of treated groundwater into the Upper Horizon from the southern infiltration
galleries.
Monitor VOC cleanup performance of extraction well EW-15A
Monitor groundwater quality downgradient of extraction wells EW-13C, EW-31C, and
EW-30C.
Monitor for dieldrin to evaluate the effectiveness of the extraction system
Monitor for dieldrin to evaluate the effectiveness of the extraction system
Monitor for dieldrin to evaluate the effectiveness of the extraction system
Monitor for dieldrin to evaluate the effectiveness of the extraction system
Proposed New Monitoring Wells—OU 1
PMW001AVLM150A Monitor the VOC and off-site chloroform plumes located south and southeast of the
proposed Banta Road Extraction Wellfield (OU 1 Remedial Design), respectively.
Monitor the VOC and off-site chloroform plumes located south and southeast of the
proposed Banta Road Extraction Wellfield (OU 1 Remedial Design), respectively.
Monitor the off-site chloroform plume located southeast of the proposed Banta Road
Extraction Wellfield (OU 1 Remedial Design).
Monitor VOC cleanup performance of extraction wells EW-19A and EW-20A
Monitor VOC cleanup performance of extraction wells EW-24B and EW-25B
Monitor cleanup of the VOC plume east of the Banta Road Extraction Wellfield (OU 1
Remedial Design)
Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume east of the Banta Road Extraction Wellfield (OU 1 Remedial Design)
PMW008 A\LM 157A Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume east and northeast of the Banta Road Extraction Wellfield (OU 1 Remedial
Design)
PMW009A\LM158A Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume northeast of the Banta Road Extraction Wellfield (OU 1 Remedial Design)
PMW002AVLM151A
PMW003A\LM152A
PMW004AXLM153A
PM\V005B\LM154A
PMW006A\LM155A
PMW007A\LM156A
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-2. (Continued)
Well ID Rationale
Proposed New Monitoring Wells—OU 1 (Continued)
PMW010AVLM159A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)
PMW011AVLM160A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)
PMW012A\LM 161A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)
PMW013AVLM162A Monitor VOC concentrations north of the OU 1 Remedial Design Extraction Wellfield
constructed near former Agricultural Well #2
PMW014BVLM163A Monitor potential migration of off-site chloroform plume east of Banta Road Extraction
well field
PMW015BNLM164A Monitor potential migration of off-site chloroform plume southeast of Banta Road
Extraction well field
PMW016AVLM165A Monitor potential migration of off-site chloroform plume northeast of Banta Road
Extraction well field
Existing Monitoring Wells—SWMU 1/Area 2
LM030AUA Monitor TCE and PCE migrating from source area to EW008A
LMQ40B Closest Middle Horizon well to VOC source area. Monitor for VOCs.
LM041B Monitor for VOCs to evaluate effectiveness of SVE system in preventing ground water
contamination
LM094AU Monitor VOCs from SWMU I/Area 2 to evaluate the performance of the SVE system.
Existing Monitoring Wells—Area 3
LM032AU Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater
impacts
Existing Monitoring Wells—Area 1 Building 237
LM137A Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater
impacts
LM061AU Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater
impacts
Existing Monitoring Wells—SWMUs 2/3
LM003AA Monitor performance of removal action at SWMUs 2/3. Closest downgradient well.
Monitor for SVOCs, OC and C/U pesticides.
LM015AA Monitor performance of removal action at SWMUs 2/3. Closest downgradient well.
Monitor for SVOCs, OC and C/U pesticides.
SEC-9.DOC 9-33 2 April 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-2. (Continued)
Well ID Rationale
Existing Monitoring Wells—SWMU 4
LM004AU Monitor for SVOCs, VOCs, OC and C/U pesticides, and simazine to assess potential
groundwater impacts at SWMU 4
LM027AUA Monitor for SVOCs, VOCs, OC and C/U pesticides, and simazine to potential
groundwater impacts at SWMU 4 nearest downgradient well
Existing Monitoring Wells—SWMU 6
LM017A Monitor for VOCs, OC and C/U pesticides, and chlorinated herbicides to evaluate the
performance of the excavation at SWMU 6
LM092C Upgradient from potential source at SWMU 6. Monitor for VOCs.
Existing Monitoring Wells—SWMU 7
LM095AU Downgradient from south area pits. Monitor for VOCs, OP, OC, and C/U pesticides,
chlorinated herbicides, SVOCs, and dioxins/furans.
New Monitoring Wells—SWMU 7
LM166AU Monitor for VOCs, TPHD, OP, OC, and C/U pesticides, chlorinated herbicides, and
SVOCs to evaluate potential groundwater impacts from contaminants left in place.
LM 167AU Monitor for VOCs, TPHD, dioxins/furans, SVOCs, OP, OC, and C/U pesticides
dioxins/furans, and chlorinated herbicides. Nearest downgradient well from Pits D and F.
Existing Monitoring Wells—SWMU 8
LM019A Monitor for VOCs, SVOCs, OC and C/U pesticides, and simazine to evaluate the
performance of the remedial action.
LM097AU Nearest well to potential source of OC pesticides, simazine, VOCs, and dioxin/furan
compounds.
LM119A Monitor for VOCs, SVOCs, chlorinated herbicides, and OC pesticides, nearest
downgradient well to potential source area.
New Monitoring Wells—SWMU 8
LM168A Nearest downgradient well from potential source at SWMU 8. Monitor for VOCs,
SVOCs, chlorinated herbicides, dioxins/furans, and OC pesticides.
Existing Monitoring Wells—SWMU 10A
LM014A Monitor for SVOCs to ensure No Further Action determination for SWMU 10A was
appropriate.
Existing Monitoring Wells—SWMU 20
LM085B Monitor vertical migration downgradient from SWMUs 20/23 and Area I/Building 10.
Monitor for VOCs, SVOCs. OC and C/U pesticides, chlorinated herbicides, and TPHD.
LM093AU Monitor VOCs, SVOCs, OC, OP, and C/U pesticides from SWMUs 20/23 to evaluate the
performance of the remedial action.
LM115AU Monitor VOCs, SVOCs, OC, OP, and C/U pesticides, and chlorinated herbicides to
^ evaluate migration from source area.
SEC-9.DOC 9-34 2 April 1998
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DDJC-Tracy Sile-Wide Comprehensive Record of Decision
Table 9-2. (Continued)
Well ID
Rationale
Existing Monitoring Wells—SWMU 24
LM116A Monitor for VOCs, SVOCs. PCBs, TPHG, TPHD, OC. and C/U pesticides to evaluate
migration from source area.
LM118AU
Nearest downgradient well to potential source of TPH, VOCs, SVOCs, OC and C/U
pesticides, and PCBs at SWMU 24.
Existing Monitoring Wells—SWMU 27
LM117A Monitor migration of VOCs, herbicides, and TPH-MO from potential source at SWMU
27.
Existing Monitoring Wells—SWMU 33
LM002A Monitor for VOCs, SVOCs, OC and C/U pesticides associated with SWMU 33.
Monitoring will assess effectiveness of removal action and identify impacts from
contaminants left in place.
LM129A
Monitor source area for VOCs, SVOCs, TPH, and chlorinated herbicides.
Existing Monitoring Wells—Drum Storage Area 30-1
LM169A Nearest downgradient well. Monitor for VOCs, SVOCs, and pesticides/herbicides.
C/U = carbamate/urea
OC = organochlorine
OP = organophosphorus
OU = Operable Unit
SVE = soil vapor extraction
SVOC = semivolatile organic compound
TPHD = total petroleum hydrocarbons as diesel
TPHG = total petroleum hydrocarbons as gasoline
TPH-MO = total petroleum hydrocarbons as motor oil
VQC = volatile organic compound
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-3. OU 1 Groundwater
Alternative 3 - Groundwater Extraction and Treatment
Item Description
DIRECT CAPITAL COSTS (Dieldrin)
EQUIPMENT COSTS (EC)
Conveyance Piping and Fittings
Wellhead Equipment (Pumps & Controls)
Granular Activated Carbon (GAC) Units
CONSTRUCTION COSTS
Extraction and Injection Wells*
Equipment Pads
Permitting
Pumping Test
Trenching
System Startup
Mechanical
Instrumentation
Electrical
Quantity Unit
2.000 Linear foot
1 Lump sum
1 8 each
1 1 each
9 each
1 lump sum
1 lump sum
2,000 linear foot
1 lump sum
40% of EC
10% of EC
20% of EC
Unit Cost
($)
$5
$10,000
$3.500
Subtotal EC
$10,000
$2,500
$10,000
$15.000
$13
$15,000
Subtotal
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS (Dieldrin)
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
TOTAL INDIRECT CAPITAL COST
TOTAL
CAPITAL REQUIREMENT
Total Cost
(S)
$10,000
$10,000
$63,000
$83,000
$110,000
$22,500
$10,000
$15,000
$26,000
$15,000
$33,200
$8,300
$16.600
$256,600
$339,600 |
$20,400
$13,600
$6,800
$34,000
$101,900
$57,800
$68,000
$302,500 |
$642,100 |
ANNUAL OPERATION AND MAINTENANCE COSTS (Dieldrin)
Influent/Effluent Monitoring1"
Spent GAC Changeout Costs0
Labor
Maintenance Materials
Groundwater Monitoring*1
Injection Well Redevelopment0
216 each
27 each
0.25 man-year
1 lump sum
1 lump sum
1 lump sum
TOTAL O&M COSTS
$200
$1,900
$75,000
$2,000
$10,000
$16,800
$43,200
$51,300
$18,750
$2,000
$10,000
$16,800
$142,050
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-3. (Continued)
Item Description
Unit Cost Total Cost
Quantity Unit (S) ($)
PRESENT WORTH (Dieldrin)
Interest Rate
Years
DIELDRIN UPGRADE PRESENT WORTH
CAPITAL COSTS (VOCs)
1%
30
I $2.528.000 |
| $3,324,400 |
TOTAL PRESENT WORTH
| $12.037.500
* Based on nine extraction wells and two injection wells
h Based on one influent sample and one effluent sample collected monthly and analyzed for dieldrin.
c Based on three changeouts per year for each well. Includes disposal of spent GAC and replacement with fresh GAC.
a Based on monitoring 10 wells for dieldrin.
e The two injection wells will be re-developed every two months to prevent fouling.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-4. SWMU 1/Area 2 - Aboveground Solvent Tank/Building 26 Recoup Operations
Alternative 3 - Soil Vapor Extraction
Item Description
Quantity
Unit
Unit Cost
(S)
Total Cost
($)
DIRECT CAPITAL COSTS
SOIL VAPOR EXTRACTION
Mobilization/Demobilization*
Air Extraction Vents
Collection Piping
Rental of Mobile Blower System1"
Labor (O&M)
Air Effluent Testing
Confirmation Sampling (Soil Gas)
CLOSURE REPORT
1
1
2,000
12
0.25
1
1
40
lump sum
lump sum
linear foot
months
man-year
lump sum
lump sum
hour
TOTAL DIRECT CAPITAL COST (DCC)
$1,000
$47,000
$20
$2,000
$75,000
$5,000
$2,000
$70
$1,000
$47,000
$40,000
$24,000
$18,750
$5,000
$2,000
$2,800
$140.550
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
PRESENT WORTH
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
$8,500
$5,700
$2,900
$14,100
$42,200
$23,900
$28,200
I $125.500 |
$266,100
$266.000 |
Assumptions:
* Mobilization/demobilization of SVE system will be conducted concurrently with same for systems at other sites.
b Includes vapor-phase carbon treatment; assumes that two systems will be needed, each operated for 6 months.
0 25-page report to be included in depot-wide closure report.
SEC-9.DOC
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-5. Area 1 Building 237
Alternative 3 - Soil Vapor Extraction
Item Description
DIRECT CAPITAL COSTS
SOIL VAPOR EXTRACTION
Mobilization/Demobilization*
Air Extraction Vents
Collection Piping
Rental of Mobile Blower System6
Labor (O&M)
Air Effluent Testing
Confirmation Sampling (Soil Gas)
CLOSURE REPORT
Quantity Unit
1 lump sum
1 lump sum
500 linear foot
6 months
0.25 man-year
1 lump sum
1 lump sum
40 hour
Unit Cost
($)
$1,000
$22,000
$20
$2,000
$75,000
$5,000
$2,000
$70
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
TOTAL
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
7%
I
Total Cost
($)
$1,000
$22,000
$10,000
$12,000
$18,750
$5,000
$2,000
$2,800
$73,550 |
$4,500
$3,000
$1,500
$7,400
$22,100
$12,600
$14,800
$65,900 |
$139,500 |
$140,000 |
Assumptions:
1 Mobilization/demobilization of SVE system will be conducted concurrently with same for systems at other sites.
h Includes vapor-phase carbon treatment.
c 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-39
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-6. Area 3
Alternative 3 - Soil Vapor Extraction
Item Description
Quantity
Unit
Unit Cost
(S)
Total Cost
J$)
DIRECT CAPITAL COSTS
SOIL VAPOR EXTRACTION
Mobilization/Demobilization*
Air Extraction Vents
Collection Piping
Rental of Mobile Blower System*1
Labor (O&M)
Air Effluent Testing
Confirmation Sampling (Soil Gas)
CLOSURE REPORr
1
1
2000
6
0.25
1
1
40
lump sum
lump sum
linear foot
months
man-year
lump sum
lump sum
hour
TOTAL DIRECT CAPITAL COST (DCC)
$1,000
$46,000
$20
$2,000
$75,000
$5,000
$2,000
$70
$1,000
$46,000
$40,000
$12,000
$18,750
$5,000
$2,000
$2,800
$127,550
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
PRESENT WORTH
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
$7,700
$5,200
$2,600
$12,800
$38,300
$21,700
$25,600
[ $113.900 |
| $241.500 |
$242,000
Assumptions:
' Mobilization/demobilization of S VE system will be conducted concurrently with same for systems at other sites.
b Includes vapor-phase carbon treatment.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-40
2 April 1998
-------
Table 9-7. Groundwater Monitoring Requirements (ug/L) for DDJC-Tracy
Analyte
Method
Beneficial
Use Limit
Background
Concentration
Quantitation
Limit
Groundwater
Concentration
Estimated Requiring
Detection Limit" Evaluation
Rationale
Soil Cleanup Standards (ue/ke)
Acclonc
Aldrin
Benzyl alcohol
bis(2-E(l)yllicxyl)pluhalatc
2-Bulanone
Carbaryl
Carbofuran
Chlordanc
2,4-D
ODD
DDE
DDT
Dicamba
1,2-Dichloroelhene
SW8260B
SW808IA
SW8270C
SW8270C
SW8260B
E632
E632
SW8081A
SW815IA
SW8081A
SW8081A
SW8081A
SW8151A
SW8260B
700
0.002
NA
4.2
4,200
60
18
0.03
70
0.15
O.I
0.1
210
6
NE
0.005b
NE
NE
NE
0.382b
NE
0.104"
0.101"
0.005b
0.005b
0.005b
0.09 lb
NE
10
0.05
10
10
20
5
5
0.1
10
0.1
O.I
O.I
10
0.5
700
0.01 0.05(0.01)
10
2 10(2)
4,200
60
18
0.05 0. 1 (0.05)
70
0.15
0.1
0.1
210
6
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to (he estimated
detection limits (in parenthesis).
Corresponds to quantitation limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
-------
Analyte
Soil Cleanup Standards
Oicldrin
Diclhylplithalate
2,4-Dimelhylphcnol
Di-n-bulyl phthalatc
2,4-Dinitrophcnol
2,4-Dinitrotoluene
Dioxins/Furans
Diurun
Endrin
Ethylbcnzcne
Fluoranllicnc
Method
(ug/kg) (Continued)
SW8081A
SW8270C
SW8270C
SW8270C
SW8270C
SW8270C
Beneficial
Use Limit
0.002
5,600
140
700
14
0.11
SW8280 0.0000002
7
E632
SW8081A
SW8260B
SW8270C
14
2
29
280
Table
Background
Concentration
0.005"
NE
NE
NE
NE
NE
0.000001
O.I44b
0.005"
NE
NE
9-7. (Continued)
Quantitatlon Estimated
Limit Detection Limit*
0.05 0.01
10
10
10
50 10
10 2
0.01 0.01
1
0.1
2.0
10
Groundwater
Concentration
Requiring
Evaluation
0.05(0.01)
5.600
140
700
50(10)
10(2)
0.01(0.01)
14
2
29
280
Rationale
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
-------
Table 9-7. (Continued)
Analyte
Method
Beneficial
Use Limit
Background
Concentration
Quantitatlon
Limit
Groundwater
Concentration
Estimated Requiring
Detection Limit8 Evaluation
Rationale
Soil Cleanup Standards fug/kg) (Continued)
Hcptuchlor
Hcplachlor Epoxide
2-Hcxanonc
Liudane
Linuron
MCPA
Mclluocarb
4-Mcthyl-2-pcnlanone
2-Mclhylnaphthalcnc
4-Mclhylphenol
Monuron
Naphthalene
PCB (Aroclor 1260)
SW808IA
SW8081A
SW8260B
SW8081A
E632
SW8151
C632
SW8260B
SW8270C
SW8270C
E632
SW8270C
SW8082
0.006
0.003
NA
0.03
1.4
3.5
NA
40
NA
NA
NA
20
NA
0.005"
0.005"
NE
0.005"
0.157"
NE
1.36"
NE
NE
NE
0.163"
NE
NE
0.01
0.01
10
0.03
2
380
5
10
10
10
1
10
0.5
0.01 0.01 (0.01)
0.01 0.01 (0.01)
10
0.03
1.0 2(1.0)
100 380(100)
5
40
10
10
1.0
20
0.5
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to quantitation limit.
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to quantilation limit.
Corresponds to beneficial use limit.
Corresponds to quantitation limit.
Corresponds to quantitation limit.
Corresponds to quantilation limit.
Corresponds to beneficial use limit.
Corresponds to quantitation limit.
-------
Analyte
Method
Beneficial
Use Limit
Table
Background
Concentration
9-7. (Continued)
Quantitation Estimated
Limit Detection Limit*
Groundwater
Concentration
Requiring
Evaluation
Rationale
Soil Cleanup Standards (ue/kg) (Continued)
Pcnlachlorophcnol
Phenanthrene
Phenol
Phoratc
Pyrcnc
Ronncl
Simazinc
2,4,5-T
Tctrachloroclhcnc
Toluene
TPH-Dicsel
TPH-Gasolinc
TPH-Motor Oil
Trichlorocthene
SW8270C
SW8270C
SW8270C
SW8141A
SW8270C
SW8141A
E507
SW8151A
SW8260C
SW8260C
SWSOISMod
SWSOISMod
SWSOISMod
SW8260B
1.9
NA
4.200
NA
210
NA
4
70
0.7
42
100
5
100
2.3
NE
NE
NE
NE
NE
NE
0.492"
NE
NE
NE
NE
NE
NE
NE
50 10
10
10
0.5
10
0.5
0.2
10
2 0.5
1
100
50 40
100
1
50(10)
10
4,200
0.5
210
0.5
4
70
2 (0.5)
42
100
50 (40)
100
2.3
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to quantitation limit.
Corresponds to beneficial use limit.
Corresponds to quantitation limit.
Corresponds to beneficial use limit.
Corresponds to quantitation limit.
Corresponds (o beneficial use limit.
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
Corresponds to beneficial use limit.
I
0
H
6)
n
W
ft
5.'
n
n
o
3
H
8"
3
•ft
n
70
n
n
1
o
J
n
5'
-------
Table 9-7. (Continued)
Analyte
Soil Cleanup Standards
2,4,6-Trichloroplicnol
Method
(ue/kg) (Continued)
SW8270C
Beneficial
Use Limit
0.5
Background
Concentration
NE
Quantitation
Limit
10
Estimated
Detection Limit*
2
Groundwater
Concentration
Requiring
Evaluation
10(2)
Rationale
Quantitative results will
be
Xylenes
SW8260B
17
NE
17
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).
Corresponds to beneficial use limit.
' Estimated method detection limits (MDLs) which should be achievable for project laboratories by performing the MDL study following 40 CFR 136, Appendix B issued July 1,1997.
The reported MDLs will be laboratory specific and shall be at or below estimated detection limit. Groundwater monitoring results will include reporting of all concentrations between
the laboratory MDL and quanlitation limit as trace or "DNQ." In cases where a change in matrix or other effects caused the MDL or quantitation limit to differ significantly from the
laboratory-derived MDL/RL values, the results shall be flagged accordingly, along with the estimates of the detection limit and quantitation limit actually received.
b These compounds have not been detected in background wells. The value cited is the lowest detection limit used to analyze groundwater during the remedial investigation.
() = estimated detection limit
NA = not available
NE = not evaluated
ug/kg = micrograms per kilogram
pg/L = micrograms per Liter ^^^
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-8 SWMU 4 - Storm Drain Lagoon
Alternative 3 - Excavation and Disposal of Sediments
Item Description Quantity Unit
DIRECT CAPITAL COSTS
SEDIMENT EXCAVATION/DEW ATERING
Engineering Oversight* 60 hour
Mobilization & Demobilization 1 lump sum
Site Preparation 1 lump sum
Excavation6 3,010 ton
Sediment Dewatering 3,000 cubic yards
Clean Backfill 560 cubic yards
Site Restoration 1 unit
Sediment Trap or Cyclones 1 unit
POST-EXCAVATION SAMPLING
Sampling
Personnel 40 hour
Sampling Material 1 lump sum
Soil Analyses' 31 sample
Surface Water Analyses 10 sample
CLASS III DISPOSAL FACILITY*
Pre -Disposal Lab Analytical Testing/ 1 lump sum
Waste Profile
Disposal0 3,010 ton
CLOSURE REPORT* 40 hour
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services 6% of DCC
Office Engineering During Construction 4% of DCC
Non-Design Engineering 2% of DCC
Construction Management 10% of DCC
Contingency 30% of DCC
Contract Administration 1 7% of DCC
Contractor' s Overhead and Profit 20% of DCC
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
Unit Cost
($)
$130
$10,000
$1,000
$30
$5
$10
$59,400
$150,000
$60
$500
$500
$125
$300
$30
$70
7%
1
Total Cost
($)
$7,800
$10,000
$1,000
$90,300
$15,000
$5,600
$59.400
$150,000
$2,400
$1,000
$15,500
$1,250
$300
$90,300
$2,800
| $452,650 |
$27,160
$18,110
$9,050
$45,270
$135,800
$76,950
$90,530
| $402,870 |
| $855,520 |
| $855,520 |
Assumpiions:
* Two-person crew (one senior and one professional), 6 days, 10-hour days
b Sediment volume to be excavated is approximately 2,315 cubic yards (3,010 tons). Assumed moisture content of sediment is 50%.
c Assumes 1 sample collected per 100 cubic yards.
d Disposal of dewatered sediment at nearby municipal (Subtitle D) landfill.
c Cost includes transportation and 10% county tax.
1 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-46
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-9. SWMU 6 - Building 28 Sump
Alternative 4a- Excavation and Class II Disposal
Item Description
DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight"
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation1"
Imported Fill
Backfilling and Compaction
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses0
CLASS II DISPOSAL FACILITY11
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal'
CLOSURE REPORT'
Quantity Unit
20 hour
1 lump sum
1 lump sum
100 linear foot
130 ton
78 ton
130 ton
12 hour
1 lump sum
5 sample
I lump sum
78 ton
40 hour
Unit Cost
($)
$130
$1,500
$500
$3
$30
$6
$30
$60
$500
$200
$300
$60
$70
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
TOTAL
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
Total Cost
($)
$2,600
$1,500
$500
$300
$3,900
$468
$3,900
$720
$500
$1,000
$300
$4,680
$2,800
I $23,168 |
$1,400
$1,000
$500
$2,400
$7,000
$4,000
$4,700
I $21,000 |
| $44,168 |
| $45,000 |
Assumptions:
1 Two-person crew (one senior and one professional), 2 days, 10-hour days
b The total volume of soil to be excavated is 100 cy (130 tons).
c Assumes 1 sample collected per 20 cubic yards.
d Disposal of 78 tons of contaminated soil at McKittrick's Class II Disposal Facility
c Cost includes transportation, treatment (stabilization), and 10% county tax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-47
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-10. SWMU 6 - Building 28 Sump
Alternative 4b - Excavation and Class I Disposal
Item Description
DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation1"
Imported Fill
Backfilling and Compaction
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses0
CLASS II DISPOSAL FACILITY*
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal'
CLOSURE REPORT'
Quantity Unit
20 hour
1 lump sum
1 lump sum
100 linear foot
1 30 ton
78 ton
1 30 ton
1 2 hour
1 lump sum
5 sample
1 lump sum
78 ton
40 hour
Unit Cost
($)
$130
$1,500
$500
$3
$30
$6
$30
$60
$500
$210
$300
$200
$70
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
TOTAL INDIRECT CAPITAL COST
TOTAL
PRESENT WORTH
CAPITAL REQUIREMENT
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
Total Cost
(S)
$2,600
$1,500
$500
$300
$3,900
$468
$3,900
$720
$500
$1,050
$300
$15,600
$2,800
I $34.138 |
$2,100
$1,400
$700
$3,500
$10,300
$5,900
$6,900
I $30,800 |
I $64,938 |
I $65,000 |
Assumptions:
1 Two-person crew (one senior and one professional), 2 days, 10-hour days
b The total volume of soil to be excavated is 100 cy (130 tons).
c Assumes I sample collected per 20 cubic yards.
d Disposal of 78 tons of contaminated soil at Chemical Management's Kettleman Hills Class I Disposal Facility
c Cost includes transportation, treatment (stabilization), and 10% county tax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-48
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-11.
Alternative
Item Description
DIRECT CAPITAL COSTS
Installation of Two New Monitoring Wells
INDIRECT CAPITAL COSTS
Land Use Restrictions
SWMU 7 - Burn Pit No. 1
2 - Institutional Controls
Unit Cost
Quantity Unit ($)
1 lump sum $17,000
lump sum $50,000
TOTAL CAPITAL REQUIREMENT
ANNUAL GROUNDWATER MONITORING
Chemical Analyses (Year 1)
Chemical Analyses (Years 2-4)
Fieldwork
Reporting
COSTS '
1 lump sum $12,000
1 lump sum $9,000
1 lump sum $10,000
1 lump sum $15,000
TOTAL ANNUAL MONITORING COSTS (YEAR 1)
TOTAL ANNUAL MONITORING COSTS (YEARS 2 - 4)
FIVE-YEAR SITE REVIEW
Site Review Report
Site Review Assessment and Report
Contingency
1 lump sum $10,000
20% O&M
TOTAL S-YEAR SITE REVIEW
PRESENT WORTH
Interest Rate 7%
Years 10
TOTAL PRESENT WORTH
Total Cost
($)
$17,000
$50,000
$67,000
$12,000
$9,000
$10,000
$15,000
$37,000
$34,000
$10,000
$2,000
$12,000
$208,000
1 Groundwater monitoring of the two new wells will be conducted.
SEC-9.DOC
9-49
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-12. SWMU 8 - Burn Pit No. 2
Alternative 4 - Excavation and Class I Disposal
Item Description
DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation1"
Imported Fill
Backfilling and Compaction
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses0
CLASS I DISPOSAL FACILITY4
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal*
CLASS III DISPOSAL FACILITY'
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal8
CLOSURE REPORT"
GROUNDWATER MONITORING1
Installation of Two New Monitoring Well^
Chemical Analyses
Fieldwork
Reporting
Quantity
100
1
1
800
10,400
5,800
10,400
40
1
80
1
3,400
1
2,400
40
1
1
1
1
TOTAL DIRECT CAPITAL
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
Unit
hour
lump sum
lump sum
linear foot
ton
ton
ton
hour
lump sum
sample
lump sum
ton
lump sum
ton
hour
lump sum
lump sum
lump sum
lump sum
COST (DCC)
6%ofDCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
Unit Cost
($)
$130
$3,000
$1,000
$3
$30
$6
$30
$60
$500
$210
$300
$200
$300
$30
$70
$20,000
$3,000
$10,000
$7,000
Total Cost
($)
$13,000
$3,000
$1,000
$2,400
$312,000
$34,800
$312,000
$2,400
$500
$16,800
$300
$680,000
$300
$72,000
$2,800
$20,000
$3,000
$10,000
$7,000
| $1,493,300 |
$89,600
$59,800
$29,900
$149,400
$448,000
$253,900
$298,700
SEC-9.DOC
9-50
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-12. (Continued)
Unit Cost Total Cost
Item Description Quantity Unit ($) ($)
TOTAL INDIRECT CAPITAL COST $ ] ,329,300
TOTAL CAPITAL REQUIREMENT | $2.822.600
PRESENT WORTH
Interest Rate 7%
Years 1
TOTAL PRESENT WORTH [ $2.823.000
Assumptions:
' Two-person crew (one senior and one professional), 10 days, 10-hour days
" Soil/debris volume to be excavated is approximately 8,000 cubic yards (10,400 tons). Approximately 5,800 tons is clean soil
that can be backfilled; 3,400 tons is contaminated soil; 2,400 tons is uncontaminated debris.
e Assumes I sample collected per 100 cy.
d Disposal of 3,400 tons of contaminated soil at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
c Cost includes transportation, treatment (stabilization), and 10% county tax.
1 Disposal of 2,400 tons of uncontaminated debris (e.g., concrete, wood, etc.) at nearby municipal (Subtitle D) landfill.
1 Cost includes transportation and 10% county tax.
h 25-page report to be included in depot-wide closure report.
1 Groundwater monitoring will be conducted.
' One new well will be installed to replace LM97A which will be removed during excavation of the former burn pit. The second
new well will be used to characterize the dieldrin plume downgradient of the site.
SEC-9.DOC 9-51 2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-13. SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup
Operations and Area 1 Building 10
Alternative 3 - SVE, Excavation and Class I Disposal
Item Description
DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Site Preparation
Excavation6
Imported Fill
Backfilling and Compaction
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analysesc
CLASS I DISPOSAL FACILITY*
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal"
CLOSURE REPORT'
SOIL VAPOR EXTRACTION
Construction Trailer (rental)
Mobilization/Demobilization
Air Extraction Vents
Collection Piping
Blower System Rental
Labor
Air Effluent Testing
Confirmation Sampling (Soil Gas)
Quantity
40
1
1
320
320
320
20
1
3
1
320
40
1
1
1
50
6
0.25
1
1
TOTAL DIRECT CAPITAL
Unit
hour
lump sum
lump sum
ton
ton
ton
hour
lump sum
sample
lump sum
ton
hour
month
lump sum
lump sum
linear foot
months
man-year
lump sum
lump sum
COST (DCC)
Unit Cost
(S)
$130
$1,000
$500
$30
$6
$30
$60
$500
$210
$300
$200
$70
Subtotal
$500
$3,000
$18,000
$20
$2,000
$75,000
$2,000
$2,000
Subtotal
1
Total Cost
($)
$5,200
$1,000
$500
$9,600
$1,920
$9,600
$1,200
$500
$630
$300
$64,000
$2,800
$97,250
$500
$3,000
$18,000
$1,000
$12,000
$18,750
$2,000
$2,000
$57,250
$154,500 |
SEC-9.DOC
9-52
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-13. (Continued)
item Description
Quantity
Unit
Unit Cost
($)
Total Cost
($)
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6%ofDCC
4%ofDCC
2%ofDCC
10%ofDCC
30%ofDCC
17%ofDCC
20%ofDCC
PRESENT WORTH
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
Interest Rate
Years
7%
I
S9.300
$6,200
$3,100
$15,500
$46,400
$26,300
$30,900
$137,700
$292,200
TOTAL PRESENT WORTH
\ $293.000 |
Assumptions:
1 Two-person crew (one senior and one professional), 4 days, 10-hour days
b The floor drain located within Building 26, and the sumps at Manholes W-l and W-3 will be excavated which represents
approximately 320 tons of soil and concrete.
c Assumes 3 samples collected
d Disposal at Chemical Waste Management's Kettleman Hills Class 1 Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-53
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-14. SWMU 24 - Building 247 Petroleum Laboratory Waste Oil
Alternative 3 • Bioventing
Item Description Quantity
Unit
DIRECT CAPITAL COSTS
BIOVENTING
Construction Trailer (rental) month
Mobilization/Demobilization lump sum
Air Injection Vent lump sum
Collection Piping 20 linear foot
Blowers each
Gauges, Valves, etc. lump sum
Equipment Pads each
Treatability Study 1 lump sum
GROUNDWATER MONITORING1
Chemical Analyses 1 lump sum
Fieldwork 1 lump sum
Reporting 1 lump sum
CLOSURE REPORT" 40 hour
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services 6% of DCC
Office Engineering During Construction 4% of DCC
Non-Design Engineering 2% of DCC
Construction Management 1 0% of DCC
Contingency 30% of DCC
Contract Administration 1 7% of DCC
Contractor' s Overhead and Profit 20% of DCC
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
ANNUAL OPERATION AND MAINTENANCE COSTS
Energy 3,500 kw-hr
Labor 0.5 man-year
Maintenance Materials 1 lump sum
TOTAL O&M COSTS
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
Unit Cost
($)
$500
$3,000
$14,000
$20
$2,000
$500
2,500
$10,000
$1,000
$5,000
$5,000
$70
$0.10
$75,000
$2,000
7%
2
Total Cost
(S)
$500
$3,000
$14,000
$400
$2,000
$500
$2,500
$10,000
$1,000
$5,000
$5,000
$2,800
$46,700 |
$2,900
$1,900
$1,000
$4,700
$14,100
$8,000
$9,400
$42,000 |
$88,700 |
$350
$37,500
$2,000
$39,850 |
$166,000 |
Assumptions:
' Groundwater monitoring of LM 1 1 8A will be conducted.
h 25-page report to be included in depot-wide report.
SEC-9.DOC
9-54
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-15. SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206
Alternative 3 - Excavation and Class I Disposal
Item Description
DIRECT CAPITAL COSTS
Construction Costs
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Site Preparation
Excavation1"
Imported Fill
Backfilling and Compaction
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses'
CLASS I DISPOSAL FACILITY*
Field Sampling
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal6
CLOSURE REPORT'
Quantity Unit
20 hour
1 lump sum
1 lump sum
170 ton
170 ton
170 ton
1 6 hour
1 lump sum
8 sample
10 hour
1 lump sum
170 ton
40 hour
Unit Cost
($)
$130
$3,000
$1,000
$30
$6
$30
$60
$500
$210
$60
$300
$200
$70
TOTAL DIRECT CAPITAL COST (DCC)
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
TOTAL
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
Total Cost
($)
$2,600
$3,000
$1.000
$5,100
$1,020
$5,100
$960
$500
$1,680
$600
$300
$34,000
$2,800
| $58,660 |
$3,600
$2,400
$1,200
$5,900
$17,600
$10,000
$11,800
I $52,500 |
| $111,160 |
I $112,000 |
Assumptions:
' Two-person crew (one senior and one professional), 2 days, 10-hour days
b Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately 130
cubic yards (170 tons).
c Assumes 8 samples collected.
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
' Cost includes transportation, treatment (stabilization), and 10% county lax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-55
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-16. Drum Storage Area - Building 30
Alternative 2 - Institutional Controls
Unit Cost
Item Description Quantity Unit ($)
DIRECT CAPITAL COSTS
Installation of One New Monitoring Well 1 lump sum $10,000
INDIRECT CAPITAL COSTS
Land Use Restrictions 1 lump sum $50,000
TOTAL CAPITAL REQUIREMENT
ANNUAL GROUNDWATER MONITORING COSTS'
Chemical Analyses 1 lump sum $2,000
Fieldwork 1 lump sum $5,000
Reporting 1 lump sum $5,000
TOTAL ANNUAL MONITORING COSTS
FIVE-YEAR SITE REVIEW
Site Review Report
Site Review Assessment and Report 1 lump sum $10,000
Contingency 20% of DCC
TOTAL 5-YEAR SITE REVIEW
PRESENT WORTH
Interest Rate 7%
Years 10
TOTAL PRESENT WORTH
Assumptions:
* The new well will be monitored for
SVOCs on a quarterly basis for one year.
Total Cost
($)
$10.000
$50,000
I $60.000 |
$2,000
$5,000
$5,000
| $12,000 |
$10,000
$2,000
| $12,000 |
| $87,000 |
SEC-9.DOC
9-56
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-17. Surface and Near-Surface Soils • Northern Depot Area
Alternative 3 - Asphalt Cover
DDJC-Tracy, Comprehensive RI/FS
Item Description
Quantity
Unit
Unit Cost
($)
Total Cost
($)
DIRECT CAPITAL COSTS
ASPHALT COVER-SURFACE AND NEAR-SURFACE SOILS
Asphalt*'b
ASPHALT PAVEMENT FOR ROADWAY
Asphalt11"
CLOSURE REPORT0
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
138,000 square foot
9,700
40
square foot
hour
6%ofDCC
4%ofDCC
2%ofDCC
10%ofDCC
10%ofDCC
17%ofDCC
20%ofDCC
PRESENT WORTH
TOTAL INDIRECT CAPITAL COSTS
TOTAL CAPITAL REQUIREMENT
Interest Rate
Years
TOTAL PRESENT WORTH
$2.00
S2.00
$70
7%
1
$276,000
$19,400
$2.800
$17,900
$12,000
$6,000
$29,900
$29,900
$50,700
$59,700
| $206.100 |
| $504.300 |
$504,000
Assumptions:
* Asphalt unit cost based on quote from Capital Asphalt Construction, Inc., Stockton, CA, for 4 inches of asphalt and 4 inches of
aggregate base; unit cost includes grading and compaction.
b It is assumed that drainage controls are not needed.
c 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-57
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-18. SWMU 2/3 - Sewage and Industrial Waste Lagoons
Alternative 3 • Excavation and Class I Disposal
Item Description
Quantity
Unit
Unit Cost
($)
Total Cost
($)
DIRECT CAPITAL COSTS
Construction Costs
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Site Preparation
Excavation"
POST-EXCAVATION SAMPLING
Sampling
Analyses
CLASS I DISPOSAL FACILITY*
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal*
CLOSURE REPORT'
INDIRECT CAPITAL COSTS
Engineering Design Services
TOTAL INDIRECT CAPITAL COST
I hour
I lump sum
1 lump sum
067 ton
$77,200
$15,000
$12,941
$9.23
$77,200
$15,000
$12,941
$139,000
lump sum
$355,400
6%ofDCC
PRESENT WORTH
TOTAL CAPITAL REQUIREMENT
Interest Rate
Years
TOTAL PRESENT WORTH
7%
1
$355,400
1
15,067
40
:APITAI
lump sum
ton
hour
L COST (DCC)
$240,300
$75.50
$70
$240,300
$1,137,800
$2,800
| $1,980,500 |
$11,880
$11,880
$1,992.380
$2.132.000
Assumptions:
' Two-person crew (one senior and one professional), 2 days, 10-hour days
b Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately 130
cubic yards (170 tons).
c Assumes 8 samples collected.
d Disposal at Chemical Waste Management's Kettieman Hills Class I Disposal Facility
c Cost includes transportation, treatment (stabilization), and 10% county tax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-58
2 April 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 9-19. SWMU 33 - Industrial Waste Pipeline
Alternative 3 - Excavation, Grouting, and Institutional Controls
Item Description
Quantity
Unit
Unit Cost
($)
Total Cost
($)
DIRECT CAPITAL COSTS
Construction Costs
SOIL EXCAVATION
Engineering Oversight*
Mobilization & Demobilization
Grouting
Excavation1"
Site Restoration
Pier Drilling
Hydroflush IWPL
POST-EXCAVATION SAMPLING
Sampling & Analyses0
20
170
Hour
Lump sum
Lump sum
Ton
Lump sum
Lump sum
Ton
Lump sum
$130
$15,000
$37,300
$31
$1,000
$78,500
$7,500
$23,700
$2,600
$15,000
$1,000
$5,200
$1,000
$78,500
$7,500
$23,700
CLASS I DISPOSAL FACILITY11
Waste Profile
Disposal*
CLOSURE REPORT'
1 Lump sum
40 Hour
TOTAL DIRECT CAPITAL COST (DCC)
ANNUAL MONITORING (5 years) 1 Lump sum
TOTAL CAPITAL REQUIREMENT
PRESENT WORTH
Interest Rate
Years
TOTAL PRESENT WORTH
$
$27,200
$70
$27,200
$2,800
I $164.500
$65,000 $65,000
$229,500
$245,600
Assumptions:
' Two-person crew (one senior and one professional), 2 days, 10-hour days
" Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately 130
cubic yards (170 tons).
c Assumes 8 samples collected.
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
c Cost includes transportation, treatment (stabilization), and 10% county tax.
' 25-page report to be included in depot-wide closure report.
SEC-9.DOC
9-59
2 April 1998
-------
N
IQ-7 IG-B IG-9
Q
1
Contractor Lay Down Area
Northern
Infiltration
Gallery
GROUNDWATEf)
FLOW DIRECTION
Existing
Treatment
Plant No. 1
EW-21AJ
EW-30C1
EW-26B
Treatment Plant No. 2
EW-13C
•
I
§
Ew-tOd - -
EW-34A
EW-36AU«A' - -
_u« a.
GDI IG-1
EW-14A
EW-15A
EW-16A
EW17A
EW-18A
EW-19A
EW-2W,
EW-24B '
EW 25B I
Southern .,
Infiltration IG5r
Galleries
IG-3J-
e
0
LEGEND
INSTALLATION BOUNDARY
BURIED NEW PI FELINE
EXISTING BURIED PIPELINE
FUTURE SYSTEM
EXISTING ROAD TO BE IMPROVED
EXTRACTION WEU (EW)
INJECTION WELL (IW)
INFILTRATION GALLEHY.'CHIMNEY DRAIN (IGiCD)
0 300 600
APPROXIMATE SCALE IN FEET
Figure 9-1.
Operable Unit #1 (OU-1)
Groundwaier Treatment System
Exisiting and Proposed Facilities
Defense Depot San Joaquin - Tracy Site
-------
0
-005
* a
* e
a
5
Above Upper Aquifer
Contour Interval = 1 |jg/l
Upper/Middle Aquitard
Contour Interval = 0.1 ug/l
Upper Aquifer
Contour Interval = 0.1 ug/l
« Proposed Extraction Well Within
Annex
o Proposed Extraction Well at
SWMU3
® Proposed Extraction Well at
SWMU8
0 BOO 1600
SCALE IN FEET
Figure 9-2. Proposed Locations of Extraction Wells for
Remediation of Dieldrin in Groundwater
Defense Depot San Joaquin - Tracy Site
-------
LM28A «-\
LM29B *
LM62AU ®
® LM39B
i -
®LM47A
NORTH
FEET 130
LM101A
® Existing Monitoring Well Location
O Phase II Soil Boring Location
* Soil Vapor Extraction Well
O Inferred Area Extent of PCE and TCE in Soils
LM104A
/ Fence
Pad mounted
blower system
Railroad Tracks
O LM16AA
Pad mounted
|—| ^ . blower system
TRACY\BOO\9-03,FHS • VMO 12*97
Figure 9-3. SWMU 1/Area 2 • Old Sewage Lagoons/Drum Storage Area
Conceptual Site Layout of Full-Scale SVE System
Defense Depot San Joaquin - Tracy Site
-------
SOIL CONTAMINATION AREA BUILDING 237
0 2550
SCALE IN FEET
EXPLANATION
-tj>- Existing Monitoring Well
O Phase I Soil Boring Location
• Phase II Soil Boring Location
^ IRM System Extraction Well
O Previous Investigation Soil Boring
D Previous Investigation Soil-Gas Sample
Q SVE Well
|_ | Soil Contamination Area, Building 237
Q Manhole
c^} Area of Soil Contaminated with PCE
A— A' Location of Cross Section A-A'
i i Asphalt
// Edge of Pavement
IWPL Location
Figure 9-4. Area 1 - Building 237 Conceptual Site Layout of Full-Scale SVE System
Defense Depot San Joaquin - Tracy Site
-------
0-3.5 feet below ground surface
3.5-9.5 feet below ground surface
Area of Soil Contaminated by PCE and/or TCE
SVE Well
Pad-Mounted Blower System
9.5-20 feet below ground surface
Figure 9-5. Area 3 - Conceptual Site Layout Of Full-Scale SVE System
Defense Depot San Joaquin - Tracy Site
(see Section 5.4.3 for location)
-------
IRM Treatment
System
Area of Excavation
500' x 500' x 0.25' bgs
SB155 O
SS20
SE026
Storm Drain Lagoon (Unlined)
LM075A
LMOB8C
LM078B
100
5i
SCALE IN FEET
EXPLANATION
-ffl- Existing Monitoring Well Location
1 Existing Piezometer Location
O Phase I Soil Boring Location (SWMU 4 soil
boring samples were collected from the
surface only)
// Edge of Pavement
@ Phase I Surface/Near Surface Sample Location
4 Phase II Sediment/Surface Water
Sample Location
0 Previous Investigation Sediment Sample Location
O Previous Investigation Soil-Gas Sample Location
(approximate)
• •—~ Excavation Location (3 inches bgs).
Install Geofabric Filter, Supply 3 Inches of Clean Fill
Figure 9-6. SWMU 4 - Conceptual Excavation Footprint
Defense Depot San Joaquin - Tracy Site
-------
EXPLANATION
O
O
e
Existing Monitoring Well Location
Phase I Soil Boring Location
Previous Investigation Soil Boring Location
ECOS, 1988 Composite Soil Sample Location
(two soil samples collected beneath the sump
and one sand sample collected from inside
the sump during sump removal)
Previous Investigation Soil-Gas Sample Location
Approximate Location of Former Sump
Excavation Location
1
UJ
CC
I
H
O)
8
-------
Loading
Dock
Bldg. 22
3
Loading
Dock
o
o
Paved
POV
ParWng
LMr.aA
Paved
(Asphalt)
SWMU 22
L.vna.A
. S3189
SB190 O
Unpaved
SB163O/' .•
SWMU 8 X
V ,/y "" Area C = 1O-14' bgs: 20' x 280' x 41
Unpaved
Area A/B = 0-10' bgs: 70' x 280' x 10'
N
0 ^50 100
SCALE IN FEET
EXPLANATION
-®- Existing Monitoring Well Location
-^- Phase II Monitoring Well Location
O Phase I Soil Boring Location
• Phase II Soil Boring Location
J J Location of Bum Pit No. 2 (Based on Phase I
trenches and soil borings)
— •— Excavation Location
Figure 9-8. SWMU 8 - Conceptual Excavation Footprint
Defense Depot San Joaquin - Tracy Site
-------
LM25A (LM25AA)
I
O
EW-OM
Paved (Asphalt)
A STREET
Paved (Asphalt)
Ramp
LM129A
f\ Sump
USTSITE13
' SB432/432b
LM93AU :OSB206
SSB018
SSB017
SB427/4276
(4'xS')
SB426M26b
SB425M25b
>B424
Area of Excavation
20'x2O'x 15'bgs
Area of Excavation
6' x 6' x 15' bgs Floor Drain |
Bldg. 10
SWMU 20
Former TCE Tank
(4.5' x 5.5')
Q
O
EXPLANATION
-
-------
FEET
25
LM118AU
(SB445) Q
Building 247
Extent of VOC Soil Contamination
(dashed where inferred)
J
Concrete
Ramp \
\
f N
/ \
/ I
J- k~"J
®LM116A
®LM120A
0)
3-
8
T>
-------
^Former Service Pit for US-T. Site 7
Filled with Concrete
SB096/
O
HP100/
Sump filled with sand
and capped with
Bldg. 206
SWMU 27
SB452 (Concrete Slab)
Former
Locomotive
Pit Filled with
5347-) -s. .^x. Concrete
SB451
• Area of
Excavation
Area of Excavation
65' x& *5' bgs
10' x 1O' x5' bgs
EXPLANATION
Phase I Monitoring Well Location
Previous Investigation Soil Boring Location
Phase I Soil Boring Location
Phase II Soil Boring Location
Phase III Soil Boring Location
Phase I Hydropunch Location
Phase III Hydropunch Location
CPT Location (Approximate)
Previous Investigation Soil-Gas Sample Location
Phase II Slant Soil Boring Location
Area of Excavtion
Railroad
Former Stairs
Edge ol Pavement
0 12.5 25
i^-5^^
SCALE IN FEET
Figure 9-11. SWMU 27/Area 1 - Conceptual Excavation Footprint
Defense Depot San Joaquin - Tracy Site
-------
T3
(0
§
•c
O
0)
O
I
"c
LU
Sewage
Lagoons
Northern
Depot
Soils
Storm Drain
Lagoon
100
Area 2
Area 1,
Bldg. 206
Area 1,
Bldg. 237
Day Care
Center
Bldg. 236 H
L'.
EXPLANATION
3 150 300
Scale in Feel
Railroad TracKs
Fence Line
Agricultural Area Dirt Access Road
Approximate Location of Possible Soil Contamination
Identified by WCC in the Comprehensive RI/FS Work Plan:
Area to be Paved
Figure 9-12.
Soil Contamination in Northern Depot
Investigated During the Comprehensive RI/FS
Defense Depot San Joaquin - Tracy Site
-------
Excavation and Off-site
Disposal
Components: Remove existing industrial
waste lagoon liners and partitions;
excavate lloor material of sewage
and industrial waste lagoons and
localized contaminant pockets.
Confirmation sampling will be
necessary during excavation.
Material that can be accepted
by landfill will be disposed off site
in a Subtitle D facility.
Excavate localized contaminant
pockets to specified depth
Excavate Floor to a
Depm of 2 Feet
Excavate Floor to a
Depth of 2 Feet
Excavate Floor to
a Depth of 2 Feet
Sewage
Treatment Plant
SCA1EINFECT
Legend
0
1
1 '
IRU emuem Intel
Sewage Treatment Plant
Effluent Intel
Formef Industnal
Wmewalei Intel
RaibOdO Tracks
Off-site Disposal of Industrial
Waste Lagoon Liners
Figure 9-13.
Selected Alternative for SWMUs 2 and 3
Defense Depot San Joaquin - Tracy Site
»EPCCM'.M1: Ml
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
10.0 STATUTORY
DETERMINATIONS
10.1 Sites Recommended for No
Further Action
Twenty-one sites at Defense Depot San Joaquin
(DDJC)-Tracy were recommended in the
comprehensive Remedial Investigation/
Feasibility Study (RI/FS) for no further action
due to the absence of contamination (see
Table 9-1). Two additional sites, solid waste
management units (SWMUs) 10A and 14, and
23 were recommended for no further action
because there is not an unacceptable risk to
human health or the environment and the cost of
a remedial alternative is prohibitive (see
Table 7-15). Because no remedial actions are
required for these sites, no discussion of
statutory requirements is needed.
10.2 Statutory Requirements
Section 9.0 identifies the selected remedy for
each site recommended for remedial action. This
section discusses how each selected remedy
meets the statutory requirements of the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
Section 121. Specifically, a remedy should:
• Protect human health and the environment;
• Comply with Applicable or Relevant and
Appropriate Requirements (ARARs) (or
justify an ARAR waiver);
• Be cost-effective;
• Utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent
practicable (also includes agency and
community acceptance); and
• Satisfy the preference for treatment to
reduce toxicity, mobility, or volume as a
principal element (or explain why this
preference is not valid).
10.3 Operable Unit (OU11
Groundwater
The selected remedy (Alternative 3) modifies
the OU1 ground water treatment system by
installing groundwater extraction wells in the
three areas of dieldrin contamination (near
SWMUs 2 and 3, SWMU 8, and within the
Tracy Annex). Granular activated carbon (GAC)
will be used to remove the pesticides.
10.3.1 Protection of Human Health and
the Environment
The selected remedy extracts and treats ground-
water from each of the three identified areas of
dieldrin contamination. Modeling results predict
that the cleanup standard of 0.05 micrograms
per liter (ng/L) for dieldrin will be met in
approximately 50 years at SWMUs 2/3 and 8.
However, more than 50 years will be required to
reduce the concentrations in the Tracy Annex
below the cleanup standard. Because dieldrin
has low mobility and is, therefore, difficult to
extract, a more aggressive pumping strategy will
not significantly affect the cleanup time. The
selected remedy will contain the dieldrin until
the cleanup standard is met and is, therefore,
protective of human health and the environment.
10.3.2 Compliance With ARARs
The selected remedy complies with all federal
and state ARARs. The cleanup standards
specified in the OU1 ROD (WCC, 1993) are
consistent with chemical-specific ARARs as
follows:
Chemical
Aquifer Cleanup
Standard Basis
DCE
PCE
TCE
6.0 ^g/L
5.0ng/L
5.0ng/L
California MCL
Federal MCL
Federal MCL
No ARAR waivers are necessary. No chemical-
specific ARARs (i.e., Maximum Contaminant
Levels [MCLs]) have been identified for
dieldrin. The California Action Level of
0.05 ng/L for dieldrin is a performance
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standard. The location-specific ARARs
identified for this site are listed in Table 10-1.
Action-specific ARARs for groundwater
extraction and treatment are listed in Table 10-2.
10.3.3 Cost-effectiveness
Groundwater extraction with GAC is the only
treatment alternative considered effective at
OU 1. Air stripping would remove the volatile
organic compounds (VOCs) but would not
remove the dieldrin in the groundwater. GAC
would remove both dieldrin and VOCs. The
incremental cost of adding treatment for dieldrin
is small compared to the total treatment system
cost. Alternative 3, the selected remedy, is the
only alternative that addresses all three areas of
dieldrin contamination. It provides the best
overall effectiveness proportional to the cost
($2,528,000) and is therefore considered cost-
effective. Reinjecting groundwater at this site
also is proposed as a cost-effective means for
disposal of treated water.
10.3.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.3.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected remedy
provides greater long-term effectiveness and
permanence than the other alternatives. The
mobility of the contaminants will be controlled
through extraction, and treatment will be used to
remove the dieldrin from the aquifer perma-
nently. The remedy provides short-term
effectiveness, is readily implementable, and is
considered the most cost-effective (although the
most costly) of the alternatives. No cost
effective treatment technologies with proven
effectiveness were identified. No resource
recovery techniques were appropriate for dilute
VOCs and pesticides.
10.3.4.2 The state and the United States
Environmental Protection Agency (U.S. EPA)
have accepted the feasibility study and concur
with the implementation of Alternative 3 as
recommended in this Record of Decision
(ROD).
10.3.4.3 One public comment was received
questioning the capacity of the reinjection wells
and the cost of groundwater treatment (refer to
Responsiveness Summary for discussion).
10.3.5 Preference for Treatment as a
Principal Element
The use of groundwater extraction, followed by
treatment by carbon (and air stripping if VOCs
are present) satisfies the statutory preference for
the use of remedies that include treatment as a
principal element.
10.4 Group A Sites
The Group A Sites (SWMU I/Area 2, Area 1
Building 237, and Area 3) are considered
potential sources of VOCs to OU 1 ground-
water. The selected remedy for the Group A
sites is soil vapor extraction (SVE)
(Alternative 3).
10.4.1 Protection of Human Health and
the Environment
The selected remedy is one of the two alterna-
tives considered the most protective of human
health and the environment. In the selected
remedy, VOCs are extracted from the soil and
treatment is provided at the surface to control air
emissions.
10.4.2 Compliance With ARARs
10.4.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for the
Group A sites are listed in Table 10-1. Action-
specific ARARs for SVE are listed in Table
10-3.
10.4.2.2 Background threshold concentrations
and beneficial use numerical limits for the
Group A sites are listed in Table 7-1.
Tables 10-4, 10-5, and 10-6 provide, for
SWMU I/ Area 2, Area 1 Building 237, and
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Area 3, respectively, an identification of the
ARARs. other factors that are involved in
developing cleanup standards, and the cleanup
standards themselves. The ARARs are the basis
for the cleanup standards developed. These
standards were developed meet ARARs and to
protect background groundwater quality and
beneficial uses in a way consistent with the
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.4.3 Cost-effectiveness
Only Alternatives 3 and 4 are protective of
human health and the environment; however,
Alternative 3 is much less costly to implement
than Alternative 4. Alternative 3 is estimated to
cost $648,000, whereas Alternative 4 is
estimated at $42,054,000. Because Alternative 3
provides comparable effectiveness to
Alternative 4 at a much lower cost. Alternative 3
is considered cost-effective. Also, the VOCs in
the soils at the Group A sites may be a
continuing source of VOCs in groundwater at
OU 1. Therefore, remediating the Group A sites
may significantly reduce the cost of ground-
water remediation at OU 1 by decreasing aquifer
cleanup times.
10.4.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.4.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. Alternatives 3 (SVE) and 4
(excavation) both satisfy the threshold criteria.
Alternative 3 was selected over Alternative 4
because it utilizes treatment to remove the
contaminants and is much more cost-effective.
The selected alternative provides long-term
effectiveness and permanence; reduces the
toxicity, mobility, and volume of the contami-
nants; provides short-term effectiveness; is
readily implementable; and is considered the
most cost-effective of the alternatives.
Alternative treatment methods were not
considered because SVE has been identified as
the presumptive method for treating VOCs in
vadose zone soils. No economical method of
recovering the VOCs was identified.
10.4.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the
implementation of Alternative 3.
10.4.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.4.5 Preference for Treatment as a
Principal Element
The use of SVE, followed by emissions treat-
ment, satisfies the statutory preference for the
use of remedies that include treatment as a
principal element.
10.5 SWMU 4—Storm Drain Lagoon
The selected remedy is excavation with off-site
disposal of the sediments (Alternative 3). All
sediment excavated from the bottom of the
storm drain lagoon will be disposed of off-site.
10.5.1 Protection of Human Health and
the Environment
The selected remedy is the only alternative that
removes chemicals of concern (COCs) (metals
and pesticides) from the lagoon. Confirmation
samples will be collected to ensure that the
excavation is protective of the environment. By
combining the action proposed in this ROD with
the appropriate best management practices for
stormwater pollution prevention, long-term
protection can be achieved. The lagoon will
remain in use as part of the DDJC-Tracy
stormwater system.
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10.5.2 Compliance With ARARs
10.5.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in
Table 10-3.
10.5.2.2 Background threshold concentrations
and beneficial use numerical limits for SWMU 4
are listed in Table 7-1. Table 10-7 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards.
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994). Table 10-8 identifies chemical-specific
disposal requirements.
10.5.2.3 The remedy includes the construction
of a sediment trap and overflow weir to comply
with the narrative toxicity water quality
objective for inland surface waters (Cal-EPA
CVRWQCB, 1994). National Ambient Water
Quality Criteria to protect freshwater life will be
used as performance standards to evaluate the
success of the selected remedy.
10.5.3 Cost-effectiveness
Alternative 3 is the only alternative protective of
human health and the environment. Therefore,
this alternative provides the most overall
effectiveness relative to its cost of S552.700.
10.5.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.5.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence that is better or comparable to the other
alternatives (because they do not remove the
existing contamination). Potential risks to
ecological receptors from pesticides and metals
in surface soil are reduced to a hazard index of
10 (see Table 10-7). Excavation is used to
remove the sediment from the lagoon
permanently. The five-year review process will
be used to assess the possibility of a continuing
low-level source. The remedy provides short-
term effectiveness, is readily implementable,
and is considered cost-effective. When
combined with the appropriate best management
practices as part of the DDJC-Tracy stormwater
program, this alternative best satisfies the five
balancing criteria. No cost-effective alternative
technologies or recovery techniques for treating
low concentrations of pesticides were identified.
10.5.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the imple-
mentation of Alternative 3 as recommended in
this ROD.
10.5.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.5.5 Preference for Treatment as a
Principal Element
The selected remedy relies on excavation with
off-site disposal rather than treatment. No
appropriate in situ methods were identified for
treating the SVOCs and pesticides in the
sediment at the bottom of the lagoon. Treating
the excavated soil (on or off site) is not cost-
effective due to the relatively small quantity of
soil excavated, the cost for tests to identify an
appropriate treatment process, and the cost of
treatment.
10.6 SWMU 6—Building 28 Sump
The selected remedy is excavating the
contaminated soils and disposing of them at an
off-site disposal facility (Alternative 4).
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10.6.1 Protection of Human Health and
the Environment
The selected remedy removes the potential
threats that pesticides pose to the beneficial uses
of groundwater and background groundwater
quality. The selected remedy is considered the
most effective of the alternatives for protecting
human health and the environment.
10.6.2 Compliance With ARARs
10.6.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in
Table 10-3.
10.6.2.2 Background threshold concentrations
and beneficial use numerical limits for SWMU 6
are listed in Table 7-1. Table 10-9 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to meet ARARs and
protect background groundwater quality and
beneficial uses in a way consistent with the
chemical-specific performance standards of the
Water Quality Goals established in Basin Plan
for the Central Valley Region - Sacramento
River and San Joaquin River Basins (Cal-EPA
CVRWQCB, 1994).
10.6.3 Cost-effectiveness
Only Alternatives 3 and 4 are protective of
human health and the environment; however,
Alternative 4 is much less costly to implement
than Alternative 3. Alternative 4 is estimated to
cost between $45,000 and $65,000, whereas
Alternative 3 is estimated at $169,000. Because
the selected excavation and off-site disposal
action of Alternative 4 provides comparable or
better effectiveness than Alternative 3 at lower
cost. Alternative 4 is considered a cost-effective
remedy. In addition, excavation probably costs
less than maintaining the long-term institutional
controls of Alternative 2.
10.6.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.6.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence, reduces the volume of the contaminants,
provides short-term effectiveness, is readily
implementable, and is considered cost-effective.
No cost-effective alternative treatment
technologies or resource recovery techniques
were identified for low levels of pesticide
contamination.
10.6.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the imple-
mentation of Alternative 4 as recommended in
this ROD.
10.6.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.6.5 Preference for Treatment as a
Principal Element
The selected remedy relies on excavation with
off-site disposal rather than treatment. No
appropriate in situ methods were identified for
treating the pesticides in the soil. Treating the
excavated soil (on or off site) would not be cost-
effective due to the relatively small quantity of
soil excavated, the cost for tests to identify an
appropriate treatment process, and the cost of
treatment. In situ stabilization is considered in
Alternative 3 as a treatment option, but there are
uncertainties regarding its long-term effective-
ness and it is less cost-effective.
10.7 SWMU 7— Burn Pit No. 1
The selected remedy for SWMU 7 is institu-
tional controls (Alternative 2). The planned
institutional controls include land use restric-
tions around the disposal pits. The restrictions
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would designate the land for industrial use and
prevent its use for schools, hospitals, play-
grounds, or housing until COCs are below levels
of concern. The institutional controls also
restrict construction in and the demolition of
Buildings 19 and 21. In addition, the remedy
includes the use of monitoring to evaluate the
effectiveness of these controls in protecting the
beneficial uses of groundwater.
10.7.1 Protection of Human Health and
the Environment
The selected remedy is protective of human
health for both current and future exposure
scenarios. Groundwater monitoring is used to
identify potential impacts to groundwater that
were identified in the water quality site assess-
ment. The analyte concentrations that would
require analysis in the Well Monitoring Program
are specified in Section 9.5.3. Institutional
controls for Buildings 19 and 21 and ground-
water monitoring are continued at least until the
first five-year review and the need for continued
controls will be reevaluated at that time.
10.7.2 Compliance With ARARs
10.7.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for institutional controls are listed in
Table 10-3.
10.7.2.2 Background threshold concentrations
and beneficial use numerical limits for SWMU 7
are listed in Table 7-1. Table 10-10 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect groundwater
quality and beneficial uses, consistent with the
chemical-specific in performance standards of
the Water Quality Goals established in Basin
Plan for the Central Valley Region -
Sacramento River and San Joaquin River Basins
(Cal-EPA CVRWQCB, 1994).
10.7.3 Cost-effectiveness
Alternatives 2 through 4 are considered protec-
tive of human health and the environment.
Long-term threats to groundwater have not been
confirmed and the long-term monitoring of the
selected remedy (Alternative 2) would identify
any potential concerns and require discussing in
the Well Monitoring Program if a concern is
identified. The selected remedy costs $208,000
to implement; Alternatives 3 and 4 cost
significantly more at $822,000 and $2,605,000
respectively. Therefore, the selected remedy
provides the most cost-effective remedy at
SWMU 7.
10.7.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.7.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. Given that groundwater
contamination has not been detected and much
of the soil is underneath Buildings 15, 18, 19
and 21, the cost of a more aggressive alternative
does not appear warranted. The long-term
effectiveness is assessed through monitoring.
The toxicity, mobility, and volume of contami-
nants will not be reduced; however, much of the
soil is already covered by pavement or
buildings, so contaminant migration is limited.
The selected remedy provides short-term
effectiveness, is readily implementable, and is
considered cost-effective. No cost-effective
alternative treatment technologies or resource
recovery techniques were identified for low
levels of pesticide contamination.
10.7.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the imple-
mentation of Alternative 2 as recommended in
this ROD.
10.7.4.3 One public comment expressed
concern over the cost of excavation (Alternative
4) and potential exposure to excavated soils.
The comment also expressed interest in
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
encapsulation (Alternative 3) (refer to
Responsiveness Summary for discussion).
10.7.5 Preference for Treatment as a
Principal Element
The selected remedy relies on institutional
controls rather than treatment. The potential
threat to the beneficial uses of groundwater has
not been confirmed through historical
monitoring. Also, portions of the SWMU 7
burial pits are covered by buildings. Treatment
would be expensive and very difficult to
implement at this site.
10.8 SWMU 8—Burn Pit No. 2
The selected remedy is excavating the contami-
nated soils from the former burn pit and
disposing of them at a Class I disposal facility
(Alternative 4).
10.8.1 Protection of Human Health and
the Environment
The selected remedy provides the greatest
protection of human health and the environment.
Contaminated soils (containing SVOCs,
pesticides, herbicides, and petroleum hydro-
carbons) are permanently removed from the site
and disposed of at a Class I disposal facility.
10.8.2 Compliance With ARARs
10.8.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in
Table 10-3.
10.8.2.2 Background threshold values and
beneficial use numerical limits for SWMU 8 are
listed in Table 7-1. Table 10-11 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.8.3 Cost-effectiveness
Only Alternative 4 is protective of human health
and the environment. The estimated cost for
Alternative 4 is $2,823,000. SWMU 8 is a major
potential source area for dieldrin contamination
in groundwater at OU 1. As explained in Section
10.4.3, it is considered more cost-effective to
address source areas than to extend operation of
the OU 1 groundwater treatment system.
Therefore, the selected excavation and off-site
disposal action of Alternative 4 is considered a
cost-effective remedy.
10.8.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.8.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence, reduces the volume of the contaminants,
provides short-term effectiveness, is readily
implementable, and is considered cost-effective.
None of the other alternatives satisfied the
threshold criteria as well as the selected remedy.
There is a trade-off between cost and satisfying
the other four balancing criteria. The additional
cost is considered justified, and the alternative is
considered cost-effective. No cost-effective
alternative treatment technologies or recovery
techniques were identified for low levels of
pesticide contamination.
10.8.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the imple-
mentation of Alternative 4 as recommended in
this ROD.
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10.8.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.8.5 Preference for Treatment as a
Principal Element
The selected remedy relies on excavation with
off-site disposal rather than treatment. No
appropriate in situ methods were identified for
treating the pesticides in the soil. Bioventing
was evaluated, but was not as effective as the
selected remedy in addressing pesticide
contamination at the site (dieldrin is of
particular concern).
10.9 SWMU 20 Aboveqround
Solvent Tank Building 26
Recoup Operations and Area 1
Building 10
The selected remedy includes soil vapor
extraction, excavation with disposal at a Class I
disposal facility, and natural attenuation
(Alternative 3).
10.9.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. A portion of
the contaminated soils (containing SVOCs,
pesticides, and petroleum hydrocarbons) is
permanently removed from the site and disposed
of at a Class I disposal facility. The remaining
soils are treated by SVE and natural attenuation.
The selected remedy addresses all existing site
risks and potential impacts to groundwater.
10.9.2 Compliance With ARARs
10.9.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for SVE and excavation and disposal
are listed in Table 10-3.
10.9.2.2 Background threshold values and
beneficial use numerical limits for SWMU 20
are listed in Table 7-1. Table 10-12 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.9.3 Cost-effectiveness
Only Alternatives 3 and 4 are protective of
human health and the environment. Alternative
3, soil vapor extraction with excavation,
provides comparable effectiveness to the larger
excavation remedy of Alternative 4; however,
Alternative 3 is less costly to implement.
Alternative 3 is estimated to cost $293,000,
whereas Alternative 4 is estimated at $355,000.
Therefore, Alternative 3 is considered the most
cost-effective alternative.
10.9.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.9.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence, reduces the volume of the contaminants,
provides short-term effectiveness, is readily
implementable, and is considered cost-effective.
A larger excavation (Alternative 4) could be
marginally more effective, but is also more
difficult to implement and more expensive. No
cost-effective alternative treatment technologies
or recovery techniques were identified for low
levels of pesticide contamination.
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10.9.4.2 The state and U.S. EPA have accepted
the feasibility study and concur with the
implementation of Alternative 3 as
recommended in this ROD.
10.9.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.9.5 Preference for Treatment as a
Principal Element
The selected remedy relies on a combination of
treatment (SVE), excavation with off-site
disposal, and natural attenuation. The excava-
tion is limited and addresses the soil beneath the
sumps and floor drains associated with
Buildings 10 and 26. The phenols are expected
to attenuate naturally. Per the request of the
Regional Water Quality Control Board
(RWQCB), predesign soil-gas sampling will be
performed in areas designated for SYE
remediation and the results may expand the size
of the area targeted for SVE treatment.
10.10 SWMU 24—Petroleum Waste
Oil Tank
The selected remedy for SWMU 24 is
bioventing (Alternative 3). However, predesign
soil gas sampling will be conducted to
determine if SVE also needs to be implemented.
10.10.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. Potential
threats to background groundwater quality and
beneficial uses from VOCs, SVOCs, and
petroleum hydrocarbons are permanently
eliminated. Although bioventing does not
enhance the biodegradation of polychlorinated
biphenyls (PCBs), the threat posed to ground-
water by PCBs is low relative to the threat posed
by other COCs. The remedy includes three
quarters of monitoring data to assess the natural
attenuation of petroleum hydrocarbons in
groundwater. Potential risks to future depot
workers are eliminated by this remedy.
10.10.2 Compliance With ARARs
10.10.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for bioventing are listed in Table 10-3.
10.10.2.2 Background threshold values and
beneficial use numerical limits for SWMU 24
are listed in Table 7-1. Table 10-13 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.10.3 Cost-effectiveness
Alternative 4 is considered cost-effective
because pesticides and PCBs are permanently
removed from the site. Alternatives 3 and 5 are
also considered cost-effective because long-term
threats to groundwater from pesticides and
PCBs are considered relatively low at SWMU
24. Alternative 3 is the least costly of these
alternatives to implement ($166,000 as
compared to $214,000 for Alternative 4 and
$263,000 for Alternative 5). Therefore,
Alternative 3 provides the most cost-effective
remedy for the site.
10.10.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.10.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
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extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence, reduces the toxicity and volume of the
contaminants, provides short-term effectiveness,
is readily implementable, and is considered cost-
effective. Excavation (Alternatives 4 and 5) is
only marginally more effective, more difficult to
implement (since excavation under Building 247
would be required), and more costly. No cost-
effective alternative treatment technologies or
recovery techniques were identified for low
levels of pesticide contamination.
10.10.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 3 as
recommended in this ROD.
10.10.4.3 One public comment expressing
concern over the high cost of excavation
(Alternatives 4 and 5) and potential exposure to
excavated soil was received (refer to
Responsiveness Summary for discussion).
10.10.5 Preference for Treatment as a
Principal Element
The use of bioventing satisfies the statutory
preference for the use of remedies that include
treatment as a principal element.
10.11 SWMU 27—Building 206
Roundhouse Sump/Area 1
Building 206
The selected remedy is excavating contaminated
soil and disposing of it at a Class I disposal
facility (Alternative 3).
10.11.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. Potential
threats to background groundwater quality and
beneficial uses from VOCs, pesticides, and
herbicides are permanently eliminated. Potential
risks to future depot workers and the environ-
ment are also eliminated.
10.11.2 Compliance With ARARs
10.11.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in
Table 10-3.
10.11.2.2 Background threshold limits and
beneficial use numerical limits for SWMU 27
are listed in Table 7-1. Table 10-14 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.11.3 Cost-effectiveness
Alternative 3 is the only alternative protective of
human health and the environment and therefore
provides the most overall effectiveness relative
to its cost of $112,000. Depending on the level
of contamination in the excavated soil,
Alternative 3 may be less expensive than the
long-term costs of implementing institutional
controls.
10.11.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.11.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence, reduces the volume of the contaminants,
provides short-term effectiveness, is readily
implementable, and is considered cost-effective.
No cost-effective alternative treatment
SEC-IO.DOC
10-10
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
technologies or recovery techniques were
identified for low levels of pesticide
contamination.
10.11.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 3 as
recommended in this ROD.
10.11.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.11.5 Preference for Treatment as a
Principal Element
The selected remedy relies on excavation with
off-site disposal rather than treatment. No
appropriate in situ methods were identified for
treating the pesticides in the soil. Treating the
excavated soil (on or off site) will not be cost-
effective due to the relatively small quantity of
soil excavated, the cost for tests to identify an
appropriate treatment process, and the cost of
treatment.
10.12 Building 30 Drum Storage Area
The selected remedy for the Building 30 Drum
Storage Area is institutional controls with
groundwater monitoring (Alternative 2).
10.12.1 Protection of Human Health and
the Environment
Baseline risk assessment results do not indicate
potential adverse risks to depot workers or
future construction workers. A potential threat
to background groundwater quality was
identified; however, the COCs have not been
detected in the groundwater at this site.
Modeling suggests a future threat to ground-
water is possible. The selected remedy protects
human health and the environment by requiring
monitoring and discussion in the Well
Monitoring Program if a concern is identified.
The analyte concentrations that would require
analysis in the Well Monitoring Program are
identified in Section 9.5.8.
10.12.2 Compliance With ARARs
10.12.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for institutional controls are listed in
Table 10-3.
10.12.2.2 Background threshold concentra-
tions and beneficial use numerical limits for the
Building 30 Drum Storage Area are listed in
Table 7-1. Table 10-15 provides an identifica-
tion of the ARARs, other factors that are
involved in developing cleanup standards, and
the cleanup standards themselves. The ARARs
are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses,
consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.12.3 Cost-effectiveness
Alternatives 2 and 3 are considered protective of
human health and the environment. Long-term
threats to groundwater from the drum storage
area have not been confirmed and the long-term
monitoring of Alternative 2 would identify any
future concerns. Alternative 2, institutional
controls, costs $87,000 to implement.
Alternative 3, excavation and off-site disposal,
costs significantly more at $1,860,000.
Excavation is considered cost-prohibitive
because of the difficulty of excavating beneath a
building where sensitive robotics activities are
conducted. Therefore, Alternative 2 provides the
most cost-effective remedy for the site.
SEC-IO.DOC
10-11
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
10.12.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.12.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected alternative
provides long-term effectiveness and
permanence, provides short-term effectiveness
as groundwater monitoring will identify any
short-term impacts, is readily implementable,
and is considered cost-effective. To ensure that
the threshold criteria are met, the institutional
controls include installing a monitoring well and
quarterly monitoring for SVOCs for one year to
confirm that there is no threat to background
groundwater quality. No cost-effective
alternative treatment technologies or recovery
techniques were identified for low levels of
phthalate contamination.
10.12.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 2 as
recommended in this ROD.
10.12.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.12.5 Preference for Treatment as a
Principal Element
The selected remedy relies on institutional
controls rather than treatment. The potential
threat to the beneficial uses of groundwater has
not been confirmed through historical
monitoring. Further groundwater monitoring
will be performed to assess the success of
institutional controls.
10.13 Surface and Near-Surface
Soils—Northern Depot Area
The selected remedy for the surface and near-
surface soils in the Northern Depot Area is
installing an asphalt cover (Alternative 3).
10.13.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. No impacts
to background groundwater quality or beneficial
uses were identified at this site. The installation
of an asphalt cap, to be maintained by
DDJC-Tracy, will prevent depot workers (grader
operators) from being exposed to arsenic and
manganese in the surface and near-surface soils
in the area. The lifetime of the cap is estimated
at 20 years as long as annual or semiannual
sealing is provided.
10.13.2 Compliance With ARARs
The selected remedy complies with all federal
and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for asphalt cover installation are listed
in Table 10-3. No COCs were identified as
impacting groundwater quality at this site. The
cleanup standards (Section 9.5.9.3) correspond
to a hazard index of 1.0 for grader operators.
10.13.3 Cost-effectiveness
Alternatives 3 and 4 are the only alternatives
that provide long-term effectiveness for the
surface and near-surface soils in the Northern
Depot Area. Alternative 3, asphalt paving, costs
significantly less than the excavation and off-
site disposal proposed in Alternative 4.
Alternative 3 is estimated at $504,000, whereas
Alternative 4 is estimated to cost between
$769,000 and $995,000, depending on the level
of contamination in the soil. Because
Alternative 3 provides comparable worker
protection to Alternative 4, Alternative 3 is
considered highly effective relative to its cost.
10.13.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.13.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
SEC-10.DOC
10-12
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
extent practicable. The selected alternative
provides long-term effectiveness and perma-
nence (the asphalt cover will need to be main-
tained by DDJC-Tracy), reduces the mobility of
the contaminants, provides short-term
effectiveness, is readily implementable, and is
considered cost-effective. No alternative
treatment technologies or recovery techniques
were identified for low levels of disperse metals.
10.13.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 3 as
recommended in this ROD.
10.13.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.13.5 Preference for Treatment as a
Principal Element
The selected remedy relies on containment
rather than treatment. The asphalt cover will
protect workers from exposure to arsenic and
manganese in the soils. The size of the Northern
Depot Area and nature of the contamination
preclude a cost-effective approach for treatment.
10.14 SWMUs 2 and 3—Sewage and
Industrial Waste Lagoons
The selected remedy is excavation with off-site
disposal (Alternative 3).
10.14.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. Risks to
human health and threats to beneficial uses and
background groundwater quality are addressed
by excavation. Impacts to ecological receptors
will be addressed by installing a geofabric filter
and clean backfill to isolate contaminants from
receptors.
10.14.2 Compliance With ARARs
10.14.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action-specific
ARARs for institutional controls are listed in
Table 10-3.
10.14.2.2 Background threshold values and
beneficial use numerical limits for SWMUs 2/3
are listed in Table 7-1. Table 10-16 provides an
identification of the ARARs, other factors that
are involved in developing cleanup standards,
and the cleanup standards themselves. The
ARARs are the basis for the cleanup standards
identified. These standards rely on the best
practicable technology to protect background
groundwater quality and beneficial uses in a
way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region • Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.14.3 Cost-effectiveness
The selected remedy is the only alternative that
is protective of human health and the environ-
ment. The estimated cost is approximately
$2,100,000. It is considered more cost-effective
to address the soil source area than to extend the
operation of the OU 1 groundwater treatment
system. Therefore, excavation and off-site
disposal is considered a cost-effective remedy.
10.14.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.14.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected remedy
provides short- and long-term effectiveness and
permanence, reduces the volume of the
contaminants, is readily implementable, and is
considered cost-effective. No cost-effective
alternative treatment technologies or recovery
SEC-IO.DOC
10-13
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
techniques were identified for low levels of
pesticide contamination.
10.14.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 3 as
recommended in this ROD.
10.14.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.14.5 Preference for Treatment as a
Principal Element
The selected remedy relies on excavation rather
than treatment. No appropriate in situ methods
were identified for permanently treating the
pesticides in the soils.
10.15 SWMU 33—Industrial Waste
Pipeline (IWPL)
The selected remedy for the IWPL is grouting,
limited excavation, and institutional controls
(Alternative 3). The institutional controls
include groundwater monitoring to identify
potential impacts to background groundwater
quality from the aldrin, dieldrin, diethyl-
phthalate, and di-n-butylphthalate that will
remain after the excavation is completed.
Section 9.6.2 identifies the beneficial use limits
that cannot be exceeded in the groundwater
samples without requiring discussion in the
Well Monitoring Program.
10.15.1 Protection of Human Health and
the Environment
The selected remedy provides protection of
human health and the environment. No risks to
human health or ecological receptors were
identified for SWMU 33. A portion of the
contaminants will be removed in the excavation.
Groundwater monitoring is specified to assess
any impact of the residual soils on groundwater
quality.
10.15.2 Compliance With ARARs
10.15.2.1 The selected remedy complies with
all federal and state ARARs. No ARAR waivers
are necessary. Location-specific ARARs for this
site are listed in Table 10-1. Action specific
ARARs for excavation and institutional controls
are listed in Table 10-3. Table 10-8 lists waste
soil and sediment hazardous waste levels for
both the total and leachable portion of
constituents from 22 CCR Division 4.5,
Section 66261.
10.15.2.2 Background threshold values and
beneficial use numerical limits for the SWMU
33 are listed in Table 7-1. Table 10-17 provides
an identification of the ARARs, other factors
that are involved in developing cleanup
standards, and the cleanup standards themselves.
The ARARs are the basis for the cleanup
standards identified. These standards rely on the
best practicable technology to protect back-
ground groundwater quality and beneficial uses
in a way consistent with the chemical-specific
performance standards of the Water Quality
Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San
Joaquin River Basins (Cal-EPA CVRWQCB,
1994).
10.15.3 Cost-effectiveness
Alternative 3 is considered cost-effective
because contamination along the IWPL does not
appear to be impacting groundwater at this time.
The limited excavation, grouting, and
institutional controls in Alternative 3 are
estimated to cost $242,600 and will be effective
in detecting any future groundwater concerns.
10.15.4 Utilization of Permanent
Solutions, Alternative Treatment,
and Resource Recovery
10.15.4.1 The selected remedy uses permanent
solutions and alternative technologies or
resource recovery technologies to the maximum
extent practicable. The selected remedy may not
prevent soil contaminants from migrating to
groundwater; however, the removal action
SEC-IO.DOC
10-14
17 February 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
addresses the most contaminated areas, and
most of the area in question is paved. In
addition, the selected remedy represents imple-
mentation of the best practicable technology,
consistent with SWRCB Resolution No. 68-16.
The groundwater monitoring program specifies
beneficial use limits that cannot be exceeded
without discussion in the Well Monitoring
Program. The mobility, toxicity, and volume of
the contaminants will be reduced through
limited excavation. The selected remedy
provides short-term effectiveness and is
implementable. It is considered the most cost-
effective of the alternatives. The cost-benefit
analysis indicates that it is more cost-effective
to rely on the OU 1 groundwater treatment
system to address pesticides flushed from the
vadose zone than to further excavate the
contaminated soils. No cost-effective alternative
treatment technologies or recovery techniques
were identified for low levels of pesticide
contamination.
10.15.4.2 The state and U.S. EPA have
accepted the feasibility study and concur with
the implementation of Alternative 2 as
recommended in this ROD.
10.15.4.3 One public comment expressing
concern over the high cost of excavation and
potential exposure to excavated soil was
received (refer to Responsiveness Summary for
discussion).
10.15.5 Preference for Treatment as a
Principal Element
The selected remedy relies on limited excava-
tion, grouting, and institutional controls rather
than treatment. Further treatment beyond that
proposed in the selected remedy is not
considered cost-effective. Further groundwater
monitoring will be performed to assess the
success of the selected remedy.
SEC-IO.DOC 10-15 17 February 1998
-------
o
Table 10-1. Compliance With Location-Specific ARARS
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARARs, or
Performance Standard
(for NPL Sites)
Compliance
3.
4.
Nal'l Historic
Preservation Act
(16U.S.C. §461-
467)
Endangered
Species Act
NA
50 CFR 17
Executive Order
11988,
Protection of
Flood Plains
40 CFR 6, Section 6.302(b)
California Fish
and Game Code
Division 6, Part 1,
Chapter 6
No building or location at DDJC-Tracy
has been considered for the National
Registry of Historic Sites.
Several species on both the federal and
state endangered or threatened species
lists are found in the vicinity of DDJC-
Tracy. Any remedial action taken at
the site must not jeopardize these
species.
Relates to actions that will occur in a
flood plain, i.e., lowlands and relatively
flat areas adjoining inland and coastal
waters and other flood-prone areas.
Actions must be taken to avoid adverse
effects, minimize potential harm,
restore and preserve natural and
beneficial values.
This statute prohibits Ihe deposition of
any substance deleterious to fish, plant,
or bird life where the substance can
pass into the waters of the state. This
code may apply to the Storm Drain
Lagoon (SWMU 4).
Not applicable.
Applicable.
Applies to remedial actions
taken at all DDJC-Tracy
sites.
Not applicable.
DDJC-Tracy docs not lie
within a floodplain area.
NA
No known rare or endangered
species have been observed at the
depot. There is no reason to
believe that planned remedial
actions will jeopardize any
endangered or threatened species.
NA
Applicable.
May apply to the Storm
Drain Lagoon (SWMU 4).
No deleterious substances will be
deposited in the Storm Drain
Lagoon.
D
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n
3
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o
No.
Source
Table 10-2. Compliance With Action-Specific ARARs for OU 1 Groundwater Remediation
Standard,
Requirement,
Criterion, or Limitation Description
ARAR or Performance
Standard Applicability
Compliance
Porter-Cologne
Water Quality
Control Act
(California Water
Code Section 13000
el seq.).
California Water Code
Section 13243.
The RWQCB may specify
certain conditions or areas where
the discharge of waste, or certain
types of waste, is not permitted.
Applicable. Applies (o
groundwater remedial actions.
The location of the treated
water discharge and waste
discharge standards will be
approved by the RWQCB
before the discharge occurs.
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13304,
13240, 13241,
13242, 13243).
Water Quality Control Plan
(Basin Plan) for the
RWQCB, Central Valley
Region.
RWQCB, Central Valley
Region Basin Plan, "Policy
for Investigation and
Cleanup of Contaminated
Sites."
Establishes water quality
objectives, including narrative
and numerical standards, (hat
protect the beneficial uses and
water quality objectives of
surface and ground waters in the
region. Describes implementa-
tion plans and other control
measures designed to ensure
compliance with statewide plans
and policies and provide
comprehensive water quality
planning.
Establishes and describes policy
for investigating and remediating
contaminated sites. Also
includes implementation actions
for setting groundwater and soil
cleanup standards.
Applicable. Specific
applicable portions of (he
Basin Plan include beneficial
uses of affected water bodies
and water quality objectives to
protect those uses. Any
activity, including but not
limited to the discharge of
contaminated soils or waters
or in situ treatment or
containment of contaminated
soils or waters, must not result
in actual water quality
exceeding water quality
objectives.
Applicable. Cleanup
standards for OU I
groundwater should be equal
(o background concentrations
unless such standards are
technically and economically
infcasiblc to achieve. In such
cases, cleanup standards
should not exceed applicable
water quality objectives.
Beneficial uses were
considered in establishing
cleanup standards for
groundwater contaminants.
The most stringent federal or
state objective was selected
as the appropriate cleanup
standard. The waste
discharge standards
developed for treated
groundwater are protective of
groundwater quality.
Cleanup standards do not
exceed the applicable water
quality objectives. It has been
demonstrated in (he RI/FS
that it is not economically
feasible to reduce
contaminant concentrations
to background levels.
S
00
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a)
r
Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
9
00
Porlcr-Colognc
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242. 13243).
RWQCB, Central Valley
Region Basin Plan, "Policy
for Application of Water
Quality Objectives."
RWQCB, Central Valley
Region Basin Plan,
"Wastcwaler Reuse
Policy."
This policy defines water quality
objectives and explains how the
Regional Water Board applies
the numerical and narrative
water quality objectives to
ensure the reasonable protection
of beneficial uses of water and
how the Regional Water Board
applies Resolution No. 68-16 to
promote the maintenance of
existing high-quality waters.
Requires applicants for waste
discharge requirements and
discharge permits to evaluate
land disposal as an alternative to
discharge to surface waters.
Applicable. Applies to OU 1
groundwatcr remedial actions.
Water quality objectives were
defined and are consistent
with the referenced sections.
Applicable. Applies to
groundwater extracted by the
OU 1 groundwater treatment
system.
Rcinjcction of treated
groundwater will be pursued
as the primary disposal
method. Treated groundwalcr
that cannot be rcinjcctcd will
be disposed to the percolation
ponds.
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-------
o
Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
Porter-Cologne
Water Quality
Control Acl
(California Water
Code Sections
13000, I3140,
13263, 13304).
State Water Resources
Control Board Resolution
No. 68-16 ("Anti-
degradation Policy").
9
vO
Requires that high-quality
surface and ground waters be
maintained to the maximum
extent possible. Degradation of
waters is allowed (or allowed to
remain) only if it is consistent
with the maximum benefit to the
people of the state, does not
unreasonably affect present and
anticipated beneficial uses, and
does not result in water quality
less than that prescribed in
RWQCB and SWRCB policies.
If degradation is allowed, the
discharge must meet best
practicable treatment or control,
which must prevent pollution or
nuisance and result in the highest
water quality consistent with
maximum benefit to the people
of the state.
Applicable. Applies to
discharges of waste to waters,
including discharges to soil
that may affect surface or
ground waters. In situ cleanup
standards for contaminated
groundwater must be set at
background level, unless
allowing continued
degradation is consistent with
the maximum benefit to the
people of the state. If
degradation of waters is
allowed or allowed to remain,
(he discharge must meet best
practicable treatment or
control standards, and result in
the highest water quality
possible that is consistent with
the maximum benefit to the
people of the stale. In no case
may water quality objectives
be exceeded.
DDJC-Tracy will apply best
practicable treatment or
control method for ground
water remediation. Water
quality objectives will not be
exceeded.
O
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I
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-------
00
f
Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000,13140, 13240,
13260, 13263,
13267, 13300,
13304. 13307).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13240).
State Water Resources
Control Board Resolution
No. 92-49 (as amended
21 April 1994).
State Water Resources
Control Board Resolution
No. 88-63 ("Sources of
Drinking Water Policy")
(as contained in the
RWQCB's Water Quality
Control Plan).
Establishes requirements for
investigation, cleanup, and
abatement of discharges.
Among other requirements,
dischargers must clean up and
abate the effects of discharges in
a manner that promotes the
attainment of either background
water quality, or the best water
quality that is reasonable if
background water quality cannot
be restored. Requires the
application of Title 23, CCR,
Section 2550.4 requirements to
cleanups.
Specifies that, with certain
exceptions, all groundwatcrs and
surface waters must have the
beneficial use of municipal or
domestic water supply.
Applicable. Applies to
groundwater remedial actions.
The groundwater cleanup
system will be operated in
such a way that the best
water quality reasonable is
restored. The requirements of
Chapter 15 will be met.
Applicable. Applies in
determining beneficial uses for
waters that may be affected by
discharges of waste.
Water use as municipal or
domestic water supply used
as a basis for determining
beneficial use limits.
O
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Table 10-2. (Continued)
o
KJ
No.
10
to
I
s
00
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260, 13263,
13267, 13304).
Title 27, CCR, Division 2,
Subdivision 1 (Section
20080 ctseq.)
Title 23, CCR, Division 3,
Chapter 15 (Section 2510
et seq,).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172.13260.13263,
13267.13304).
Title 27.CCR. Section
20090(d),
Title 23, CCR, Section
2511(d).
Establishes waste and siting
classification systems and
minimum waste management
standards for discharges of waste
to land for treatment, storage,
and disposal. Engineered
alternatives that are consistent
with the Title 27/Title 23
performance goals may be
considered. Establishes
corrective action requirements
for responding to discharges to
land, including spills, leaks, and
other unauthorized discharges.
Actions taken by public agencies
to cleanup unauthorized releases
are exempt from Title 27/Title
23 accept that wastes removed
from immediate place of release
and discharged to land must be
managed in accordance with the
classification (Title 27.CCR
.Section 20200 /Title 23. CCR.
Section 2520) and siting
requirements of Title 27 or Title
23 and wastes contained or left
in place must comply with Title
27 or Title 23 to the extent
feasible.
The application of specific
sections of Title 27/Titlc 23 is
discussed below. Provisions
of Title 23 apply to hazardous
waste and provisions of Title
27 apply (o designated and
nonhazardous solid waste.
Applicable. Applies to
remediation and monitoring of
sites.
See specific requirements
discussed below under
Porter-Cologne Water
Quality Control Act.
Ground water will be
remediated and monitored
according to Title 27/TitIc 23
regulations.
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8
Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
ll
12
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260, 13263,
13267, 13304).
Title 27, CCR, Section
20400,
Title 23, CCR, Section
2550.4.
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260, 13263,
13267, 13304).
Title 27, CCR, Section
20410,
Title 23. CCR, Section
2550.6
Cleanup standards must be set at
background concentration levels,
or, if background levels arc not
technologically and
economically feasible, then at
the lowest levels that are
economically and
technologically achievable.
Specific factors must be
considered in setting cleanup
standards above background
levels.
Requires monitoring for
compliance with remedial action
objectives for three years from
the date of achieving cleanup
standards.
Relevant and Appropriate.*
Applies in setting groundwater
cleanup standards for all
discharges of waste to land.
Relevant and Appropriate.*
Applies to OU 1 groundwater
remedial actions.
Attainment of background
levels for dicldrin is not
technologically or
economically feasible.
Cleanup standards above
background levels will be
evaluated every five years. If
the actual concentration of a
constituent is lower than its
associated cleanup standard,
the cleanup standard shall be
lowered to reflect existing
water quality.
Post-cleanup monitoring will
be conducted in accordance
with these provisions.
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Table 10-2. (Continued)
No.
13
14
to
I
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260, 13263,
13267. 13304).
Title 27, CCR, Section
20415,
Title 23, CCR, Section
2550.7.
Requires general soil, surface
water, and groundwater
monitoring.
Relevant and Appropriate.'
Applies to all areas at which
waste has been discharged to
land.
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260, 13263,
13267. 13304).
Title 27, CCR, Section
20425,
Title 23, CCR, Section
2550.9.
Requires an assessment of the
nature and extent of the release,
including a determination of the
spatial distribution and
concentration of each
constituent.
Relevant and Appropriate.1
Applies to areas at which
monitoring results show
statistically significant
evidence of a release.
Monitoring will be
conducted, accordance with
the requirements of Title 27
Article 5/Title 23 Article 5
for all ground water at the
facility subject to
remediation. The agencies
will be provided with
quarterly and annual
monitoring reports as part of
the site-wide ground water
Well Monitoring Program
which covers assessment of
ground water at the facility
during the implementation of
soil and ground water
remedial actions.
Further assessment of the
nature and extent of releases
to ground water is ongoing as
part of implementing the
ground water remedial
actions.
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Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
15 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147. 13172,
13260, 13263,
13267, 13304).
Title 27, CCR, Section
20430,
Title 23. CCR, Section
2550.10
Requires implementation of
corrective action measures that
ensure that cleanup standards arc
achieved throughout the zone
affected by the release by
removing the waste constituents
or treating them in place. Source
control may be required. Also
requires monitoring to determine
(he effectiveness of the
corrective actions.
Relevant and Appropriate.'
Applies to groundwater
remedial actions.
Corrective action measures
will be implemented and the
actions will be monitored (o
assess effectiveness.
16
17
•a
$
California Safe
Drinking Water Act
(California Health &
Safety Code Section
4010ef seq.).
Title 22, CCR, Section
64400 et seq.
Staff Report of the
RWQCB, Central
Valley Region.
"A Compilation of Water
Quality Goals."
Requirements for public water
systems; includes Maximum
Contaminant Levels (MCLs) and
Secondary Maximum
Contaminant Levels (SMCLs).
SDWA standards for this
cleanup action are 6 ng/L for
DCE. Standards for TCE and
PCE arc established by the
Federal Safe Drinking Water
Act.
Provides guidance on selecting
numerical values to implement
narrative water quality
objectives contained in the Basin
Plan.
Relevant and appropriate. The
act is legally applicable for an
aquifer and associated
distribution and prc-treatment
system that is currently
defined as a "public water
system." If it is only a
potential "public water
system," then the act is
relevant and appropriate.
Performance Standard. To be
considered in selecting
appropriate numerical values
to implement the Basin Plan
for setting cleanup standards
and discharge limits. The
numerical values contained in
the staff report may be
ARARs or Performance
Standards, depending on the
source of the values.
Sec Section 10-3 for a list of
cleanup goals for (he OU I
remedial action.
Concentrations protective of
beneficial uses have been
established that arc consistent
with the referenced action
levels.
Cleanup standards were
developed consistent with (he
specified methodology.
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Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
18
19
20
ho
I.
Solid Waste Disposal
Act as amended by
the Resource
Conservation and
Recovery Act
(RCRA) 42 USC
6901 etseq.
California Hazardous
Waste Control Act
(HWCA) California
Health and Safety
Code 25100 ef seq.
Health and Safety
Standards for
Management of
Hazardous Waste
Health and Safety
Standards for
Management of
Hazardous Waste
22CCR 66264
CCR, Title 22, Division
4.5, Chapter 14, Article 16,
Sections 66264.600-
66264.603
CCR, Title 22. Division
4.5, Chapter 14, Article 9,
Sections 66264.170-
66264.178.
RCRA outlines the requirements
for the transportation, storage,
and disposal of defined
hazardous wastes. Some of the
wastes handled during any
remedial action at DDJC-Tracy
may be hazardous wastes.
Applies to owners and operators
of facilities that treat, store, or
dispose of RCRA hazardous
waste in miscellaneous units.
Covers environmental
performance standard,
monitoring, inspections, and
post-closure care.
Applies to owners and operators
who store hazardous waste more
than 90 days in containers.
Covers use and management of
containers, containment,
inspections, and closure.
Applicable. Applies to
hazardous waste management.
The specific requirements that
may be applicable depend on
the wastes handled and the
technologies identified in the
RI/FS process.
Relevant and Appropriate.
Relevant and Appropriate
AH wastes (i.e., spent GAC)
generated by the OU I
groundwalcr treatment
system will be handled in
accordance with the
substantive requirements of
RCRA.
The selected remedy will
utilize air stripper units
which are considered
miscellaneous units.
CA Regulatory Agency:
DTSC
The spent granular activated
carbon units are the only
anticipated hazardous waste
to be generated by the
selected remedy. These units
are considered to be
containers. Because these
units may be stored for more
than 90 days, this regulation
applies.
CA Regulatory Agency:
DTSC
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oo
t-
Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
21 Hazardous Waste
Control Acl
(California Health
and Safety Code
25100 et set/.).
27 CCR, Division 2,
Subdivision 1.
22 Air Resources Act H
&S Code, Div. 26,
Sec. 39000.
CCR. Title 17, Part III.
Chapter 1, Sec. 60000 and
San Joaquin Valley
Unified Air Pollution
Control District Rules and
Regulations, Rules 4651
and 2201.
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i
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Title 27 establishes waste and
siting classification systems and
minimum waste management
standards for discharges of waste
to land for treatment, storage,
and disposal. Title 27 also
contains corrective action
provisions for responding to
leaks and other unauthorized
discharges.
Regulates nonvehicular sources
of air contaminants in California.
The local Air Pollution Control
District (APCD) sets allowable
emissions limits. Regulations for
the release of organic solvents
from an air stripper arc specified
in Rule 4651, Volatile Organic
Compound (VOC) Emissions
from Decontamination of Soil,
and Rule 2201, New and
Modified Stationary Source
Rule. San Joaquin Valley
Unified APCD performs a
screening health risk assessment
for soil or groundwatcr cleanup
projects based on the CAPCOA
Risk Assessment Guideline as a
matter of policy. Maximum
allowable cancer risk is 10 in 1
million. Public notification is
required if the site is within
1,000 feet of a K-12 school.
Applicable. Applies to
discharges of waste to land for
treatment storage and disposal.
Spent GAC and other wastes
will be classified and handled
in accordance with Title 27
requirements.
Applicable. Applies to soil
decontamination processes
and could reasonably apply to
this groundwater remediation
system and associated air
emissions. BACT is required
if the emissions exceed two
pounds per day of a regulated
air contaminant. For this type
of process, a control
effectiveness of 95% is
considered BACT.
Air emissions standards for
the air stripper system will be
specified by SJVUAPCD.
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9
I-J
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Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
23
24
25
San Juaquin Valley
Unified Air Pollution
Cunlrol District
(SJVUAPCD) Rules
and Regulations,
Regulation VIII
SJVUAPCD Regulation
VIII, Rules 8010. 8020,
and 8060.
San Juaquin Valley
Unified Air Pollution
Control District
(SJVUAPCD) Rules
and Regulations,
Regulation IV
SJVUAPCD Regulation
IV, Rule 4102.
42 USC Section 300
ct scq.
40CFR \44etscq.
Prohibitory rules regulate
fugitive dust and PM10
emissions that occur during
demolition, construction, and
vehicle travel on paved and
unpavcd roads. Requires the use
of dust suppression measures
during all site preparation and
vehicle travel.
Prohibits the emission of any
regulated air pollutants in such
quantities that the source causes
injury, detriment, or nuisance to
the public.
Regulates subsurface emplace-
ment of fluids through an
injection well. There arc five
classes of wells regulated.
Applicable. Applies to
construction and site
preparation activities as well
as the PMIOemissions due to
ground disturbances during the
installation of the ground water
remediation system.
Applicable. Applies to the
operation of the groundwaler
remediation system emissions
which could feasibly create a
nuisance due to TCE/PCE
odors and PMIO emissions
from ground disturbances
during the installation of the
groundwater remediation
system.
Applicable. Applies to
groundwater infiltration
galleries, which are classed as
Type V wells.
Construction and site
preparation activities will
include dust suppression and
PM10 emission control
measures. At a minimum,
water will be used to
minimize the emission of fine
paniculate dust to less than
the visible dust emission
requirement specified in Rule
8010.
The groundwater remediation
system will be operated in a
manner that eliminates or
substantially reduces the
potential to create a nuisance.
Infiltration galleries will be
operated in accordance with
these regulatory provisions.
>
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Table 10-2. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or Limitation
Description
ARAR or Performance
Standard Applicability
Compliance
26
27
Resource
Conservation and
Recovery Act
Subpart AA (22 CCR
66265.1030 et seq.).
Article 27 Air Emission
Standards for Process
Vents (22 CCR
66265.1030-66265.1035).
National Emission
Standards for
Hazardous Air
Pollutants (40 CFR
63.920 elseq.).
Subpart PP—National
Emission Standards for
Containers (40 CFR 63.922
et seq.).
Applies to treatment, storage,
and disposal facilities with
process vents associated with
solvent extraction or air or steam
stripping operations managing
RCRA hazardous wastes with
organic concentrations of at least
lOppmw. These operations
must reduce total organic
emissions below specified
concentrations or use a control
device to reduce total organic
emissions by 95 percent by
weight.
Applies to owners and operators
of containers who arc subject to
40 CFR parts 60, 61, or 63.
Containers must, among other
things, be equipped with a cover
and closure devices that form a
continuous barrier over container
openings. Any open-lop
containers must ensure that no
materials are exposed to the
atmosphere.
Relevant and appropriate.
Requirements are not
applicable because
contaminant concentrations do
not exceed RCRA hazardous
waste levels. However, the
requirements are relevant and
appropriate for groundwatcr
extraction and air-stripping
operations.
Relevant and appropriate.
Containers storing hazardous
materials and wastes will be in
place to support all remedial
options.
The remedial action will be
managed to ensure that total
organic emissions arc
controlled below specified
emission levels.
All containers will be
managed so as to avoid the
release of volatile hazardous
air pollutants. Containers
will be properly equipped
and will only be open during
loading and unloading
events.
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Table 10-2. Compliance With Action-Specific ARARs for OU 1 Groundwater Remediation
El'A's legal position is that Tillc 23 CCR. division 3. chapter 15 and Title 27 CCR. division 2, subdivision 1 arc ARARs only as invoked by 23 CCR 251 l(d) and 27 CCR 20090(d), respectively. The
RVVQCB disagrees willi this and reserves the legal position that these requirements are applicable.
APCU = Air Pollution Control District
ARAR = Applicable or Relevant and Appropriate Requirement
CAA = Clean Air Act
CCR = California Code of Regulations
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
DCE = dichloroclhcnc
GAC = Granular Activated Carbon
HWCA = Hazardous Waste Control Act
MCL = maximum contaminant level
NA = not applicable
NAAQS = National Ambient Air Quality Standards
NESIIAP = National Emission Standards for Hazardous Air Pollutants
NSPS = New Source Performance Standards
OU = Operable Unit
PCE = letrachloroethcne
POTW = Publicly Owned Treatment Works
RCRA = Resource Conservation and Recovery Act
Rl/FS = Remedial Investigation/Feasibility Study
RWQCB = Regional Water Quality Control Board
SJVUAPCD = San Joaquin Valley Unified Air Pollution Control District
SMCL = Secondary Maximum Contaminant Level
SWMU = Solid Waste Management Unit
SWRCU = Stale Water Resources Control Board
TCE = trichloroclhcnc
VQC = volatile organic compound ^
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Table 10-3. Compliance With Action-Specific ARARs for Soil Remediation
No. Source
I Porlcr-Colognc
Water Quality
Control Act
(California Water
Code Sections
1 3000, 13304,
13240. 1324 1,
13242, 13243).
2 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243).
Standard,
Requirement,
Criterion, or
Limitation
RWQCB, Central
Valley Region,
Water Quality
Control Plan
(Basin Plan),
"Policy for
Investigation and
Cleanup of
Contaminated
Sites."
RWQCB, Central
Valley Region
Basin Plan,
"Policy for
Application of
Water Quality
Objectives"
Description
Establishes and describes the
policy for the investigation and
remediation of contaminated
sites. Also includes
implementation actions for
setting ground water and soil
cleanup levels.
This policy defines water
quality objectives and explains
how the Regional Water Board
applies numerical and narrative
water quality objectives to
ensure the reasonable protection
of beneficial uses of water and
how the Regional Water Board
applies Resolution No. 68-16 to
promote the maintenance of
existing high-quality waters.
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Cleanup levels All sites.
for soils should be equal to
levels that would achieve
background concentrations
in ground water unless such
levels are technically and
economically infeasible to
achieve. In such cases, soil
cleanup levels are such that
ground water will not exceed
applicable groundwater
quality objectives.
Applicable. Applies to all All sites.
cleanups of discharges that
may affect water quality.
Compliance
Soil cleanup standards
were established to
comply with (his
requirement
Soil cleanup standards
were established to
comply with this
requirement
-------
9
Ul
8
n
Table 10-3. (Continued)
No. Source
3 Porter-Cologne
Standard,
Requirement,
Criterion, or
Limitation Description
RWQCD, Central Establishes water quality
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Specific All sites.
Compliance
Soil cleanup standards
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243).
Valley Region objectives, including narrative
Basin Plan. and numerical standards, that
protect the beneficial uses of
surface and groundwaters in the
region. Describes
implementation plans and other
control measures designed to
ensure compliance with
statewide plans and policies and
provide comprehensive water
quality planning. Also includes
implementation actions for
setting soil cleanup levels for
soils that threaten water quality.
1
applicable portions of the
Basin Plan include
beneficial uses of affected
water bodies and water
quality objectives to protect
those uses. Any activity,
including for example a
new discharge of
contaminated soils or in situ
treatment or containment of
contaminated soils, that
may affect water quality
must not result in water
quality exceeding water
quality objectives.
Implementation plans and
other policies and
requirements may also
apply.
were established to
comply with this
requirement
-------
sn
r
Table 10-3. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13263. 13304).
Stale Water
Resources Control
Board Resolution
No. 68-16,
"Antidcgradation
Policy".
Requires that high-quality
surface and groundwatcrs be
maintained to the maximum
extent possible. Degradation of
waters will be allowed (or
allowed to remain) only if it is
consistent with the maximum
benefit lo the people of the
state, will not unreasonably
affect present and anticipated
beneficial uses, and will not
result in water quality less than
that prescribed in RWQCB and
SWRCB policies. If
degradation is allowed, the
discharge must meet best
practicable treatment or control,
which must prevent pollution or
nuisance and result in the
highest water quality consistent
with maximum benefit to the
people of the slate.
Applicable. Applies to
discharges of waste lo
waters, including discharges
to soil that may affect
surface or grounclwaters. In
situ cleanup levels for
contaminated soils must be
set so that ground waters are
not degraded, unless
degradation is consistent
with the maximum benefit
of the people of the state. If
degradation is allowed, the
discharge must meet best
practicable treatment or
control and result in the
highest water quality
possible that is consistent
with the maximum benefit
lo the people of ihc stale. In
no case may water quality
objectives be exceeded.
All sites.
Soil cleanup standards
were established to
comply with this
requirement
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No. Source
5 Porter-Cologne
Waler Quality
Control Act
(California Water
Code Sections
13000.13140,
13240, 13260,
13263, 13267,
13300, 13304.
13307).
6 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13240).
Standard,
Requirement,
Criterion, or
Limitation
State Water
Resources Control
Board Resolution
No. 92-49 (as
amended 21 April
1994).
Slate Water
Resources Control
Board Resolution
No. 88-63
("Sources of
Drinking Water
Policy") (as
contained in the
RWQCB's Basin
Plan).
Table 10-3.
Description
Establishes requirements for (he
investigation, cleanup, and
abatement of discharges.
Among other requirements,
dischargers must clean up and
abate the effects of discharges
in a manner that promotes the
attainment of cither background
water quality or the best water
quality that is reasonable if
background water quality
cannot be restored. Requires
the application of Title 23,
CCR, Division 3, Chapter 15
requirements to cleanups.
Specifics that, with certain
exceptions, all ground and
surface waters have the
beneficial use of municipal or
domestic water supply.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Applies to all All sites.
cleanups of discharges that
may affect water quality.
Applicable. Applies in All sites.
determining beneficial uses
for waters that may be
affected by dischargers of
waste.
Compliance
Soil cleanup standards
were established to
comply with this
requirement
Cleanup standards to
maintain beneficial
uses were developed in
a way consistent with
the requirements for
municipal or domestic
water supply. Conse-
quently, California
stale primary MCLs arc
relevant and
appropriate; however,
(he most stringent
federal or state standard
was used to determine
the beneficial use limit.
California standards
may be found in 22
CCR 66439 et seq.
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o
I
Standard,
Requirement,
Criterion, or
No. Source Limitation
7 Staff Report of the The Designated
RWQCB, Central Level
Valley Region. Methodology for
Waste
Classification and
Cleanup Level
Determination.
8 Staff Report of the "A Compilation of
RWQCB, Central Water Quality
Valley Region. Goals."
Table 10-3.
Description
Provides guidance on how to
classify wastes according to
Title 27, CCR, Division 2,
Subdivision 1 /Title 23, CCR,
Division 3, Chapter IS, Article
10.
Provides guidance on selecting
numerical values to implement
the narrative water quality
objectives contained in the
Basin Plan.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Performance Standard. To Excavation - SWMUs
be considered in . . . , „ -n 97 ,-
determining the 2,3,4.6.8,20.27,33
classification of wastes and
contaminated soils.
Performance Standard. To All sites.
be considered in selecting
appropriate numerical
values to implement the
Basin Plan for setting
cleanup levels and
discharge limits. The
numerical values contained
in the staff report may be
applicable, relevant, and
appropriate or to be
considered, depending on
the source of the values.
Compliance
This methodology will
be used when
classifying excavation
wastes. Designated
wastes will only be
discharged to an off-
site Class I or Class II
facility.
This guidance was
considered as one of
the criteria for setting
beneficial uses and,
consequently, setting
soil cleanup levels.
D
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2
n
3
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n
3
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n
73
n
o
o
3.
0
O
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n
5'
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3
9
Table 10-3. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
o
LJ
10
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13304).
Porter-Cologne
Water Quality
Control Acl
(California Water
Code Sections
13140-13147,
13172,13260,1326
3,13267,13304).
Title 27, CCR,
Division 2,
Subdivision 1
(Section 20080 el
seq.),
Title 23, CCR,
Division 3,
Chapter 15
(Section 2510 et
seq. ).
Title 27.CCR,
Section 20090(d),
Title 23, CCR,
Section 2511 (d).
Establishes waste and siting
classification systems and
minimum waste management
standards for discharges of
waste to land for treatment,
storage, and disposal.
Engineered alternatives that are
consistent with the Title
27/Tillc 23 performance goals
may be considered. Establishes
corrective action requirements
for responding to leaks and
other unauthorized discharges.
Actions taken by public
agencies to cleanup
unauthorized releases arc
exempt from Title 27/Tillc 23
accept thai wastes removed
from immediate place of release
and discharged to land must be
managed in accordance with the
classification (Title 27.CCR
.Section 20200 /Title 23, CCR,
Section 2520) and siting
requirements of Title 27 or Title
23 and wastes contained or left
in place must comply with Title
27 or Title 23 to the extent
feasible.
The application of specific
sections of Title 27/Title 23
(o different situations is
discussed below. Provisions
of Title 23 apply to
hazardous waste and
provisions of Title 27 apply
to designated and
nonhazardous solid waste.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Applicable. Applies to
remediation and monitoring
of sites.
Applies to all sites subject
to remediation.
Excavated soil will be
classified appropriately
and deposited in a
disposal facility (hat
maintains compliance
with this provision.
Waste management
procedures consistent
with Title 27/Title 23
will be utilized in soil
handling and managing
stockpiled soils.
Ground water will be
monitored and soil sites
will be remediated and
closed according to
Title 27/Title 23
regulations.
I
s
00
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CD
I-
Table 10-3. (Continued)
Standard,
Requirement,
Criterion, or
No. Source Limitation Description
II Porler-Colognc Title 27, CCR, Requires closure of existing
ARAR or Performance Actions and Sites
Standard (Applicability) Affected Compliance
Applicable. Applies to Applies to all sites subject The OU I ground water
o
g
12
N)
I
$
00
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263. 13267,
13304).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13304).
Section 20080(d)
Title 23, CCR,
Section 2510(d).
Title 27, CCR,
Section 20080(g),
Title 23, CCR,
Section 25
waste management units in
accordance with the
requirements of Title 27 Article
8/Title 23 Article 8.
Requires monitoring. If water
quality is threatened, corrective
action consistent with Title 27,
Article 5/Titlc 23 is required.
"existing" waste
management units (i.e.,
areas where waste was
discharged to land on or
before 27 November 1984,
but that were not closed,
abandoned, or inactive prior
to that date).
to remediation.
Relevant and Appropriate.'
Applies to areas of land
where discharges have
ceased as of 27 November
1984 (the effective date in
the revised Title 27/Titlc 23
regulations).
Applies to all sites where
water quality is
threatened. (All sites
except for the North
Depot surface soils.)
and the SWMUs that
arc suspected sources
of contamination will
be closed in accordance
with the requirements
of Title 27 Article
8/Title 23 Article 8.
These requirements
include closure in
accordance with an
approved closure and
post-closure
maintenance plan that
provides for continued
compliance with the
applicable Title 27
standards for waste
containment,
precipitation and
drainage control, and
monitoring.
The monitoring
program at these sites
will be implemented in
accordance with Title
27/Titlc 23.
-------
a
9
to
I
No. Source
13 Porlcr-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
14 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13269).
Standard,
Requirement,
Criterion, or
Limitation
Title 27, CCR,
Section 20400,
Title 23, CCR,
Section 2550.4.
Title 27, CCR,
Section 204 10,
Title 23, CCR,
Section 2550.6
Table 10-3.
Description
Cleanup levels must be set at
background concentration levels
or, if background levels are not
technologically and
economically feasible, at the
lowest levels that are
economically and
technologically feasible.
Specific factors must be
considered in setting cleanup
levels above background levels.
Cleanup levels above
background levels shall be
evaluated every five years. If
the actual concentration of a
constituent is lower than its
associated cleanup level, (he
cleanup level shall be lowered
to reflect existing water quality.
Requires monitoring for
compliance with remedial
action objectives for three years
from the date of achieving
cleanup levels.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Relevant and Appropriate.1 All sites.
If water quality is
threatened, (his section
applies in setting soil
cleanup levels for all
cleanups of discharges of
waste to land.
Relevant and Appropriate.' SVE - Group A sites.
Applies to all soil cleanup SWMU 20
activities. ., . ,•„,..,,
Excavation - SWMUs
2,3,4,6,8,20.27,33
Institutional Controls -
SWMUs 7, 11, 33
Dio venting - SWMU 24
Natural Attenuation -
SWMU 20
Compliance
Sites where wastes will
be left in place will be
managed and
monitored in
accordance with the
requirements of Title
27/Tille 23.
Sites will be monitored
for at least three years
after cleanup standards
have been achieved.
-------
o
Ui
00
to
I.
Table 10-3. (Continued)
Standard,
Requirement,
Criterion, or ARAR or Performance Actions and Sites
No. Source Limitation Description Standard (Applicability) Affected
15 Porter-Cologne Title 27, CCR, Requires general soil, surface Relevant and Appropriate." SVE - Group A sites,
Water Quality Section 20415, water, and groundwatcr Applies to all areas in which SWMU 20
Control Act „. . ,,, ,,~D monitoring. waste has been discharged „ . ew/nn
,,,.., .... Title 23, CCR, 6 .11 Excavation - SWMUs
(California Water . n-,,nA to land.
,, . p . occlion 2550.7. 2,3,4,6,8,20,27,33
Code Sections
13140-13147, Institutional Controls -
1 3 1 72, 1 3260, SWMUs 7, 1 1 ,33
!3267;i3269). Bioventing - SWMU 24
Natural Attenuation -
SWMU 20
Asphalt Cover -
N. Depot surf, soils
Compliance
Monitoring will be
conducted in
accordance with the
requirements of Title
27 Article 5/Title 23
Article 5 for all ground
water at the facility
subject to remediation.
The agencies will be
provided with quarterly
and annual monitoring
reports as part of the
site-wide ground water
Well Monitoring
Program which covers
assessment of ground
water at the facility
during the
implementation of soil
and ground water
remedial actions.
a
2
n
H
3
0
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1
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0
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3
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n
8
o
D.
O
•*>
O
S.
5
5'
-------
9
to
I
No. Source
1 6 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172. 13260,
13263, 13267.
13269).
17 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263,
13267,13269).
Standard,
Requirement,
Criterion, or
Limitation
Title 27, CCR,
Section 20425,
Title 23, CCR,
Section 2550.9.
Title 27, CCR,
Section 20430,
Title 23, CCR,
Section 2550.10
Table 10-3.
Description
Requires an assessment of the
nature and extent of the release,
including a determination of the
spatial distribution and
concentration of each
constituent.
Requires the implementation of
corrective action measures that
ensure that cleanup levels arc
achieved throughout the zone
affected by the release by cither
removing (he waste constituents
or treating them in place.
Source control may be required.
Also requires monitoring to
determine the effectiveness of
(he corrective actions.
(Continued)
ARAR or Performance
Standard (Applicability)
Relevant and Appropriate.'
Applies to sites at which
monitoring results show
statistically significant
evidence of a release.
Relevant and Appropriate.*
If water quality is
threatened, this section
applies to all soil cleanup
activities.
Actions and Sites
Affected
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6.8.20,27,33
Institutional Controls -
SWMUs 7. II, 33
Bioventing - SWMU 24
Natural Attenuation -
SWMU 20
Asphalt Cover -
N. Depot surf, soils
SVE - Group A sites.
SWMU 20
Excavation - SWMUs
2,3.4.6,8,20.27,33
Institutional Controls -
SWMUs 7. II. 33
Bioventing - SWMU 24
Natural Attenuation -
SWMU 20
Asphalt Cover -
N. Depot surf, soils
Compliance
Further assessment of
the nature and extent of
releases will continue
during implementation
of the RD/RA.
Corrective action
measures and
monitoring will be
undertaken as
prescribed. To
demonstrate cleanup,
the concentration of
each COC in
groundwalcr must be
equal to or less than the
cleanup standard for at
least one year
following the corrective
action; otherwise, the
remedy will be
rccvaluated.
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GO
r
u
•o
3.
No.
18
19
20
Source
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263,
13267,13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13 140- 13 147,
13172, 13260,
13263, 13269).
Standard,
Requirement,
Criterion, or
Limitation
Title 27, CCR,
Section 20950;
22207(a);
22212(a).and
22222,
Title 23 CCR
I Illt« +"J) ^-*^— -IX,
2550.0(b); 2580;
2580(0'.
Title 27, CCR,
Section 2 1400,
Title 21 CTR
&I11& »*St ^*V^f\|
Section 2582.
Title 27, CCR,
Section 20080(d),
Tillo T\ CCK
1 Illl* £J, V*V~1\,
Section 25 10(d)
Table 10-3.
Description
General closure requirements,
including continued
maintenance of waste
containment, drainage controls,
and groundwater monitoring
throughout the closure and post-
closure maintenance periods.
Requires surface impoundments
to be closed by removing and
treating all free liquid and either
removing all remaining
contamination or closing the
surface impoundment as a
landfill.
Requires closure of existing
waste management units
according to Title 27, Article
8/Tillc 23 Article 8.
(Continued)
ARAR or Performance
Standard (Applicability)
Applicable. Applies (o
partial or final closure of
waste management units.
Applicable. If water
quality is threatened, this
section is relevant and
appropriate for natural
topographic depressions,
excavations, and diked
areas where wastes
containing free liquids were
discharged.
Applicable. Applies to all
areas where waste has been
discharged (o land.
Actions and Sites
Affected
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Institutional Controls -
SWMUs 7, 11, 33
Bio venting - SWMU 24
Natural Attenuation -
SWMU 20
Excavation - SWMUs
2,3,4
All sites.
Compliance
Monitoring and
maintenance of waste
management units will
be conducted during
closure and post-
closure periods for as
long as wastes pose a
threat to water quality.
Clean closure will be
attempted . Cleanup
standards identified in
this ROD arc expected
to protect water quality
and attain clean
closure. Clean closure
will be verified with
ground water
monitoring.
All SWMUs and soil
contamination areas
will be closed
according to Title 27
closure requirements.
a
i1
r>
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n
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n
n
o
1
3
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n
n
o
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o
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n
5'
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o
o
i.
I
No.
21
22
23
Source
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172. 13260,
13263, 13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147.
13172, 13260,
13263, 13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
Standard,
Requirement,
Criterion, or
Limitation
Title 23, CCR,
Scction),2520
2521,
Title 27, CCR,
Section
20200(c),20210.
Title 27, CCR.
Section
20200(c),20220.
Table 10-3.
Description
Requires that hazardous waste
be discharged to Class I waste
management units that meet
certain design and monitoring
standards.
Requires that designated waste
be discharged to Class I or
Class II waste management
units.
Requires that nonhazardous
solid waste be discharged to a
classified waste management
unit.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Applies to Excavation - SWMUs
discharges of hazardous 2,3,4,6,8,20, 27,33
waste to land for treatment.
storage, or disposal.
Applicable. Applies to Excavation - SWMUs
discharges of designated 2,3,4,6,8,20,27,33
waste (nonhazardous waste
that could cause degradation
of surface or groundwaters)
to land for treatment,
storage, or disposal.
Applicable. Applies to Excavation - SWMUs
discharges of nonhazardous 2,3,4,6,8,20,27,33
solid waste to land for
treatment, storage, or
disposal.
Compliance
Hazardous wastes will
be discharged to Class I
waste management
units. Excavated
hazardous wastes will
be properly manifested
and disposed of off site
at a permitted Class I
hazardous waste
treatment storage or
disposal facility.
Designated wastes will
be discharged off site to
permitted Class I or
Class II waste
management units.
Nonhazardous solid
wastes will be
discharged to classified
waste management
units.
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CD
r
o
i
to
No. Source
24 CWA, Section 402,
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13260,13263,
11170 S 11172
1 J J 1 \J.J i t h/«J/^|
1117*1 11176
I J *J 1 +J I I J J / LF,
13377, 13383).
25 CWA, Section 402,
Porter-Cologne
Water Quality
Control Acl
(California Water
Code Sections
13260,13263,
11170 ^ 11172
lJJI\J'JllJJIift
11171 11174
1 _}_? / _7, 1 J J / f»
13377, 13383).
Standard,
Requirement,
Criterion, or
Limitation
40 CFR Parts
122,123, 124,
National Pollution
Discharge
Elimination
System,
implemented by
Slate Water
Resources Control
Board Order No.
92-08 DWQ
40 CFR Parts
122,123, 124,
National Pollution
Discharge
Elimination
System,
implemented by
California General
Slonnwalcr Permit
for Industrial
Activities, State
Water Resources
Control Board
Order #97-03-
DWQ.
Table 10-3.
Description
Regulates pollutants in
discharge of storm water
associated with construction
activity (clearing, grading, or
excavation) involving the
disturbance of 5 acres or more.
Requirements to ensure storm
walcr discharges do not
contribute to a violation of
surface water quality standards
Regulates pollutants in
discharge of storm walcr
associated with hazardous waste
treatment, storage, and disposal
facilities, wastewater treatment
plants, landfills, land
application sites, and open
dumps. Requirements to ensure
storm water discharges do not
contribute to a violation of
surface water quality standards.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Applies to Excavation - SWMUs
construction areas over 5 2,3,4
acres in size. Includes
measures lo minimize
and/or eliminate pollutants
in storm water discharges
and monitoring to
demonstrate compliance.
Applicable. Applies to SVK - Group A Sites,
storm water discharges from SWMU 20
industrial areas. Includes „. ,. o«»»jit«»^
. . . Bio venting - SWMU 24
measures lo minimize "
and/or eliminate pollutants
in storm water discharges
and monitoring to
demonstrate compliance.
Compliance
Storm water best
management practices
(BMPs) will be used to
prevent adverse effects
to surface water.
Excavations will be
conducted during dry
season. A Storm Walcr
Pollution Prevention
Plan will be submitted
lo the RWQCB under
the storm water
compliance program.
All (rcatmcnl activilics
will comply with (he
substantive portions of
the permit, including
implementation of best
management practices.
A Storm Walcr
Pollution Prevention
Plan will be submitted
lo the RWQCB under
the storm water
compliance program.
o
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n
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n
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l
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n
n
o
3
•o
n
n
[/i
n
73
n
O
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o
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O
n
n
o'
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o
Table 10-3. (Continued)
No.
26
Source
California
Standard,
Requirement,
Criterion, or
Limitation
Title 22, Division
Description
Establishes standards for
ARAR or Performance
Standard (Applicability)
Applicable. Applies to
Actions and Sites
Affected
Excavation • SWMUs
Compliance
Hazardous wastes will
Hazardous Waste
Control Law
M
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
12 (Standards
Applicable to
Generators of
Hazardous Waste),
Article 1
(Applicability) 22
CCR66262.il
generators of hazardous waste.
Applicable for determining if
the wastes from excavated sites
or treatment processes arc
classified as hazardous or non-
RCRA hazardous waste, and the
remedial action constitutes
treatment, storage, or disposal
of hazardous waste.
hazardous waste
management. The specific
requirements that may be
applicable will depend on
the wastes handled and the
technologies identified in
the RI/FS process.
2,3,4,6,8,20,27,33
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
a
o
u»
b
o
n
Table 10-3. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
27 California
Hazardous Waste
Control Law
o
fc
•a
3.
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
9 (Use and
Management of
Containers) 22
CCR 66264.171-
66264.178
The chemicals recovered from
the sediments, surface soils,
subsurface soils, or groundwalcr
may need to be managed as
either a RCRA or non-RCRA
hazardous waste. The treatment,
storage, and disposal
requirements for these wastes
are cither applicable or relevant
and appropriate (depending
upon the classification of the
waste material) and they
include: using containers to
store the recovered product that
are compatible with this
material (22 CCR 66264.172);
using containers that are in
good condition (22 CCR
66264.171); segregating the
waste from incompatible wastes
(12 CCR 66264.177); inspect
the containers (22 CCR
66264.174); isolating the waste
from sources of ignition (if the
material is ignilablc) and (22
CCR 66264.176); providing
adequate secondary
containment for the waste
stored (22 CCR 66264.175);
containers must be closed
during transfer (22 CCR
66264.173); and all hazardous
material must be removed at
closure (22 CCR 66264.178).
Applicable if during
excavation, treatment
processes, or cleanup
activities hazardous waste is
identified through the
proper characterization
process, the hazardous
waste will be managed in
accordance with the
standards staled in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
O
a
n
C/5
?
k
CL
?
•a
3
n
n
70
n
o
o
s.
D
n
n
o
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Table 10-3. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
28 California
Hazardous Waste
Control Law
o
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste). Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
12 (Waste Piles)
22CCR
66264.251.
66264.254,
66264.256-
66264.259
Delineates requirements for the
management of waste piles for
hazardous wastes. This
regulation is applicable to sites
where excavated materials are
classified as hazardous wastes
and managed in waste piles.
The titles of the regulations are
Section 66264.251. Design and
Operating Requirements;
Section 66264.254. Monitoring
and Inspection; Section
66264.256. Special
Requirements for Ignitable or
Reactive Waste; Section
66264.257. Special
Requirements for Incompatible
Wastes; Section 66264.258.
Closure and Post-Closure Care;
and Section 66264.259. Special
Requirements for Hazardous
Wastes P020.P021.P022,
P023, P026. and P027.
If during excavation,
treatment processes, or
cleanup activities,
hazardous waste is
identified through the
proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27.33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
8
00
-------
d
r
o
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
29 California
Hazardous Waste
Control Law
•o
a.
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
19 (Corrective
Action for Waste
Management
Units) 22 CCR
66264.552,
66264.553
CAMU: Placement,
consolidation, and treatment of
soils and wastes being
generated as part of a corrective
action under RCRA will not be
considered a new disposal to
land as long as the materials are
handled in designated CAM Us.
Land disposal restrictions (22
CCR 66268) are not invoked
when remediation wastes arc
managed in a CAMU. A
CAMU can only be used for the
management of remediation
wastes pursuant to
implementing corrective actions
at the facility.
USEPA intended that the
federal CAMU rule be
considered for the management
of wastes generated at
CERCLA sites. Excavation of
wastes from the discharge and
disposal sites might be managed
at a CAMU for on-base
disposal, or ex situ
biorcmcdiation.
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
o
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
29 (Conlinucd)
A CAMU is an area within a
facility for the purpose of
implementing corrective
actions. Uncontaminalcd areas
are allowed to be designated as
part of a CAMU when they are
necessary to achieve the overall
goals for the facility and will
enhance the protectivencss of
the remedial action. The CAMU
rule allows consolidation and
treatment of wastes in a single
unit, from other areas of the
facility, without triggering
minimum technology
requirements and LDR found in
other provisions of RCRA and
HWCL; that is, placement of
wastes into a CAMU is not
considered land disposal and
rcdeposition of treated wastes
into the CAMU docs not trigger
the LORs. Groundwatcr must
be monitored at the CAMU in
order to detect and characterize
a release.
-------
r
3
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
30
California
Hazardous Waste
Control Law
3I
California
Hazardous Waste
Control Law
I.
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article I (General)
22 CCR 66268.3,
66268.7(a) & (b),
66268.9
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 3
(Prohibitions on
Land Disposal) 22
CCR 66268.30-
66268.35
Provides the purpose, scope,
and applicability of LDRs. The
title of the sections of the
regulations are: Section
66268.3, Dilution Prohibited As
a Substitute for Treatment;
Section 66268.7, Waste
Analysis and Record Keeping;
and Section 66268.9, Special
Rules Regarding Wastes That
Exhibit a Characteristic.
These standards arc applicable
to sites where excavated
material is classified as
hazardous waste and is disposed
of or treated in an area not
designated as a CAMU.
Provides waste-specific LDRs
for Section 66268.30. Waste
Specific Prohibitions-Solvent
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Only applicable if
hazardous wastes are
disposed of or treated in an
area not designated as a
CAMU or disposed of or
treated beyond the area of
contamination.
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, (he
hazardous waste will be
managed in accordance with
the standards stated in these
sections of (he regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
31 (Continued)
32 California
Hazardous Waste
Control Law
M
•a
a
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 4
(Treatment
Standards) 22
CCR 66268.41-
66268.43
Wastes; Section 66268.31,
Waste Specific Prohibitions-
Dioxin-Containing Wastes;
Section 66268.32, Waste
Specific Prohibitions-California
List Wastes; Section 66268.33,
Waste Specific Prohibitions-
First Third Wastes; Section
66268.34. Waste Specific
Prohibitions-Second Third
Waste; and Section 66268.35,
Waste Specific Prohibitions-
Third Third Waste.
These standards arc applicable
to sites where excavated
materials arc classified as
hazardous waste and are
disposed of or treated in an area
not designated as a CAMU.
Provides treatment standards
expressed in contaminant
concentrations in Section
66268.41. Treatment Standards
Expressed As Concentrations in
Waste
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards slated in these
sections of (he regulation.
Excavation - SWMUs
2,3.4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
32 (Continued)
o
Ct
o
33 California
Hazardous Waste
Control Law
I
8
Title 22, Division
4.5
(Environmental
Health Standards
Tor Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 5
(Prohibitions on
Storage) 22 CCR
66268.50
Extract; Section 66268.42.
Treatment Standards Expressed
As Specified Technologies; and
Section 66268.43. Treatment
Standards Expressed As Waste
Concentrations.
These standards provide waste
specific LDRs for solvent
wastes, dioxin-containing
wastes, and California Listed
Wastes.
This standard is applicable to
sites where excavated material
is classified as hazardous waste.
The standard provides
prohibitions on storage of
restricted wastes.
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
34 San Joaquin Valley
Unified Air
Pollution Control
District
(SJVUAPCD)
Rules and
Regulations,
Regulation VIII.
SJVUAPCD
Regulation VIII
Rules 8010, 8020,
and 8060.
Prohibitory rules regulate
fugitive dust and PM10
emissions that occur during
demolition, construction, and
vehicle travel on paved and
unpaved roads. Requires the use
of dust suppression measures
during all site preparation and
vehicle travel.
Applicable. Applies to
construction and site
preparation activities as
well as the PM10 emissions
due to ground disturbances
during the installation of the
SVE, bioventing, and
excavation activities.
SVE - Group A sites,
SWMU 20
Excavation • SWMUs
2,3,4.6,8.20,27,33
Dioventing - SWMU 24
Construction and site
preparation activities
will include dust
suppression and PMIO
emission control
measures. At a
minimum, water will be
used to minimize the
emission of fine
particulate dust to less
than the visible dust
emission requirement
specified in Rule 8010.
35 San Joaquin Valley
Unified Air
Pollution Control
District
(SJVUAPCD)
Rules and
Regulations,
Regulation IV.
SJVUAPCD Prohibits the emission of any
Regulation IV regulated air pollutants in such
Rule 4102. quantities that the source causes
injury, detriment, or nuisance to
the public.
Applicable. Applies to the
use and operation of the
remediation systems and the
associated emissions that
could feasibly create a
nuisance due to odors.
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
The SVE and
bioventing systems will
be operated in a manner
that eliminates or
substantially reduces
the potential to create a
nuisance.
I.
g
00
-------
Table 10-3. (Continued)
No.
Standard,
Requirement,
Criterion, or
Source Limitation
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
36
Air Resources Act
H&S Code. Div.
26. Sec. 39000.
37
Air Resources Act
H&S Code, Div.
26. Sec. 39000.
I
ig
00
CCR, Title 17,
Part HI, Chapter I,
Sec. 60000 and
San Joaquin
Valley Unified Air
Pollution Control
District Rules and
Regulations, Rules
4651.
CCR, Title 17,
Part HI, Chapter 1,
Sec. 60000 and
San Joaquin
Valley Unified Air
Pollution Control
District Rules and
Regulations, Rules
2201.
Regulates nonvchicular sources
of air contaminants in
California. The local Air
Pollution Control District sets
allowable emissions limits.
Regulations for release of
organic solvents from an air
stripper are specified in Rule
4651 Volatile Organic
Compound (VOC) Emissions
from Decontamination of Soil.
New and Modified Stationary
Source Rule. SJVUAPCD
performs a screening health risk
assessment for soil or
ground water cleanup projects
based on the CAPCOA Risk
Assessment Guideline as a
matter of policy. Maximum
allowable cancer risk is 10 in 1
million. Public notification is
required if site is within 1,000
feet of a K-12 school.
Applicable. Applies to soil
decontamination processes
and remediation systems
and their associated air
emissions. BACT is
required if the emissions
exceed 2 pounds per day of
a regulated air contaminant.
For this type of process, a
control effectiveness of
95% is considered BACT.
Applicable. Applies to soil
decontamination processes
and remediation systems
and their associated air
emissions. BACT is
required if the emissions
exceed 2 pounds per day of
a regulated air contaminant.
For this type of process, a
control effectiveness of
95% is considered BACT.
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
SVE, excavation, and
bioventing systems will
be operated in a manner
that complies with the
requirements in
SJVUAPCD Rule
4651.
SVE, excavation, and
biovenling systems will
be operated in a manner
that complies with the
requirements in
SJVUAPCD Rule
4651.
-------
5!
r
9
t-j
I
i
Standard,
Requirement,
Criterion, or
No. Source Limitation
38 Clean Air Act National Emission
(CAA) (42 USC Standards for
§740 1 -7642). Hazardous Air
Pollutants (40
CFRPart 61),
Subparts A, E, F,
J, V, and FF, and
SMAQMD Rule
4002.
39 National Emission Subpart PP--
Standards for National Emission
Hazardous Air Standards for
Pollutants (40 CFR Containers (40
63.920 etseq.). CFR 63.922 et
seq.).
Table 10-3.
Description
Section 11 2 of the CAA
establishes national emission
standards for hazardous air
pollutants (NESHAPs). The
standards address new and
existing sources, and are
oriented toward particular
hazardous pollutants at their
point of emission from specific
sources.
Applies to owners and operators
of containers who are subject to
40 CFR parts 60, 61, or 63.
Containers must, among other
things, be equipped with a cover
and closure devices that form a
continuous barrier over
container openings. Any open-
top containers must ensure that
no materials arc exposed to the
atmosphere.
(Continued)
ARAR or Performance Actions and Sites
Standard (Applicability) Affected
Applicable. Applies to air SVE - Group A sites,
emissions at DDJC-Tracy SWMU 20
associated with soil o«i»*n
... . . . . Excavation - SWMUs
remed,at,on technolog.es. 2>3i4i6820 2? 33
Bioventing • SWMU 24
Relevant and appropriate. SVE - Group A sites,
Containers storing SWMU 20
hazardous materials and _. . c«/»4n
..... . . Excavation - SWMUs
wastes will be in place to
support all remedial 2,3,4,6,8,20.27,33
options.
Compliance
Hazardous air pollutant
standards will be met at
the points of emission.
All containers will be
managed so as to avoid
the release of volatile
hazardous air
pollutants. Containers
will be properly
equipped and will only
be open during loading
and unloading events.
-------
Table 10-3. (Continued)
No.
40
Source
National Emission
Standard,
Requirement,
Criterion, or
Limitation
Subparl DD— A
Description
pplies lo owners and opera
ARAR or Performance
Standard (Applicability)
tors Relevant and appropriate.
Actions and Sites
Affected
SVE - Group A sites.
Compliance
The volumes and
Standards for
Hazardous Air
Pollutants (40 CFR
63.680 et seq.).
National Emission
Standards from
Off-site Waste and
Recovery
Operations (40
CFR 63.680 et
seq.).
>
3.
>O
*o
00
of off-site treatment, storage,
and disposal facilities,
wastcwatcr treatment
operations, or hazardous waste
recycling facilities that are
major sources of hazardous air
pollutants. Requires any of the
following: (1) the installation
of air emission controls; (2) the
pretreatment of the hazardous
air pollutant before entering
management units; or (3)
ensuring that volatile hazardous
air pollutant concentrations
remain below 500 ppmw.
SWMU 20
Bioventing - SWMU 24
Excavation - SWMUs
2,3,4,6,8,20,27.33
concentrations of
volatile hazardous air
pollutants are expected
to fall below specified
action levels. In the
event higher
concentrations arc
observed, appropriate
control devices will be
installed.
-------
Table 10-3. (Continued)
1 EPA's legal position is that Title 23 CCR. division 3, chapter 15 and Title 27 CCR, division 2. subdivision I are ARARs only as invoked by 23 CCR 251 l(d) and 27 CCR 20090(d). respectively. The
RWQCB disagrees with this and reserves the legal position that these requirements are applicable.
APCD = Air Pollution Control District
ARAR = Applicable or Relevant and Appropriate Requirement
BMPs = Best Management Practices
CAA = Clean Air Act
CAMU = Corrective Action Management Unit
CAPCOA = California Air Pollution Control Officer Association
CCR = California Code of Regulations
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
DCE = dichloroethene
GAC = Granular Activated Carbon
HWCA = Hazardous Waste Control Act
LDR = Land Disposal Restriction
MCL = maximum contaminant level
NA = not applicable
NAAQS = National Ambient Air Quality Standards
NESHAP = National Emission Standards for Hazardous Air Pollutants
NPL = National Priority List
NSPS = New Source Performance Standards
OU = Operable Unit
PCE = tclrachlorocthcne
POTW = Publicly Owned Treatment Works
RCRA = Resource Conservation and Recovery Act
RI/FS = Remedial Investigation/Feasibility Study
RWQCB = Regional Water Quality Control Board
SDWA = Safe Drinking Water Act
SJVUAPCD = San Joaquin Valley Unified Air Pollution Control District
SMAQMD = Sacramento Metropolitan Air Quality Management District
SMCL = Secondary Maximum Contaminant Level
SVE = soil vapor extraction
SWMU = Solid Waste Management Unit
SWRCB = State Water Resources Control Board
TCE = trichloroclhcne
UST = underground storage lank
VOC = volatile organic compound
-------
Table 10-4. Determination of Soil Cleanup Standards for
Threat to Threat to
Maximum Beneficial Background
Background Concentration Uses In Groundwater RBC RBC
Constituent Threshold* Detected Groundwater Quality E-06 HI = 1 RL
VOCs (ug/kg)
Tetrachloroellienc (PCE) NE 400 Yes Yes NA NA 10
Trichloroelhenc (TCE) NE 220 ug/L1 Yes Yes NA NA 10
SWMU 1/Area 2, DDJC-Tracy
Equilibrium
Partitioning
Equilibrium Limit Protective
Region Partitioning Limit of Background
IXPRG" Protective of MCL' Water Quality"
17,000 2.4 0.2
7.000 1.3 0.3
Soil Gas
Model Cleanup
Level* Standards
14 780 ppbv'
NE 350 ppbv**
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA. 1996).
Equilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
Equilibrium partitioning limit based upon comparison of detection limit to soil-water concentrations.
Model level derived using vadose zone and groundwaler modeling, and based upon predicted achievement of MCL in groundwater at the source area.
Soil cleanup standard for PCE corresponds (o a target soil gas cleanup standard of 5.4 ug/L (780 ppbv).
TCE was detected only in soil gas at SWMU I/ Area 2.
Soil cleanup standard for TCE corresponds to a target soil gas cleanup standard of 1 .9 ng/L (350 ppbv).
HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remedial Goal
RBC = risk-based concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be rcproducibly delected as verified by the use of a low-level standard
O
O
n
oo
o.
n
0
O
a
n
3
n
n
i
o
o
-------
Table 10-5. Determination of Soil Cleanup Standards for Area 1 Building 237
Threat to Threat to
Maximum Beneficial Background
Background Concentration Uses In Groundwater RBC RBC
Constituent Threshold* Detected Groundwater Quality E-06 HI = 1
VOCs(ug/kg)
Telrachloroethene (PCE) NE I.I 20 Yes Yes NA NA
Trichloroelhene (TCE) NE ND NA NA NA NA
Equilibrium
Region Partitioning Limit
RL IX PRG° Protective of MCLC
10 17,000 2.4
10 7.000 1.3
Equilibrium
Partitioning
Limit Protective
of Background
Water Quality4
0.2
0.3
Soil Gas
Model Cleanup
Level* Standards
IS 780 ppbv'
NE 350 pphv«
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA, 1996).
Equilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
Equilibrium partitioning limit based upon comparison of detection limit (o soil-water concentrations.
Model level derived using vadose zone and groundwaier modeling, and based upon predicted achievement of MCL in groundwater at the source area.
Soil cleanup standard for PCE corresponds to a target soil gas cleanup standard of 5.4 jjg/L (780 ppbv).
Soil cleanup standard for TCE corresponds to a target soil gas cleanup standard of 1 .9 (ig/L (350 ppbv).
HI = Hazard Index
NA = not applicable
NE = not evaluated
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
R L = Laboratory reporting limit corresponding to the lowest concentration that can be rcproducibly detected as verified by (he use of a low-level standard
0
O
O
C/3
ft
s:
n
n
o
n
3
s>
<'
n
70
o
n
o
-n
a.
o
•»
n
-------
Table 10-6. Determination of Soil Cleanup Standards for Area 3
Constituent
VOCs fog/kg)
Telrachloroelhene (PCE)
Trichloroelhene (TCE)
Background
Threshold*
NE
NE
Maximum
Concentration
Detected
227
440
Threat to
Beneficial
Uses In
Groundwater
Yes
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
RBC
E-06
NA
NA
RBC
HI-1
NA
NA
RL
10
10
Region
IX PRG°
17,000
7.000
Equilibrium
Partitioning Limit
Protective of MCLe
2.4
1.3
Equilibrium
Partitioning
Limit Protective
of Background
Water Quality4
0.2
0.3
Soil Gas
Model Cleanup
Level* Standards
22 780 ppbv'
32 350 ppbv»
Background threshold values were determined for inclals in all sile soils; background threshold values for pesticides apply only to soils less than 2 feel deep.
Region IX FRG based on industrial exposure scenario (USEPA. 1996).
Equilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
Equilibrium partitioning limit based upon comparison of detection limit lo soil-water concentrations.
Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of MCL in groundwater at the source area.
Soil cleanup standard for PCE corresponds to a target soil gas cleanup standard of 5.4 Mg/L (780 ppbv).
TCE was detected only in soil gas at SWMU I/Area 2.
XI = Hazard Index
NA = not applicable
NE = not evaluated
NR = Not Required
PRO = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding lo the lowest concentration lhat can be rcproducibly detected as verified by the use of a low-level standard
O
2
n
I
on
Q.
n
n
o
O
n
70
n
n
t
o
O
-------
Table 10-7. Determination of Soil Cleanup Standards for SWMU 4
Threat to Threat to
Maximum Beneficial Background
Background Concentration Uses In Groundwater RBC
Constituent Threshold* Detected Groundwater Quality E-06
Pesticides (ug/kg)
Total DDX 3,877 NE Yes Yes NA
Metals (pg/kg)
Lead NE NE No No NA
Selenium NE 25.000 No No NA
Equilibrium Equilibrium
Partitioning Limit Partitioning
Ecological Region IX Protective of Limit Protective Cleanup
RBC RL PRGb Beneficial Uses' of Background" Standards
241 3 5.600 NE NE 241
5.130 NE NE NE NE 5,130
616 NE NE NE NE 616
' Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feel deep.
0 Region IX PRO based on industrial exposure scenario (USEPA, 1996).
' Equilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
d Equilibrium partitioning limit based upon equivalency of background threshold values in groundwater (A Horizon) or detection limits to soil-water concentrations.
HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = Not Required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration ^
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly delected as verified by the use of a low-level standard o
n
n
y
n
k
EL
n
n
o
3
3"
n>
3
«*
0
•s
o
o
o
-n
rt
5'
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table 10-8. Chemical-Specific Requirements for Disposal of
Soil/Sediment, DDJC-Tracy
Substances
STLC
(mg/L)
TTLC Wet Weight
(mg/kg)
Inorganic Substances
Antimony and/or antimony compounds
Arsenic and/or arsenic compounds
Barium and/or barium compounds (excluding barite)
Beryllium and/or beryllium compounds
Cadmium and/or cadmium compounds
Chromium (VI) compounds
Chromium and/or chromium (III) compounds
Cobalt and/or cobalt compounds
Copper and/or copper compounds
Fluoride salts
Lead and/or lead compounds
Mercury and/or mercury compounds
Molybdenum and/or molybdenum compounds
Nickel and/or nickel compounds
Selenium and/or selenium compounds
Silver and/or silver compounds
Thallium and/or thallium compounds
Zinc and/or zinc compounds
15
5.0
100
0.75
1.0
5
5b
80
25
180
5.0
0.2
350
20
1.0
5
7.0
250
500
500
10,000*
75
100
500
2,500
8,000
2,500
18,000
1,300
20
3,500C
2,000
100
500
700
5,000
Organic Substances
Aldrin
Chlordane
DDT, DDE, DDD
Dieldrin
Dioxin (2,3,7,8-TCDD)
Endrin
Heptachlor
Lead compounds, organic
Lindane
Methoxychlor
Pentachlorophenol
Polychlorinated biphenyls (PCBs)
Trichloroethene
0.14
0.25
0.1
0.8
0.001
0.02
0.47
-
0.4
10
1.7
5.0
204
1.4
2.5
1.0
8.0
0.01
0.2
4.7
13
4.0
100
17
50
2,040
' Excluding barium sulfate.
b If the soluble chromium as determined by the TCLP set forth in Appendix I of Chapter 18 of this division, is less than 5 mg/L,
and the soluble chromium, as determined by the procedures set forth in Appendix I of Chapter 11, equals or exceeds 560 mg/L
and the waste is not otherwise identified as a RCRA hazardous waste.
c Excluding molybdenum disulfide.
STLC = Soluble Threshold Limit Concentration
TTLC = Total Threshold Limit Concentration
Source: Title 22, California Code of Regulations, Division 4.5, Section 66261.
TBL10-8.DOC
10-60
2 April 1998
-------
Table 10-9. Determination of Soil Cleanup Standards for SWMU 6
Constituent
Background
Threshold*
Maximum
Concentration
Detected
Threat to
Beneficial
Uses In
Groundwater
Threat to
Background
Groundwater RBC
Quality E-06
RBC
Hl = 1
RL
Equilibrium
Partitioning Limit
Region IX Protective of
PRO" Beneficial Uses'
Equilibrium
Partitioning Limit
Protective of Model
Background" Level*
Cleanup
Standards
Pesticides and Herbicides (ug/kg)
Dicamba
Dieldrin
Endrin
Hcplachlor
Undone
2,4.5-T
2.82
1 2.9
1
13.5
1.23
2.97
3.84
24.9
66.7
23
56
74.8
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10
2
3
1.5
1.7
5
20,000.000
120
200.000
420
1,500
6,800,000
1.3
O.I
21
0.1
0.2
14
0.01
0.01
O.I
0.04
<0.01
0.02
NE
3'
NE
NE
5
NE
10
3
3
1.5
1.7
5
Background threshold values were determined for metals in all site soils; background threshold values Tor pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA. 1996).
Equilibrium partitioning limit based upon equivalency of numerical beneficial use limits to soil-water concentrations.
Equilibrium partitioning limit based upon equivalency of background threshold values in groundwaler (A Horizon) to soil-water concentrations.
Model level derived using vadose zone and groundwaler modeling, and based upon predicted achievement of numerical beneficial use limit in groundwaler at the source area.
Model level extrapolated from SWMU 7, which has similar concentrations and distribution of dieldrin.
HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly delected as verified by the use of a low-level standard
D
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73
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-------
Table 10-10. Determination of Soil Cleanup Standards for SWMU 7
Threat to Threat to Equilibrium
Maximum Beneficial Background Partitioning Limit
Background Concentration Uses In Groundwater RBC RBC Region Protective of
Constituent Threshold* Detected Groundwater Quality E-06 Hl = 1 RL IX PRG6 Beneficial Uses'
VOCs (jig/kg) • Pit F Only
1,2-Uichloroclhcnc NE 7.1 Yes Yes NA NA 10 120,000 1.2
Trichloroclhenc (TCE) NE 22 Yes Yes NA NA 5 7,000 1.3
SVOCs
-------
Table 10-11. Determination of Soil Cleanup Standards for
Background
Constituent Threshold*
SVOCs(ng/kg)
bis(2-Eihylhcxyl)phlhalaic
Oiclhylphlhalale
2,4-Uinilrotolucnc
Naphthalene
NE
NE
NE
NE
Maximum
Concentration
Detected
4.000
120
220
2,100
Threat to
Beneficial
Uses in
Groundwater
No
No
Yes
Yes
Threat to
Background
Groundwater RBC
Quality E-06
Yes
Yes
Yes
Yes
NA
NA
NA
NA
HBC
HI = 1 RL
NA 330
NA 330
NA 330
NA 330
SWMU8
Equilibrium
Partitioning Limit
Region IX Protective of
PRG" Beneficial Uses'
140,000
10,000,000
1,400.000
2,400,000
224
1,222
9
21
Equilibrium
Partitioning
Limit Protective
of Background Model
Water Quality" Level*
122
0.2
0.4
21
NR
NE
NE
NE
Cleanup
Standards
330
330
330
330
Pesticides and Herbicides (|ig/kg)
Chlordane. total
2.4-D
ODD
DDE
DDT
DDX, Total
Dicldrin
Lindane
Linuron
MCPA
Sintazinc
585
3.06
28.1
1.284
2.565
3.877
12.9
1.23
96
66.2
84
2.130
47.2
51,400
15.200
2.640
69.240
2.640
34.3
280
82.5
300
Yes
Yes
Yes
No
No
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
NA
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
30,000'
600'
NA
NA
NA
NA
NA 5
NA 25
NA 3
NA 3
NA 3
NA 3
NA 2
NA 1.7
NA 200
NA 5.000
NA 10
1,500
6.800
7.900
5,600
5,600
NE
120
1,500
1.400.000
6,800,000
16,000
10
11
81
NA
7
NA
O.I
0.2
1
1
1
10
0.02
3
15
1
NA
0.01
0.004
0.1
O.I
0.1
NE
NE
NR
NR
NR
NE
2
NE
NE
NE
NE
10
25
81
NE
7
30,000
2
1.7
200
5,000
10
Petroleum Hydrocarbons (pg/kg)
TPII as Gasoline
TPH as Diesel
TPH as Motor Oil
NE
NE
NE
11
2,600
14,000
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA NE
NA NE
NA NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
l.OW
10,000"
10.0001
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA, 1996).
Equilibrium partitioning limit based upon equivalency of numerical beneficial use limits to soil-water concentrations.
Equilibrium partitioning limit based upon equivalency of background threshold values in groundwatcr (A Horizon) or detection limits to soil-water concentration.
Model level derived using vadusc zone and groundwatcr modeling, based upon predicted achievement of MCL in groundwalcr.
Risk-based cleanup standard based on mitigating exposure to future construction workers.
Limits for TPH were determined using the scoring criteria in the Tri-Rcgional guidance.
Ml = hazard index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remedial Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly delected as verified by the use of a low-level standard
-------
Table 10-12. Determination of Soil Cleanup Standards for SWMU 20 and Area 1 Building 10
Equilibrium
Threat to Threat to Partitioning
Maximum Beneficial Background Limit Protective
Background Concentration Uses In Groundwater RBC RBC Region IX of Beneficial
Constituent Threshold* Detected Groundwater Quality E-06 Hl = 1 RL PRG" Uses'
VOCs (jig/kg)
Trichloroelhenc (TCE) NE 630 Yes Yes NA NA 10 7,000 1.3
Elhylbcnzcne NE 6.1 No Yes NA NA 5 230.000 653
Xylcncs NE 35 No Yes NA NA 5 320,000 582
SVOCs (ug/kg)
Diethylphlhalalc NE 490 No Yes NA NA 330 10,000,000 1,222
2.4-Oinitrophenol NE 3.210 Yes Yes NA NA 1.300 1.400,000 II
Pentachlorophenol NE 2,380 No Yes NA NA 830 7.900 227
2,4.6-Trichlorophcnol NE 1.420 Yes Yes NA NA 330 170.000 10
Pesticides and Herbicides (fig/kg)
Dieldrin 12.9 5.3 No Yes NA NA 2 120 O.I
Mclhiocarb 820 900 Yes Yes NA NA 500 NE 1
MCPA 66.2 79.3 Yes Yes NA NA 5.000 6.800,000 1
Unuron 96 240 Yes Yes NA NA 200 1,400,000 1
Petroleum Hydrocarbons (Ug/kg)
TPH as Diesel NE 500 Yes Yes NA NA NE NE NE
Equilibrium
Partitioning
Limit Protective
of Background Model Cleanup
Water Quality" Level* Standards
0.3 36 5 (350 ppb')
1 NE 5
0.3 NE 5
0.2 NE 330
5 NE 1400
7 NE 830
7 NE 330
0.01 27 2
1 NE 500
O.I NE 5,000
O.I NE 200
NE NE lO.OOO"
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA, 1996).
Equilibrium partitioning limit based upon equivalency of the numerical beneficial use limits to the soil-water concentration.
Equilibrium partitioning limit based upon equivalency of background threshold values or PQLs to the soil-water concentration.
Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of MCLs in groundwater at the source area.
Soil cleanup standard for TCE for treatment with S VE corresponds (o a target soil-gas cleanup standard of 1 .9 pg/L (350 ppbv).
Standards for TPH were determined using scoring criteria from Tri-Rcgional Guidelines.
Ill = Hazard Index
NA = not applicable
NE = nut evaluated
NR = Not Required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to Ihe lowest concentration that can be rcproducibly delected as verified by the use of a low-level standard
DDJC-Tracy Site-Wide Comprehensive Record of Decision
-------
Background
Constituent Threshold*
VOCs(ug/kg)
Acetone
2-Butanone (MEK)
Ethylbcnzene
2-llexononc
4-Mctliyl-2-pcnianonc (MIUK)
Toluene
Xylcncs
SVOCs(ug/kg)
2,4-Dimethylphenol
Fluoranthene
2-Methylnaphlhalene
4-Methylphenol
Naphthalene
Phenanthrene
Phenol
Pyrene
Petroleum Hydrocarbons (Mg/kg)
TPH as Gasoline
TPH as Diesel
Pesticides and PCBs (|ig/kg)
PCBs(Aroclor-l260)
Cartiofuran
Lindane
Phorale
Ronnel
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
490
1.23
38.8
40.8
Table 10-13.
Maximum
Concentration
Detected
860.000
500
37.000
66.000
80
160.000
200.000
260
23.000
30.000
880
20,000
24,000
350
16,000
5.160
1.390
450
620
30
439
353
Determination of Soil Cleanup Standards for SWMU 24
Threat to
Beneficial
Uses In
Groundwater
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Threat to
Background
Groundwater RBC
Quality E-06
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
RBC
HU1
NA
NA
NA
NA
NA
16,000'
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
RL
10
10
10
10
10
5
5
330
330
330
330
330
330
330
330
1
10
30
500
1.7
20
35
Equilibrium
Partitioning Limit
Region IX Protective of
PRG" Beneficial Uses'
8,800.000
27.000.000
230,000
NE
2,800,000
880,000
320,000
14.000,000
27,000.000
NE
3.400.000
240.000
NE
100,000,000
100.000
NE
NE
340
34,000.000
1,500
140,000
34,000.000
89
30
653
0.3
436
56
582
34
8.023
6
17
21
14
1
5,610
NE
NE
182
4
0.2
17
1.038
Equilibrium
Partitioning Limit
Protective of Cleanup
Background" Standards
0.4
0.3
1
3
6
1
21
14
0.3
27
NE
NE
45
0.2
0.004
2
1
10
10
10
10
10
5
5
330
330
330
330
330
330
330
330
1,000'
10,000'
30
500
1.7
20
35
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA, 1996).
Equilibrium partitioning limit based upon equivalency of numerical beneficial use limits to soil-water concentrations.
Equilibrium partitioning limit based upon equivalency of background threshold values in groundwalcr (A Horizon) or detection limits to soil-water concentrations.
Risk-based cleanup standard based on mitigating exposure to future depot workers to toluene in indoor air and arbitrary assumption that toluene concentration must be reduced by a factor of 10.
Limits for TI'M were determined using the scoring criteria in the Tri-Kcgional Guidelines.
n
k
5.'
n
n
i
HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding lo the lowest concentration that can be reproducibly delected as verified by the use of a low-level standard
8
3
O
-------
Table 10-14. Determination of Soil Cleanup Standards for SWMU 27
Equilibrium
Threat to Threat to Equilibrium Partitioning
Maximum Beneficial Background Partitioning Limit Limit Protective
Background Concentration Uses In Groundwater RBC RBC Region Protective of of Background Model Cleanup
Constituent Threshold* Detected Groundwater Quality E-06 HU1 RL IXPRG" Beneficial Uses' Water Quality* Level* Standards
VOCs(ug/kg)
Trichlorocthcnc (TCE) NE 5.9 No Yes NA NA 5 7,000 1.3 0.3 36' 5'
SVOCs (fig/kg)
Benzo(a)pyrene
Tola! PAHs
NE
NE
6.100
22,900 Jl I
Pesticides, Herbicides, and PCBs (fig/kg)
2.4-D 3.06 4.36
MCPA 66.2 142
PCBs(Aroclor-l260) NE 1.800J14
2,4,5-T 2.97 5.69
No
No
No
Yes
No
No
No
No
Yes
Yes
No
Yes
1,000 NA
IS.OOO" NA
NA
NA
1,000
NA
NA
NA
NA
NA
330
460
25
5,000
30
5
260
33,800
6.800.000
680.000
340
680,000
NA
NA
II
I
NA
14
NA
NA
0.02
O.I
NA
0.02
NE
NE
NE
NE
NE
NE
1,000
15,000
25
5,000
1,000
5
Petroleum Hydrocarbons (Hg/kg)
TPH as Motor Oil NE
12.000
Yes
Yes
NA
NA
10
NE
NE
NE
NE
10.000'
Background threshold values were determined for metals in all site soils; background threshold values Tor pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA, 1996).
Equilibrium partitioning limit based upon equivalency of the numerical beneficial use limits to the soil-water concentration.
Equilibrium partitioning limit based upon equivalency of MCL (TCE) background threshold values (A Horizon), or detection limits to soil-water concentrations.
Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of MCLs in groundwater.
Model level extrapolated from Area 1 Building 10, which has similar concentrations and distribution of TCE.
Soil cleanup standard for TCE corresponds to a soil gas cleanup standard of 1.9 ng/L (350 ppbv).
Sum of benzo(a)anlhracene, benzo(b)fluoranlhene, benzo(k)fluoranlhene, and indcno(l,2,3-cd)pyrcne.
Standards for TPH as motor oil were determined using scoring criteria from Tri-Regional guidance.
D
2
o
V)
III = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limil corresponding to the lowest concentration that can be rcproducibly delected as verified by the use of a low-level standard
o.
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a
3
3-
O
70
D
n
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-------
Table 10-15. Determination of Soil Cleanup Standards for Drum Storage Area Building 30
Background
Constituent Threshold*
SVOCs (ug/kg)
Benzyl alcohol
bis(2-Elhylhcjiyl)phtlialatc
Uiclhylphalale
Di-n-butylphthalate
NE
NE
NE
NE
Maximum
Concentration
Detected
1.300
2.800
230
96,000
Threat to
Beneficial
Uses In
Groundwater
No
Yes
No
Yes
Threat to
Background
Groundwater RBC
Quality E-06
Yes
Yes
Yes
Yes
NA
NA
NA
NA
RBC
Hl = 1
NA
NA
NA
NA
RL
330
330
330
330
Equilibrium
Partitioning Limit
Region IX Protective of
PRG" Beneficial Uses'
10,000,000
140,000
10.000.000
68,000.000
1.618
244
1.222
83,401
Equilibrium
Partitioning Limit
Protective of Cleanup
Background" Standards*
0.3
122
0.2
119
330
330
330
330
' Background threshold values were determined for inelals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
6 Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Equilibrium partitioning limit based upon equivalency of numerical beneficial use limits to soil-water concentrations.
d Equilibrium partitioning limit based upon equivalency of detection limits to soil-water concentrations.
' Cleanup standards serve as criteria fur evaluating the continued need for institutional controls.
HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-16. Determination of Soil Cleanup Standards for SWMU 2 and SWMU 3
Threat to Threat to Equilibrium
Maximum Beneficial Background Partitioning Limit
Background Concentration Uses In Groundwater RBC Ecological Region Protective of
Constituent Threshold* Detected Groundwater Quality E-06 RBC RL IXPRG" Beneficial Uses"
SVOCs (ug/kg)
bis(2-Elhylhexyl)phthalate NE 790 Yes Yes NA NA 330 140,000 244
2,4-Dimelhylphenol NE 450 No Yes NA NA 330 14,000,000 34
Di-n-butylphthalate NE 4.600 No Yes NA NA 330 68.000.000 83.401
4-Mclhylphcnol NE 400 Yes Yes NA NA 330 3,400.000 17
Pesticides (ug/kg)
Aldrin 0.817 30.2 Yes Yes NA NA 1.7 110 3
Chlordane. total 585 32,900 No Yes 8,000 NA 5 1,500 10
ODD 28.1 13.100 No Yes NA NA 3 7.900 1.600?
DDE 1,284 3.350 No Yes NA NA 3 5.600 I.8001
DDT 2.565 8.900 No Yes NA NA 3 5,600 1,700'
DDX, total 3,877 25.350 No Yes 30.000 241 3 5.600 NA
Dieldrin 12.9 4.770 Yes Yes 600 NA 2 120 370'
Uiuron 88.2 145 Yes Yes NA NA 260 1.400,000 4
Endrin 1 31.9 No Yes NA NA 3 200.000 21
Lindane (Gamma-BHC) 1.23 40 Yes Yes NA NA 1.7 1,500 0.2
Monuron 100 220 Yes Yes NA NA 260 NE 0.04
2,4-U 3.06 16.9 No Yes NA NA 25 6.800,000 47'
Hcptachlorepoxide 0.765 6.250 Yes Yes NA NA 1.5 210 0.004
Melals (ug/kg)
Lead NE NE No No NE 28,300 NE NE NE
Selenium 514 13,500 No No NA 616 NE NE NR
' Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
" Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Equilibrium partitioning limit based upon equivalency of the numerical beneficial use limits to the soil-water concentration.
J Equilibrium partitioning limit based upon equivalency of background threshold values (A Horizon) or PQLs to soil-water concentrations.
' Model level derived using vadosc zone and groundwater modeling, based upon predicted achievement of beneficial use limits in groundwatcr at the source area.
' Revised on basis of supplemental Dl-WET results obtained during removal action.
Ill = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remedial Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
Equilibrium
Partitioning
Limit Protective
of Background
Water Quality"
122
1
119
1
0.3
10
3
IS
1
NA
0.01
O.I
O.I
0.004
0.01
0.2
0.002
NE
NR
Model
Level*
NE
NE
NE
NE
NE
NR
NR
NR
NR
NR
O.I
NE
120
(120)
NE
NE
NE
NE
NE
NR
Cleanup
Standards
330
330
330
330
3
10
1,600
1,800
1,700
241
370
260
3
1.7
260
47
1.5
28,300
616
O
PJ
2
9
3
n
C/5
k
EL
"
o
3
3
n
3
5'
n
?
n
o
a.
0
?
n'
5*
-------
Table 10-17. Determination of Soil Cleanup Standards for SWMU 33
Constituent
Threat to Threat to
Maximum Beneficial Background
Background Concentration Uses In Groundwater RBC RBC
Threshold* Detected Groundwater Quality E-06 Hl = 1 RL
Equilibrium
Partitioning Limit
Region IX Protective of
PRG" Beneficial Uses'
Equilibrium
Partitioning
Limit Protective
of Background Model Cleanup
Water Quality* Level* Standards
VOCs (ug/kg)
Xylcncs
SVOCs (ug/kg)
Diclhylphlhalale
Di-n-bulylphlhalalc
Naphthalene
NE
NE
NE
NE
32
1 30
1.900
2.800 J
No
No
No
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
5
330
330
330
320,000
10.000.000
68.000.000
800.000
S82
1.222
83.401
21
0.3
0.2
119
21
NE
NE
NE
NE
S
330
330
330
Pesticides (ng/kg)
Aldrin 0.817 1.54
Carbaryl 230 540
Dicldrin 12.9 22.6
Melhiocarb 820 3.200
Hydrocarbons (jig/kg)
TPH as Diesel NE 15,100
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.7 110
400 68,000.000
2 120
500 NE
10
NE
3
24
O.I
1
NE
0.3
0.2
0.01
1
NE
NE
NE
27
NE
NE
1.7
400
2
500
100,000
Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
Region IX PRG based on industrial exposure scenario (USEPA. 1996).
Equilibrium partitioning limit based upon equivalency of the numerical beneficial use limits to the soil-water concentrations.
Equilibrium partitioning limit based upon equivalency of background threshold values (A Horizon) or detection limits to soil-water concentrations.
Model level extrapolated from SWMU 7, which has similar concentrations and distribution of B2EHP.
Standards for TPH as dicscl was determined using the scoring criteria in the Tri-Regional guidance.
HI = Hazard Index
NA = not applicable
NE = not evaluated
NK = not required
PRG = Preliminary Remedial Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresixmding to the lowest concentration that cnn be rcprnilnclhly delected as verified by llie use of a low-level standard
o
o
n
3
o
oq
n
k
Ex
n
O
rt
73
t
O
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
Table B-1.
Summary of Data Flags and Figure Abbreviations
Comments Explanation
1 Qualified due to detected concentration in associated method blank sample.
2 Qualified due to detected concentration in associated trip blank sample.
3 Qualified due to integration nonconformances; bias cannot be determined.
4 Qualified due to detected concentration in associated equipment rinsate blank sample.
5 Qualified as positively biased due to surrogate recoveries above the established acceptance limits.
6 Qualified as negatively biased due to surrogate recoveries below the established acceptance limits.
7 Qualified due to surrogate recoveries outside the established acceptance limits; bias cannot be
determined.
8 Qualified as positively biased due to MS/MSD recoveries above the established acceptance limits.
9 Qualified as negatively biased due to MS/MSD recoveries below the established acceptance limits.
10 Qualified due to MS/MSD recoveries outside the established acceptance limits: bias cannot be
determined.
11 Qualified as positively biased due to LCS recoveries above the established acceptance limits.
12 Qualified as negatively biased due to LCS recoveries below the established acceptance limits.
13 Qualified due to LCS recoveries outside the established acceptance limits; bias cannot be
determined.
14* Qualified as positively biased due to calibration nonconformances.
15* Qualified as negatively biased due to calibration nonconformances.
16 Qualified due to calibration nonconformances; bias cannot be determined.
17 Qualified as negatively biased due to holding time nonconformances.
18 Qualified as negatively biased due to sample receipt nonconformances.
19 Qualified as positively biased due to sample receipt nonconformances.
20 Qualified due to sample receipt nonconformances; bias can not be determined.
21 Qualified as positively biased due to other criteria (used twice, once for selenium and once for
miscalculation).
22 Qualified as negatively biased due to other criteria (Not used).
23 Qualified due to other criteria; bias cannot be determined (Not used).
24 Qualified due to detected concentration in associated source water sample.
25 Reporting limit estimated due to low standard response.
26 Chromatogram did not match the diesel standard fingerprint pattern.
27 Retention time windows shifted during analysis.
DUP = duplicate sample
J = qualified as estimated
mg/kg = milligrams per kilogram
mg/L = milligrams per Liter
NC = No Constituents detected above laboratory reporting limit or above background
R = qualified as rejected
TEQ = toxiciry equivalent, expressed as Mg/kg or jjg/L of 2,3.7-8 TCDD for soil and water, respectively.
TPHD = total petroleum hydrocarbons, diesel range
TPHG = total petroleum hydrocarbons, gasoline range
U = qualified as not detected
Mg/kg = micrograms per kilogram
jig/L = micrograms per Liter
* = most commonly used qualifiers
MS/MSD = matrix spike/matrix spike duplicate
LCS = laboratory control samples
APP-B.DOC B-l 12 December 1997
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
11.0 REFERENCES
Advanced Engineering & Planning Corp., Inc.
(AEPCO), 1991. Alternatives
Evaluation/Implementation Report,
Industrial Process System Assessment and
Process Alternatives Evaluation at Defense
Depot Region West (DDRW), Tracy.
January.
Anderson, D.W.; Jehl, J.R.; Risebrough, R.W.;
Woods Jr., L.A.; DeWeese, L.R.;
Edgecomb, W.G. Science 190, 806-8. 1975.
Canonic Environmental Services, 1989.
Laboratory Results of Lined Industrial
Wastewater Pond Samples. February.
Cal-EPA CVRWQCB, 1994. Basin Plan for the
Central Valley Region - Sacramento River
and San Joaquin River Basins. 1994.
Cal-EPA DTSC, 1992. Supplemental Guidance
for Human Health Multimedia Risk
Assessments for Hazardous Waste Site and
Permitted Facilities. July.
DDRW-Tracy, 1996. Personal communication
between Marshall Cloud of DDRW-Tracy
and Nancy Barnes of Montgomery Watson.
May 30.
Dupont, R.R., 1993. Bioventing/Soil Vapor
Extraction Do's and Dont's. Presented at
Montgomery Watson Remediation Seminar,
Concord, California. June.
Edens, F.W.; Benton, E.; Bursian, S.J.; Morgan,
G.W. Toxicology and Applied
Pharmacology, Volume 38, 307-14. 1976.
Edens, F.W. and Garlich, J.D. Poultry Science,
Volume 62, 1757-63. 1983.
ENSOTECH, 1991. Geologic Well Logs for
Interim Groundwater Remediation at Tracy
Defense Depot. Draft. February.
Heath, R.G.; Spann, J.W.; Kreitzer, J.F. Nature
(London) 224, 47-8. 1969.
Heintz, G.H.; Hoffman, D.J.; Gold, L.G.
Journal of Wildlife Management. 53:418-28.
1989.
Menzie, C.A.; Potocki, B.B; Santodonato, J.,
1992. "Exposure to Carcinogenic PAHs in
the Environment." Environment Science and
Technology, 26(7): 1278-1284.
Montgomery Watson, 1993. DDRW-Tracy,
California, Amendments to the
Comprehensive Remedial
Investigation/Feasibility Study (RI/FS)
Work Plan. June.
Montgomery Watson, 1994a. DDRW-Tracy,
California, Final Well Abandonment Work
Plan. September.
Montgomery Watson, 1994b. DDRW-Tracy,
California, Final Comprehensive Site Wide
RI/FS - Phase I Site Characterization
Report. October.
Montgomery Watson, 1994c. DDRW-Tracy,
California, Final Comprehensive Site Wide
RI/FS - Phase 11 Work Plan. December.
Montgomery Watson, 1995. DDRW-Tracy Draft
Comprehensive RI/FS. Phase II Technical
Memorandum. March.
Montgomery Watson 1996a. DDRW-Tracy
California, Final Comprehensive Remedial
Investigation/Feasibility Study. Volumes I
and II. November.
Montgomery Watson, 1996b. DDRW-Tracy,
California, Remedial Action Work Plan for
Operable Unit 1. January.
Montgomery Watson, 1996c. DDRW-Tracy,
California, Final Remedial Design Report
and Analysis for Operable Unit 1, 100
Percent Submittal. April.
Montgomery Watson, 1996d. Final
Comprehensive Site-Wide Baseline Risk
Assessment, Appendix R to the DDRW-
Tracy Comprehensive RI/FS. November.
SEC-II.DOC
11-1
31 Match 1998
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DDJC-Tracy Site-Wide Comprehensive Record of Decision
Montgomery Watson, I996e. DDRW-Tracy.
California, Final Construction
Specifications, OU 1 Remedial Design, 100
Percent Submittal. April.
Montgomery Watson, 1996f. DDRW-Tracy,
Final Well Abandonment Engineering
Report. November.
Montgomery Watson, 1996g. DDRW-Tracy,
California, Final Explanation of Significant
Differences. January.
Montgomery Watson, 1997a. Final
Comprehensive Site-Wide Proposed Plan.
November 1996.
Montgomery Watson, 1997b. Draft Technical
Memorandum Site-Specific Risks for
Exposure Units 8, JO, and 11. June.
Radian, 1986. DDRW, Tracy, California,
Geohydrological Investigations, Final
Engineering Report.
Radian, 1996a. Final EE/CAfor the Industrial
Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons. January.
Radian, 1996b. Day Care Center Closure
Report.
Radian, 1996c. Final Underground Storage
Tank Closure Report. May.
Radian, 1996d. Draft Action Memorandum for
Removal Actions at the Industrial Waste
Pipeline, Sewage Lagoons, and Industrial
Waste Lagoons. February.
Radian, 1996e. Environmental Master Plan,
Version 1.0. Final. December.
Radian, 1997. DDRW-Tracy Well Monitoring
Program: 1996 Annual Monitoring Report.
April.
USATHAMA, 1980. U.S. Army Toxic and
Hazardous Materials Agency Installation
Assessment of Defense Depot, Tracy,
California, Report No. 181. October.
U.S. Army Environmental Hygiene Agency
(USAEHA), 1980. Solid Waste Special
Study No. 10-61-0165-81 DDTC. July.
USAEHA, 1985. Geohydrological Study No.
38-26-0488-85, Defense Depot, Tracy.
February.
U.S. EPA, 1988, CERCLA Compliance with
Other Laws, Draft Guidance, OSWER
Directive 9234.1-01, August 8, 1986.
U.S. EPA, 1989a. Exposure Factors Handbook,
EPA/600/8-89/043, 1989.
U.S. EPA, 1989b. Risk Assessment Guidance for
Superfund, Volume I: Human Health
Evaluation Manual (Part A), EPA/540/1-
89/002, Interim Final. December.
U.S. EPA, 1989c. Guidance on Preparing
Superfund Decision Documents: The
Proposed Plan, The Record of Decision,
Explanation of Significant Differences, The
Record of Decision Amendment. Interim
Final. July.
U.S. EPA, 1990a. RCRA Facility Assessment
Defense Depot, Tracy, California. April.
U.S. EPA, 1990b. National Oil and Hazardous
Substances Pollution Contingency Plan
Final Rule, 40 CFR Part 300, Federal
Register Vol. 55, No. 46, March.
U.S. EPA, 199la. Ecological Assessment of
Superfund Sites: An Overview, Publication
9345.0-051. December 1991.
U.S. EPA, 1991b. Human Health Evaluation
Manual Supplemental Guidance: Standard
Default Exposure Factors, Publication
9285.6-03. March.
Woodward-Clyde Consultants (WCC), 1992a.
Final Comprehensive RI/FS Work Plan,
DDRW-Tracy. September.
WCC, 1992b. Draft Final Operable Unit No. 1
RI/RA, DDRW-Tracy, California. July.
SEC- II. DOC
11-2
31 March 1998
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
WCC, 1992c. Operable Unit 1 FS Report
DDRW-Tracy, California. December.
WCC, 1992d. Draft Final Operable Unit 1
Rl/RA Report DDRW-Tracy, California.
July.
WCC, 1993. Final Operable Unit No. 1, Record
of Decision, DDRW-Tracy, California.
August.
SEC-ll.DOC 11-3 31 March 1998
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RESPONSIVENESS
SUMMARY
-------
DDJC-TRACY RECORD OF DECISION
RESPONSIVENESS SUMMARY
A. OVERVIEW
Since 1942, the DDJC-Tracy facility has played an active role in the Tracy community,
sen-ing as one of the largest employers in this historically agricultural region. According
to the installation's 1994 Community Relations Plan, the Tracy community is generally
well-informed about environmental concerns at the depot and generally supportive of the
installation's efforts to remediate its contaminated sites.
In February 1997, DDJC-Tracy published and distributed a Proposed Plan for Twenty
Sites (Proposed Plan), which summarized the cleanup alternatives considered in the
DDRW-Tracy Comprehensive Remedial Investigation/Feasibility Study (RI/FS). The
RI/FS identified twenty sites within the original installation boundaries where action is
required to reduce the risks posed by on-site contaminants. Preferred remedial
alternatives were identified for each of the twenty sites. The Proposed Plan was mailed to
the installation's 1,200-address community contact list, and was presented and discussed
at a public meeting held at the City of Tracy Community Center on 19 February 1997. •
Although the meeting was well attended, no verbal comments specific to the cleanup
alternatives presented in the Proposed Plan were received from the public. Public
comments recorded at the 19 February meeting included questions about:
• The installation's history of success with the cleanup of large contaminant plumes,
and the usual time frame for accomplishing such cleanups;
• The effectiveness of the installation's existing air stripper and groundwater treatment
system;
• The reuse of treated groundwater for agricultural purposes;
• The reuse of industrial wastewater from other industries in the community;
• How the reinjection of treated groundwater impacts the movement of contaminant
plumes;
• Other remediation projects under way at the installation; and
• Whether the installation is currently conducting any activities that would lead to the
future need for remediation.
An adjacent property owner submitted the single written comment received on the
Proposed Plan. In this comment the property owner expressed his overall support for
several of the proposed alternatives, and his concern about the capacity and the cost of the
proposed groundwater treatment system. This comment is addressed in Section C of the
Responsiveness Summary ("Summary of Public Comments Received During Public
Comment Period, and Agency Responses").
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B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in environmental issues at DDJC-Tracy has been low to moderate
throughout the course of the depot's history. Recurring issues of concern primarily
involve the movement of contaminants in groundwater.
In 1980, DDJC-Tracy (then known as Defense Depot Tracy) began sampling a series of
14 groundwater monitoring wells. In May 1984, the depot advised the California
Regional Water Quality Control Board (RWQCB) that the TCE and PCE levels in three
of these wells exceeded the respective state action levels. The depot's on-post newsletter,
the Tracy Triangle, addressed this situation in several articles beginning in July 1984.
Contamination issues at the DDJC-Tracy depot began to receive widespread coverage in
the local and regional press when, in July 1985, the installation was identified as one of a
number of sites to be studied by a county toxic waste task force. Nearby residents and the
principal of the nearest school were invited to a public meeting at Defense Depot Tracy
on 2 April 1986 to discuss the depot's groundwater monitoring program, the test results,
and future plans. Media attention continued as the installation added monitoring wells
both on- and off-site. In July 1986, State Assemblymember Patrick Johnston toured the
site's groundwater monitoring facilities. The installation's first Community Relations
Plan '(CRP) was also prepared that year.
Public participation activities waned until DDJC-Tracy was placed on the National
Priorities List of the U.S. Environmental Protection Agency's on August 30, 1990.
Following this listing, opportunities for community involvement in environmental
restoration activities increased. DDJC-Tracy issued a number of press releases, held
public comment periods on new environmental study documents, and conducted several
public meetings.
In May 1991, a series of interviews was conducted with community residents and
representatives. Community attitudes toward the depot and its environmental restoration
program were mostly favorable. Community concerns at that time included the effects
that a State of California "red line" around the depot might have on local real estate, the
impacts that the injection well system might have on local aquifers, the length of the
cleanup period, efforts to contain the contamination, and the desire for more information
about the depot's environmental restoration activities. Interviewees expressed an interest
in attending public meetings and in receiving newsletters and status reports. The CRP
was updated to reflect this new input.
The CRP was again updated in 1994. At that time, the principal environmental concerns
within the community involved the ongoing drought and the dropping groundwater table.
Related concerns included groundwater contamination of the Upper Tulare Aquifer due to
saltwater intrusion and/or various chemical and hazardous materials spills.
-------
In September 1995, DDJC-Tracy received a great deal of media attention when the depot
announced it had discovered pesticide residues in the lawn outside the installation's on-
site Child Development Center. DDJC-Tracy acted quickly to excavate and replace the
lawn, and to keep concerned parents and the community informed throughout this
process. A public meeting was held on 13 September 1995, at the Child Development
Center site to present the excavation plan and to answer all questions regarding the health
and safety of the children attending the facility. Specialists in the fields of toxicology and
risk assessment were included on the depot's presentation panel and informational
handouts were made available. The meeting was very well attended, and DDJC-Tracy
received high marks from the community and the press for its proactive handling of this
incident.
In June 1996, DDJC-Tracy initiated a new series of informational fact sheets for
distribution to the installation's community contact list. Fact Sheet #1 summarized the
Engineering Evaluation/Cost Analysis (EE/CA) for three on-post waste sites. A postage-
paid environmental concerns questionnaire was included with the fact sheet mailing.
A mailing to the community contact list in February 1997 served several purposes. The
mailing, which was introduced with a letter from DDJC's Commander, Captain Michael
Casey, transmitted a copy of the installation's Proposed Plan for Twenty Sites and
requested public comments on this document. The mailing announced a public meeting
to be held 19 February 1997 to discuss the Proposed Plan. Fact sheet #2 also announced
DDJC-Tracy's plans to reinstitute a Technical Review Committee (TRC), and included a
TRC membership application form. Per discussions with CaJ-EPA's Department of
Toxic Substances Control, it was determined that, due to the generally low level of
interest within the community, it was not necessary to establish a Restoration Advisory
Board at the depot. Instead, the TRC concept would be expanded to allow for more input
from community members.
The first meeting of the installation's new TRC, held at the City of Lathrop Council
Chambers on 22 May 1997 was attended by eleven community members of the TRC.
Topics of discussion included TRC formation logistics and the status of the installation's
remedial program.
A chronology of community involvement activities and media coverage to date is
attached to this document.
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C. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING
PUBLIC COMMENT PERIOD, AND AGENCY RESPONSES
Part I - Summary and Response to Local Community Concerns
Remedial Alternative Preferences
(1) Asphalt capping and encapsulation appear to be steps in the right direction, as toxics
become more of a hazard when they are extracted or otherwise entrained.
DDJC-Tracy Response: Comment noted.
(2) Alternatives involving excavation increase the potential for exposure to toxics.
DDJC-Tracy Response: Construction crews performing the excavation may be subject
to some additional risk. These crews can use risk reduction techniques, engineering
controls, and personal protective equipment to control any potential exposure to
excavated contaminants. The soil can be wetted to minimize airborne dust, and the
excavated material can be transported in covered vessels. These measures will minimize
short-term exposure to construction crews and the general public.
Excavation reduces the risk of exposure within the surrounding community. The
proposed excavations are primarily designed to remove threats or potential threats to
groundwater quality. If the contaminants are not excavated from the sites in question,
they will be more likely to contact groundwater and migrate beyond the depot boundaries.
Technical Comments
(1) If the injection wells are of insufficient capacity to handle the anticipated volumes of
treated wastewater, and overflow occurs as a result, then site conditions will not have
improved significantly.
DDJC-Tracy Response: The injection system is one of the most difficult design issues
to address. DDJC-Tracy will probably construct injection galleries to discharge the
treated water. The galleries are more expensive than injection wells, but can handle
larger volumes of treated water. Additional injection galleries can be constructed if the
need arises.
Cost Issues
(1) Given the limited number of families living in the path of the groundwater
contaminant plume, an alternative less costly than the proposed air stripper and
groundwater treatment system would probably be acceptable.
-------
DDJC-Tracy Response: The groundwater treatment system primarily addresses the
portions of the groundwaier plume that exceed federal and state action levels. These
federal and state standards apply to all aquifers regardless of the number of people
potentially impacted by a plume. DDJC-Tracy will fund the design, construction, and
operation of a treatment system that will reduce contaminant concentrations to these
action levels. Portions of the plumes with concentrations below the action levels will be
left to attenuate.
Part II - Comprehensive Response to Specific Legal and Technical Questions
(Not applicable.)
D. REMAINING CONCERNS
(Not applicable.)
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Attachment A
Chronology of Community Involvement Activities
and Media Coverage
July 1984 - An environmental update of the depot's groundwater testing program
appeared in DDRW-Tracy's monthly newsletter, the Tracy Triangle.
September 19S4 - A short article in the Tracy Triangle presented the results from the
June sampling of the 14 groundwater monitoring wells. The tests revealed traces of PCE
and TCE above state action levels in some wells.
December 1984 - A front-page article in the Tracy Triangle indicated plans to add 12
monitoring wells to track the source, or sources, of the chemicals.
May 1985 - An article in the DLA Dimensions announced that the drinking water at
DDRW-Tracy meets or exceeds all requirements of both state and federal agencies.
19 July 1985 - An article in the Tracy Press announced that DDRW is one of 61 sites to
be looked at by a county toxic task force.
20 July 1985 - A front-page article in the Manteca Bulletin announced that a task force
would study toxic waste sites in the area, including DDRW.
20 July 1985 - An article in the Stockton Record announced that Assemblymember
Patrick Johnston and Supervisor Bill Sousa would be forming a task force to help the
state agencies do better jobs and that the task force recognized DDRW as a toxic waste
site.
22 July 1985 - An article in the Tracy Press stated that a task force had been formed to
study toxic waste sites in San Joaquin County, including DDRW.
24 July 1985 - A front-page article in the Manteca News listed DDRW as one of the
toxic sites to be reviewed.
20 September 1985 - An article in the Modesto Bee announced that DDRW was
preparing to drill more test wells to determine whether the solvents contaminating the
base's groundwater were migrating onto surrounding farmland.
26 November 1985 - An article in the Modesto Bee stated that the San Joaquin County
Toxic Task Force wanted the military to adopt special safeguards in the event DDRW
was selected as a regional storage center for hazardous waste.
2 April 1986 - A public meeting was held at DDRW-Tracy to discuss the groundwater
monitoring program, test results, and future plans. Nineteen residents and the principal of
the nearest school were invited. Fourteen residents were in attendance.
-------
8 April 1986 - A press release was issued to announce the results from the additional
IK nhoring \vells and plans to install test wells off-site.
July 1986 - California State Assemblymember Patrick Johnston toured the site and was
brought up to date on the groundwater monitoring program.
July 1989 - An article in the Tracy Triangle announced DDRW's placement on the
National Priorities List (NPL) of the U.S. Environmental Protection Agency.
14 July 1989 - An article in the Stockton Record announced that DDRW had been
placed on the NPL by the U.S. EPA.
30 July-30 August 1989 - A Public Notice in the Tracy Press announced a public
comment period on the Draft Negative Declaration for the interim remediation system for
groundwater.
9-11 May 1990 - A public notice in the Tracy Press announced a public comment
period and a public meeting at the Tracy Public Library on a Draft Interim Remedial
Action Plan for site cleanup activities.
30 August 1990 - The Federal Register announced DDRW's placement on the National
Priorities List.
12 July 1991 - Public notices in the Tracy Press and Stockton Record requested public
comment on the Federal Facility Agreement for DDRW-Tracy.
30 August 1991 - Public Notices in the Tracy Press and Stockton Record requested
public comment on the Primary Document Delivery Dates for DDRW-Tracy.
15 October 1991 - An article in the Modesto Bee discussed DDRW Tracy's efforts to
locate a site for the depot's information repository.
3 August 1992 - An article in the Stockton Record updated the public on the cleanup
processes being conducted at DDRW-Tracy.
24 December 1992 - Public notices in the Tracy Press and Stockton Record announced a
public comment period and public meeting at the Tracy Public Library on the Feasibility
Study/Proposed Plan for Operable Unit 1.
14 January 1993 - An article in the Modesto Bee announced a public meeting for the
Proposed Plan for DDRW-Tracy.
15 January 1993 - An article in the Stockton Record discussed the public meeting held
on 14 January 1993.
-------
23 February 1994 - An article in the Tracy Press discussed the air-stripping process at
DDRW-Tracy.
30 March 1994 - A front-page article in the Stockton Record listed DDRW-Tracy as one
of three Superfund cleanup sites in San Joaquin County.
9 September 1995 - Articles in the Tri-Valley Herald and the Stockton Record reported
the discovery of traces of the long-banned pesticide DDT in the lawn area surrounding the
Child Development Center at DDRW-Tracy and described DDRW-Tracy's response.
13 September 1995 - DDRW-Tracy held a public meeting to discuss actions taken in
response to the discovery of DDT in the lawn area surrounding the on-post Child
Development Center. A panel of experts was available to answer questions from the
community.
22 April 1996 - DDRW environmental and public affairs staff teamed with Radian
Corporation to host an environmental awareness program and open house for local high
school students in conjunction with Earth Day.
23 April 1996 - Articles in the Stockton Record, Manteca Bulletin, Modesto Bee, and
Tracy Press reported on Earth Day activities at DDRW-Tracy and DDRW-Sharpe.
June 1996 - A fact sheet describing the Engineering Evaluation/Cost Analysis at three
DDRW-Tracy waste sites was distributed to the community contact list.
January 1997 - DDRW-Tracy's Proposed Plan for Twenty Sites (Proposed Plan) was
mailed to the community contact list, along with a fact sheet that announced the
reintroduction of the Technical Review Committee and encouraged public participation.
8 February 1997 - An article in the Tracy Press announced the upcoming public meeting
on DDRW-Tracy's Proposed Plan.
8 February 1997 - A front-page article in the Tracy Press reported that a small amount of
corrosion inhibitor had leaked during transport and described DDRW-Tracy's response.
9 February 1997 - An article in the Stockton Record announced upcoming public
meetings to discuss cleanup proposals at the DDRW-Tracy and DDRW-Sharpe depots.
22 May 1997 - A new Technical Review Committee met to learn about the progress of
DDRW-Tracy's Installation Restoration Program.
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^pP^fiESPONSE.Ta:^|i
^m£?AYSCM/»V OnUUCMTC *
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-TIJICV Site-Wide Comprehensive Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
O ARCHITECTURAL
D STRUCTURAL
D G EC-TECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Site-Wide Comprehensive ROD (Draft)
DATE October 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
01.
G2.
SWMU 33;
Responses lo
EPA General
Comment Nos.
I, 2, and 6
(April 4, 1997
EPA teller)
General Comments
The ROD has yet to reflect discussions between (he RPMs which result in
changes lo SWMU 4. Example: pending concurrence from Cal-EPA-RWQCB,
the threat to groundwater may no longer exist. Thus, the remaining threat to the
environment, as substantiated in the ecological risk assessment, will be the
remaining reason to take action. The entire ROD should be reviewed for
instances where text will need to be revised to reflect this change.
Although the response and revised ROD text adequately address EPA's concerns
associated with SWMUs 2 and 3, (here remain unresolved issues with SWMU 33.
DDRW-Tracy's response to General Comment No. I explains "a potential threat
to water quality will remain (aldrin, dieldrin, di-n-butylphthalate, and
diethylphthalate will be left in place). Institutional controls (specifically
groundwalcr monitoring) will be required lo delect any groundwalcr impacts from
SWMU 33." As explained in EPA General Comment No. 6 of April 4, 1997, a
Technical and Economic (T&E) analysis (which is acceptable in content and
format to the RWQCB) is needed to justify why cleanup to FS soil cleanup levels
is not feasible at SWMU 33. Such a T&E analysis has not been reviewed or
approved by the agencies and the existing T&E discussion in (he Draft ROD and
Final RI/FS does not appear adequate, as previously expressed. Nevertheless,
EPA understands that DDRW-Tracy is proceeding with the SWMU 33 Removal
Action, even though the regulatory agencies have not approved the proposed
remedy (limited excavation and disposal with institutional controls). Unless an
acceptable T&E analysis is approved by the agencies, further Remedial Action
may be required at SWMU 33 at a later date.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The treatment of SWMU 4 will be
modified throughout the entire ROD per
discussions with the agencies (see Sections
5.5.1, 6.6.5, and 9.7.1 for major revisions.
Non-concur. It is the understanding of
DDJC-Tracy that the proposed approach is
consistent with state requirements for the
protection of water quality. The stale
regulations do not require an action on the
basis of a potential threat to water quality.
Monitoring is required by the selected
remedy, and action levels have been
proposed to respond to any groundwaler
impacts. The ROD will be modifed to
indicate that monitoring must be continued
until contaminants are no longer present
above the specified cleanup standards or
until it can be demonstrated that there will
be no impact to groundwaler quality (sec
Paragraph 9.1.2). DDJC-Tracy is unaware
of any federal regulation requiring a
technical and economic (T&E) analysis lo
justify llic use of institutional controls.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF 12
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U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tracy Site-Wide Comprehensive Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
O GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Site-Wide Comprehensive ROD (Urafll
DATE October 15. IW7
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G2.
(Conl'd)
G3.
SWMU 33;
Responses (o
EPA General
Comment Nos.
1,2, and 6
(April 4, 1997
EPA Letter)
(Cont'd)
Cleanup Levels;
Responses to
EPA General
Comment No. 7
April 4, 1997
EPA Letter) and
June 6, 1997
Technical
Memorandum
The Excavation and Disposal altcrnntivc identified in the RI/FS which would
achieve FS soil cleanup levels at SWMU 33 was not even considered in the Draft
ROD. Specifically, sections 7, and 8 of the ROD do not evaluate, or even
mention, the only alternative from the RI/FS which is designed (o achieve FS soil
cleanup levels. Instead, the ROD substitutes the $4.7 million Excavation and
Disposal remedy from the RI/FS with a $0.24 million Excavation and Disposal
with Institutional Controls remedy, without explanation. Even though Section
7.6.2.2 assumes that the Removal Action for SWMU 33 will be completed, this is
no reason to drop out consideration of remedial alternatives identified in the
RI/FS, particularly the only alternative which would clearly achieve cleanup
objectives. Please revise Sections 7 and 8 to include evaluations of the
Excavation and Disposal remedy described in the RI/FS. If the $4.7 million
Excavation and Disposal is not the selected alternative, the ROD needs (o support
this position with an agency approved T&E analysis.
The response to L:PA General Comment 7 stales thai "All cleanup levels will be
made consistent with the tables in Section 8 of the final RI/FS." However, all
cleanup levels arc not consistent with the Final RI/FS. Instead, some cleanup
levels have been made less stringent as described in the Radian June 6, 1997
technical memorandum, Status of Analytical Method Changes and Reporting
Limit/Clean-Up Level Recommendations for DDRW-Sharpe/Tracy Programs.
This tech memo proposes some increases in soil cleanup levels at the SWMUs. It
also proposes increasing some of (he Waste Discharge Requirements (WDRs), as
well as changes to some analytical methods. The proposed increases in soil
cleanup levels and WDKs are the direct result of (imposed increases in laboratory
reporting limits, resulting from a survey of seven laboratories. lil'A has some
concerns with DDRW-Tracy's proposal to increase cleanup levels.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Sections 7.0 (Section 7.6.2 and
Table 7-14) and 8.0 (see Section 8.14 and
Table 8-2) will be revised to include the
$4.7 million excavation and disposal
remedy.
Concur. The memo will be revised to
include matrix and methods. The memo will
be included as Appendix F to the draft final
ROD. Comparative reporting limits for
water will be provided, and the tables will
be reorganized by matrix and to distinguish
between cleanup standards and effluent
criteria. The effluent monitoring program
will be designed (o achieve the lowest
possible achievable limit by the besl
available technology.
»MA!EU OF CEHND FORM 7 (Revised)
89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE
12
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DPRW-Tracv Site-Wide Comprehensive Record of Decision UUL 97)
DSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
O MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW She-Wide Ciuii|)n.-lnMiMvt: KOI) (Ur:ifu
DATE Uclnhct 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G3.
(Conl'd)
Cleanup Levels;
Responses to
EPA General
Comment No. 7
April 4, 1997
EPA Letter) and
June 6, 1997
Technical
Memorandum
(Cont'd)
The vast majority of (he soil cleanup levels ;it each SWMU arc based on the
reporting limit, even though calculated soil concentrations needed to protect
ground water quality are lower, typically by an order of magnitude, then the
reporting limit. This is evident from Tables 10-9 through 10-17 of the Draft
Comprehensive ROD. If the results of the equilibrium partitioning screening and
groundwater modeling are to be accepted as valid, proposed soil cleanup levels
are not necessarily conservative, since they may not be protective of groundwater
quality. The only reason soil cleanup levels have not been set even lower is for
practical reasons, i.e., laboratory reporting limits. It seems reasonable that one
would want to use the lowest reporting limit available in order to minimize
impacts to groundwater quality. From Table 2 of the June 6 technical memo, it
appears that some laboratories are certainly capable of reporting limits which are
lower than the proposed reporting limits in Sections 9.3 through 9.6 of the Draft
ROD. For this reason, EPA is concerned that using the average reporting levels,
and thus, the resulting cleanup levels, may not be fully protective of ground water
quality.
Since Cut EPA is the primary agency which determines what level of cleanup is
needed to protect the water resources of California and (o meet state ARARs
applicable to protecting water quality, DDRW-Tracy should immediately attempt
to obtain Cal EPA concurrence on the proposed changes to soil cleanup levels,
WDRs, and method changes.
Additionally, EPA recommends that the June 6 lech memo be formally submitted
ID the agencies and revised lo address NIC following concerns:
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL7VEP ATTACHED
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 3 OF 12
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDK W-Tracv Silc-WiJc Cninpfclmnxivc Kct-nrU of Decision (JUI. 97)
D SITE DEV & GEO
D ENVIR PROTAUTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Silo-Wide Cninprclicn.sivc RUU (Ufiifl)
DATE Oclobcr 15. I9'J7
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G3.
(Conl'd)
Cleanup Levels;
Responses to
EPA General
Comment No. 7
April 4, 1997
EPA Letter) and
June 6, 1997
Technical
Memorandum
(Conl'd)
Table 2 (June 6 tech memo) presents the results of a reporting limit survey
from seven laboratories. Unfortunately, this table does not identify the
analytical method and media (soil or water) associated with each analyte.
Since reporting limits can vary depending on analytical method and media,
this table should be expanded to identify the applicable melhod(s) and media
applicable to each analyte and laboratory. Additionally, the text should
explain if these methods are ones which characteristically have the lowest
reporting limits. If not, a detailed explanation should be provided.
With few exceptions, Table 2 presents comparative reporting limits for soil
(ug/kg) but not for water (u.g/L). As a result, a comparison of reporting
limits cannot be made for most WDR parameters, which are in units of (ig/L.
Thus, it does not appear that this table can be used to justify any increase in
reporting limits for WDR parameters in its current form.
The second paragraph on page 2 Males, "At this lime, Radian is not aware of
any regulatory concerns with meeting the |>cimilled monthly median criteria
for halogenated VOCs listed in the Waste Discharge Requirements." EPA
disagrees with this observation. As indicated in the 1996 Annual Report,
Appendix H, reporting limits exceeded the WDRs for the following VOCs:
chloroform, 1,1-DCE, PCE, and DCE. Since WDRs are ROD-bascd
standards, any excccdance of WDRs is a violation of the OU-I ROD. Thus,
any method changes proposed for effluent monitoring should be designed to
achieve the 0.5 Mg/L WDRs for the above VOCs in order to maintain
compliance with the ROD. Can the proposed change to Method
SWKO10/8020 achieve the 0.5 ug/l, reporting limits lor (he above VOCs or
can (lie existing Method SW8260 achieve these reporting limits more easily?
(Note also EPA's objection to the ROD referring to Radian's beliefs
regarding regulatory concerns; DI.A is legally the author of this ROD.)
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
OF CEHND FORM 7 (Revised)
EDITIONS OF THIS FORM ARE OBSOLETE
PAGE!
B9
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Site-Wide Comprehensive Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
Q OTHER
REVIEW Silc-Wide Comprehensive ROD (Dr;ifl)
DATE October 15. 1997
NAME Michael Work, EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G.1.
(Conl'd)
04.
Cleanup Levels;
Responses to
EPA General
Comment No. 7
April 4, 1997
EPA Letter) and
June 6, 1997
Technical
Mcmornndum
(Cont'd)
Day Care
Center;
Response to
EPA General
Comment No. 8
and Detailed
Comment No.
23 (April 4,
1997 EPA
Letter)
• Tables I and 2 and (he supporting text arc often confusing because WDRs,
soil cleanup levels, and aquifer cleanup standards are addressed together.
For clarity, all discussion of method changes, reporting limits, and cleanup
levels should be separated into three distinct sections - one addressing
WDRs, one addressing soil cleanup levels, and one addressing aquifer
cleanup standards. Per Table I, EPA expects that there will be no proposed
changes to aquifer cleanup standards.
After the revised tech memo has been reviewed and approved by the regulatory
agencies, the ROD must incorporate all cleanup standards and should cite this
memo as the basis for some of the cleanup standards.
The response to bold comments indicates that the Day Care Center will be treated
as a timc-criiical removal action, however this is often not reflected in the
document. Please revise Table D (Declaration) to identify the selected remedy
for the Day Care Center site and to indicate the remedy was implemented as a
time-critical removal action. Please also revise Section 5.7.21 to indicate that (he
selected remedy is not "No Further Action", hut excavation and disposal and that
the action was implemented as a lime-critical removal action. Additionally,
Section 6.5.10 should clarify that the remaining risks at (he Day Care Center site
are less than I x 10-6 and HI = I and that (he action taken was a time-critical
removal action.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The treatment of (he Day Care
Center as a lime-critical removal action will
be clarified as indicated (sec Section 5.8,
6.5.15, and Table D-l). Il will be clarified
that the incremental risk associated with
soils remaining at the Day Care Center was
reduced (o zero.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 5 OF 12
F \COMMFNIS OOHOOO ROOTRAC f DOC
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tracv Silc-Widc Comprehensive Record of Decision (JUL 97)
OSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
n SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Site- Wide. Comprehensive
October 1 5. 1997
Midmcl Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G5.
Groundwalcr;
Response to
EPA General
Comment Nos.
3 and 10 and
Detailed
Comment Nos.
21 and 33
(April 4, 1997
EPA Letter)
This comment was inadequately addressed. As previously explained by EPA, this
ROD must COMPREHENSIVELY address groundwalcr contamination. It should
not simply be an extension of the OU-1 ROD. However, in many sections of this
ROD, the groundwater remedy is still not comprehensively addressed.
In (he Declaration, Section D.4.1 (Description of (he Remedy), the (cxt was not
revised to indicate (hat (he Comprehensive ROD will rcevaluate the OU-I ROD
(and subsequent ESD) decision for the OU-1 VOC plume to determine if it still
appropriate. Instead, the text was revised to state "This ROD includes a
comprehensive evaluation of all groundwater issues..." Although this latter
statement is accurate, it is not sufficiently specific. Please revise (he "Description
of the Remedy" as previously requested. Additionally, Table D-l (selected
remedy for each site) slid docs not list the preferred rcmcdy(ics) for groundwater
remediation. This ladle should provide a comprehensive summary of the selected
remedies.
Section 7.3.2 (Remedial Action Objectives) and Section 7.3.3 (Remedial
Alternatives) only address dicldrin contamination. Per EPA General Comment
No. 10, these sections should address all groundwalcr constituents which warrant
cleanup, including VOCs. It is not sufficient to address VOC (OU-I) ground water
contamination only in Section 4.3.1 (Background). Please revise Sections 7.3.2
and 7.3.3 to make (hem comprehensive, i.e., they should identify remedial action
objectives and remedial alternatives for VOC and dicldrin contamination in
groundwater.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Accepted. The evaluation of alternatives in
the OU I ROD is consistent with current
information on groundwalcr at the site.
DDJC-Tracy does not consider the OU I
ROD to be an interim ROD. Additional
text has been added to Section 7.3 regarding
the selection of the OU I remedy. Table 7-1
reviews all contaminants detected in
groundwalcr and determines if remediation
is required to address (he impacts. Section
8.2.1 provides an evaluation and modifies
the selected remedy.
Concur. Tables D-l and 9-1 will be
modified to include OU I. The cost for
VOCs will also be referenced in (he text.
IN
1
1 OF CEHND FORM 7 (Revised)
JfVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 0
rtOfi M'KJl
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DPRW-Tracy Site-Wide Comprehensive Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
O ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
0 INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Site-Wide Comprehensive ROD (Drufl)
DATE October 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G5.
(Conl'd)
G6.
Groundwalcr;
Response In
EPA General
Comment Nos.
3 und 10 and
Detailed
Comment Nos.
2 land 33
(ApriU, 1997
EPA Letter)
(Cont'd)
SWMU4;
Response to
EPA General
Comment Nos.
12 (April 4,
1997 EPA
Letter)
Section 8.2 (Analysis of Remedial Alternatives for OU I Groundwater) continues
to focus on dicldrin. The eight criteria evaluations (Sections 8.2.2 through 8.2.9)
only address dieldrin contamination. Although Section 8.2.1 briefly discusses
VOC contamination, it is inadequate, both in terms of content and format.
Section 8.2.1 should be replaced by expanding sections 8.2.2 through 8.2.9, so
that they comprehensively evaluate both VOC and dieldrin contamination in
groundwaler.
Table 9-1 (Selected Remedy) still docs not address groundwater. It should be
revised to identify the comprehensive groundwater remedy. Table 9-3 (cost
summary) only addresses dieldrin in OU I groundwater. This table should be
revised to summarize costs for the comprehensive groundwater rcmedy(ics).
Figure 9-1 presents proposed extraction well locations for dieldrin contamination
only. Similar figures should be added which show the locations of extraction
wells and injection facilities for VOC groundwutcr contamination.
Although the proposed remedy has been modified to be more responsive to
agency concerns, it is possible (hat removal of 3 or 9 inches of sediment will not
achieve the stated cleanup standards listed in Section 9.5.1.2 (page 9-6). If this
occurs, it is EPA's understanding that DDRW-Tracy may attempt to justify no
further excavation based on a T&E analysis. However, since the cleanup
standards for DDT, ODD, DDE, and selenium are based on protection of
ecological resources (H1=IO) and not protection of background watei quality, a
T&E analysis cannot be used to justify nonnttainmcnt of cleanup standards for
these four contaminants. As a result, additional remedial action may be warranted
to provide protection of aquatic species. A contingency should be included in
this ROD for SWMU 4 in the event (hat cleanup levels are not achieved.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL7VEP ATTACHED
Comment noted. No T&E analysis is
anticipated for SWMU 4. This site is
presently being discussed with U.S. EPA,
and the risk assessment calculations are
being revised (see Section 6.6.5). If action
is performed, DDJC-Tracy will either
continue excavation or bring in backfill and
install a geofabric filter to isolate ecological
receptors from contaminants left in place.
This decision will be based on confirmation
sampling results.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 7 OF 12
t -COMMENTS oounoo
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tracv SHc-Widc Cumpiclicnsivc Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
O SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Site-Wide Comprehensive KO1J (Draft)
DATE October 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
G7.
Future Threat ID
Groundwatcr
from Vadose
Zone
Contamination
For some sites, potential impacts to groundwalcr arc no) being remedied by
cleanup proposed al those sites. For example, at SWMU I/Area 2, SVE will be
performed, even though it will not remediate PCBs which could potentially
impact groundwatcr in the future. At SWMU 24, biovcnting will be performed,
even though PCBs and pesticides would no) be fully remediated (sec page 9-15,
fust paragraph) and could impact groundwater in the future. At the Drum Storage
Area (Building 30), Institutional Controls are proposed, even though SVOCs
could impact groundwater in the future. Al SWMU 33, limited excavation will
be performed, although phthalates could impact groundwater in the future. At
SWMU 10A, no action is proposed, although the groundwater could be impacted
by SVOCs in the future.
For all such sites, downgradicnt monitoring is proposed to check for the presence
of these contaminants. However, the text indicates that downgradient monitoring
may occur for a period of only I to 4 years, in addition to monitoring associated
with (he long lenn well monitoring program. IIPA is concerned that this may be
insufficient time, since it is possible that the maximum impact to groundwater
could occur after (his I to 4 year period.
Constituents left in the soil that are considered a potential lineal (o gioundwater
may require long-term groundwalcr monitoring. If the impact to groundwater
may not occur for several decades, monitoring over a period of I to 4 years may
neither confirm nor deny whether groundwalcr could be impacted. Because of
uncertainties associated with the potential impact to groundwater and the lime of
its Inline occurrence, Ilie KOI) should clarify llial monitoring may he. required
beyond one or two 5-year review periods. Thus, the previous cost estimates for
institutional controls and groundwalcr monitoring may be inadequate and should
be rcevalualcd.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Additional discussion regarding
PCBs at SWMU I/Area 2 and SWMU 24
will be provided. The primary justification
for the selected remedy is (hat in each of the
examples cited (he impacts arc potential
instead of measured. If these constituents
are measured in the Well Monitoring
Program, the selected remedy will need to
be reconsidered.
Concur. Per paragraph 9.1.2, groundwaler
monitoring will continue until cleanup
standards are met or until it can be
demonstrated that no further threat to water
quality remains.
I' ^.U OF CEHND FORM 7 (Revised)
DEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Site-Wide Comprehensive Record of Decision (JUL 97)
DSITEDEV&GEO D GEOTECHNICAL D SAFETY D SYSTEMS ENG REVIEW Site- Wide Comprehensive ROD (Droll)
D ENVIR PROT&UTIL D MFG TECHNOLOGY D ADV TECH a VALUE ENG DATE rvmhcr IS l«)97
ARCHITECTURAL D ELECTRICAL O ESTIMATING DOTHER MAUJI^
n STBI irjURAL H iNRT*,rnNTRnLS n RPFr.iFirAT|nN|s NAME Michael Work. EPA
ITEM
1.
2.
3.
4.
5.
DRAWING NO.
OR REFERENCE
PagcD-l:
Section D.5.2
Page D-2
Section 6.1.2,
groundwalcr
exposure units,
page 6- 1
Table 6-5,
Summitry of
Potential
Human Health
Risks, Future
Receptors
Section 6.5,
Reference to
Technical
Memorandum
COMMENT
Detailed Comments
Section D.5.2 refers to five year reviews being conducted in accordance with
CERCLA I21(e). However this section of CERCLA refers to permits and
enforcement. Please explain the significance of this text with regard to five-year
reviews.
Regarding the EPA signatory, the correct title is Chief, Federal Facilities Cleanup
Office.
The second sentence states, "The Tracy Annex, OU- 1 , and properly north of the
depot were evaluated as three separate l£Us." Please clarify that these Ells are
groundwater EUs.
Please indicate dial Ilie "On-Depol Groundwalcr" CU is also Exposure Unit 1 .
The section should reference the addendum to the Basewidc Risk Assessment:
"Technical Memorandum, Site-Specific Risks for Exposure
Units 8, 10, and II."
ACTION CODES: W - WITHDRAWN
A - ACCEPTED/CONCUR N - NON-CONCUR
D - ACTION DEFERRED VE - VE POTENTIAL/VEP ATTACHED
ACTION
Concur. Paragraph D.5.2 should instead
refer to CERCLA I21(c ).
Concur. The signature page will be modified
as indicated.
Concur. Section 6.1.2 has been modifed
accordingly.
Concur. Table 6-5 has been corrected.
Concur. The addendum will be referenced
as indicated (sec Sections 6.5.6, 6.5.7, and
6.5.8).
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 9 OF 12
T (COMMENTS oounoo nootrwcY ooe
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tracv Site-Wide Comprehensive Record of Decision (JUL 97) .
O SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Silc-Widc Conipiclicnsivc KUD (Dr:ifl)
DATE Oclobcf 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
6.
7.
8.
y.
Table 6-7,
Summary of
Site Risks at
EU 10
Section 7.2,
ARAR for
Injected
Discharge,
page 7-6
Section 7.3.1.3,
Chloroform,
page 7-8
Table 7-1,
Chloroform
Remedial
Decision
Rationale
A value in Table 6-7 should be corrected to be consistent with results in the
technical memorandum for EUs 8, 10 and 11: SWMU 8 hazard index should be
17 rather than 1.7.
Section 7.2.6.14 describes the stale's Anti-degradation Policy (California
SWRCB Resolution 68-16) and Section 7.2.6.16 describes the California
SWRCU Resolution y2-4y. However, (he text is not clear if these ARARs apply
specifically to the injection of treated water. This should be clarified.
The last sentence of this paragraph incorrectly indicates that chloroform is
discussed in Section S.I.2. The lexl should be revised to indicate chloroform is
discussed in Sections 5.2.2. and 5.2.7.
The remedial decision rationale lor chloroform stales "detected levels may or
may not be depot-related." This is incorrect and is inconsistent with revisions to
Section 5.2.5, which indicate that chloroform at the depot and depot annex wells
arc loo far west and cross gradient to be attributed to off-site sources. Please
revise the rationale in Table 7-1 to be consistent with Sections 5.2.5 and 5.2.7.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. This value will be corrected as
indicated (sec Table 6-7).
Concur. SWRCB Resolulion 68-16 and
SWRCB Resolution 92-49 apply to all
discharge methods, including injection.
Section 7.2.6.14 has been modified
accordingly.
Concur. Section 7.3.1.7 has been corrected.
Concur. Table 7-1 will be modified
accordingly.
IN -iJJ OF CEHND FORM 7 (Revised)
•QEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE IQ
T \crjMMFWfv [j
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Sile-Wide Comprehensive Record of Decision (JUL 97)
OSITEDEV&GEO
D ENVIR PROTAUTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
O MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
a ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Silc-Widc Cumnichcn.sivc ROD (Draft)
DATE October 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
10.
II.
12.
Section 8,
Response to
EPA Detailed
Comment No.
31.a.I (April 4,
1997 EPA
Letter)
Section
8.14.1.1,
SWMU 33
Analysis of
Alternatives,
page «-22.
Table 9.1,
Response to
EPA Detailed
Comment No.
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDUW-Tracv Site-Wide Comprehensive Record of Decision (JUL 97)
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Site-Wide Comprehensive ROD (Draft)
DATE October 15. 1997
NAME Michael Work. EPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
13.
14.
15.
16.
Seclion9.3.IO,
SWMU8
Injection Well,
page 9-4
Figure 9-8, SVE
Well Locations
Section 9.5.3,
SWMU 7,
Kcspon.se to
I-PA Detailed
Comment No.
51 (April 4,
1997 EPA
Letter)
Section 10.15.
SWMU 33,
Response to
EPA Detailed
Comment No.
73 (April 4,
1997 EPA
Letter)
Please indicate on a figure the location of the proposed injection well and
expected zone of injection.
Please indicate SVE well locations on Figure 9-8 for VOC remediation at SB 108
and SB43I, as recommended in Section 9.6.2.4.
The response to this comment indicated that the revised draft ROD will clarify
when monitoring results may necessitate revaluation of the remedy (Institutional
Controls). No such language could he found in Section 9.6.3. Please clarify.
The response to this comment indicates (hat "best practical technology was
implemented consistent with SWRCU Resolution No. 68-16." Please see EPA
General Comment above on SWMU 33. A T&E evaluation, acceptable to both
EPA and Cal EPA, is needed to justify why the selected remedy uses the "best
practical technology."
ACTION CODES:
A • ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N • NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The extraction wells associated
with dicldrin at SWMU 8 are shown on
Figure 9-2. After wellhead treatment for
pesticides, the water will be pumped to the
OU I groundwutcr treatment system and
discharged to the OU I injection facilities
(Figure 9-1).
Concur. The locations of the SVE wells will
be relocated on Figure 9-9 as indicated.
Accepted. These concerns were addressed in
Paragraphs 9.7.3.7 and 9.7.3.8 (there is no
section 9.6.3 in the ROD).
Non-concur. We believe that monitoring is
consistent with SWRCB Resolution No. 68-
16 in this case. If impacts arc discovered
through monitoring, further action or a T&E
analysis will be necessary.
U OF CEHND FORM 7 (Revised)
'9
IEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE '
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DESIGN REVIEW COMMENTS PROJECT DDuw-TracvJuiv 1997 Drait ROD
CORPS OF ENGINEERS
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O GEOTECHNICAL
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a ADV TECH
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Draft
REVIEW
DATE October 15. 1997
NAME Kara Christcnson. Office uf Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Paragraph
2.2.2.4
Faragrapli 2.2.3
Paragraph 2.2.9
Tbl 2-2
Paragraph 3.0
This section still attributes the plume to an off-site source, bul response to M.
Work's comment #11 admits that source was oil-site. Sec also Paragraph 5.2.5
(attributed to on-sitc source) and Table 7-1 (attributed to off-site source). Please
revise.
Description of Well Monitoring Plan should specify numbers and locations of
wells, possibly a map.
Provide a reference to Table 2-2 to clarify which sites are no further action.
Since Section 2 deals with the Site History, the title for (his table, "Summary of
Site Status" is unclear without a timcframe. Does DDRW-Trucy mean current
status, or status as of a particular dale" Also, please provide explanation for
footnote '".'" which appears in SWMU 2/3 columns. Also, please list potential
COCs for Day Care Center.
Please dcscril>c and respond In public comments.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Disagree. Section 2.2.2.4 refers to a
particular chloroform plume that originates
off-site. There are chloroform detections
associated with DDJC-Tracy and a
chloroform plume associated with a
neighboring facility.
Concur. Table 7-1 will be revised to discuss
on-site chloroform concentrations.
Concur. The wells associated with the
remedies selected in this ROD and their
purpose are identified in Table 9-2. A map
showing all monitoring wells will be added
to Appendix Fi (see Figure H-2).
Concur. A reference to Table 2-2 will be
added to Paragraph 2.2.9.1.
Concur. All changes will be made as
indicated.
Public comments arc provided in the
Responsiveness Summary. A reference to
the Responsiveness Summary has been
added.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF 13
I r.'jMMFIIt'. (jOKtlMirt'/illur. lift.
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O SAFETY
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a OTHER
Draft
REVIEW
DATE Oclobcr 15. 1997
NAME Kara Chrislcnson. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
6.
7.
8.
9.
Paragraph 5.1.1
Paragraph
5.9.1.1
Tbl5-l9
Paragraph 6.5.6
10.
Paragraph 6.5.7
Please include RI/FS for GUI.
Typo.
This (able identifies a lower cancer risk than identified in Table 6-6. Please
correct.
It is unclear why discussion begins with these EUs. Please discuss EUs 1-7.
Second sentence is not logical. Other sites within EU 8 could be responsible for
cancer risk even if they were not sampled.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Hie first bullet in Paragraph 5.1.1
identifies the final document from the
remedial investigation of OU I.
Concur. Paragraph numbering will be
checked in Section 5.0.
Concur. The cancer risk for SWMU 27 will
be modified in Table 5-19.
Comment noted. The discussion in
Paragraph 6.5.6 begins with these exposure
units because they consist of multiple sites.
The analyses of these particular EUs arc
necessary to address risks on a sile-by-siic
basis. This is not n concern for EUs I
through 7.
Comment noted. No surface soil samples
were collected at the other sites. The
identified cancer risk was associated with
exposure to surface soils. Therefore, the
cancer risk is solely attributed to SWMU
27/Arca I. No reason to sample Ihc surface
soils at Ihc other sites was identified in the
Work Plan.
U OF CEHND FORM 7 (Revised)
u
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
-------
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DESIGN REVIEW COMMENTS PROJECT DDRw-TracvJuiv 1997 Draft ROD
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O SAFETY
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O OTHER
Draft
REVIEW
DATE October 15. 1997
NAME Kara Clirislensun. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
II.
Paragraph 6.5.8
12.
Paragraph 6.5.9
Explain why DDRW-Tracy is continuing to assess risk even (hough manganese at
SWMU7 and beryllium at SWMU 30 are within background levels. Provide
background ranges described by Shaklclt & Uoerngen.
Why does the first sentence exclude cm-depot and annex sites? Also, the meaning
of the last paragraph is unclear. What does DDRW-Tracy intend by the phrase
"one category high"? In addition, why does DDRW-Tracy contend here that
remediation is not required for SWMUs 1, 3 and 4, when these sites are included
elsewhere in (lie ROD for remediation. This paragraph should be revised or
deleted.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W • WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Accepted. This assessment was provided for
completeness. Beryllium concentrations
range from < 1 to 15 inicrograms per gram
throughout the Western U.S (the maximum
concentration at SWMU 30 was 2.56
inicrograms per grain). The estimated
arithmetic mean concentration for the
Western U.S. is 0.97 inicrograms per gram.
Manganese concentrations ranged from
<300 to 5,000 inicrograms per gram (the
maximum concentration detected at SWMU
7 was 970 inicrograms per gram). The
estimated arithmetic mean concentration for
the western U.S. is 480 micrograms per
gram. Paragraph 6.5.8 has been modified
accordingly.
Concur. The exclusion will be deleted.
Concur. An explanation of the biases will
be included in the draft final document
(Paragraphs 6.5.10, 6.5.11, 6.5.12, and
6.5.13).
Disagree. SWMUs 1, 3, and 4 are being
remediated for groundwatcr protection and
to protect ecological receptors. They are not
being remediated to protect human health.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 3 OF 13
p, oounoo nnrj rriAf.y t/y.-
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DESIGN REVIEW COMMENTS PROJECT uuRw-TiacvJuiv 1997
CORPS OF ENGINEERS
ROD
D SITE DEV & GEO
D ENVIR PROT&UTIL
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D GEOTECHNICAL
D MFG TECHNOLOGY
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D ADV TECH
D ESTIMATING
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a VALUE ENG
D OTHER
Draft
REVIEW
DATE October 15. 1997
NAME Kara Chrisiciison. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
13.
14.
15.
16.
17.
18.
Paragraph
6.5.10
Paragraph
6.6.6.3
Tbl 6-6
Tbl 6-7
Paragraphs
7.2.4.5 and
7.2.4.6
Paragraph
7.2.4.6
Is "remediation" correct or is "removal" more appropriate?
Why are Ihc concentrations for protective concentrations for ecological receptors
so different from those in Paragraph 6.6.6.4? Also, ROD should explain origin of
hazard index of 10 and why it is used as a standard.
Cancer risk in this table is inconsistent with cancer risk depicted in Table 5-19 (re
SWMU 27, Area 1, Building 206).
Hazard index in this table is inconsistent with HI in Table 5-11 (re SWMU 7).
Why were SWMUs 2 and 3 omitted from (his discussion?
AWQCs should be classified as TBCs, not ARARs. Also, please discuss whether
there arc stale-promulgated standards that should be considered ARARs.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/YEP ATTACHED
Comment noted. Remediation seems
appropriate in this context.
Comment noted. The comment appears to
refer to Paragraphs 6.6.5.3 and 6.6.5.4. 'Pic
risks differ because there is a greater
opportunity for bioaccumulation to affect
herons, which occur at SWMU 4 but not at
SWMUs 2 and 3. Paragraph 6.6.5.4 has
been revised for clarity.
Concur. Table 5-19 will be corrected
accordingly.
Concur. Table 5-11 will be corrected
accordingly.
Comment noted. Water discharged to
SWMU 2 immediately percolates into the
ground. SWMU 3 is no longer in use. This
is clarified in Paragraph 7.2.4.5.
Concur. This point will be corrected
throughout the document. No state-
promulgated standards were identified.
U OF CEHND FORM 7 (Revised)
iPREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAG]
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DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Juiv 1997 Draft ROD
CORPS OF ENGINEERS
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Draft
REVIEW
DATE October 15. 1997
NAME Kara Chrislcnsoii. Office of Rcaional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
19.
Paragraph 7.2.6
20.
21.
22.
Paragraph
7.2.6.2
Paragraph
7.2.6.7
Paragraph
7.2.6.14
The Federal Safe Drinking Water Act and its regulations concerning
Underground Injection Control, 40 C.F.R. Part 144, should be included as an
action specific ARAR. Subchapler 15 of the Porter Cologne Act should be
included as an action specific ARAR, particularly, Articles 1,2, 3, 5, 8, and 9.
Please clarify that the reference to Div. 4.5 of Title 22 in this section (identifying
action specific ARARs) is (he same as the regulations discussed in Paragraph
7.2.4.2 (identifying chemical specific ARARs).
Revise reference to "amendment".
Please clarify the following with respect to ground water extraction and treatment.
Resolution 68-16 is a state ARAR for the establishment of numerical limits for
the reinjection of treated groundwater into clean areas (i.e., high quality waters)
of an aquifer. These numerical limits arc established on both a monthly median
and a daily maximum basis. If treated groundwater is injected within the
contaminated plume, the concentration level in the groundwater cannot exceed
the concentration in the groundwater at the point of injection measured on a
monthly median basis. The concentration must also not exceed the federal and
slate ARARs. With respect to injection of treated groundwater outside the
contaminated plume, the effluent must meet daily and 30-day median
concentrations as specified in the ROD. In addition, please specify that hydraulic
control of the plume will be maintained during extraction of contaminated
groundwater and (rc)injcclion of treated groundwater.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. 40 CFR Part 144 will be added to
the action-specific ARARs (Paragraph
7.2.6.17). Title 27 regulations (replacing
Chapter 15) will be added as well
(throughout Section 7.2.6).
Concur. This ARAR is both chemical- and
action-specific.
Concur. The text will be revised to indicate
that the CAA and its amendments were
considered as ARARs in defining and
evaluating remedies.
Disagree. The RWQCB prefers the
language included in Paragraph 7.2.6.14.
The clarification regarding injection is
addressed on a site-by-site basis. The
frequency and concentrations are not
generally specified by Resolution 68-16 as
indicated in the comment; instead, a site-
specific determination is made. It is our
interpretation that all effluent discharged
must meet the 30-day median concentrations
specified in the ROD. Paragraph 7.2.6.14
will clarify that hydraulic control of the
plume will be maintained during injection.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 5 OF 13
1 '/iMMFIIir. (XH«n'X)IIMllll»'.M/if.
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DESIGN REVIEW COMMENTS PROJECT ppRW-Tracv July iw? Pratt ROD
CORPS OF ENGINEERS
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D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
Draft
REVIEW
DATE October 15. 1997
NAME Kara Cliristcnson. Office uf Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
23.
24.
25.
27.
Paragraph
7.5.1.2
Tbl 7-4 and
Paragraph 8.4.8
Paragraph 8. 2
Paragraph
8.2.1.1
Paragraph 8.3.2
Regarding SWMU 4, why hasn't DDRW-Tracy considered combining
Alternatives 2 and 3 as a 4th alternative? Alternative 3, removal of contaminated
material from the lagoon, docs not .seem (o address the Tact that contamination
may continue if (here is no source control. If this is not (he case, the text should
be revised to address this issue.
For SWMU 4, why is Alternative 2, source control, three times more expensive
than Alternative 3, limited excavation, particularly when (here is less soil to
remove under source control'.'
The reason dieldrin is the only contaminant discussed is not explained until
Paragraph 9.3.3. Section 8.2 should provide this explanation or refer to Paragraph
9.3.3.
Revise reference to section 7.2.
This paragraph raises similar issues as Paragraph 6.5.9 (Comment #12). Please
clarify what is meant by ?actual risk is likely to be one category lower due to bias
in risk estimate.? It is inappropriate to discredit the risk assessment at this stage.
It is unclear why DDRW-Tracy states that these sites do not require remediation
when the ROD is still proposing action for them. How can all alternatives,
including no action, IK protective of human health, particularly whcic Iheic is a
threat to groundwalcr?
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N • NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Comment noted. Future impacts, if any, are
better addressed through the stormwater
pollution prevention program. No known
existing upstream sources have been
identified.
Comment noted. Alternative 2 assumed
source control every 5 years for 30 years.
The repeated action results in a higher cost.
Concur. This explanation will be added to
Paragraph 8.2.1.1.
Concur. This reference will be corrected to
Section 7.3.
Concur. Additional clarification is provided
in Paragraph 6.5.10. The analysis of bias
was a part of the risk assessment.
Comment noted. Actions at these sites were
not required to protect human health. The
actions instead protect groundwalcr and/or
ecological receptors. Several of (he sites do
not pose a risk to human health. Instead,
they pose a risk to the environment.
1IEU OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
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DESIGN REVIEW COMMENTS PROJECT DDRw-TracvJuiv 1997 Draft ROD
CORPS OF ENGINEERS
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D OTHER
REVIEW utaii
DATE October 15. 1997
NAME Kara Christcnson. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
28.
Paragraph 8.4.4
29.
Paragraph 8.5.2
30.
Paragraph 8.6.9
31.
32.
Paragraph 8.9.3
Paragraph
8. II. 1.1
Please specify the long-term effectiveness of Alternative 3 if there is no source
control. This issue docs not appear to have been analysed.
Please clarify how all alternatives, particularly the no action alternative, are
protective of human health, especially if there is a potential threat to groundwater.
Please provide similar clarification in Paragraphs 8.6.2, 8.7.2, etc.
It seems unlikely that institutional controls protect the environment. Please
clarify.
Provide reference to support statement (hat PCB and pesticide soil contamination
present only a low threat to groundwaler.
Please explain status of buried drums found at this site.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Comment noted. No continuing sources
have been identified, so the long-term
effectiveness of Alternative 3 should be
high. Section9.7.1.15 indicates that the five-
year review will be used to assess potential
continuing sources.
Comment noted. The threat to groundwater
would not result in groundwater
concentrations that would endanger the
health of the potential users of groundwaler
identified in the risk assessment.
Accepted. The text will be modified to
clarify that "trigger levels" have been
established in the groundwater monitoring
program to identify when it is necessary to
reevaluate the selected alternative to protect
the environment.
Concur. Additional justification for this
decision will be provided in Paragraph 8.9.3
of the draft final ROD.
Concur. All drums were removed (TliLIC
nnginccring Corporation, 1991).
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 7 OF 13
T'C'JMMENIS UOMROO PriOinACY rXX".
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CORPS OF ENGINEERS
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CJ SYSTHMS ENG
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REVIEW
DATE
NAME
October 15. 1997
Kara Cliristcnson. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
33.
34.
35.
36.
37.
38.
39.
Paragraph
8.11.9
Paragraph
8.12.2
Paragraph
8.12.4
Paragraph 9.3.3
Paragraph 9.3.4
Paragraph 9.3.5
Paragraph 9.3.8
Tliis section says thai the State will not accept Alternative 2, but Table 8-2 rates it
high fur slate acceptance. Please revise either text or table, as appropriate.
Reference to future construction worker is inconsistent with Table 6-5, which
identifies (lie future grader operator.
Reference to "liability" seems inappropriate.
Please correct reference lo "this Comprehensive RI/FS".
Please revise first sentence. Section IU.3 presents all ARARs, not just those for
groundwater.
The diluent treatment slamlaitis were required nol "proposed" by the OUI liSD.
Please revise accordingly. Also, please explain the basis for concluding that
these standards arc not achievable. Please explain the origin of the laboratory
reporting limits.
Please explain why 30-year limcf'nimc is used.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N • NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The text in Paragraph 8.11.9 will
be revised to reflect a high likelihood of
state acceptance.
Concur. This paragraph will be modified lo
refer to a grader operator.
Concur. The potential exposure risk will be
clarified.
Concur. This reference will be modified
(Paragraph 9.5.3).
Concur. This sentence will be modified as
indicated (Paragraph 9.5.4).
Concur. Text will he modified lo show dial
the standards are required (Paragraph 9.5.5).
The memo on reporting limits will be
revised and submitted lo the agencies as
Appendix F lo the draft final ROD.
Comment noted. This duration was based on
page 6-13 of the Interim final Guidance for
Conducting Feasibility Studies Under
CliRCI.A (Paragraph related to has
changed to 9.5.8).
19
OF CEHND FORM 7 (Revised)
DEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGg'
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DESIGN REVIEW COMMENTS PROJECT upRw.Tracyjuiviw? Draft ROD
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REVIEW
DATE
NAME
Draft
October 15. 1997
Kara Christcnson. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
40.
41.
42.
43.
44.
45.
Paragraph 9.4.3
Paragraph 9.4.7
Paragraph 9.5.1
Paragraph
9.5.1.4
Paragraph
9.5.1.5
Paragraph
9.5.2.3
Please explain why Area I, Building 237 ilocs not require a TCP. cleanup
standard.
This paragraph suggests, hut docs not explicitly stale, that the paitics must
unanimously agree on when SVli may be permanently turned off. All parties
need to be clear on this.
Since Paragraph 8.4.4 associates this alternative with negative impacts on lagoon
ecosystem, DDkW-'l racy should explain why the alternative should still be
selected. Please explain how these impacts will be mitigated.
Please describe sediment sampling in more detail.
Why does follow-up monitoring omit some contaminants covered by cleanup
standards?
Please clarify basis for standards -- what does "(lie reporting limit" refer to?
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. A cleanup standard for TCH will be
added (Paragraph 9.6.3).
Concur. This point will be clarified
(Paragraph 9.6.5).
Concur. It is not possible to mitigate these
impacts. DDJC'-Tracy is concerned about
these potential impacts and questions
whether the long-term benefits of excavation
justify (he short-term impact to habitat.
Comment noted. Sediment sampling will be
fully detailed in (he remedial action Work
Plan.
Comment noted, 'lite contaminants thai are
omitted were not identified as potential or
existing threats to groundwatcr quality.
Concur. The reporting limit generally
corresponds to the quantifiable limit of a
chemical substance. Additional detail on
reporting limits will be supplied as
Appendix I- lo (he draft final ROD.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 9 OF 13
nn'itiri'ififnA'./nry:
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D ENVIR PROT&UTIL D MFG TECHNOLOGY D ADV TECH D VALUE ENG
D ARCHITECTURAL D ELECTRICAL D ESTIMATING D OTHER
D STRUCTURAL O INST&CONTROLS D SPECIFICATIONS
REVIEW
DATE
NAME
Uraft
October 15. IW7
Kara Clirislcnsun. Orficc of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
46.
47.
48.
49.
50.
51.
Paragraph
9.5.3.7
Paragraph
9.5.4.4
Paragraph
9.5.4.8
Paragraph
9.5.5.5
Paragraph
9.5.5.6
Paragraph
9.5.6.4
Why docs follow-up monitoring omit some contaminants covered by cleanup
standards?
Clarify basis for standards -- what do "the analytical method reporting limit" and
"calculated equilibrium partitioning limit" refer to?
Why does follow-up monitoring omit some contaminants covered by cleanup
standards?
Clarify "(he analytical method reporting limit".
Why does follow-up monitoring omit some contaminants covered by cleanup
standards?
Clarify basis for standards -- what does "reporting limit" refer to?
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The need for monitoring TPH will
be discussed with the KWQCH. It is
possible that monitoring for TPH will be
required, but no action level will be
established.
Concur. Equilibrium partitioning limits arc
discussed in Section 6.7. 'Ilic draft final
ROD will discuss reporting limits in
Appendix P.
Concur. The need for monitoring TPH will
be discussed with the RWQCB and an
appropriate action limit will be established.
Concur. The draft final ROD will discuss
reporting limits in Appendix F.
Concur. The need for monitoring TPH will
be discussed with the RWQCD, and an
appropriate action level will be established.
Concur. The draft final ROD will discuss
reporting limits in Appendix F.
OF CEHND FORM 7 (Revised)
fcEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE
DESIGN REVIEW COMMENTS PROJECT DDRw.TracvJuiviw? Draft ROD
CORPS OF ENGINEERS
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D G EC-TECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW Draft
DATE
NAME
Oclober 15. 1997
Kara Chrislcnson. Office uf Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
52.
53.
54.
55.
56.
57.
Paragraph
9.5.6.7
Paragraph
9.5.7.4
Paragraph
9.5.7.6
Paragraph
9.5.8.3
Paragraph
9.5.9.2
Paragraph
9.6.1.3
Why (Joes follow-up monitoring omit some contaminants covered by cleanup
standards?
Clarify basis for standards -- what docs "reporting limit" refer to?
Why docs follow-up monitoring omit some contaminants covered by cleanup
standards?
Clarify basis lor standards - what docs "reporting limit" refer to?
Please explain why institutional controls, i.e., a prohibition on grading soil, is
insufficient. The text suggests thai the only risk is to a grader operator; if grading
is prohibited, would there be any risk?
(.'lanly basis foi slamlaxls •- what docs "icpoilmj! limit" id'ci lu?
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The need for monitoring TPH will
be discussed with the RWQC1J, and an
appropriate action level will be established.
TCE and PCE are already monitored per the
requirements of the OU I ROD as part of
OU I. These requirements are included in
Table 9-2 of the draft final ROD.
Concur. The draft final ROD will discuss
reporting limits in Appendix I-'.
Concur. The need for monitoring TPH will
be discussed with the RWQCB and an
appropriate action level will be established.
Also, standards for PCBs and PAHs are
based on health risk; PCBs and PAHs do not
threaten groundwater quality.
Concur. The draft final ROD will discuss
reporting limits in Appendix I7.
Comment noted. Graders are the primary
workers in this area. DDJC-Tracy needs to
use this area for storage in (he future.
(.'oncur. The dr.'ill final KOI) will discuss
reporting limits in Appendix !•'.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE II OF 13
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE
DESIGN REVIEW COMMENTS PROJECT DDRw-Tracyjuiv 1997 Draft ROD
CORPS OF ENGINEERS
O SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
Draft
REVIEW
DATE October 15. 1997
NAME Kara Chrislcnson. Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
58.
59.
60.
61.
Paragraph
9.6.1.5
Paragraph
9.6.2.5
Paragraph 10.1
Paragraphs
10.4.2.2,
10.5.2.2,
10.6.2.2,
10.7.2.2.. etc.
Why docs follow-up monitoring omit sonic contaminants covered by cleanup
standards?
Explain why DDRW-Tracy would leave contaminants above cleanup levels.
Please specify contaminated sites that are recommended for no further action
(SWMUs lOAand 14).
These sections should clarify the relationship between ARARs and cleanup
standards by stating that ARARs urc the basis lor cleanup standards. The
references to tables in Section 7 seems unnecessary and somewhat confusing.
Also, these sections state that (he various tables "provide (he basis for developing
cleanup standards," which is inaccurate. These tables also contain the cleanup
standards themselves. Please revise this language accordingly.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL7VEP ATTACHED
Comment noted. All components of total
DDX (sum of ODD, DDE, and DDT) will
be monitored. Selenium and lead may
impact ecological receptors, but will not
impact groundwatcr.
Comment noted. These contaminants arc
generally below buildings or under paved
areas. The threat of migration to
groundwater is considered low. The threat
will be further reduced by grouting the
IWPL so that no water can enter the soil
through the pipeline. Groundwatcr
monitoring will be required because
contaminants will be left in place.
Concur. These sites will be specified in
Paragraph 10.1.
Concur. The relationship of cleanup
standards to ARARs will be clarified. The
tables in Section 7.0 do hot contain cleanup
standards (cleanup standards were not
identified for all of (he chemicals listed in
Table 7-1). Cleanup standards arc specified
in Section 10.0. The tables in Sections 6.0
and 7.0 provide the basis for developing
OF CEHND FORM 7 (Revised)
IEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE f
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE
DESIGN REVIEW COMMENTS PROJECT Donw-Tracv Juiv iw? Druft ROD
CORPS OF ENGINEERS
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
a MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
DOTHER
Until
REVIEW
DATE October 15. IW7
NAME
Kara Chrislciison, Office of Regional Counsel
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
61.
62.
63.
64.
Paragraphs
10.4.2.2,
10.5.2.2,
10.6.2.2,
10.7.2.2., clc.
(Conl'd)
Paragraphs
10.6.4, 10.8.4,
10.8.4, 10.10.4,
10.11.4,
10.12.4,
10.13.4, 10.14.4
Tbl 10-2 and
Tbl 10-3
Tbl 10-8
These sections do nut unuly/.c "permanent solutions, alternative treatment and
resource recovery." Please present a more specific analysis for each proposed
remedy. Also, the present language "to the maximum extent practicable" is
inappropriate, since none of DDKW-Tracy's remedies arc alternative treatments,
nor do they provide resource recovery.
ARAR 26 in Table 10-2 and ARARs 31 and 34 in Table 10-3 regarding 22 CCR
Division 4.5 are too vague. Please sec attached ARARs list for appropriate
specificity. Also, these tables should not include non-applicable requirements;
we suggest including (he non-applicable requirements as a table at the end of
Section 7. Finally, it is not appropriate at this point to continue to use the term
TBC; we suggest the term "performance standard."
Do these cleanup standards apply to surface and neai surface soils? 11 not, please
include a (able of cleanup standards for (hem.
ACTION CODES:
A • ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N • NON-CONCUR
VE - VE POTENTIAUVEP ATTACHED
cleanup standards. The SWRCB docs not
have a fixed process for selecting soil
cleanup standards, but all of the information
in the Section 6.0 tables is considered in
selecting an appropriate standard.
Comment noted. The language "to the
maximum extent practicable" is required by
U.S. EPA Guidance on Preparing Supcrfund
Decision Documents, pages 6-32 and 6-33.
The analysis provided appears to be
consistent with the guidance document.
Concur. The discussion of 22 CCR Division
4.5 will lie modified. Nonapplicablc
requirements will be moved to the end of
Section 7.0. The term TBC will be replaced
with performance standard.
Comment noted. These are not cleanup
standards. They arc disposal standards.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 13 OF 13
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DPRW-Tracv Site-Wide Comprehensive Recoid of Decision. Draft
O SITE DEV & GEO
D ENVIR PROT&UTIL
a ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
Q ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Site-Wide Comprehensive ROD (Draft)
October 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Soil Cleanup
Levels
General Comments
In the Draft ROD, DDRW Tracy presents a revised methodology to establish soil
cleanup levels for site remediation. The revised methodology replaces soil
cleanup levels selected for their prolecliveness of water quality that were
previously presented in the Draft ROD (February submitla!) and the Final
Feasibility Study (FS). The new methodology is derived from laboratory practical
quantification limits (PQLs). To establish the PQLs for DDRW Tracy,
equilibrium partitioning limit concentrations were developed for each constituent
using the maximum concentrations found at each site. The implementation of this
process has lead to an overall increase in the soil cleanup levels for a majority of
sites.
The establishment of PQLs represents a departure from the previous criteria for
(he development of soil cleanup levels. As such, there must be sufficient
documentation to support their prolecliveness of State ARARs. DDRW Tracy
needs to evaluate the soil cleanup levels derived from the PQLs on a site by site
basis and determine if they are sufficiently protective of the cleanup goals
established in ihe FS.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIA17VEP ATTACHED
Concur. Cleanup standards were
occasionally based directly on estimated
concentrations to protect background
groundwater quality. In many cases, the
concentrations derived from modeling and
equilibrium partitioning were well below the
concentrations that can be reproducibly
identified using existing technology. DDJC-
Tracy will provide additional rationale in the
draft final ROD on the conservative nature
of the model and equilibrium partitioning
estimates to support the development of
cleanup standards (sec Section 9.0 and
Appendix F).
The use of "PQL" will be removed from the
text. The cleanup standards presented are
consistent with (he lowest concentrations
that can be reproducibly identified using a
low level standard with best available
technology.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF 8
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tiacv Site-Wide Comprehensive Record of Decision, Draft
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
O STRUCTURAL
D GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Silc-Widc Comprehensive ROD (Draft)
October 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Well Monitoring
Program
Confirmation
Sampling
Five Year
Review
Group A Sites
The Draft ROD should describe that the well monitoring program is fluid and that
its parameters are subject to change. Specifically wells and the contaminants of
concern may be adjusted based on the continued evaluation of results.
The Draft ROD should include language explaining that confirmation sampling
will be included at sites where active remediation will be implemented. The
language should refer the reviewer to (he sampling and analysis plan for (he
facility.
The Draft ROD sets up limits for five year reviews based on costing purposes.
Five year reviews arc required under CERCLA Section 1218 for sites where
hazardous substances remain in place. Costing purposes are not included in the
statue and should be stricken form the Draft ROD as an element of a five year
review.
Specific Comments
The Draft ROD should include a discussion of post ROD remedial activities (i.e.,
remedial design work) to be conducted at these sites. Specifically that additional
soil-gas investigations to determine the lateral and vertical extent of vadose zone
contamination arc planned for Solid Waste Management Units (SWMUs) I, 20/23,
33, Area I Building 10, Area 2, and Area 3. The specifics of potential remedial
actions should also be described.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. This will be added to Section 9.1.2.
The decision logic from the Well
Monitoring Program will also be included in
Appendix E of the draft final ROD.
Concur. Reference to the sampling and
analysis plan will be added to Section 9.10.
Concur. Per paragraph 9.1.2, ground water
monitoring will continue until cleanup
standards are met or until it can be
demonstrated that no further threat to water
quality remains.
Concur. The additional investigation is
referred to in Paragraph 9.6.1. The text will
be modified to clarify that the additional
investigation will be a soil-gas investigation.
The VOC issues associated with SWMU 20
and the 1WPL in the vicinity of building 10
will be addressed under SWMU 20 (Section
9.7.5.1) rather than under the Group A sites.
OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
89
PA
t COMMENTS oonn'x> rv
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Site-Wide Comprehensive Record of Decision. Draft
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Site-Wide Comprehensive ROD (Draft)
October 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Group A Silcs
(Cont'd)
SWMU4
SWMU7
SWMUX
Section 9.5.1.7 states that the selected remedy is protective of human health and
the environment. It reduces the toxicity found in the sediment and surface water.
The Draft ROD should indicate that further maintenance of SWMU 4 will be
conducted under (lie Storm Water Management Program.
Section 9.5.3.4 lies any extension of the remedy to the five year review. This may
not be entirely accurate in that it implies that the remedy may be terminated at the
live year review. The Draft KOD should state (hut the remedy will be evaluated
for further action including the possibility of implementing active remedial action
at the five year review.
The Draft ROD portrays the remedy lor SWMU X in an inconsistent manner.
Section 9.5.4.5 slates thai excavation and disposal will permanently remove all soil
contaminants. However Section 9.5/tY) slates lhat potential further action at
SWMU H will depend upon the magnitude of any volatile organic compound
(VOC) reported. The sections should be rewritten to I) describe the proposed
action in more relative terms and 2) describe the additional actions being
considered and providing details of said actions.
ACTION CODES: W - WITHDRAWN
A - ACCEPTED/CONCUR N - NON-CONCUR
D - ACTION DEFERRED VE - VE POTENTIAL/VEP ATTACHED
Accepted. The specifics of the potential
remedial actions are described in paragraphs
9.6.7 through 9.6.10. Figures 9-3,9-4, and
9-5 show the conceptual design of the
system.
Concur. Paragraphs 9.7.1.15 and 9.7.1.16
that maintenance of SWMU 4 will occur
under the Storm Water Pollution Prevention
Program.
Concur. This reference will be deleted. Per
Paragraph 9.1.2, the third bullet in
Paragraph 9.7.3.4 states that groundwatcr
monitoring will continue until cleanup
standards arc met or until it can be
demonstrated that no further threat to water
quality remains. A general statement on the
revaluation of the selected remedy will be
added to Section 9.1.
Concur. The text will be clarified to
indicate lhat all known contamination will
he excavated (Paragraph 9.7.4.5).
Additional picdesign sampling is required
that may impact the scope of the selected
remedy (see Paragraph 9.7.4.6). No specific
additional actions have been identified at
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 3 OF 8
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PDRW-Tracv Site-Wide Comprehensive Record of Decision. Draft
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
O STRUCTURAL
D GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Silc-Widc Comprehensive ROD (IJrafl)
October 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
SWMU8
(Cont'cl)
SWMU24
6.
SWMU27
Dunn Storage
Area U30
The Draft ROD should include language relating to proposed additional design
work anticipated Tor this site.
The ROD recommends bioventing as the preferred remedial action. This remedial
action will not remove, reduce, or remediate detected levels of PCBs and
pesticides in the soil. Section 9.5.6.5 rationalizes this decision due to the low
levels of these compounds detected. This approach does not adequately justify the
position taken in the Draft ROD. Language should be added regarding the relative
levels of PCDs and pesticides involved related to the potential threat they impose
and the economic cost of remediation.
The Draft ROD should include language regarding the proposed soil
characterization for (his site.
The Draft ROD should present Ihc five year review us a lime for evaluating the
effectiveness ol the prescribed remedy, not as a trigger point for determining it's
continuance.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W • WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAUVEP ATTACHED
this time. The ROD will specify that the
predesign sampling results will be evaluated
in the remedial design process and that
additional actions will be identified as part
of the design process if necessary
(Paragraphs 9.7.4.6 and 9.7.4.7).
Concur. Additional language on predesign
soil-gas work has been added to the remedy
(Paragraph 9.7.6.6). Additional text will also
be added on the likelihood of groundwatcr
impacts from pesticides and PCDs
(Paragraph 9.7.6.5).
Concur. Paragraph 9.7.7.5 will be modified
to clarify that confirmation samples will be
collected following excavation.
Concur. Paragraph 9.7.8.4 will IK revised as
indicated (also see Paragraph 9.9.1).
U OF CEHND FORM 7 (Revised)
89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
t XQMMENIS'DOHR'XJ n>
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT UDRW-Tracy Site-Wide Comprehensive Record of Decision. Draft
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Silc-WitIc Comprehensive ROD (Drain
October 1997
Jim Pinasi-o. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
8.
Section 5.0
All compounds evaluated in lite I\S should IK listed and their Talc in terms of
eventual remediation should be described.
9.
Section 5.7.4
The rationale lor no further action needs to l>c added for SWMU 10.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAUVEP ATTACHED
Accepted. Many chemicals (not all of which
were determined to be contaminants) were
evaluated in the RI/FS (Montgomery
Watson, 1996). The Baseline Risk
Assessment identifies all chemicals that
were evaluated for risks to human health and
ecological receptors. Section 6.0 of the
RI/FS identifies all the chemicals that were
evaluated in the water quality assessment for
potential impacts on water quality. The
appendices of the RI/FS identify all
chemicals that were analyzed in addition to
the ones that were evaluated for risk or
impact to water quality. The RI/FS used this
analysis to identify contaminants of concern
(COCs) in Section 8.0. All CUCs are
identified in Section 5.0 of the ROD. The
basis for their identification as COCs is
discussed in Section 6.0 of the ROD
(summarizes conclusions from (he RI and
the BRA). The remedial solutions to
address COCs are developed, evaluated, and
selected in Sections 7.0, 8.0, and 9.0 of the
ROD.
Concur. Paragraphs 5.7.4.1 and 5.7.4.2
discuss the rationale for no further action at
SWMU IOA.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 5 OF 8
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tnicv Site-Wide Comprehensive Record of Decision. Dralt
OSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D AOV TECH
D ESTIMATING
D SPECIFICATIONS
O SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Silc-Widc Comprehensive KOI) (DrulD
Oclobcr 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
10.
II.
12.
Section 10.3.2
Sections
10.5.4.3,
10.6.4.3,
10.7.4.3, etc.
Section 10.7
Ilic term "Action Level" has no meaning anil should be replaced by maximum
contaminant level. The designation of the ARAR lor dicldrin us to be considered
(TBC) is not substantiated. It is the States opinion that it is applicable and should
be so stated in the Draft ROD.
These sections refer lo a public comment expressing a concern about the high cost
of soil excavation. The Draft ROD should include details of (he concern along
with DDRW Tracy's response.
The Draft ROD proposes to restrict the potential demolition of Buildings 19 and
21. It may not be prudent or possible to restrict the actual demolition of a
building. A more reasonable approach may be to restrict the use or access to the
designated building while they exist.
ACTION CODES:
A-ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Non-concur. This is a non-promulgated
action level developed by the Regional
Water Quality Control Board and should be
considered a TBC.
Accepted. The response is included in Part
C of ihe Responsiveness Summary. Cross-
reference to the responsiveness summary
will be provided throughout Section 10.0.
Non-Concur. The ROD does not rule out the
demolition of the buildings; however, the
presence of the buildings was considered in
the selection of the remedy (there is
technical justification for this since the
buildings substantially eliminate percolation
through contaminated vadosc zone soils).
There arc no health risks at the buildings so
access need not be restricted. Demolition or
excavation of the buildings needs to be
brought to the attention of the signatory
parties because this could result in the
mobilization of contaminants that arc
presently contained. Disposal issues would
also need to IK.' ptupcily addressed.
U OF CEHND FORM 7 (Revised)
69
tREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PA
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT PUKW-Tracv Site-Wide Ominiclicnsivc Record uf Decision. Draft
DSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
O MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Site-Wide Comprehensive KUIJ (Draft)
Oclubcr 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
13.
Section 10.7.1
14.
Section 10.7.4.1
15.
Section 10.9.5
The Draft ROD refers lo ground water monitoring actions with respect to the
cleanup. The Section should also include Icxt as lo how monitoring will be
conducted, who is included in the decision making body, and what is their
authority.
The Draft ROD portrays monitoring as u permanent solution. This is inconsistent
as nothing is being done to remove the threat of contamination. It is more proper
to characterize monitoring as evaluation of contamination of the environment and
also provide trigger levels.
Justify the expectation that phenols will naturally attenuate.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. This point will be clarified in
Section 9.1. Per discussion in the 4
November meeting, the Annual Well
Monitoring Report will be identified as a
primary document. As such, the agencies
may comment on the conclusions and
recommendations and use the dispute
process if necessary to resolve issues.
Non-Concur. Monitoring may not be short
term in this case. The RWQCB has agreed
that the potential threat to groundwater is
low at this site as long as existing buildings
and pavement remain in place, but this must
be verified through monitoring. The
"Trigger" levels that would require
evaluation are identified in Paragraph
9.7.3.7 (table). If no impacts are observed,
no further action is anticipated. Appropriate
remedies will need to be developed if trigger
levels are exceeded.
Concur. Additional discussion on phenols is
provided in Section 9.7.5.13.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 7 OF 8
f MK, f>'IMfr,(( ll'rflTrt*'. /
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT DDRW-Tracv Site-Wide Comprehensive Record of Decision. Draft
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D GEOTECHNICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Silc-WiJe Comprehensive ROD ,;Jriift)
October 1997
Jim Pinasco. DTSC
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
16.
Section 10.12
and 10.15
17.
18.
Section
10.12.4.1
Section 10.12.5
19.
Section 10.13.1
and 10.13.4.1
The Sections should include a detailed contingency to manage (lie threat of an
increase in the ground water contamination level (i.e., what are the trigger points
and what are their related contingencies).
The Draft ROD should include a description of (he institutional controls being
proposed.
The Draft ROD should provide detail of how the selected remedy will reduce the
volume of contaminants and provides short term effectiveness.
The heading for this Section "Preference for Treatment as a Principal lllcment" is
misleading. It portrays institutional controls as an active permanent remedy. The
heading should be rewritten to be more accurate.
The Section should include who is responsible for maintaining (he cap over its
lifetime.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Accepted. Trigger levels were provided in
Paragraphs 9.7.8.4 and 9.8.2.5. Institutional
controls are described in Section 9.0.
Concur. This point will be clarified as
indicated.
Non-Concur. The heading can be confusing,
but is specified in the guidance. Its intent is
to recognize that there is a preference for
treatment in all cases. When treatment is
not implemented, (he ROD should recognize
that this is because a suitable treatment
option was not determined in the feasibility
evaluation.
Concur. It will be clarified that DDJC-
Tracy is responsible for maintaining (he cap.
89
OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PA
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comniclicn.sivc Record.Of Decision. DDKW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
a SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
a SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Dessctle. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
General Comments
Soil Cleanup
Levels
The ROD proposes an increase in soil cleanup levels for a number of constituents
of concern (CoCs) at DDRW Tracy based on laboratory practical quantitution
limits (PQLs). The ability for particular laboratories to achieve quantitalion is not
adequate justification for establishing cleanup levels. Soil cleanup levels should
be based on the concentrations necessary to protect background water quality (if
ground water has not been impacted) and beneficial uses of the underlying ground
water. In determining the concentrations necessary to protect water quality,
DDRW Tracy developed equilibrium partitioning limit concentrations using the
maximum concentration detected in soil at each site. The ROD proposes cleanup
levels based on PQLs which are considered generally achievable rather than the
concentrations which were developed using the equilibrium partitioning limit.
The equilibrium partitioning limits, as shown in (he tables presented in Section 8
of the Comprehensive RI/FS Report, are in some cases one or more orders of
magnitude lower than the PQL. This raises the concern (hat the PQL for certain
constituents may not be protective of water quality. However, the equilibrium
partitioning limits may be considered conservative estimates. DDRW Tracy states
(Comprehensive RI/FS Report, Appendix P - page I'-18) that the equilibrium
partitioning limit concentration for each contaminant is the maximum
concentration expected in soil water and docs not account for an expected decrease
in concentration resulting from migration through less contaminated or clean soils
to llie ground wilier. As a result, using PQLs which are higher than the equilibrium
partitioning limit concentrations may be acceptable depending on (he conditions at
the site.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Cleanup standards were
occasionally based directly on estimated
concentrations to protect background
groundwater quality. In many cases, the
concentrations derived from modeling and
equilibrium partitioning were well below the
concentrations that can be reproducibly
identified using existing technology. DDJC-
Tracy will provide additional rationale in
Section 9.0 of the draft final ROD on the
conservative nature of the model and
equilibrium partitioning estimates to support
the development of cleanup standards.
Hie use of "PQL" will be removed from the
text. The cleanup standards presented are
consistent with the lowest concentrations
that can be reproducibly identified using a
low level standard with best available
technology.
Analytical methods will be identified in
Appendix F. Detection limits vary from
laboratory to laboratory.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF 19
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Drafl Site-Wide Comprehensive Record Of Decision. IJDUW-Tracv
DSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
O SAFETY
D ADV TECH
a ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
10 October 1997
Kntcn Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
General Comments
Soil Cleanup
Levels (cont'd)
Narrative
Vadose Zone
Soil Cleanup
Standards
As we discussed during the 8 September 1997 Remedial Project Manager's
meeting, the ROD should justify on a site-specific basis how each soil cleanup
level is adequate (o protect water quality. At sites where using a PQL is justified,
DDRW Tracy should modify the soil cleanup levels based on PQLs specified by
EPA for the particular analytical method to be used, or if none is specified, the
PQL which can be obtained that is closest (o the equilibrium partitioning limit
developed by DDRW Tracy. In cases where vadosc zone and ground water
modeling was used to derive site-specific concentrations, the concentrations
derived from modeling should be specified as the cleanup levels. In addition, we
request that DDRW Tracy identify the analytical method, including the detection
limit, to be used in evaluating compliance with cleanup standards, as part of (he
selected remedy.
In cases where (he selected remedy includes soil vapor extraction, the ROD
indicates the selected remedy will continue until the cleanup standard has been
achieved. This language suggests that treatment will be ceased when the numerical
cleanup standard is met which docs not ensure (hat the narrative part of the
standard will be implemented. The remedies should be revised to specify the
vadose zone cleanup "standard," and how compliance with the standard will be
evaluated, using the entire text presented in Section 8.3.0.5 of the RI/FS Report.
In cases where the selected remedies include the potential implementation of soil
vapor extraction, or other treatment technology, lo address VOC contamination,
(he selected remedy should include the narrative slaiuhiid (see site-specific
comments).
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Accepted. DDJC-Tracy will modify the
existing language in Section 9.6.4.
OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE!
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Traey
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Dessclle. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
ARARs
Attached is a copy of a Title 27 and Chapter 15 cross reference table. We request
that all references to Chapter 15 be changed to the appropriate corresponding Title
27 sections.
Concur. References will be changed as
indicated (see Sections 7.0 and 10.0).
General Comments
Five-Year Site
Reviews
Selected
Remedies
Include l:ield
Investigations of
VOC Source
Areas
Five-year reviews of a number of the selected remedies are required by CERCLA
Section I2l(c) since hazardous substances remain in place. The ROD limits the
number of five-year reviews based on "costing purposes". This justification is not
adequate. Five year reviews are required so long as hazardous substances remain
on site and such reviews should be based on site-specific conditions, including the
estimated duration and success of a remedial action. The text limiting the number
of five-year reviews should be deleted (also see section-specific comments).
The ROD should clarify that contaminant fate and transport modeling was
conducted at sites identified as having Rl data gaps with respect to characterising
the lateral and vertical extent of vadose zone contamination. As a result, text
should be added to describe conditions that will "trigger" implementation of soil
vapor extraction, or other treatment technology, to address soil vapor
contamination as part of a presumptive remedy, (see site-specific comments).
Concur. Per paragraph 9.1.2, groundwater
monitoring will continue until cleanup
standards are met or until it can be
demonstrated that no further threat to water
quality remains.
Concur. The ROD will clarify in
Section 6.7.8 that fate and transport analysis
was conducted at sites with Rl data gaps.
Non-Concur. DDJC-Tracy does not wish to
include presumptive remedies in the ROD
(presumptive remedies were not included in
theRl/FS). The ROD will clarify that
prcdcsign soil gas sampling will be
performed and thai SVIi wells will be added
as needed lo attain ihc specified cleanup
simulant.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 3 OF 19
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D AOV TECH
D ESTIMATING
D SPECIFICATIONS
Q SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Dcsscllc. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Confirmation
Sampling
Continued
Groundwatcr
Monitoring
At sites where active remediation is selected as the remedy, final cleanup is
achieved when concentrations of CoCs present in soils remaining above (he water
table arc shown to be at or below cleanup levels, as set forth in (he ROD. llic
ROD should clarify that confirmation sampling will be conducted as part of these
selected remedial actions in accordance with an approved sampling and analysis
plan.
The ROD clarifies (lint groundwatcr monitoring will be conducted on a regular
basis at each site to evaluate any threat to water quality and to assess the
effectiveness of the remedial action conducted. The ROD includes a table
(Table 9-2) to show the monitoring wells and constituents to be sampled as part of
the selected remedies. The ROD should clarify that these monitoring wells and
constituents may be changed in the future based on decisions made as part of (he
Well Monitoring Program.
The text describing a number of the selected remedies docs not include all CoCs
identified in Table 9-2 or all of the CoCs for which cleanup levels arc established
for the particular site. This is misleading with respect to whether or not all CoCs
addressed by the selected remedy will be evaluated in ground water. The CoCs
discussed in the text of the selected remedies and Table 9-2 should be consistent
and the ROD should clarify that ground water sampling will be conducted for all
CoCs with cleanup levels.
The ROD stales that data hum ground water sampling conducted as parl of the
selected remedy will (Devaluated as pail nl'llic Well Monitoring Program. The
ROD further specifics silc-s|>ccilic cnnccnlralions in ground water which will
require evaluation. Bach selected remedy should describe the rationale for
concentrations which "trigger" an evaluation. In cases where ground water is not
impacted, concentrations detected above background ground water levels should
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W • WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The need for a sampling and
analysis plan will be clarified. This plan
will be addressed in a new subsection
(Section 9.10) in Section 9.0 that covers
RD/RA Work Plans, predesign sampling,
and design.
Concur. The decision logic from the well
monitoring program will be incorporated
into the Record of Decision (sec
Appendix E, Figure E-2). This logic defines
process that provides for future flexibility.
Concur. Table 9-2 will be revised as
indicated.
The concentrations that require an
evaluation generally correspond to
beneficial use levels at the present time. It
does not seem appropriate to require a
detailed evaluation following a single
detection of a contaminant above
background concentrations. Conditions
based on beneficial use limits that would
"digger" evaluation on the basis of
groundwatcr monitoring results are
identified in Section 9.0 of the ROD. These
conditions could result in (he
implementation olSVli, excavation.
OF CEHND FORM 7 (Revised)
PEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE
)9
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv .
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
Q OTHER
REVIEW
DATE
NAME
Draft
IQOi-lubcr 1997
Karen Dcsscltc. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Continued
Groundwater
Monitoring
(Cont'd)
be evaluated. In cases where an impact to ground water has occurred, all ground
water data for the CoCs which have impacted ground water should be evaluated.
New ground water monitoring wells are to be installed as part of some of the
selected remedies presented in the ROD. The ROD should show the proposed
locations of these wells relative to (he SWMU to be remediated on a site-map.
biovenling, or some other remedy. DDJC-
Tracy proposes that results above
background levels and trends be evaluated
in the Annual Well Monitoring Report. This
qualitative evaluation will indcntify what, if
any, additional action is required. If
beneficial use limits are exceeded, the
Annual Well Monitoring Report will include
an evaluation of whether the selected
remedy is still appropriate in addition to
identifying additional actions. The Annual
Well Monitoring Report will be identified as
a primary document (see Section 9.1) in the
ROD and may be commented on and
disputed by the agencies.
Concur. Figures E-2 and E-3 show the
locations of the new monitoring wells.
Specific Comments
Section 5.0
The text in this section docs not discuss all constituents evaluated at each site
during (he KI/KS process. At a minimum the site-specific tables in this section
entitled "Summary of Fate and Transport and Risk Data" should address all CoCs
for which cleanup levels me established. Hitch of these tables should include a
column which shows the "impacted medium" and s|nxifies the constituents found
lu adversely impact the medium, as included in Table 5-7.
Concur. This information has been added to
the tables in Section 5.0 entitled "Summary
of Fate and Transport and Risk Data" (sec
Tables 5-1 through 5-25, odd-numbered
tables, and Tables 5-26, 5-2K, and 5-33).
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
IN LIEU OF CEHND FORM 7 (Revised)
15AprB9
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 5 OF 19
r -couMEHts onuRon nootn»cv ooc
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft SUc-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
a ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
2.
3.
Seclion 5.5.2
Section 5.5.3
4.
5.
Section 5.5.4
Seclion 5.5.5
This section should acknowledge that volatile organic constituents have impacted
ground water at SWMU 6.
Text should specifiy that dioxins/Curans have impacted soil at SWMU 7.
Text should specify that dioxins/furans have impacted soil at SWMU 8.
This section should specify that PCC is a contaminant in groundwnter and soil at
SWMU 20/23. Napthalenc and bis (2-cthyl hexyl)phthalate should also be
identified as contaminants detected in soil which pose a threat to ground water at
this site.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIA17VEP ATTACHED
Concur. Section 5.5.2.1 notes that SWMU 6
is a likely former source of TCE and PCE to
groundwater. The first bullet under
"Conclusions" also makes this point.
Concur. Section 5.5.3.1 specifies that
dioxins/furans have contaminated the soil at
SWMU 7. Table 5-12 indicates that the
mass of the dioxins/furans THQ in the soil al
SWMU7is6.2xl06.
Concur. Section 5.5.4.1 specifics that
dioxins/furans have contaminated the soil at
SWMU 8.
Accepted. PCE was detected once in a
sample from LM85B at a concentration of
0.96 micrograms per liter. The presence of
PCE in the Middle Horizon has not been
confirmed in subsequent rounds of
sampling. Section 5.5.5.1 and the first
bullet under "Conclusions" addresses PCE.
tU OF CEHND FORM 7 (Revised)
09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAG
19
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
O INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Section 5.5.5
(Cont'cJ)
Section 5.6.3
The text should specify that bis (2-cthyl hcxyl)phlhnlute has impacted soil and
poses a threat to ground water at SWMU 33. Soil has also been impacted by
ODD, DDT, DDE, ethylbenzene, TCE and PCE.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Non-Concur. Naphthalene was not identified
as a COPC in Paragraph 6.3.16.5.0.1 of the
Rl/FS. BEHP was identified as a COPC;
however, Paragraph 6.3.16.7.0.7 of the
RI/PS concluded (hat it did not pose a threat
(o background groundwatcr quality at this
site.
Accepted. Section 5.6.3.1 discusses TCE,
PCE, ODD, DDT, and DDE. The first bullet
under "Conclusions" comments on SWMU
33 as a probable source of TCE and PCE to
groundwaler. The second bullet under
"Conclusions" addresses SWMU 33 as a
source of ODD, DDE, and DDT to
groundwatcr. The text notes that
ethylbenzene has been delected in soil, but
not in groundwater.
Non-Concur. bis(2-Elhylhexyl)phthalate
has been detected in soils at the site, but
was not determined to pose a potential threat
to background groundwater quality (sec
Paragraph 6.3.25.7.0.10 of the RI/FS).
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 7 OF 19
ITOMMfllll ll'M«fV,lifl'.CItf1»f.f IKi':
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE OEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Scclion 5.7.4
Section 6.2.2
Section 7.2.4
This section should include text to clarify (he rationale lor the no fiulhci action
decision at SWMU 10. Text should describe the basis for determining that it is nut
economically feasible to remediate this site. Table 5-33 shows that SVOCs
detected in soil pose a threat to ground water and beneficial uses but, Table 7-15
states that COPCs bis (2-clhyl hexyl)phthalale and metals do not pose a threat to
ground water. Results of the water quality site assessment show that antimony,
DDXs and dieldrin detected in soil pose a threat to ground water at this site. This
should be corrected.
Herbicides, petroleum hydrocarbon, and PCBs should be included in the list of
general COPCs for the facility.
The ROD should clarify that Slate Water Resources Control Board Resolution No.
88-63 applies to all surface water and ground waters of the State.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Paragraph 5.7.4.1 clarifies the
rationale for no further action at SWMU
IOA. Paragraph 5.7.4.2 describes the basis
for determining (hat it is not economically
feasible to remediate the site (using material
from Appendix T in the RI/FS). Table 5-33
shows that antimony poses a threat to
background groundwater quality. Table 7-15
indicates that COPCs have not been detected
in groundwater above background levels.
Concur. Paragraph 6.2.2 includes
herbicides, petroleum hydrocarbons, and
PCBs in the list of general COPCs for the
facility.
Concur. Paragraph 7.2.4.5 discusses (he
application of SWRCB Resolution No. 88-
63 to surface waters in California. Paragraph
7.2.4.6 discusses the application of SWRCB
Resolution No. 88-63 to groundwater in
California.
U OF CEHND FORM 7 (Revised)
9
•PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGEJ
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Conmiclicnsivc Record Of Decision. DDRW-Tracv
D SITE OEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen DcsseUc. RWQCD
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
10.
Section 9.3.5
The Icxt proposes increasing cleanup standards for a number of constituents;
however, only modified diluent treatment standards arc shown. The ROD should
clarify what is proposed lo be modified. Waste Discharge Requirements (WDR)
Order No. 96-022 contain effluent limitations for the discharge from DDRW
Tracy's ground water extraction and treatment system. As we have discussed
during past Remedial Project Manager's meetings, DDRW Tracy should substitute
analytical methods which can detect the CoCs at their WDR limits for methods
which are not able to detect at WDR required levels. Specifically, EPA Standard
Method SW 8010/8020 should be substituted for Method SW 8260 to detect 1,1
DCE, TCE, and PCE at the WDR effluent limitations for these constituents
specified in Order No. 96-022. DDRW Tracy should be using analytical methods
which demonstrate compliance with the effluent limitations.
Use of methods with reporting limits which are higher than the effluent limitations
is not adequate justification for modifying the WDR limitations. In the case of
monuron and diuron. Method H632 continues to be used lo evaluate compliance
with WDR limits. This method provides accurate identification and quantification;
however, DDRW Tracy has indicated (hut the reporting limits are higher than the
monthly median WDR limits. As is the case with cleanup levels, effluent
limitations are set forth to protect water quality and beneficial uses. The effluent
limitations for monuron and diuron were established based on background ground
water concentrations to protect ground water from being impacted by the
rcinjcclioii of lliesc CoC's. In continuing to evaluate compliance with existing
effluent limits specified in Order No. 96:()22, DDRW Tracy should use the
analytical method with the lowest method detection limits inul reporting limits and
report any delectable concentrations in the monthly icpurt.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIA17VEP ATTACHED
Accepted. DDJC-Tracy has identified a
laboratory that can attain (he effluent
limitations specified in the WDRs for
halogenated VOCs using SW 8260. We
propose going back to the original limits for
these compounds. No alternative method
with a lower reporting limit has been
identified for monuron and diuron. See the
table associated with Paragraph 9.5.5.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 9 OF 19
t 'f.'iMMm?1". hOMt'M* r I'4.1 HA',/f)'/.
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft SHc-Widc Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Ufiifl
IQOclobcr 1997
Karen Bcsscilc. RWOCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Site-Specific Comments
Group A Sites
(SWMU I/Area
2, Area I
Building 237, &
Area 3)
As we discussed in our I May 1997 ROD comment letter, ground water data
collected from monitoring wellsLM61A and LMI37A at Area I Building 237
suggests that this site is a source area for both PCE and TCE. TCE concentrations
range from 10 to 60 ppb and PCE concentrations range from 24 to 200 ppb in
groundwatcr. The nature and extent of both contaminants should be evaluated and
cleanup levels should be established in the ROD (to be included in Section 9.4.3).
Because this area is in close proximity to SWMU 33, SWMU 33 should be
investigated simultaneously, including an evaluation of the extent of contamination
from both constituents in addition to the SVOCs and pesticides specified in the
ROD.
The selected remedy discussion for the Group A sites does not clearly show that
additional soil-gas sampling at SWMU 33, SWMU 20/23, Area I Building 10,
Area I/Building 237, Area 3, and SWMU I/Area 2 will be conducted lo determine
the extent of VOC vadose zone contamination prior lo design of a remedial
system. We understand that this work is lo be accomplished as a predesign
investigation during the RD/RA phase. The ROD should clearly reflect that these
activities arc part of the selected remedy for these sites. The selected remedy for
Area I Building 237 (sec figure 9-3) limits soil gas investigations to the area
between manhole W-5 and SB-463. The selected remedy (Section 9.4.1 and
Section 9.4.3) should specify that pic-design soil gas investigations will identify
the lateral and vertical cxlcnl of contamination for the area identified during
previous investigations and Ihc ;IICH smioumliiig SWMU 33. In addition, Section
9.4.1 and Section 9.4.3 of the ROD should slate lhal a predesign investigation
will be conducted for all Group A sites lo determine VOC contaminants in soil up
to concentrations which arc at or above the soil cleanup standards identified for
each of these sites.
ACTION CODES:
A - ACCEPTED/CONCUR
D • ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The ROD will be modified lo
clarify that the predesign sampling effort
will include soil gas analysis (sec
Section 9.6.1). The predesign sampling
effort will only identify the extent of the
contamination above cleanup standards.
The ROD will clarify that both TCE and
PCE will be addressed in the soil gas
sampling effort. A cleanup standard will be
provided for TCE; however, the ROD will
note (hat TCE has not been delected in soil
samples from Area I building 237.
Sections 9.6.1 and 9.6.3 will be modified as
indicated to show that the nature and extent
of VOC contaminants at or above cleanup
standards will be determined. The portion
of the IWPL specifically identified in (he
text will be investigated and step-outs from
(he specified area will be performed if
necessary to identify the lateral and vertical
extent of contamination above (he cleanup
standards.
OF CEHND FORM 7 (Revised)
pEVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
O ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
a SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Dessetle. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
I.
Group A Sites
(SWMU I/Area
2, Area I
Building 237. &
Area 3) (Cont'd)
The remedy should stale that the decision to build/cxpand/operale an SVE system
will depend upon the magnitude of the threat to groundwaler quality posed by the
vadose zone contamination and an analysis of the technical and economic
feasibility for SVE technology at the site. The ROD should further specify that
each feasibility analysis shall be prepared by DDRW Tracy as a primary
document. Text should be added to stale that the decision shall be made by the
signatory parties to the FPA and shall be based, at a minimum, on the following
factors:
a. Whether the constituent is present in soil gas in concentrations equal to or
in excess of the soil gas cleanup standards identified for each of these sites;
b. the cost and lime associated with installing and continued operation of the
SVE system to remove the contamination in the vadose zone to achieve the
vadose zone cleanup standards;
c. the cost and lime associated with (he predicted additional groundwaler
remediation if no SVE is implemented; and
d. the incremental cost over lime of vadose zone remediation compared to the
incremental cost of groundwaler remediation, on the basis of a common
unit (e.g., cost to remove a pound of TCE), provided that the underlying
groundwalcr has not reached aquifer cleanup levels.
Section 9.4.2 ol'the ROD stales that vadose /.one modeling suggests that
.SWMU l/Aien 2, Area I Uuilding 237 iitul Area 3 niiiy he continuing sources of
VOCs lo groundwaler. This text should he modified to slate lhal gioundwiilcr data
indicalc that SWMU l/Area 2, Area I Building 237 and Area 3 are continuing
source areas of VOCs to groundwater and that vadose zone modeling was
conducted which appears (o confirm this rinding.
ACTION CODES: W - WITHDRAWN
A - ACCEPTED/CONCUR N - NON-CONCUR
D - ACTION DEFERRED VE - VE POTENTIAL/VEP ATTACHED
DDJC-Tracy intends to install the SVE
systems identified in this ROD to achieve
(he required numerical cleanup standards
(including additional wells as needed).
See response to General Comment 2
regarding the narrative cleanup standard.
Factor "a" has been modified and identified
as an item that must be demonstrated. The
other three factors have been added. It is
believed that factor "b" in the comment
should refer to aquifer cleanup standards
instead of vadose zone cleanup standards.
Concur. Paragraph 9.6.9 states lhal the
selected remedy includes continued
groundwater monitoring to evaluate the
performance of the selected remedy, as
described in Paragraph 9.1.2. LM061AU
and LM137A have been added to Table 9-2.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 11 OF 19
I '(/»MM( llf,
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Sile-Widc Comprehensive Record Of Decision. DDRW-Tracv
Q SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
n STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen Bessette. RWQCU
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Group A Sites
(SWMU I/Area
2, Area I
Building 237, &
Area 3) (conl'd)
2.
SWMU 4
Section 9.4.5 states, in part, that DDRW Tracy will operate the SVE system until
the cleanup standard has been achieved. Ilie following should be added to this
sentence Aand until it is demonstrated that the following two items have been met:
I. the remaining vadose /.one VOC contaminants no longer cause
concentrations in the Icachate to exceed aquifer cleanup levels (the
numerical standards are met); and
2. VOCs have been removed to (he extent technically and economically
feasible.
The feasibility analysis will include but not be limited to consideration of factors a.
through d. specified above.
The ROD should show ifuil the selected remedy includes continued ground water
sampling to evaluate the performance of the selected remedy, as described in
Section 9.1.2. Monitoring of VOCs at wells LM061A and LMI37A at Area I
Building 237 should be included in Table 9-2.
The selected remedy addresses contaminants in sediments which were found to
pose a threat to background ground water quality based on vadose zone modeling
results. Figure B-10 of the ROD shows the subsurface soil data collected at this
site. The selected remedy should summarize (his subsurface soil dala and describe
the potential impacts to water quality and how they were evaluated. Section
9.5. I.I of the ROD should further identify the contaminants which have impacted
ground water at this site. Text should clarify (hat evaluation of the remedial
alternatives included an assessment ol data collected to characterize the vertical
extent of soil contaminants beneath the sediments in the lagoon.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W • WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The text clarifies that the vertical
extent of contamination was investigated.
The remedy for SWMU 4 will be revised
per the discussion in the 8 September
meeting. DI-WET results from the October
1996 sampling event will be included in
Appendix C along with the cross-sections
presented in the September 1997 RPM
meeting. Per comment 18 from Kara
|B9
OF CEHND FORM 7 (Revised)
^PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE OEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
IQOclobcr 1997
Karen Bcsscllc. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
2.
SWMU4
(cont'd)
Section 9.5.1.4 states that excavation will be performed to a depth of 9 inches in
(he northern portion of the lagoon, because concentrations of OC pesticides arc
higher in that area. However, the text also states that dicldrin is present at a depth
of 18 inches at concentrations above the cleanup standard necessary to protect
ground water in at least one location in the northern lagoon area (SB 107). Ground
water has been impacted by dicldrin at this site. The remedy should be modified to
excavate this area to meet cleanup levels. 11 ic ROD should also clarify that the
selected remedy includes collecting confirmation samples (see general comment).
The text in Section 9.5.1.7 indicates thai the selected remedy is protective of
human health and the environment because the remedy reduces the toxicity and
volume of CoCs found in sediment and surface water. Hie text should clarify that
the remedy removes the threat posed to ground water and surface water by the
CoCs found in soil at (he site.
Because this site is intended for continued use as a storm water holding pond, the
remedy should clarify that regular removal of sediments accumulated during future
use of the pond will be conducted as part of DDRW Tracy's storm water
management program.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Christcnsen of U.S. EPA, AWQC will be
classified as TBCs instead of ARARs.
Therefore, no threat to surface water has
been identified. Periodic removal of
sediments from (he lagoon will be
considered as a maintenance activity under
the storm water pollution prevention
program rather than a part of the selected
remedy. Paragraph 9.7.1.15 notes that future
sediment issues will be addressed through
the storm water pollution prevention
program (sediment removal or source
control will be practiced as appropriate).
Paragraph 9.7.1.16 clarifies that the remedy
removes the threat posed to groundwater
and surface water at the site because it
removes the contaminated sediment from the
storm drain lagoon.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 13 OF 19
1 'COMMENTS DO
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Diaft Site-Wide Comprehensive Record Of Decision. DDRW-Trncv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
O STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
O INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
lOOclubcr 1997
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
SWMU7
SWMU8
The (cxl in Section 9.5.3.4 indicates Ihut "any extension" of the remedy will be
determined based on the initial live ycur review. This terminology implies thai the
remedy will cease unless il is deemed necessary to continue beyond five years
which in effect establishes a five year remedy. This is not acceptable. Institutional
controls is not a "no action" alternative. Ground water monitoring must be
conducted as part of the selected remedy. There is no fixed period associated with
the remedy and there is no fixed period associated with conducting ground water
monitoring as part of the remedy. The period of five years and the text referring to
"any extension" should be deleted. The ROD should state that the selected remedy
will include re-evaluating the remedial alternatives to consider active remedial
action if and when ground water monitoring indicates an impact from CoCs
present in soil at the site (specific "trigger" language should be presented). The
ROD should show the location of the new monitoring wells relative to the
locations of LM095A and LM043A which were previously used to monitor for
CoCs at this site. The words "at least" should be added to the beginning of the
first sentence in Section 9.5.3.8.
Section 9.5.4.5 states, in part, that excavation and disposal will permanently
remove all contaminants in soil and debris at SWMU 8, thereby permanently
preventing migration of any soil constituents to ground water, but Section 9.5.4.6
states that potential further action at SWMU 8 will depend upon the magnitude of
any VOCs reported. This inconsistency should be corrected. The term "all" when
referring to contaminants in soil should be replaced by "majority" and the term
"preventing" replaced with "reducing". The "potential" action to address VOCs
should be described (e.g., further excavation or soil vapor extraction to remove
VOC contaminants above (he VOC cleanup standards). The decision to lake such
action may be based on the technical and economical feasibility to remediate the
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Paragraph 9.7.3.4, third bullet,
indicates that monitoring will be required
for as long as contaminants are left in place
with concentrations that could threaten
groundwater quality or until it can be
demonstrated that no further threat to
groundwater quality exists.
Concur. Paragraph 9.7.3.6 indicates that
two new wells will be installed as part of the
selected remedy. The locations of the new
monitoring wells are shown in Figure E-30.
The words "at least" have been added to (he
beginning of the first sentence in Paragraph
9.7.3.8.
Accepted. Section 9.7.4.5 has been
clarified. The excavation will remove all
known contamination above cleanup
standards. Further monitoring for VOCs is
warranted to identify additional
contamination. 'Hie term "all" has been
clarified in (his manner. The remedy is
intended to prevent, not reduce, impacts to
groundwater. Ilie text indicates that the
remedy will prevent known impacts.
)9
OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE
t 'COMMFMCi nOHR'HI IKi
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Silc-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Karen iJcsscllc. RWQCD
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
SWMU8
(Cont'd)
SWMU 20/23,
Aboveground
Solvent
Tank/Building
26, Area I
Building 10
contaminated soil. Section 9.5.4.5 should include (cxl to clarify that (he limits of
the disposal urea arc well-defined, and soils will be removed to the depth of (he
water table during remediation. Table 9-2 should show that the proposed MW8-
IAU will be monitored for all CoCs for which cleanup levels have been
established.
The ROD should specify that the selected remedy for these sites includes
conducting pre-design soil-gas sampling and cvjlualion of the results. The text
should specify that soil gas investigations will be conducted (o the extent necessary
(o determine the lateral and vertical extent of VOC contamination in the vadose
zone (o determine where concentrations arc at 01 above (he soil gas cleanup
standards identified in the ROD for these sites. 1'ext should be added to specify the
conditions for expanding the areas of soil vapor extraction as part of the selected
remedy. Although, the selected remedy include;. SVE as a component of the
remedial action at all of these sites, the text in Section 9.5.5.1 and Table 9-1
should stale that DDRW Tracy will provide a complete charnctci i/ation of (he
vadose zone contamination (including SWMU 33) as part of predesign
investigation prior to remedial action.
The selected remedy indicates thai soil will be excavated at soil boring locations
SB 431 and SB 108, the floor drain (SWMU 23), and at manholes W-l and W-3 to
remediate VOCs, SVOCs and pesticides. In addition, the selected remedy includes
conceptual locations for (wo SVC wells near manhole W-l and W-3. Because the
selected remedy is limited to only two areas with known contamination, it docs not
addicss our com cms Ilia) llic.se .situs WCH- nol coiii|ilclrly cli;n,-iclai/ccl diniiij: llic
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Section 9.7.4.5 has been modified
to indicate that (he limits of the disposal area
are well defined. Table 9-2 shows proposed
monitoring well LMI68A for SWMU 8.
Concur. Predesign soil gas sampling and
evaluation are specified in Paragraphs
9.7.5.7, 9.7.5.8, and 9.7.5.9. The associated
evaluation will be part of the design analysis
report. The investigation will identify the
areas associated with SWMU 20 thai are
above the specified numerical cleanup
standard. All of SWMU 20 will be
addressed in the investigation. The IWPL
will be addressed between manholes W-1
and W-2. Step-outs from lliesc areas will be
performed as needed until (he extent of (he
area above the numerical cleanup standard
has been identified. SB 430 and 432/432b
will be added to the area to be evaluated. A
more general investigation of the IWPL is
not included in (he remedy.
Noii-C!(iMc.iir. DDK.1-Tracy does nol w;inl In
identify additional investigation as a primary
part of a selected remedy in Table 9-1. The
selected remedy is appropriate.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 69
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 15 OF 19
T •OOMMEIlTSDOMnOfj DOOtnAr.Y t
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft She-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
IQOclohcr 1997
Karen Bcsselie. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
5.
SWMU 20/23,
Abovcground
Solvent
Tank/Building
26, Area I
building 10
(Cont'd)
Rl phase. The conceptual design (figure 9-8) should include soil gas investigation
or SVE locations to complete (he characterization at SWMU 23. The conceptual
full-scale SVE system should include additional SVE wells near SB 431 and the
floor drain (SWMU 23, Figure 9-8).
Section 9.5.5.6 (table) should be modified and include all VOCs detected above
aquifer cleanup levels in down gradient compliance monitoring wells. Section
9.5.5.7 should specify (he conditions for expanding the SVE treatment system (i.e.,
concentrations detected above soil-gus cleanup levels und (he factors listed for (he
Group A sites in comment # above). Text should also be added to specify that
areas of SWMU 33 (IWPL) at SB430 and SB432/432b will be assessed and
remediated as part of the SVE remedy. Section 9.5.5.9 which addresses areas of
the IWPL should slate that the SVE remedy will be expanded to remediate TCE
detected above the cleanup level. Section 9.5.5.10 which describes the vadose
zone cleanup standard as part of the remedy should be modified to add (he items,
as specified above in comment # for me Group A sites. Section 9.5.5.13 should
justify why natural attenuation of phenols detected in soil at SB432/432b is
considered to be adequate.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL7VEP ATTACHED
Concur. The draft final ROD will indicate
that an approved sampling and analysis plan
will be required (Section 9.10). The draft
final ROD will clarify that the condition for
expanding the SVE system is the numerical
cleanup standard (Section 9.7.5.7). The
SVE well locations will be modified on the
basis of the comments received. One SVE
well near SB 431 will address the Moor drain
(no evidence of contamination at the drain).
TCE will be added to the table associated
with Paragraph 9.7.5.4.
See response to General Comment 2 for
discussion of narrative cleanup standards.
Concur. Paragraph 9.7.5.13 of the draft final
ROD provides a more detailed analysis of
the impact of phenols on water quality.
IN ' iEU OF CEHND FORM 7 (Revised)
19
gREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
OS/STEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
10 October 1997
Kaicn Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
7.
SWMU 24
The selected remedy for SWMU 24 is biovcnling. Section 9.5.6.5 sliilcs that PCUs
and pesticides would nut be fully remediated during bioventing. It is unclear
whether or not the selected remedy will meet the cleanup levels for PCBs and
pesticides. The text justifies incomplete remediation based on a "low relative"
threat posed by these constituents. This is nol adequate justification lor leaving
concentrations in place above cleanup levels. The ROD should present a technical
and economic analysis to justify any cleanup levels greater than concentrations
necessary to protect background water quality.
Ground water data suggest that SWMU 24 may be u VOC source area.
Additionally, the ROD clarifies how vadose zone modeling has predicted that
VOCs present in soils pose a threat to background water quality. Section 9.5.6.1
should specify that the selected remedy includes conducting prc-dcsign soil-gas
sampling and evaluation of the results. Text in Section 9.5.6.6 should specify the
conditions (i.e., concentrations detected above: soil-gas cleanup levels and the
factors shown above), including a technical and economic feasibility analysis, for
implementing soil vapor extraction, or other trentmcnt technology to address soil
vapor contamination as part of the selected remedy. Table 9-1 should be modified
to reflect that this site will be characterized as part of a prcdcsign investigation.
The groundwater sampling program should require continued evaluation of PCE
and TCE (section 9.5.6.7). Monitoring well I.Ml ISA is listed in Table 9-2;
however, the text should specify that this well will be monitored for all CoCs for
which cleanup levels are established. Tl'l I (> and Tl'l 1-1.) should be added to (lie
CoCs to be monitored at all the monitoring wells for this site.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Additional discussion on PCBs and
pesticides is provided in the draft final
ROD. See Paragraphs 9.7.6.2 and 9.7.6.5.
Concur. Paragraph 9.7.6.6 will be modified
to clarify the predesign soil gas sampling
requirements. The concentrations in soil gas
that would trigger SVE arc specified in the
table associated with Paragraph 9.7.6.6.
SVE wells will be added as needed to
achieve these standards. We do not think a
T&E analysis should be required before
implementing SVE.
Non-Concur. DDJC-Tracy docs not want to
identify additional investigation as a primary
part of a selected remedy in Table 9-1. The
selected remedy is appropriate.
The draft final ROD indicates that an
approved sampling and analysis plan
(Section 9.10) will be a primary document
to ensure that KWQCH concerns about
characleri/alion arc addressed.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 17 OF 19
T r.(jMMrril';i>'jl4nr.4>ri'iMM«'.v|//.
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U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Draft Site-Wide Comprehensive Record Of Decision. DDRW-Tracv .
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Draft
IQOelober 1997
Karen Bessette. RWQCD
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
SWMU24
(Cont'd)
SWMU 27
Section 9.5.6.9 stales that the biodcgradation of VOCs and SVOCs will mitigate
the threat to groundwatcr. DDRW Tracy has not performed information
suggesting degradation of VOCs or SVOCs is occurring at this facility.
Therefore, the statement that VOCs and SVOCs biodcgradc in groundwaler should
be removed from (he Report.
Section 10.10 incorrectly states that "Pre-dcsign soil-gas sampling will be
conducted to determine whether biovcnling or SVE is more effective." The ROD
should be modified to accurately state that SV13 may be implemented bcfoic
biovcnting to meet VOC cleanup levels depending on evaluation of the results of
the pre-design soil-gas sampling, including any technical and economic fcasiblity
analysis.
The ROD should clarify thai llic selected icmcdy includes completing the
characterization of soil contamination as part ol the excavation activities. Ground
water monitoring should be conducted for all CoCs for which cleanup levels are
established.
ACTION CODES:
A • ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/YEP ATTACHED
Concur. As evident in (he table associated
with Paragraph 9.7.6.7, TClf and PCE have
been added to the Well Monitoring
Program. LMII8A will be monitored for all
cleanup standards as indicated, including
TPHG and TPHD.
Concur. Paragraph 9.7.6.6 will be modified
as indicated. SVI! may he performed in .
addition to biovcnling.
Non-Concur. Dioventing stimulates the
biodegradation of petroleum hydrocarbons
and kctones in the vadosc /.one. Paragraph
9.7.6.9 indicates that biodcgradalinn (by
hicivcnlin^) will lic:il omlaminanls belou1
lliey reach (not m) <:i (Hindu alct.
Accepted. Paragraph 9.7.7.5 Males (hat
confirmation sampling will be conducted to
ensure that the cleanup standards arc
attained.
Concur. Groundwaler monitoring will be
conducted for all COCs exceeding the levels
specified in (he table associated with
Paragraph 9.7.7.6.
IEU OF CEHND FORM 7 (Revised)
09
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE I
.10
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Uialt Site-Wide Comprehensive Record Ol Decision. DDR W-Tracy
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
10 October 1997
Karen DcsscUe. RWQCD
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
9.
Drum Storage
Area IJ30
.Section 9.5.K.2 should clarify that grouiulwatcr data was not available as a basis
for (lie selected remedy. This .section states (hut cleanup standards arc based on
modeling of potential threats to background water quality and that the cleanup
levels were developed to protect background water quality. However, the cleanup
levels do not represent the concentrations which were determined as necessary to
protect water quality (see general comment #1). The text in Section 9.5.8.2
suggests that the institutional controls remedy may be ceased based on (lie 5-year
site review. The ROD should clarify that the 5-year review is to assess the
effectiveness of (he remedy to determine whether or not active remediation is
necessary. As discussed in comments above, we believe the remedy may not be
"discontinued" and ground water monitoring is required to continue until the
wastes remaining in place ate deemed to no longer pose a threat to water quality.
Tlic ROD should slate that the selected remedy will include re-evaluating the
remedial alternatives to consider active remedial action if and when ground water
monitoring (also included as purl of the selected remedy) indicates an impact from
CoCs present in soil at the site (see general comment #7). Section 9.5.8.4 slates
(hat ground water sampling for VOCs, SVOCs ijul pesticides/herbicides will be
performed and Table 9-2 is referenced; however. Table 9-2 includes only SVOCs.
Table 9-2 should IK; corrected.
ACTION CODES:
A • ACCEPTED/CONCUR
D • ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. Paragraph 9.7.8.2 has been
modified to show that groundwatcr data
were not available to use for selecting the
remedy.
Concur. The ROD will be modified to
indicate that five-year reviews and
groundwater monitoring will be required as
long as wastes arc in place (hat exceed the
concentrations indicated in the table
associated with Paragraph 9.7.8.4 or if
increasing concentration (rends arc
observed, as discussed in Paragraph 9.1.
Paragraph 9.7.8.4 requires (he evaluation of
C'OCs as pail of (lie Well Monitoring
Program.
Concur. Table 9-2 has been corrected as
indicated.
IN LIEU OF CEHND FORM 7 (Revised)
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 19 OF 19
I <.',MMr I IK ti't\*tl'itt I",|,FM*'.' fi*/.
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Final Site-Wide Comprehensive Record of Decision. DDJC-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFC TECHNOLOGY
D ELECTRICAL
O INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHIER
REVIEW
DATE
NAME
Final Silc-Wide Tracy ROD
23 March I 998
Karen Bessette. RWOCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
We have reviewed the Final Silc-Widc Comprehensive Record of Decision (ROD)
for DDJC Tracy, submitted 18 February 1998. As you are aware, the Remedial
Project Managers agreed to extend the date to finalize the ROD for 30 days from
29 January 1998, to 2 March 1998 to allow additional time to review and address
regulatory agency comments submitted in late January. We appreciate the Defense
Logistics Agency's responsiveness in addressing our comments on the Draft Final
ROD. The followup discussions during the RPM meeting on 5 March 1998 have
served to resolve our remaining concerns provided that the ROD text is changed in
accordance with the comments listed below. In addition, attached are revised
ARARs Tables 10-2 and 10-3 (Attachments 1 and 2) which show changes
necessary to resolve EPA's comments regarding Regional Board ARARs.
No response required.
General Comments
Water Quality
Objectives
The ROD states that DDJC Tracy will evaluate the appropriateness of the selected
remedy in cases where site-specific water quality objectives arc exceeded. The
water quality objectives identified in each selected remedy include background
levels, concentrations which represent non-detccl background levels, or numerical
limits necessary to protect the beneficial uses of ground water at DDJC Tracy. As
discussed during the 5 March 1998 RPM meeting, we request that each selected
remedy identify these concentrations and the source of the water quality objective
selected for the constituents requiring ground waier evaluation at each particular
site.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N • NON-CONCUR
VE - VE POTENTIAL7VEP ATTACHED
Concur. The evaluation of groundwater
monitoring analytical requirements will be
provided in Table 9-7. Estimated detection
limits will be identified in the table.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF 5
T:\rRACV\DOUROOVFINAUU:OMMCNTStf
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U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Final Sllc-WiJc Comprehensive Record of Decision. DDJC-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
O STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Final Silc-Wide Tracy ROD
23 March 1 998
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
(Continued)
Disposal of
Excavated Soil
In addition, us agreed during the 19 March 1998 conference call, the method of
analysis will be identified for each of the constituents requiring ground water
evaluation. Also, in cases where the objective is a background concentration equal
to non-dctect or less than the US EPA specified method detection limit (MDL), or
where the objective is the beneficial use limit which is less than the MDL, the
selected remedy will identify the USEPA MDL or an "estimated" detection limit,
and a quantitation limit. These concentrations will include a footnote which states
that ground water monitoring results will include reporting of all concentrations
detected above the MDL or the estimated detection limit and below the laboratory
quantilation limit as trace. The footnote will also state that in cases where the
limits achieved differ significantly due to a change in matrix or other effects, the
results will be flagged accordingly, including an explanation and the estimates of
the limits actually achieved.
As requested in general comment #6 of our Draft Final ROD comments, to provide
flexibility, each remedy to excavate and dispose of contaminated soils should
replace text regarding prc-dctcrmined disposal methods with the following general
statement: "The excavated soil will be transported and disposed of at a Class I or
other disposal facility in compliance with stale and federal laws and regulations."
This text was not used in all remedies which include excavation and off-site
disposal. We again request that this text replace the text which indicates pre-
determined disposal methods as part of (he selected remedies, particularly in the
cascofSWMUS.
ACTION CODES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Accepted. The text for SWMU 8 in
Section 9.0 will be modified. A method of
disposal must be assumed for costing
purposes. This can be revised in the
remedial design.
IN LI
15 A|
F CEHND FORM 7 (Revised)
PREVIOUS EDITH >F THIS FORM ARE OBSOLETE
PAGE:
T:\TRAC VU)O14ROO\flN«L2\COMMENTS\nwoCB
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Final Site-Wide Comprehensive Record of Decision. DDJC-Tracv
OSITEDEV&GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Final Silc-Wide Tracy ROD
23 March 1 998
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
3.
ARARs for
SWMU4
The storm water detention pond discharges to surface waters of the state,
specifically, the West Side Irrigation District Canal that discharges to Sugar Cut at
the Old River which flows into the San Joaquin River. The ROD should include
the narrative toxicity water quality water quality objective for inland surface
waters, as set forth in the Basin Plan for the Central Valley Region, Sacramento,
and San Joaquin River Basins (Basin Plan), as an ARAR for SWMU 4. The ROD
should specify that the National Ambient Water Quality Criteria to protect
freshwater aquatic life, published by USEPA under the Clean Water Act, are the
TBCs that implement this stale ARAR.
Concur. National Ambient Water Quality
Criteria will be applied to storm water
discharge as indicated.
Specific Comments
I.
2.
3.
Section 7.2.6.3
Section 7.2.6.5
Section 7.3.1.12
Add the following to the beginning of the first sentence "Title 23, Division 3,
Chapter 15 of the CCR and".
This section should specify that the NPDES requirements implemented by State
Water Resources Control Board Order No. 92-0!} DWQ, specifically, general
permit 5B39SO13143, are applicable to DDJC-Tracy to ensure that storm water
discharges do not contribute to a violation of surface water quality standards. This
section should also specify that the water quality objectives for inland surface
waters set forth in the Basin Plan arc applicable Ho DDJC-Tracy discharges to
surface water.
Replace the sixth sentence with the following sentences: "These background levels
were based upon detection limits derived from use of a modified method as part of
an initial background study. These detection limits were not reproducible. The
numerical beneficial use limit (Cal/EPA and USEPA Cancer Potency Factor) for
dieldrin is 0.002 ug/1."
ACTION COOES:
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/YEP ATTACHED
Concur. The text will be added as indicated.
Concur. The text will be added as indicated.
Concur. The text will be added as indicated.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 3 OF 5
T:\TRACY\OO 14R(XVMAL2\COMMENTS\flWOC8MAfl DOC
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Final Site-Wide Comprehensive Record of Decision. DDJC-Tracv
O SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
a STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
D SAFETY
D ADV TECH
D ESTIMATING
D SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Final Silc-Widc Tracy ROD
23 March I 998
Karen Bessette, RWOCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
Section 9.5.1
Section 9.5.4
Section 9.5.5
Section 9.7.1.12
This section briefly describes (he OU 1 treatment system, including only
rcinjcction as the discharge method. Add the following sentences after the first
sentence in this section: "The primary disposal method is to discharge extracted
and treated ground water to shallow aquifers utilizing injection wells and
infiltration galleries located on the main base property. DDJC-Tracy will construct
additional subsurface disposal facilities in these areas or on the northern Annex
properly, as necessary, to optimize the capacity of the ground water recharge
disposal method. As a backup disposal method after optimization of all available
subsurface disposal systems, treated ground water may be discharged to the on-sitc
wastewaler evaporation/percolation ponds in cases of emergency. An
"emergency" is defined as conditions such as failure of piping or capacity
problems such that discharge to ground water is not possible, as jointly determined
by DDJC-Tracy and the regulatory agencies."
Add the following text to the end of the third sentence "or background levels."
Add the following sentence after the third sentence in this section "Attainment of
background levels is not technically or economically feasible."
The ROD should specify that the selected remedy will ensure that discharges from
SWMU 4 to the local irrigation canal must meet the federal ambient water quality
criteria for the protection of freshwater aquatic life set forth in Section 304 of the
Clean Water Acl. Text should be added to clarify that the preliminary cleanup
standards for sediment and the extent of excavation will be evaluated and revised as
jointly determined by DDJC-Tracy and the agencies based on additional data
collected during the RD/RA phase to evaluate the affects of the sediment on surface
water. The ROD should further clarify that the selected remedy includes construction
of a sediment trap at the inlet and an overflow weir at the outlet to manage sediment
such that the remedy will ensure that sediment remaining does not cause any
discharge to exceed the federal freshwater ambient water quality criteria.
ACTION CODES:
A-ACCEPTED/CONCUR
D • ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIALWEP ATTACHED
Concur. The text will be added as indicated.
Concur. The text will be added as indicated.
Concur. The text will be added as indicated.
Concur. New paragraphs will be inserted
into Section 9.7.1 to address this issue.
Potential impacts to surface water quality
will be considered in determining the final
cleanup standard for sediment.
Accepted. DDJC-Tracy proposes to provide
a sediment trap on the northern inlet and an
overflow weir, but recommends sampling to
determine whether a sediment trap is needed
on the southern inlet. The southern inlet
INLI1
15 A|
IF CEHND FORM 7 (Revised)
PREVIOUS EDITK
F THIS FORM ARE OBSOLETE
PAGEM
T ATRACr\DO 14RO0lFNAL2\COMMENTSttWOCt
-------
U.S. ARMY ENGINEER AND SUPPORT CENTER, HUNTSVILLE CORPS OF ENGINEERS
DESIGN REVIEW COMMENTS PROJECT Final Site-Wide Comprehensive Record of Decision. DDJC-Tracv
D SITE DEV & GEO
D ENVIR PROT&UTIL
D ARCHITECTURAL
D STRUCTURAL
O MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST&CONTROLS
a SAFETY
D ADV TECH
O ESTIMATING
O SPECIFICATIONS
D SYSTEMS ENG
D VALUE ENG
D OTHER
REVIEW
DATE
NAME
Final Silc-Widc Tracy ROD
23 March 1 998
Karen Bessette. RWQCB
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
7.
(continued)
Section 9.7.3.6
Section 9.8.1.5
10.
Appendix C,
Technical
Memorandum -
Ambient Water
Quality Criteria
Table 9-2 was modified to include monitoring well LM095 as requested in general
comment #3 of our Draft Final ROD comments; however, the text in Section
9.7.3.6 was not modified. Section 9.7.3.6 should be modified to specify that
monitoring of well LM095A will continue as part of the selected remedy to
evaluate ground water in the down gradient vicinity of the north area pits at
SWMU7.
This section should describe the 1997 excavation activities conducted and any
remaining actions necessary to complete the remedy at the former Sewage and
Industrial Lagoon sites. Specifically, the text should include the following
sentences "The initial excavation activities attempted to provide clean closure.
The cleanup standards were modified to protect water quality and are expected to
achieve clean closure. Clean closure is expected to be verified through ground
water monitoring."
This memorandum should clarify that the storm water detention pond discharges to
surface waters of the state. The text should specify that the narrative toxicity water
quality objective for inland surface waters, as set forth in the Basin Plan, is an
ARAR for SWMU 4. The text should further specify that the National Ambient
Water Quality Criteria to protect freshwater aquatic life, published by USEPA
under the Clean Water Act, are the TBCs that implement this state ARAR. In
addition, the text should specify that the NPDE3 requirements implemented by
State Water Resources Control Board Order No. 92-08 DWQ, specifically, general
permit 5B39S013143, are applicable toDDJC-Tracy to ensure that storm water
discharges do not contribute to a violation of surface water quality standards.
ACTION CODES: W - WITHDRAWN
A -ACCEPTED/CONCUR N - NON-CONCUR
D - ACTION DEFERRED VE - VE POTENTIAL/VEP ATTACHED
drains a paved area (pesticides aren't
expected in runoff) and already has a long,
wide concrete channel where significant
settling occurs.
Concur. The text will clarify that LM095AU
will be retained.
Concur. The requested text will be added.
Concur. Appendix C will be revised to
indicate that AWQC apply. Because of its
importance, the detailed identification of
ARARs in this comment should be inserted
into Sections 7.2.6.5 and 10.5.2 of the ROD.
rather than into an attached memorandum
evaluating data collected during the
remedial investigation.
IN LIEU OF CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 5 OF 5
T:\THACrroi4ROWTNALrcOMHEmSWVVOC8UAfl.DOC
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u. s. ARMY ENGINEERING & SUPPORT CENTER. HUNTSVILLE
DESIGN REVIEW COMMENTS PROJECT PDJC-Tracy Record of Decision
CORPS OF ENGINEERS
D SITE DEV & GEO
D ENVIR PROT& UTIL
D ARCHITECTURAL
D STRUCTURAL
D MECHANICAL
D MFG TECHNOLOGY
D ELECTRICAL
D INST & CONTROLS
D SAFETY D SYSTEMS ENG
D ADV TECH D VALUE ENG
D ESTIMATING D OTHER
D SPECIFICATIONS
REVIEW
DATE 26 March 1998
NAME Michael Work. U.S. LPA
ITEM
DRAWING NO.
OR REFERENCE
COMMENT
ACTION
2.
3.
4.
General
General
Section 9.7. L.I 5
Sections 9.7.1.12
and 9.7.1.14
There are numerous instances in which the text erroneously refers to soils in reference to
SWMU 4 sediments.
The word "affects" is erroneously used to mean "effects."
Delete the last sentence of 9.7.1.15 regarding the source of the pesticides.
Changes to Sections 9.7.1.12 and 9.7.1.14 Follow (using strike-out and italics)
9.7.1.12 Cleanup standards for total DDX, lead, and selenium are risk-based
concentrations (see Section 6.6.5). These standards are considered preliminary because
(hey were estimated using literature values rather than site-specific bioaccumulation
factors, and to evaluate the affects of the sediment on surface water. The preliminary
These cleanup standards and the extent of excavation will be evaluated and revised as
jointly determined by DDJC-Tracy and the agencies. The final Any modification of the
cleanup standards will likely be adopted be made through an explanation of significant
differences to this ROD.
9.7.1.14 The storm water pond will only receive storm water. With significant dilution
from runoff. It is uncertain if the storm water discharge will exceed the AWQC, however,
the concentrations will be confirmed by sampling (under the storm water pollution
prevention program) at least two discharge events per year (the first event of the year and
one other) for the next five years and evaluated in the first five-year review. The potential
carryover of sediment from the pond will also be evaluated. If dissolved contaminants
(filtered and unfiltered water samples) exceeding the discharge standard or contaminated
sediment arc found in the discharge, DDJC-Tracy will evaluate and identify an
appropriate modification of the selected remedy (e.g., additional excavation, sediment
traps, etc.) to achieve the discharge requirements. In that event, the facility will evaluate
the potential impacts of sediment on ambient water quality. The AWQC will also be
included in the evaluation of sediment cleanup standards in the anticipated explanation of
significant differences.
ACTION CODES
A - ACCEPTED/CONCUR
D - ACTION DEFERRED
W - WITHDRAWN
N - NON-CONCUR
VE - VE POTENTIAL/VEP ATTACHED
Concur. The text has been revised as indicated.
Concur. The text has been revised as indicated.
Concur. The text has been revised as indicated.
Concur. The text has been revised as indicated.
CEHND FORM 7 (Revised)
15 Apr 89
PREVIOUS EDITIONS OF THIS FORM ARE OBSOLETE
PAGE 1 OF
1
I tRAOM..ll Id. ill i IN*| »i iItUli I.I
-------
SFUND RECORDS CTR
3096-00231
Defense Distribution Depot San Joaquin (DDJC),
racy Site, Tracy, California
Site-Wide Comprehensiv
Record of Decision
Volume 2 of 2 - Appendices
FINAL
April 1998
US. Army Corps
'Engineers
Jgineering and - ..
upport Center, HimtsvDle •*
•• ='.•-••• "™.:is S'f
-------
RCN: 602214.02
FINAL
DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN (DDJC), TRACY SITE
TRACY, CALIFORNIA
SITE-WIDE COMPREHENSIVE RECORD OF DECISION
VOLUME 2 OF 2
(APPENDICES)
Prepared for:
U.S. Army Corps of Engineers
Engineering and Support Center
Huntsville (CEHNC)
4820 University Square
Huntsville, Alabama 35816-1822
Attn: CEHNC-PM-ED
Prepared by:
Radian International
10389 Old Placerville Road
Sacramento, California 95827
April 1998
-------
APPENDIX A
ADMINISTRATIVE RECORD FILE INDEX
-------
Administrative Record File Index - DDJC Tracy
Date
67/07/01
80/07/2 1
80/10/01
82/06/01
H2/ 10/12
83/08/05
84/05/07
84/05/30
84/06/01
84/06/15
84/06/26
84/07/05
84/07/05
84/07/17
84/07/26
84/08/07
84/09/05
84/10/05
84/10/10
84/1 1/02
84/11/13
84/11/21
85/01/10
85/02/01
85/07/12
85/08/01
85/08/02
85/08/15
85/08/28
85/09/13
85/11/13
Author
DWR
USEHA
USATHAMA
Jefferson Assoc., Inc.
DDTC-J
DDTC-J
D1IS
RWQCB
DDTC-J
DDTC-J
RWQCB
DDTC-J
USAEHA
RWQCB
USAEHA
USAEHA
USAEHA
DDTC-J
DHS
DHS
RWQCB
USAEHA
DHS
USATHAMA
RWQCIJ
SJLHD
RWQCU
DDTC-J
DDTC-J
DHS
RWQCU
Addressee
DDTC
DDTC
DDTC
DDTC
DLA-WS
EPA
DDTC-J
DDTC-J
RWQCB
RWQCU
DDTC-J
RWQCB
DDTC-J
DDTC-J
DDTC-J
DDTC-J
DDTC-J
USAEHA
RWQCB
DDTC-D
USAEHA
DLA-WS
DDTC-D
DDTC
DDTC-J
DDTC-J
DDTC-J
RWQCU
SJLHD
Commander, DDTC
Commander, DDTC
Subject
San Joaquin County Gruundwutcr Investigation.
Solid Waste Special Study No. 10-61-0165-81, Defense Depot Tracy, Tracy, California
Installation Assessment of Defense Depot Tracy, California, Report #181
Environmental Assessment, Defense Depot Tracy, Tracy California
Information to DI.A regarding the DoD Installation Restoration Program.
Letter forwarding statistical data requested during a telephone conversation on 2 August 1983.
Letter informing DDTC that the industrial pond does not require a permit.
Letter forwarding a report regarding the inspection of DDTC on 2 Apr 84.
RWQCB response to letter of 1 1 May 84 (Groundwater Monitoring Program).
Transmillal of the plan for sampling, preserving, and analy/.ing groundwatcr.
Letter requesting DDTC purge wells by pumping water until pll, electrical conductivity, and temperatures
stabilize, rather than by pumping 3 to 5 volumes as suggested.
Response to RWQCB letter dated 26 June 1984.
Correspondence providing information and guidance concerning actions being taken to correct monitoring
program problems.
Letter regarding the time schedule for submiltal of analytical results.
Request for review of the plan for the groundwater investigation at DDTC.
Notification of a groundwater consultation scheduled for DDTC during the period 17-20 September 1984.
Request that installations use only the new containers for the groundwater monitoring program and return all old
and extra containers to USAEHA.
Minutes of the Groundwater Consultation meeting between USAEHA, RWQCB and DDTC.
DHS review comments on (he plan for groundwuter quality investigation at DDTC.
Clarification as to what the Toxic Substances Control Division can and will require in regard to the hazardous
waste site investigation.
RWQCB comments on the groundwater investigation.
Groundwater Consultation No. 38-26-0474-85, Strategy for Groundwater Quality Investigation, Defense Depot
Tracy, Tracy, California, 17-20 September 1984.
DHS comments on the Hazardous Waste Site Investigation at DDTC.
Geohydrological Study No. 38-26-0488-85, Defense Depot Tracy, California
Letter regarding the status of the SOW for the groundwatcr contamination project.
Closure plan for (he underground storage tanks at DDTC.
Comments on the draft Statement of Work for (he hazardous contamination investigation at DDTC.
DDTC response to letter of 2 Aug 85 (draft Statement of Work for the hazardous contamination investigation.
Notice of the formulation of a closure plan for underground storage tanks.
Draft Statement of Work lor lu/aulinis waste contamination investigation.
KWQCB comments on the draft plans for the gcoliydrological investigation.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
85/11/14
85/12/13
8(i/03/OI
86/03/04
86/04/07
86/04/1 1
86/06/1 1
86/06/12
86/07/14
86/07/17
86/08/05
86/08/15
86/08/27
86/10/20
86/1 1/07
86/11/12
86/11/13
86/1 1/26
86/12/01
87/02/01
87/03/06
87/03/16
87/03/19
87/04/01
87/04/09
87/04/13
87/04/17
87/04/17
87/04/17
87/04/17
Author
uc
DDTC-WB
SJLHD
Radian
Col-
DDTC-WB
DDTC-WB
Coli
DHS
DDTC-WB
RWQCB
RWQCB
RC
WCC
WCC
CoE
DDTC-W
Dl IS
WCC
CoE
WCC
DHS
WCC
WCC
WCC
DDTC-W
CoE
DDTC-W
DDTC-W
DDTC-W
Addressee
DDTC
RWQCB
DDTC-WB
CoE, Hunlsvillc
DDTC-J
CoE
UWQCB
DDTC-W
Deputy
Cuintnander, DDT
RWQCB
DDTC-J
RWQCB
DDTC
CoE
CoE, Huntsville
DDTC-WB
DHS
DDTC-J
DDTC
WCC
DDTC
DDTC-J
DDTC
DDTC
DDTC-W
SJCHD
WCC
RWQCB
DHS
WCC
Subject
Gcohydrological Investigations, Final Plans, Defense Depot Tracy, Tracy, California
RWQCB response to letter of 13 Nov 85 (Geohydrological Investigations)
Permanent closure tank removal policy
Geohydrological Investigations Draft Engineering Report, DDRW-Tracy
Recommendation for I'll use II, groundwatcr contamination confirmation and corrective action investigation al
DDTC.
Confirmation that Options 1 and 2 not be exercised under the current contract with Radian Corporation.
Request review/comment for the proposed scope of work for the continuation of the Groundwatcr Quality
Assessment Study.
l.cller forwarding llic proposed SOW lor I'liasc II and III, IKP, Groundwater Contamination Assessment al
DDTC.
Comments on the draft Geohydrological Investigations Report.
Request for comments on the Radian Corporation's Draft Final engineering Report.
RWQCB's comments to the Gcohydrological Investigation.
Disposal, treatment, and reuse of soils contaminated with petroleum fractions.
Geohydrological Investigations, Final Engineering Report, Defense Depot Tracy, Tracy, California
Minutes for the pre-construction meeting held on 15 October 1986.
Draft Phase II Work Plans RI/FS
Request for review comments on the RI/FS Work Plans.
I .eller forwarding llic Phase II Work Plans, RI/FS.
Request for a 30-day extension lo commcnl on the I'liasc II Work Plan RI/FS.
Phase 11 Work Plans, Remedial Investigation/Feasibility Study, Defense Depot Tracy
Request to change analytical laboratory lo perform the USEPA Method 601 and 602
Letter Report Number 1, Defense Depot Tracy, Tracy, California.
DHS comments and recommendations of the Phase 11 Work Plans for the RI/FS.
Draft Letter Report Task 8, Sampling and Analysis of Private Wells, Defense Depot Tracy.
Work Plans, Remedial Investigation/Feasibility Study, Defense Depot Tracy.
Cost estimate lor sampling and analysis of the Raspo Well 3AG.
Letter transmitting the Work Plans for the RI/FS.
Response to WCC letters dated 3 1 March 1987 and 3 April 1987.
Notification that Well #12 will be tested again to verify (he finding of the first lest.
Letter transmitting the well log for the irrigation well located approximately 300 feel north of DDTC's northern
boundary.
Letter transmitting the well log for the irrigation well located approximately 300 feet north of DDTC's northern
boundary.
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
87/04/17
87/04/19
87/04/22
87/04/22
87/04/23
87/04/30
87/05/13
87/05/20
87/06/13
87/07/10
87/07/13
87/07/20
87/07/2 1
87/07/3 1
87/08/10
87/08/19
87/08/26
87/09/29
87/10/14
87/10/19
87/10/21
87/10/29
87/11/20
88/02/01
88/03/10
88/03/17
88/03/28
88/04/01
88/04/04
H8/04/04
88/04/04
Author
DDTC-W
WCC
DDTC-W
DHS
DHS
CoE
DIIS
DDTC-W
WCC
DDTC-G
RWQCD
WCC
WCC
DDTC-W
DDTC-W
RWQCB
RWQCB
WCC
DHS
RWQCB
CoE
WCC
DDTC-W
WCC
WCC
DLA-WS
WCC
liCOS, Inc.
DDTC-W
DDTC-W
DDTC-W
Addressee
DHS
CoE
DLA-WS
DDTC-W
DDTC-WB
WCC
DDTC-J
DIIS
DDTC
DDTC-D
RWQCB
CoE
CoE
WCC
SJCHD
DDTC-W
DDTC-W
CoE
DDTC-WB
DDTC-W
DDTC-WB
WCC
RWQCB
DDTC
CoE
DDTC-W
CoE
DDTC
SJLHD
DIIS
RWQCB
Subject
Nolitlcalion lliat Well #12 shall be tested again to verify the finding of the fust test.
Letter submitting Addendum No. 2 to the work plans for Tasks 30 and 32.
Request for funds to exercise options and Hunlsvillc Division support tor the RI/FS.
Letter confirming staff approval of the placement of 10 groundwater monitoring wells.
Underground storage tank closure plan, notice of deficiencies.
CoE review comments on the RI/FS letter reports and work plans.
Letter approving the request for a change in the classification of core material extracted during the construction
of off base ground water monitoring wells.
Addendum to the tank closure plan.
Letter Report Number 2.DDTC
Letter regarding the damages arising from exercise of right-of-way to Mr. Frank J. Raspo's properly.
Minutes of 7 July 1987 meeting held at DDTC.
Letter forwarding 4 copies of Draft Work Plans for the Part 2 field work to be performed as part of the
Minutes of the Project Review Meeting at DDTC held 7 July 1987.
Letter transmitting DIIS' letter regarding material ^classification.
RI/FS.
Notification that DDTC will comply with request to provide all analytical results, geotcchnical data and site
assessment inform.
Minutes for Waste Discharge Requirements and Groundwater Progress Review Meeting held on 7 July
RWQCB comments on the work plan for the remedial investigation.
Letter forwarding an addendum to the proposed Part 2 Work Plan.
1987.
Notice that (lie closure plan has adequately addressed all of the issues needed to ensure the proper closure of (he
unit.
RWQCB comments on the groundwater RI/FS.
Request for funds to contract for an aquifer pump test in Contaminated Area 2.
Summary of (he chemical analysis data from the 48 soil borings identified as SH3 1 and SB52 that were
and sampled from 17-20 August 1987.
DDRW addressing RWQCB's concerns regarding the groundwater RI/FS.
Letter Report Number 3, DDTC
Minutes from Progress Review Meeting Two on the Defense Depot Tracy RI/FS project.
Slate of California involvement in intcragency agreements for clean up of hazardous waste sites.
Letter advising DDRW the drilling subcontractor for performing soil boring and sampling work within
Southern Pacific Railroad right of way is Excelled), Inc.
Tank Closure Report lor Buildings 28 and 247, Underground Storage Tanks at DDTC.
Letter forwarding the proposed work plans for additional well sampling and soil borings.
Letter forwarding (he proposed work plans for additional well sampling and soil borings.
Letter forwarding the proposed work plans for additional well sampling and soil borings.
drilled
the
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
88/04/18
88/04/18
88/04/21
88/04/29
88/05/19
88/05/27
88/05/27
88/06/10
88/06/17
88/06/20
88/06/22
88/06/23
88/07/19
88/08/15
88/08/23
88/08/24
88/09/07
88/09/13
88/09/22
88/09/22
88/10/17
88/10/20
88/11/01
88/11/28
88/1 1/28
88/11/29
88/11/29
88/12/05
Author
SJLHD
WCC
WCC
WCC
DDTC-W
DDTC-W
RWQCB
DDTC-W
Canonic
Environmental
WCC
WCC
WCC
DDTC-W
RWQCB
WCC
DHS
WCC
WCC
DDTC-WB
DDTC-WB
DHS
RWQCB
WCC
Klcinfcldcr
Raymond Vail &
Assoc.
DDTC-W
DDTC-W
Canonic
Environmental
Addressee
DDTC-WB
CoE
SPTC
DDTC
CoE
CoE
DDTC-D
Oil:
DDTC
CoE
CoE
DDTC
RWQCB
RWQCB
CoE
DDTC-W
DDTC
CoE
EPA
DHS
DDTC-D
DDTC-D
Col:
DDTC
DDTC
DHS
RWQCB
Professional
Consultants, Inc.
Subject
Review comments by SJLHD on Phase II of the tank removal closure plan.
Letter transmitting four copies of the proposed Addendum No. 1 to the work plans for Tasks 30 and 32.
Letter submitting Contractors Right of Entry Forms, Exhibit A, and Certificate of Insurance.
Draft Remedial Investigation Engineering Report, DDTC
DDTC comments on the Remedial Investigation/Feasibility Study.
DDTC comments on the Draft Remedial Investigation Engineering Report.
Letter requesting that DDTC continue with the ground water investigation immediately.
1 .eller forwarding RWQCB's comments on the RI/F'S groundwalcr project.
Point Source Sampling Investigation.
WCC recommending (hat both Options 1 1 and 12 be exercised at this time, for a total ol 22 new wells to he
installed.
Summarization of the status of efforts to obtain approval from the Southern Pacific to drill soil borings within its
i ight of way adjacent to DDTC.
Letter Report Number 4, DDTC
Letter transmitting a copy of Letter Report Number 4, which summarizes the last laboratory analysis from 63
monitoring wells associated with the Rl of groundwater and soil.
RWQCB review comments for the Groundwater Remedial investigation.
Letter transmitting notes summarizing the discussions and conclusions from Progress Review Meeting Three on
the Rl/FS project.
Review comments on the proposed off-site well installation.
Work Plan Section 1 1.0, Additional (iroundwalcr Monitoring Wells, DDTC'
WCC proposed comments to the comments submitted by RWQCB.
Request for comments on the closure plan for the underground storage tanks.
Request lor comments on the closure plan for the underground storage tanks.
Contract stipulations for the Rl/FS does not allow sufficient flexibility for changing situations.
Letter recommending that the final contract contain provisions for maintaining flexibility in the RI/F'S process.
Comments and discussion in response to RWQCB and DHS letters regarding the remedial investigations
currently underway at DDTC.
Soil Sampling Investigation, DDTC
Preliminary Submillal, Proposed Improvements for Evaporation Ponds, 1, 2, and 3, and Various Sanitary
Conveyance Facilities.
Responses to letters from RWQCB and DHS.
Responses to letters from RWQCB and DIIS.
Detection limits ol the samples taken on 5 April 1988.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
8X/ 12/05
88/12/12
88/12/13
88/12/13
88/12/23
89/01/10
89/01/10
89/01/23
89/01/26
89/01/30
89/02/24
89/02/24
89/02/27
89/03/01
89/03/09
89/03/24
89/04/07
89/04/07
89/04/10
89/04/1 1
89/04/1 1
89/04/25
89/04/25
89/04/28
89AM/28
89/05/11
89/05/12
89/05/15
Author
wcc
RMS Prof. Consults,
Inc.
DDTC-WB
WCC
WCC
DDTC-WB
ERC
DHS
DDTC-WB
ERC
DDTC-WB
DDTC-WB
CoG
ERC EESC
WCC
ERC
RWQCB
WCC
DDTC-WB
RWQCB
RWQCB
CoE
DDTC-WB
ERCEESC
ERCEESC
ERC EESC
DHS
DDTC-WB
Addressee
CoE
PVER, Inc.
CoE, Hunlsvillc
CoE
DDTC
CoE
CoE, Hunlsvillc
DDTC-WB
DHS
CoE, Hunlsville
DHS
RWQCB
WCC
DDTC
DDTC
CoE, Hunlsville
RWQCB
DDTC
Coli
DDTC-WB
DDTC-WB
WCC
Coli
DDTC
DDTC
DDTC
DDTC-WB
RWQCB
Subject
Facl slice! delineating the conlenl ol each RI/FS report deliverable.
Tiansmitlal of contract prints of the photos ol the fuel tank excavation.
Comments on the Statement of Work for the aquifer pump test.
Submission ol a revised l;acl Sheet which describes DDTC's report dcliverables.
Phase 1 Remedial Investigation Report, DDTC
Review comments for (he Draft Phase I Remedial Investigation Report.
Preliminary Draft Work Plan Aquifer Pump Test Defense Depot Tracy
Request for additional information to complete closure certification report for underground waste storage
at Building 247 and Warehouse 28.
Additional information necessary to meet State Underground Tank Closure requirements.
Draft Work Plan Aquifer Pump Test Defense Depot Tracy
Copy of the draft Work Plan for the Aquifer Pump Test.
Copy of the draft Work Plan lor the Aquifer Pump Test.
tanks
Request for WCC to incorporate review comments in the Phase II Remedial Investigation/feasibility Study
(MIPS).
Work Plan, Aquifer Pump Test, DDTC
Data Analysis Supporting Task 36 Well Locations for DDTC
Draft Aquifer Pump Test Engineering Report, Defense Depot Tracy
Comments for Phase I Remedial Investigation report.
Technical Stihniiltal of Task 28 - Part 1, Gromulwater Sampling anil Analyses for DDTC.
Request the development of a delivery order contract for the installation, operation, and mainlciiam.T of a
remediation system to mitigate groundwater contamination.
RWQCB's comments to the Phase 1 Remedial Investigation Report and Data Analysis Supporting Task 36
Locations.
Draft DHS comments on the geology and well placement.
Well
CoE comments and request that Phase 1 of llie RI/FS be revised to include more analysis and correlation of the
field data.
Request the development ol a delivery order contract for a supplemental study to the existing RI/I\S.
Aquifer Pump Test Engineering Report, DDTC
Evaluation ol (iioundwalcr Withdrawal and Treatment, DDTC.
Section C, Descriplion/Specilicalion/Woik Statement Data Items DD 1423 and DD IC>M, Interim Remedial
Measure, Defense Depot Tracy, California
Comments to the Phase I Draft Remedial Investigation report and the Data Analysis Task 36 Well Locations
Report.
Status report on the RI/I-'S project.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
89/05/16
89/05/16
89/05/16
89/05/26
89/06/06
89/06/26
89/07/03
89/07/05
89/07/10
89/07/10
89/07/19
89/07/19
89/07/20
89/07/25
89/07/28
89/07/28
89/08/09
89/08/18
89/09/05
89/09/05
89/11/20
90/01/15
90/01/15
90/01/23
90/01/24
90/01/24
90/01/25
90/01/25
90/02/06
90/02/21
Author
DDTC-WB
ERC EESC
ERC EESC
CoE
DDTC-WB
RWQCB
WCC
DDTC
DHS
RWQCB
WCC
DDTC-WB
CoE, Huntsville
CoE
Coll
DDTC-W
DHS
DDTC-W
DDTC-W
Ensolcch, Inc.
Ensotech, Inc.
Ensolech, Inc.
Ensotech, Inc.
AEPCO
DDTC-WB
Ensotcch, Inc.
Ensolecli, Inc.
DDTC-WB
Ensolcch, Inc.
Addressee
RWQCB
DDTC
DDTC
DDRW-WB
CoE
DDTC-W
DDTC
DDTC-WB
DDTC-WB
DDTC
RWQCB
WCC
WCC
CoE
DDTC-WB
EPA
EPA
DDTC
DDTC
DDTC
DDTC
CEHND
CoE
DDTC
DDTC
CoE
DDTC
Subject
Request for comments on the Aquifer Pump Test Report; Evaluation of Groundwatcr Withdrawal and Treatment,
I-'S; Environmental Assessment; ROD; and Work Statement for IRM.
Environmental Assessment, Interim Groundwater Remediation System, Defense Depot Tracy, California
Record of Decision - Interim Groundwater Remediation System - Defense Depot Tracy, California
Draft scope of work lor the Supplemental Study to the RI/I-'S.
DDTC-WB's response to telefax of 25 May 1989 (Industrial Process Assessment and Process Alternatives
Evaluation).
RWQCB comments on the RI/I-S Engineering Report, Volume 1.
Draft RI/FS Engineering Report DDTC
Negative Declaration for Interim Remediation System (Air Stripper) for Groundwater Treatment, US Defense
Logistics Agency, Defense Depot Tracy, Tracy, California
Comments on the proposed Interim Remedial Measure (IRM).
Contract DACA87-89-R-0099, Interim Groundwater Withdrawal, Treatment and Disposal System
RWQCB's comments on the Statement of Work for the Interim Groundwater System.
Work Plan, Section 13.0, Additional Ground water Monitoring Wells for DDTC
Submittal of analysis on the sanitary and industrial sewerage system.
Solicitation/Modification of Contract for Interim Groundwater Withdrawal Treatment and Disposal System
Request that the disposition of the comments be in separate correspondence and the incorporation of the changes
in the final feasibility study.
CoE's comments on the RI/I-S to WCC.
DDTC review comments to the Rl/l-'S contract modification.
DHS comments on (he Interim Groundwater Withdrawal, Treatment, and Disposal System.
Letter proposing that DDTC be deleted from further consideration as an NPL site.
Letter proposing that DDTC be deleted from further consideration as an NPL site.
Permit for Drilling 18 Wells at DDTC
Safely, Health, and Emergency Response Plan (Draft) for DDTC
Site Specific Safely Plan, Groundwater Remediation (Draft) for DDTC
Preliminary Draft Groundwater Model Report
Draft Investigation Plan Industrial Process System Assessment & Process Alternatives Evaluation at Defense
Depot Tracy
Request for review ol the abandoned well sites.
Permits Status Report for Interim Groundwaler Remediation al DDTC
Equipment Submiltal Data (Draft) for Interim Groundwaler Remediation al Tracy Defense Depot, San Joaquin
County, California
DDTC's comments on (he documents from Ensotcch. Inc.
Rationale for Monitoring Well Placement al DDTC
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
90/02/22
90/02/22
90/02/28
90/02/28
90/03/02
90/03/08
90/03/22
90/03/24
90/04/01
90/04/04
90/04/05
90/04/06
90/04/18
90/05/04
90/05/04
90/05/10
90/05/17
90/05/25
90/05/25
90/05/31
90/05/3 1
90/06/08
90/06/15
90/06/15
')()/( )6/2(>
90/07/02
90/07/10
90/07/12
90/07/16
Author
DDTC-WB
Ensolcch, Inc.
CoE
CoE
DDTC-WB
Ensolcch, Inc.
Ensotech, Inc.
Ensotech. Inc.
DDRW
DDTC-WB
Ensotech, Inc.
DDTC-WB
DHS
DDTC-WB
DDTC-WB
CoE
Acpco, Inc.
DDTC-WH
DDTC-WB
DDTC-WB
DDTC-WB
DDTC-WB
Ensolech, Inc.
RWQCB
DDUW-WB
RWQCB
DDRW-DE
Ensotech, Inc.
DDRW-DE
Addressee
CoE
DDTC
AEPCO, Inc.
Ensolcch, Inc.
CoE
DDTC
DDTC
DDTC
RWQCB
DDTC
CoE
DHS
RWQCB
DHS
AEPCO, Inc.
DDTC
RWQCB
DHS
DHS
DHS
CoE
DDTC
DDTC-WH
I-I'A
DDTC-WB
RWQCB
DDTC
CoE
Subject
DDTC's comments on the AEPCO, Inc., Draft Investigation Plan.
Addendum to Work Plan
CoE comments on the DDTC Process Evaluation.
CoE comments on Ihe Groundwater Treatment System.
DDTC comments on Ihe Addendum to Work Plan, Interim Groundwalcr Withdrawal, Treatment, and Disposal
System and Rationale for Monitoring Well Placement Report.
Rev 1 Safety, Health, and Emergency Response Plan for Defense Depot Tracy
Prcvcntative Maintenance Schedule for Interim Groundwaler Remediation at DDTC
Preliminary Groundwater Model Report, DDTC
Interim Remedial Action Plan for DDTC
Copy of the Draft Investigation Plan Industrial Process System Assessment and Process Alternatives
Evaluations.
Topographic Site Survey for Interim Groundwaler Remediation at DDTC
DDTC comments on the Abandoned Water Well Evaluation Project.
Formal agreement between Region 1 Permitting and Site Mitigation for the Site Mitigation Units (SMU) to
oversee characterization and remediation activities.
Request for review and approval of the Solid Waste Management Units Investigation Plan.
Request for review and approval of Ihe Solid Waste Management Units Investigation Plan.
CoE comments on the Point Source Evaluation Investigation Plan.
Final Investigation Plan (Rev 01) Industrial Process System Assessment and Process Alternatives Evaluation at
Defense Depot Tracy, California
Request review of WCC's Woik Plan, Task 33, Soil Boring, and Task 37. Grouiulwatcr Monitoring Wells.
Request review of WCC's Work Plan, Task 33, Soil Boring, and Task 37, Groundwaler Monitoring Wells.
Copy of the draft Scope of Work for the DDTC Well Monitoring Program.
Request review of the Abandoned Water Well Evaluation and Underground Storage Tank Investigation and
Study.
DDTC comments on the Statement of Work for the Abandoned Well Evaluation and Draft Underground Storage
Tank Investigation and Study
Final Safely, Health, and Emergency Response Plan for Defense Depot Tracy
RWQCB comments on the draft Scope of Work lor the regular monitoring to Ihe RI/FS wells.
Letter suhmilling minutes lor Ihe Piojeel Managers Meeting held 4-5 June 1991.
RWQCB comments on the proposed Statement of Work underground lank and abandoned walei well
investigations.
Request review of the Solid Waste Management Unit RI/FS Statement of Work.
Design Calculations for Interim Groundwater Remediation at DDTC
Request ("oil increase the sampling requirements on a quarterly basis (Well Monitoring Program).
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
90/07/18
90/07/23
90/07/24
90/07/24
90/08/01
90/08/01
90/OK/OI
90/08/01
90/08/02
90/08/07
90/08/07
90/08/09
90/08/14
90/08/3 1
90/09/27
90/09/27
90/09/28
90/09/28
90/09/28
90/10/09
90/10/23
90/11/01
90/1 1/14
90/11/14
90/1 1/2(>
90/11/27
90/12/11
90/12/13
Author
DDRW-DE
DDKW-DG
Ensolech, Inc.
RWQCB
DDRW-DE
DHS
D1IS
Nakata Plan Grp, Inc.
Col:
DDKW-DE
DDRW-DE
DDRW-DE
CoE
RWQCB
CoE
CoE
CoE
DDRW-DE
DDRW-DE
Coli
Col-
Golden Wcsl Builders
DDRW-DE
DDRW-DE
Coli
CoE
Ensolech, Inc.
DDRW-DIi
Addressee
DHS
CoE
DDRW-WB
DDRW-DE
DHS
DDRW-DE
DDRW-DE
DDTC
Ensolecli, Inc.
CoC
CoE
CoE
Ensolecli, Inc.
DDRW-WB
WCC
Ensolecli, Inc.
Ensotech, Inc.
CoE
DHS
DDRW-WU
Ensotech, Inc.
DDRW
RWQCB
DHS
linsolcch, Inc.
AEPCO, Inc.
DDTC
CoF.
Subject
DHS coiinneiits on WCC's risk assessment portion of the RI/FS.
DHS comments on WCC's RI/FS risk assessment.
Notification that the air stripping tower will be shipped to the depot on 24 July 1990.
Notification (hat the Statement of Work for (he remediation of the underground storage tank site appeared
satisfactory.
Copy ol the internal audit on the monitoring well drilling operations.
DHS comments on the risk assessment of the draft RJ/FS engineering report.
Acceptance ol technical responses and submittal of a schedule for the Interim Grouridwalcr Treatment System.
Concept Development Report, DDTC
Letter notifying linsolcch that the vapor control unit docs not meet the terms of the contract.
Comments from DHS on the RI/FS Study Risk Assessment.
Letter transmitting a copy of the waste discharge requirements for the IRM as proposed by RWQCB.
Documents regarding the late revisions for the IRM Waste Discharge Permit.
Notice of failure to comply with contract requirements.
Letter approving the revised statement of work for the monitoring well sampling program.
Change in laboratory, revised schedule, and internal audits for RI/FS.
Letter requesting that the addendum to the "Authority to Construct" permit application for the IRM be received
by 22 August 1990.
CoE comments on the document submittals for the interim ground water withdrawal, treatment, and disposal
system.
DDRW requesting a response for a firm start date on the construction of the IRM.
Letter requesting a response lor a firm star! dale on the construction of the IRM.
CoE responding to DDRW-WB's letter dated 28 September 1990.
CoE review comments on the permit application for construction of the air stripping lower and vapor control
unit.
DDRW Building 201 Contract/Scope of Work
Request review of the Draft Work Plan for Investigation of Solid Waste Management Units and Work Plans
the Well Monitoring Program.
Request review of the Draft Work Plan for Investigation of Solid Waste Management Units and Work Plans
(he Well
Coli comments on the document suhmillals for (lie interim gioinulwaler withdrawal, treatment, and disposal
system.
Request disposition ol comments and incorporation of changes in the final report.
Application for Authority to Construct and Permit to Operate Air Stripping Tower and GAC Vapor Control
Units to Cleanup TCE and PCE Contaminated Groundwatcr
Letter requesting lluit Mr. Marshall Cloud he replaced as Ihc conlracling officers representative for the IRM.
for
for
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
y< 1/12/27
yi/oi/16
91/01/16
y i/o 1/25
y i/o 1/25
y I/O 1/25
y 1/01/28
yi/oi/2y
yi/oi/2y
yi/oi/3i
yi/oi/3i
y 1/02/01
y 1/02/05
91/02/05
91/02/06
91/02/06
yi/02/ll
yi/02/n
yi/02/n
91/02/13
y 1/02/1 5
y 1/02/1 5
91/02/15
y 1/02/22
91/02/25
9I/02/2S
y 1/03/01
Author
DDRW-DE
CoE
CoE
KWQCB
KWQCB
KWgCH/msC
CoE
CoE
EPA
Aepco, Inc.
DHS
WCC
DDRW-WB
EPA
DDRW-DE
WCC
DDRW-WB
DDKW-WB
DDRW-WB
EPA
DDRW-WB
DDRW-WB
DDRW-WB
lil'A
Ensotcch, Inc.
DDRW-WB
DDRW-WB
Addressee
CoE
DDRW-DE
DDRW-WB
DDRW-DE
RWQCU
uwgcu/msc
WCC
DDRW-DE
DDRW-Dli
DDRW
DDRW-DE
DDRW
CoE
CoE
DHS
DDRW
DHS
KWQCH
EPA
DDRW-WB
EPA
RWQCB
DHS
DDRW-WB
DDKW
EPA
DHS
Subject
DDRW comments to the Industrial Process System Assessment and Process Alternatives Evaluation l-"inal
Investigation Plan.
Request for a technical report which documents the work completed under the COE purchase order.
Letter recommending that DDRW request permission to proceed with the well monitoring and solid waste
management unit piograms with regulatory comment.
Comments on the Solid Waste Management Units and Well Monitoring Work Plans
Comments on the work plan lor the Well Monitoring Program
Review comments on the Woik Plan lor the Well Monitoring Program.
CoE comments on (he Preliminary Draft RI/FS Report.
Letter clarifying the relationship between the well monitoring program and monitoring for the IRM.
EPA comments on the Draft Work Plan lor Investigation of solid waste management units.
Alternatives Evaluation/ Implementation Report, Industrial Process System Assessment and Process Alternatives
Evaluation at DDRW, Tracy, California
Comments on the Draft Work Plans for the Solid Waste Management Units.
Final Work Plan for Investigation of Solid Waste Management Units at Defense Distribution Region West,
Tracy, California
CoE comments on the Preliminary Draft RI/FS Report.
EPA comments on the Work Plans for the Well Monitoring Program
Copy of Volume II of the Well Monitoring Plan.
Vol I and II, Work Plan for the Well Monitoring Program at Defense Distribution Region West, Tracy
Copy of the final Alternatives Evaluation/Implementation Report.
Copy of the final Alternatives Evaluation/Implementation Repoil.
Copy of the final Alternatives Evaluation/Implementation Report.
EPA comments on the draft scope of work for UST Investigation and Study.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan for Investigation of Solid Waste
Management Units.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan lor Investigation of Solid Waste
Management Units.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan for Investigation of Solid Waste
Management Units.
EPA comments on the draft scope of work for the Abandoned Walerwcll Evaluation.
Geologic Well Logs (Draft) for Interim Ciroundwalcr Remediation at Tracy Defense Depot, San Joaquin County,
California
Copy of the Installation Assessment of Defense Depot Tracy and Pre-Survey Instructions for Installation
Assessment.
Two copies of the Draft RI/FS Report.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
y 1/03/01
y i/03/oi
91/03/11
yi/03/12
y 1/03/1 5
yi/03/lH
y 1/03/25
91/03/29
91 AM/01
91/04/02
91/04/05
91/05/01
91/05/06
91/05/17
91/05/22
91/05/23
91/05/27
91/05/29
91/05/29
91/05/29
91/05/31
9I/06AM
91/06/10
91/06/19
91/06/21
91/06/24
91/06/27
91/07/05
91/07/09
91/07/11
91/07/18
91/07/18
Author
DDRW-WU
DDRW-WB
DDRW-WB
DDRW-WB
CiWESIKJC
EPA
DDRW-WB
CoE
DDRW-WB
Ensulech, Inc.
Ensotech, Inc.
DDRW-WB
RWQCB
IZnsolech, Inc.
EPA
EPA
Ensotech, Inc.
DDRW-WB
DDRW-WB
DDRW-WB
DHS
Ensotech, Inc.
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
RWQCB
RWQCB
DDRW-WB
CoE
CoE
DDRW-WB
Addressee
EPA
Coli
ATSDR
EPA
DDUW
DDRW-WB
EP A
DTSC
CoE
DDRW
DDTC
CoE
DDRW-WB
DDRW
CoE
DDRW-WB
DDRW
CoE
RWQCB
CoE
DDRW-WB
DDRW
CoE
CoE
CoE
CoE
Col-
DDRW-WB
EPA
RWQCB
Ensotech, Inc.
EPA
Subject
Two copies of the Draft RI/FS Report.
DDRW informing CoE of their difficulties with Ensotech, Inc., ihe prime contractor for ihc air stripper project.
Two copies of the Draft RI/FS Report.
Information submitted as requested by EPA's letter dated 28 February 1991.
Remediiilion Status Report, DDKW Building 201 Underground Tank Sile Remediation
EPA comments on the Community Relations Plan.
DDRW response to EPA, RWQCB, and DI1S comments regarding the Well Monitoring Program, Solid Waste
Management Units, and Abandoned Well Project and Underground Storage Tanks.
Letter addressing comments received by DTSC, RWQCB, and EPA.
Copy ol the signed Building 201 UST Contract.
Installation Data Report for Interim Groundwaler Remediation at Tracy Defense Depot, Tracy, California
Start-Up Schedule for Interim Groundwater Remediation at DDTC
DDRW comments on the Statement of Work for Building 201 soil treatment/disposal.
Letter indicating those wells which should be measured monthly for groundwater elevations for a period of one
year.
Report on Prove-Out of Interim Groundwater Remediation System at Tracy Defense Depot, Tracy, California
EPA comments concerning the Draft RI/FS Report.
EPA input concerning the selection of monitoring wells to be used to measure monthly groundwaier levels.
Sile Specific Quality Management Plan (SSQMP) for Interim Groundwaler Treatment System at Tracy Defense
Depot, San Joaquin County, California
DDRW comments on the Installation Data Report for Groundwater Remediation.
Letter informing RWQCB of Ihc intent to begin sampling for the well monitoring program.
DDRW comments on the Installation Data Report.
DHS comments on the Draft RI/F'S Report.
Drill Cuttings Disposal Report for Interim Groundwater Remediation System at DDTC
DDRW comments on the Prove-Out of Interim Groundwater Remediation System Report.
DDRW review comments for the Drill Cuttings disposal report and (he Site Specific Quality Management Plan.
DDRW notifying CoE of deficiencies in the construction of the 1RM.
Notification of the existence of a Federal Facilities Agreement between the regulatory agencies and DDRW.
RWQCB comments on the Statement of Work for the RI/FS Work Plan.
RWQCB comments on ihe RI/FS Report.
Letter notifying EPA of (he intent to issue a press release which details the signing of the FFA.
Letter presenting a proposed plan for completion of (he RI/FS for OU-1.
Letter notifying (lie contractor of deficiencies in the installation of the interim ground water withdrawal and
disposal system.
Letter submitting copies ol Ihc publication notices soliciting public comment on the Federal Facility Agreement.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
9 1/07/19
91/07/22
91/07/24
91/07/29
91/07/30
91/07/31
91/08/02
91/08/09
91/08/09
91/08/09
91/08/13
91/08/15
91/08/19
91/08/19
91/08/20
91/08/21
91/08/21
91/08/21
91/08/23
91/08/23
91/08/23
91/08/24
91/08/26
91/08/26
91/08/26
91/08/26
91/08/29
Author
DDRW-WB
EPA
EPA
CoE
DDRW-WB
RWQCU
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
EPA
DDRW-WB
DDRW-WB
EPA
DDRW-WB
DDRW-WB
EPA
DDRW-WB
DTSC
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
EPA
RWQCB
DDRW-WB
Addressee
CoE
DDRW-WB
DDRW-WB
DDRW-DE
CoE
DDRW-WB
DDRW-WB
RWQCB
EPA
DHS
DDRW
DDRW-WB
EPA
DTSC
DDRW-WB
RWQCB
CoE
DDRW-WB
CoE
DDRW-WB
DDRW-WB
EPA
EPA
Col:
DDRW-WB
DDRW-WB
I-PA
Subject
DDRW comments lor (he Installation Data Report and the Prove-Out Report.
Letter delineating (he US EPA's concerns regarding (he location of (he proposed Subsistence Warehouse.
EPA's response to DDRW's letters of 18 July 1991 and 22 July 1991.
Letter proposing deadlines for the Federal Facility Agreement at DDRW.
Request that monitoring wells 2F-89-25 and 2F-89-26 not be dcslroycd because of (he location of several old
SWMUs in proximity to (he new Subsistence Warehouse.
Letter requesting dial DDRW investigate options and take actions to discontinue the use of (he agricultural
supply wells and to replace (he water supply for those well owners.
RWQCB requesting a 30-day extension for the review of (he Draft Solid Waste Management Unit Engineering
Report.
Letter proposing document delivery dates and a press release of the document deadlines.
Letter proposing document delivery dales and a copy of (he public notice to be published in (he Tracy Press and
Stockton Record regarding
Letter proposing primary document deadlines.
Draft Quarterly Groundwaler Monitoring Program, May 1991, for (he Well Monitoring Program at Defense
Distribution Region Wesl, Tracy, California
EPA's preliminary comments on the investigative effort at DDRW Tracy's Subsistence Warehouse.
Letter informing EPA of the discovery of an old burn pit at (he Subsistence Warehouse construction site.
Letter informing DTSC of (he discovery of several old buried 55-gallon drums and numerous old burn pits in the
Subsistence Warehouse construction site.
EPA comments on the proposed schedule tor draft primary documents.
Letter requesting RWQCB's review and comment on (he Draft Quarterly Ground water Monitoring Report.
DDRW review comments on the DDRW-Tracy Subsistence Warehouse Scope of Work (SOW).
EPA comments on (he Scope of Work for the Subsistence Warehouse removal action.
Correspondence regarding (he funding for the replacement of the Raspo agricultural wells.
DTSC comments of (he SOW for the Subsistence Warehouse Construction Sile.
RWQCB comments on (he Draft Investigation and Remediation Plan.
DDRW requesting EPA review the preliminary sampling results from the Subsistence Warehouse construction
site.
DDRW requesting permission to release stockpiled excavation soils for oilier construction purposes.
Notification that DDRW is officially releasing the Subsistence Warehouse stockpiled soils from restriction.
Letter agreeing with DDRW-WB's letter that the stockpiled soils from (he Subsistence Warehouse do not
represent an imminent threat to human health and the environment.
RWQCB comments on the Proposed Plan for (he completion of the RI/FS forOU-l.
Lei lei transmitting ihe SOW fur the rapid clKitaclcri/.alion and cleanup of the Subsistence Warehouse
construction site.
0
O
o
H
•^
V
n
>+z
t ft:
\Jl
n
k
CL
«*
rt
JO
a
rt
a.
o
-*l
o
re
2
f.
3
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
91/08/29
«J 1/08/30
91/09/01
91/09/03
91 /09AM
91/09/05
91/09/09
91/09/10
91/09/12
91/09/12
91/09/12
91/09/16
91/09/17
91/09/18
91/09/18
91/09/18
91/09/18
91/09/19
91/09/24
91/09/26
91/10/01
91/10/01
91/10/07
91/10/10
91/10/16
91/10/16
91/10/17
91/10/17
91/10/18
91/10/21
91/10/23
Author
RWQCB
DDRW-WB
EPA
DDRW-WB
DDRW-WU
DDRW-WB
EPA
RWQCB
DDRW-WB
DDRW-WB
DTSC
CoE
DDRW-WB
CoE
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
Coif
DDRW
Unknown
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
lil'A
DDRW-WH
Addressee
DDRW-WB
RWQCB
DDRW
CoE
DTSC
DLA-WE
DDRW-WB
DDRW-WB
RWQCB
Resident
DDRW-WB
Ensotech, Inc.
RWQCB
WCC
EPA
DTSC
CoE
Coli
DDRW-WB
DDRW-WB
DDRW-Tracy
CoE
CoE
DTSC
CoE
Coli
DTSC
DDRW-WB
DDRW-WB
lil'A
Subject
RWQCB comments on (he 1RM Prove-Out Phase Reports.
Letter requesting the Ruspo agricultural wells be made an agenda item for the upcoming project manager's
meeting.
Aerial Photographic Analysis of DDRW Tracy
DDRW review comments on the Quarterly Groundwater Monitoring Report.
DDRW's proposed schedule change for the draft primary documents.
An informational teller regarding the Subsistence Warehouse cleanup.
EPA comments on the Draft SWMU Engineering Report.
RWQCB comments on the Draft Solid Waste Management Unit Engineering Report.
DDRW's response to RWQCB letter dated 3 1 July 1991 .
Response to documents requested during meeting held 5 September 1991.
DTSC comments on the Solid Waste Management Unit Engineering Report.
Approval to proceed with full-scale operation of the groundwater withdrawal, treatment, and disposal system.
Letter concerning the olfsilc contamination of crops and agricultural supply wells.
CoE comments to the Draft Quarterly Monitoring Report Number 1 for the Well Monitoring Program.
Notification that the public comment period for the FFA expired and DDRW had received no comments.
Letter regarding the public comment period for the Federal Facility Agreement.
Notification that (he public comment period for (lie Federal Facility Agreement has expired and there were no
comments received.
DDRW review comments for Telic Engineering Corporation Draft Subsistence Warehouse Report.
DTSC comments on the prove-out reports for the groundwater treatment plant.
Letter regarding the excavation and testing at the Consolidated Subsistence Facility.
Final Defense Distribution Region West, Environmental Program, Community Relations Plan, 1991
Community Relations Plan
Request that CoE send the RWQCB and DTSC appropriate number of copies of all SOWs and reports for the
Building 201 site characterization.
DDRW notifying CoE of their concerns with the start-up of the air stripper by Ensotech. Inc.
Letter requesting DTSC provide a list of all ARARs which might affect development of the Operable Unit One
Draft Feasibility Study.
DDRW notifying CoE of the IRM failure on 12 October 1991.
Letter responding to an inquiry regarding the Raspo properly casement.
Letter notifying DTSC ol an equipment failure which resulted in a spill of TCE/PCE contaminated water at the
IRM.
DTSC comments and recommendations regarding the RI/FS activities at DDRW Tracy
EPA comments on the Draft Quailcily (ii omul water Monitoring (May 1991) Report.
Lcllcr Iransmilling minutes ol (he Project Manager's Meeting held 10- 1 1 October 1991.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
91/10/24
91/10/26
91/10/29
91/10/29
91/10/29
91/10/29
91/10/30
91/10/31
91/11/01
91/11/01
91/11/06
91/11/11
91/1 I/I 1
91/11/15
91/11/15
91/11/19
91/11/19
91/11/20
91/11/20
91/11/20
91/11/22
91/11/26
91/11/20
91/11/27
91/12/01
91/12/01
91/12/02
Author
DDRW-WB
Telie Engineering,
Corporation
DDRW-WU
DDRW-WB
DDRW-WB
DISC
WCC
WCC
DDRW-WB
IT Corp.
DDRW-WB
WCC
WCC
DDRW-WB
EPA
DDRW-WB
EPA
DDRW-WB
DDRW-WB
PHS, SJC
RWQCB
DTSC
lil'A
DTSC
WCC
WCC
DTSC
Addressee
CoE
DDRW
Resident
Resident
DTSC
DDRW-WB
CoE
CoE
CoE
DDRW
EPA
DDRW
DDRW
CoE
DDRW-WB
RWQCB
DDRW-WB
Col-
Resident
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW
DDRW
DDRW-BE
Subject
Letter transmitting photographs of the IRM during the lime of the spill.
Project Summary Report, DDRW Tracy, subsistence Warehouse
Letter requesting permission to collect water samples from private wells which might be in the (low path of the
contaminants.
Letter requesting permission to collect water samples from private wells which might be in the flow path of the
contaminants.
Letter transmitting the Subsistence Warehouse Removal Action Summary Report for informational purposes.
DTSC requiring DDRW to prepare a report for regulatory review regarding the inadequacies of the air stripper.
Draft Letter Report (Response to Comments and Outline of Remaining Work) for the DDRW Tracy OU#I RI/FS
WCC's minutes for me Project Manager's Meeting held 10-11 October 1991.
Notification dial (he air stripper now has an outside telephone line.
Soil Treatment/Disposal, Building 201, DDRW Tracy
WCC's minutes from the Project Manager's meeting held 10-1 1 October 1991.
Quarterly Monitoring Report of May 1991 Sampling Round for Well Monitoring Program at DDRW Tracy
Quarterly Monitoring Report ol August 1991 Sampling Round for Well Monitoring Program at DDRW Tracy
Letter requesting the IRM startup be rescheduled.
EPA comments on the Draft Work Plan for Well Evaluation and Abandonment.
Letter transmitting the minutes for the Project Manager's Meeting held on 14 November 1991.
This letter documents EPA's approval of the revised Federal Facility Agreement schedule submitted on 10
September 1991.
DDRW requesting that a cure notice be issued to the contractor because of its failure to operate the IRM.
Letter transmitting the laboratory results for the water samples taken from his well on 6 and 14 November 1991.
Letter expressing concerns relative to the recent confirmation of contamination in off-site domestic drinking
water wells.
Request that DDRW Tracy submit a time schedule for development of a long term alternative water supply lor
(hose domestic wells impacted by groundwater contamination.
Recommendations regarding groundwatcr contamination at off-site residences near DDRW.
F.PA comments on the Draft Minutes ol the Project Manager Meeting held 10-11 October 1991.
DTSC recommending that DDRW provide an alternative drinking water supply to any resident impacted and
conduct an nlfsilc well survey lor a one-mile distance from DDRW.
Final Solid Waste Management Unit Engineering Report, DDRW, Tracy
Comprehensive Rl/FS Work Plan, DDRW Tracy
DTSC approving DDRW's request for an extension of the delivery date for the OU- 1 Draft F'inal FS and
Proposed Plan.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
91/12/03
91/12/04
91/12/04
91/12/05
91/12/06
91/12/10
91/12/13
91/12/13
91/12/13
91/12/16
91/12/16
91/12/19
91/12/19
91/12/20
91/12/30
92/01/01
92/01/02
92/01/06
92/01/06
92/01/16
92/01/16
92/01/16
92/01/17
92/01/20
92/01/21
92/01/22
92/01/23
Author
DDRW-WB
CoE
Ensolcch, Inc.
CoE
EPA
DDRW-WB
DDRW-WB
DDKW-WB
EPA
DDRW-WB
RWQCB
DTSC
EPA
DDRW-WB
Ensotcch, Inc.
IT Corp.
GWESBGC
DDRW-WB
DDRW-WB
CoE
DTSC
DTSC
DDRW-D
Ensolcch, Inc.
EPA
EPA
EPA
Addressee
Resident
DHS
DDRW
Ensolech, Inc.
DDRW-WB
CoE
EPA
RWQCB
DDRW-WB
CoE
DDRW-WB
DDRW-WB
DDRW-WB
CoE
CoE
DDRW
DDRW
CoE
EPA
Ensotech, Inc.
DDRW-WB
DDKW-WB
Coli
CoE
DDRW-WB
DDRW-WB
DDRW-WB
Subject
Letter transmitting the laboratory test results for the water samples taken from his well on 6 and 4 November
1991
Letter requesting concurrence regarding the use of bioremediation as the method of treatment for the soil from
Building 201.
Monthly Operation Report, Interim Groundwalcr Remediation System, DDRW Tracy
Notice to discontinue work on the interim groundwater treatment system.
EPA review comments on EPA EMSL's aerial photography analyses.
DDRW review comments on the Telic Engineering Company's Project Summary Report for the Subsistence
Warehouse construction project.
Notification that DDRW is providing bottled water to two residents near DDRW.
Notification that DDRW is providing bottled water to two residents near DDRW.
EPA comments on Rl/FS for OU- 1/
Letter requesting 2 copies of the Oracle Database User Instruction Manual and review the possibility of adding
sampling of all IRM wells to the existing contract.
RWQCB comments and concerns with the Draft Work Plan for Well Evaluation and Abandonment.
DTSC comments of the Draft Work Plan for Well Evaluation and Abandonment.
EPA review comments on the Draft Quarterly Monitoring Report of the August 1991 Sampling Round for the
Well Monitoring Program.
DDRW comments on the Draft Work Plan for Well Evaluation and Abandonment.
Ensotech's response to CoE's letter dated 18 December 1991.
Remedial Action at Building 201, DDRW Tracy
Remediation Status Report, DDKW Building 201 Underground Tank Site Remediation
Letter directing the CoE, Iluntsville Division, to proceed with the termination for default process on the IRM
unit.
Letter informing EPA that bioremedialion is the selected treatment method for dicsel contaminated soils from the
Building 201 site.
CoE notifying Ensolech of their failures to perform in accordance with (he contract.
DTSC letter expressing concern regarding the expansion of DDRW Tracy's groundwalcr contamination.
Notification thai the groundwater treatment system restoration report submitted was insufficient and requested
that the report he resuhniilled.
Leller urging (he Coli (o default the interim remedial measure unit contractor because of their failure to gel the
system operational.
Ensolech's response to CoE's letter dated 19 December 1991.
Letter submitting a draft analysis of potential Federal ARARs for the Rl/FS for OU- 1 .
Summary of the meeting of 16 December 1991 regarding chemicals of concern for OU-I RI/1;S.
lil'A review comments on the l:inal May 1991 Quarterly Monitoring Report.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/01/24
92/01/24
92/01/30
92/01/30
92/01/30
92/01/31
92/02/01
92/02/01
92/02/05
92/02/05
92/02/06
92/02/10
92/02/13
92/02/19
92/02/20
92/02/24
92/02/28
92/02/28
92/02/28
92/02/28
92/03/01
92/03/05
92/03/05
92/03/06
92/03/09
92/03/1 1
92/03/1 1
92/03/12
92/03/12
92/03/12
92/03/12
Author
lil'A
Resident
DDRW-WB
DDRW-WB
DDRW-WB
RWQCB
IT Corp.
WCC
DDRW-D
EPA
DDRW-WB
WCC
EPA
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WH
RWQCB
WCC
IT Corp.
DDRW-WB
DDRW-WB
WCC
WCC
DDRW-WH
USAMC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
Addressee
DDRW-WB
DDRW-D
EPA
Deputy Secretary,
Resources Agency
Ofc of Env Proj Rev
DDRW-WB
DDRW
DDRW
Resident
DDRW-WB
EPA
CoE
DDRW-WB
CoE
CoE
EPA
EPA
DTSC
DDRW-WB
DDRW
DDRW
EPA
CoE
CoE
CoE
Residents
DLA
Resident
Resident
Resident
Resilient
Subject
Letter submitting guidance lor (he natural resource damage assessment.
Letter requesting status on the contamination located on his property.
Letter requesting EPA determine the necessity ol" performing a Natural Resources Damage Assessment at
DDRW Tracy.
Letter requesting the Resources Agency determine the necessity of performing a Natural Resources Damage
Assessment at DDRW Tracy.
Letter requesting this office determine the necessity of performing a Natural Resources Damage Assessment at
DDRW Tracy.
RWQCB comments for the work plan for Remedial Action at Building 201.
Treatment/Disposal Alternatives Report, Soil Treatment/Disposal for Building 201, DDRW Tracy
Final Work Plan for Well Evaluation and Abandonment at DDRW Tracy
Response to Mr. Raspo's letter dated 24 January 1992.
EPA comments on the Risk Assessment and the Overall RI/FS Work Plan.
Letter requesting an extension for submittal of the Draft Rl Report for Operable Unit # 1 .
Letter requesting a 17 day extension of the deadline for the Third Quarterly Monitoring Report.
Letter approving DDRW's request for a 36-day extension on the Draft RI Report.
Request for a schedule extension for (he Draft Abandoned Watervvell Evaluation Report.
Notification of the need loresample the five domestic wells sampled in December 1991.
Letter requesting an extension of the submittal date deadline for the Draft Abandoned Waterwell Evaluation
Report.
Letter requesting 91 additional days for the Draft Abandoned Walenvell Evaluation Report.
Request for an additional 91 days to review the Draft Abandoned Walcrwcll Evaluation Report.
Letter transmitting information regarding ARARs for Operable Unit 1.
Quarterly Monitoring Report of the November 1991 Sampling Round for the Well Monitoring Program at
Defense Distribution Region West -
Technical Work Plan Remedial Action at Building 201, Defense Distribution Region West, Tracy, California
Submitlal of the minutes for the Project Manager's Meeting held 26-27 February 1992.
DDRW comments for the Treatment/Disposal Alternatives Report Soil Treatment/Disposal for Building 201.
Letter transmilling a tentative list of the 26 wells recommended for sampling and analysis.
WCC minutes lor the Project Manager's Meeting held 26-27 February 1992.
Letter requesting permission to sample his private domestic well.
Letter endorsing the request for (he acquisition of agricultural land adjacent to DDRW.
Letter requesting permission to sample his private domestic well.
Letter requesting permission to sample his private domestic well.
Letter requesting permission to sample his private domestic well.
Letter requesting permission to sample his private domestic well.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/03/13
'J 2/03/1 6
92/03/17
92/03/19
92/03/24
92/03/27
92/04/09
92/04/13
92/04/17
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/21
92/0-1/30
92/04/30
92/04/30
92/04/30
92/04/30
92/04/30
92/04/30
92/05/01
92/05/01
92/05/01
92/05/03
92/05/04
Author
wcc
wcc
wcc
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WIEP
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WM
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
ESE, Inc.
IT Corporation
WCC
DDRW-WB
DDRW-WU
Addressee
CoE
ETCC
ETCC
DDRW-WB
CoE
USDOI
EPA
EPA
DLA-WS
Resident
Resident
Resident
Resident
Resident
Resident
Resident
Resident
CoE
lil' A
EPA
RWQCB
DTSC
RWQCB
DISC
DDRW-WB
DDRW
DDRW
DDRW
EPA
D'HSC
Subject
Letter transmitting the final list of (lie 26 wells to be sampled and aiialy/cd.
Notification of tlic intent to commence with the collection of groundwutcr samples from 26 on-sitc monitoring
wells, water supply wells, and off- site private wells.
Notification ol the resampling of the five domestic wells initially samples on 30 December 1991.
RWQCB review comments for the Final Work Plan for Well Evaluation and Abandonment.
Letter addressing concerns ol the Tracy Well Monitoring Well Delivery Order.
Letter submitting a copy of Ecological Risk Assessment section of (he Draft Operable Unit 1 for information
purposes.
Letter transmitting the minutes from the telephone conference call that occurred on 23 March 1992.
Letter transmitting WCC's minutes for the Project Manager's Meeting held 20 March 1992.
Response to AMCEN letter dated 1 1 March 1992 regarding the acquisition of agricultural land adjacent (o
DDRW.
Letter requesting permission to collect a sample from (heir domestic water well.
Letter requesting permission to collect a sample from his agricultural/domestic water wells.
Letter requesting permission to collect a sample from his domestic water well.
Letter requesting permission to collect a sample from his domestic water well.
Letter requesting permission to collect a sample from his domestic water well.
Letter requesting permission to collect a sample from her domestic water well.
Letter requesting permission to collect a sample from his domestic water well.
Letter requesting permission to collect a sample from his domestic water well.
DDRW's review comments for the Site Wide RI/FS Work Plan.
Letter requesting a seven day extension for (he Draft Final Site Wide RI/FS Work Plan.
Letter requesting an extension for the Draft Abandoned Watei well Evaluation Report.
Letter requesting an extension for the Draft Abandoned Waterwell Evaluation Report.
Letter requesting an extension for the Draft Abandoned Waterwell Evaluation Report.
Letter requesting a seven day extension of the document delivery date for the Draft Final Site Wide RI/FS Work
Plan.
Letter requesting a seven day extension of the document delivery date for the Draft Final Site Wide RI/FS Work
Plan.
Letter providing concurrence with the Final Well Abandonment Work Plan.
Comprehensive Quality Assurance Plan
US Army Corps of Engineers, Contract DACAH7-9I-D-OOIO, Draft Site Investigation Report, Building 201,
Defense Distribution Region West
Draft Final Comprehensive RI/FS Work Plan, Defense Distribution Region West
Submission ol the Draft Site Investigation Report for regulatory review and comment.
Submission ol (lie Draft Site Investigation Report for regulatory review and comment.
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/1)5/04
92/05/05
92/05/05
92/05/05
92/05/0()
92/05/09
92/05/22
92/06/01
92/06/08
92/06/08
92/06/1)8
92/06/09
92/06/09
92/06/09
92/06/09
92/06/09
92/06/17
92/06/25
92/06/25
92/06/25
92/06/26
92/06/26
92/06/26
92/06/26
92/06/26
92/06/29
92/06/29
92/06/29
92/06/29
92/06/29
Author
DDRW-WB
DDRW-WB
DDRW-WD
DDRW-WB
KWQCB
DDRW-WU
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
Addressee
RWQCB
DTSC
RWQCB
EPA
DDRW-BI:
CoE
DDRW-WB
DDRW
RWQCB
EPA
DTSC
RWQCB
EPA
DTSC
CoE
CoE
CoE
DTSC
EPA
RWQCB
DTSC
RWQCB
EPA
CoE
CoE
CoE
RWQCB
DTSC
EPA
WCC
Subject
Submission of the Draft Site Investigation Report lor regulatory review and comment.
Letter transmitting the meeting minutes from the Project Manager's Meeting held 23-24 May 1992.
Letter transmitting the minutes from the Project Manager's Meeting held 23-24 May 1992.
Letter transmitting the minutes from the Project Manager's Meeting held 23-24 May 1992.
RWQCB comments on Ihc SOW lor (lie IRM and Well Monitoring Program.
DDRW review comments on the Draft Site Investigation 1 Report.
Quarterly Monitoring Report of the February 1992 Sampling Round for the Well Monitoring Program
Draft Operable Unit No. 1 FS Report, DDRW-Tracy, California, Vol II
DDRW's response to EPA comments on the Draft Final Site Wide RI/1:S Work Plan.
DDRW's response lo EPA comments on the Draft Final Site Wide RI/FS Work Plan.
DDRW's response lo EPA comments on the Draft Final Site Wide RI/FS Work Plan.
Letter requesting an extension for the Site Wide Remedial Investigation/Feasibility Study Work Plan.
Letter requesting an extension for the Site Wide Remedial Investigation/Feasibility Study Work Plan.
Letter requesting an extension lor the Site Wide Remedial Investigation/Feasibility Study Work Plan.
Letter requesting for review and comment of the Draft Operable Unit #1 Proposed Plan for DDRW Tracy.
Defense Distribution Region West - Tracy, Proposed Plan for Contaminated Groundwatcr, Tracy, California.
June 1992
Letter expressing displeasure with the Draft Operable Unit One (OU-I) Proposed Plan prepared by Woodward-
Clyde Consultants.
Letter agreeing with the regulatory agencies that the addendums to the Site Wide RI/FS Work Plan be made
primary documents.
Letter agreeing with NIC icgulalory agencies Ihul Ihc addendums lo NIC Site Wide UI/FS Work Plan be made
primary documents.
Letter agreeing with the regulatory agencies that the addendums to the Site Wide RI/FS Work Plan be made
primary documents.
Letter requesting that EPA rescind its insistence on PRGs at this lime.
Letter requesting that EPA rescind its insistence on PRGs at this time.
Letter requesting thai EPA rescind its insistence on PRGs at this time.
DDRW directing CoE to withhold any further driller or field work progress payments on this project.
Request lhal Solid Waste Management Unit (SWMU) #13 data be used in (he Draft Final Site Wide RI/F'S Work
Plan as agreed lo during the Project Managers meeting.
Minutes for the Project Manager's meeting of 15-16 June 1992.
Minutes for the Project Manager's meeting of 15- 16 June 1992.
Minnies for the Projccl Manager's meeting of 15-16 June 1992.
Minutes for the Project Manager's meeting of 15-16 June 1992.
Minnies fur Ihc Projccl Manager's meeting of 15-16 June 1992.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/06/30
92/07/01
92/07/07
92/07/07
92/07/07
92/07/07
92/07/07
92/07/31
92/07/3 1
92/07/3 1
92/07/3 1
92/08/06
92/08/24
92/08/24
92/08/27
92/08/27
92/1)8/27
92/08/28
92/08/3 1
92/08/31
92/08/3 1
92/09
92/09/02
92/09/04
92/09/04
Author
DDRW-WU
WCC
DDRW-WB
DDRW-WU
DDRW-WU
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WU
DDRW-WB
EPA
EPA
DDRW-WB
PHS, SJC
DDRW-WB
DDRW-WB
DDRW-WU
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WU
Woodward-Clyde
DT.SC
DDRW-WU
DDRW-WB
Addressee
EPA
DDRW
UCID
ISWMU
WSID
DFG
City of Tracy,
Public Works Dept.
EPA
RWQCB
DTSC
DDRW-BE
DDRW-BE
CoE
DDRW-WB
CoE
EPA
RPA
CoE
RWQCB
EPA
DTSC
Col7., lluiilsvillc
DDKW-HF:
RWQCU
DTSC
Subject
Lellcr transmitting the final report on the remediation effort at the Subsistence Warehouse construction site.
Final Analytical Data Submittal lor Well Evaluation and Abandonment at Defense Distribution Region West,
Tracy, California
Letter soliciting the identification of ARARS lor remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of grouiulwuler contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter notifying the regulatory agencies how they intend to dispose of purge water and drill cuttings.
Letter notifying (he regulatory agencies how (hey intend to dispose of purge water and drill cuttings.
Letter notifying the regulatory agencies how they intend to dispose of purge water and drill cuttings.
Letter confirming the dale of the dispute resolution meeting.
Notification of resolution of the dispute invoked by EPA regarding the Draft Final Comprehensive KI/FS Work
Plan.
DDRW comments on the Post Treatment/Disposal Report Soil Treatment/Disposal for Defense Distribution
Region West Tracy, California.
Letter regarding the investigation of off-site contamination of domestic wells.
DDRW review comments lor the Operable Unit One Feasibility Study.
Resolution of dispute for DDRW Tracy Draft Final Comprehensive RI/FS Work Plan.
Letter transmitting the Post Treatment/Disposal Report Soil Treatment/Disposal for Defense Distribution Region
West (DDRW) Tracy. California.
Replacement of ruptured gas line during the initial well excavation effort.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance at DDRW
Tracy.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance found at DDRW
Tracy.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance at DDRW
Tracy.
Final Comprehensive RI/FS Work Plan.
Letter notifying DDRW that DTSC.' considers Ilie dispute to he resolved and the Draft Final RI/FS Work Plan ID
be approved.
Letter submitting a location map and laboratory results of the substance found in the new water line trench
adjacent to the Subsistence Warehouse.
Letter submitting a local ion map and laboratory results of the substance found in llic new water line Irencli
adjacent lo the .Subsistence Warehouse.
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/09/04
92/09/08
92/09/10
92/09/10
92/09/10
92/09/10
92/09/11
92/09/18
92/09/18
92/09/18
92/09/22
92/10/01
92/10/01
92/10/01
92/10/01
92/10/02
92/10/02
92/10/02
92/10/09
92/10/09
92/10/09
92/10/09
92/10/09
92/10/09
92/10/15
92/10/16
92/10/26
92/10/28
92/10/28
Author
DDRW-WB
Senator Johnston
DDRW-WU
DDRW-WB
DDRW-WD
DDRW-WIJ
RWQCB
DDRW-WB
DDKW-WB
DDRW-WU
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDKW-IJE
DDRW-BE
DDRW-BE
DDRW-BE
DISC
DDKW-UE
RWQCB
DDRW-BE
DDRW-BE
DDRW-HE
Addressee
EPA
DDRW-D
Col-
RWQCB
DISC
l-ll 'A
DDRW-BE
EPA
DTSC
RWQCB
CoE
EPA
DTSC
RWQCB
DDRW
RWQCB
EPA
DTSC
CoE
DTSC
RWQCB
EPA
CoE
DDRW-BE
CoE
DDRW-BE
CoE
CoE
EPA
Subject
Letter submitting a locution map and laboratory results of (be substance found in the new water line trench
adjacent to the Subsistence Warehouse.
Letter urging DDRW (o survey wells within a mile radius including sampling of identified wells along Banta
Road, and schedule a community awareness forum.
Letter forwarding the minutes lor the Project Manager's Meeting held 22-23 July 1992.
Letter forwarding the minutes lor Ihc Project Manager's Meeting held 22-23 July 1992.
Letter forwarding (he minutes lor the Project Manager's Meeting held 22-23 July 1992.
Letter lorwaiding the minutes fur the Project Manager's Meeting held 22-23 July 1992.
RWQCB comments on (he Draft Engineering Report lor the Well Monitoring Program.
Letter requesting an extension of the delivery dale for the Site-Wide KI/FS.
1 -eller requesting an extension of the delivery dale for the Site-Wide KI/FS.
Letter requesting an extension of the delivery date for the Site-Wide Rl/FS.
DDRW comments on the Draft Final OU- 1 RI/RA.
Submission of the revised Federal Facilities Agreement schedule for review/approval.
Submission of the revised Federal Facilities Agreement schedule for review/approval.
Submission of the revised Federal Facilities Agreement schedule for review/approval.
Draft Final Operable Unit No. 1 FS Report, DDRW-Tracy, California
Letter transmitting the final minutes for the Project Managers meetings of 1 5- 1 6 June and 22-23 July 1 992.
Letter transmitting the final minutes for the Project Managers meetings of 15-16 June and 22-23 July 1992.
Letter transmitting the final minutes for the Project Managers meetings of 15-16 June and 22-23 July 1992.
DDRW comments on the Operable Unit #1 and Proposed Plan Draft Final.
Notification that DDRW is pivparnl lu begin spreading (In: remaining soil from Ihc Subsistence Waivliinisc on
the DDRW Tracy Facility.
Notification that DDRW is prepared to begin spreading (lie remaining soil from the Subsistence Warehouse on
the DDRW Tracy Facility.
Notification that DDRW is prepared to begin spreading the remaining soil from the Subsistence Warehouse on
the DDRW Tracy Facility.
Letter requesting that CoE exercise Option 5 (rcclassily the soil stockpile) of the Site Investigation Report.
DTSC's review of detection limits lor the Site Wide RI/FS Work Plan found no reportable anomalies other than
those previously identified.
DDRW comments for the Final Analytical Data Report for Well Abandonment.
Letter requesting that DDRW Tracy provide a time schedule and work plan for discontinuing well use and
conducting an alternative water supply evaluation.
Letter requesting (hat San Joaquin County Public Health Services be added to the document distribution list.
Letter requesting CoE add wells LM-1 12 and LM-1 13 (o Ihc well monitoring/RI/FS work effort.
Minutes for the Project Managers Meeting held 14 Oct 92.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
92/11/01
92/11/01
92/1 1/01
92/11/04
92/11/10
92/11/12
92/11/12
92/1 1/16
92/11/19
92/1 1/23
92/11/23
92/11/24
92/1 1/30
92/1 1/30
92/12/01
92/12/02
92/12/02
92/12/02
92/12/02
92/12/03
92/12/04
92/12/04
92/12/07
92/12/08
92/12/10
92/12/10
Author
IT Corp.
WCC
WCC
DDRW-BE
DDKW-Wi
PHS, SJC
RWQCU
UWQCIJ
EPA
EPA
RWQCB
DDRW-BE
DDRW-BE
DDRW-BE
DDRW
DTSC
DTSC
EPA
RWQCB
EPA
EPA
EPA
DDRW-BE
DDRW-BE
DDRW-BE
PSK, Corp.
Addressee
DDRW
DDRW
DDRW
EPA
EPA
DDRW-D
DDKW-HF.
TliPC
DDRW-BE
DDRW-BE
DTSC
EPA
RWQCB
EPA
DDRW-UE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
EPA
RWQCB
PHS
DDRW
Subject
I'osl Treatment/Disposal Rcporl Soil TrcalmcnI/Disposiil for Defense Distribution Region West, Tracy,
California
Final Operable Unit No. 1 1 Rl/RA Report, DDRW-Tracy
Final Well Evaluation and Abandonment Engineering Report, Defense Distribution Region West, Tracy,
California
Submission ol'lhe revised FFA deadlines lor the DDRW Tracy Facility IRP documents.
Letter requesting a 30 day delivery dale extension to (he linali/.ution period of the Draft Final F'S and Proposed
Plan for OU-I.
Public Health Services comments to DDRW Tracy's letter dalcd 14 September 1992.
UW(JCI) comments on Ilie Draft Finn) I'casihility Study Report and Proposed Plan for Operable Unit No. 1.
Letter requesting premise access lo monitoring wells to measuie gioundwalcr levels and to collect and analy/.c
water quality samples.
EPA comments on the proposed revisions to the FFA schedule.
EPA comments on minutes of meeting of October 14-15, 1992.
RWQCB comments on DTSC's 22 Oct 92 review of the Draft Final Well Evaluation and Abandonment
Engineering Report for DDRW Tracy.
DDRW requesting a position statement from EPA regarding the inclusion of PHS/EHD in the CERCLA process.
Letter submitting a time line lor the accomplishment of the abandonment of the off-site agricultural wells.
DDRW Tracy requesting an additional 10-day delivery date extension to the finalizalion period of the Draft
Final Proposed Plan and Feasibility Study for OU-1.
Proposed Plan for Contaminated Groundwater Remediation of Operable Unit No. 1 at Defense Distribution
Region West-Tracy
DTSC approving DDRW's request lor an extension ol the delivery date lor the OU-I Draft Final F'S and
Proposed Plan.
DTSC approving the proposed changes in the FFA schedule.
EPA comments on the Comprehensive RI/FS Risk Assessment Statement of Work.
Letter submitting the well sample results for turbidity at DDRW Tracy.
EPA comments on the ARARs Tables lor the Draft Final FS lor OU-I
EPA's position on the request of the San Joaquin County Public Health Service/ Environmental Health Division
lo be included in the CERCLA process al DDRW-Tracy.
F.PA concurring with DDRW Tracy's request for an extension for revision/review of the Draft Final Feasibility
Study for Operable Unit No. 1 .
DDRW requesting review of the revised FFA schedule for DDRW Tracy.
Letter submitting the daily starlup/proveout reports for the Tracy IRM for the period of November 5-14, 1992.
DDRW's response lo a letter from Public Health Services dated November 12. 1992.
Transcript for DDRW Tracy Facility Community Meeting lo Rslablisli Ilic Technical Review Commillce (TRC)
-------
Administrative Record File Index • DDJC Tracy (Continued)
Date
92/12/14
92/12/16
92/12/17
92/12/24
93/01/01
93/01/04
93/01/11
93/01/11
93/01/11
93/01/1 1
93/01/12
93/01/12
93/01/14
93/01/17
93/01/19
93/01/25
93/01/27
93/01/28
93/01/28
93/01/30
93/02/01
93/02/02
93/02/02
93/02/02
93/02/04
93/02/04
Author
DDRW-BE
RWQCB
DDRW-BE
EPA
JMM
JMM
DDRW-BE
DDRW-UF.
DDRW-UE
DDRW-BE
DDRW-BE
DTSC
PSR, Corp.
RWQCB
EPA
DDRW-BE
EPA
DDRW-BE
SJFBF
WCC
JMM
DDRW-BE
DDRW-Bli
RWQCB
DDRW-BE
JMM
Addressee
CoE
DDRW-BE
EPA
DDRW-BE
DDRW
EPA
WCC
L-PA
RWQCB
EPA
EPA
DDRW-BE
DDRW
DDRW-BE
DDRW-BE
SJVUAPCD
DDRW-BE
CoE
DDRW-BE
DDRW
DDRW
SJFBF
EPA
DDRW-BE
EPA
DDRW
Subject
Letter submitting (he lest results from the RWQCB tor the well monitoring program they are conducting at
DDRW Tracy.
Letter submitting an inspection report anil a memorandum on stockpiled soils from the Subsistence Warehouse.
Letter transmitting the final minutes for the Project Managers meeting held 14-15 October 1992.
Letter recommending an extension to the fmali/.ation process of the FFA schedule from 30 to 45 days.
final Uroundwalcr Pilot Plant Chemical Data Acquisition Plan
Minutes from the telephone conference (17 December 1992) on evaluation of detection limits for the
Comprehensive Phase I Remedial Investigation.
DDRW Tracy furnishing WCC with a copy of the Proposed Plan Fact Sheet for the DDRW Tracy Operable Unit
#1 Feasibility Study/Proposed Plan.
DDUW providing EPA with a list oldie wells and sampling methods to be used lor lite upcoming sampling
round.
DDRW requesting a variance to the Monitoring and Reporting Section of the Waste Discharge Requirement.
DDRW resubmitting a revised Federal Facilities Agreement Schedule for review and comment.
DDRW providing the regulatory agencies with a copy of (he transcript for the public meeting held on 19
December 1992.
DTSC confirming the agreements reached during a tele-conference held November 19, 1992.
Transcript for DDRW Tracy Facility Community Meeting for the Operable Unit No. 1 Feasibility
Study/Proposed Plan
Letter requesting DDRW complete a Report of Waste Discharge for the disposal of the treated groundwater from
OU-I by 15 Mar 93.
Letter concurring with the revised Federal Facility Agreement schedule.
Letter requesting approval of its Application lor Permit to Construct for the Tracy Facility air stripper.
EPA comments on the Risk Assessment and ihe Comprehensive RI/FS Work Plan.
Letter requesting CoE expedite the removal of the Subsistence Warehouse soil pile from the DDRW Tracy
Facility.
Letter addressing the Proposed Plan for Contaminated Groundwater Remediation of Operable Unit No. 1 at
Defense Distribution Region West - Tracy.
Final Engineering Report for the Well Monitoring Program at Defense Distribution Region West - Tracy, Tracy,
California
Final Well Monitoring Program Quarterly Monitoring Report - September 1992 .Sampling Round
DDRW's response to the San Joaquin Farm Bureau Federation's letter dated January 28, 1993.
Minutes for the Project Managers' meeting held January 13-14, 1993.
Notification that James Taylor will replace Camilla Williams as Project Manager for Ihe DDRW Tracy project.
Minutes lor (he Project Managers' meeting held December 10, 1992.
(iiiuindwaler Treatment Pilot Plant Monthly Operations Reports
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Administrative Record File Index - DDJC Tracy (Continued)
Date
93/02/OK
9.5/02/11
93/02/22
9.5/02/2:5
9.5/03/03
93/03/08
93/03/12
93/03/17
93/03/26
93/03/29
93/03/29
93/03/29
93/04/01
93/04/08
93/04/08
93/04/09
93/04/09
93/04/12
93/04/12
93/04/12
93/04/12
93/04/13
93/04/14
93/04/15
93/04/19
93/04/26
93/04/26
93/04/29
Author
DDRW-BE
SWRCB
DDRW-BE
DDRW-BE
DDRW-BE
EPA
RWQCB
lil'A
RWQCB
DDRW-BE
RWQCB
RWQCB
MW
DDRW-BE
DDRW-BE
DTSC
DTSC
DDRW-BE
EPA
RWQCB
TRC Member
DDRW-BE
Enscco
TRC Member
DDRW-BE
DDRW-BE
RWQCB
DDRW-BE
Addressee
CoE
DDRW-D
EPA
CoE
CoE
DDRW-BE
DDRW-BE
DDKW-BE
DDRW-BE
CoE
DDRW-BE
DDRW-BE
DDRW
TRC Members
CoE
DDRW-BE
DDRW-BE
CoE
DDRW-BE
DDRW-BE
DDRW-BE
MW
DDRW
DDRW-B
EPA
TRC Member
DDKW-BE
Col-
Subject
DDRW requesting CoE direct Woodward-Clyde Consultants review the ARARs lor DDRW Tracy Operable
Unit No. 1, lor specificity.
Notilicaiion thai the DDRW Tracy Facility Operable Unit No. 1 Feasibility Study/ Proposed Plan is acceptable.
Letter transmitting final minutes for the Project Managers' meetings held on December 10, 1992 and January 13-
14, 1993.
Letter requesting thai CoE contact JMM and ensure that specific changes be made to the well monitoring
numbering system.
DDRW requesting CoE direct MW to institute a numbering sequence for all air stripper extraction wells.
EPA providing DDRW with an updated copy of the Draft Preliminary Remediation Coals Table.
Letter addiessing disposal of stockpiled soil excavated from the foundation of the Subsistence Warehouse.
Letter transmitting contour maps based on MW's September 1992 quarterly monitoring round at DDRW Tracy.
RWQCB comments on the list of wells and sampling methods to be used in the Spring 1993 quarterly
groundwater monitoring round.
Letter transmitting a copy of the waste discharge requirements for H.J. Heinz for informational purposes.
RWQCB clarifying their position on the proposed rehabilitation program for the IRM system at DDRW Tracy.
Letter requesting DDRW complete a Report of Waste Discharge lor the disposal of the treated groundwatcr from
OU-I in order to receive Waste Discharge Requirements.
Final Groundwatcr Treatment Pilot Plan System Start-up and Prove-out Report
Letter transmitting minutes from the Technical Review Committee (TRC) meeting held 23 March 1993.
Letter transmitting a soil survey ot San Joaquin County for use in the Comprehensive Site Wide RI/FS.
DTSC recommending that the Final Engineering Report for the Well Monitoring Program be discussed at the
April Project Managers' meeting.
Notification ol approval of Operable Unit No. 1 Feasibility Study.
DDRW requesting CoE prepare sections 2. 1 .6 and 2. 1 .1 for the Report of Waste Discharge.
EPA's comments on the Draft Work Plan Amendments lor Phase 1 of the Comprehensive RI/FS.
RWQCB comments on the Draft Comprehensive RI/FS Work Plan Amendments and evaluation of detection
limits for the Comprehensive Phase 1 Remedial Investigation.
Letter submitting comments on the TRC minutes.
DDRW providing MW with copies of DDRW Tracy Facility's Project Managers' meeting minutes for the period
October 10, 1991 through January 14, 1993.
Analytical Services Quality Assurance Project Plan for the Comprehensive RI/FS
Letter responding to the minutes of the TRC meeting for DDRW Tracy.
Letter transmitting minutes for the Project Managers' meeting held on 23 March 1993.
DDRW responding to comments made on the TRC meeting minutes of 15 April 1993.
RWQCB addiessing concerns they have with the Site Wide Remedial Investigation Work Plan.
DDUW requesting that CoE hydrogcologists review RWQCH well survey (csl results.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
93/05/01
93/05/01
9.1/05/12
93/05/14
93/05/14
93/05/15
93/05/18
93/05/18
93/05/26
93/05/27
93/06/01
93/06/01
93/06/01
93/06/02
93/06/03
93/06/04
93/06/07
93/06/08
93/06/08
93/06/10
93/06/1 1
93/06/1 1
93/06/15
93/06/16
93/06/21
93/06/24
Author
MW
MW
CoE
DDRW-BE
DDRW-BE
DDKW
DDKW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DISC
MW
MW
Col:
DDRW-BE
RWQCB
DDRW-BE
DDRW-BE
DDRW-BF.
DTSC
DDRW-BE
RWQCB
DDKW-BE
DDKW-BE
EPA
DDKW-BE
Addressee
DDRW
DDRW
DDRW
CoE
RWQCB
RWQCB
CAAE
CAAE
EPA
DDRW-BE
DDRW
DDRW
DDRW-BE
DTSC
DDRW-BE
CAAE
EPA
EPA
DDRW-1JI;
Col;
DDRW-III;
CoE
CoE
DDRW-BE
Col;
Subject
Defense Distribution Region West, Tracy, California, Draft Groundwatcr Treatment Pilot Plant Three Month
Evaluation Report
Defense Distribution Region West, Tracy, California, Final Well Monitoring Program. Quarterly Monitoring
Report, January 1993 Sampling Round
Defense Distribution Region West, Tracy Facility, Operable Unit No. 1, Groundwatcr Treatment Remedial
Design, Statement of Work
DDRW providing CoE a copy of the DDRW Environmental Program Review performed by the U.S.
Environmental Hygiene Agency.
DDRW submitting the Tracy Facility's Report of Waste Discharge.
Report of Waste Discharge for Defense Distribution Region West, Tracy Facility. Tracy, CA
DDRW notifying RWQCB thai water was pumped from its storm water pond to the West Side Irrigation
District's distribution system.
DDRW responding to a letter from Congressman Richard Pombo.
DDRW forwarding a copy of the Tracy Facility's Report of Waste Discharge.
Request for a decision on the CERCLA 15-Month Rule.
DTSC recommending that DDRW explore long-term remedial alternatives for residents impacted by
groundwalcr contamination.
Defense Distribution Region West, Tracy, California, Final Amendments to the Comprehensive Remedial
Investigation/Feasibility
Defense Distribution Region West, Tracy, California, Draft Groundwater Treatment Pilot Plant Injection Well
Rehabilitation and Chemical Testing Work Plan
Response to DDKW-Tracy Idler of 29 April 1993, Regional Water Quality Control Board Well Survey Test
Results
Alternative water supply for the Rose and Rnspo properties.
RWQCB comments on the Draft Record of Decision for Operable Unit No. 1 . <,
DDRW responding to an inquiry from Congressman Richard Pombo.
Final minutes for the Project Managers' meeting held 23 March 1993.
Letter transmitting draft minutes for the Project Manager's Meeting held 27 - 28 Apr 93.
IX ISC comments on ihc Draft Record of Decision for Operable Unit No. 1.
DDRW comments on the Operable Unit No. 1 Groundwalcr Treatment Remedial Design scope of work.
RWQCII (.•oiuinenlN on (lie Statement ol Woik lor Grotindwaier Treatment Remedial Design.
DDRW requesting Col; obtain repair costs from MW lor level monitoring wells 48 and 57.
DDRW requesting WCC provide a legal review/approval of the ARARs section for the Draft Final ROD.
Minutes of Ihc conference call between EPA and RWQCB held on June 18, 1993.
Response to lil'A Draft Oll-l ROD comments.
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
93/06/29
93/06/30
93/06/30
93/06/30
93/07/02
93/07/02
93/07/07
93/07/15
93/07/15
93/07/15
93/07/22
93/07/22
93/07/28
93/08/01
93/08/01
93/08/01
93/08/03
93/08/04
93/08/04
93/08/11
93/08/1 1
93/08/12
93/08/17
93/08/20
93/08/26
93/08/26
'.) 3/08/30
93/09/01
93/09/01
93/09/03
93/09/13
93/09/19
Author
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
MW
RWQCB
MW
DDRW-BE
DDKW-BE
DDRW-BE
MW
MW
EPA
MW
MW
WCC
MW
MW
MW
RWQCB
RWQCB
DTSC
CPA
RWQCB
DDRW
EPA
DDKW-llli
DDRW-BE
DDRW-BE
DDRW-BE
MW
MW
Addressee
CoE
CoE
EPA
TRC Member
DDRW
EPA
CoE
EPA
RWQCB
CoE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW
DDRW
DDRW
CoE
DDRW-Bli
CoE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
EPA
DDRW-Bli
EPA
CoE
EPA
EPA
Coll
DDRW-BI-
Subject
Dral't Groundwatcr Treatment Pilot Plant Injection Well Rehabilitation anil Chemical Testing Work Plan
comments.
DDRW requesting establishment ol background levels lor metals and pesticides at DDRW.
Submission of minutes for a conference call held on 30 March 1993.
DDRW response to TRC comments.
Groundwatcr Treatment Pilot Plant Monthly Operations Reports No. 2
RWQCB comments on EPA's letter dated 21 June 1993.
Draft Groundwater Modeling Workplan for Defense Distribution Region West. Tracy, California
Minutes for the Project Managers' meeting held on 25 May 1993.
Letter transmitting the DDRW Tracy Facility Supply Well #4 Abandonment Work Plan.
Letter requesting the reparation of well LM-57.
Minutes for the Project Managers' meeting held on 7 July 1993.
Minutes for the Project Managers' meeting held on 8 July 1993.
EPA comments on the Draft Final ROD for OU #1 .
Final Groundwater Treatment Pilot Plant Three Month Evaluation Report No. 2
Defense Distribution Region West, Final Well Monitoring Program, Quarterly Monitoring Report, April
Sampling Round.
Final Operable Unit No. 1 , Record of Decision, DDRW-Tracy, California
Written notification concerning the DDRW-Tracy Pilot Plant system shutdowns occurring on July 19 and
29, 1993.
Letter transmitting video tapes and log sheets from the industrial waste pipeline investigation.
Written notification of the Tracy Pilot 1'lanl syslem shutdown occurring on 3 August 1993.
Letter approving the Draft Final OU- 1 ROD.
RWQCB approving the Draft Final Record of Decision.
DTSC comments on the Work Plan for Well 4 Abandonment.
EPA responding to DDRW's letter of May 27, 1993.
RWQCB's response to information received from EPA regarding the Draft ROD for OU-I.
Work Plan for Well 4 Abandonment at Defense Distribution Region West, Tracy, California
review
1993
July
Letter documenting a telephone conversation with CoE regarding potential modification to the final amendments
to the Comprehensive KI/FS Work Plan.
Letter Iransmilling minutes lor the Pmjecl Managers' meeting held on 7 July 1993.
Submission of the amendment to the Well /I4 Abandonment Work Plan.
Letter submitting a copy of the OU- 1 signature pages for the DDRW Tracy ROD.
Letter transmitting the OU- 1 Design Schedule.
Written notification of the DDRW Tracy Pilot Plant shutdown occurring on 8 September 1993.
Final Phase 1 Site-Wide Ecological Assessment Work Plan for the Naval Air Station Molietl Field.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
93/09/20
93/09/22
93/09/27
93/09/30
93/10/01
93/10/01
93/10/05
93/10/05
93/10/06
93/10/07
93/10/12
93/10/15
93/10/21
93/10/22
93/10/25
93/10/27
93/10/27
93/10/27
93/11/01
93/11/01
93/11/17
93/11/30
93/12/01
93/12/01
93/12/01
93/12/10
Author
EPA
RWQCB
EPA
DDRW-BE
DDRW-BE
MW
MW
MW
DDRW-BE
CoE
EPA
RWQCB
MW
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
MW
MW
MW
EPA
EPA
MW
MW
DDRW-ABE
Addressee
DDRW-BE
DDRW-BE
DDRW-BE
CoE
EPA
DDRW
CoE
CoE
CoE
USEHA, HSHB-
ME-SR
DDRW-BE
DDRW-BE
CoE
EPA
RWQCB
DTSC
EPA
RWQCB
DDRW
DDRW
CoE
DDRW-ABE
DDRW-ABE
DDRW
DDRW
CoE
Subject
EPA comments on the Draft Remedial Design/Remedial Action Schedule for Operable Unit No. 1.
RWQCB comments on the Draft Groundwaler Modeling Work Plan.
EPA comments on the Final Well Monitoring Program Quarterly Monitoring Report. April 1993 Sampling
Round (August 1993).
DDRW requesting CoE investigate (he possibility and potential cost savings of using dedicated sampling devices
al DDRW Tracy monitoring wells.
DDRW Operable Unit #1 revised Design Schedule.
Final Groundwater Modeling Interim Technical Memorandum, Defense Distribution Region West, Tracy,
California
Notification that the DDRW Tracy Pilot Plant was shutdown due to a brief power failure.
MW response lo USAGE review comments on (he July monthly report.
DDRW providing maps ol the water and wastewater systems at the DDRW Tracy Facility.
CoE requesting thai HSHB-ME-SR review the DDRW Tracy Risk Assessment work.
EPA comments on the revised RD/RA Schedule for DDRW Tracy OU- 1 .
RWQCB comments on the Groundwaler Treatment Pilot Plan System Start-up, Prove- out anil Evaluation
Reports.
Notification that the DDRW Tracy Pilot Plant system was shutdown. The shutdown was caused by a high level
alarm al the pad drainage sump.
DDRW Operable Unit #1 revised Design Schedule.
Waste Discharge Requirements (WDRs) revision for Defense Distribution Region West, Tracy Facility
Federal Facility Agreement personnel change notification.
Federal Facility Agreement personnel change notification.
Federal Facility Agreement personnel change notification.
Defense Distribution Region West, Tracy, California. Well Monitoring Program, Well Redevelopment Report
Draft Pre-Design Technical Summary and Remedial Design Work Plan
Response lo review comments on September Monthly Report.
EPA notifying DDRW of receipt of the Draft Risk Assessment SOW for the Site Wide Comprehensive Work
Plan.
Notification of a change in EPA's RI/FS oversight support contractor.
Defense Distribution Region West, Tracy, California, Draft Groundwater Treatment Pilot Plant Operation and
Maintenance Manual
Final Well Monitoring Program, Quarterly Monitoring Report, July 1993 Sampling Round
DDRW review comments on the Draft Risk Assessment Statement of Work for the Site Wide Comprehensive
Work Plan.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
93/12/10
93/12/13
93/12/13
93/12/13
93/12/13
93/12/14
93/12/16
93/12/20
93/12/22
93/12/23
93/12/28
93/12/30
93/12/31
94/01/01
94/01/03
94/01/06
94/01/12
94/UI/I4
94/01/19
94/02/01
94/02/08
94/02/10
94/02/11
94/02/1 1
94/02/14
94/02/16
94/02/23
94/03/09
94/03/10
Author
DDKW-ABE
DDRW-ABE
DDRW-ABE
EPA
MW
EPA
RWQCB
DDRW-ABE
EPA
DDRW-ABE
DISC
DDRW-ABE
DISC
MW
DDRW-ABE
DDRW-ABE
EPA
DDRW-ABE
DDRW-ABE
MW
DDRW-ABE
EPA
CoE
DTSC
EPA
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
Addressee
EPA
CoE
Resident
DDRW-AIIE
CoE
DDRW-ABE
DDRW-ABE
City of Tracy
DDRW-ABE
DTSC
DDRW-ABE
EPA
DDRW-ABE
DDRW
CoE
CoE
DDRW-ABE
CoE
El'A
DDRW
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DTSC
CoE
DDRW-ABI:
CoE
Subject
Comments on EPA's comments of the l:inal Well Monitoring Program Quarterly Monitoring Report, April
Sampling Round.
Review comments for the Final Groundwater Modeling Interim Technical Memorandum.
DDRW providing sampling results for the January and April 1993 sampling rounds.
Letter transmitting EPA preliminary risk calculations with regard (o human health aliecls associated with
groundwalcr data collected.
Response lo review comments on the August Monthly Report and Startup and Prove-out Report.
EPA comments on the Groundwalcr Modeling Interim Technical Memorandum.
RWQCB responding to DDRW letter dated October 25. 1993.
Placement of information repository for DDRW.
EPA comments on the Well Monitoring Program, Well Development Report.
DDRW providing DTSC information regarding the use of Eureka Laboratory.
Letter concurring with DDRW's Risk Assessment Statement of Work.
Notification of soil contamination at Building 201 (DDRW Tracy Facility).
DTSC and RWQCB comments on the Well Redevelopment Report and Groundwater Modeling Technical
Memorandum.
Final Groundwater Treatment Pilot Plan Three Month Evaluation Report No. 3
Building 201 expansion foundation fill material.
DDRW requesting monitoring well/air stripper repairs.
EPA's comments on (he Draft Predesign Technical Summary and Draft Remedial Design/ Remedial Action
Work Plan for OU-I.
DDRW comments on the RI/FS Site Charnclcri/.alion Report.
Minutes for (he Project Managers' Meeting held December 7-8, 1993.
1993
Defense Distribution Region West, Tracy, California, Groundwater Treatment Pilot Plant Monthly Operations
Reports No. 3
DDRW comments on the Groundwatcr Treatment Pilot Plant Monthly Operations Report No. 3.
EPA comments on the Draft SOW lor Well Evaluation and Abandonment and Draft SOW for Comprehensive
RI/FS Work Plan Amendment.
Notification of access agreements from landowners whose properly adjoins DDRW Tracy.
DTSC requesting an extension for comments on the Comprehensive Site Wide RI/FS, Phase 1, Analytical Data
Report.
EPA comments on the Draft Comprehensive RI/I;S, Phase 1, Site Characleri/.ation Report.
DDRW response to DTSC letter dated 1 1 February 1994.
DDRW addressing EPA's comments on the Comprehensive Site Wide RI/FS, Site Characleri/,alion Report.
Col: providing information on off-site monitoring well casements.
Air stripper maintenance problems experienced at the DDRW Tracy Facility.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
94/03/10
94/03/1 1
94/03/15
94/03/23
94/03/30
94/04/01
94/04/01
94/04/01
94/04/05
94/04/07
94/04/08
94/04/1 1
94/04/1 1
94/04/13
94/04/13
94/04/13
94/04/14
94/04/14
94/04/14
94/04/18
94/04/18
94/04/19
94/04/20
94/04/22
94/04/27
94/04/2')
94/05/01
94/05/01
94/05/02
94/05/06
94/05/09
Author
MW
DDRW-ABE
DTSC
EPA
RWQCB
MW
MW
MW
DDRW-ABE
MW
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
EPA
CoE
MW
DTSC
DDRW-ABE
DDRW-ABE
DTSC
MW
MW
MW
TRC Member
EPA
DDRW-AUE
Addressee
RWQCB
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW
DDRW
CoE Huntsvillc
EPA
Resident
TRC Members
CoE
DDRW-ABE
Resident
Resident
CoE
PHS
DDRW-ABE
DDRW
CoE
DDRW-ABE
RWQCB
EPA
DDRW-ABE
Coi;
DDRW
CoE, Huntsvillc
DDRW-AB
DDRW-ABE
EPA
Subject
MW proposal to streamline the reporting process of the Quarterly Monitoring Reports under the Wei
Monitoring Program.
DDRW review comments on the air stripper monthly operations report.
Comments on the Draft Comprehensive RI/FS - Phase 1 - Site Characterization Report/Analytical Data Report,
Defense Distribution Region West, Tracy Site.
EPA's response to streamlining the quarterly monitoring report format.
RWQCB comments on the Groundwatcr Treatment Pilot Plant Three Month Evaluation Report No. 3
Defense Distribution Region West, Tracy, California, Characterization of Investigation-Derived Waste,
Remedial Investigation, Phase 1
Draft Remedial Measure Expansion Design Analysis, DDRW, Tracy.
Draft DDRW - Tracy Facility Operable Unit 1 Remedial Action Plan
Minutes for the Project Managers' Meeting held on 15 and 16 February 1994.
Minutes from the Prcmobilialion meeting for OU-1 CPT investigation held on 7 April 1994.
Private well sample results.
Minutes for the Technical Review Committee meeting held on 15 February 1994.
DDRW comments on the Groundwater Treatment Pilot Plant Monthly Operations Report for March 1994.
Revised Federal Facility Agreement proposed schedule.
Private well sample results.
Private well sample results.
DDRW comments on the Draft Well Abandonment Work Plan.
DDRW submitting a mnp and legend depicting all the solid waste management units and undergrouiH
tanks at the DDRW Tracy Facility.
EPA comments on (he Draft Well Abandonment Work Plan.
Defense Distribution Region West, Tracy, California, Subsistence Warehouse Stockpiled Soil. Rapid
Final Report
Minutes from the Baseline Risk Assessment Work Plan Meeting held on 31 March 1994.
DTSC comments on (he Draft Well Abandonment Work Plan.
Request for extension of Waste Discharge Requirements operating permit.
Letter submitting the revised Federal Facility Agreement schedule.
DTSC comments regarding the Draft Well Abandonment Work Plan for DDRW Tracy.
DDRW Tracy Nile Wide Itackgiouml Assessment Technical Memorandum.
Final Well Monitoring Program, Quarterly Monitoring Report, January 1994 Sampling Round
Community Relations Plan, DDRW-Tracy
Comments on the TRC meeting of 15 February 1994.
EPA requesting a written statement which explains the "good cause" for (he revised FFA schedules.
DDRW's FFA schedule rationale as requested by EPA
storage
Response.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
94/05/1 1
94/05/12
94/05/12
94/05/12
94/05/13
94/05/18
94/05/19
94/05/20
94/05/23
94/05/24
94/05/24
94/05/25
94/05/26
94/05/26
94/06/01
94/06/01
94/06/01
94/06/01
94/06/06
94/06/06
94/06/06
94/06/10
94/06/13
94/06/15
94/06/20
Author
DDRW-ABE
Dames & Moore
Dailies & Moore
MW
DDRW-ABE
DDRW-ABE
EPA
DISC
EPA
DDRW-ABE
DDRW-ABE
EPA
DDRW-ABE
DTSC
MW
MW
MW
MW
DDRW-ABE
EPA
MW
DTSC
DTSC
DDRW-ABE
DDRW-ABE
Addressee
CoE
DDRW
DDRW
EPA
TRC Members
TRC Member
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
CoE
DDRW-ABE
CoE
DDRW-ABE
DDRW
DDRW
DDRW
DDRW
CoE
DDRW-ABE
Coli
DDRW-AHI-
DDRW-ABE
CoE
CoE
Subject
DDRW comments on Ihe IRM design.
Draft Chemical Data Acquisition Plan, Well Abandonment
Site Safety and Health Plan for Well Abandonment
MW requesting an informal review ol the format for the extended data packages being provided by their
subcontract laboratory.
Final minutes for the TRC meeting held on 15 February 1994.
DDRW's responding to letter dated 2 May 1994.
Approval of extensions to DDRW Tracy FFA Schedules for the Comprehensive RI/FS/PP and ROD and OU-I
RD/RA.
DTSC's and RWQCU's concurrence of the Characicri zaliun of Investigation Derived Waste, Remedial
Investigation, Phase 1 report.
EPA comments on Ihe characterization of Investigative derived waste report.
DDRW comments on Groundwater Treatment Pilot Plant Three- Month Evaluation Report No. 4.
DDRW Tracy's comments on Draft Chemical Duta Acquisition and Health and Safety Plans for Supply Well #4
Abandonment.
EPA requesting additional information and n written response their letter dated 23 May 1994.
Clarification of DDRW Tracy's position regarding monitoring well sample turbidity.
DTSC approving revisions to the FFA schedule.
Draft IRM Expansion - Installation of Injection/ Extraction Wells and Chimney Drains Work Plan
Defense Distribution Region West, Tracy, CA, Draft Interim Groundwater Treatment Plant Expansion
Defense Distribution Region West, Tracy, CA, Draft Interim Ground water Treatment Plan Expansion. Volume II
- Drawings
Defense Distribution Region West, Tracy, CA, Characlcri/.alion of Investigation-Derived Waste. Remedial
Investigation, Phase 1
DDRW requesting CoE contact Montgomery Watson regarding software requirements for Ihe DDRW Tracy
IRM.
EPA comments on the Draft Well Monitoring Program, Annual Monitoring Report, October 1993 Sampling
Round.
Response to EPA Comments on Draft Investigative Derived Waste Report.
Comments on Ihe Draft Chemical acquisition Plan and Site Safety and Health Plan for the Abandonment of Well
No. 4 rcjwiil.
DTSC comments on the Draft Chemical Data Acquisition Plan, Well Abandonment, and Draft Site Safely and
Health Plan, Well Abandonment.
DDRW comments on Ihe Draft Well Monitoring Program, Annual Monitoring Report.
DDRW comments on the Final Well Monitoring Program, Quarterly Well Monitoring Report, January 1994
Sampling Round.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
94/06/2 1
94/06/22
94/06/22
94/06/23
94/06/23
94/06/27
94/06/27
94/06/28
94/06/28
94/06/29
94/06/30
94/06/30
94/07/01
94/07/06
94/07/13
94/07/14
94/07/25
94/07/27
94/08/01
94/08/01
94/08/01
94/08/01
94/08/10
94/08/11
94/08/1 1
94/08/11
94/08/11
94/08/12
94/08/12
94/08/12
94/08/12
Author
DDRW-ABE
DTSC
RWQCB
DDRW-ABE
EPA
DDRW-ABE
DTSC
DDRW-AUE
EPA
EPA
DDRW-ABE
EPA
MW
DDRW-ABE
DTSC
CoE
MW
DTSC
CoE
MW
MW
MW
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DTSC
EPA
Addressee
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
CoE
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW
DDRW
DDRW
CoE Hunlsvillc
Resident
Resident
Resident
Resident
Resident
Resident
Resident
DDRW-ABE
DDRW-ABE
Subject
Well 4 abandonment requirements.
Request for extension for comments concerning the Draft Well Monitoring Program. Annual Monitoring Report.
Notification of change of Project Manager for RWQCB.
DDRW comments on the Draft Interim Remedial Measure Expansion - Installation of Injection/Extraction Wells
and Chimney Drains Work Plan.
EPA comments on the example extended data package.
DDRW comments on the Draft Final Well Abandonment Work Plan.
DTSC comments on the Draft Final Well Abandonment Work Plan.
DDRW comments on the Comprehensive Site-Wide Baseline Risk Assessment Work Plan.
Relocation of (he information repository/administrative record for DDRW Sharpc and Tracy Facilities.
Commends on the Draft Chemical Data Acquisition Plan - Well Abandonment, May 94
DDRW comments on the Draft Final Site Characterization Report.
EPA comments on the Draft Final Well Abandonment Work Plan.
Final Groundwatcr Treatment Pilot Plan Three-Month Evaluation Report No. 4
DDRW review comments on (he Site Wide RI/FS Analytical Data Report.
Review comments on Draft Final Comprehensive RI/FS Phase 1 Site Characterization Report and Analytical
Data Report.
Use of Missouri River Division Laboratory for DDRW Tracy Facility investigations.
Minutes for the meeting at EPA on 19 July 1994.
Review comments on the Draft Well Monitoring Program.
Scope of Work for IRM Expansion
Defense Distribution Region West, Tracy, California, Ground water Treatment Pilot Plant Monthly Operations
Reports No. 4.
Defense Distribution Region West, Tracy, CA, Final Well Monitoring Program.
DDRW Tracy, California, Draft Groundwater Treatment Pilot Plant Three-Month Evaluation Report No. 6
Private well results for the January 1994 sampling round.
Private well results for the January 1994 sampling round.
Private well results for the January 1994 sampling round.
Private well results for the January 1994 sampling round.
Private well results for the January 1994 sampling round.
Private well results for the January 1994 sampling round.
Private well results for (he January 1994 sampling round.
Extension for submittal of comments concerning the Draft Comprehensive Site Wide Baseline Risk Assessment
Work Plan.
Comments on the Draft Comprehensive RI/F'S, Phase II Work Plan and Draft Comprehensive Risk Assessment
Work Plan.
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Administrative Record File Index - DDJC Tracy (Continued)
Date
94/08/15
94/OH/24
94/08/3 1
94/09/01
94/09/01
94/09/01
94/09/01
94/09/08
94/09/19
94/09/2 1
94/10/01
94/10/01
94/10/01
94/10/24
94/10/25
94/11/01
94/11/01
94/11/01
94/11/01
94/11/01
94/1 1/04
94/1 I/I 1
94/11/28
94/12/01
94/12/01
94/12/01
94/12/01
Author
DTSC
DDRW-ABE
DDRW-ABE
Col:
MW
MW
MW
DDRW-ABE
EPA
lil'A
MW
MW
MW
DDRW-ABE
EPA
MW
MW
MW
MW
MW
MW
DTSC
DDRW-ABE
CoE
CoE
CoE
DDRW-ABE
Addressee
DDRW-ABE
CoE
EPA
DDRW-ABE
DDKW
DDRW
CoE I luntsvillc
EPA
DDRW-ABE
DDRW-ABE
DDRW
DDRW
DDRW
EPA
DDRW-ABE
DDRW
DDRW
CoE Huntsvillc
CoE Hunlsvillc
DDRW-Tracy
CoE
DDRW-ABE
RWQCB
DDRW
DDRW
DDRW
lil'A
Subject
Review comments on Draft Comprehensive RI/FS, Phase II Woik Plan.
Coiiiinents on the Draft Comprehensive R1/I7S Work Plan.
Minutes from the Project Managers' Meeting held on 7-8 June 1994.
Revised FFA schedule for Operable Unit 1.
Defense Distribution Region West, Tracy, California, l-'inal Well Abandonment Work Plan
Defense Distribution Region West, Tracy, CA, Final Groundwater Treatment Pilot Plant Three-Month
Evaluation, Repoil No. 5
DDRW Tracy, California, Final Ground water Treatment Pilot Plant Three-Month Evaluation Report No. 5
Request for FFA schedule extension.
EPA concurrence of low-flow groundwalcr sampling.
Approval ol proposal extension to DDRW Tracy FFA schedule lot Opciablc Unit 1 KD/RA.
Draft Final Comprehensive Remedial Investigation/ Feasibility Study - Phase 1, Site Characterization Report
Final Well Monitoring Program, Annual Monitoring Report, October 1993 Sampling Round
Defense Distribution Region West, Tracy, CA, Final Comprehensive Remedial Investigation/Feasibility Study -
Phase I, Analytical Data Report
Minutes for the Project Managers' Meeting held on 17-18 August 1994.
Comments on Final Phase I Site Characterization Report and Draft Final Phase II Work Plan.
Defense Distribution Region West, Tracy, California, Final Groundwater Treatment Pilot Plant Three-Month
Evaluation Report No. 6
Defense Distribution Region csl, Tracy, CA, Interim Groundwater Treatment Plant Expansion Start-up and
Prove- out Work Plan, Table 2- 1
Draft Well Monitoring Program Low-Flow Sampling Study Work Plan for Defense Distribution Region West,
Tracy
DDRW Tracy, California, Draft Gioundwater Treatment Pilot plant Three-Month Evaluation Report No. 7
Interim Groundwater Treatment land Expansion Construction management Mid-Project Progress Report, Aug
25, !994loOct 19, 1994
Minutes for 1 1 October 1994 conference call on Draft Baseline Risk Assessment Work Plan.
Comments on Draft Final Phase II Work Plan.
Waste discharge requirements for DDRW Tracy.
Scope ol Work for Engineering Evaluation/Cost Analysis for Industrial Waste Lagoon Removal Action at
Defense Distribution Region West, Tracy, CA
Scope of Work for Engineering Evaluation/Cost Analysis for Industrial Waste Pipeline Removal Action at
Defense Distribution Region West, Tracy, CA
Appendix A, Annex B, Investigation, Alternatives Proposal, and Design for Removal Action of Underground
Storage Tank Sites at DDRW Tracy, CA
Minutes for the Project Managers' Meeting held on 19 October 1994.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
94/ 12/01
94/12/01
94/12/01
94/12/01
94/12/01
94/12/01
94/12/07
94/12/07
94/12/08
94/12/12
94/12/14
94/12/14
94/12/14
94/12/14
94/12/15
94/12/15
94/12/15
94/12/19
94/12/19
94/12/28
95/01/01
95/01/01
95/01/05
95/01/11
95/01/13
95/01/18
95/01/20
95/01/23
Author
MW
MW
MW
MW
MW
MW
James J. Oakham, Jr.,
MAI
James J. Oakham, Jr.,
MAI
DDRW-AliE
EPA
DDRW-AI3E
DDRW-ABE
DDRW-A13E
DDRW-ABE
DDRW-AUE
DDRW-ABE
DTSC
DDKW-ABE
DDRW-AUE
MW
MW
MW
RC
EPA
lil'A
DTSC
DDRW-ABE
DLA COL R.S.
LaBaron
Addressee
DDRW
DDRW
DDRW
DDRW
DDRW
DDRW
CoE Saclo
Appraisal Brancli
CoE Sacramento,
Appraisal Branch
DDRW-ABE
Resident
Resident
Resident
Resident
Resident
Resident
DDRW-ABE
Resident
CoE
CoE
DDRW
CoE Huntsvillc
CoE Huntsvillc
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
ASCW-BE Tracy
Subject
Defense Distribution Region West, Tracy, (.'A, Final Bench Test Work Plan
Defense Distribution Region West, Tracy, CA, Well Monitoring Program, 1994 Work Monitoring Program.
Defense Distribution Region West, Tracy, CA, Final Comprehensive Remedial Investigation/Feasibility Study -
Phase II Work Plan
Defense Distribution Region West, Tracy, CA, Lower Tularc Monitoring Well Technical Memorandum
Defense Distribution Region West, Tracy, CA, Start- Up, Prove-Out, and Extended Prove-Out Work Plan
Defense Distribution Region West, Tracy, Well Monitoring Program, Quarterly Monitoring Report, August 1994
Sampling Round
Real Estate Planning Report Part A lor Proposed Easement Acquistions Near The Tracy Facility DDRW
Real Estate Planning Report Pail A lor Proposed Easement Acquisitions for Contaminant Plume Management
near the Tracy Facility
Minutes lor the Technical Review Committee Meeting held on 3 Ocl 94
EPA comments on the Draft Final Comprehensive Risk Assessment Work Plan.
Private wells results for the March 1994 sampling round.
Private well results for (he March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results lor (he March 1994 sampling round.
Private well results for the March 1994 sampling round.
DTSC and RWQCB comments on (he Draft Final Phase 11 Work Plan.
Private well icsulls for (he March 1994 sampling round.
DDRW comments on the Interim Ground water Treatment Plan! Expansion drawings.
Conference call minutes on the Draft Final Baseline Risk Assessment Work Plan.
Defense Distribution Region West, Tracy, CA, Final Groundwater Treatment Pilot Plant Three-Month
Evaluation Report No. 7
DDRW Tracy, California, Groundwaler Treatment Pilot Plant Monthly Operations Reports No.4, July -
December 1994
DDRW Sharpe/Tracy Integrated Geographic Information System Needs Analysis and Requirements Document
Comments on statements of work for removal actions for the industrial waste lagoon/industrial waste pipeline
and underground storage tanks.
Comments on the Low-Mow Sampling Work Plan.
DTSC and RWQCB comments on the Draft Well Monitoring Program, Low-Flow Sampling Study Work Plan.
Comments on the Low Flow Sampling Study Work Plan.
8 Feb 95 TRC Meeting @ Ogilen, Utah
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Administrative Record File Index - DDJC Tracy (Continued)
Date
95/01/27
95/01/31
95/02/01
95/02/01
95/02/06
95/02/08
95/02/09
95/02/10
95/02/16
95/02/20
95/02/20
95/02/25
95/03/01
95/03/01
95/03/01
95/03/01
95/03/01
95/03/09
95/03/10
95/03/10
95/03/10
95/03/17
95/03/17
95/03/20
95/03/22
95/03/22
95/03/27
Author
DDRW-ABE
DDRW-ABE
MW Jamie S. Atwood
RC
EPA
DDRW-ABE
DDRW-ABE
MW
ASCW-BE
MW
MW
ASCW-BE
MW
MW
MW
MW
PTASI
EPA
MW
PTASI
RC
ASCW-BE
ASCW-BI:
ASCW-BE
Unknown
Unknown
ASCW-BE
Addressee
RWQCB
EPA
Steve Light,
CEHND
CoE Huntsville
DDRW-ABE
EPA
EPA
CoE Huntsville
CoE
Steve Light,
CEHND
Steve Light,
CEHND
RWQCB
DDRW
DDRW
DDRW
CoE Hunlsville
ASCW-BE
ASCW-BE
Marshall Cloud
ASCW-BE
CoE Muntsville
Residents
DDRW - Tracy
Participants
RWQCB
Subject
Comments on the Draft Waste Discharge Requirements Permit.
Request for a 23-day extension lor the Operable Unit 1 design/implementation schedule.
Minutes of Project Coordination Meeting on January 23, 1995
Draft Final DDRW Sharpe/Tracy Integrated Geographic Information System (GIS) Needs Analysis and
Requirements Document
EPA response to DDRW's letter of 31 January 1995.
DDRW submitting a table as requested in EPA's letter dated 6 February 1995.
EPA approving the FFA schedule extension for OU-I RD.
January 27, 1995 Conference Call Minutes on Draft Final BRAWP
Comments on the Environmental Baseline Study Statement of Work
Confirmation of Abandonment and Demolition Task at Well AG-3
A-E Weekly Quality Control Report: Well Investigation and Abandonment of Well AG-3
DDRW requesting a 15-day extension of the due dale for the DDRW Tracy air stripper monitoring report.
Defense Distribution Region West, Tracy, CA, Draft Final Comprehensive Site-Wide Baseline Risk Assessment
Work Plan.
Defense Distribution Region West, Tracy, CA, Final Well Monitoring Program, Low-Flow Sampling Study
Work Plan
Defense Distribution Region West, Tracy, California. Well Monitoring Program. Quarterly Monitoring Report,
October 199'! Sampling Round
Defense Distribution West, Tracy, California: Well Monitoring Program; Low-Flow Sampling Study Work Plan
Monthly Monitoring Report: March 1993
EPA comments on the Pre-Design Data Report for Operable Unit I.
Final Well Repairs for Well Abandonment DO (21)
MONTHLY REPORT FOR FEBRUARY 1-28, 1995
Final DDRW Sharpe/Tracy Integrated Geographic Information System (IGIS) Needs Analysis and Requirements
Document
Private wells results for the August 1994 sampling round.
Minutes for the Technical Review Committee Meeting held 5 December 1994.
Minutes for the Project Managers' Meeting held 29-30 November 1994.
Minutes ol Project Managers' Meeting 22-23 March 1995
RPM Minutes March 22, 1995
Request for permission to shut down the Operable Unit 1 air stripper for maintenance.
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Administrative Record File Index - DDJC Tracy (Continued)
Date
95/03/29
95/03/30
95/04/0 1
95/04/01
95/04/01
95/04/01
95/04/06
95/04/06
95/04/10
95/04/1 1
95/04/1 1
95/04/13
95/04/17
95/04/17
95/04/17
95/04/24
95/04/26
95/04/26
95/04/27
95/04/27
95/05/01
95/05/01
95/05/01
95/05/01
95/05/01
95/05/04
Author
RC
EPA
MW
MW
RC
RC
MS Sieve Krucgcr
USEPA, Michael
Work
PTASI
MW Robert P.
Schlicher
RC Scott Kranhold
DISC Jim Pinasco
Cull Huntsvillc
MW Andrew Somes
MW Jamie S. Atwood
ASCW-BE, Mcllvoy
MW Nancy Barnes
RC Francis E. Slnvich
MW
MW
MW
PTASI
PTASI
RC
The Stockton Record
RC
Addressee
Col- Huntsvillc
ASCW-BC
Col£ Hunlsville
CoE Huntsville
CoE Hunlsville
CoE Huntsville
Marshall Cloud
ASCW-BE
ASCW-BE
Sieve Light,
Huntsville
ASCW-BE
Marshall Cloud
ASCW-BE Tracy
ASCW-BE
Steve Light,
Hunlsville
RWQCB
ASCW-BE
ASCW-BE and CoE
Hunlsville
Distribution List
Sieve Light
Coii i imiiNviiie
ASCW-BH
DDRW - Tracy
ASCW-BE
General Public
Coli llunlsvillc
Subject
DDRW Sharpe/Tracy Integrated Geographic Information System (IGIS) Database Design Document (Draft
Final)
Response to EPA comments on the Draft Final Comprehensive Baseline Risk Assessment Work Plan for DDRW
Tracy.
DDRW, Tracy, CA Draft Extended Prove-Out report Expanded Interim Remedial Measure System
DDRW, Tracy, CA, 30 Percent Remedial Design Report & Analysis for Operable Unit 1
Draft Delivery Order 002 Environmental Baseline Study Work Task Proposal for Defense Distribution West
Sharpe/Tracy, California
Draft Delivery Order 002 Environmental Baseline Study Work Task Proposal for Defense Distribution West
Sharpe/Tracy, California
5 Apr 95 Conference Minutes on Discussion of Work Submiltal Forwarded to CEIIND Prior to Meeting on GUI
Design
Review comments on PWP lor Monitoring Well Sampling & Analysis @ DDRW Sharpe & Tracy; Amendments
for 27 Dec 94
MONTHLY REPORT FOR MARCH 1-31, 1995
Status Update of 1RM Expansion Project at Tracy
Copy of EBS Questionnaire for Interviewing Property Owners
Review of Hie Draft Pre-Dcsign Data Report, DDRW, Tracy
COE Package for Out Lease of Tracy Annex
State of California, Department of Water Resources, Well Completion Reports for Tracy
Comprehensive Summary of Approach Used for Determination of Depot-wide Soil it Dcioni/.ed Water
Extraction Tesl Soil Lcachate Background Threshold Levels at Tracy
Feb 1995 Monthly Report for Tracy Air Stripper
List of Subcontractors for Site Access & Field Studies at Tracy
Draft Environmental Baseline Study for Tracy
Letter lo Sieve Light Regarding Phase III Sampling
Technical Memo Review ( Juimiciils and Phase III Sampling for Phase II Investigation and Report DDRW -
Tracy
DDKW.Tiacy, CA. Well Monitoring I'mgiam IW4 Annual Repoil
Monthly Monitoring Repoil: May 1995
Monthly Monitoring Report - May 1995
Administrative Support Center West-Tracy Operable Unit I CPT Study Work Plan
Newspaper Article: Project Manager Wins Award for Innovative Way to Clean Up Depots
Draft ASCW Sharpe/Tracy Integrated Geographic System (IGIS) User Guides
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
95/05/04
95/05/04
95/05/04
95/05/05
95/05/10
95/05/11
95/05/1 1
95/05/16
95/05/18
95/05/18
95/05/19
95/05/23
95/05/26
95/05/30
95/06/01
95/06/01
95/06/01
95/06/01
95/06/01
95/06/01
95/06/05
95/06/05
95/06/08
95/06/08
Author
RC
Tracy Press, Sam
Matthews
USHPA, Michael
Work
PTASI
ITASI
MW Jamie S. Alwood
USEPA. Michael
Work
DDKW-Tracy RIM
USEPA, Michael
Work
USEPA, Michael
Work
MW
MW Nancy Barnes
Patricia L. Rivers,
OUSD
MW Nancy Barnes
MW
MW Susan Tiffany
PTASI
RC
RC
USACOE,
Sacramento District
MW
MW Jamie S. Alwood
Michael Work,
USEPA
Steven L. Glaser, MW
Addressee
CoE lluntsville
ASCW-BE
ASCW-BE Tracy
DDRW, Tracy
Facility
DDRW - Tracy
ASCW-BE Tracy
Marshall Cloud
ASCW-Bli Tracy
Marshall Cloud
Marshall Cloud
Steve Light, CoE
Huntsville
Steve Light
ASCW-BE, Tracy
Marshall Cloud
CoE lluiilsvillc
ASCW-BE
DDRW - Tracy
ASCW-BE
CoE Hunlsville
ASCW-BE
Sieve Light
Sieve Lighl and
Marshall Cloud
Mr. Marshall Cloud
Coli Hunlsville
Subject
ASCW Sharpe/Tracy Integrated Geographic Information Syslcin Implementation Plan (Draft)
City's Plans for Goll Course
EPA's Review of Data Validation Portion of Tracy's Comprehensive RI/FS Phase II Analytical Data Report,
Volumes), II. Ill
Quarterly Monitoring Report: Fiisl Quarter 1995
Monthly Monitoring Report, April 1995
Video Survey of the Grouting of and Abaiuibnmcnt of Well AG3
Flow Chart for Amending a KOI)
1RM Specifications for Equipment, Well Pumps, Piping, Meiers, & Valves for Tracy A/S System
Receipt of DDRW-Tracy's Draft Technical Memorandum: Comprehensive Remedial Investigation/Feasibility
Study - Phase II (Mar 95 (Volumes I & II)
DDKW-Tracy's Draft Technical Memorandum: Comprehensive Remedial Investigation/Feasibility Sluily -
Phase II, Volumes 1 & II
DDRW Tracy Background Discussions
Draft Status Report: Abandonment of Well AG-3
Technical Assistance for Public participation in the DERA Program-Federal Register Notice of Request for
Comments
Weekly DQCRS from Road Work. Well Abandonment. ,«i Phase III Rl
Technical Memorandum Human Health Risk Assessment at Exposure Units 1.2,7
Preliminary Applicable or Relevant and Appropriate Requirements for ASC-Tracy Feasibility Study
Monthly Monitoring Report, June 1995
Delivery Order 0003: OU Design Support Work Task Proposal
Operable Unit 1 CIT Study Work Plan
Environmental Baseline Study OU 1 Easement Properties
DDKW-Tracy Phase II Rl Final Investigation Derived Waste Rcporl
Details Concerning DDRW-Tracy Phase II Rl Final Investigation Derived Waste Report
DDRW - Tracy's 30 Per Cent Remedial Design Rcporl and Analysis, Remedial Action Work Plan (Apr 95) for
Operable Unit 1
Risk Assessment Criteria, Coinmillce Meeting Minnies, May 9, 1995
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Administrative Record File Index - DDJC Tracy (Continued)
Date
95/06/09
95/06/12
95/06/12
95/06/14
95/06/20
95/06/20
95/06/21
95/06/26
95/06/26
95/06/30
95/07/01
95/07/01
95/07/01
95/07/01
95/07/01
95/07/05
95/07/06
95/07/06
95/07/07
95/07/11
95/07/17
95/07/18
95/07/18
Author
Karen 1 lessen.
RWQCB, Central
Valley
Dennis C. Noble,
Attorney ;it L;iw
MW
Francis li. Slavick, KC
Francis li. Slavich, RC
Steven L. Glascr, MW
Nancy Barnes, MW
Jim Pinasco, DISC
Sleven L. Glaser, MW
RC
MW
PTAS1
RC
RC
RC
PTASI
Diane Hinson, PUS,
SJC
SWRCB, Central
Region
DoD, Material Mgt
Distributions, IMP,
Virginia Crowson
MW
Nancy Humes, MW
Francis li. Slavieh, RC
Steven M. Newton,
MW
Addressee
Mr. Marshall Cloud,
RRWQCU
Steve Light
Sieve Light
Steve Light
Marshall Cloud,
Steve Light
Mr. Marshall Cloud
CoE Huntsville
CoB Huntsville
CoE Huntsville
DDRW-Tracy
CoE Hunlsville
CoE Huntsville
CoH Hunlsville
DDRW - Tracy
RWQCB
Diane Hinson,
SJCPHS
Mr. Marshall Cloud,
Col: Huntsville
Sieve Light
Steve Light
Steve Light
Subject
Addendum to Pre- Design Data Report lor Operable Unit 1, DDRW Tracy
Irrigation Well Installation 2(>l()l S. Chrisnian Koail APN 252-040-05 Anthony Traina, el. al.
A-E Weekly Quality Control Report, June 12, 1995, Well Investigation & Abandonment
Delivery Order OOOft, Project Management Contract IMCAK7-95-D-OOOI, Meeting Minutes, Public Relations
Delivery Order 0003, Groundwaler Treatment Remedial Design Support lor DDRW Submiltal of Work Task
Proposal
Baseline Risk Assessment at DDRW - Tracy
Submitlal of Well Abandonment Work Plan for AG-3
Review of 30 Per Cent Design Report and Analysis and Draft Remedial Action Work Plan for Operable Unit No.
1, DDRW, Tracy
Corrections and Clarifications to the Meeting Minutes of the May 9, 1995 Baseline Risk Assessment CCM for
ASCW - Tracy
DDRW Sharpe/Tracy Integrated geographic Information System Draft Final Database Design Document
DDRW-Tracy Environmental Baseline OUI Easement Properties Final Report
Monthly Monitoring Report July 1995
DDRW Sharpe/Tracy Integrated Geographic Information System Implementation Plan, Draft Final
DDRW Sharpe/Tracy Integrated Geographic Information System Draft Final User Guides, Version 1
DDRW Sharpe/Tracy Integrated Geographic Information System, Draft final User Guides. Version II
Quarterly Monitoring Report - Apiil - June 1995
Proposed Irrigation Well Installation, APN 252-040-05, 26101 Chrisman Rd, DDRW Tracy
Proposed Irrigation Well installation, APN-252-040-05, 26101 S. Chrisman Road, Tracy
Proposed Easement Acquisitions for contaminant Plume Management Near DDRW - Tracy
Transmillal of Predralt Proposed Plan
AH Weekly Quality Control Repoil. 17 July 95
Delivery order 0003, Contract DACA87-95-D-OOI, Groundwaler Treatment Remedial Design Support lor
DDRW OU#I CPT Study Field Reports
Strawberry Agricultural Well Potential Impact on DDRW-Tracy
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Administrative Record File Index - DDJC Tracy (Continued)
Date
95/07/20
95/07/25
95/07/27
95/07/27
95/07/28
95/07/2K
95/07/3 1
95/07/3 1
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/15
95/08/17
95/08/18
95/08/22
95/08/24
95/08/25
95/08/27
95/08/28
Author
Michael Work,
USEPA
David C. Ennis
RC
RWQCB, Central
Valley
MW
MW
Pcier U. LcVon, MW
Randy Marx, RC
MW
MW
MW
MW
MW
MW
PTASI
RC
RC
RC
Joe Sehratz, Calcon
Systems, Inc.
Michael Work,
USEPA
Steven L. Glaser, MW
Unknown
Michael Work,
USIil'A
Michael Work,
USEPA
Unknown
Michael Work,
USCPA
Addressee
Marshall Cloud
Steve Light
Steve Light
Jim Pinasco, DTSC
Marshall Cloud
CliHND
Steve Light
Steve Light
CoE Huntsville
CoE Huntsville
CoE Huntsville
CoE Huntsville
DDRW - Tracy
DDRW - Tracy
DDRW - Tracy
CoE Huntsville
CoE
Coli lluiilsvillc
Peter Kalush
Marshall Cloud
Steve Light
DDRW Remedial
Project Mgrs
Marshall Cloud
Marshall Cloud
General Public
Marshall Cloud
Subject
DDRW Tracy Technical Memorandum, Human Health Risk Assessment at Exposure Units 1,2, & 7, June
Possible Use of Zero Valcnt Metals for Operable Unit 1 , Groundwater Cleanup at DDRW, Tracy
Document Submission - Final Environmnetal Baseline Study
General Comments on Well Monitoring Program 1994 Annual Monitoring Report lor Tracy
Well Completion Reports Well Abandonment Program Delivery Order 021
Comprehensive RI/FS - Phase II and Phase HI Analytical Data Report, Vol 1, II, & III
1995
Response To Comments on DDRW Tracy Well Monitoring Program Draft Low-Flow Sampling Study Work
Plan
Submittal of Record of Decision Summary Table
Draft Comprehensive Site-Wide Baseline Risk Assessment
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume I
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume 2
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume HI
Final Groundwater Model Technical Evaluation, Volume 1
Final 3-D Groundwater Model Technical Evaluation, Volume 2
Monthly Montioring Report, August 1995
Draft Engineering Evaluation Cost Analyses (EE/CA) for the Industrial Waste Pipeline. Sewage Lagoons,
Industrial Waste Lagoons for DDRW-Tracy
DDRW Tuicy & Shaipc, CA Delivery Onler 000: Community Relations Task Work Task Proposal
USTSile Investigation Work Plan, Draft
Tracy DDRW Air Stripper- Valve Failure
DDRW Tracy Incomplete RI Submission and EPA's Risk Assessment Comments of July 20, 1995
Submittal of Draft Comprehensive Site-Wide Risk Assessment Section 6 - Ecological Assessment
Presentation of DDRW Draft Comprehensive RI/FS and BRA Findings to Remedial Project Managers
Resolution of Informal Dispute Re DDRW-Tracy incomplete Rl
DDRW-Tracy Draft Explanation of Significant Difference for OU-I ROD (Aug 95)
Public Notice for Agriculture Lease Meeting on September 7, 1995
Ltr. regarding DDRW Tracy Investigation of AG-2/Lower Tulare
&
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
95/08/30
95/08/30
95/09/01
95/09/01
95/09/01
95/09/01
95/09/01
95/09/01
95/09/01
95/09/08
95/09/09
95/09/09
95/09/13
95/09/14
95/09/14
95/09/15
95/09/15
95/09/18
95/09/19
95/09/20
95/09/20
95/09/22
95/09/26
95/09/26
95/09/26
Author
Deborah C.Z. Hirsch,
RC
Slevcn L. Glaser, MW
MW
MW
MW
MW
MW
MW
RC
Nancy Price, Stockton
Record
Scott Howard, The
Valley Newspaper
Stockton Record
RC
MW
Peter B. LeVon, MW
AMCEN-R
(MMDIM), Col Mark
Porter
Deborah C.Z. Hirsch,
RC
MW
Michael Work,
USEPA
Deborah C.Z. Ilirsch,
RC
Steven L. Glaser, MW
CPT Will Harmon
CoE
RC
RC
Addressee
Steve Light
Marshall Cloud
CoE Hunlsville
CoE Huntsvillc
CoE Hunlsville
CoE Hunlsville
CoE Hunlsville
CoE Hunlsville
CoE Hunlsville
General Public
General Public
General Public
CoE Hunlsville
Steve Light
Steve Light
DDRW - Tracy
Sieve Light
Marshall Cloud
Mi. Marshall Cloud
Steve Light
Steve Light
Marshall Cloud
ASCW-BE
CoE Hunlsville
CoE Huntsvillc
Subject
Delivery Order 006: Transmital of Meeting Minutes and Draft Posler Boards
Parental Notification Letter, Day Care Center
DDRW-Tracy Operable Unil 1 CPT Technical Memorandum Final Report
DDRW-Tracy 60 Per Cenl Remedial Action Work Plan for Operable Unil 1
DDRW-Tracy 60 Per Cent Construction Specifications for Operable Unit 1 , Volume II
Interim Groundwater Treatment Expansion Operations & Maintenance Manual
DDRW-Tracy: 60% Remedial Design Report ana Analysis for Operable Unil 1
DDRW-Tracy 60% Construction Specifications Volume 1
DDRW-Tracy Underground Storage Tank Closure Report Draft
Newspaper Article: F'eds Looking for A Few Good Farmers for Leases Near Tracy Depot
Day Care Center Discovers Minute Amount of DDT
Newspaper Article: DDT Found at Tracy Depot at Day-Care Center
Engineering Evaluation/Cost Analyses (EE/CA) for the Industrial Waste Pieline, Sew Lagoons, & Industrial
Waste Lagoons Draft Final
Original Dala Sheets for Phase II DI-WET Dala
Response to comments on DDRW-Tracy Well Monitoring Program
Proposed Easement Acquislions for Contaminant Plume Management near DDRW - Tracy
Transmiltal of Public Meeting Minutes and Copies ollnloi (national Postcrboard Sets Prepared for Public
Meetings
Modeling Backup to Montgomery's Letter Dated July 18, 1995
DDRW-Tracy's Draft UST Site Investigation Work Plan (Aug 1995)
Transmiltal of Public Meeting Minutes & Copies of Informational Posterboards Sets Prepared for Public
Meetings
Day Care Meeling Minutes, September 5, 1995
Analytical Dala Summary for Vegetative Layer Hanow Source Sampled on August 17,1995
Petroleum Contaminated Soil Removal DDRW-Tracy & Sharpc Draft-Draft
Work Task Proposal for the IRM Goundwater Treatment Plant Scale Study, DDRW-Tracy
Work Task Proposal for the Two Phase Extraction Ticalability Study, DDRW-Tracy
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
95/09/29
95/09/29
95/09/30
95/10/04
95/10/04
95/10/04
95/10/05
95/10/05
95/10/10
95/10/10
95/10/11
95/10/11
95/10/16
95/10/18
95/10/19
95/10/24
95/10/24
95/10/25
95/1 0/2(>
95/10/26
95/10/30
95/10/30
95/10/31
95/10/31
95/11/01
95/11/02
95/11/02
95/11/0.1
Author
Curtis & Tompkins.
Lls. Analytical
Laboratories
MW
MW
ASCW-PSM
Jim Pinasco, DISC
RC
PTASI
WMD/C&C&T
CoE
PTASI
Brian K. Davis, Ph.D,
DTSC
RC
RC
EPA
RWQCB
ASCW-BE
RWQCB
KC
DTSC
RC
MW
RWQCB, Karen
Bcssclt
DDRW-BG
RC
RWQCB
Michael Work,
USEPA
Michael Work,
USEPA
Jim Pinasco, DTSC
Addressee Subject
Marshall Cloud Preliminary Results from Analysis of Contaminated Soil @ Tracy Daycare Center
Steve Light EPA Comments on Human Risk Assessment Technical Memorandum
CoE lluntsville Extended Prove-Out Report Expanded Interim Remedial Measure System, September 1995 1 copy
PTASI Well Monitoring
Marshall Cloud Quote Tor Removal of Contaminated Soil @ Tracy Daycare Center
Steve Light 29 Sep 1995 Conference Call Minutes & Monthly Planner lor Get & Nov 1995
ASCW-BE Sharpe Quaterly Monitoring Report, July - September 1995
Davy International Test Results lor Child Care (.'enter - '1 racy Facility
DDRW-Tracy Extended Prove-Out IRM, Design Review Comments, May 5, 1995
DDRW - Tracy Monthly Monitoring Report, September 1995 2 copies
Jim Pinasco, DTSC Risk Assessment Evaluation of DDRW Tracy
CoE Final Integrated Geographic Information System (IG1S) Implementation Guide
Steve Light Draft DDRW Tracy's Operable Unit 1 Two Phase Extraction Treatability Study Work Plan
DDRW-Tracy Draft Final EE/CA, DDRW Tracy, Removal Action for SWMUs 2. 3, and 33
DDRW-Tracy Draft Undeground Storage Tank (UST) Site Investigation Work Plan general comments
EPA Approval of DTSC request for a 30 day comment extension
Jim Pinasco, DTSC Draft Final Engineering Evaluation/Cost Analyses for the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons
CEIIND Draft Pesticide Evaluation I'm Day Care IVnli-r (IK'C) Toi-lmiral Memorandum DDRW-Tracy
DDRW-Tracy Engineering Evaluation/Cost Analyses (liE/CA), lor the Industrial Waste Pipeline. Sewage Lagoons, and
Industrial Waste
CEHND Operable Unit 1, 60 Percent Design Review, DDRW-Tracy, DACA87-95-D-OOOI
CoE Hunlsville Operable Unit 1, Explanation ol Significant Difference for Chg of Groundwater Extraction
Marshall Cloud Draft Final Explanation of Significant Difference for OU 1 ROD, DDRW-Tracy
Michael Work, EPA Decision not to conduct NRDAat DDRW Tracy
CoE Huntsville Final Operable Unit 1 CPT Study Technical Memorandum, DDRW-Tracy, October 31, 1995 3 copies
D'I'SC, Jim Pinasco Draft Comprehensive KI/FS tudy Report, DDRW-Tracy
Marshall Cloud Draft Final ESD for OU- 1 Ocl95
Marshall Cloud Ltr. regarding Draft Final ESD for OU- 1 (Oct 95)
Marshall Cloud Draft Comprcshensive RI/FS. DDRW Tracy
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
95/1 1/03
95/1 1/07
95/1 1/08
95/11/09
95/1 1/10
95/11/13
95/11/13
95/11/13
95/11/13
95/11/13
95/11/13
95/11/14
95/11/20
95/1 1/22
95/11/29
95/12/02
95/12/04
95/12/08
95/12/12
95/12/14
95/12/14
95/12/15
95/12/19
95/12/20
95/12/20
Author
Michael Work,
USEPA
Michael Work,
USEPA
UD
DTSC, Jim Pinasco
I'TASI
DTSC, Jim Pinasco
Michael Work,
USHPA
Michael Work,
USEPA
MW, Roberta
Schlicher
RC
RWQCB, Robert
Reeves
MW
Michael Work,
USEPA
RC
AMCEN-R
RC
CoE
RC
Michael Work,
USEPA
RWQCB
RWQCB. Robert
Reeves
RC, Slavich
RC
MW, Roberta
Schlicher
RWQCH
Addressee
Marshall Cloud
Marshall Cloud
CoE, Steve Light
Marshall Cloud
DDKW-Tracy
Marshall Cloud
Marshall Cloud
Marshall Cloud
CoE, Steve Light
CoE Huntsville
DTSC, Jim Pinasco
DDRW-Tracy
DDRW-Tracy
Coi£, Steve Light
ASCW-BI:
CoE, Steve Light
DDRW-
Tracy/Sharpe
CoE, Steve Light
Marshall Cloud
Marshall Cloud
ASCW-BE
CoL, Steve Light
ASCW-BE
Coli, Sieve Light
DDRW-Tracy
Subject
Llr. regarding Example Proposed Plan
Letter regarding Draft Final OU-I 60% Remedial Design (Sep 95)
Document Submission: Draft Interim Remedial Measure (IRM) Study Work Plan, DDRW - Tracy 3 copies
Llr verifying 30 day extension for comments concerning the Draft Base Wide RI/FS Study Report
Monthly Monitoring Report, Tracy l;acility, Report Period October 1995, Report Dale November 10, 1995
Review of Draft 60% Design for U- 1 , DDRW-Tracy
Ltr. DDRW-Tracy FFA Schedule xlension Request for Draft inal Compreshensivc Rl/FS/PP nd Draft ROD
Llr DDRW-Tracy FFA Schedule Extension Request for Draft Final Compreshensivc KI/FS/PP and Draft ROD
OUI Explanation of Significant Difference DDRW-Tracy Revised Draft Final
Final Two Phase Extraction Treatability Study Work Plan
Comments on the 60% Remedial Design Report & Analysis for OU-I & 60% Remedial Action Work Plan for
DDRW-Tracy.
DDRW-Tracy Operable Unit 1 Explanation of Significant Difference
Example Table Format for Risk Assessment Uncertainties
Draft Underground Storage Tank Closure Report, DDRW-Tracy
Proposed liascmcnt Acquisitions foi Contaminant Plume Management Near the DDRW-Tracy
Draft Environmental Master Plan, DDRW-Shapre and DDRW- Tracy
Draft-Draft Site Visit, Petroleum Contaminated Soil Removal.
Work Task Proposal for Tracy Well Management Project
Llr. OU-I Remedial Design 60%
Well Abandonment Engineering Report for DDRW-Tracy
Well abandonment Engineering Report, DDRW-Tracy
Final Pesticide Evaluation for Day Care Center Technical Memorandum DDRW-Tracy
Minutes RPM meeting Dec 5-7, 1995
OU-I Explanation of Significant Difference. DDRW-Tracy Final
Notice, Tentative Waste Discharge Kcq. for Tracy OU-I Cirnundwaler Treatment System
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
9.V 12/20
95/12/29
95/12/29
96/01/01
96/01/01
96/01/01
96/01/02
96/01/05
96/01/05
96/01/05
96/01/06
96/01/06
96/01/10
96/01/12
96/01/12
96/01/13
96/01/15
96/01/16
96/01/17
96/01/17
96/01/18
96/01/19
96/01/19
96/01/19
Author
KWQCH, Karen
Besselt
ASCW-BE, Marshall
Cloud
KC, Slavic!)
MW
KC
KC
RC
MW
MW
MW, Roberta
Schlichcr
MW
MW
RC
ASCW-1JE
PTASI
KC
KC
ASCW-BE, Marshall
Cloud
ASCW-BE, Marshall
Cloud
ASCW-BE, Marshall
Cloud
ASCW-BE
ASCW-BE
MW
MW
Addressee
ASCW-BE
RWQCB, Karen
Bassclt
CoE, Sieve Light
CoE
DDKW-Traey
CoE
CoE
CoE, Hunlsville
CoE
CoE
CoE
CoE
CoE, Sieve Light
RWQCB, Karen
Besselt
ASCW-BE
Col:
Col:, Sieve Light
Michael Work, EPA
DISC, Jim Pinasco
RWQCB, Karen
Bcsscll
EPA, DTSC,
RWQCB, CoE,
MW, RC
EPA, DTSC,
RWQCB, CoE,
MW, RC
CoE
CoE
Subject
DDKW-Tracy Grouiulwaler Treatment System, Nov. 95 Report
Llr stating need Tor more analytical data to evaluate pesticide problem in groundwater at
DDRW-Tracy
Draft Soil Stockpile Disposal Evaluation lor Day Care Center Technical Memorandum DDKW- Tracy
95% Construction Cost Estimate OU- 1
Well Abandonment/Well Installation (Addendum to DDRW-Sharpe Tracy Master Work
Management Task, January 1996
Draft Sampling and Anaylsis Plan for SMWUs 2 and 3
Draft Sampling and Analysis Plan for SWMUs 2 & 3
100 Percent Design Subniittal
95% Design Submittal
95 Percent Remedial Design Report and Analysis for OU-I
95 Percent Construction Specifications, OU-I Remedial Design, Vol I & 11, Tracy
Final Remedial Action Work Plan for Operable Unit 1, Tracy
Draft OUI Two Phase Extraction Treatability Study Summary Report, January 1996
Ltr with Dec 95 report for DDRW-Tracy Groundwater Treatment System
Monthly Monitoring Report for December 1-31, 1995.
Delivery Order 12 Well Monitoring Work Task Proposal
Draft Master Work Plan (Well Management). Sharpe and Tracy
Llr. requesting 208 day extension for Draft/Final Risk Assessment, KI/FS, Proposed Plan
Ltr. requesting 208 day extension for Draft/Final Risk Assessment, RI/FS, Proposed Plan
Llr. requesting 208 day extension for Draft/Final Risk Assessment, RI/FS, Proposed Plan
Revised Delivery Schedule for Risk Assessment, RI/FS, PP and ROD
Fax notifying PMM Fcb 1, 1996 at Montgomery Watson
OU-1 Explanation of Significant Difference, DDRW-Tracy
Meeting Notes for KPM Meeting February 1, 1996.
Plan) Well
, and ROD
, and ROD
and ROD
-------
Date
%/()l/22
'JO/0 1/24
96/01/24
96/01/24
96/01/25 •
96/01/26
96/01/26
96/01/26
96/01/26
96/01/26
96/01/29
96/01/29
96/01/29
96/01/30
96/01/30
96/01/31
96/01/31
96/02/01
96/02/0!
96/02/05
96/02/05
96/02/05
96/02/07
96/02/19
96/02/20
96/02/2 1
96/02/22
96/02/22
Author
KWQCB, Antonia
Vorsl
Michael Work,
US EPA
RC. Slavich
RWQCB
RWQCB
MW
MW
RC
RC
RC
Michael Work,
USEPA
RC
RWQCB
Hunter Surveying, Inc.
Hunter Surveying, Inc.
RC
RC
MW. Sue Tiffany
PTASI
RC
RC
RWQCB
Marshall Cluud
KC
ASCW-Uli
ASCW-UE
Michael Work,
USEPA
Stockton Record
Administrative Record File Index - DDJC Tracy (Continued)
Addressee Subject
Marshall Cloud Project Manager for DDRW-Tracy be Robert Reeves while Karen Bessette is on leave, 1-15-96 to 7-1-96.
Marshall Cloud DDRW-Tracy I;I7A Schedule Extension Request
Sieve Light Regulatory Agency Comment Responses for Draft Final Engineering Evaluation/Cost Analyses
DTSC, Jim Pinasco FFA Time Schedule Extension Request, DDRW-Tracy Itr.
DDRW-Tracy Tracy WDR's, RWQCB Meeting Agenda fur January 25, 1996
CoE Final Well Monitoring Program Low-Flow Sampling Study Report January 1996
CoE OU-I Pesticides Consensus Statement, DDRW-Tracy
Steve Light Draft Situ-Specific Health and Safely Plan, Sewage Lagoon (SWMUs 2 & 3) Soil Sampling
Col: Final Engineering Evaluation/Cost Ananlysis (Eli/CA) for the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons
CoE Delivery Order 12/13-Pieliminary Draft Well Monitoring Program Work Plan Addendum-QAPP
Marshall Cloud GPA comments on DDRW-Tracy 95% RD Report OU- 1 (Jan 96)
CoE Comments on OU- 1 , 95% Design Review, DDRW-Tracy
DTSC, Jim Pinasco Comments, 95% Design Report for Groundwater OU- 1 , DDRW-Tracy
ASCW-BE Record of Survey, portion of Sec. 26.2S., R.5E., M.D.B. & M. San Joaquin Country, CA MAP
ASCW-BE MAP, Record of Survey a portion of section 35, T.2S., R.5E..M.D.B. & M. San Joaquin Country - CA
CoE DDRW-Sharpe and Tracy, Mod-A Draft Work Task Proposal for Underground Storage Tank (UST) Project
CoE Delivery Order 12/13-Preliminnry Draft Well Monitoring Program Work Plan Addendum
ASCW-BE Draft Action Mem lor Kern Act. at liul Waste Ppln, Sew. Lagcl
DDRW-Tracy Quarterly Monitoring Report Report Period Oct-Dec 1995 Report Dale: February 1996
CoE Draft Action Memorandum for Removal Actions at the Industrial Waste Pipeline, Sewage Lagoons and
Industrial Waste Lagoons
CoE, Hunlsville Draft Action Memorandum for Removal Actions
Marshall Cloud Notice of Adoption of Waste Discharge Requirements & Initial Study & Negative Declaration for DDRW-Tracy
OU-I Groundwaler Treatment System
CoE Comments OU 1 Two 1'hase Extraction Trcatability Study Summary Report
CoE January Monthly Treatment Plant Performance Monitoring Report
C'AAIi, Dennis Li Ho Request lor meetings to discuss Kil.S and Low How ground water sampling program
Regulators Fax Project Managers Meeting Fub 29, 1996
Marshall Cloud Llr. Final EE/CA for Ind. Waste Pipeline, Sewage Lag. & Ind. Waste Lag. Draft Sampling & Analysis Plan lor
SWMUs 2 & 3.
ASCW-Uli Proof of Publication on Itlit'A lor three Tracy Solid Waste Management Unit Sites
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-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/02/23
96/02/23
96/02/23
96/02/23
96/02/27
96/02/29
96/03/04
96/03/04
96/03/05
96/03/OK
96/03/08
96/03/12
96/03/13
96/03/14
96/03/14
96/0.1/1
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/o
"r
3
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
9(i/()6/()6
96/06/1 1
96/06/12
96/06/14
96/06/14
96/06/17
96/06/18
96/06/20
96/06/20
96/06/24
96/06/28
96/06/29
96/07/01
96/07/01
96/07/12
96/07/12
96/07/12
96/07/15
96/07/15
96/07/15
96/07/19
96/07/19
96/07/22
96/07/22
96/07/23
96/07/23
96/07/29
96/07/31
Author
RC
RC
ASCW-BC
RC
RC
ASCW-BE
RC
MW
RC
Michael Work,
USEPA
RC
RC
RC
USEPA
RC
RC
RC
RC
RC
RC
RC
RC
ASCW-BE
RC
ASCW-BE
Michael Work,
USEPA
ASCW-BE
RC
Addressee
ASCW-BE, John
Guzman
CoE, Huntsville
Regulators,
CEHND, MW, RC
CoE, Huntsville
CoE, Huntsville
RWQC13, Karen
Bessette
CoE, Hunlsvillc
Marshall Cloud
CoE
Marshall Cloud
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
DTSC, RWQCB,
ASCW-BE
ASCW-BE
CoE, Huntsville
CoE, Hunlsvillc
CoE, Huntsville
Regulators
CoE, Hunlsville
CoE, Huntsville
CoE, Huntsville
RWQCB, Karen
Bessette
CoE, Hunlsville
CoE, Steve Light
Marshall Cloud
Tracy Residents
CoE, Huntsville
Subject
Administrative Record Audit for DDRW Sliarpc Tracy
IGIS User Guides, Final
RPM Meeting invitation lor July 15-16, 1996, DDSJ
Final Comprehensive Field Work Plan, DDRW-Sharpc & DDRW-Tracy Vol l-Text & Vol 2-QAPP
May 1996 Monthly Treatment Plant Performance Monitoring Report (Well Monitoring)
Llr. accompanying Monthly Report for Monitoring and Reporting Order No. 96 for May 1996
Final UST Site Investigation Field Work Report for DDRW-Tracy
Low Flow Pump Preliminary Analysis
Draft Hazardous Material Storage Addition to Warehouse 28 Environmental Assessment
EPA Comments on DDRW-Tracy's 60% Removal Action Design for SWMUs 2, 3, and 33, May 1996
Draft Well Monitoring Program 1995 Annual Monitoring Report
Draft Child Care Facility Closure
90% Removal Action Design for SWMUs 2, 3, and 33 Design Analysis Report
Llr Informant Dispute, DDRW-Tracy Comprehensive RI/FS Baseline Risk Assessment (BRA) and added
comments from July 8, 1996 conference call
Final Draft Administrative Record Assessment Report
Groumlwalcr Treatment Plant Monthly Performance Monitoring Report - June
(iroiiiulxvater Treatment I'liinl Monthly Performance Monitoring Report - Juno 1996
90% Removal Action Design for SWMUs 2, 3, and 33 Specifications
DDRW-Tracy OU-1 Well Installation Status
Comments from RWQCB to include in Final UST Site Investigation Work Plan
Draft Waste Management Plan, DDRW-Sharpe and Tracy
Draft Waste Management Plan, Sharpe and Tracy
Llr attached to Tracy site monthly Monitoring Report for June 1-30, 1996
Well monitoring Program Quarterly Monitoring Report Second Quarter 1996 Sampling Round, DDRW-Sharpc
and DDRW-Tracy
DDRW Tracy Air Stripper Scaling Problem
EPA Input to DDRW-Tracy 's Comprehensive RI/FS/BRA
Test Results from drinking water wells, Jan-Mar 1996
Final Well Monitoring Program Field Work Plan
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/07/31
96/08/01
96/08/05
96/08/05
96/08/07
96/08/07
96/08/08
96/08/12
96/08/12
96/08/12
96/08/13
96/08/13
96/08/13
96/08/14
96/08/15
96/08/15
96/08/16
96/08/16
96/08/18
96/08/21
96/08/21
96/08/30
96/09/06
96/09/06
96/09/06
96/09/06
96/09/06
96/09/09
96/09/12
Author
RWQCB
EPA
Michael Work,
USEPA
RC
ASCW-BE
ASCW-BE
MW
ASCW-BE
CEHND
RC
MW
MW
RC
MW
EPA
RC
RC
RC
MW
ASCW-BE
ASCW-BE
RC
MW
RC
RC
RC
RC
EPA
ASCW-BE
Addressee
ASCW-BE
ASCW-BE
Marshall Cloud
CoE, Huntsville
RWQCB Karen
Bessette
RWQCB, DTSC,
EPA
CEHND
EPA, Michael Work
MW
ASCW-BE
DTSC
DTSC
CEHND
CEHND
ASCW-BE
CoE
CoE, Hunisville
CoE, Hunisville
CoE
RWQCB
RWQCB
CoE, Huntsville
RWQCB
CoE, Hunisville
CoE, Hunisville
CoE, Huntsville
CEHNC
DDRW-Tracy
Regulators, Radian,
MW, Bcchlel
Subject
Llr Well Installation Work Plan, DDRW-Tracy
Region 9 Preliminary Remediation Goals (PRGs) 1996
Llr Response lo EPA Comments, Final Comprehensive RI/FS Phase II & HI Analytical Data Report
Draft OUI Repairs and Enhancements Work Plan
Ltr with info closure of USTs
Transmillal page with Final Well Moniloring Program Field Work Plan
Draft Final Comprehensive Site-Wide Baseline Risk Assessment
Llr requesting two day extension from 8/13/96 lo 8/15/96 for DDRW-Tracy Draft Final Comprehensive
Remedial Investigation Feasibility Study
Revised Final Comprehensive RI/FS - Phase II and Phase III Analytical /Data Report to Vol I-1II
RPM Meeting Minutes foi July 15- 16, 1996
Draft Final Baseline Risk Assessment
Ltr w/ Drafl Final Baseline Risk Assessment
July Monthly Treatment Plant Performance Moniloring Report, DDRW-Tracy
Comprehensive Draft Final RI/FS Vol I-1I1
Response to Tracy's request for a 2-day FFA schedule extension, Comprehensive RI/FS/BRA/PP Extension
approved to 8/1 5/96.
Final Preferred Alternatives Report for UST Sites 7, 9, 10, and 20
Draft Final Environmental Master Plan
Final Waste Management Plan (Addendum lo Comprehensive Field Work Plan for Sharpc/Tracy
Response to Comments Received on the Draft Comprehensive RI/FS
Tracy Monthly Report for Moniloring and Reporting Order forJuly 1996
Llr scaling problem with air stripping system, Tracy Site
Final Ou-l Repairs and Enhancements Work Plan
Ltr Aerial Photos at DDRW-Tracy
Draft Final Administrative Record Assessment
Final Child Care Facility Closure Report, DDRW-Tracy
Modification 2, OUI Repairs and Enhancements, PLC I/O Point Lists
Final Drum Storage Facility Environmental Assessment
DDRW-Tracy Well Monitoring Program, Quarterly Moniloring Report Second Quarter 1996 Sampling Round,
July 1996
Announcement of RE/F'S Approval Meeting lor Oct 9- 10, 1996 lo discuss outstanding issues only.
D
D
n
H
t/l
k
£.'
n
5
•o
Q
3"
n
3
•f.
n
73
y
~
—
D
j
~.
3
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/09/13
90/09/13
96/09/17
96/09/19
96/09/26
96/09/27
96/10/01
96/10/03
96/10/04
96/10/10
96/10/14
96/10/15
96/10/16
96/10/18
96/10/21
96/10/21
96/10/29
96/10/31
96/10/31
96/11
96/ 11/01
96/11/01
96/11/04
96/1 1/05
96/11/06
96/11/08
96/11/12
96/11/12
96/11/18
Author
RC
RC
RC
UC
EPA
ASCW-BE
UC
ASCW-BE
UC
MW
RC
EPA
ASCW-BE
Michael Work,
USEPA
ASCW-BE
MW
Michael Work,
USEPA
RC
UC
Radian
MW
MW
Davy International
Environmental
Division
RWQCB
ASCW-BE
UWQCB
RC
RC
RC
Addressee
CoE, Hunlsvillc
CEHNC
CEHNC, DDRW-
Tracy
ClilINC
DDRW-Tracy
RWQCB
CoE, Hunlsvillc
RWQCB
CEHNC
CEHNC
CEHNC
ASCW-BE
RWQCB, Karen
Bessette
Marshall Cloud
EPA, Michael Work
CoE, Hunlsvillc
ASCW-BE
ASCW-BE
Oil INI)
CoE, Hunlsville
CEHNC
CEHNC
CoE, Sacramento
ASCW-BE
CEIINC. DTSC.
RWQCB, EPA, RC
ASCW-BE
CEIINC
CEIINC
CEIINC
Subject
Groundwalcr Treatment Plant Monthly Performance Monitoring Report-August
Final Hazardous Material Storage Addition to Warehouse 28 Environmental Assessment
Technical Memorandum Maintenance of Existing Low Flow Pumps-Summary and Results
DDKW-Tracy Solidification Trcalabilily Study
Llr Draft Final CompreliensiveRI/FS/BRA/PP DDRW-Tracy, Aug 96
Monthly Monitoring Report for Aug 1-31, 1996
Final DDRW-Tracy Well Monitoring Program, 1995 Annual Monitoring Report
Llr to describe calcium carbonate scaling problem with air stripper and action taken to improve.
Draft Waste Water Treatment Plant Effluent Diversion, Drawings and Specifications
Draft Groundwater Treatment System Oplimi/alion Work Plan
Groundwaler Treatment Plant Monthly Performance Monitoring Report-September 1996
Fax questioning review period for ROD documents
Llr with Tracy Monthly Monitoring and Reporting Order 96 for Sep. 1996
DDRW-Tracy Extension, Comprehensive RI/FS
Ltr Proposed document extension dates.
Mceting/Telecons Conducted Oct 9, 10, 15, 18, 1996
Ltr DDRW-Tracy Extension for the Comprehensive RI/FS/PP/BRA
Draft Environmental Program Status Briefing Report October. 1996. DDRW-Tracy
Well Monitoring Program Quarterly Monitoring Report Third Quarter 1996 Sampling Round
Final Comprehensive Site-Wide Proposed Plan.
Final DDRW-Tracy Response to Coments on the Draft Final Comprehensive Rl/FS Nov 1996
Proposed Plan Information Booklet
Draft Project Work Plan, DDRW-Sharpe & Tracy, Petroleum Contaminated Soil Removal
F'ax Comprehensive RI/FS Documentation - COC's to be considered for clean up levels.
Fax Notice of Project MaiiagcrsMecling November 29-21, 1996
F'ax feedback on draft response to comment Comprehensive RI/FS Report
Groundwaler Treatment Plant Operation anil Maintenance Monthly Progress Report for October 1996
Gi omul walcr Treatment Plant O& M Monthly Progress Report lor Oct 1996, DDRW-Sliaipe/Tracy
Groumlwalcr Treatment Plant Monthly Performance Monitoring Report-October
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
%/ 11/21
96/1 1/25
96/1 1/26
96/11/26
96/1 1/27
96/1 1/27
96/11/27
96/11/27
96/12/02
96/12/02
96/12/10
96/12/12
96/12/13
96/12/13
96/12/13
96/12/13
96/12/16
96/12/17
96/12/18
96/12/18
96/12/18
96/12/19
96/12/19
96/12/19
96/12/19
96/12/21
%/!2/.1l
96/12/31
97/01/02
97/01/03
97/01/06
Author
MW
ASCW-BE
ASCW-BE
RC
RC
RC
RC
RC
EPA
RC
RC
RC
EPA
RC
RC
RWQCB
DISC, Jim Pinasco
RC
ASCW-BE
RC
RC
ASCW-BG
ASCW-BE
ASCW-BE
RC
MW
lil'A
Pad lie Legacy
RC
Radian
RC
Addressee
CEHNC
RWQCB
RWQCB, Karen
Bcsscllc
CEHNC
COHNC
CEHNC
CEHNC
CoE
ASCW-BE
CEHNC
CEHNC
CEHNC
ASCW-BE
CEHNC
CoE, Huntsville
ASCW-BE
DISC, Brian Davis
CoE
ASCW-
UPM/ASCW-Wti
CoE
CoE
RWQCB
SJCPHS
RWQCB
EPA. RWQCB,
DTSC
CEHNC
ASCW-UI;
DDRW-DDJC-
Tracy Silc
DTSC
CoE, Huntsville
CoE
Subject
Final Comprehensive Rl/FS, Appendix R: Comprehensive Site-Wide Baseline Risk Assessment Vol V
November 1996
Llr Tracy Monthly Report lor Monitoring and Reporting Order No. 96 for Ocl 1996
l.tr request variance of Waste Discharge Requirement for the groundwater pump & treat operation, Tracy
Revision Itr re: OUI Repairs and Enhancements Work Plan August 1996
Technical Memorandum of DDRW Tracy Storm Water Pond Investigation
Report of l;ield Activities and Results lor Samples Collected at (he DDRW-Tracy Storm Water Pond
Ltr Report of Field Activities and Results for Samples Collected at the DDRW-Tracy Storm Water Pond
Ltr Report of Field Activities and Results for Samples Collected at (he DDRW-Tracy Storm Water Pond
Ltr DDRW-Tracy Well Monitoring Program, Quarterly Monitoring Report
Final Waste Water Treatment Plant Effluent Diversion Drawings and Specifications November 1996
Environmental Master Plan Version 1.0, DDRW-Sharpe/Tracy, December 1996
Groundwater Treatment Systems Operation and Maintenance Monthly Update Report-November
Ltr EPA Comments on the Replacement Pages for the Comprehensive Rl/FS for DDRW-Tracy
Draft Well Monitoring Program 1996 Annual Monitoring Report
Project Manager's Meeting Minutes for Dec 4-5, 1996
RWQCB comments to Rl/FS for Tracy site
Llr DDRW-Tracy Draft Response to Draft Final Comprehensive RE/FS for Nov 96
Final Scale Study Report for DDRW-Sharpe and DDRW-Tracy
Proposed Rail Over Crossing al PDRW-San Joaquin, Tracy Site
November Monthly Treatment Plant Performance Monitoring Report (Well Monitoring)
November Monthly Treatment Plant Performance Monitoring Report (well Monitoring), DDRW-Tracy
Monthly Monitoring Report for Nov 1996
Ltr with Quarterly Monitoring Report
Tracy Monthly Monitoring and Reporting Order No. 96 for Nov 1996
Llr with Submission of Technical Memorandum for DDRW-Tracy Storm Water Pond Field Effort
Final Comprehensive Rl/FS Vol l-lll November 1996
I'iisl (Juailci 1997 ( imumlwalci Sampling livcnl/Keciiiiiiiicmlalioiis DDRW-Tracy
Final Archeological & Architectural Inventory & Evaluation fr the DDJC Tracy Site
Llr Preliminary Recommcntdations for 1997 Groundwater Monitoring Program DDRW-Tracy
Prelim Draft Well Monitoring Program Field Work Plan, DDRW-Sharpe/Tracy
Draft Acid Cleaning Work Plan (January 1997)
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
97/01/08
97/01/09
97/01/14
97/01/15
97/01/16
97/01/17
97/01/20
97/01/21
97/01/22
97/01/22
97/01/24
97/01/27
97/01/27
97/01/31
97/01/31
97/01/31
97/02/04
97/02/06
97/02/10
97/02/10
97/02/1 1
97/02/13
97/02/1 «
97/02/19
97/02/24
97/02/25
Author
RC
RC
DTSC
RC
RC
ASCW-BE
RC
RC
Davy Int.
EPA
EPA
ASCW-BE
RC
DDRW-DP
RC
RC
ASCW-BE
ASCW-BE
RC
RC
Radian
ASCW-BE
Radian
Peters Shorthand
Reporting
EPA
CoE, Sac
Addressee
CoE, Hunlsville
CoE, Hunlsville
ASCW-BE
CoE
CoE
RWQCB
CoE
CoE
CoE, Sacramento
ASCW-BE
ASCW-BE
RWQCB, Karen
Bessette
CoE
Public, residents
near Tracy
CoE, Hunlsville
CoE, Huntsville
Public
RWQCB
CoE, Huntsville
CoE, Hunlsville
CoE, Hunlsville
Tracy private well
residents
Coli, Ilimlsvillc
ASCW-BE
ASCW-BE
ASCW-BE
Subject
Draft Comprehensive Record of Decision for Tracy
Final Groundwater Treatment System Optimization Work Plan for DDRW-Sharpe/Tracy
Ltr comments Final Comp RI/FS, DDRW-Tracy
Groundwater Treatment Systems Operation & Maintenance Monthly Update Report-December
Ground water Treatment Plant Monthly Performance Monitoring Report - December 1996
Ltr request modification of the WDR. Change for Monuron or Diuron to meet achievable levcs.
Response to Comments on the DDRW-Tracy Well Monitoring Prog. Qlrly Mon Rep., Second Qrt 96 Samplling
Round & Tracy Well Monitoring Prog Qrt Mon. Rep, Third Qlr 96 Sampling Round
Final Site Remediation for the Sewage & Industrial Waste Lagoons, & the Industrial Waste Pipeline Drawing &.
Specifications January 97
Final Project Work Plan Sharpe/Tracy, Petroleum Contaminated Soil Removal
Draft Llr Finalization of Tracy Comp RI/FS, Comments on Overall Quality of Doc, Counsel Comments EPA-
Need for Res of Env Issue from Tech Memo on the Slorm Water Pond
Llr. I'inali/.ation of Tracy Comp RI/FS, Comments on Overall Quality of Doc., EPA Region 9 Counsel
Comments, Need for Resolution of Env Issue Raised in Tech Memo for Storm Water Pond
Cover llr for Tracy's monthly reporl for Monitoring & Reporting Order #96.
Final 100% Design Site Remediation for the Sewage & Industrial Waste Lagoons, & the Industrial Waste
Pipeline Design Analysis Report January 97
Special Announcement letter inviting public to the Proposed Plan Update and soliciting TRC members
Draft Site-Wide Comprehensive Record ol Decision for DDRW-Tracy
Draft Engineering Technical Memorandum OU-I Well Installation - January 1997
Mailer with Fact Sheet #2, the Proposed Plan info and the Special Announcement letter from the Commander
Transmiltal re Waste Discharge Requirements Order #96-122
Groundwaler Treatment Systems Operation & Maintenance Monthly Update Reporl - January
Final Acid Cleaning Work Plan for DDRW-Tracy
Draft Low-Flow Sampling System Installation Work Plan
Results for samples taken July - September 1996.
Jannaiy 1997 Monthly Tiealmcnl Plant Performance Monitoring Repoil (Well Monitoring) I)I)I(W Tiaey
Fclnuaiy 19, 1997 Meeting Minnies lor Pioposcil Plan for the Final Cleanup I'lojccl
Draft Annual Monitoring Report 1996 DDRW-Tracy
Final Warehouse 28 Well Replacement DDJC, Tracy Site
a
o
o
H
' f\
•J I
O
c.
o
o
3
•a
n
•s.
n
TO
a
—\
a.
o
ft
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
97/03/05
97/03/06
97/03/06
97/03/07
97/03/07
97/03/10
97/03/10
97/03/11
97/03/18
97/03/24
97/03/26
97/03/28
97/03/28
97/03/31
97/04/01
97/04/01
97/04/10
97/04/10
97/04/16
97/04/17
97/04/23
97/04/25
97/04/29
97/04/29
97/05/05
97/05/07
97/05/12
97/05/15
97/05/16
97/05/19
97/05/21
Author
ASCW-BE
Mont Watson
Mont Watson
K;uli;m
Kiid in n
Coll, Sac
Radian
ASCW-Bli
Radian
Radian
ASCW-BE
ASCW-BE
Riidian
Radian
ASCW-BE
DISC
ASCW-BE
Radian
Radian
ASCW-BE
Radian
ASCW-BE
Radian
Radian
El'A
ASCW-BE
Radian
Radian
Radian
CoO.S
EPA
Addressee
RWQCB
CoE, Huntsville
Coli, Huntsville
Cols, Iluiilsvillc
CoE, Huntsville
ASCW-BE
Coli, Huntsville
CoE, Huntsville
CoE, Hunts ville
CoE, Huntsville
CoE , H & CoE Sac
Real Est
DISC
Coli, Hunlsvillc
CoE, Hunlsville
RWQCB
ASCW-BE
Residents
CoE,H
CoE, H
Residents
CoE.S
RWQCB
CoE, H
CoE, H
ASCW-BE
TRC Members
ASCW-BE
Col-, II
CoE, H
ASCW-BE
ASCW-BE
Subject
Ltr to accompany Jan 97 Monthly Treatment Plant Performance Monitoring Report (Well Monitoring) DDRW-
Tracy
Response to comments am) slip sheets on O&M Manual
Response to comments & slip sheets on Extended Prove-out Report
Groundwalcr Treatment Systems Operation and Maintenance Monthly Update Report lor Dec 96
Acid (.'leaning Evaluation and Prove-Out, (Technical Memorandum)
Llr OU-I Contract Asvard
l;inal Well Monitoring Program l;ield Work Plan DDRW-Sharpe/Tracy
Response It) EPA Draft Annual Monitoring Report Comments
Ciroundwater Treatment Plant Monthly Performance Monitoring Report - February
Final Low-Mow Sampling System Installation Work Plan lor DDRW-Sharpc/Tracy
Llr DDRW Tracy Railroad Easement Requirements
Llr: Draft Record of Decision
Final Well Monitoring Program 1996 Quality Assurance Procedures Technical Memorandum
Preliminary Draft Groundwaler Treatment System Oplimi/alion Engineering Technical Memorandum, DDRW-
Sharpe/Tracy
Ltr with Tracy's monthly report for Monitoring & Reporting Order No. 96 for Feb. 1997
Ltr Extension for comments concerning the Draft Site-Wide Comprehensive ROD, DDRW-Tracy Site
Private Well Test Results for Oct - Dec 1996
Groundwater Treatment Systems Operation & Maintenance Monthly Update Report - March
Groundwater Treatment Plant Monthly Performance Monitoring Report - March 97
Ltr Test Results from Private Wells for Jan - Mar 1997
OU- 1 Groundwater Treatment System, Project Work Plan
Ltr Monthly Report lor Monitoring for March 1997
Well Monitoring Program Well Sampling Data Sheets Fourth Quarter 1996 Sampling Round
Well Monitoring Program 1996 Annual Monitoring Report
Ltr Five Year Review
Ltr TRC Meeting Date and Committee Member Acceptance
Map of Proposed Robertson Wells
(iroundwaler Treatment Systems Operation & Maintenance Monthly Update Report-April lor Sharpe & Tracy
Groundwater Treatment Plant Monthly Performance Monitoring Report - April
Site Remediation for the Sewage & Llnduslrial Waste Lagoons, and the Industrial Waste Pipeline. Scope &
Specifications
Llr Draft Comprehensive ROD (Feb 97). DDRW. FFA Schedule
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
Subject
97/00/05 Radian Coll, 11 Well Monitoring Program Quarterly Monitoring Report First Quarter 1997 Sampling Round (DDKW-Tracy-
June 1997)
97/05/29 ASCW-BE RWQCU Llr with Tracy Monitoring and Reporting Order No. 96 report lor April 1997
96/11/21 Kvaerncr Davy CoE, S Technical Proposal OU-1 Groundwater Treatment DDRW-Tracy
97/06/09 Radian ASCW-BE Ltr Second Quarter Analytical Results for Private Well & Tap Locations, Rose Properly
97/06/13 Kvaerner Davy CoE, S OU-1 Ground water Treatment System, Performance Monitoring Report-Plant I, May 1997
97/06/17 Radian CoE, H Groundwater Treatment Systems Opr & Maintenance Monthly Update Report for May 1997
97/06/30 Radian CoE, H Draft Design Site Remediation for the Sewage & Ind. Waste Lagoons and the Ind. Waste Pipeline,
Modification I
97/06/27 Radian CoE, H Draft Limited Sequestration System Operation Engineering Technical Memorandum
97/06/25 ASCW-BE Joe Rose Ltr test results of PWI from April to June 1997
97/06/23 ASCW-BE RWQCB Ltr with Tracy Monitoring and Reporting Order No. 96 report for May 1997
97/06/25 Radian CoE, H Information Repository Bioremediation Technology Evaluation Doc. Draft Technology Evaluation Work Plan
97/05/30 Radian CoE, H Revised Work Plan Addendum-Sampling of EW 30C. OU-I Well Installation (April 1996)
-------
APPENDIX B
FIGURES
-------
Pav«d
(Aspnall)
/ Railroad Tracks
SS050 .
* Fencr-ime /
8;oo2i
K |0 9)
X;-,.
• Sod Borwg location
3 Ptxjs* il Surface Ne« SiaUt:* S*un|>la location
i Pna>e it Sari-Gas Simple locjtion
;»»flh conc«m>aion$ a TCE «i yg I)
4. Phase il Sotf-CdS-Sod Bont^q ^encal Ptol^ Location
. ; Sorf GJS Sjmpte r^d
r^« Sod Gas 1soconc«ntroiK>n Cortour of fCE »i pgl
' T~ Edgeol Pjv»nw<
Locnon ft TCE tori fl
(0007)
10 4)
Railroad Tracks
Gravel Surface
Paved
(3i a \ •:**<"">«>
' - Bldg 257
.' (Damca.sneOI
Figure B-1.
JWMU I/Area 2 • Old Sewage Lagoons/
Ciim Storage Area TCE Concentrations
Detected in Soil-Gas Samples
Defense Depot San Joaquin - Tracy Site
-------
SB1I
WPIH COUPOUNO ' CONC
9 t " " P'E
SSO*7
DEPTH CPU POUND
COMPOUND _"' "COHC tm»fll
sous
01P1H CUUPOUHD CONC
DCPIH COMPOUND CONC UN»tg>
OCPTH. COMPOUND jCO«C_lM*Ji
-4«- Eir&hng. Mnnioring Well Location
Phase H UonlotmoWati Location
O Previous invesligaten Sod Bating Location
Phase I Sol Bonng Locahon
Phase il Soil Bormg Location
O Ptkdib 11 Surt*.fe'f4«ar Surlace Sample locdiion
Silt; Etoundary
Intttied Arcal Eitcnl ol PCE in $004
lnta»rfcd A/eal Eilcni ol TPH n Sorts
l«it«iiun A/eai Eitenlof lea
Fwite -7;-- Edge 01 Pa«ni*n1
J Tiark<>
ȤI14
OCPTH
;-ti
• 0
i J t [i.|
COMPOUND
MtP'y •*'• :>1
PC(
M«l
-------
IMJSA f IM29B
•f-
«*""•»•- . ' IU,
"T*
LM47A
LM94A
iiyjy . . . _ _ .
DEPTH COMPOUND cV**c 1,4 «9i
'i- B«"niJjarim'aetn« 04M
f •uO'jnrww ?*4
MIOIA1^*
^ SS059
' ^ o
&&!•
DEPTH ilOMPOUNO* '
I BwiiaiDHiuOfir
FlwwwWim
SSOi6
DEPTH COMPOUND "~CONc"lH9%q
BMvrMb)fkxxanin«n4 0 144
EUnfOUttiuo'trvnwM 0031
/ 4- LM10SA /
/ LM408 , "
QSSOS7 ^SB,5
SSOij
"DEPTH
i j
95
•4 5
COMPOUND
NC
NC
AncMOf-260
CONG (T^V)t
140
SWMU1
LU149*
LM30AUA T
S /X
y ~~ *O "*»* w * /
/ V SS°" "^-^ SSOM / SS9M /~»^ /
—t-r- ~^o^—• o / V-^'^
f ^J i ssou »«.^
/ •
/^ SWMU1 S8MI
B,?,.*'--^ SB145*
P«v«d
lAsphaoi
x OSSOM S8110 -v.^ SS0500 '/ \ J^
Lass. 'yf " />^-^^ / "^^
OtPTM COMPOUND CONC Ivvkg, / £^ ***J ^^
30 Dt*i*WDi*jQt«r«n«n« ' 01?2 y ^^7 • SB4M X,
^F
SSOS7
DEP^H CCV^OIINO CONC .^^
10 B«nn.*(*niniK*n* 3i /
B»o/c.oi"'.-4«r«n«fl* 164
Fiyfj"!'!*"* : ti
Ossosi
fEMM N^s
S8402 *
SB114 •
ssooo
DEPTH COMPOUND CONC ,pl
2 0 Ac«n«iMr>iwi« I&3 Ji
Ai«v«c«n* i 310 J
*.-« 99»OJ
ia«-^ iSoooj
w U Si»rt.n:« NuJi Sunjce Sj'
Of*'" COMPOUND CO»*C ^91.1
'I 1 Q«nft;l4>4i>1tvt**'* 1 U
B*n?nth-m,tri---^i« i JJ
rluui Jiilli^l* j H,
P«.nji>tl.t«r«« » ..>
O O
, SS061
/ . SB401
VNV set 13 •
w /
Xy
/^x.
??."«
: •: tattle. J.' -anthi Jem1*- 1 •
3«>ucii.rv'«n« * •
Buyoii'.^luoiirib-n* J •
&•!•.*.•')•• •cr*vl""'r * '
Cf-.y. .
rvr^r.":. i •n.iitf>".«.Bn« }
BHg 257
(Oenxjbstied)
COUC ,ugt;i
^oft
Figure B-3.
SWMU I/Area 2 • Old Sewage Lagoons/
Drum Storage Area SVOCs and
Pesticides/PCBs Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
-------
„
0 -t- LMJ9B
IM«AU..«SBIU t- ».
SB46*
LIM7A O
3. r
IMI01A "4-
Surtace TLM102A
LM104A /
. EUgeol .. •.. •-,.
• Pavement
S8I2 SS053 5847 ^ .
-
*-^ . SS057 '
t \' ! » SWVUt ^•*^._ uuwac"1* nsvi's
/ ^» . / SBUZ . . •"•» u» ' i.
/.,.' ^v^ :-.. S8», -*K .-l«H4.A^^ •S84» v.
°SS05S .
SB110 /
.
/•-...-
/"•-.
/ .
>x sain /••-.•; s.
^. • / .' n-
SB.,! / , , .XX *ti(Jj|»or Sdl r^*i ii.iinpk* LOCJIiUi
• S.HlMiwingl(i.:.it«uii
O f'twio II Surijt-L-.NoJt SudaLM San t4o Lo.:ali»i
P j Plus* »l S*'ilSjirr.tiJ
N 'SSOW / *•
Figure B-4.
SWMU 1/Area 2 - Old Sewage Lagoons/
Drum Storage Area Site Location Map
Defense Depot San Joaquin - Tracy Site
-------
Figure B-5.
Area 1 • Building 237
Constituents Detected in Soil, Soil Gas,
and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
S.«»rt! Mreilfjormtry Walw
-------
Railroad '
Tracks
Fenceline
Orchard
LM058AU
^Viy
SV146 "V$
LM059A
LM32A (sampled 10/18/94)
COMPOUND
PCE
TCE
Chromium, diss.
CONC. (ug/l)
120
59
32.8
SV145
SB79
SB26C
SV136Q
LM032AU •
LM033E
LM0348>
SB116
DEPTH
3.5
ITS
COMPOUND
Methylene chloride
TCE
bis(2-Ethylhexyl)phthalate
Matnyiene cnionde
TCE
CONC. (ug/Kg)
104
113
150J
98.9
SB115
DEPTH
5.0
9.5
18.0
COMPOUND
Methylene chloride
bis(2-Ethythexyl)phthalate
Methylene chloride
bis(2-Etnylhexyl)phthalate
Methylene chloride
bis(2-Ethylhexyl)phthalate
CONC. (ug/kg)
102
160 J
62.6
180 J
101
140 J
SB116
DEPTH
3.5
7.5
16.0
COMPOUND
PCE
NC
bis(2-Ethylhexyl)phthalate
CONC. (ug/kg)
70.5
190J
SB116
SV138 D \
SB118
Orchard
5s
\
SB119
DEPTH
5.0
8.0
20.0
COMPOUND
NC
NC
bis(2-Ethythexyl)phthalate
CONC. (|jg/kg)
140 J
EXPLANATION
Existing Monitoring Well Location
Soil Boring Location
Area Investigated During the Phase I Rl
Previous Investigation Soil-Gas Sample Location
• i
D
SB117
DEPTH
2.0
9.5
15.0;DUP
COMPOUND
PCE
TCE
bis(2-Ethylhexyl)phthalate
PCE
TCE
bis(2-Ethylhexyl)phthalate
PCE
TCE
bis(2-Ethylhexyl)phthalate
CONC. (ug/kg)
227
440
490 J
57.6
127
140 J
60.5; 72.3
106; 129
420 J
SB 120
DEPTH
2.5
10.0
COMPOUND
NC
NC
Soil Contamination Area
Former Drum Storage
Area
Area of Soil Contamination by PCE and/or TCE
0 50 100
SCALE IN FEET
N
Notes:
Sample results are shown for only those organic compounds and metals
detected at concentrations above established DDJC-Tracy background
levels.
NC = No constituents detected above laboratory reporting limit or
above background.
J.J15 = Data qualifier flags indicating the value is estimated.
DUP = Duplicate sample was collected for analysis; results
are listed to the right with normal sample results.
Figure B-6.
Constituents Detected in Soil and
Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson, 1996a
-------
EXPLANATION
r _^ AWM «i S
-------
/ometct
Sod Baring location (SWMU 4 sari
»«!• coNwclMt Irotn the
only)
0 Ptus* I SunMee'Nvv Surtact Sanv«* LncJton
A PlUMfli
Figure B-6.
SWMU 4 - Storm Drain Lagoon
Organic Constituents and Metals Detected in
Soil and Sediment Samples
Defense Depot San Joaquin - Tracy Site
-------
Si
I
Figure 0-9.
SWMU 4 - Storm Drain Lagoon
Constituents Detected in Surface
Water and Groundwater Samples
Defense Cepot San Joaquin • Tracy Site
-------
«p E using Monurmg Wtll LoCilon
1 So- Botwg location (SWMU 4 sod bo.ng
i sanpm ««t coBriOM trom the sufi3;e only)
• PTUM I Suiiact No* Suflacv Sjn^t* Loctfun
• Hand Aum LocMon 118" on)
• HPO-108 MPO-116- .HfO-104
9WH1« COMPOUND COMC.|M9««
• HPO-ItT\ ; \
Figure B-10.
SWMU 4 • Slorm Drain Lagoon
Analytes Delected in Soil at Depth
Defense Depot San Joaquin - Tracy Site
-------
SB 159
DEPTH
COMPOUND
CONC. (pg/kg)
9.5 : ODD
! DDE
DDT
Chlorpynlos
Endrm
Gamma-BHC (Lmdane)
Heptachlor
1090
62
564
281
567
29.4
23
13.0
2.4.5-T
ODD
DDE
15.5 2.4.5-T
ODD
DDE
. Dialdnn
i Endnn
I Gamma-BHC (Lmdane)
i Heplachlor
74.8
22.2
3.06
58.5
1.53
1 01
12.7
0.895
56
3.33
'.M0087B (Sampled 1 0/13/941
COMPOUND
CONC.
-------
•\ .
''
iAu>nan>
1 V. tMlfc'AU
1
C ' SV63 C
\
.
^ a
r
! w , MIJ-'M
i ^ M*t« rcM»omc 'co*: |^^
1 ^ ^^^^ • i»«**.«**no »«.*••
i ' --' x***"C •• :.'•
: •-•-• i .TSC?0£I ' .^_' 'nr0""0
I - " ' i I!*»I)" ' • »•
p •,-:...•;.. '.;. ^^^i^oc. .._ ', - "
C'».. i«v«^>
t li:
v ':..««*, o. . ou-n M o. ' --*'i^r~l ofn"-*0 T* "•'"" "«"*~*~ ~tn~ «.'••
m,... - „.,..,,„,,,,. ,^,.. ,.. .TV»HI «T , •• o~-.-...,o :
TSO?0» 1 , PIT*^"^^^ sn.-'Me
i ^i 1^,^ r> ^ U"H ' COMfOU^ [CO«K t^^i
. ~-^-.^^' '. • (M.«*»j»leo »».<*>!
Tf.nch ^^^ 1 If 1 . 1 T
7-1 ^^^^ 5*.'.'.^-»
i ^S t»i»i'Ll59ll*f9y50 ^cpNt 1,4^1
< ". . b«n««wtlO JI^IP'
1
1
I 1
1 b*i,j is
..."> >.tl-
| : !
1 I -!
! '
1
j rrmiiouwt.'" -rw*c .-i
! . **! (WWM*»IVMMMH i«i
| h-— 1 U
> ! •»v»^' i ft • K
; i (r--.
i : i /
! ....I." i ! wnm
It, .': / /
I ='• " _..--""8Se
,-'' me ..,
T
..... ... j
i
. £ .I-LA»,iT.O'J ' Ho<**
• » SlHlH.'1'l Li- «-.." ^ , Noui(
Q »', >' .(cult l., .!••-• ?tU ItMOt
*.i.-l.i,y r.tirfn'ud'i |C.. t i.. rth.i' ""^
• !....» ( >,.. S-M.. LI^-I..». • °UP "Ow**1
i -".-.. -:-::::;;::"—"' s
*' (*l|'r"I '"* * ( ^- • 5^
'""""'
1
:i»* 1
J ft a BKJA»*IMBM
t DDO
(DOC
(DOT
/ 0^-
/ UM«
/ 1 D»««*w>Ttb
y' IDO I»»C
M OO^j *M>-i.*v>»|lVMMM '
1 DOD
, 00* ;
looi
MU
X
~*"*'-
^
-1
OHC ,^»y,
•r
«.«
J in
*rf r
3**».fl
JV.NT
MOMC
••: ' i:
toC SU.
HL '» '
LJ
18*1')
OCX**' 1 COM*1>WNL * JCCVtL. -w9*rf.
TO T»et>-«Xyei..,iw«Mie~'
OOf ' »r'
OO' »-.
[bnWwvitb ; ii. '• '
^^•^ tOC !•**?.*»!»*••'»'•*•«***' "
1 DOO •- '
. n i • "
1 001 . ""
' OHM* »•'
1
^LWW
\
-t-
*• LU43*
0 ^\
E
ii
!
!
1
i
i
i
i
i
> ,
«M Mm»M •** i ••rim to* •n*r>»n fM^it •*• MMd to *<• >^n »"> *wy>n« WTO* ••«<•<»
Figure B-1 2.
SWMU 7 (North Araa) - Burn Pit No. 1
Organic Constituents Detected in Surface Soil
and Groundwater Samples
Defense Depot San Joaquin - Tracy
-------
S-iSOiS
OE»TH COMPOUND CCNC ,*•; h*
S 0 twi EifvtttcyijphiMUt* 'jO
DDO «*4
DOC *U
DOT 7i 4
0**a« 7 49
2.4. a ..«
IMO !7»cc
0«3*mFui*n TEO 19. 10 '
tOO ODD i hj
OK ' i8
oor m
D*kififi 1 fl*
2.4 0 J 26
Iron 3 SI i iO;
MCK* Si '00
150 TPM-D 120 JCO
DOO 1 IS
DOT 413
4
's
j
r
i
1
T
*
4
I
t
T
t
t
;
Urn
'PIT
s
Mvfd
Bttg 19
PIVHI
Ci^*-* COMPO..-JO »:ot*; .^hgi
4-. r.ttnFuiin TCQ 2b« i3'
Tiench 7-2
'S«*Figur*636-Slor umpt* .
Bullions *nd *n*JyHc*l mft^s)
X
/""* x
x''/ X^'
»•' / /
•B162
*
/
/
Q
\
N
/
IUOKAU
f
couPOf^o com «<»r.
»,»
S^lftl
DEPTH COMPOUND CONC.^-I
90 XlKXO 91
SBI8
V
I
•if
|5/
M!
/*>1TG//
/
V~ Tt«n<* 7-3
(So Hgm !.]«-< kx unvk
bulkxa ino «n«iytul inuU)
Sod Bonn] Location
SWil Suri
L«jt«on
G PIVVHXJS In vtf \ligjlion Sod-Cus S^mpi* CoCd
^"_7J LoCJlnn ut Bun P-t B^chtiBert Pi«» lu I9S»
~ {A* bi*1 Dr^wnig tSSl)
,' ' '*,' Locjhon of Bum Pa Entiiiyjm iy5i
(A»-bu« Otawiig i^SlI
~JJ J A/««» InvwklHj^iMj Lgnivj Ptuw I Hi
a
sow
'\\
si
SS8010
sseoio
OEPTM COMPOUND COM: w
17$ Jetton* '4
t
SB092 S8090
Figure B-13.
SWMU 7 - (South Area) - Burn Pit No. 1
Constituents Detected in Soil and
Groundwater Samples
Defense Depot San Joaquin - Tracy Site
-------
Figure B-14.
SWMU 8 - Burn Pit No. 2
Constituents Detected in Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
-------
FEtt
SB4094M97A SO l^cl Eau ,A(
30
I
I
60
70
_J—
[ Gravel Cover]
O £§<=•
otf
r
\
\
V-«.
\
\
\
I
\
\
".'.-I \
(.IMMHMU C1MC W*QI
V*b'i»««AMa 77I<
LEGEND
Sample Location
d Roundaiy of
Sly '"• una (SU> to YK s/3 brown unj pied fm« occ
16 modwm p^wd «pp 20 30*. fut«k. ixm-ptaslK moist kXM«
S^nd'sJI jfavel miturv m ap()foiiimat*ty MJUAI praf>orti ctptl' s
F.K?
0«tvB.1i(i Uv»i wid-gtavH noriuiti krss giawl ttian
Mtnvf niurtt mor«- dW4 (ti*in Move inchX>il>QConcrtH
-------
(Apptoi)
I jiitullb- it Lltr^U ITVIt^thll
F.«2
! :\4"r. till l.iyer -jt*l gi,.v.:l nuiliiii; *dt\
-tiflnt')t.tr
.-ul t.nK let'*,
Figure B-16.
SWMU ] - Trench 8-2
Organic Constituents and Metals
Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
St«tftc
-------
i -f
V E lotMtn IRM Sv«w
-------
i""^1
- >
Vu
t.'*»*H*iD
n:
NC
ti:[
:o»* ,.»N»
I/
•*••••
18«t(
ucrtu
10
ibO
110
coitf(*«>
,'mr
1C(
P*«k.M»i«*iiral
J »O**i«Ji»irt
M^-tftrlHiCM**!*
IIM: im»g>
VJMXIJ*
' It
; J*>
?tM
lit r*ajn
_ tt&lv)ated Our**) Phas« I Rl
f- Eibbog Mormo
System gittachon We*
Wff
CtPlM COMMHMO
• 0 Om ' &#&*
Cl**L 1^*4
»H NC
, /-••:;-;• - |-~
X »»"aT-.-,~ • • ' 3
/•.;.af -.•.•-• £:
uaoit
OIPIM
4l
COMKAJND
'Ct*j»t-w
ClM»«M
Ow-
l««4
A«
C'JNC «««»«
Ol»
«ot*
»•!*
»*• •
Jl»
HMJl
Ut^-'ti
* ti
inu ti.«
H'l
•(.!•- .•.:.!
Iff
Mv-n
S>.k«n
I*-JV t t^*-.^ir*,»«U*
*%«h,.l*>A>«
Cjrtm.-1-.ilt.B
«nn
Itflf
UMAiirfti
1.wt
l*w^ 1 tlr«.-i*HJ >•-•*-•*
M«O
;.. -f*. ii«j*-ii
/;
-•» iu>
i i*. 10*
HC 'j«0
NT tw
w: JW
I7f «»
•Ci-a/ji*
NC.!«0
1« JOO NC
,'«
/M>
Figure 8-18.
SWMU 20 • Above C-aund Solvent Tank
SWMU -' • Building 28 Recoup Operation and
Area 1 Building 10 Constituents Delected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Sou* UolvnxKV IVjIKO 19V&I
-------
/ } A(^rui>rMtv Eitenl ut V
l^X |iLi!.(i*f«l MIN^U nJ**r,H(
I'lviM) I Mnri4(i«N.g Wi.'l _
Plus* II Mmrtunng Wv<
O Plu*.- II HYttri>|i««:h Lit
8 ECO-1; t'tritt DiwiHttr Suit S.in(Jt' Itxition
Figure B-19.
SWMU 24 - Building 247 Petroleum Laboratory
Waste Oil Tank
Organic Constituents and Metals Detected
in Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
-------
-UU ™ t i , I 1 •—
/|.» ir I ., -. / /
< \'. •-, '•'•. / /usTsner
^ \'« ». . *".. •/ /•
Phase I Mo*i*txiig W«U L
So' Bonng location
PTiaM I HycfcopuflCti
Q Phase til Hydropunch Locition
CPT Locatcn
Q PTCVIXM invoM^jlon ScMKUt S*»rpl« Loctfon
/.. ••. Fdua.mconoK.
> « '. ___——" ™'
f") Fomw/D«inofc«r**a BuMng (tta Klab ol
J.Jli . Out quatfiw ll«9t »nd oxnirwru fv tn
01 Itjl J-XJ
OOP
't "flrt <*4n rxn-*l
Figure B-20.
SWMU 27 Building 206 - Rouncnouse Sump
and Area 1 Building 206
Constituents Detected in Surface Soil and
Soil Boring Samples
Defense Depot San Joaquin • Tracy Sile
-------
EXPLANATION
Phase I Monitoring Well Location
Soil Boring Location
Phase I Hydropunch Location
Phase 111 Hydropunch Location
CPT Location (Approximate)
Previous Investigation Soil-Gas Sample Location
Phase II Slant Soil Boring Location
Approximate area where strong hydrocarbon
odors and staining were reported during
pavement removal
Former Stairs
9
o
D
Former/Demolished Building (the slab of
Building 206 is still intact)
Edge of Pavement
Gravel Surface
Former Service Pit lor UST Site 7
Filled with Concrete v
x \
LM117A
X
X
X
X
X
CPT011
SB476
DEPTH
5.0
10.0
15.0
COMPOUND
NC
NC
Dt-n-bulylphthalala
CONC. (pg/kg)
130
eDnflralD
'
SB475
SB47S
DEPTH
5.0
1O.O
15.0'OUP
COMPOUND
Di-n-butylphthalat»
NC
Di-n-butylphlhalate
CONC. (vgntg)
770
450;S90
SB446
DEPTH
3.0
5.0
9.5
COMPOUND
bi3(2-Ethyti«xyl)phmalatB
bis(2-Ethy»iexvl)phthalal8
Dc-n^utytphthalate
brafZ-EtfiymexyllphBialale
Di-n-buty1phlhalal»
CONC. (tigfeg)
130
5OO
100
270
420
SB474
SB474
DEPTH
5.0
10.0
15.O
COMPOUND
NC
NC
NC
SB449
DEPTH
2.0
8.0
14.0
COMPOUND
NC
bis(2-Ethytha>cyl)ph!halata
bis(2-E1hylhexyl)phftaUit»
CONC. (M9*g)
1,700
13O
SB44B
DEPTH
2.0
8.0
14.0
COMPOUND
bis(2-Etfiy1heiyl)phthalata
NC
Di-n-butylphlhalata
CONC. (pg/Kg)
150
95.0
SB450
D6PTH
2.0
8.0
14.0
COMPOUND
NC
NC
NC
12.5
55i
SCALE IN FEET
25
Note:
NC = No constituents detected above laboratory
reporting limit or above background.
OUP = Duplicate sample was collected for analysis;
results are listed with normal sample results
Figure B-21.
SWMU 27 Building 206 Roundhouse Sump
and Area 1 Building 206 Constituents
Detected in Soil Boring Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson, 1996a
-------
CPT009
• ..' ' Fom» 5*.,ct P< Xx UST SM 7
'•. '• '/ • '•• -*** ic«,«.sttb)
* * y/ ca«o *• x^
X
C PlASv IMirfxioiHHj W.-tlLw-tUill
• bod Bomtg LuLitlimi
f, Pia.s« < HyaiuptMicli Loiaton
( . Phuv III HydrofNRicli Loulm
O CP1 Location (ApfNOitfnut)
t) Prrwus tnv«Ui9*luti So^C^. S^n^k- Lo
j Htw** II Sum Su4 Buf»
odon and siawwig wt*w (•ponmi du>'>g
pavvnH
SlMk
Bu*)v>g 206 B till
JJiS • 0«» Qirt*-*' tu^i Mid uuwMnU Fw •Pt
NC • M> eo*»t«j«iu a»fa«t»i MXMM KUft
* tft« hJ*OC«rbc- r jn»rn p rf-.»n' m m* Mite*- (Vi-»M-H <•> UI
Figure B-22.
SWUU 2? Building 206 - Roundhouse Sump
and Area 1 Building 206
Constituents Detected in Groundwater Samples
Defense Depot San Joaquin - Tracy Site
-------
SB 128
DEPTH
3.5
8.0
25.5
COMPOUND
Di-n-butyl phthalate
NC
NC
CONC. (ug/kg)
1 6.000 J
DEPTH
B.O
12.0
25.5
COMPOUND
Di-n-butyl phlhalate
bis(2-Ethylhexyl)phthalate
Di-n-butyl phthalate
bis(2-Ethylhexyl)phthalate
Di-n-butyl phthalate
bis(2-Ethylhexyl)phthalate
CONC.
-------
Figure 8-24.
Surface Soil Results (0-0.5 Feet bgs)
Oufense Depot San Joaquin - Tracy Silo
-------
£C»:f MTfl
yv
«
o :
! o
V-- |( c
:o "
O •:••'
o i
o .••'•'
COHPO^NO CONC 1
COMPOUW) . N: I
I
fi
I ! .,/•
5 1 /•
,<- '•>-
.,
1 /• *~
EXPLANATION
Q Pnase » SwUh-c-Nedt s
Scui Saiitpte Lo»:ai»on$
• | NnowjtttaltitJ Sttclix Sd
M* > Nj C'.risIUi..1 ti J«HiCl*i1 «tx,v« MbdJi.'y i«fOitii*j him) Of
Figure B-25.
Near Surface Soil Results
(0.5-1.5/2.0 Feet bgs)
Defense Depot San Joaquin • Tracy Site
-------
i? MoiMoruig W«f Loufton
Prus« it MOMOIH.J w«ia
Plus* I Mniriuiw) Well I tx^
IflM
• So-l 6oniig LOCJJCO
| PhuM ll S«d>n«nt tjufUC
^ Pluw II StfOvwni Sarr^M LucJI
0 Pr«vmu» SwJvnem Smlac* WJiet sampt* LUCJUO*
Q PIWVOU& liivttstKfjboi) So4-Gu S*iv»* LocatKXi
Q PIUM I SuiUc* Soil Sifrpl* I
3 mw
D
I
I 1 5«««g««oainoujlnjiL<70<»»
^ umXDM c,av« Sui>»
\_ __>^_»| " S
" ^^ r
II 1> I *l II I I -l-(-s-J.-,Jw lV-I- • H^l - I- I I—«— I I- I--I— I
' Figure B-26.
SWMU 2,SWMU 3 - Present Sewage Lagoons/
Industrial Lagoons
Organic Constituents Detected in Soil and
Sediment Samples
Defense Depot San Joaquin - Tracy Site
-------
EXPLANATION
^ormg W«fl
•^ PtUM II UoftfunnQ Wafl Local on
- Pruu I UorakMnf W^l Louliun (
V imi Syxlcm Citi4CtK>n Wei Localcn
• So' Boring Location
f PTUM it StfOmeft-Surtac* Waief Sanyxe Location
( PhaM II Swkntn Samp*« Localbn
0 PMVDUS S*<*m«*Si*)ac« W*t«i Sa(T^ri« Location
O Pt«v«Ju» InMSl^Abon So*-Ga» Samplt Location
Q PTWM t Surface So4 Sairpta Looion
^ IRM EtDuw« InM
Plant Emuvil Intel
EflkNrt mtat
Dbctttrgt (torn cnohng opw afon
St«40t and Indusiral Lagoons
-7^— Edg* ol Pavefntrt
camnwrt* Mt TM* B 1.
II.,.
Ra*oaO Tuck
I
s
1 1 I'lM < .IMM .,!*, ! <«f ,n>|k'll
1 . .Hi V« ' .1
/
/
/
/
/ SWMU3EA5!
I llnKl)
/
;'(* m . . Mf.H«jr M. •• .-j.
&«., 11 )• '
0........ *J.
/-* I- "I
'\Us
\
\
\
\
Figure B-27.
SWMU 2/SWMU 3 - Present Sewage
lagoons/Industrial Lagoon*
Metals Detected in Soil and Sediment Samples
Defense Depot San Joaquin - Tracy Site
SMUTCH M.'drfortwrfy Wjt&oti t
-------
emlng Uonumg WM locjuon
Pn>M II Monttng Wrt location
Phaa* I Uaniang w«l Location (MIH WM Locator)
Sol Botng LocUnn
PhjM II S«limai«/Sulaci
Pfus* II S«Jimefl SwrvW Loccton
Oi— Lin« ol Equal ConcwWMon MMC) on
/ 1M4 AmuH Monrtomg Ftopon
$•«<)• Ti«atmtfll Plun £ltu»r« InM
NTRATION
OCTOBER '5rJ
UPPER MO«IZCN
Extent otDwvtitPtutntftMkMl on OctOtwi
dali I9W Afiu4lMon«uttfviR<.paft
*HJ -vJustrut lagooni
-,— Eil-j» olPs
O'"! I^CM aig*r< tcmcOjVj* JO*) mMlll
4—1-1- » . |
>WMU 3 EAST
.irwd)
\
\
\
\
\
>c
^Wi-U?
Dtl'TH M)NB->l*>ltl 1,'M1 ...di
>T. rrftn Oi «<
not o oiu
r>wi»*i o f^f
S*-/w* i .')
? < r> .1 u
r*««. !> MI
N
Ratbud Tiach
SWMU
Const!
Defe
Figure B-28.
SWMU 2/SWMU 3 • Present Sewage Lagoons/
Industrial Lagoons
Constituents Detected in Surface Water and
Groundwater Samples
Defense Depot San Joaquin -Tracy Site
$• . *
-------
C IWPL iJUHiote
(J. ? i
-.-• Mcftnonal LifetX
Ounng IWF\ kwesfigatcvt
EustngUomonng WetLoubon
t «ngm* vx) aracfeon ot fww iMrah «J«nMt*a ajurg *>• ttNHi nt
unM u F* t» kn*t ••>• noi ***wg»r»d
»**» •>• Ho*n lot onlyim»«o)gan« compound* »nd
Oroo«l*v
not po«*a
Figure B-29.
SWMU 33 - Industrial Waste Pipeline
Constituents Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
-------
SB 157
DEPTH
3.0
7.5.Dup
14.5
I COMPOUND ! CONC. (mg/kg)
i Nickel i 59.9
NC; NC
i NC
I <>
x^*L
X SB157 • *-^^ JII
S
L.:
LM016AA (Sampled 12/8/94)
COMPOUND CONC. • (ug/l)
TCF
LM016AUA
SB 156
DEPTH
3.0
9.0
COMPOUND
NC
NC
15.0 NC
SB158
DEPTH : COMPOUND
8.0
NC
14.5
NC
n
Paved (Asphalt)
\ 58213
EXPLANATION
•v-
--
L,__
D
Existing Monitoring Well Location
Phase I Monitoring Well Location
(Abandoned)
Soil Boring Location
Phase I Hydropunch Location
Site Boundary
Previous Investigation Soil-Gas
Sample Location
IWPL Location
Edge of Pavement
Notes.
Sample results are shown for only those organic compounds and metals
detected at concentrations above established DDJC-Tracy background
levels in soils.
Detections of phlhalates are not shown on this figure because they are
not considered indicative ot contamination from this site.
NC = No constituents detected above laboratory reporting limit or above
background.
DUP = Duplicate samples were collected for analysis, results are listed
to the right with normal sample results.
0 ..^12-5 ._25
SCALE IN FEET
Figure B-30.
SWMU 5 - Old Industrial Lagoon, Building 255
Constituents Detected in Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source. Montgomery Watson. 1
-------
SB413
DEPTH
5.0
120
170
' COMPOUND
:NC
NC
NC
SB 167
DEPTH
2.5
8.0
15.4
COMPOUND CONC.
Chromium
Molybdenum
img/kgj
50.1
i 1.41
NC
Beryllium
1.03
•Tr'j
-
\
\
SB.167
Gravel Surface , ..y-
SB 166
DEPTH
45
10.5
15.5
COMPOUND CONC.
Molybdenum
Methylene chloride
Molybdenum
imo/'kg]
1 48
0.104
1 55
\
LM096A (Sampled 10/1294)
COMPOUND
CONC. iuol]
NC
Paved (Asphalt)
SB 137
SB168
DEPTH COMPOUND CONC.
imo/'koj
V5 ' Beryllium
1.136.5
15.5: Dup i Beryllium
, Chromium
' Molybdenum
NC: 1.7
NC. 55
NC: 1.7
SS078/SS079-4
EXPLANATION
j Approximate Site Boundary
Existing Monitoring Well Location
Soil Boring Location
Phase II Surface/Near Surface
Sample Location
; Phase II Geophysical Transect
Previous Investigation Soil-Gas
Sample Location
Notes:
Sample results are shown tor only those organic compounds and metals
detected at concentrations above established DDJC-Tracy background
levels in soils.
NC = No constituents detected above laboratory reporting limit or above
background.
DUP = Duplicate samples were collected tor analysis, results are listed
to the right with normal sample results.
Figure B-31.
SWMU 9 - Subsistence Waste Pit
Organic Constituents and Metals Detected in
Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
Bldg.213
Newly Paved in 1995
(asphalt)
Former Edge of Pavement
SWMU 10
TS007
SB415
DEPTH
5.0
13.0
20.0
COMPOUND CONC. (ug/kg)
NC
NC
Dielhylphthalale 14OJ11
^bw^
~---^
DEPTH COMPOUND CONC. mg/kg
Sample results are shown for only those organic compounds and metals
detected at concentrations above established DDJC-Tracy background
levels in soils.
NC = No constituents detected above laboratory reporting limit or above
background.
J.J15 =Data Qualifier flags and comments. For an explanation of flags
and comments, see Table B-1
D
Existing Monitoring Well Location
Phase I Soil Boring Location
Phase I Surface Sample Location
Phase I Trench
Soil Boring Location
Phase II Trench
Trench Soil Sample
Mound (1952 Aerial Photos)
and Scar (1965 Aerial Photos)
Excavation (1957 Aerial Photos)
Phase II Geophysical Investigation
Area of Phase I Investigation
Previous Investigation Soil-Gas
Sample Location
Figure B-32.
SWMU 10 - Medical Waste Burial Pit
Organic Constituents and Metals Detected
in Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
SB171
Ol/
SG640 V
TSG26 .
TSG25
Trench 10A-3
SB170 SB172*
Trench 10A-1
SG07
Trench 10A-2
SB63
Trench 10A-4
SB42°
SB173
«»
--/
SB61
TSG31
seee
Existing Monitoring Well
O Previous Investigation Soil Boring
9 Soil Boring Location
rj Previous Investigation Soil-Gas Sample
• Phase II Trench Sample
- Phase II
[""I Phase II Geophysical
| j Approximate Extent of Disposal
SB64
SB62
so
SCALE IN FEET
icx>
Figure B-33.
SWMU 10A - Possible Medical
Waste Burial Pits Site Location Map
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
LM022A -€>•
LM021A-$-
'SB169
SB171,
SB 180 »€
SB179 •
SB178 •
SB172
• 'SB170
SWMU 10A
i
i
jf
i
i
i
/
SB 173
SB 174
-£-
®
f~ZI
Previous Investigation Soil-Gas
Sample Location
Existing Monitoring Well Location
Soil Boring Location
Phase I Hydropunch Location
Phase I Surlace/near
surface sample location
Phase I Geophysical Investigation
Approximate Site Boundary
I
S
100
3CAL?IN FEET
200
Figure B-34.
SWMU 11 - Burial of Lime/Foot/Bath
Site Location Map
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
COMPOUND ; CONG. (M9/I)
NC
EXPLANATION
• Soil Boring Location
Phase I Hydropunch Location
---] Approximate Site Boundary
NC = No constituents detected aoove laboratory reporting
limit or above background.
Figure B-35.
SWMU 12 - Embalming Fluid Dump
Constituents Detected in Soil and
Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
2550
SCALE IN FEET
-------
SS002
SB183*
SB47a'SB472R
DEPTH
5.0
1SO:Dup
25.0: Dup
30.5
COMPOUND
Di-n-butylphmalale
CONC. (uo'ka)
160 J11
Di-n-buiyiphmalate 110J11:NC
TPH-MO i 106.000 JI6;NC
Oi-n -butyl phlhalata
180 J11
EXPLANATION
Approximate Extent of White Powder
Product Based on Phase II Trenches
and Soil Borings (2 to 9 feet thick from
5 to 14feetbgs)
Approximate Extent of Lube Oil
(Black Tar-Like Material) Based on
Phase I Soil Borings and Phase II
Trenches (1 to 2 feet thick from
2 to 4 feet bgs)
Existing Monitoring Well Location
Soil Boring Location
Trench Location
Phase II Geophysical Investigation
Water Pipeline
Unpaved
SB485/SB485R
DEPTH
15.0
25.0
COMPOUND
bis( 2-Efhylh8xyl tphthalate
NC
i CONC. iM9*g>
i 3.600 J11
I
Trench 14-5
LM98A (Sampled 10/11-941
COMPOUND
CONC.
SWMU 14
Trench 14-6 |
. SB473 I
Trench 14-3
LM013A
COMPOUND
CONC. iug/Vg)
, NC
SB18!
DEPTH
COMPOUND
CONC.
3.0
; NC
bisi2-E»ylrtexyt|phrhalate
LM013A (Sampled
COMPOUND
NC |
10/12/94)
CONC. i'pg/1)
SB473/SB473R
DEPTH
5.0
150
30.0
COMPOUND
Di-n-butylphthalate
NC
Boron
1 CONC. l)jg/Kg)
1 110J11
I
i 25.100
i
25
50
SCALE IN FEET
Notes:
Concentrations of oil ana grease are not shown on this figure because they
are not considered indicative of contamination from this site.
NC = No constituents detected above laboratory reporting limit or above
background.
, J15 =Dala qualifier flags and comments. For an explanation of flags
ano comments 5eeTaoleB-t
Figure B-36.
SWMU 14 - Lube Oil Dump
Organic Constituents and Metals Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
SB 183
DEPTH COMPOUND
3.5
8.0
NC
NC
29.5 NC
SWMU15
LM099A (Sampled 1CV11/94)
COMPOUND
EXPLANATION
-e-
•
D
c:::,
— <
—
Existing Monitoring Well Location
Soil Boring Location
Previous Investigation Soil-Gas
Sample Location
Approximate Site Boundary
Embankment (Cut Slope)
Water Line
Note:
NC = No constituents detected above laboratory reporting
limit or above background.
SCALE IN FEET
Figure B-37.
SWMU 15 - Pesticide Waste Trench
Constituents Detected in Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
SB81
SB 185
DEPTH
3.5: Dup
COMPOUND CONC. (mg/kg)
Dioxins/Furans TEQ i NC: 3.1 x 10-8
5.0: Dup ' Beryllium
: Dieldrm
8.5 i Beryllium
16.5
Beryllium
1.42: 1.59
NC: 0.0091
1.22
1.99
Chromium . 59.3
Cobalt 18.6
! Copper
• Iron
' Magnesium
Molybdenum
Nickel
Vanadium
47.7
38.200 J
13.200
1.51
68
65.9
Zinc I 90.9
-"7*
^"-4
Vr~
\£
Yrt
1 2
jz
/'^
/'^f
-f£~.
•isci-
'.*££
:*^.
Fenced Area
LM023A (Sampled 10/14/94)
COMPOUND
NC
Bldg. 258
LM023A
fefe
Wip
^
SB 186
DEPTH COMPOUND * CONC. (mg/kg)
1.0 ODD
Beryllium
4.5 Beryllium
Boron
0.149
1.16
1.51
27.8
15.0 Dioxins/Furans TEQ ' 14X10"8
Beryllium 2.6
Chromium 61 4
Cobalt 19.2
Copper , 49.6
Iron
Lead
Magnesium
39.600 J
154
13.500
Manganese 858
Mercury 0.282
Molybdenum 1.77
Nickel 72
! Vanadium
Zinc
70.9
94.2
LM100A (Sampled 10/17/94)
COMPOUND
NC
Paved
(Asphalt)
LM100AU
/ x>>
/ SWMU 16 V
SB 187
DEPTH
4.0
8.5
15.0
COMPOUND CONC. (pg/kg)
Beryllium . 1.390
Dioxins/Furans TEQ 4.7xlO's
Beryllium
Dioxins/Furans TEQ
Beryllium
1.510 j
1.5 x10'5 '
1.580
SB185
' D SG17
Edge of Pavement
EXPLANATION
•&
•
D
,
'__»_' Approximate Site Boundary
Existing Monitoring Well Location
Soil Boring Location
Previous Investigation
Soil-Gas Sample Location
25 50
i
SCALE IN FEET
D SG19
Railroad Tracks
Gravel Surface
D SG41
Notes:
Sample results are shown for only those organic compounds and
metals detected at concentrations above established DDJC-Tracy
background levels.
TEQ = oxiciry Equivalent (expressed as ug/kg and ug/l of
2,3.7.8-tetrachlorodibenzo-p-dioxin(2.3.7.8-TCDD])
for soil and water, respectively.
NC = No constituents detected above laboratory reporting
limit or above background.
DUP = Duplicate sample was collected for analysis: results are
listed 10 the right with normal sample results.
Figure B-38.
SWMU 16 - Possible Hazardous Waste Disposal Area
Site Location Map and Constituents Detected in
Soil and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
Pavement
(Asphalt)
HP029
SWMU21
SB1
SV168
HP029 (Sampled 06/25/93)
COMPOUND
• CONC. (ug/l)
Barium, diss.
Iron. diss.
257
SB188
DEPTH
3.0; Dup
9.0
16.0
COMPOUND
Beryllium
NC
CONC. (mg/kg)
1.77: 1.82
NC :
Bldg. 201
EXPLANATION
•
D
©
Soil Boring Location
Previous Investigation Soil-Gas
Sample Location
Phase 1 Hydropunch Location
Site Boundary (Concrete Patch)
Notes:
NC = No constituents detected above laboratory reporting
limit or above background.
Sample results are shown for only those organic constituents and
dissolved metals detected at concentrations above established
DDJC-Tracy background threshold levels.
DUP = Duplicate sample was collected tor analysis; results are
feted to the right with normal sample results.
i
s
Figure B-39.
SWMU 21 - Battery Acid Dump
Constituents Detected in Soil
and Hydropunch Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
*?<•'•• -
'-. • £
-;•*•>••.- .
•'-:'•' *:*
^C-jj-
II
-4-
LM096A
LM114A(
COMPOL
NC
SB 168
DEPTH ' COMPOUND CONC. (mg/kg)
1.5 Beryllium j 1.13 ,-•""'
6.5 NC ^A
155: Oup Beryllium NC: 1.7 ^V^
Chromium NC: 55 Ov
Molybdenum j 1.47: 1.7 \ '
Bldg.22
-„-"-.( .
EXPLAN;
1
i
\TION
' l
\
\
\
\
\
Unpaved
SVfi
-$- Existing Monitoring Well Location
• Soil Boring Location
Q Previous Investigation
Soil-Gas Sample Location
T 3 APProx'male Site Boundary
• Note.
} Sample re
at concent
, oackgroun
- NC = No
; limit
DUP = Di
re
re
.
suits are
rations al
d threshc
constitue
or above
jpiicate s
suits are
suits.
shown for only those metals detected
Dove established DDJC- Tracy
id levels.
nts detected above laboratory reporting
i backqround. where applicable
I
Sampled 10/13/94} /jT'T'lil
ND j CONC.(ug/I) WlW
| fT
^- LM114A
„_,- SG36 COMPOUND ! CONC. (ug/l)
• "*"""%N^ f^fj\ Copper, tot. 30.7
"**••*"' \ J
SWMU 22 SG1n \ -^
u \rLM18A
SB16fl &
-------
3VVMU '0
Gravel Surface
SB 194
DEPTH
0.5
1.5
COMPOUND
NC
NC
SB 193
DEPTH
0.5
1.0
COMPOUND
! NC
1 NC
EXPLANATION
• Soil Boring Location
Q Phase I Surface/near surface sample location
|" ~ " "| Approximate S ite Boundary
-77— Edge of Pavement
Note:
NC = No constituents detected above laboratory reporting limit or above background, where applicable.
Concentrations of oil and grease are not posted on this figure as they are not considered indicative
of contamination from this site.
DUP= Duplicate sample was collected for analysis: results are listed to the right with normal sample
results.
I
N
0 50 100
SCALE IN FEET
Figure B-41.
SWMU 25 - Boundary Roads
Constituents Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
Edge of Pavement
U nlined Sewage Lagoons
SWMU2
• SB149
SV60
D
SWMU2
EXPLANATION
II Geophysical Survey Grid and
Site Boundary
_A Existing Piezometer Location
• Soil Boring Location
D Previous Investigation Soil-Gas
Sample Location
v Berm
m Former/Demolished Building
Now Paved (Asphalt)
Figure B-42.
SWMU 29 - Used Motor Oil Disposal Pit
Site Location Map
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a I
-------
FORMER DRUM STORAGE AREA
Bldg. 22
PALLET DISPOSAL AREA
(Paved Asphalt)
SG30-2 SB 199
SB1400 •
SB139
Unpaved SB200
(Gravel)
Depot Boundary/Fenceline
EXPLANATION
i~~~""j Approximate Site Boundary
Existing Monitoring Well Location
• Soil Boring Location
[•] Phase II Soil-Gas Sample Location
Drainage Ditch
Edge of Pavement
0 50 100
SCALE IN FEET
Note:
SB 139 and SB 140 were sampled as part ot the
investigation ot Drum Storage Area. Bldg. 22.
Figure B-43.
SWMU 30 - Salvage Area
Site Location Map
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
SB 138
SB199
DEPTH : COMPOUND \ CONC. (po/kg)
3.5 | NC
7.0
16.0
Phenol
Beryllium
9,700
994
NC
SB4S6
DEPTH
4.0
COMPOUND
NC
9.0 I NC
16.0 : NC
LM019A
To
SWMU8
SB 198
DEPTH
4.0
7.5; Dup
15.5
COMPOUND
2.4,6-Trichlorophenol
2.4.6-Trichlorophenol
Beryllium
Molybdenum
2.4.6-Trichlorophenol
DDE
DDT
Beryllium
CONC
(ug*g)
361
572: NC
1.750:2.080
1.580: 1.420
687
4.16
3.35
1.650
SB453
DEPTH i
4.0 |
9.0 ;
14.0 '
COMPOUND
NC
NC
NC
Fenceline
if)
L- '/
3457 ^^^*
» T4
* X
<' /S
SB454
DEPTH i
4.0
9.0
16.0
COMPOUND
NC
NC
NC
SB457
DEPTH
4.0
9.0
16.0
COMPOUND
NC
Benzo(a)anthracene
! Benzo(k)fluoranlhene
i Fluoranthene
NC
i CONC. (ug/kg)
0.180
0.097
t 0.812
i
EXPLANATION
r~j
•&
•
a
Approximate Site Boundary
Existing Monitoring Well Location
Soil Boring Location
Phase II Soil-Gas Sample Location
Edge of Pavement
Boron | 25.1 :
f^- Molybdenum j 1.55 N^
Vanadium ! 63.5 ]
/
^ 0 50 100
SCALE IN FEET
Notes:
Sample results are shown for only those organic compounds and metals
detected at concentrations aoove established DDJC-Tracy background
levels in soils.
NC = No constituents detected above laboratory reporting limit or above
bacKgrourg.
DuP = Duplicate samoie was collected for analysis: results are listed to
t*>e fght with normal sample results.
Figure B-44.
SWMU 30 - Salvage Area
Organic Constituents and Metals
Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source' Montgomery Watson. 1996a
-------
Paved
(Asphalt)
SB201
DEPTH COMPOUND , CONC. (mg/kg)
3.0
80
9.5
Manganese
Nickel
816
60.5
13.5
NC
Barium
397
Bldg. 247
SWMU 31
SB203
!\
SB201
SB203
DEPTH
2.5
9.0
13.5
COMPOUND
NC
NC
NC
SB202
EXPLANATION
Paved
(Asphalt)
Existing Monitoring Well Location
Soil Boring Location
r —
i __i Approximate Site Boundary
NC = No constituents detected above laboratory
reporting limit or above background, where
applicable.
I
N
0 ..^10 20
SCALE IN FEET
Figure 8-45.
SWMU 31 - Wood Preservation Area
Constituents Detected in Soil
and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
LM121A (Sampled 10/20/94)
COMPOUND
NC
\ LM121A
V
Paved
(Asphalt)
Bldg. 201
Note:
Sample results are shown tor only those organic
constituents and metals detected at concentrations above
DDJC-Tracy background threshold levels.
The excavation was underlain by a concrete tank cradle:
soil borings inside the excavation met refusal.
NC = No constituents detected above laboratory
•eporting limit or above background, where applicable
3JP = Duplicate sample was collected tor analysis: results
are listeo to the right with normal sample results
0
Bldg. 201
Addition
Existing Monitoring Well Location
Soil Boring Location
ECOS, 1988 Discrete Soil
Sample Location
Approximate Site Boundary/
UST Excavation
Former/Demolished Building
(the slab of Building 206 is still intact)
I
S
7"
7.5
Figure B-46.
SWMU 64 - Waste Oil Pit
Constituents Detected in Soil
and Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
SCALE IN FEET
-------
o
Paved
(Asphalt)
SB141
DEPTH
5.0
9.0
15.0
COMPOUND
NC
NC
i NC
Area 1 Building 237
SB141
SB39
Open Storage
Area
Bldg. 236
EXPLANATION
• Soil Boring Location
© Phase I Hydropunch Location
NC = No constituents detected above laboratory reporting
limit or above background, where applicable
Figure B-47.
Area 1 - Building 236
Constituents Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
^,.5:.
?z;-*&&~-- ~
Infiltration
Gallery
Open Storage Area
(Concrete Slab)
EXPLANATION
Soil Boring Location
~~~i Approximate Site Boundary
Edge of Pavement
NC = No constituents detected above laboratory reporting
limit or above background, where applicable.
0 37.5 75
SCALE IN FEET
Figure B-48.
Drum Storage Area Building 15
Constituents Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
>k
^
H \-
SB134
DEPTH
3.5
9.0
16.5
; COMPOUND : CONC. ((jg/kg)
NC
: NC
bis(2-Ethylhexyl)phthalate
2,800
Gravel Surface
SB 133
DEPTH
3.5
6.0
15.5
i COMPOUND
NC
NC
; NC
SB135
DEPTH COMPOUND
CONC. (ug/kg)
5.0
NC
9.0
Di-n-butylphthalate
120
17.0
NC
SB13i
I
SB 136
DEPTH
3.0
9.0
17,0
COMPOUND
bis(2-Ethyihexyi)phthaiate
CONC. (ug/kg)
! 1.500
NC !
NC
!
SB 133
Paved
(Asphalt)
LM035A (sampled 10/18/94)
COMPOUND CONC. (ug/l)
PCE
TCE
15
0.51
LM035AU
EXPLANATION
$- Existing Monitoring Well Location
• Soil Boring Location
Approximate Site Boundary
SB 138
DEPTH ; COMPOUND
3.5
9.5
17.5
NC
NC
NC
SB139
DEPTH i COMPOUND
2.0
15.0; Dup
17.5
B140
NC
NC:NC
NC
SB139
V
Unpaved
SB140
DEPTH
2.0
9.5
16.0
COMPOUND
i NC
j NC
i NC
Notes:
Samole results are shown lor only those organic compounds
ana metals detected at concentrations above established
DDJC-Tracy background levels in soils.
NC - No constituents detected above laboratory reocrtmg
limit or above background.
OUP = Duplicate sample was collected for analysis: results
are iistea 10 the right with normal sample results.
0
100
200
SCALE IN FEET
Figure B-49.
Buiding 22 - Drum Storage Area
Constituents Detected in Soil and
Groundwater Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. 1996a
-------
a
z
to
cc
o
f£m
SS070
DEPTH
0.5
1 COMPOUND
Senzo(a)anthracene
8enzo(a)pyrene
Benzo%^£-^v--. v ^ .,
.,,,^,355^***- -*=:•-3
. ' -.yVJtrNirvV:"''.:- - i*
-^2CJ
>*—^~
SS071
DEPTH [COMPOUND
CONC. (ug'kg)
0.5
Anthracene
Benzo(a)anthracene
!Banzo(a)pyrene
Benzo(b)fluoranthene
Benzo(kjfluoranthene
Fluoranthene
Phenanthrene
Alpha-chlordane
Gamma-chlordane
DDD
:DDE
'- Dieldnn
56.2: 8 12
1.57: 1 62
2.95: 4.34
3.24: 3.97
1.27: 1.58
4.33: 3.88
7 34: 7.45
6.36: 2.57
1 58: 8.21
190: 331
NC: 2.340
120: 246
SS070
«ea
SS068
DEPTH COMPOUND
0.5
Benzo(a)anthracene
Benzo(b)fluoranlhene
Fiuoranthene
Alpha-crtlordane
Gamma-chlordane
DDD
Dieldnn
. .-r^—'~uS .- ^^^..-tas=^S:.- mff3^~^.
DEPTH COMPOUND
CONC.
Benzo(a)pyrene
Benzo(b |(luoranthene
Benzo(k)(luoranthene
Fluoranthene
Phenanlhrane
Alpha-chlordane
Gamma-chlordane
DDD
Dieldnn
Lead
r*—i Site Boundary (fenced play yard)
*—x-r
@ Phase I Hydropunch Location
Phase II Surface Sample Location
Soil Boring Location
Tree
MAIN DEPOT ENTRANCE
I
S
Note:
Sample results are shown lor only those organic compounds
and metals detected at concentrations above established
DDJC-Tracy background levels tor shallow (0.5 feet bgs) soils
Figure B-50.
Day Care Center
Organic Constituents and Metals
Detected in Soil Samples
Defense Depot San Joaquin - Tracy Site
Source: Montgomery Watson. I996a
-------
APPENDIX C
SWMU 4 TECHNICAL MEMORANDA
-------
TECHNICAL MEMORANDUM
Analysis of SWMU 4 — Storm Drain Lagoon
(DACA87-95-D-0001 Delivery Order 014)
SWMU 4 — Storm Drain Lagoon
Background
SWMU 4 is a storm water retention lagoon that collects all storm water runoff from DDRW-
Tracy through a network of underground storm drains and open surface drainage ditches (see
Figure C-l). Semivolatile organic compounds (SVOCs)—including polycyclic aromatic
hydrocarbons (PAHs)—pesticides, and metals have been detected in the lagoon sediment. The
Final Comprehensive Remedial Investigation/Feasibility Study (RI/FS) (Montgomery Watson,
1996a) identified SWMUs 2 and 3, SWMU 8, and SWMU 33 as the primary source areas for
pesticides in groundwater; however, SWMU 4 was also considered a potential source area.
Vadose zone modeling was performed and equilibrium partitioning limits were determined to
develop cleanup standards to protect beneficial uses and background groundwater quality for
SWMU 4. These results were the primary drivers for defining the scope of the remedial
alternatives that were developed in the RI/FS. Radian has reevaluated the likelihood of impacts
to groundwater from sediment and soil contamination at SWMU 4 using new subsurface soil
results (collected just above the water table) and groundwater monitoring data (see discussion
below).
The RI/FS also identified potential impacts to ecological receptors at SWMU 4. The potential
impacts to ecological receptors were not a factor in determining the scope of excavation for the
selected remedy. The contaminants responsible for the estimated risk were mingled with the
contaminants responsible for water quality concerns and were addressed simultaneously through
excavation to address the water quality impacts. As a result, a screening level assessment of the
risk to ecological receptors was performed. The hazard index in the RI/FS was determined using
literature values rather than site-specific data. Using a hazard index of 10, the screening-level
assessment identified DDD, DDE, DDT, and selenium in the lagoon sediment as potential threats
to ecological receptors. Human health is not threatened under either the depot worker or the
construction worker scenario. The uncertainties of the risk assessment have now been reviewed
(see below) and several assumptions were identified that are highly conservative.
Assessment of SWMU 4 as a Potential Source of Contamination in Groundwater
Although SWMU 4, the DDRW-Tracy storm water detention pond, cannot be dismissed as a
potential source of contaminants in groundwater, there is little evidence that contaminants in the
sediment or the soil beneath the pond have affected or will adversely affect groundwater.
Because the concentrations of contaminants in the sediment and the soil beneath the storm water
pond do not indicate a current threat to groundwater quality, no further action to protect
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Memorandum
25 August 1997
Page 2
groundwater quality is warranted at SWMU 4 (see Figures C-2a and C-2b for soil and sediment
sampling results). This conclusion is supported by four points:
1. The October 1996 Subsurface Sampling Results Show That Migration from the
Surface Sediment to the Subsurface Soil Is Minimal. The concentrations and numbers
of analytes that exceed background or cleanup concentrations are much lower in the soil
samples collected at 1 to 1.5 feet below the bottom of the pond than in the sediment
samples collected from 0 to 6 inches below the bottom of the pond (see Table 1). The
compounds that are present in the soil at concentrations greater than background levels
(DDD and the PCB Arochlor 1260) have not been detected in groundwater samples from
downgradient monitoring wells (LM004A and LM027AA). Dieldrin was detected above
the practical quantitation limit (3 |ig/kg) in only one soil sample collected from deeper
than 6 inches.
The data from fourteen surface sediment samples (0 to 6 inches below the bottom of the
pond) collected during the remedial investigation (Montgomery Watson, 1996a) and 18
subsurface soil samples collected above the water table (1 to 1.5 feet below the bottom of
the pond) (Radian, technical memorandum, 27 November 1996) indicate that the number
of compounds and their concentrations decrease with depth beneath the storm water
pond. The surface sediment samples had one to five SVOCs reported; however, no
SVOCs were reported in the subsurface soil samples. The PCB Arochlor 1260 was
detected in eight surface sediment samples at concentrations of 41 to 459 u.g/kg;
however, this contaminant was only detected in one of the 18 subsurface soil samples (at
a concentration of 160 ng/kg).
No urea-carbamate pesticides or chlorinated herbicides were reported in the subsurface
soil samples. The pesticide DDD was detected in all the surface sediment samples at
concentrations of 31 to 2,310 fig/kg. Although this compound was detected in 14 of the
18 subsurface soil samples from 1 to 1.5 feet below the bottom of the pond, the
concentrations ranged from 1.5 to 380 (ig/kg, and only four concentrations were above
soil background concentrations (28.1 u,g/kg) for DDRW-Tracy. The concentrations of
DDT, which was detected in four subsurface soil samples, and DDE, detected in ten
subsurface soil samples, were all less than the soil background concentrations of 2,565
u.g/kg and 1,284 Hg/kg, respectively. Dieldrin was reported in four surface sediment
samples and four subsurface soil samples; however, the highest reported concentration in
the subsurface soil (6.5 Hg/kg) was less than the lowest concentration in the surface
sediment samples.
2. DI-WET Results for Subsurface Soils Do Not Indicate Any Confirmed Impacts to
Water Quality. One subsurface soil sample that had measurable concentrations of DDE
(73 ^ig/kg), DDD (380 ug/kg), DDT (1.1 ug/kg), and dieldrin (2.7 ug/kg) was subjected
to the waste extraction test with de-ionized water (DI-WET) to determine what fraction
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Memorandum
25 August 1997
Page 3
of the compounds may be leachable. Analyses of the leachate from the sample only
showed reportable concentrations of DDE (0.13 Jig/L) and DDD (1.1 |ig/L). DDT and
dieldrin concentrations were below reporting limits in the leachate. Although the
leachate results suggest that there is potential for the frequently reported DDD and DDE
to adversely affect groundwater, neither DDD nor DDE have been reported in any
samples collected from LM004A and LM027AA, the wells closest to SWMU 4 in the
downgradient direction.
3. Only Dieldrin Has Been Detected in Both Surface Sediment and Subsurface Soil
Samples and in Downgradient Monitoring Wells. Only dieldrin (one of six samples
from LM004A and one of 11 samples from LM027AA), monuron (two of four samples
from LM027AA, none from LM004A), diuron (one of two samples from LM004A and
three of four from LM027AA), simazine (one of one from LM027AA), and manganese
(one of one from LM027AA) detections have indicated any adverse impact on
groundwater. However, dieldrin is the only one of these compounds reported in the
groundwater samples that was also reported above background levels in the surface
sediment or subsurface soil samples from the pond.
4. Dieldrin Has Not Been Measured in Downgradient Wells Since 1994. Dieldrin has
been detected in one of six LM004A groundwater samples and one of 11 LM027AA
samples. In July 1993, a dieldrin concentration of 0.011 u,g/L was measured at LM004A.
In 1995 and 1996, all dieldrin results were less than the reporting limit of 0.10 Hg/L.
Between 1987 and 1993, dieldrin concentrations at LM027AA ranged from less than
0.005 M-g/L (detection limit) to 0.11 Jig/L. All dieldrin results were less than the reporting
limit (0.1 ug/L) in 1995 and 1996.
Conclusion. The surface sediment, subsurface soil, soil leachate, and groundwater results
suggest that SWMU 4 is not now, and is unlikely to be in the future, a source of contamination in
groundwater. Although there has been an almost constant downward driving force of standing
storm water in the pond, contaminant concentrations exceeding background levels in the
sediment have not been driven into the groundwater in the 25 years that the pond has been used.
It is not clear from the groundwater analyses that the dieldrin, monuron, and diuron detected in
the groundwater samples can be attributed to the storm water pond. There is no clear evidence
that the remediation of the soil at this site would have any effect on groundwater quality.
The cost of excavating all soils above cleanup standards based on equilibrium partitioning limits
is estimated as $700,000. The above analysis shows that the benefits associated with excavation
at SWMU 4 are doubtful and, therefore, funding excavation to address unlikely groundwater
impacts is not warranted at this site.
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Memorandum
25 August 1997
Page 4
Assessment of Impacts to Ecological Receptors
The Final Comprehensive Baseline Risk Assessment (Montgomery Watson, 1996a) provided a
screening level assessment of the risk to ecological receptors at SWMU 4. Spotted sandpipers
and great blue herons were identified as receptors with completed pathways at SWMU 4. DDT,
DDE, DDD, and selenium were identified as contaminants of concern for ecological receptors at
SWMU 4 (see Section 6.6.5 in the draft Record of Decision [Radian, July 1997]). Because of
uncertainties in the assessment of ecological risk, the risk assessment does not provide a good
basis for scoping a remedial action at SWMU 4. The following uncertainties were identified.
1. The Presence of Selenium Above Background Concentrations At SWMU 4 is
Questionable. The risk assessment (Montgomery Watson, 1996a) indicated that the
analytical results for selenium were uncertain. Six surface sediment samples with
selenium results ranging from 15.5 to 31.3 mg/kg were considered questionable and
reanalyzed by Montgomery Watson during the remedial investigation. When reanalyzed,
five of these samples had no detectable selenium above a detection limit of 0.3 mg/kg,
and the sixth sample had a selenium concentration of 1.83 mg/kg. Nevertheless, the 15.5
to 31.3 mg/kg levels were retained for the calculation of risk to ecological receptors.
When Radian took subsurface soil samples in October 1996, the results for selenium in
all subsurface soil samples were below the reporting limit. Because the subsurface soil
samples were collected approximately 12 to 18 inches below where the sediment samples
were collected, selenium may not be present above the background concentration in the
sediment.
2. The Impacts of DDT, DDD, DDE, and Selenium on Ecological Receptors Are
Probably Not as Severe as Estimated in the Risk Assessment. The calculation of
exposure endpoints and the toxicity assessment used for the risk characterization relied
on conservative estimates and literature values rather than site-specific data.
Conservative uncertainty factors were applied to estimate chronic toxicity endpoints. The
uncertainties in the risk characterization include the following:
• It was assumed that 50% of the birds' diet of fish and invertebrates was consumed
from SWMU 4. However, it is unlikely that birds do 50 percent of their feeding
in the lagoons.
• It was assumed that the great blue heron's diet was primarily fish. However, the
fish population in SWMU 4 is unconfirmed. Also, the risk assessment used a
very conservative bioaccumulation factor for carnivorous game fish that are not
present in the pond.
• The toxicity values and bioaccumulation factors used in the risk characterization
were derived from the literature. A recalculation of the risk using site-specific
data would almost certainly result in reduced chemical-specific cleanup standards.
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Memorandum
25 August 1997
Page 5
Conclusion. Because of these and other uncertainties, the screening level ecological assessment
does not provide a sound basis for remedial decisions about or scoping an excavation of
SWMU 4.
Ambient Water Quality Criteria. Surface water concentrations in the pond for dieldrin and
DDT exceed federal ambient water quality criteria (AWQC) for the protection of aquatic life.
These criteria are applicable to storm water discharged from SWMU 4. The water quality
criteria developed under the Clean Water Act Section 304 regulate "waters of the United States."
The storm water detention pond is a human-made structure and does not impound any natural
water body. Therefore, the AWQC apply to the discharge rather than to the pond itself.
Possible Modifications to the Selected Remedy for SWMU 4
Because there has been no indication of an impact to groundwater quality at SWMU 4, it is
recommended that the cleanup standards for bis(2-ethylhexyl)phthalate, fluoranthene,
phenanthrene, pyrene, carbaryl, carbofuran, total chlordane, and dieldrin be deleted (see Table 2,
attached). The cleanup standards for each of these compounds were previously identified solely
to protect groundwater quality.
To address potential ecological impacts at SWMU 4, the selected remedy could be modified to
include the following:
1. Two detailed observations of the flora and fauna at the pond will be performed during the
first year following the approval of the ROD. The assessments will be spaced approximately
six months apart. More frequent observations to determine the frequency of occurrence of
the herons and sandpipers will supplement the two detailed assessments. These site
assessments will provide a more accurate estimate of the level of food for the receptors and
their use of it.
2. Following these assessments, the risk characterization in the Baseline Risk Assessment
(BRA) will be reviewed. If sufficient invertebrates and fish are observed to warrant
sampling, samples will be collected and site-specific toxicity values and bioaccumulation
factors will be determined. The risk estimates will be revised using the site-specific data if
sampling is performed.
3. Chemical-specific cleanup standards will be developed using the revised risk characterization
to achieve a hazard index of 10.
Further actions at SWMU 4 are contingent on the results of the revised risk assessment for
ecological receptors. If no sediment concentrations exceed the revised cleanup standards, then
the remedy for SWMU 4 will consist of groundwater monitoring in accordance with the
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Memorandum
25 August 1997
Page 6
requirements of 23 CCR, Section 2550.6. If sediment concentrations exceed the revised cleanup
standards, excavation will be implemented as a remedy at that time.
Five-year site reviews are required for the selected remedy, per CERCLA guidance, because
contaminants will be left in place (organochlorine pesticides and dieldrin in the northern portion
of the lagoon).
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Table
Compound
bis(2-Ulliylliexyl)plilhalatc
Fluoranlhene
Plicnuntlirene
Pyrene
Carbaryl
Chlordane
2,4-D
Dicldrin
DDT
DDE
ODD
Selenium
1 . Comparison of Sediment
and Soil Results for
Concentration Range in
Detection Frequency in Surface Sediment
Surface Sediment (us/kg)
7 of 18
3 of 18
2 of 18
4 of 18
1 of 18
4 of 18
lof 18
5 of 18
1 of 18
lof 18
11 of 18
4 of 18/1 of 18
NRto 10,000
NRto 1,600
NRto 1,700
NRlo 1.800
NR (o 930
NR 10 828
NR to 6.86
NR to 205
NRto 158
NRto 815
NRto 2,3 10
NRto 31.3
Organic Constituents at
Detection Frequency
Subsurface Soil
Oof 18
Oof 18
Oof 18
Oof 18
Oof 18
Oof 18
Oof 18
4 of 18
4 of 18
lOof 18
I3of 18
Oof 18
SWMU4
Concentration Range
in in Subsurface Soil
(na/kg)
NR
NR
NR
NR
NR
NR
NR
NR to 6.5
NRto 18
NR to 73
NR to 380
NR
NR = none reported
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Table 2. Chemical-Specific Cleanup Standards for SWMU 4
Chemical
Cleanup Standard in Draft ROD
(ng/kg)
Comments
bis(2-Ethylhcxyl)phthalate
330
Fluoranthene
330
Phenanthrene
330
Pyrene
330
Carbaryl
550
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). bis(2-Ethylhexyl)phthalate was not detected in
subsurface soil samples and has not been detected in LM004A or LM027AA.
These data suggest the model was too conservative for this compound and a soil
cleanup standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Fluoranlhene was not detected in subsurface
soil samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Phenanthrene was not detected in subsurface
soil samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Pyrene was not detected in subsurface soil
samples anil has not been detected in LM004A or LMU27AA. These data
suggest (he model was loo conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Carbaryl was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for (his compound and a soil cleanup
standard is not required.
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Table 2. (Continued)
Chemical
Cleanup Standard In Draft ROD
(tig/kg)
Comments
Carbofuran
1000
Clilordane, total
20
2,4-D
25
Dicldrin
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Carbofuran was not detected in subsurface soil
samples and lias not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Chlordane was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). 2,4-D was not delected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not required.
Modeling was used to establish a cleanup standard to protect water quality
(standard corresponds to PQL). Dicldrin was detected in 4 of 18 subsurface
soil .samples. No diekliin was delected in leachatc from ;\ DI-WliT analysis
performed on the most concentrated subsurface soil (I to I.S feel below the
bottom of the pond). Dieldrin was periodically detected in LM004 A and
LM027AA prior to 1995. Since 1995, all results for dieldrin have been below
the reporting limit. There is no clear link between the dieldrin concentrations
previously delected in LM004A and LM027AA and SWMU 4. We recommend
continued monitoring for dieldrin at LM004A and LM027AA with revised
(lower) reporting limits. We recommend deleting the cleanup standard for
dieldrin from the ROD and revisiting this issue in (he five-year review of (he
site.
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Table 2. (Continued)
Chemical
Cleanup Standard in Draft ROD
Comments
DDT
25
DDE
50
ODD
50
Selenium
1,310
The cleanup standard lor DDT was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The BRA
included a number of assumptions that were not site-specific. It is
recommended that the ROD require some additional evaluation of impacts to
ecological receptors and that the cleanup standard be recalculated using site-
specific data.
The cleanup standard for DDE was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The URA
included a number of assumptions that were not site-specific. It is
recommended (hat the ROD require some additional evaluation of impacts to
ecological receptors and thai the cleanup standard be recalculated using site-
specific data.
The cleanup standard for DDD was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The BRA
included a number of assumptions that were not site-specific. It is
recommended that the ROD require some additional evaluation of impacts to
ecological receptors and that the cleanup standard be recalculated using site-
specific data.
The clciinup standard lor selenium was developed to attain a ha/aiil index of 10
lor the great blue heron using IJKA data (Montgomery Watson, 1996).
Selenium was initially detected in six sediment (0 to 6 inches below the bottom
of the pond) samples during the remedial investigation. These same samples
were reanalyzed and selenium was detected in only one of the six samples.
Selenium was not detected in any of the subsurface soil (I to 1.5 feet below the
bottom of the pond) samples collected by Radian. The data for selenium arc,
therefore, highly suspect. It is recommended (hat the sediment be resampled for
selenium. If the presence of selenium is confirmed, it is also recommended that
the ROD require some additional evaluation of impacts to ecological receptors
and that the cleanup standard be recalculated using site-specific data.
PQL = Practical Quantilution Limit
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TECHNICAL MEMORANDUM
DDRW-Tracy Storm Water Pond Investigation
November 26, 1996
Summary
A band auger investigation was performed at the DDRW-Tracy storm water pond to determine: 1) if soil
contamination was present, and 2) if soil contamination is present, to determine the extent of contamination
(•vertical and lateral), and the potential for contamination to migrate to groundwater. Eighteen samples were
collected at various locations and analyzed for metals, semi-volatile organic compounds (SVOCs),
pesticides and polychJorinated biphenyls (PCBs), urea and carbamate pesticides and chlorinated herbicides
(see Figure 1). Metals, pesticides and PCBs were detected in samples collected, and one soil sample from
each method (with the highest detected target analyte concentrations) was selected for additional analysis to
determine metals and organic solubilities. Table 1 presents the analjtical results for the soil samples thzt
were collected during the investigation. No analytes were detected above the Soluble Threshhold Limit
Concentrations (STLC) which indicates leaching from the soil downward to groundwater is minimal.
Scope of work
The original scope of work included the collection of 18 soil samples at six boring locations within the
stormwater collection pond. Soil samples were to be targeted for collection at depths of 1.0, 2.0, and 4.0
feet BGS (three samples per location). However, groundwater encountered at approximately 1.5 feet BGS
prevented the collection of "dry" soil samples for chemical analyses, therefore, soil samples were collected
just above groundwater at approximately 1.5 feet BGS in all 18 hand auger locations. The scope of work
was revised (per CEHNC direction) and twelve additional soil sample locations were sampled within the
pond. Samples were collected at the following locations to assess soil conditions:
Inlets (HP0101 and HP0102)
Low area (HPO104)
Area with minimal surface mixing (HPO 103)
Locations randomly distributed throughout the pond (HPO 105 through HPO 118).
Field Activities
Samples were collected using a four-inch outer diameter hand auger. Field sampling procedures and
equipment decontamination were performed in accordance to the Comprehensive Field Work Plan, Volume
1 of 2 (Radian, June 1996). Samples were analyzed at CLS Laboratory in Rancho Cordova, California
and at Radian Analytical Services Laboratory in Austin, Texas.
-------
The field work was performed from 9 to 11 October 1996 by RUST Emironmental and Infrastructure
Corp. Eighteen (18) soil samples (HP0101 through HP0118) were collected at depths up to 1.5 feet BGS in
the stormwater settling pond. Sample locations are shown on Figure 1. The hand augers were advanced to
total depths ranging from approximately 1.5 feet BGS to 3 feet BGS. Soils encountered included silts 2^d
clays to approximately 1.5 feet BGS and sandy silts below 1.5 feet BGS. In each hand auger, one soil
sample was collected from approximately 1.0 to 1.5 feet, directly above the saturated zone. A duplica^
soil sample was collected at the inlet (HP0101 sample location), and the soil sample collected at HP0102
was assigned for a matrix spike/matrix spike duplicate analysis. All soil samples were analyzed in
accordance with U.S. EPA Method SW8270 for SVOCs, Method SW8150 for chlorinated herbicides,
Method SW8081 for organochlorine pesticides and PCBs, Method E632 for carbamale and urea pesticides,
and Method SW6010 for metals. Following completion of investigation activities, the hand auger borbgs
were backfilled with the native soil removed and each location was marked with a wooden stake.
Results
Of the five analytical methods performed on the soils collected at the storm water pond, target anahtes
were only detected in two of the methods; SW8081 for pesticides and PCBs and SW6010 for metals.
Analytes were not detected above the laboratory reporting limit for Methods E632, SWS150 and SWS270.
Additional analysis for one sample from SW8081 and SW6010 were performed using a deionized waier
(DI WET) leaching procedure and the leachale analyzed by SW8081 and SW6010 analysis to determbs
the potential for solubility of target analytes. For pesticides and PCBs, sample HP0118 was selected for
DI WET analysis based on the detection of 4,4'-DDD at 380 ug/kg, the highest detection of a regulated
compound. For metals, sample HP0110 was selected for DI WET analyses because this sample had the
highest concentrations of chromium, vanadium, and zinc. The majority of samples collected contained
similar concentrations of detected metal analytes.
The DI WET analysis detected no analytes above the regulated hazardous waste Emirs for either merais or
pesticides and PCBs, indicating a minimal potential for these contaminants to migrate towards
groundwater.
Quality Assurance/Quality Control
Data validation and assessment for analytical data were performed in accordance to guidelines specified in
the Comprehensive Field Work Plan, Volume 2 of 2, Quality Assurance Project Plan (Radian, June
1996). In summary, all of the data can be used to define constituents of concern at the DDRW-Tracy
storm water pond. No d?t? points were rejected and any limitations of specific data points for use are
qualified as estimated results (noted with a J or UJ). A list of all qualified data points is presented in Table
-------
LOCATION OF AREA
AT DDR W- TRACY
Figure 1. Storm Woter Pond Sampling Locations
DDRW-Trocy
-------
TnNo I.DDRW-Tincy
Sloun W.'ilm Pnnd Sampling Oclohnr 199G
Ml: 11IOU
SAMPLeiDENTiriCAtlOU
III'UIOI HP0101 Hl'0102 HPOI03 t IC0101 I IPO 105 Hl'0100 HPU107 HP0100 IIPOtUQ MP01U) IIP0110 IIP0111 IIPUI12 HP01I3 HP0114 MPOt 15 HPU110 MPOI17 MPOMB IIPU11B
Diipllcaln Lnnrlinln Lnarlmlo
tGJi
All Analylos
SWB270
All AitalytoG
SW8I50
All AnRlytos
SW8080 (ug/Kfl)
4. 4". ODE
4.4'-DOD
Heplnchlor Epoxlde 1
Heplaclilor Epoxlde
Dloldiln
4,4'-DDT
Arochlor 1260
All Other analytot
SWG010(mg/Kg)
Aluminum
Antimony
Araonlc
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Polatilum
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
NO
ND
NO
7.2
29
ORL
DRL
2
7.4
160
ORL
10200
1.71
4.27
158
0.618
0.454
3360
24.5
6.1
18.7
18700
9.23
4730
257
27.6
1780
ND
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• "
Table 2. Summary of Qualified Data '
DDRW-Trncy Storm Water PoncJ Sampling. October 1996
Ofimpip r"uir~u~i A "' ' — " — — ~
Sample Number Date Lab SDG LsS ~ ~ ~
MclliiMl | 612
iiromiMiooins
III'IHIIIM IIMIINS
Ml'oio;s<)ooiNS
liriMOIMIOOINS
lll'OllllMlcMIINN
III'OIDVSIHHIINS
III'0|0(,S(NIO|NN
iironnsiMioiN.s
IIIMIIOMNIHIOINS
lll'll|09.S
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Talile 2. Summnry of Qualified Data
DDRW-Tracy Storm Wnler Pond Samplimi. October 1996
Sample
Sanipli! Number Date
Lah
SDG
Extract
Dale
Ana.
Dale
L.ili
QC
Analylc Result
Rep. Dilu.
Limit Factor
Unit
Milliml SU'XOXDiiiiiliin it'll
III'IH I KM Mill INS
M.-|||1ulS\V!UMI
IM'OIOJSIWOINS
NMIi.MlS\VX2VO
liroi06S(>00|NS
IIIIIIO.INf MHIINS
liroiOISIHIOINN
III'OIOJSOOOINS
1 1 1'lll HIM Mill INS
III'OIOISUODIDS
1 1 I'm nisi mi) INN
III'OHI7MH>(>|NS
llril|IIKS( Hill INN
III'dlOVNOOOINS
lll'lll III.S(MIIIINS
lll'lll I IS< Mill) NS
III'IIII2SIMHIINS
III'OII 1MMIIIINS
lll'lll HNOOOINS
lll'OinSOIIOINS
lirOlir.SOOOlNS
lll'lll 1 7SOIIIIINS
iirinifi.s(MiiiiNs
I II' I M'H,
1 1)/ 9/96
10/9/96
1 0/9/96
1 0/9/96
I (I/ 9/96
lo/iow.
lo/ 1 n/96
III/KI/%
I) I/ 1 11/96
Ki/ni/9r>
Mi/io/96
111/10/96
111/1(1/96
III/ 11/96
1(1/1 IW.
Ill/ 11/96
10/11/96
10/11/96
10/1(1/96
HI/11/96
CI NH
HAS
HAS
KAN
HAS
HAN
HAS
HAS
KAN
HAS
HAS
KAN
KAN
HAS
KAN
HAS
HAS
HAS
II AS
KAN
KAN
IMIIX
IMlIK
IMIIX
IMIIX
IMIIX
96I01JN-IM
96101.17.01
96I01S702
96103.17-01
9610117.0-1
9610.15707
9610157-08
961015709
9610.157-10
9610157-11
9610.157-12
9610157.11
961 0157- M
9610157-15
961(1.157-16
96I0.1J7-I7
9610.157-IR
9610157- 19
9610.157-20
9610157-21
Ki/n/vr,
MIHI/'H,
II I/ 11/96
III/.1I/96
1(1/1 1/96
IO/H/96
10/15/96
10/15/96
10/15/96
IO/IV96
10/15/96
IO/I.1W.
10/15/96
IO/I5W.
10/15/96
10/15/96
10/15/96
10/15/96
10/15/96
It)/ 15/96
10/15/96
10/15/96
10/15/90
10/15/96
10/15/96
1 I/ IW
ll/ l/9d
ll/ I/V(,
1 I/ 1/96
ll/ 1/96
10/15/96
10/17/96
10/17/96
10/17/96
10/17/96
10/17/96
10/17/96
10/17/96
10/17/96
10/17/96
IO/ 17/96
10/17/96
10/17/96
10/17/96
10/17/96
III/ IS/96
IO/IX/96
IO/IX/%
IO/IX/96
IO/IX/96
NSI
NNI
NSI
NNI
NSI
NSI
NSI
NNI
NNI
NSI
NSI
NNI
NSI
NNI
NSI
NNI
NNI
NNI
NSI
NSI
NSI
llf|il:»hli>r OOOOO(M)
llcpl.iJiluf 1 |Mixult 0000000
l.iinhiiic 00110000
Mtlli(.«ychl..r 0 000000
li.x;i|iliune 0.000(100
DiniKcli 0.000000
llcxnclilmiicychipciilailicif) 000000
1 lcv.nlil..iiiL>cl..|K.nl.iilici|>L'iilailii-i|I.OOnOOO
lli:K.icliliciilailicin.OOOOOO
1 lcx.iclilni<>C)xlii|K'iil;iilicipciil.iilici<> 000000
I lcK.iclilui(K;ycl(i|iciilaillcifl 000000
I lcx:iclilniiicyclLlii|Kiilailici(l 000000
Hcx.iclili>ri>cycl«|>CMl.i(liciO.OOOOOO
Mcx,itliloiiH:)clii|iciil.iiliciO.OOOOOO
McxacliliitiKycln|>cnlailiciri'i:yili>|>ciil.iilici().0000(KI
1 lc\nilil<«iiLyilo|wiitnilici
-------
Sediment
))))))))))))
V
1.5'
Water Table
Sand
TRACV\ROOVM.FH6-VUa 12/M7
Figure C-1. Storm Water Detention Pond, Defense Depot San Joaquin - Tracy Site
-------
EXPLANATION
»
*
o
Sod Boring Location
(SWWU 4 K* bonng umpfes •«•
cotteifld from ttw surtae* oory)
S«n>*« tociion
Storm Dram Lagoon (IMirwd)
•ndcomma**!, aWTtMtB-i.
•f« tilM to (*<• "flf *
-------
NOT TO SCALE
JSffl— . .
COWObuNt COM: W»T
DOO 14
OOt i*
KWJ11I ^
MO ' "Yi
ont ?'
EXPLANATION
• Sod Bomg locat«n fSWMU 4 woi boring
uroples were collected from ffw uxlace only)
t Pr«» It 5«ftnw«r&url«c* Water
Sample Localon
r^= Earthen ficrm
,' • t rtn O»ain Uajoon (Unl"«J)
U^D^ 'tiult •'• ihown tor onV "x>M p*snc*>»» «nd
iM*ei»d it coneifBr.Kxw (KM MUbtetwd DOX-Tf»ey
NC > No coti
•MM*
Figure C-2b.
Cross Section of Soil and Sediment Sampling
Results for SWMU 4 Organic Constituents
Defense Depot San Jaoquin - Tracy Site
-------
.-i. \ i.\iLfx.\.i
PESTICIDES AND POLYCHLORINATED BIPIIBVYLS
WET HXTRACTION (DEIONIZED WATER)
Analytical Method: EPA 5080
Preparation Method: SW3520
Pi WifT
CoinPaiiy: Radian lntgrm.».n..i 1 1 r
Prujeci Name: Tnicv DO 1 4 VWP
Dimple Description: NA
S.impJe Number:
15018
Projccl Number: 6022 140400
Lab ID:
Date/Time Received: JO/n/%
Hale Prepared: 1 0/31. /9ft
miiial Wi./Volt.mc: jOOQ mi.
Final Volume: 5.0 mL
Dnie/Tirne Sampled: Kl/ll/% fig
Matrix: Soi! ^ S l "^
Batch Number: 9190-ufilO^
<«• Moisture: NA
DF
RL
JYimary
Column(2C)
Dnte
Arulyzed
nlplia-BHC
c.inuna-BHC (Lir.dane)
ilclia-DHC
heia-BHC
Heptaclilor
Aldrin
Hepcadilor Epoxidc
EndositlfDn I
4.4'-DDE
Dicldrin
fliulrin
4.4--DDD
P.nucsulfan 11
4.4%-DDT
Endrin Aldehyde
Eiiclosulfan Suifate
Toxaphenc
Chlordajie (Technical )>
MctJioxychlor
Aroclor 1016
Aroclor 1221
Aroclor J232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
0.000050
0.000050
O.OOU050
0.000050
0.000050
0.000050
0.000050
0.000050
0.00010
-0.00010
0.00010
0.00010
0.00010
0.00010
0.00010
0.00010
0.0025
0.00050
0.00050
0.0025
0.0050
0.0025
0.0025
0.0025
0.0025
0.0025
BRL '.V» BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL *
BRL
BRL
BRL
BRL
BRL
BRL
BRL
0.00013 J 0.00013
BRL *j
BRL
BRL 1'J BRL
0.0011 J 0.001 1
BRL vJ" BRL
BRL i BRL
BRL \ BKL
BRL BRL
BRL 1 BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
| BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
0.00016
BRL
BRL
0.0010
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
H/01/9ft
il/Oi/96
11/01/96
11/01/96
11/01.'%
!!. -ci /ys
i':/Oi/P6
11/01/96
J/Ol/96
I A) 1/96
2/01/9^
1/C1/3P
',/Ol/96
1/01/96
1/01/96
l/Oi/96
1. '01/90
1/01/96
!.'OI/9e
1/01/96
I/O 1/96
i /r>i :oi
i/ul»VO
I/O I. ''96
1/01/96
11/01/96
11/01/96
Surrogates
Primary
% Recovery
lscColumn[1C)
2nd Column(2C)
Limits
TcirachJoro-iD-xylene
68
104
60 - 150
Qualifier Legend:
cow lencr art Closures arc iwgralpans of this repon.
-------
-i- til .»<
.-t.v i. \icA-\--ii
PESTICIDRS AND POLYCHLORINATED BIPIIENYLS
WET KXTRACTION (DEIONIZED WATER)
Analytical Method: EPA 8080
Preparation Method: SW3520
Pi VVITT
Company: Radian lnteniniion.il LLC
Project Name: Tnicv DO 14 SWP
Sample Description: NA
SDG#: 15018
Projeci Number: 6022140400
Lib ID: 150 18- 1/66698-3030
Sample Number: HP0118S(XKI1NS
Dale/Time Received: JO/1 1/96
Dale Prepared: j 0/3 1/96
Iniiial Wt. /Volume: lOOO mL
Final Volume: 5.0 mL
Analyie
nlpha-BHC
cnmma-BHC (Ltndane)
dclia-BHC
heia-BHC
Heptaclilor
Aldrin
Heptaclilor Epoxidc
Hndostilfan I
4.4--DDE
Dicldrin
Endrin
4.4'-DDD
£ndcsu.lfan 11
4.4'-DDT
f-ndrin Aldehyde
Eudosulfan Suifate
Tcixapheiic
Chlordane (Technical^
MeiJioxychlor
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
A rod or 1260
Surrogates
Tcirachloro-in-xylene
16:15
Date/Time Sampled:
Matrix: Soil ( S )
10/1 1 /% 09:(X1
Bjitch Number: 9i90-"61031
DF
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
*RL
0.000050
0.000050
0.000050
0.000050
0.000050
0.000050
0.000050
0.000050
0.00010
-0.00010
0.00010
0.00010
0.00010
0.00010
0.00010
0.00010
0.0025
0.00050
0.00050
0.0015
0.0050
0.0025
0.0025
0.0025
0.0025
0.0025
% Moisture: NA
Rrporting Unii*fni
Primary 1st Column(lC) 2nd
BRL '!4 BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL * BRL
0.00013 J 0.00013
BRL tf BRL
BRL I'J BRL
0.0011 J 0.0011
BRL Vtf BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
RRL
BRL
BRL
BRL BRL
% Recovery
Primary 1 sc Columnf 1C) 2nd
68 68
l/L (ppinT^
^^
Column(2C)
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
0.00016
BRL
BRL
0.0010
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
Column (2C)
104
D.ite
Analyzed
11/01 /9ft
i 1/0 1/96
11/01/96
11/01/96
i I/O 1/96
! I/O 1/96
I.V01/96
11/01/96
11/01/96
11/01/06
11/01/96
11/01. -96
11/01/96
11/01/96
11/01/96
ll/Oi/96
H/01/9G
ll/Oi/96
11/01/96
11/01/96
i 1/0 1/96
1 I/O 1/96
1 1/01/96
11. -'01/96
11/01/96
11/01/96
Limits
60 - 150
»»^« T
Qualifier Legend:
The cover letter and enclosures are integral parts of this report.
-------
- \1" r ,
\<^ ^ L.J"
\ ^ ^P
^L^< ' L
APPENDIX D
CALCULATIONS
-------
Calculation of Clean-up Levels Protective of Ecological Receptors
This appendix provides the calculations performed to determine preliminary and conservative
chemical-specific cleanup standards to protect ecological receptors. Concentrations were
estimated using literature intake benchmarks. The total DDX concentrations were based on
values from Heath, Spann, and Kreitzer (1969) and Anderson et al. (1975). Concentrations for
selenium were based on intake values reported by Heintz, Hoffman, and Gold (1989). Lead
concentrations were based on Edens et al. (1976) and Edens and Garlich (1983). The calculations
were coordinated with and reviewed by Mr. Clarence Callahan of the U.S. EPA and were found
to be reasonable.
-------
CALCULATION SHEET
SIGNATURE
PROJECT
SUBJECT
PATE
! ' I '•
CHECKED
U)
DATE
I ^U *? "/
JOB NO
^r
Pfrlc.4 SHEET
OF *)
.SHEETS
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OC o
- r ^
~ i- > (20 3
- O
o .G\
^
, -~ »-,-. > v v « -^ ,
5 VA>
-------
RADIAN
CALCULATION SHEET
CALC. NO.,
SIGNATURE.
PROJECT_
SUBJECT
DATE.
CHECKED
G>
DATE M
JOB NO..
SHEET.
OF.
.SHEETS
wvv"
~\
-v
V. 0 \
~- 0. t>~
\ VN^ ~- c .
\ K^
V^ /
0
10-88-30702
-------
RADIAN
CORPORATION
CALCULATION SHEET
CALC NO..
SHEETS
c\. »c -3^ 3^,;.^ _ ^eii \, .
-A- r\ v r" »' V v/ ^ -^
'Cp\\^ I*. irtU^rixV- £>.k\lf ,v
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(ir^occiy'^l^s)
tSbT \\ T^^ -
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(1^-^v^ - c. VA ^3^v
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-------
RADIAN
CALCULATION SHEET
SIGNATURE.
PROJECT
SUBJECT
DATE.
JOB NO..
SHEET
CALC. NO,.
DATE
OF.
.SHEETS
v- --
L
-------
SIGNATURE.
JROJECT
SUBJECT
? 7/'X
CALCULATION SHEET
DATE I) Phi 7*7
CALC. NO.
DATE U /
JOB NO
SHEET
OF
.SHEETS
5
f
\-V
10-86-30702
-------
APPENDIX E
WELL MONITORING PROGRAM
-------
DDJC-Tracy Sile-Wide Comprehensive Record of Decision
E1.0 INTRODUCTION
E2.0 WELL MONITORING PROGRAM
Prior to completion of the Comprehensive Record of Decision (ROD), the purpose of the well monitoring
program at DDJC-Tracy was to collect the groundwater data necessary for:
• Monitoring and tracking groundwater contamination;
• Validating the effectiveness of the groundwater extraction and treatment systems;
• Confirming that groundwater contaminants have not impacted potable wells within and downgradient
from groundwater with concentrations exceeding aquifer cleanup levels; and
• Determining the effect of groundwater injection and percolation.
The selected remedy in the ROD includes groundwater monitoring at SWMUs and other areas of soil
contamination. This monitoring adds two objectives to the well monitoring program:
• Determining if a SWMU or area of soil contamination is degrading groundwater; and
• Evaluating the appropriateness of the selected remedies.
E2.1 After an initial sampling period of one year, the frequency of sampling of wells in the monitoring
program is determined by taking each well through an annual decision process that was introduced in the
Environmental Master Plan, Version 1.0 (Radian, 1996e). Figure E-l illustrates the decision process that
is used to determine the sampling frequency in the well monitoring program after the initial one-year
period. The purpose of the frequency decision flowchart is to reduce the monitoring to essential while
continuing to meet the objectives of monitoring. The monitoring well sampling flowchart is divided into
three criterion types: age, location, and data needs. The frequency decision process in Figure E-I focuses
sampling and analysis on obtaining data needed to assess the effectiveness of remediation systems and
progress toward groundwater cleanup. In coordination with sampling frequency decisions for each well,
decisions on the analyses to be performed should also be reviewed annually.
E2.2 The selection of analytical methods for each monitoring well is driven by the data needs at the
location. Data needs for all DDJC-Tracy locations are driven by the following:
• Contaminants for which aquifer cleanup standards have been established; and
• Potential contaminants in the soils of known or suspected source areas.
E3.0 MONITORING WELL LOCATIONS
Monitoring wells located within or a short distance downgradient from a SWMU or other area of soil
contamination have been identified as part of selected remedy. Figure E-2 illustrates well locations
downgradient from SWMUs, Areas, and Drum Storage Areas with the same color as the area they are
intended to monitor.
The Comprehensive RI/FS and ROD identifies four locations downgradient from SWMUs and the Drum
Storage Area, Building 30 where additional wells should be located to monitor for contaminants that
APP-E.DOC E-l 12 December 1997
-------
Age Criterion
Location Criterion
Data Needs Criterion
Monitoring/SampRni
Recommendation
•Guard-
wti) downQrddiefl!
ol plums edge «
extraction wen &//
WORwell? "
Wtttn
100 fid
w eduction
wtl?
Simple giarwiy *»
lyeirmaEWsartup
Reduce surfing
Bsentimual
Nearesl
wen 10 idemrtiaj
comanwuin
souce?
Measuie wiier levels
ouanerty
Water level \
measurements \
needed af ?
recent
results \ Y»
> Background
or MCLS?
Figure E-1.
Groundwater Monitoring Well
Samp!::; crequency
Decision Flowchart
-------
DDJC-Tracy Site-Wide Comprehensive Record of Decision
pose a threat to groundwater. Wells were installed in the four locations during October and November
1997. The locations of the newly installed wells and pre-existing wells relative to SWMUs and the Drum
Storage Area are shown in Figure E-3.
APP-E.DOC E-2 12 December 1997
-------
|