PB98-964505
EPA 541-R98-031
October 1998
EPA Superfund
Record of Decision:
Barstow Marine Corps Logistics Base
OUs 1 & 2
Barstow, CA
4/7/1998
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(Final)
April 1998
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MARINE CORPS LOGISTICS BASE
BARSTOW, CALIFORNIA - CTO 0298
FINAL
OPERABLE UNITS 1 AND 2
RECORD OF DECISION REPORT
CLE-J02-01F298-B7-0027
3 April 1998
PREPARED BY;
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MARINE CORPS LOGISTICS BASE
BARSTOW, CALIFORNIA - CTO 298
FINAL
OPERABLE UNITS 1 AND 2
RECORD OF DECISION REPORT
CLE-J02-01F298-B7-0027
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Steve Griswold, R.G.
CLEAN Project Manager
Jacobs Engineering Group Inc., Pasadena
Goepel
CLEAN Technical Reviewer
Jacobs Engineering Group Inc., Pasadena
Jorge-PenaTEia, P.E.
Operable Units 1 and 2 Manager
License No. CA. C42770
Jacobs Engineering Group Inc., Pasadena
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TABLE OF CONTENTS
Page
ACRONYMS AND ABBREVIATIONS ix
1.0 DECLARATION 1-1
1.1 Site Name and Location 1-1
1.2 Statement of Basis and Purpose 1-1
1.3 Assessment of OUs 1 and 2 1-2
1.4 Description of the Selected Remedy 1-2
1.4.1 OU 1 - Yermo Annex Plume 1-3
1.4.2 OU 2 - Nebo North Plume 1-4
1.4.3 OU 2 - Nebo South Plume 1-5
1.5 Statutory Determinations ;..1-5
2.0 SITE BACKGROUND 2-1
2.1 Facility Location and Description 2-1
2.2 Present Site Use 2-1
2.3 Site History and Enforcement Activities 2-2
2.4 Scope and Role of OUs 1 and 2 2-4
2.5 Summary of Site Characteristics 2-6
2.5.1 General Site Conditions 2-6
2.5.2 Geology 2-7
2.5.3 Hydrogeology 2-8
2.5.4 Groundwater Flow Directions and Gradients 2-9
2.5.5 Groundwater Use 2-11
2.6 Groundwater Removal Actions 2-11
2.7 Risk Characterization/Management 2-12
2.7.1 Assessment of Risk 2-12
2.7.2 Summary of Human Exposure Assumptions 2-13
2.8 Remediation Goals 2-13
2.8.1 Groundwater Cleanup 2-13
2.8.2 Points of Compliance with Groundwater Cleanup
Standards 2-16
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2.8.3 Vadose Zone Cleanup Standards 2-18
2.8.4 Criteria for "Shut-off" of AS/SVE Systems 2-19
2.8.5 Vadose Zone and Groundwater Modeling to Determine
AS/SVE System "Shut Off 2-22
2.8.6 Determination of Asymptotic Conditions for "Shut Off of AS/SVE
Component of Groundwater Remedy 2-22
2.8.7 Approach to Groundwater and Vadose Zone Cleanup
atCAOC16 2-23
2.8.8 Approach for Groundwater and Vadose Zone Cleanup
atCAOC26 2-26
2.8.9 Approach for Groundwater and Vadose Zone Cleanup at
Warehouse 2 (Nebo North Plume) 2-27
2.8.10 Approach for Groundwater and Vadose Zone Cleanup
at CAOC 6 (Nebo South Plume) 2-28
2.8.11 Remedial Approach for Groundwater at CAOCs 23, 35, and
15/17 2-28
2.8.12 Initial Groundwater and Vadose Zone Primary
FFA Deliverable 2-29
2.9 National Contingency Plan Statutory Balancing Criteria 2-30
2.10 Applicable and Relevant or Appropriate Requirements 2-31
2.10.1 Chemical-Specific ARARs Driving Remedial Action
Objectives 2-33
2.10.2 Location-Specific ARARs 2-36
2.10.3 Action-Specific ARARs 2-36
2.11 Highlights of Community Relations and Participation 2-38
3.0 YERMO ANNEX PLUME (OU 1) DECISION SUMMARY 3-1
3.1 Summary of Plume Characteristics 3-1
3.1.1 Contaminants of Concern 3-1
3.1.2 VOC Contaminant Sources 3-3
3.1.3 Location of Vadose Zone Contamination 3-4
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3.1.4 Location of Groundwater Contamination 3-7
3.1.5 Contaminant Migration Routes 3-7
3.2 Summary of Yermo Annex Plume Risks 3-9
3.2.1 Chemicals of Concern 3-9
3.2.2 Summary of Toxicity Values 3-10
3.2.3 Human Health Risk 3-10
3.2.4 Ecological Risk 3-11
3.3 Rationale for Remedial Action Decisions 3-11
3.3.1 Groundwater Cleanup 3-12
3.3.2 Source Reduction 3-14
3.4 Description of Remedial Action Alternatives, Yermo Annex Plume 3-18
3.4.1 Alternative 1 - No Action 3-18
3.4.2 Alternative 2 - Institutional Controls/Groundwater
Monitoring : 3-18
3.4.3 Alternative 3 - Groundwater Removal (Extraction Wells
at Base Boundary), Ex Situ Treatment, and Discharge 3-20
3.4.4 Alternative 4 - Groundwater Removal (Extraction Wells
at Base Boundary and Off-Base Background Boundary),
Ex Situ Treatment, and Discharge 3-21
3.4.5 Alternative 5 - Groundwater Removal (Extraction Wells
at Base Boundary and Off-Base MCL Boundary), Ex Situ
Treatment, and Discharge 3-22
3.4.6 Alternative 6 - Groundwater Removal (Extraction Wells
at Base Boundary and CAOC 26 Boundary), Ex Situ
Treatment, and Discharge 3-22
3.4.7 Alternative 8A - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary and
CAOC 26 Boundary, AS/SVE at CAOC 26), Ex Situ
Treatment, and Discharge 3-23
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3.4.8 Alternative 8B - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary and
CAOC 26 Boundary, AS/SVE at CAOC 26 and
Downgradient of CAOCs 16,15/17, and 35), Ex Situ
Treatment, and Discharge 3-23
3.4.9 Alternative 8C - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary, Off-Base
MCL Boundary, and CAOC 26 Boundary; AS/SVE
at CAOC 26 and Downgradient of CAOCs 16,15/17,
and 35), Ex Situ Treatment, and Discharge 3-24
3.4.10 Alternative 80 - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary,
Off-Base Background Boundary, and CAOC 26 Boundary;
AS/SVE at CAOC 26 and Downgradient of CAOCs 16,
15/17, and 35), Ex Situ Treatment, and Discharge 3-24
3.5 Summary of Comparative Analysis of Alternatives 3-25
3.5.1 Threshold Criteria .3-25
3.5.2 Primary Balancing Criteria 3-26
3.5.3 Modifying Criteria 3-29
3.6 Summary of Selected Remedy For the Yermo Annex Plume 3-29
3.6.1 Performance Standards for Groundwater and Source
Reduction 3-33
3.6.2 Infiltration Standards 3-33
3.6.3 Groundwater and Vadose Zone Monitoring 3-33
3.7 Statutory Determination 3-34
3.7.1 Protection of Human Health and the Environment 3-35
3.7.2 Compliance with ARARs 3-35
3.7.3 Cost Effectiveness 3-35
3.7.4 Use of Permanent Solutions to the Maximum Extent
Practicable 3-36
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3.7.5 Preference for Treatment as a Principal Element 3-36
3.8 Documentation of Significant Change 3-37
4.0 NEBO NORTH PLUME 4-1
4.1 Summary of Plume Characteristics 4-1
4.1.1 Contaminants of Concern 4-1
4.1.2 VOC Contaminant Sources 4-1
4.1.3 Location of Vadose Zone Contamination 4-2
4.1.4 Location of Groundwater Contamination 4-3
4.1.5 Contaminant Migration Routes 4-3
4.2 Summary of Nebo North Plume Risks 4-5
4.2.1 Chemicals of Concern 4-5
4.2.2 Summary of Toxicity Values 4-5
4.2,3 Human Health Risk 4-5
4.2.4 Ecological Risk 4-6
4.3 Rationale for Remedial Action Decisions 4-7
4.3.1 Groundwater Cleanup 4-7
4.3.2 Source Reduction 4-9
4.4 Description of Remedial Action Alternatives, Nebo North Plume 4-10
4.4.1 Alternative 1 - No Action 4-11
4.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring
with Fail-Safe Extraction and Treatment Containment 4-11
4.4.3 Alternative 3 - Groundwater Removal, Ex Situ Treatment,
and Discharge 4-12
4.4.4 Alternative 4 - Groundwater Removal, Ex Situ Treatment, and
Discharge with Source Reduction (AS/SVE)
at Warehouse 2 4-13
4.4.5 Alternative 5 - Source Reduction (AS/SVE)
at Warehouse 2 4-14
4.5 Summary of Comparative Analysis of Alternatives 4-14
4.5.1 Threshold Criteria 4-15
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4.5.2 Primary Balancing Criteria 4-16
4.5.3 Modifying Criteria 4-18
4.6 Summary of Selected Remedy For the Nebo North Plume 4-18
4.6.1 Performance Standards for Groundwater and Source
Reduction 4-21
4.6.2 Infiltration Standards 4-21
4.6.3 Groundwater and Vadose Zone Monitoring 4-21
4.7 Statutory Determination 4-22
4.7.1 Protection of Human Health and the Environment 4-22
4.7.2 Compliance with ARARs 4-23
4.7.3 Cost Effectiveness 4-23
4.7.4 Use of Permanent Solutions to the Maximum Extent
Practicable 4-23
4.7.5 Preference for Treatment as a Principal Element 4-24
4.8 Documentation of Significant Change 4-24
5.0 NEBO SOUTH PLUME 5-1
5.1 Summary of Plume Characteristics 5-1
5.1.1 Contaminants of Concern 5-1
5.1.2 VOC Contaminant Source 5-2
5.1.3 Location of Vadose Zone Contamination 5-2
5.1.4 Location of Groundwater Contamination 5-2
5.1.5 Contaminant Migration Routes 5-3
5.2 Summary of Nebo South Plume Risks 5-4
5.2.1 Chemicals of Concern 5-4
5.2.2 Summary of Toxicity Values 5-5
5.2.3 Human Health Risk 5-5
5.2.4 Ecological Risk 5-6
5.3 Rationale for Remedial Action Decisions 5-6
5.3.1 Groundwater Cleanup 5-6
5.3.2 Source Reduction 5-9
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5.4 Description of Alternatives 5-9
5.4.1 Alternative 1 - No Action 5-10
5.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring .5-10
5.4.3 Alternative 3 - Vadose Zone Source Reduction
(AS/SVE at CAOC 6) 5-11
5.4.4 Alternative 4 - Groundwater Removal (Extraction Wells
at MCL/Background Boundary), Source Reduction
at CAOC 6, Ex Situ Treatment, and Discharge 5-12
5.4.5 Alternative 5 - Groundwater Containment and Removal
(Extraction Wells at MCL), Ex Situ Treatment,
and Discharge 5-13
5.5 Summary of Comparative Analysis of Alternatives 5-13
5.5.1 Threshold Criteria 5-14
5.5.2 Primary Balancing Criteria 5-15
5.5.3 Modifying Criteria 5-17
5.6 Summary of Selected Interim Remedy For the Nebo South Plume ....5-17
5.6.1 Performance Standards for Groundwater 5-19
5.6.2 Infiltration Standards 5-19
5.6.3 Groundwater and Vadose Zone Monitoring 5-20
5.7 Statutory Determination 5-20
5.7.1 Protection of Human Health and the Environment 5-20
5.7.2 Compliance with ARARs 5-21
5.7.3 Cost Effectiveness 5-21
5.7.4 Use of Permanent Solutions to the Maximum
Extent Practicable 5-22
5.7.5 Preference for Treatment as a Principal Element 5-22
5.8 Documentation of Significant Change 5-22
6.0 RESPONSIVENESS SUMMARY 6-1
7.0 REFERENCES 7-1
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Tables
Table 2-1 Operable Units 1 & 2 Contaminants of Concern Groundwater
Cleanup Levels 2-39
Table 2-2 Federal Chemical-Specific ARARs, Operable Units 1 and 2 2-40
Table 2-3 State Chemical-Specific ARARs, Operable Units 1 and 2 2-42
Table 2-4 Federal Location-Specific ARARs, Operable Units 1 and 2 2-45
Table 2-5 State Location-Specific ARARs, Operable Units 1 and 2 2-46
Table 2-6 Federal Action-Specific ARARs, Operable Units 1 and 2 2-47
Table 2-7 State Action-Specific ARARs, Operable Units 1 and 2 2-51
Table 3-1 Yermo Plume - On-Base Maximum Groundwater Concentrations
of VOCs and Associated MCLs 3-39
Table 3-2 Yermo Plume - Off-Base Maximum Groundwater Concentrations
of VOCs and Associated MCLs 3-39
Table 3-3 Carcinogenic Toxicity Values for Chemicals of Concern in
Groundwater and Vadose Zone at Yermo Annex 3-40
Table 3-4 Noncarcinogenic Toxicity Values for Chemicals of Concern in
Groundwater and Vadose Zone at Yermo Annex 3-41
Table 3-5 Summary of Comparative Analysis - Yermo Plume 3-42
Table 3-6 Treated Groundwater Discharge Limitations Lahontan RWQCB
Board Order No. 6-93-106 3-43
Table 4-1 Nebo North Plume - Maximum Groundwater Concentrations of
VOCs and Associated MCLs 4-25
Table 4-2 Summary of Comparative Analysis - Nebo North Plume, NRF-1 4-26
Table 5-1 Nebo South Plume Maximum Groundwater Concentrations of
VOCs and Associated MCLs 5-23
Table 5-2 Summary of Comparative Analysis - Nebo South Plume, NEP-4 5-24
Figures
Figure 2-1 Location of MCLB Barstow Operable Units 1 and 2 2-57
Figure 2-2 Mojave River Regional Map and Major Topographic Features 2-58
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Figure 2-3 Well Locations and Hydrogeologic Cross Section A-A' Yermo
Annex 2-59
Figure 2-4 Hydrogeologic Cross Section A-A1 Yermo Annex 2-60
Figure 2-5 Hydrogeologic Cross Section Line Nebo Main Base 2-61
Figure 2-6 Hydrogeologic Cross Section A-A1 Nebo Main Base 2-62
Figure 2-7 Yermo Annex Groundwater Table Contour Map January 1994 2-63
Figure 2-8 Nebo Main Base Groundwater Table Contour Map January 1993 2-64
Figure 3-1 Operable Unit 1 Yermo Annex Groundwater VOC Plume
Boundaries 3-44
Figure 3-2 PCE Plume in Groundwater from CAOCs 15/17,26, 35, and
Building 573, Yermo Annex 3-45
Figure 3-3 TCE Plume in Groundwater from CAOCs 15/17, 26, 35, and
Building 573, Yermo Annex 3-46
Figure 4-1 Operable Unit 2 - Nebo Main Base Groundwater VOC Plume
Boundaries 4-27
Figure 4-2 PCE Plumes in Groundwater from NRF-1 and CAOC 6 Nebo
Main Base 4-28
Figure 4-3 TCE Plumes in Groundwater from NRF-1 and CAOC 6 Nebo
Main Base 4-29
Appendices
Appendix A DON Positions on POC ARARs
Appendix B Administrative Record Index
Appendix C Transcript for Public Meeting
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ACRONYMS AND ABBREVIATIONS
ARARs applicable or relevant and appropriate requirements
AS/SVE air sparging/soil vapor extraction
AT&SF Atchison, Topeka, and Santa Fe Railway
bgs below ground surface
BLRA baseline risk assessment
Cal/EPA California Environmental Protection Agency
Cal/OSHA California Occupational Safety and Health Administration
CAOC CERCLA area of concern
CAP corrective action plan
CCR California Code of Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
cis-1,2-DCE cis-1,2-dichloroethene
COC chemical of concern
CRWQCB California Regional Water Quality Control Board
DON Department of the Navy
DISC Department of Toxic Substances Control
DWR California Department of Water Resources
EDB ethylene dibromide
EE/CA engineering evaluation/cost analysis
EPA U.S. Environmental Protection Agency
ESD explanation of significant differences
F Fahrenheit
FFA Federal Facility Agreement
FS feasibility study
ftfit foot per foot
gpm gallons per minute
ILCR incremental lifetime cancer risk
IR Installation Restoration
IRIS Integrated Risk Information System
IWTP industrial wastewater treatment plant
Jacobs Jacobs Engineering Group Inc.
kg kilogram
MCB Maintenance Center Base
MCL maximum contaminant level
MCLB Marine Corps Logistics Base
MCLG maximum contaminant level goal
mg/kg-day milligrams per kilogram per day
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mph miles per hour
MSL mean sea level
MTBE methyl tert butyl ether
Navy U.S. Department of the Navy
NCR National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
NTCRA non-time-critical removal action
OU operable unit
O&M operations and maintenance
PCBs polychlorinated biphenyls
PCE tetrachloroethene
ppb parts per billion
RAO remedial action objective
RCRA Resource Conservation and Recovery Act
RD/RA remedial design/remedial action
RFA RCRA facility assessment
RG remediation goal
RI/FS remedial investigation/feasibility study
RME reasonable maximum exposure
ROD Record of Decision
ROI radius of influence
RWQCB Regional Water Quality Control Board
SARA Superfund Amendments and Reauthorization Act (1986)
SOV soil organic vapor
SVE soil vapor extraction
SVOC semivolatile organic compound
SWMU solid waste management unit
SWRCB State Water Resources Control Board (California)
TBC to be considered
TCE trichloroethene
TEF technical and economical feasibility (analysis)
TPCA Toxic Pit Closure Act
TPH-D total petroleum hydrocarbons as diesel
USGS United States Geological Survey
UST underground storage tank
VLEACH vadose zone leaching model
VOA volatile organic analysis
VOC volatile organic compound
WMA waste management area
WMU waste management unit
WQCP water quality control plan
M9/L
micrograms per liter
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1,1-DCA 1,1-dichloroethane
1,1-DCE 1,1-dichloroethene
1,1 -TCA 1,1 -trichloroethane
1,1,1 -TCA 1,1,1 -trichloroethane
1,1,2-TCA 1,1,2-trichloroethane
1,2-DCA 1,2-dichloroethane
1,2-DCE 1,2-dichloroethene
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1.0 DECLARATION
1.1 Site Name and Location
The Marine Corps Logistics Base (MCLB) Barstow is in San Bernardino County,
California, in the central Mojave Desert approximately 135 miles northeast of Los
Angeles. The Base consists of two areas: the 4,006-acre Nebo Main Base, which
includes the Rifle Range, is 3.5 miles east of Barstow and intersected by Interstate 40;
and the 1,680-acre Yermo Annex, which is 7 miles east of Barstow between Interstates
15 and 40. Groundwater underlying the Yermo Annex and Nebo Main Base is
designated as Operable Units (OUs) 1 and 2, respectively. OUs 1 and 2 comprise two
major groundwater regions separated by the Harper Lake - Camp Rock Fault: Yermo
Annex groundwater in the Yermo Subbasin; and Nebo Main Base groundwater in the
Barstow Subbasin. This Record of Decision (ROD) addresses the cleanup of
groundwater contamination at OUs 1 and 2 at MCLB Barstow. The area! extent of
interconnected groundwater in which the contamination occurs in each OU is
designated an aquifer, whereas the area! extent of similarly contaminated groundwater
within the aquifer is designated a plume.
In November 1989, MCLB Barstow was placed on the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) National Priorities List (NPL) due
to the presence of soil and groundwater contamination on the Base.
1.2 Statement of Basis and Purpose
This decision document presents the selected remedial actions for the three
contaminant plumes identified in the OU 1 (Yermo Annex plume) and OU 2 (Nebo
North and South plumes) aquifers at MCLB Barstow. The actions selected for these
OUs were developed in accordance with the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) of 1980, as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986, and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
1-1
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The decisions for these OUs are based on the information contained in the
Administrative Record for MCLB Barstow. The two primary documents used for the
basis of the decisions are the Remedial Investigation (Rl) Report for Operable Units 1
and 2 (Jacobs Engineering Group Inc. [Jacobs] 1995a) and the Feasibility Study (FS)
Report for Operable Units 1 and 2 (Jacobs 1995b).
The U.S. Marine Corps, the U.S. Department of the Navy (Navy or DON), the U.S.
Environmental Protection Agency (EPA), and the California Environmental Protection
Agency's (Cal/EPA) Department of Toxic Substances Control (DTSC) and Lahontan
Regional Water Quality Control Board (RWQCB) concur with the selected remedies for
these OUs.
1.3 Assessment of OUs 1 and 2
Actual or threatened releases of hazardous substances from OUs 1 and 2 groundwater
contaminant plumes may present a current or future threat to public health, welfare, or
the environment if not addressed by implementing the response actions selected in this
ROD.
1.4 Description of the Selected Remedy
This ROD addresses the groundwater contaminant plumes in the OUs 1 and 2 aquifers
and related vadose zone contamination. The selected remedies for each groundwater
contaminant plume are described in this section. The remedial approach to the
groundwater and vadose zone contamination is to reduce the contaminant mass in
groundwater and the vadose zone to levels at or below federal and state maximum
contaminant levels (MCLs). The OUs 1 and 2 groundwater contaminant plumes are
primarily characterized by tetrachloroethene (PCE) and trichloroethene (TCE) but also
contain other volatile organic compounds (VOCs). This ROD sets aquifer cleanup
levels for PCE, TCE, 1,1-dichioroethene (1,1-DCE), and 1,2-dichloroethane (1,2-DCA)
as the more stringent of the federal and state MCLs. The major components of the
selected remedies are described as follows.
1-2
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Although, under CERCLA Sec. 121(e)(1), remedial actions are exempt from permitting
requirements, CERCLA requires compliance with substantive applicable or relevant and
appropriate requirements (ARARs) that otherwise would have been addressed in such
permits.
1.4.1 OU 1 - Yermo Annex Plume
The selected remedy involves groundwater extraction, ex situ treatment and
recharge of treated groundwater back into the aquifer, and air sparging/soil
vapor extraction (AS/SVE) systems for groundwater and vadose zone VOC
mass removal. Groundwater cleanup standards are based on removing
constituents to levels at or below secondary and primary MCLs as measured by
groundwater monitoring wells. Vadose zone cleanup standards are based on
removal of VOCs from soils to levels that will not cause groundwater to exceed
the groundwater cleanup standards, based on an interpretation of soil gas data
using appropriate vadose zone fate and transport and groundwater mixing zone
models. Monitoring will be conducted to verify adherence to groundwater
cleanup standards. The major components of the selected remedy include the
following.
• Remedy all the contaminant plume that exceeds the MCL, except directly
beneath waste management areas/waste management units (see Section
2.8.2), by extracting groundwater at three locations: 1) four on-Base wells at
the CERCLA area of concern (CAOC) 26 plume downgradient boundary; 2)
eight wells at the Base eastern boundary; and 3) four off-Base wells at the
MCL boundary.
• Treat extracted groundwater aboveground by activated carbon units.
• Operate existing AS/SVE systems for groundwater/vadose zone source
removal at CAOC 26, and for groundwater VOC mass removal downgradient
of CAOCs 16,15/17, and 35.
• Recharge, treated groundwater back into the aquifer via two infiltration
galleries located at the upgradient edge of the plume.
• Monitor the vadose zone at CAOCs 16, 15/17, and 26 for the effectiveness
of the AS/SVE systems.
• Monitor groundwater throughout the duration of the remedial action, which is
estimated to take approximately 30 years, subject to evaluations of
treatment effectiveness at 5-year intervals.
1-3
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• Monitor groundwater at CAOCs 23 and 35 subject to landfill closure
requirements.
• Sample groundwater quarterly for 1 year for five dissolved metals (nickel,
chromium, antimony, thallium and aluminum) at selected wells in the area of
CAOC 16 to ascertain if these metals are naturally occurring or the result of
Base activities.
• Implement institutional controls as described in Section 1.4.2.
1.4.2 OU 2 - Nebo North Plume
The selected remedy involves an AS/SVE system for groundwater and vadose
zone VOC mass removal at Warehouse 2 and natural attenuation (e.g.,
dispersion, degradation, sorption and volatilization) to reduce contamination in
the groundwater plume to levels at or below MCLs. The remedy also includes
fail-safe pump-and-treat as a backup in case natural attenuation fails to stop
plume migration. The major components of the selected remedy include the
following.
• Use AS/SVE system for groundwater/vadose zone source removal at
Warehouse 2.
• Implement institutional controls including access restrictions to prevent the
use of untreated groundwater for drinking water in the area of the plume
above MCLs, and well head treatment of potentially impacted water supply
wells.
• Design and implement sampling protocol to monitor and evaluate the
progress of natural processes in achieving remediation goals.
• Activate an existing groundwater extraction and treatment pilot study system
on a contingency basis to provide containment backup if natural processes
fail to contain the plume. This ROD establishes "triggers" for turning the
extraction and treatment system on and off, if required.
• Monitor vadose zone at Warehouse 2 for the effectiveness of the AS/SVE
system.
• Monitor groundwater throughout the duration of the remedial action, which is
estimated to take approximately 15 years, subject to evaluations of
treatment and cost effectiveness at 5-year intervals.
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1.4.3 OU2- Nebo South Plume
The selected remedy is an interim remedy consisting of containment and
removal of the groundwater contaminant plume from the aquifer, followed by ex
situ treatment and recharge of treated groundwater back into the aquifer. The
containment measure is a necessary interim action designed to stop any further
migration of the VOC plume. An AS/SVE pilot study is currently underway to
evaluate the feasibility of this technology to reduce remediation time and thus
enhance the cost-effectiveness of containment. The major components of the
selected interim remedy include the following.
• Capture the contaminant plume above MCLs through five groundwater
extraction wells at the leading edge of the plume.
• Treat extracted groundwater by activated carbon units aboveground.
• Recharge treated groundwater back into the aquifer via percolation ponds
located on the northeast comer of the Nebo Main Base, downgradient of the
plume.
• Implement institutional controls as described in Section 1.4.2.
• Select the final remedy at a later date with an accompanying Proposed Plan
and ROD.
A major component of the selected interim remedy will also include conducting
Phase II of the AS/SVE pilot study to further investigate the extent of vadose
zone and groundwater contamination underlying CAOC 6, and evaluating the
technical feasibility and effectiveness of AS/SVE at this CAOC.
1.5 Statutory Determinations
The selected remedies for the OUs 1 and 2 groundwater contaminant plumes 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
actions, and are cost-effective. These remedies use permanent solutions and
alternative treatment technologies to the maximum extent practicable and satisfy the
statutory preference for remedies that employ treatment that reduce toxicity, mobility, or
volume as a principal element.
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The effectiveness of the remedial actions for each of the plumes will be reviewed at a
minimum at 5-year intervals, or as otherwise prescribed in this ROD, during operation
of the respective systems to ensure that the remedies continue to adequately protect
human health and the environment and are achieving cleanup goals.
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FOR THE UNITED STATES MARINE CORPS, MARINE CORPS LOGISTICS BASE,
BARSTOW:
D.O. McBride
C
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2.0 SITE BACKGROUND
2.1 Facility Location and Description
MCLB Barstow (also referred to as the Base) is located within the central Mojave
Desert in San Bernardino County, California (Figure 2-1). The Mojave River traverses
the Base from west to east. The Base consists of two areas: Nebo Main Base, which
includes the Rifle Range, and the Yermo Annex. The Nebo Main Base (1,568 acres) is
3.5 miles east of Barstow and is intersected by Interstate 40. The Rifle Range (2,438
acres) is south and adjacent to the Nebo Main Base. The Yermo Annex (1,680 acres)
is 7 miles east of Barstow, adjacent to Interstate 15. Other surrounding communities
include Yermo to the northeast and Daggett to the east.
2.2 Present Site Use
MCLB Barstow is a large-scale industrial facility. The primary mission of MCLB Barstow
is to provide logistical support to Marine Corps commands throughout the western
United States and the Pacific. The mission includes procuring, storing, and distributing
military supplies and equipment and maintaining and repairing operational and combat
equipment.
The Nebo Main Base is the center for most of the Base administration, Base housing,
military and dependent support facilities, and covered storage for supplies and
equipment. The Rifle Range is a secured area where Marines can practice and
improve their marksmanship. The Yermo Annex is used mainly for maintenance and
repair activities.
Workers and residents at the Nebo Main Base receive their domestic water from the
Southern California Water Company. There are no active groundwater production
wells at the Nebo Main Base.
Two active groundwater production wells at the Yermo Annex (YDW-4 and YDW-5) are
within the Yermo contaminant plume. Both of these wells have carbon filtration
treatment systems to remove VOCs to non-detectable levels. This water is used for
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various domestic and industrial uses at the Yermo Annex. The two active wells are
operated in compliance with the State's drinking water program A third groundwater
production well at the Yermo Annex is inactive.
The areas immediately surrounding MCLB Barstow are basically undeveloped except
for some small-scale, older commercial development along Highway 66 west of the
main entrance to the Nebo Main Base. Future plans in the immediate vicinity indicate
five main land uses:
• Rural-urban (low density residential)
• Open space/recreation
• Agricultural
• Industrial
• Commercial.
The area west of the main entrance to the Main Base where Interstate 40, Route 66,
and the Atchison, Topeka, and Santa Fe (AT&SF) railroad lines converge is slated for
industrial development per the City of Barstow and San Bernardino County.
2.3 Site History and Enforcement Activities
MCLB Barstow was established in 1942 at Nebo Main Base (Figure 2-1) as a Marine
Corps Depot of Supplies; that is, a staging area for supplies and equipment for Marine
Corps forces deployed in the Pacific during World War II. By 1943, the Marine Corps
Depot of Supplies began providing logistical support to Marine Corps commands
throughout the western United States and the Pacific.
Yermo Annex (Figure 2-1) was acquired in 1946 because Nebo Main Base operations
outgrew escalating mission requirements. In 1961, a 10-acre central repair shop
(Building 573) was built to provide additional vehicle repair and rebuilding capabilities.
The Rifle Range (Figure 2-1) was acquired in the mid-1950s for shooting practice and
continues to serve the same function today with minimal changes.
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Until the early 1960s, MCLB Barstow's major industrial operations were conducted at
Nebo Main Base; in the early 1960s, the major industrial operations were moved to the
Yermo Annex. The hazardous waste generation and disposal operations associated
with these industrial activities began at Yermo Annex at this same time.
Operations at MCLB Barstow have included maintaining, issuing, and shipping
materials held in the Marine Corps Stores Distribution System. During its 50 years of
operation, MCLB Barstow has generated industrial waste such as waste oil, fuel,
solvent, paint residue, grease, hydraulic fluid, battery acid, various gases, and other
components, including some that are sources of low-level radiation. Additional waste
generated included pesticides, herbicides, polychlorinated biphenyls (PCBs), calcium
hypochlorite, and sodium hypochlorite. In the early years, some of these wastes were
disposed of in landfills, bum trenches, and other areas located throughout the Nebo
Main Base, Yermo Annex, and the Rifle Range.
With the passage of CERCLA in 1980, the Navy began the Installation Restoration (IR)
Program to identify, investigate, and clean up past hazardous waste disposal sites.
MCLB Barstow and the Navy have been actively involved in this program since the
early 1980s.
Site assessment activities have been conducted since 1983 to determine the nature
and extent of contamination and hydrogeological conditions underlying the Base. In
1988, chlorinated solvents, including trichloroethene (TCE), were found in groundwater
production wells at the Yermo Annex, and the wells were connected to a carbon
filtration treatment system. Several groundwater production wells at the Nebo Main
Base were abandoned due to groundwater degradation. In 1977, the Nebo Main Base
was connected to the Southern California Water Company system for its potable water
supply.
In November 1989, the Base was placed on the CERCLA National Priorities List (NPL)
due to the presence of soil and groundwater contamination. In October 1990, MCLB
Barstow entered into a Federal Facility Agreement (FFA) with the EPA, the DTSC, and
the California Regional Water Quality Control Board (CRWQCB). The FFA constitutes
a legally binding agreement between the Marine Corps and the regulatory agencies.
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The FFA specified a schedule for completing the CERCLA investigation and
remediation activities, and defined seven OUs at the Base. OUs 1 and 2 address the
groundwater contamination at the Yermo Annex and the Nebo Main Base, respectively.
OUs 3, 4, 5, and 6 address soil contamination at 36 CAOCs. OU 7 was created to
include any additional CAOCs that may be identified from the ongoing Resource
Conservation and Recovery Act (RCRA) Facility Assessment (RFA) at the Base.
Groundwater Rl activities for OUs 1 and 2 were conducted within the framework of the
FFA to define regional hydrogeologic conditions and assess the nature and extent of
groundwater contamination at the Base. Phase I Rl activities were conducted between
February and December 1992. The Phase I Rl identified the presence of VOCs
exceeding federal and state drinking water standards in the groundwater at both the
Yermo Annex and the Nebo Main Base. Phase II Rl activities, conducted between
June and September 1994, focused on defining the vertical and lateral extent of the
groundwater contamination detected in Phase I. The investigative approach and
results of the groundwater Rl are presented in the Draft Remedial Investigation Report,
dated 15 June 1995 (Jacobs 1995a).
2.4 Scope and Role of OUs 1 and 2
For investigative purposes, the Federal Facility Agreement groups the inferred
hazardous waste disposal sites (designated CAOCs) at MCLB Barstow into seven
operable units as follows. CAOCs are grouped into OUs on the basis of similar
characteristics to facilitate response actions.
• OU 1: Groundwater and vadose zone contamination underlying the Yermo
Annex. The Rl identified one large commingled VOC plume emanating from
several sources including CAOCs 16,15/17, 23, 26, and 35.
• OU 2: Groundwater and vadose zone contamination underlying the Nebo Main
Base. The Rl identified two discrete plumes: the Nebo north plume, believed to
have originated from Warehouse 2; and the Nebo South plume, which
originated from CAOC 6.
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• OU 3: Shallow soil contamination at the Yermo Annex from five CAOCs (18, 20,
21, 23, and 34), for which analytical data existed prior to the Rl.
• OU 4: Shallow soil contamination at the Nebo Main Base from four CAOCs (2,
5, 9, and 11), for which analytical data existed prior to the Rl.
• OU5: Shallow soil contamination at the Yermo Annex from 16 CAOCs (15/17,
16, 19, 22, 24 through 32, 35, and 36), for which analytical data did not exist
prior to the Rl.
• OU 6: Shallow soil contamination at the Nebo Main Base from 11 CAOCs (1, 3,
4, 6, 7, 8, 10, 12, 13, 14, and 33), for which analytical data did not exist prior to
the Rl.
• OU 7: Soil and groundwater contamination from any additional solid waste
management units (SWMUs) that may be identified under the RFA process to
have released hazardous materials into the soils.
This ROD provides information about the alternatives considered for groundwater and
vadose zone remedial actions at OUs 1 and 2, and identifies the selected alternative
with the rationale for its selection.
This information is based on detailed field investigation and engineering reports
prepared for OUs 1 and 2. The three primary documents are the Remedial
Investigation (Rl) Report for OUs 1 and 2 (Jacobs 1995a), the Feasibility Study (FS)
Report for OUs 1 and 2 (Jacobs 1996a) and the Proposed Plan for OUs 1 and 2
(Jacobs 1996b). The Rl and FS reports are part of the MCLB Barstow Administrative
Record. The Draft Final Proposed Plan is undergoing public comment.
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2.5 Summary of Site Characteristics
2.5.1 General Site Conditions
In general, both the Nebo Main Base and the Yermo Annex, including those
areas near potentially contaminated groundwater, are located near the Mojave
River where topography is relatively flat. The topographic surface slopes gently
north to the river at the Nebo Main Base and the Rifle Range, and gently slopes
south-southeast to the river at the Yermo Annex.
The Mojave River is the dominant surface water feature in the Mojave Desert.
The Mojave River originates as a series of interconnecting drainages along the
northeast front of the San Bernardino Mountains, extends east-northeast from
the mountain front, passes through the Base, and terminates at Soda Lake
about 70 miles east of the Base. Because the river is primarily fed by mountain
front drainages, the river bed is generally dry; flows in the Barstow area are
limited to periods of heavy rainfall. Surficial flow is also evident near areas of
bedrock highs and intermittently along the Harper Lake-Camp Rock fault near
the Nebo Main Base.
On average, about 90 percent of the flow of the Mojave River is retained within
the Mojave River drainage basin to recharge several groundwater basins,
including the Yermo and Barstow subbasins (California Department of Water
Resources [DWR] 1967). MCLB Barstow is partly within the 100-year floodplain
of the Mojave River, which passes through the northern portion of Nebo Main
Base and the southern portion of the Yermo Annex. On-site flooding at the
Nebo Main Base is rare and even less frequent at the Yermo Annex. The
surface water drainage systems at both Yermo Annex and Nebo Main Base
have been designed to intercept and convey runoff water to the Mojave River.
The Barstow area is characterized by intense summer heat, minimal rainfall and
low humidity, strong winds, periodic thunderstorms, and flash floods. Factors
that tend to moderate the weather in other areas of California are absent in the
Mojave Desert, resulting in an extreme climate. Temperature ranges from 12°
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Fahrenheit (F) to 114° F annually. Winds near Barstow are primarily from the
west at an average annual speed of about 11 miles per hour (mph). Wind gusts
of up to 65 mph have been recorded.
Annual average precipitation in the Barstow area is about 4 inches per yean
however, considerable year-to-year variability occurs, which results in the
variable discharge conditions of the Mojave River. Precipitation in the Mojave
Desert occurs primarily with the passing of weakened winter fronts from the
north and the periodic development of brief, localized thunderstorms during the
summer. Periodic episodes of intense rainfall create flash flood conditions
(referred to as floodflows) in the Mojave and in the intermittent washes near the
Base and Barstow.
2.5.2 Geology
MCLB Barstow is within the Mojave Desert Geomorphic Province (Jacobs
1994a). This province is a wedge-shaped unit bounded by the Gariock Fault on
the north and the San Andreas Fault on the southwest. The approximate
eastern boundary is the Bristol-Granite Mountains fault zone in the eastern
Mojave Desert. At this diffuse boundary, the Mojave Desert merges with the
Basin and Range Geomorphic Province.
The Mojave Desert Geomorphic Province is characterized by a series of low-
lying, northwest-trending, fault-block mountain ranges with intermontane basins
and local playas (dry lakes). The ranges are composed primarily of
Precambrian granitic and metamorphic rocks, Paleozoic sedimentary rocks,
Mesozoic granitic and volcanic rocks, and late Tertiary sedimentary and volcanic
rocks. The intermontane basins are largely filled with late Tertiary and
Quaternary alluvium. The tectonic grain is essentially defined by a series of
closely spaced northwest-trending faults. East-trending faults are more
common near the Gariock fault.
MCLB Barstow is located along the west-northwest-trending Barstow Basin,
roughly bounded by the Blackwater/Calico faults to the northeast and the
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Lenwood fault to the southwest (Figure 2-2). The Barstow Basin slopes sharply
to the southeast. Bedrock beneath the Base reaches depths of 3,500 feet
below ground surface (bgs). Exposed local bedrock consists primarily of
Tertiary sedimentary and volcanic rocks. The basin is filled by a sequence of
late Tertiary to early Quaternary alluvial deposits. The surface is mantled by
windblown sand deposits and young alluvial deposits derived from either the
Mojave River or shed from adjacent highlands. The southern portion of the
facility is underlain by coarse, alluvial fan debris containing abundant gravel and
cobbles.
2.5.3 HvdroaeoloQv
MCLB Barstow is within the Mojave River Drainage Basin, which covers about
3,700 square miles within the south-central Mojave Desert (Jacobs 1995a).
The Mojave River Drainage Basin consists of a series of subbasins separated
by largely impermeable bedrock. MCLB Barstow is within the Lower Mojave
subunit. The Lower Mojave subunit is further divided into several subbasins.
The Nebo Main Base and the Yermo Annex are within the Barstow and Yermo
subbasins, respectively. Water-bearing sediments within these subbasins are
composed primarily of late Pleistocene to Holocene alluvial deposits shed from
adjacent highlands. These deposits are unconsolidated to partially consolidated
and consist primarily of sand, silt, and gravel with lenses of clay.
The Barstow subbasin extends over approximately 20 square miles and is
delineated by various hydraulic boundaries. The projection of the Harper Lake-
Camp Rock Fault to the east, consolidated rocks to the west, and the terminus
of unconsolidated sediments to the north and south delineate the Barstow
subbasin (Miller 1969). The larger Yermo subbasin, similarly bounded by
groundwater barriers, extends over 65 square miles. The Yermo subbasin
shares a common boundary with the Barstow subbasin at the Harper Lake-
Camp Rock Fault, but its northwest boundary is not well defined (United States
Geological Study [USGS] 1969).
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Groundwater conditions at MCLB Barstow are monitored by an extensive
network of shallow, intermediate, and deep monitoring wells installed during
prior and current environmental and engineering studies (Jacobs 1991; 1993b).
The inventory of monitoring wells drilled under this investigation at the Yermo
Annex and Nebo Main Base is provided in the Draft Final Rl report. Figures 2-3
and 2-4 depict the location of monitoring wells and hydrogeologic cross section
at the Yermo Annex, respectively. Figures 2-5 and 2-6 depict the location of
monitoring wells and the hydrogeologic cross section at Nebo Main Base,
respectively.
The Mojave River recharges regional ground water. However, groundwater
conditions at the Yermo Annex are significantly different from conditions at the
Nebo Main Base. Monitoring well gauging results indicate that groundwater is
encountered from between 133 and 147 feet bgs at the Yermo Annex. At the
Nebo Main Base, groundwater is encountered between approximately 10 and
75 feet bgs in the central area of the Base and up to 175 feet bgs on the alluvial
fan south of Interstate 40. In the bed of the Mojave River, groundwater has
been encountered at depths of only 4 to 5 feet bgs (Jacobs 1993a).
The depth to the groundwater table has remained relatively stable at the Nebo
Main Base but has been lowered about 70 feet at the Yermo Annex since the
1930s (Miller 1969). The lowering of the water table can be attributed to
regional groundwater withdrawal due primarily to agricultural irrigation wells, with
minor influences coming from private and public production wells. Two active
groundwater production wells at the Yermo Annex are currently being operated
in compliance with the State's drinking water program. Groundwater production
wells at Nebo Main Base have been inactive since 1975 (Jacobs 1993a).
2.5.4 Groundwater Flow Directions and Gradients
The groundwater table surface beneath the Yermo Annex gently declines
towards the east-southeast, with hydraulic gradients ranging typically from
0.0006 to 0.001 foot per foot (ft/ft).
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Aquifer recharge from a Mojave River flood in April 1993 redirected groundwater
flow at the Yermo Annex to the north-northeast and increased the hydraulic
gradients to approximately 0.005 ft/ft. However, the regional flow direction and
gradients returned to pre-flood flow conditions within 4 months after the
recharge event. Figure 2-7 depicts the typical groundwater table contour map
for the Yermo Annex based on groundwater depth measurements collected in
January 1994.
The elevation of the groundwater table at the Yermo Annex is approximately
1,810 to 1,825 feet above mean sea level (MSL), and the groundwater table at
Nebo Main Base lies between 1,980 and 2,085 feet above MSL. The average
water table elevation difference between shallow wells (screened across the
water table) and intermediate depth wells (screened at depths of 50 to 60 feet
below the water table) is at or dose to zero, and the absolute values of the
maximum and minimum water table elevation differences are virtually equal.
Therefore, no net vertical gradients have been determined to exist at the Yermo
Annex.
At the Nebo Main Base, the groundwater gradient at the southwestern comer,
which is the topographically high area, is directed radically towards the north,
northeast, and east, at a slope of approximately 0.01 to 0.03 ft/ft (Figure 2-8).
The groundwater flow gradient decreases to approximately 0.002 ft/ft near the
central part of the Main Base, and the flow direction changes to predominantly
northeast. The flow direction then changes to predominantly eastward
underlying the Base golf course, located at the northern Main Base immediately
south of the Mojave River channel. The change in groundwater flow direction
along eastern Nebo Main Base is attributed to the presence of the Harper Lake-
Camp Rock fault and shallow bedrock to the north.
Monitoring well clusters at the Nebo Main Base, consisting of intermediate and
shallow depth wells, were measured for the presence of vertical flow gradients.
Wells NSI-6/NSI-7 and NWP-1/NS10-1 displayed a net downward vertical
gradient of 0.020 and 0.018 ft/ft, respectively. Monitoring wells NWP-3/NWP-7
and NS2-1/NS2-3 had a net upward vertical gradient of 0.093 and 0.013 ft/ft,
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respectively. Vertical gradients on all other wells at Nebo Main Base were less
than 0.005 ft/ft.
2.5.5 Groundwater Use
The Lower Mojave subunit, which includes the Barstow and Yermo subbasins, is
classified as a source of drinking water (i.e., Class I Aquifer) in the
Comprehensive Water Quality Control Plan for the Lahontan Region.
Groundwater is the sole source of drinking water in this area and its quality may
have been impacted since at least 1952. Both the Yermo Annex and Nebo
Main Base have evidence of solvent-contaminated groundwater.
The Yermo Annex area relies on on-Base water supply wells to meet its
domestic water needs. Groundwater at the Yermo Annex is extracted from the
aquifer and treated through a carbon filtration system. The Nebo Main Base
receives its drinking water through a pipeline from the City of Barstow, which
gets its water supply from groundwater wells in the Mojave River Drainage
Basin, upgradient from the Base.
2.6 Groundwater Removal Actions
As the lead agency, the Marine Corps has adopted the policy that removal actions will
take priority over continued investigation when the removal action is deemed to be
protective of human health and consistent with the final remedy. Two time-critical and
one non-time-critical groundwater removal actions have been implemented at MCLB
Barstow to address groundwater contamination at both the Yermo Annex and Nebo
Main Base. These removal actions, described as follows, meet the requirements of
CERCLA and have been fully incorporated into the remedial actions selected in this
ROD.
In 1992, TCE concentrations above drinking water MCLs were detected in a private
residence drinking water well located within the off-Base Nebo south plume boundary.
A time-critical removal action was conducted to remove the well from service and
connect the residence to the Base water supply system.
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In 1994, levels above drinking water standards were detected off-Base about 2,000
feet downgradient of the Yermo Annex eastern boundary. Trace levels (less than 1
part per billion [ppb]) were detected in one of two private residence wells located
downgradient of this area. The Base conducted a time-critical removal action to
provide the two private residence wells with wellhead carbon treatment systems as a
precautionary measure.
A non-time-critical removal action (NTCRA) for groundwater containment and cleanup
is being conducted at the Yermo Annex and has been incorporated into this ROD. The
purpose of the NTCRA is to prevent further migration of contaminants beyond the Base
boundary and accelerate groundwater cleanup activities.
MCLB Barstow has also conducted removal actions for soils under OUs 3 and 5 at the
Yermo Annex, and OU 4 at the Nebo Main Base. These removal actions are described
in the respective RODs for these OUs, which are part of the MCLB Barstow
Administrative Record.
2.7 Risk Characterization/Management
2.7.1 Assessment of Risk
The NCR directs the Marine Corps, as the lead agency for MCLB Barstow, to
conduct a baseline risk assessment (BLRA) to determine whether the Base
poses a current or potential threat to human health and the environment in the
absence of any remedial action. The BLRA provides the basis for defining
acceptable risk ranges to determine if either no action or a selected remedy will
be protective of human health and the environment.
Cancer risk is expressed in terms of the chance of contracting cancer over a
human's lifetime due to exposure to site chemicals, and is called the incremental
lifetime cancer risk (ILCR). A risk of 1 out of 1 million means that one additional
person out of a group of 1 million may develop cancer as a result of exposure to
a chemical. EPA considers a risk of less than 1 x 10"* (1 in a million) to be
protective of human health, and uses this value as the point of departure. The
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EPA also has developed a risk management range represented as 10"6 to 10"4
as the target range for managing cancer risks. An ILCR above 10"4 (e.g., 10"3)
generally requires remedial action.
Non-cancer health effects are evaluated in terms of a hazard index (the ratio of
the actual or potential level of exposure to an acceptable level of exposure).
EPA uses a hazard index level of less than 1 to be acceptable for non-cancer
health effects. Non-cancer hazards significantly above 1 indicate a potential for
adverse effects.
2.7.2 Summary of Human Exposure Assumptions
The BLRA for OUs 1 and 2 used a future resident exposure scenario with the
following exposure assumptions for the identified pathways:
• A 70-kg adult on-site resident exposed 350 days per year for 30 years.
• A 15-kg child on-site resident exposed 350 days per year for 6 years.
• Adult and child ingest 2 and 1 liters of water per day, respectively, for the
exposure frequency and duration stated above.
• A resident showers daily with site groundwater.
• The contaminated groundwater is used as a drinking water source
without treatment.
• Users are exposed to the maximum concentrations detected in the
plume.
2.8 Remediation Goals
2.8.1 Groundwater Cleanup
Primary MCLs
Groundwater cleanup levels for VOCs are established to ensure that any
persons exposed in the future will not be exposed to unsafe levels of chemicals
of concern. These cleanup levels are based on a detailed analysis of chemical-
specific applicable or relevant and appropriate requirements (ARARs) and
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health risk-based criteria that are consistent with the present and projected
beneficial uses of the affected aquifers.
MCLB Barstow overlies the Lower Mojave subunit, which is classified as a
source of drinking water (Class I aquifer) in the Comprehensive Water Quality
Control Plan (WQCP) for the Lahontan Region. The Nebo Main Base receives
its water supply from the Southern California Water District. The Yermo Annex
obtains its water from the Yermo subbasin. The only two active water supply
wells at the Yermo Annex have carbon filtration systems to meet drinking water
standards.
Because the groundwater is a source of drinking water, federal MCLs, nonzero
maximum contaminant level goals (MCLGs), and those state MCLs that are
more stringent than federal MCLs are relevant and appropriate ARARs for the
groundwater in the aquifer (EPA 1990). In addition to the Lahontan Region
WQCP and the federal and state drinking water standards, the RCRA
groundwater protection standards have also been determined to be relevant
and appropriate for remedial actions for OUs 1 and 2 due to the nature of the
chemicals of potential concern. The RCRA groundwater protection standards
require cleanup to background levels (i.e., the water quality that existed before
the discharge), unless background levels can be demonstrated to be technically
and economically infeasible to attain. Concentration limits greater than
background levels cannot exceed MCLs.
Pursuant to the RCRA Water Quality Protection Standard in Title 22 California
Code of Regulations (CCR) Section 66264.94, the DON evaluated two sets of
potential concentration limits for the purpose of establishing groundwater VOC
cleanup levels (see Table 2-1).
1) The most stringent federal and state drinking water standards (i.e.,
MCLs), and
2) Background levels based on readily achievable detection limits (i.e.,
0.5 ug/L).
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The ILCRs for chemicals of concern within each plume calculated for both of
these standards fall within the EPA risk management range of 10"* to 10"4. Both
set of standards are considered to be protective of human health and the
environment.
The technical and economic feasibility (TEF) of remedial alternatives to achieve
both sets of cleanup standards (i.e., MCLs and background) was evaluated in
the OUs 1 and 2 FS for each of the ground water plumes at MCLB Barstow. The
results of the TEF evaluation for the Yermo Annex, Nebo North and Nebo South
contaminant plumes are summarized in Sections 3.3.1, 4.3.1, and 5.3.1 of this
ROD, respectively. The complete TEF was provided to the agencies as
Appendix J of the OUs 1 and 2 Draft Final FS Report (Jacobs 1997).
Based on the TEF analysis and risk assessment results, the DON concluded
that achieving background levels of constituents in the groundwater is not
technically or economically feasible, and established MCLs as the cleanup
levels for groundwater remedial actions under this ROD consistent with the
requirements of 22 OCR 66264.94, 23 CCR 2550.4, and SWRCB Resolution
Nos. 68-16 and 92-49. MCLs will be attained throughout the contaminant
plume, except directly beneath WMAs/WMUs. The FFA signatories agreed on
and approved this conclusion in the Proposed Plan for OUs 1 and 2.
Secondary MCLs
The State asserts that the narrative taste and odor water quality objective
specified in the WQCP for the Lahontan RWQCB, which incorporates State
primary and secondary drinking water standards, is an ARAR that applies to the
establishment of cleanup levels in these OUs. The DON and EPA agree that the
negative taste and odor water quality objective is an ARAR, but do not agree
that the secondary standard of three odor units is an ARAR because the
measurement is subjective based upon the sensory determination of a panel.
The DON agrees to implement the taste and odor objective for toluene and
xylenes by using the numeric taste and odor standards proposed by EPA (see
56 Federal Register 3572, 3573, 30 January 1991), but not promulgated, as 1o-
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be-considered" standards that will be identified as performance goals in this
ROD. If the DON demonstrates compliance with the performance goals, the
DON shall be deemed to be in compliance with the taste and odor water quality
objectives and the secondary MCLs for xylene and toluene.
2.8.2 Points of Compliance with Groundwater Cleanup Standards
Background
The CERCLA NCR preamble provides that compliance with groundwater
cleanup standards should be attained throughout the affected area of the
aquifer or at and beyond the downgradient edge of the waste management area
(WMA) when the waste is left in place (the "point of compliance"). See NCR
preamble at 55 Federal Register 8753, 8 March 1990. Title 22 CCR Section
66264.95 contains similar provisions for RCRA "regulated units" and Title 23
CCR Section 2550.5 contains similar provisions for "point of compliance" for
waste management units (WMU) regulated under Title 23 CCR Chapter 15.
It is the DON'S position that the designation of "points of compliance" at the
downgradient edge of all CAOCs addressed in this ROD would be appropriate
and is supported by CERCLA, the NCR, and the administrative record for this
ROD, and that the remedial action objective (RAO) of achieving the federal
MCLs for RCE, TCE, and 1,1 DCE should apply throughout the contaminant
plume downgradient from the points of compliance. The DON believes
contamination upgradient of the points of compliance would be adequately
contained by the remedial action to ensure compliance with this RAO and would
adequately protect human health and the environment.
The NCR preamble states that there may be certain circumstances where a
plume of groundwater contamination is caused by releases from several distinct
sources that are in dose geographical proximity. The NCR preamble provides
that, in such cases, the most cost-effective groundwater cleanup strategy may
be to address the problem as a whole rather than on a source-by-source basis,
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and to draw a common "point of compliance" that encompasses all the sources
of release (55 Federal Register 8753, 8 March 1990).
See Appendix A for a more detailed explanation of the DON'S position regarding
the applicability of "point of compliance" regulatory provisions to the CAOCs
addressed in this ROD.
Designation of Point of Compliance
EPA and DISC agree that CAOCs 23, 35, and the majority of CAOC 15/17 are
WMAs/WMUs and that the designation of a "point of compliance" at the
downgradient edges of these units is appropriate. The DON hereby designates
"points of compliance" at the downgradient edge of CAOC 23 and the common
downgradient edge of CAOCs 35 and 15/17. Portions of CAOC 23 and 35
contain landfill WMUs that the DON will permanently close in-place. The WMUs
at CAOC 15/17 encompass 14 evaporation ponds, four sludge drying beds, a
temporary pond, three oxidation ponds, and the overflow area around the
ponds. At CAOC 15/17, waste residues have been removed from the WMUs
and disposed of at an appropriate off-Base facility. The DON is not proposing
any further use of the WMUs at CAOC 15/17 for waste disposal and the WMUs
are currently not permitted to receive waste. The WMUs cover the majority of
CAOC 15/17, except for the wet well, and extend from near the upgradient
boundary down to the downgradient edge of the CAOC.
The CRWQCB does not agree with DON'S proposed use of the "point of
compliance," but the CRWQCB is not contesting its use in this case, because
DON has installed a groundwater monitoring network throughout the
groundwater plume area and agrees to meet groundwater cleanup standards at
all monitoring points within the network mutually agreed upon in the post-ROD
groundwater monitoring plan. The DON has also agreed to install vadose zone
monitoring networks in soils underlying CAOC 26 and Warehouse 2, and meet
the vadose zone cleanup standard specified in Section 2.8.4
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The DON is not designating "points of compliance' for CAOCs 6, 16, 26, and
Warehouse 2 solely in the interest of obtaining the concurrence of EPA, DISC,
and the RWQCB on this ROD. The DON'S agreement to comply with
groundwater cleanup standards throughout the contaminant plume at these
CAOCs is subject to the express reservation of its rights to propose the use of
"points of compliance" for these areas in the future. The DON shall address
such proposed "points of compliance" in explanation of significant differences
(ESDs), ROD amendments, or new RODs that shall be submitted to the FFA
signatories as a primary FFA deliverable. The FFA signatories agree that this
decision will not set precedent for any other CAOCs or installations.
2.8.3 Vadose Zone Cleanup Standards
The DON and regulatory agencies have jointly determined the amount of
vadose zone cleanup necessary to protect human health and environment.
Unlike surface soil contamination, vadose zone contamination does not
constitute a "walk-on" health risk (e.g., through direct soil contact) to a human
receptor unless the contaminated soil becomes exposed by human activity (e.g.,
excavation). Surface soil contamination and the associated walk-on risk is
addressed in the soil OUs (i.e., OUs 3 to 6).
The RAO for vadose zone cleanup at MCLB Barstow is to remove contaminant
mass in the subsurface soils to the degree necessary to 1) prevent further
degradation of the groundwater above groundwater cleanup standards and 2)
minimize the aquifer cleanup time. Vadose zone soils cleanup goals are source-
specific.
Vadose zone sources at the Yermo Annex include CAOCs 15/17, 16, 23, 26
and 35. Vadose zone remedial actions for these sources are discussed in detail
in Section 3.3.2. Vadose zone sources at the Nebo Main Base include
Warehouse 2 in the Nebo North area and CAOC 6 at the Nebo South area.
Vadose zone remedial actions for these sources are discussed in detail in
Sections 4.3.2. and 5.3.2 for Nebo North and Nebo South respectively.
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Vadose zone cleanup using AS/SVE technology has been selected as part of
the remedy for CAOC 26 and Warehouse 2. Criteria for assessing attainment of
vadose zone cleanup goals at these sources are discussed in Sections 2.8.4
through 2.8.6 below.
2.8.4 Criteria for "Shut-off" of AS/SVE Systems
AS/SVE systems used to remove VOCs from vadose zone and groundwater at
MCLB Barstow will be operated until one of the following two conditions are
reached:
1. (a) remaining vadose zone VOC concentrations no longer cause modeled
groundwater concentrations to exceed the groundwater cleanup standards
(based on interpretation of soil gas data using appropriate vadose zone
fate and transport and groundwater mixing zone models), and (b)
representative groundwater concentrations measured within the AS/SVE
system radius of influence (ROI) have achieved groundwater cleanup
standards, or
2. VOCs in the vadose zone and groundwater within the ROI of the AS/SVE
system have been removed to the extent technically and economically
feasible. That is, the incremental benefit of attaining further reduction in
the concentration of VOCs is exceeded by the incremental cost of
achieving those reductions through pump and treat.
The DON will demonstrate that vadose zone cleanup standards have been
achieved for Part (a) of Condition 1 through an examination of the current
effects of remaining vadose zone contamination on groundwater based on an
interpretation of soil gas data using appropriate vadose zone fate and transport
and groundwater mixing zone model(s) (using a mixing zone extending to a
depth of 10 feet below the water table). If it is demonstrated that soil gas
concentrations of chemicals of concern (COCs) in the vadose zone no longer
cause modeled groundwater concentrations to exceed the cleanup standards,
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the parties agree that the demonstration for Part (a) of Condition 1 has been
made.
It is the CRWQCB's position that the purpose of soil remediation as specified in
state law and policy is to remove VOCs so that they no longer cause or threaten
to cause pollution in the groundwater, that is, that VOCs are no longer migrating
into the groundwater at greater than, in this case, the groundwater cleanup
standards. The CRWQCB asserts that the Marine Corps' proposed methodology
for determining shutoff of the AS/SVE system does not provide information to
evaluate whether VOCs are no longer migrating into the groundwater at
concentrations greater than the cleanup standard. A model using a 10-foot
mixing zone may not be appropriate in predicting whether VOCs in the vadose
zone will enter groundwater at levels that are greater than the groundwater
cleanup standards. However, the CRWQCB will not dispute the proposed
shutoff criteria if the facility agrees to provide detailed results of both the vadose
zone model and associated groundwater model including all model parameters.
The DON will demonstrate that groundwater cleanup standards have been
achieved for Part (b) of Condition 1 through collection of groundwater samples
from monitoring wells agreed upon by all parties. If it is demonstrated that the
representative groundwater concentrations of COCs meet the groundwater
cleanup standards, the parties agree that the demonstration for Part (b) of
Condition 1 has been made.
If it is determined that the cleanup standards in Condition 1 cannot be
achieved, the DON will demonstrate that VOCs in the vadose zone and
groundwater within the ROI of the AS/SVE have been removed by AS/SVE to
the extent technically and economically feasible as set forth in Condition 2, by
analyzing the following seven factors:
1. Whether the mass removal rate is approaching asymptotic levels after
temporary shutdown periods and appropriate optimization of the AS/SVE
system;
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2. The additional cost of continuing to operate the AS/SVE system when mass
removal reaches asymptotic levels;
3. The predicted effectiveness and cost of further enhancements of the
AS/SVE system (e.g., additional vapor extraction wells, air injection) beyond
optimization of the existing system;
4. Whether the cost of ground water pump and treat will be significantly more if
AS/SVE is discontinued;
5. Whether discontinuing the AS/SVE will significantly prolong the time to attain
the groundwater cleanup standard;
6. Historic data that present the AS/SVE system operating costs per unit of
VOC mass removed from the vadose zone and groundwater and the
concurrent soil gas and groundwater VOC concentrations, both as a function
of time; and
7. Historic data that present the groundwater pump and treat system operating
costs per unit of VOC mass removed from the groundwater and the
concurrent groundwater VOC concentrations, both as a function of time.
The signatory parties agree that the AS/SVE system may be cycled on and off
in order to optimize the operation and/or evaluate the factors listed above.
The DON will submit a primary document under the FFA providing the
appropriate demonstrations. The signatory parties to this ROD will jointly make
the decision that the AS/SVE system may be shut off permanently based on the
criteria set forth in this ROD.
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2.8.5 Vadose Zone and Groundwater Modeling to Determine AS/SVE
System "Shut Off"
Two separate models will be used to determine when to shut-off an AS/SVE
system: a vadose zone contaminant fate and transport model to simulate
contaminant migration into groundwater, and a groundwater mixing zone model
to calculate groundwater concentrations from the contaminant mass fluxes
supplied by the vadose zone model.
Under Part (a) of Condition 1, performance parameters for vadose zone
modeling will be measured by using vapor probes located at representative
depths in the vadose zone. The vapor probe monitoring results will provide an
indication of the VOC mass removal in the vadose zone. The DON proposes a
1 0-foot mixing zone be used to calculate groundwater concentrations from the
mass flux supplied by the vadose zone model because the 1 0-foot mixing zone
is representative of a typical monitoring well screen interval at MCLB Barstow.
2.8.6 Determination of Asymptotic Conditions for "Shut Off' of
AS/SVE Component of Groundwater Remedy
The DON will track the cumulative mass of VOCs removed by the AS/SVE
system, and plot the data as function of time, to help determine how quickly the
cumulative mass removed approaches asymptotic levels. It is expected that the
resulting graph of cumulative VOC mass removed versus time will follow the
general curve defined by the following exponential decay equation:
Where:
M(t) = Total cumulative mass removed at time t.
MI = Total mass removed from vapor extraction well T.
KT = Maximum cumulative total mass which the AS/SVE system
approaches asymptotically.
T = Time constant, or resident time equal to the amount of time at
which the AS/SVE system removes approximately 63% of KT
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(theoretically, T is equivalent to V/Q, or the volume of soil gas in
the vadose zone being remediated [V] divided by the volumetric
flowrate of the AS/SVE system [Q]).
t= Any time during system operation at which cumulative mass
removed is calculated.
i= Any vapor extraction well for which total mass removed is
calculated.
The above equation will be used as a guide to help determine when asymptotic
conditions have been reached. The 'asymptote' to the mass removal curve is
that total/cumulative maximum mass (KT - defined above) which the AS/SVE
system attempts to remove but approaches with ever decreasing speed.
Asymptotic conditions will have been reached when the upper limb of this curve
is substantially linear and the slope of the curve approaches zero. The specific
procedures used to evaluate if data are asymptotic will be defined during the
remedial design phase of work. However, it is not expected that field data will
match the theoretical equation exactly. Therefore, it will be necessary to use
best professional judgment based on field data to conclude that asymptotic
conditions have been reached.
In order to assess If there are zones where the AS/SVE system has not
removed VOCs, cycling will be used to allow residual vadose zone
contamination to re-equilibrate. The treatment system will be shut down
temporarily for a suitable period of time after asymptotic conditions are reached.
This will allow for VOC concentrations to re-establish in the soil gas. After
cycling, soil gas monitoring probes will be sampled to determine the remaining
VOC concentrations in the soil gas. If the resulting VOC levels are not
characteristic of the pre-cycling conditions or indicate a spike increase in soil
gas concentration, then additional treatment may be warranted. The decision to
shut off or restart any part of the remediation system will be made jointly by all
FFA signatories according to the criteria set forth in Section 2.8.4 of this ROD.
2.8.7 Approach to Groundwater and Vadose Zone Cleanup at CAOC 16
CAOC 16 is a large active industrial facility (approximately 60 acres) with a high
concentration of industrial activities, equipment and structures. The RAO for
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groundwater cleanup shall be to achieve and maintain compliance with the
groundwater cleanup standards throughout the groundwater contaminant
plume. The groundwater RAO will be achieved through continued operation of
the Yermo Annex plume groundwater pump and treat system and the AS/SVE
system downgradient of CAOC 16. These systems serve the dual purpose of
treating the contaminated groundwater to achieve MCLs and containing the
contaminated groundwater while the treatment is occurring. Institutional
controls will also be implemented to prevent access to the contaminated
groundwater until cleanup standards are achieved.
Vadose zone contamination beneath CAOC 16 has not been fully characterized
because of the physical limitations posed by the structures and base operational
activities covering the site. These limitations and logistical problems, partially
demonstrated during construction and implementation of a small-scale AS/SVE
pilot study system for Building 573 in 1994, are documented in the OUs 1 and
2 Feasibility Study for MCLB Barstow (Jacobs 1997) and include:
• High density of mission-critical operations (over 90% of CAOC area) with
very limited free space available to construct and accommodate
treatment system and equipment.
• Operational impacts, potential losses, and competitive consequences of
down time.
• Numerous underground utilities (electrical, communication, sewer, water,
gas) located throughout the building footprint.
• Inadequate access and vertical clearance inside Building 573 to
accommodate large drilling equipment required.
Due to the above conditions, alternatives designed to address the vadose zone
contamination directly under CAOC 16 (i.e., horizontal and vertical AS/SVE
systems) were determined to be extremely costly and logistically difficult, yet
limited in terms of the incremental risk reduction and protection to human health
and the environment.
Despite the uncertainties at CAOC 16, the DON believes the selected remedy
for the Yermo Annex outlined in Section 3.7 of this ROD will effectively achieve
the groundwater cleanup goals. Therefore, the DON is willing to agree to
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achieve the groundwater cleanup standards throughout the contaminant plume
solely in the interest of obtaining the concurrence of EPA, DISC, and the
RWQCB on this ROD, but reserves its right to propose a point of compliance
(POC) for this CAOC at a later date as set forth in Section 2.8.2.
At EPA's request, the DON will install nested soil vapor monitoring probes
beneath Building 573 at three locations agreed to with the regulatory agencies.
The vapor probes will be installed at shallow, intermediate and deep depths.
Data from the three soil vapor probe locations will be taken initially to establish a
baseline, and on an annual basis thereafter. Data will be submitted on an
annual basis as part of the groundwater monitoring report (see Section 2.8.12).
The monitoring frequency may be modified as appropriate as determined by the
FFA signatories.
Evaluation of the progress of the selected remedy in meeting groundwater
cleanup standards shall occur every 5 years as an FFA deliverable attached to
the CERCLA Section 121(c) 5-year review report. The 5-year progress
evaluation shall specifically consider the CAOC 16 groundwater monitoring well
and vapor probe data. The signatory parties to this ROD will jointly evaluate
whether the groundwater monitoring well and vapor probe data demonstrate
that adequate progress is being made towards meeting cleanup goals at CAOC
16. If the FFA signatories determine that the remedial action is not resulting in
adequate progress, the DON shall prepare a follow-up FFA deliverable report to
be submitted to the FFA signatories addressing the following subjects.
a) The potential need for additional remedial action at CAOC 16 (with
supporting rationale, analysis, and documentation).
b) An evaluation of the technical and economic feasibility of further
investigation and remediation beneath Building 573 and the Building 573
hardstand to meet the RAO. This feasibility analysis will identify and
evaluate one or more approaches to adequately characterize and remediate
CAOC 16. The analysis shall evaluate the approaches against the nine
NCP criteria: overall protection of human health and the environment;
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compliance with ARARs; long-term effectiveness and permanence;
reduction of toxicity, mobility, or volume through treatment; short-term
effectiveness; implementability; cost; state acceptance; and community
acceptance. Evaluation of the implementability shall specifically include the
impact of the approaches on Base operations, and any relevant
technological advances. Discussion of the overall protection of human
health criteria should include consideration of changes in land use. The
evaluation of community acceptance shall specifically include social and
economic impacts that the approaches may have on the surrounding
community. Such impacts may include the consequences of any related
degradation in the economic viability and competitiveness of MCLB Barstow.
c) Whether the basis for a CERCLA Section 121(d)(4)(C) Technical
Impracticability waiver from attaining MCLs has been established (with
supporting rationale, analysis, and documentation).
If appropriate, the agencies may request amendment of the OUs 1 and 2 ROD
in accordance with paragraph 7.10 of the FFA.
2.8.8 Approach for Groundwater and Vadose Zone Cleanup at
CAOC26
CAOC 26 encompasses a packaging and maintenance shop and the area
around it. Significant vadose zone and groundwater contamination was
detected at this CAOC. Contamination at this CAOC has been contained, and
source reduction via AS/SVE is ongoing as part of a NTCRA. Pump and treat
remediation enhanced with AS/SVE has been selected as the final remedy
which is already in place. The pump and treat and AS/SVE systems will be
operated until RAOs for groundwater and vadose zone cleanup are achieved.
Achievement of the RAO for vadose zone cleanup will be demonstrated through
sampling of the soil vapor probes already in place at this CAOC. The AS/SVE
system will be operated until shut-off criteria set forth in Section 2.8.4 of this
ROD are met. Achievement of the groundwater RAO will be demonstrated
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through sampling of compliance groundwater monitoring wells agreed upon by
all parties. The DON will submit an FFA primary document to demonstrate that
the RAOs have been achieved.
Despite agreeing to achieve the groundwater cleanup standards throughout the
contaminant plume at CAOC 26, the DON reserves its right to propose a POC
for this CAOC at a later date as set forth in Section 2.8.2.
2.8.9 Approach for Groundwater and Vadose Zone Cleanup at
Warehouse 2 (Nebo North Plume)
Warehouse 2 is the Old Repair Facility where major industrial operations took
place from 1942 to 1961. Residual vadose zone VOC contamination has been
detected underlying the location of three former UST sites. Source reduction at
Warehouse 2 using AS/SVE has been selected as part of the final remedial
alternative for Nebo North, which also includes natural attenuation of the
groundwater contaminant plume and fail-safe pump-and-treat in the event that
natural attenuation fails to contain the plume.
Vadose zone contamination at Warehouse 2 will be characterized to adequately
design the AS/SVE system. The AS/SVE system will be installed at appropriate
locations. Achievement of the RAO for vadose zone cleanup will be
demonstrated through sampling of soil vapor probes to be installed upon
completion of the remedial design characterization phase. The AS/SVE system
will be operated until both the vadose zone and groundwater RAOs have been
achieved within the source area, according to the AS/SVE shut-off criteria set
forth in Section 2.8.4 of this ROD.
Achievement of the groundwater RAO will be demonstrated through sampling of
compliance groundwater monitoring wells agreed upon by all parties. Natural
attenuation of the groundwater plume will be monitored until groundwater RAOs
are achieved throughout the entire contaminant plume. In the event that natural
attenuation fails to make adequate progress towards achieving the groundwater
cleanup standards, the pump-and-treat system will be operated as a backup
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system to enhance the remediation time and contain the contaminant plume.
The DON will submit an FFA primary document to demonstrate that the RAOs
have been achieved.
Despite agreeing to achieve the groundwater cleanup standards throughout the
contaminant plume at Warehouse 2, the DON reserves its right to propose a
POC for this area at a later date as set forth in Section 2.8.2.
2.8.10 Approach for Groundwater and Vadose Zone Cleanup at CAOC 6
fNebo South Plume)
At CAOC 6, documented releases and disposal of solvents to the ground
surface took place dating back to 1943. Groundwater and vadose zone
contamination has been detected at this CAOC. A pilot study conducted to
assess the feasibility of AS/SVE for source reduction yielded inconclusive
results. In addition, additional characterization of the extent of soil and
groundwater contamination is needed to support remedial action decisions.
Therefore, an interim remedy was selected for the Nebo South plume.
Groundwater contamination will be contained by five off-Base groundwater
extraction wells as an interim remedy. During the interim remedy period, Phase
II of the AS/SVE pilot study, including additional characterization, will be
conducted at this CAOC. The DON will submit an FFA deliverable to document
the results of these studies (see Section 2.8.12). Determination of RAOs will be
deferred until the final ROD for the Nebo South Plume.
2.6.11 Remedial Approach for Groundwater at CAOCs 23.35. and 15/17
At CAOCs 23 and 35 waste will be left in place and contained. The waste will
be capped and monitored in accordance with ARARs and the presumptive
remedy for CERCLA landfills. The majority of waste residues from the lined
ponds at CAOC 15/17 have been removed and the ponds closed in
conformance with RWQCB Toxic Pit Closure Act (TPCA) requirements. Vadose
zone cleanup will not be conducted at these WMUs.
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Groundwater RAOs for these WMUs will be achieved through continued
operation of the Yermo Annex plume groundwater pump and treat system.
When groundwater RAOs are attained at and beyond the point of compliance,
remedial action will be considered complete. Evaluation of progress to attain the
groundwater RAOs (i.e., MCLs at and downgradient of the point of compliance)
shall occur every 5 years, as an FFA deliverable attached to the CERCLA
Section 121(c) 5-year review report. The evaluation of progress will be
measured at agreed upon monitoring wells located as close as practical to the
downgradient edge of the WMUs. When MCLs are achieved at the
downgradient edge of the WMUs, the remedial action for these CAOCs will be
considered complete.
2.8.12 Initial Groundwater and Vadose Zone Primary FFA Deliverable
The DON will submit to the agencies, as the first primary FFA deliverable, a
summary of all groundwater and vadose zone monitoring within 24 months of
the signing of this ROD. This document will consolidate the vadose zone and
groundwater data to be collected from the OUs 1 and 2 source areas (including
CAOCs 16, 15/17 and 26 at the Yermo Annex and Warehouse 2 and CAOC 6
at the Nebo Main Base) during the initial ROD implementation period into a
single deliverable. These data will be used to address the specific objectives of
each CAOC, as follows:
CAOCs 16 (see Section 3.3.2):
• As requested by EPA, data collected from the soil vapor monitoring
probes for use during the 5-year review evaluation.
CAOCs 15/17 (see Section 3.3.2):
• As requested by EPA, data collected from the wet well for use during the
5-year review evaluation.
CAOC 26 (see Section 3.3.2):
• Evaluate need for shallow vadose zone SVE wells to enhance the cost-
effectiveness of the remediation system.
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Warehouse 2 (see Section 4.3.2):
• Characterization of extent of vadose zone contamination underlying
Warehouse 2, to be assessed during the AS/SVE remedial design phase
for the Nebo North plume.
• Determination of cost effective AS/SVE system design requirements.
• Results of additional groundwater monitoring taken up to that time,
designed to support that natural attenuation is occurring at the Nebo
North plume.
CAOC 6 (See Section 5.3.2):
• Additional characterization of the extent of vadose zone and
groundwater contamination underlying CAOC 6.
• Evaluation of the technical feasibility of AS/SVE to effectively cleanup
contaminants in vadose zone and groundwater thereby reducing the
cleanup time.
• Determination of radius of influence of AS/SVE system.
• Estimate of the amount of VOC mass in soil and groundwater, time for
plume cleanup, and cost of full-scale AS/SVE system implementation.
• Recommendations regarding AS/SVE system capability, and other
technologies which may be more effective if AS/SVE is deemed
technically not feasible.
After this initial primary FFA deliverable, monitoring data from groundwater
monitoring wells and soil vapor probes will be submitted on an annual basis as
part of the annual groundwater monitoring report.
2.9 National Contingency Plan Statutory Balancing Criteria
Section 121 of CERCLA and Section 300.430 of the NCP requires that remedial
alternatives be evaluated to determine which alternative provides the best balance with
respect to criteria in Section 121 of CERCLA and Section 300.430 of the NCP.
The NCP categorized the nine evaluation criteria, discussed in detail in the Draft Final
FS for OUs 5 and 6 (Jacobs 1996a), into three groups.
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1) Threshold Criteria address overall protection of human health and the
environment, compliance with ARARs (or invoking a waiver).
2) Primary Balancing Criteria address long-term effectiveness and performance;
reduction of toxicity, mobility, or volume; short-term effectiveness; implementability,
and cost. These primary balancing factors are used to weigh major trade-offs
among alternative remediation strategies.
3) Modifying Criteria address state and community acceptance that are formally
taken into account after public comment is received on the Proposed Plan and
incorporated in the ROD.
The selected alternative must meet the threshold criteria of protection of human health
and the environment and compliance with all ARARs. Any alternative that does not
satisfy both of these requirements is not eligible for selection. The primary balancing
criteria are the technical criteria upon which the detailed analysis is primarily based.
The final two criteria, known as modifying criteria, assess the public's and the state
agency's acceptance of the criteria. The Marine Corps may modify aspects of a
specific alternative based upon these criteria.
2.10 Applicable and Relevant or Appropriate Requirements
The NCP states, "Overall protection of human health and the environment and
compliance with ARARs (unless a specific ARAR is waived) are threshold requirements
that each alternative must meet in order to be eligible for selection" (EPA 1990a).
Identification of ARARs is a site-specific determination. It involves determining whether
a given requirement is applicable and if it is not applicable, then whether it is relevant
and appropriate.
A requirement is deemed applicable if the specific terms of the law or regulation directly
address the chemical of concern, the remedial action, or the location involved (e.g.,
cultural or environmental resources). If the jurisdictional prerequisites of the law or
regulation are not met, a legal requirement may nonetheless be relevant and
appropriate if the site's circumstances are sufficiently similar to circumstances in which
the law otherwise applies, and if the requirement is well suited to the conditions of the
site.
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Where ARARs do not exist, the NCR also provides agency advisories, criteria, or
guidance to be considered (TBC) useful in helping to determine what is protective at
the site or how to carry out certain actions or requirements (EPA 1990a) (55 Federal
Register 8745). The NCR preamble states, however, that provisions in the TBC
category "should not be required as cleanup standards because they are, by definition,
generally neither promulgated nor enforceable, so they do not have the same status
under CERCLA as do ARARs."
As the lead federal agency, the Marine Corps has primary responsibility for identifying
federal ARARs at MCLB Barstow. As the lead state agency, DTSC is primarily
responsible for identifying state ARARs. MCLB Barstow initiated this process and the
DTSC forwarded this request to several state agencies. Responses were received
from the California Department of Health Services, the RWQCB, California Department
of Fish and Game, and the California Integrated Waste Management Board. The
ARARs presented in this response have been reviewed and included in the ARARs
evaluation conducted in Appendix D of the FS Report for OUs 1 and 2 (Jacobs 1996a).
In addition, MCLB Barstow identified state ARARs in the Environmental Evaluation/Cost
Analysis (EE/CA) for the OU 1 removal action (Jacobs 1995c). Comments were
received from ERA Region IX and the California Regional Water Quality Control Board,
Lahontan Region. These comments and additional state ARARs that were identified
were also included in the ARARs evaluation in Appendix D of the FS Report for OUs 1
and 2.
Requirements of ARARs and TBCs are generally divided into three categories:
• Chemical-specific ARARs are health- or risk-based numerical values for
various environmental media, specified in state or federal statutes or
regulations. These numerical values establish the acceptable amount or
concentration of a chemical that may be present in a specific medium at a site,
or that may be discharged to the site or the ambient environment during
remedial actions.
• Location-specific ARARs address the areas in which the remedial action takes
place. Identified regulations that are potential ARARs may require actions to
preserve or protect aspects of environmental or cultural resources that may be
threatened by the remedial actions to be undertaken at the site.
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• Action-specific ARARs are regulations that apply to specific activities or
technologies used to remediate a site. They can include design criteria and
performance standards.
Chemical-specific, location-specific, and action-specific ARARs driving the development
of remedial actions objectives (RAOs) for groundwater and vadose zone soils at MCLB
Barstow are discussed in the sections that follow and summarized in Tables 2-2
through 2-7. A detailed discussion of all the ARARs considered for groundwater
remedy are included in the FS Report for OUs 1 and 2 (Jacobs 1996a).
2.10.1 Chemical-Specific ARARs Driving Remedial Action Objectives
Based on the above discussion and the evaluation presented in the FS for OUs
1 and 2, the substantive provisions of the following requirements have been
identified as chemical-specific ARARs driving the development of remedial
action objectives for the contaminant plumes in OUs 1 and 2:
• Water Quality Control Plan (WQCP) for the Lahontan Region, 1995
(water quality objectives, beneficial uses, waste discharge limitations).
• Federal maximum contaminant levels (MCLs) and nonzero maximum
contaminant level goals (MCLGs).
• State primary MCLs in Title 22 CCR.
• Resource Conservation and Recovery Act (RCRA) groundwater
protection standards in Title 22 CCR Sections 66264.94(a)(1), (a)(3), (c),
(d), and (e).
Of these requirements, the most stringent are the requirements under the RCRA
groundwater protection standards and Title 22 CCR Section 66264.94 to restore
affected groundwater to background conditions or the best water quality that is
reasonable if background levels of water quality cannot be achieved.
The Department of the Navy (DON) has determined that the substantive
provisions of Title 22 CCR Section 66264.94(a)(1), (a)(3), (c), (d), and (e)
constitute 'relevant and appropriate' federal ARARs for groundwater and vadose
zone (i.e., the unsaturated zone) contamination associated with the Yermo
groundwater plume (CAOCs 15/17,16,23,26 and 35) and the Nebo North
(Warehouse 2) and South (CAOC 6) plumes. It is noted that the requirements
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at Title 23 OCR Division 3 Chapter 15 Article 5 are applicable for the inactive
waste management units at CAOCs 23 and 35 (landfills) and the majority of
CAOC 15/17 (surface impoundments). However, the Title 23 CCR requirements
are not ARARs because they are no more stringent than relevant and
appropriate federal ARARs at 22 CCR. The substantive provisions of Title 22
CCR 66264.94 are considered to be relevant and appropriate for this remedial
action and are federal ARARs because they are federally enforceable (55
Federal Register 8765, March 8,1990).
DON'S Position Regarding SWRCB Resolution Nos. 92-49 and 68-16
The DON recognizes that the key substantive requirements of 22 CCR
66264.94 (and the identical requirements of 23 CCR 2550.4 and Section III.G of
State Water Resources Control Board [SWRCB] Resolution 92-49) require
cleanup to background levels of constituents unless such restoration proves to
be technologically or economically infeasible and an alternative cleanup level of
constituents will not pose a substantial present or potential hazard to human
health or the environment. In addition, the DON recognizes that these
provisions are more stringent than the corresponding provisions of 40 Code of
Federal Regulations (CFR) 264.94 and, although they are federally enforceable
via the RCRA program authorization, they are also independently based on
state law to the extent that they are more stringent than the federal regulations.
The DON has also determined that SWRCB Resolution 68-16 is not a chemical-
specific ARAR for determining remedial action goals. However, SWRCB
Resolution 68-16 is an action-specific ARAR for regulating discharged treated
groundwater back into the aquifer. The DON has determined that further
migration of already-contaminated groundwater is not a discharge governed by
the language in Resolution 68-16. More specifically, the language of Resolution
68-16 indicates that it is prospective in intent, applying to new discharges in
order to maintain existing high quality waters. It is not intended to apply to
restoration of waters that are already degraded.
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The DON'S position is that SWRCB Resolutions 68-16 and 92-49 and 22 CCR
2550.4 do not constitute chemical-specific ARARs for this remedial action
because they are state requirements and are not more stringent than the federal
ARAR provisions of 22 CCR 66264.94. The NCR set forth in 40 CFR 300.400(g)
provides that only state standards more stringent than federal standards may be
ARARs (see also Section 121(d)(2)(A)(ii) of CERCLA). The determination of
which regulations constitute ARARs is documented in Appendix D of the FS
Report for OUs 1 and 2 (Jacobs 1996a).
The substantive technical standard in the equivalent state ARARs (i.e., Title 23
CCR, Chapter 15, SWRCB Resolution 92-49, and SWRCB Resolution 68-16) is
identical to the substantive technical standard in 22 CCR Section 66264.94.
This section of Title 22 CCR will likely be applied in a manner consistent with
equivalent provisions of other regulations, including SWRCB Resolutions 92-49
and 68-16.
State of California's Position Regarding SWRCB Resolutions
Nos. 92-49 and 68-16
The State does not agree with the Marine Corps' determination that SWRCB
Resolutions 92-49 [and 68-16] and certain provisions of Title 23 CCR, Division
3, Chapter 15 are not ARARs for this ROD. However, the State agrees that
actions proposed in this ROD would comply with Resolutions 92-49 [and 68-16]
and compliance with the Title 22 provisions should result in compliance with the
Title 23 provisions. The State does not intend to dispute the ROD, but reserves
its rights if implementation of the Title 22 CCR provisions is not as stringent as
State implementation of Title 23 CCR provisions. Because Title 22 CCR
regulation is part of the State's authorized hazardous waste control program, it
is also the State's position that Title 22 CCR 66264.94 is a State ARAR and not
a federal ARAR (U.S. v. State of Colorado, 990 F.2d 1565, [1993]).
Whereas the DON and the State of California have not agreed on whether
SWRCB Resolution Nos. 92-49 and 68-16 and Title 23 CCR Section 2550.4 are
ARARs for the remedial action at the Yermo plume and the Nebo North and
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South plumes, this ROD documents each of the parties' positions on the
resolutions but does not attempt to resolve the issue.
2.10.2 Location-Specific ARARs
Location-specific requirements include those that involve restrictions on how
remedial activities are to be conducted in particular locations. CAOC 6 is near a
robust creosote community that is home to a significant population of desert
tortoise. Because the desert tortoise is an endangered species, requirements
pertaining to the protection of special-status species are ARARs as listed in
Table 2-4.
2.10.3 Action-Specific ARARs
Action-specific requirements for OUs 1 and 2 were identified for waste
generation, potential air emissions, discharge of treated water, and groundwater
monitoring for RCRA landfill closure. These action-specific ARARs are listed in
Tables 2-6 and 2-7. The following discussion expands on the groundwater
monitoring requirements for CAOCs 23 and 35.
Landfill Closure Groundwater Monitoring Requirements
To promote efficiency in the implementation of groundwater monitoring
requirements for MCLB remedial actions, this ROD addresses the groundwater
monitoring component of the landfill closure requirements for CAOCs 23 and
35. Federal and State requirements that pertain to groundwater monitoring for
RCRA corrective action programs are described below.
Federal
As discussed in Section 2.10.1, portions of the RCRA groundwater protection
standards contained in Title 22 CCR are considered to be relevant and
appropriate for the groundwater potentially impacted by releases from CAOCs
23 and 35 because the hazardous constituents being addressed by this action
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are similar or identical to those found in RCRA hazardous wastes. The
substantive requirements of a corrective action program (CAP) is required for
CAOCs 23 and 35 under 22 CCR 66264.100 and an evaluation monitoring
program under 22 CCR 66264.99 is required to demonstrate effectiveness and
compliance. Substantive provisions of the following requirements apply to the
development and implementation of a groundwater monitoring program for
CAOCs 23 and 35:
• Constituents of concern (22 CCR 66264.93)
• Concentration limits (22 CCR 66264.94)
• Monitoring points and points of compliance (22 CCR 66264.95)
• Detection monitoring program (22 CCR 66294.98)
• Statistical method for detecting a release (22 CCR 66264.97[e])
• Method for determining background (22 CCR 66264.97[e][11 ]).
State
The RWQCB Lahontan region identified the following requirements for the
development of a CAP monitoring program for landfill closure:
• Constituents of concern (23 CCR 2550.3)
• Concentration limits (23 CCR 2550.4)
• Monitoring points and points of compliance (23 CCR 2550.5)
• Detection monitoring program (23 CCR 2550.8)
• Statistical method for detecting a release (23 CCR 2550.7[e])
• Method for determining background (23 CCR 2550.7[e][11]).
The Marine Corps has reviewed these provisions and has determined that they
are identical to the corresponding Title 22 Federal ARARs, except for the more
prescriptive sampling requirements found in 23 CCR 2550.7(e)(12)(B) and 23
CCR 2550.10(g)(2). The Marine Corps accepts the more prescriptive
requirements of 23 CCR 2550.7(e)(12)(B) and 2550.10(g)(2) as State ARARs.
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However, the other Title 23 requirements cited are not ARARs for OU 1 and OU
2 remedial actions because they are not more stringent than the Federal ARARs
identified under Title 22.
Conclusions
The Federal requirements for CAP monitoring under Title 22 Article 6 are
equivalent to the State requirements for CAP monitoring under Title 23 Article 5.
Because State requirements would only be considered ARARs to the extent that
they are more stringent than Federal requirements, the Title 22 requirements for
CAP monitoring would be the controlling ARARs for remedial actions at CAOCs
23 and 35. The exceptions are the more prescriptive sampling requirements
found in 23 CCR 2550.7(e)(12)(B) and 2550.10(g)(2). The Marine Corps
accepts the more prescriptive requirements of 23 CCR 2550.7(e)(12)(B) and
2550.10(g)(2) as State ARARs.
2.11 Highlights of Community Relations and Participation
The community of Barstow is kept well informed about the MCLB Barstow remedial
actions for soils and groundwater under the CERCLA program. The remedial
investigation/feasibility study (RI/FS) and the Proposed Plan for MCLB Barstow OUs 1
and 2 were released to the public on November 3, 1997. The documents were made
available to the public through the Administrative record (Appendix B) contained in the
information repositories at the County of San Bernardino Public Library, Barstow
Branch, and at MCLB Barstow Facilities and Services Division, Environmental
Department, Warehouse 3. The notice of availability for the Proposed Plan the
supporting documents were published in the Barstow Desert Dispatch, the Sun (San
Bernardino), and the Daily Press (Victorville), on November 3, 1997. Also, the
Proposed Plan was mailed to approximately 1,500 local and interested parlies per the
site mailing list. A public comment period was held from November 3 through
December 3, 1997. A public meeting was held at the Barstow Holiday Inn on
November 12,1997. Several minor comments were received from the public during the
public comment period. Transcripts from the meeting, which include the public
comments are contained in Appendix C.
2-38
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CTO298\B70027VTAB2.DOC
CLE-J02-01F298-B7-0027
CO
CD
Table 2-1
Operable Units 1 & 2 Contaminants of Concern
Groundwater Cleanup Levels (\iglL)
X\s - ^?\™J; ;- Vv5X* » •••• * %% ^-"x"» i
5^f^^> > > >Vr™\ - v-ink v' ';-
^ .... H%*"3U ... "\ .\-> V.^ .«• < ^iJOllUyitlfWilll .. ^ ^ •••• •• A
1.1.1-Trichloroethane
1 . 1 -Dfchtoroethane
1.1-Dtahloroethene (1.1-DCE)
1.1.2-Trlcfiloro-1^.2-Tr1fliJoroethane(Freon 113)
1.2-Dtehloroethane (1.2-DCA)
ds-1.2-Dfchloroethene (ds-l^-DCE)
trans-l^-Dicfiloroelheneftrans-l^-DCE)
1^-Dtehtoroehene. Total
2-Butanone(MEK)
2-Hexanone
4-Methvt-2-Pentanone (Metiyl Isobutyl Ketone)
Acetone
Benzene
Bromodchtorometwne
Bromoform
Carbon DIsuHMe
Carbon Tetrachtoride
Chloroform
Chkxometnane
Oixomochlorometfiane
1 .2-Dtfliwro-1 .1 ^.2-Tetrachkxoethane (Fraon 1 12)
1.2-Dtehloro-1.1^2-Tetrafluoroetnane (Freon 1 14)
Methytane Chloride
Tetrachloroethene (PCE)
Toluene '
Trtchtoroetheoe (TCE)
Trtehlorofluoromelhane (Freon 1 1 )
Xytenes (Tota))c
^ - ./ ' , Basla for Goal ,-. -::. ' ,.,.,
"^ \WtoM*&^ ;
200
S
6
1200
0.5
6
10
6
N
N
N
N
1
100
100
N
0.5
100
N
100
N
N
S
5
42"
S
150
ir
\ :[****» **
1.2
2
2
2
2
2
2
2
N
N
N
N
2
1
1
N
2
1
N
1
N
N
1
1.2
O
1.2
2
O
.\, . v » ^iBOflBC** '
-. %-. ^ > ,, ^
•J-.-r--- *....'. .^. -:.-:-».>.. ^.^..C
\.\» '.>••••'•• ••••••-.'' \
/«"'> "-""•.- , -s <• -
. , - . s_» ^ f^
-^ \«0''<'1'V '^N " i M»
N
N
N
N
iff.. ^'^^S^.r?.'.'.r^^.
rt^nl n n H '""I"^ 1 1'" • - nlYi'n i"i i^i i i"H i"iti i
i":^.^..-.^-"^. -V •^--•^
N
•• %
1.5
V - •• -.^«™N -
N
N
' •. %•- v. "• •,-.''•.
'<• \-.\
.. \, * * ••- „"„,
'•• * -. -.
\ , ,' '
O, > . .
: JtettaMLi
•f f ^ ^
•. . „, ^p. - .. „ ,..
S ™
.r^.x.. - -- . ? -
> >. > n--"-ifi(r''1fiMi in
^•'•w -f t •• ^ ;'•'•' f:
-"•f „ , ,ss' ^^ ,
1.900
N
160
610
\ ^ ^
.-N r.^. ,".x ""
*s. --, .-. -\\ •.-.,••...•••*• \* ••
21
-.-. % *• * ^ •.
» V- -J - " .
N
N
•. "" .. % .
' •'
-•v.
^
-
Foojnot»»;
Moat strtngont of fedaral and slate MCL
To Iw oonsktered (TBC) risk-based criteria (RBC) where drinking water standard Is not available. Source: EPA Region IX Preliminary Remedfetfon Goals. August 1.1996.
1 • Federal MCL
2- State MCL
N-Norw
O-Other
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CTO298\B70027\TAB-A-2.DOC
CLE-J02-01F298-B7-0027
TABLE 2-2
Federal Chemical-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Requirement
PiMfmniitmitM.
rHW|umie
Citation
ARAR
Determination
Comment*
Safe Drinking Water Act (SOWA), 42 U8C 300*
National primary (kinking water standards
are health-based standards for public water
systems (maximum contaminant levels
IMCLs]).
Maximum contaminant level goals (MCLQs)
pertain to known or anticipated adverse
health effects (also known as recommended
maximum contaminant levels).
Definition of RCRA hazardous waste;
TCLP regulatory levels.
Qroundwater protection standards:
Owners/operators of RCRA treatment,
storage, or disposal facilities must comply
with condftons In this section that are
designed to ensure that hazardous
constituents entering the groundwater from a
regulated unit do not exceed the
concentration limits set forth under Section
66264.94 for contaminants of concern in the
uppermost aquifer underlying (he waste
management area beyond the point of
compliance.
Preliminary Remediation Goals (PRQs) for
tap water.
Public water system.
Public water system.
Waste generation.
Uppermost aquifer underlying a
waste management unit
beyond the point of
compliance; RCRA hazardous
waste, treatment, storage, or
disposal.
40 CFR 141.11-
141.16, excluding
141.11(d)(3);40CFR
141.60-141.63
Public Law No. 99-339
100 Statute 642
(1986)
40 Cf R 141
SubpartF
22 CCR 66261. 21.
66261.22(a)(1),
6626123,
66261. 24(a)(1), and
66261.100
22 CCR 66264.94.
except 66264.94(a)(2),
and94(b)
U.S. EPA Region 9.
August 1.1996
Relevant and
appropriate for
groundwater
Relevant and
appropriate for
groundwater
Applicable
Relevant and
appropriate
To Be Considered
The National Oil and Hazardous Substance Pollution
Contingency Plan (NCP) defines MCLs as relevant and
appropriate for groundwater determined to be a current or
potential source of drinking water In cases where MCLQs
are not ARARs. Qroundwater In the vldnlty of MCLB
Barstow has been designated for drinking water use.
MCLQs that have nonzero values are relevant and
appropriate for groundwater determined to be a current or
potential source of drinking water (40 CFR
300 *3°MI2JPHBJ through (DJ). Groundwater In the
vicinity of the MCLB Barstow has been designated for
drinking water use. Nonzero MCLQs exist for some of
the chemicals of potential concern for OUs 1 and 2.
Hazardous waste determinations are needed for
extracted groundwater being generated for storage,
treatment, or disposal.
These standards are not applicable because the
groundwater contamination being addressed by the OUs
1 and 2 dkJ not result from releases from RCRA-regulated
units. However, substantive provisions of these
requirements may be considered relevant and appropriate
for groundwater because the hazardous constituents
being addressed by this action are similar or Identical to
those found In RCRA hazardous wastes.
These PRQs are used for cleanup for the COCs that do
not have MCLs.
ro
Page1
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CTO298\B70027\TAB-A-2.DOC OLE -J02-01F298-B7-0027
TABLE 2-2
Federal Chemical-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
• Statutes and policies, and their citations, are provided as heatings to Identify general categories of potential ARARs for he convenience of he reader. Listing the statutes and policies
does not Inofcate that Navy accepted the statutes or poNdes as potential ARARs. SpecMc potential ARARs are addressed In the table below each general headng; only substantive
requirements of (he specific citations are considered potental ARARs.
ARARs - Applicable or relevant and appropriate requirements RCRA - Resource Conservation and Recovery Act
CCR • Calfomta Qode of Regulations SOWA - Safe Drinking Water Act
MCLs • Maximum contaminant levels TCLP • Toxfctty characteristics leaching procedure
MCLQs - Maximum contaminant level goals USC * United States Coda
NCR • National OH and Hazardous Substarice Po«u«on Contingency Plan
Chemical-specific ooncentralons used for feasibility study (PS) evaluation may not be ARARs Indcatad In this table, but may be concentrations based upon other factors. Such factors may
Inctodeteforiowtng:
• Human health risk-based concentrations (risk-based; PRGs 40 CFR 300.430(e][A][1] and [ZJ).
• Ecological risk-based concentrations (40 CFR 300.430f.eJIG]).
• Practical quantttatfon limits of contaminants (40 CFR 300.4W[e]tAI3J).
Page 2 of 2
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CT0296\B70027\TAB-A-3.DOC
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
CLE-J02-01F298-B7-0027
ro
k
Requirement
PreraquMtae
Citation
ARAR
Determination
Comment*
Cal/EPA Department of Toxic Substancoa Confrol (DTSC)
Definition of 'Non-RCRA hazardous waste';
persistent and btoaccumulattve toxtc substances total
threshold Bmft concentrations fTTLCs) and soluble
threshold IrhH concentrations (STLOs).
State maximum contaminant level (MCL) list
Waste generation.
22 OCR 66261 .22(a)(3) and
(4).66261.24
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CTO298\B70027VTAB- A-3. DOC
CLE-J02-01F298-B7-0027
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Requirement
Prerequisite*
Citation
ARAB
DetermtrMttoii
Incorporated Into an Regional Board Basin Plans.
Designates afl ground and surface waters of the State
as drinking water except where the TDS Is greater
than 3.000 ppm. the weR yield Is less than 200 gpd
from a single wed, the water Is a geofnermal resource
or In a water conveyance facility, or the water cannot
reasonably be treated tor domestic use using either
best management practices or best economically
achievable treatment practices.
SWRCB Resolution No. 8843
(Sources of Drinking Water
Policy)
Applicable
This resolution provides the basis for drinking
water determinations In California. Substantive
provisions are ARARs. The groundwater at
MCLB Barstow has been Identified as a source
of drinking water.
03
Incorporated Into all Regional Board Basin Plans.
Requires that quality of waters of (he state that Is
better than needed to protect afl beneficial uses be
maintained unless certain ftndngs are made.
Discharges to high-quality waters must be treated
using best practicable treatment or control necessary
to prevent pollution or nuisance and to maintain the
highest quality water. Beneficial uses must, at least,
be protected.
SWRCB Resolution No. 68-16
(Policy with Respect to
Maintaining High Quality
Waters In California) (Water
Code 13140. Clean Water Act
regulations 40 CFR 131.12)
Applicable
Action-specific ARAR for regulating discharges
of treated groundwater back Into aquifer.
Discharges to groundwater that occur as part of
the OUs 1 and 2 remeolal actions must meet the
substantive requirements of Resolution 68-16.
This resolution Is only applicable to the treated
water discharges and not to the cleanup of the
groundwater or the potential migration of
contaminant plumes.
Statutes and policies, and their citations, are provided as headings to Identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not Indicate
that the Navy accepts aD the statutes or policies as potential ARARs. Specific potential ARARs are addressed In the table below each general hearing; only substantive requirements of specific citations
are considered potential ARARs.
Page 2 of 3
-------
CTO296\B70027\TAB-A-3.DOC
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
CLE-J02-01F298-B7-0027
equiremsnl
EstaMshes poHdea and procedure* for fhe oversight
of Investigations and cleanup and abatement
acttvitle* resulting from discharges of waste that
affect or threaten water quality . It authorizes the
Regional Board* to require cleanup of all waste
discharged and restoration of affected water to
background condttons. Requires actions for cleanup
and abatement to conform to Resolution 68-16 and
applicable provisions of Title 23 OCR Division 3.
Chapter 15, as feasMe.
V
\
Provides general waste Discharge requirements tor
land disposal of treated groundwater. The order
contains discharge specifications that include 30-day
medtan and dally maximum values. Discharge
monitoring program requirements are also specified.
Prerequisites
Discharge affecting water.
Discharges of treated
groundwater In the Lahontan
Region.
Citation
SWRCB Resolution 92-49
(Policies and Procedures for
Investigation and Cleanup
and Abatement of Discharges
Under Water Code Section
13304)
Lahontan RWQCB Resolution
6-93-1 06 [General Waste
Discharge Requirements for
Land Disposal of Treated
Groundwater]
ARAR
D0t6nnliuitfon
Not an ARAR
TBC
Continents
As Resolution 92-49 Is no more stringent than
22 CCR 66264.94. a relevant and appropriate
federal ARAR. the resolution does not qualify as
a state ARAR under CERCLA. The State does
not agree with the Maine Corps' determination
that SWRCB Resolutions 92-49 and 68-16 and
certain provisions of Title 23 CCR. Division 3.
Chapter IS are not ARARs for this ROD.
However, the State agrees that actions
proposed In this ROD would comply with
Resolutions 92-49 and 6816 and compliance
with the Tito 22 CCR provisions should result In
compliance with Tttto 23 CCR provisions. The
State does not Intend to dispute the ROD, but
reserves Its rights if Implementation of the THte
22 CCR provisions Is not as stringent as State
Implementation of Title 23 CCR provisions.
Discharge of treated groundwater to oxidation
ponds or Infiltration galleries would need to meat
these discharge and monitoring requirements.
See Table 2-_ for the treated groundwater
discharge limitations.
ro
ARARs
CAOC
CCR
CFR
9Pd
MC
ppm
AppNoabte or relevant and appropriate requirements
CERCLA Area of Concern
California Code of Regulations
Code of Federal Regulations
gallons per day
Marine Corps
parts per mRHon
PRO preliminary remedtation goal
RCRA Resource Conservation and Recovery Act
RWQCB Regional Water Quality Control Board, Lahontan Region
STLC soluble threshold llmtt concentration
SWRCB California State Water Resources Control Board
TBC To be considered
TDS total dissolved solids
TTLC total threshold limit concentration
Chemlcal-speciflc concentrations used for remedal action alternative evaluation may not be ARARs Indicated In this table, but may be concentrations based upon other factors. Such factors may Include the
following.
Human health risk-based concentrations (Risk-based PRQs) [40 CFR 300.430(e)(A)(1) and (2)].
• Ecological risk-based concentrations [40 CFR 300.430(e)(Q)].
• . Practical quantttaOon Hmtts of conlamtnanta [40 CFR 300.430(eXAX3)].
Page 3 of 3
-------
CTO298\B70027YTAB-D-4.DOC
CLE-J02-01F298-B7-0027
TABLE 2-4
Federal Location-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Location
Requirement
Prerequisite
Citation
ARAR
DtttornilfMtton
Comment*
NctlofuJ Arch MO logic •! ma Htetoffcd Pr«n Act
Within arm
where action
maycauM
irreparable harm,
loss, or
destruction of
significant
artifacts
Construction on previously
undisturbed land would
require an archaeological
survey of the area.
Alteration of terrain that
threatens significant
scientific, prehistoric, historic,
or ardiaeotogte data
Substantive
requirements of
16 USC 469a-1
and36CFR65
ARAR
Phase 1 archeotogkal surveys would need to be
conducted if remedal action activities take place
In areas that have not been sun/eyed for cultural
resources.
Endangered Specie* Act of 1179'
Critical habitat
upon which
species or
threatened
species depend
Action to conserve
endangered species or
threatened species. Inducing
consultation with the
Department of the Interior.
Determination of effect upon
endangered or threatened
species or Its habitat
16 USC 1536(a)
Applicable
Desert tortoise mitigation measures will be
followed during the Implementation of remedial
actions.
Migratory Bird Treaty Act of 1972*
Migratory bird
area
Protects almost all species of
native birds In the U.S. from
unregulated 'take,' which can
Include poisoning at
hazardous waste site*.
Presence of migratory birds.
16 USC Section
703
Relevant and
Appropriate
Migratory birds and nesting activities have been
documented on MCLB Barstow, particularly In the
riparian edge zone on Vie northern boundary of
Nebo. Actions to be taken as part of OU 1 and 2
remeolaJ alternatives are not expected to Impact
migratory bird activities.
en
Statutes and poBdes. and heir citations, are provided as headings to Identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies
does not Indcate that the Navy accepts the entire statutes or policies as potential ARARs. Specific potential ARARs are addressed In the table below each general heading; onry
substantive requirements of the specific citations are considered potential ARARs.
ARARs Applicable or relevant and appropriate requirements.
CFR Code of Federal Regulations.
USC
CCR California Coda of Regulations.
United States Code.
-------
CTO298\B70027\TAB-A7.DOC
CLE-J02-01F298-B7-0027
TABLE 2-5
State Location-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Location
Requirement
Prerequisites
Citation
ARAB
Determination
Comments
FWi and Qame Cod*'
Endangered
Spectes Habitat
Projects wtthtn the stats shall not Jeopardze (he
existence of any endangered or threatened species
or result In the destruction or adverse modHtaatton of
habitat essential to the species. If (here are
reasonable and prudent alternatives available
consistent with preserving (he species that or Its
habitat which would prevent Jeopardy. No person
shad Import, export, take, possess, or sett any
endangered or threatened species or part or product
thereof.
Threatened or endangered
species determination on or before
1 January 1965 or a canoMate
species with proper notification.
Fish and Game Coda
Section 1900,2053, 2060
Relevant and
appropriate
Actions to be taken as part of OU 1 and 2
remedtal alternatives are not expected to
have any long-term Impacts on threatened
or endangered species. Desert tortoise
mitigation measures win be followed
during the Implementation of remedtal
actions.
l\j Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes
4k and policies does not indicate that the Navy accepts the entire statutes or policies as potential ARARs. Specific potential ARARs follow each general heading; only
05 substantive requirements of the specific citations are considered potential ARARs.
-------
CTO298\B70027VTAB-A-8.DOC
CLE-J02-01F298-B7-0027
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Requirement
Prerequisites
Citation
ARAR
Determination"
A
RA
TBC
Comments
Safe Drinking Water Act (SDWA), 42 USC 300'
Underground
injection of wastes
and treated
groundwater
The underground Injection control (UIC)
program prohibits Injection activities that
allow movement of contaminants Into
underground sources of drinking water
which may result in violations of MCLs or
adversely affect health. Five
classifications of Injection wells provided.
Regulates underground Injection of
wastes to protect aquifers that are, or
may reasonably be expected to be. a
source of drinking water if the
contamlnant(s) may cause a violation of
any primary drinking water regulation or
may adversely affect human health.
Substantive
requirements of 40
CFR 144. 145. 146.
and 147 under the
conditions noted In the
comment.
5
The Infiltration galleries
proposed as part of the
OU 1 remedial alternatives
would be Class V wells under
this rule since the Infiltrated
groundwater would not be a
hazardous waste. There are
currently no requirements for
Injection into Class V wells.
Substantive provisions of
these requirements are
relevant and appropriate only
to the extent necessary to
ensure that the Injection
activities would not cause the
water in the receiving aquifer
to violate primary drinking
water regulations.
Resource Conservation and Recovery Act (RCRA) 42 USC 8901 *f ssqi*
On site waste
generation
Person who generates waste shall
determine If that waste Is a hazardous
waste.
Generator of hazardous waste In
California.
22 CCR 66262.10(8).
66262.11
4.5
Applicable for any operations
where hazardous waste is
generated.
Statutes and policies, and their citations, are provided as headings to Identify general categories of potential ARARs. Listing the statutes and policies does not indcate that the Navy accepts all the
statutes or poHdes as potential ARARs. Specific potential ARARs are addressed In (he table below each general heading; only substantive requirements of the specific actions are considered potential
ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) £»Wft/orourKK»ater treatment via cart>on6^ofptkxi or ozone/carbon. 4) OU 2 discharge of
treated groundwater to oxidation ponds. S) OU 1 discharge of treated groundwator to Infiltration galleries. 6) OU 1 vapor extraction and air sparging.
Page 1 of 4
-------
CTO298\B70027YT AB- A-8. DOC
CLE-J02-01F298-B7-0027
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Discharge to
groundwater from
a regulated unit
Post-closure care.
use of property,
and plant
Requirement
Water Quality Monitoring Program.
Owners/operators of RCRA treatment.
storage, and disposal facilities must
develop and Implement a water quality
monitoring program to monitor the
potential for releases from the facility or
to demonstrate the effectiveness of a
corrective action program (CAP).
Requires monitoring and maintenance for
30 years unless It Is demonstrated that
human health and the environment are
protected.
Prerequisites
Uppermost aquifer underlying a waste
management unit beyond the point of
compliance; RCRA hazardous waste,
treatment, storage, or disposal.
Citation
22 OCR Sections
66264.93; 66264.94.
66264.95,
66264.97(e),
66264.96. 66264.100
22 CCR 66264.11 7
ARAR
Determination"
A
RA
1
1
TBC
Comments
The groundwater standards
under RCRA are considered
relevant and appropriate for
remedial actions for
groundwater and the vadose
zone since the hazardous
constituents being addressed
are similar or Identical to those
found In RCRA hazardous
waste.
The substantive requirements
of these provisions are
relevant and appropriate for
groundwater monitoring of
CAOCs 35 and 23.
Clean Air Act (CAA) 40 USC 7401 «r •*?.'
Discharge of
organic solvents to
the atmosphere
Emissions reduction by at least 85
percent. Exemptions are provided for
emissions of photochemically reactive
solvents that do not exceed 39.6 Ib/day
and for non-photochemlcally reactive
solvents that do not exceed 2970 to/day.
Discharge of organic materials into the
atmosphere from equipment In which
organic solvents or materials containing
organic solvents are used.
Mojave AQMD
Rule 442
3.6
The maximum potential
emissions for the vapor
extraction and air sparging
systems are below the limits
set for solvents. Also, the
emissions controls planned for
these systems achieve greater
than 85 percent reduction of
VOC emissions.
ro
^
CD
Statutes and policies, and their citations, are provided as hearings to Identify general categories of potential ARARs. Listing (he statutes and policies does not Indcate that the Navy accepts an the
statutes or poHdes as potential ARARs. Specific potential ARARs are addressed In the table below each general heading; onry substantive requirements of the specific actions are considered potential
ARARs.
Potential actions: 1 ) Monitoring and access restrictions. 2) Qroundwater extraction and conveyance. 3) Ex situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of
treated groundwaler to oxidation ponds. 5) OU 1 discharge of treated groundwater to WHtratJonjglerles. 6) OU 1 vapor extraction and air sparging.
2 of 4
-------
CTO298\B70027\TAB-A-8.DOC
CLE-J02-01 F298-B7-0027
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
New source of
discharge to air
Requirement
Requirements for the preconstruction
review of new or modified facilities to
ensure that construction, or modification
of such facilities does not Interfere with
the attainment and maintenance of
ambient air quality standards. This
regulation provides for no net Increase In
the emission of any affected air pollutant
from new major facilities or any
modification to an existing major facility.
Standard for approving permits requires
that equipment be designed, controlled,
or equipped with air pollution control
equipment so that It may be expected to
operate without emitting air contaminants
In violation of Section 41 700 or 41 701 of
the State Health and Safety Code or of
the Mojave AQMD Rules.
Prerequisite*
Applies to all new or modified facilities
which are required, under District rules, to
obtain an authority to construct; facilities
for which offsets are required to be
obtained pursuant to Rule 1307; or for
which the use of BACT Is required (e.g..
the potential to emit 25 pounds per day or
more of any affected pollutant).
Equipment with the potential to cause
Issuance of air contaminants.
Citation
Mojave AQMD
Rule 1301
Mojave AQMD
Rule 21 2
ARAR
Determination"
A
3.6
3.6
RA
TBC
Comments
The new source review
requirement Is applicable for
new sources of volatile organic
air emissions at the base since
base emissions exceed the
offset threshold for reactive
organic compounds of 25
tons/year. See text In Section
C4.1 .1 for further discussion of
the applicability of this
requirement to emissions
controls for the vapor
extraction and air sparging
systems.
The vapor extraction and air
sparging systems have the
potential to cause issuance of
air contaminants. On-slte
actions under CERCLA are
exempt from procedural
requirements such as
permitting. However,
notification of and concurrence
by the Mojave AQMD will take
place as part of the remedial
action review process.
ro
A
CO
Statutes and policies, and their citations, are provided as headnga to Identify general categories of potential ARARs. Listing the statutes and policies does not Indcate that the Navy accepts all the
statutes or policies as potential ARARs. Specific potential ARARs are addressed In the table below each general heading: only substantive requirements of the specific actions are considered potential
ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of
treated groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to Induration galleries. 6) OU 1 vapor extraction and air sparging.
Page 3 of 4
-------
CTO298\B70021\TAB-A-a.DOC
CLE-J02-01F298-B7-0021
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
A Applicable ppm
AQMD Air Quality Management District RA
ARAR Appfcabto or relevant and appropriate requirement RCRA
BACT Best available control technology RWQCB
CAA CtoanAlrAct SWRCB
-CCR Cafifomia Code of Regulations SDWA
CERCLA Comprehensive Environmental Response. Compensation, and Liability Act TBC
CFR Coda of Federal Regulations UIC
EPA U.S. Environmental Protection Agency USC
LAER Lowest achievable emission rate VOC
Ib/day pounds per day pg/m1
MCLs Maximum contaminant levels
parts per mHUon
Relevant and appropriate
Resource Conservation and Recovery Act
California Regional Water Quality Control Board. San Diego Region
California State Water Resources Control Board
Safe Drinking Water Act
To be considered
Underground Injection control
United States Code
volatile organic compound
mlcrograms per cubic meter
to
§
of 4
-------
CT0298\B7TO7\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Requirement
Prerequisites
Citation
ARAR
Determination"
A
RA
TBC
Comments
State Water Resources Control Board (SWRCB) and Regional Water Quality Control Board (RWQCB)'
Actions affecting
water quality in
Lahontan Region
Discharges to
land or surface
or groundwater
that could affect
water quality
Describes, the water basins in the
Lahontan region. Establishes beneficial
uses of ground and surface waters.
Establishes water quality objectives,
including narrative and numerical
standards. Establishes implementation
plans to meet water quality objectives
and protect beneficial uses, and
incorporates statewide water quality
control plans and policies.
Authorize the State and regional water
boards to establish in water quality
control plans beneficial uses and
numerical and narrative standards to
protect both surface and groundwater
quality. Authorizes regional water
boards to issue permits for discharges
to land or surface oar groundwater that
could affect water quality, including
NPDES permits, and to take
enforcement actions to protect water
quality.
Comprehensive
Water Quality Control
Plan for the Lahontan
Region (Water Code
§13240)
California Water
Code, Division 7,
Section 13241,
13243, 13360, and
13263(a) (Porter-
Cologne Water
Quality Control Act)
4,5
1,2,3.
4.5,6
1
Substantive provisions are ARARs for
discharges of treated groundwater. See
Table 2- for the treated groundwater
discharge limitations.
The water quality objectives for
groundwater are applicable to groundwater
cleanup.
Substantive provisions of sections cited, as
implemented through the beneficial use,
water quality objectives, and waste
discharge requirements of the
Comprehensive Water Quality Control Plan
for the Lahontan Region are ARARs for
discharges to groundwater from CAOCs 23
and 35. Minimization of those discharges is
addressed by the CAOCs 23 and 35
proposed remedial actions; however, past
and current discharges to groundwater
from CAOCs 23 and 35 will be addressed
by the removal action planned for OU 1
groundwater and subsequent remedial
actions for groundwater at MCLB Barstow.
ro
61
Statutes and policies, and their citations, are provided as headings (o identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not Indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
Page 1 of 6
-------
CTO298\B70027\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Leachate control
and monitoring
requirements for
landfill closure
Groundwater
monitoring
requirements for
landfill closure.
Discharges to
high quality
waters
Requirement
Leachate control and monitoring shall
cease only after the operator
demonstrates that leachate is not longer
being produced or the discharges of
leachate will have no affect on water
quality. The quantity and quality of
leachate must be monitored at least
quarterly or whenever groundwater
samples are collected.
Detection and verification monitoring in
accordance with 23 CCR, Chapter 15,
Article 5, must be conducted.
Groundwater monitoring during
postctosure must continue until leachate
is no longer being produced or opposes
no threat to water quality.
Incorporated into all Regional Board
Basin Plans. Requires that quality of
waters of the State that is better than
needed to protect all beneficial uses be
maintained unless certain findings are
made. Discharges to high-quality waters
must be treated using best practicable
treatment or control necessary to
prevent pollution or nuisance and to
maintain the highest quality water.
Beneficial uses must, at least, be
protected.
Prerequisites
Citation
14 CCR
17781(b)<1)(2)
14CCR17782(a)
b)(d)
SWRCB Resolution
No. 68-1 6 (Policy with
Respect to
Maintaining High
Quality of Waters in
Caljfomia)(Water
Code §13140, Clean
Water Act regulations
40CFR§131.12)
ARAR
Determination"
A
1
1
4,5
RA
TBC
Comments
14 CCR 17781(c)(2) cross-references the
requirements of 23 CCR 2559 for design
requirements for vadose zone monitoring to
detect the release of leachate. However,
Section 2559 was repealed 7/91 , so no
specific regulatory requirements exist for
the design of the vadose zone monitoring
system.
23 CCR, Chapter 15. Article 5, outlines
requirements for identification of water
quality protection standards, constituents of
concern, concentration limits, monitoring
points and point of compliance, and
compliance period. It also has
specifications for water quality monitoring
and system requirements.
Action-specific ARAR for regulating
discharges of treated groundwater back Into
aquifer. Discharges to groundwater that occur
as part of the OUs 1 and 2 remedial actions
must meet the substantive requirements of
Resolution 68-1 6. This resolution Is only
applicable to the treated water discharges and
not to the cleanup of the groundwater or the
potential migration of contaminant plumes.
rO
cn
ro
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions. 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill
Page 2 of 6
-------
CTO298\B
\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Cleanup and
abatement of
wastes that
affect or threaten
water quality
Discharges of
treated
groundwater in
the Lahontan
Region
Requirement
Establishes policies and procedures for
the oversight of investigations and
cleanup and abatement activities
resulting from the discharges of waste
that affect or threaten water quality. It
requires cleanup of waste discharged in
a manner that promotes either
background water quality or the best
water quality that is reasonable if
background levels of water quality
cannot be achieved. Requires actions
for cleanup and abatement to conform to
Resolution 68-16 and applicable
provisions of Title 23 CCR, Division 3,
Chapter 15, as feasible.
Provides general waste discharge
requirements for land disposal of treated
groundwater. The order contains
discharge specifications that include 30-
day median and daily maximum values.
Discharge monitoring requirements are
also specified.
Prerequisites
Citation
SWRCB Resolution
92-49 (Policies and
Procedures for
Investigation and
Cleanup and
Abatement of
Discharges Under
Water Code Section
13304)
Lahontan RWQCB
Resolution 6-93-1 06
[General Waste
Discharge
Requirements for
Land Disposal of
Treated Groundwater]
ARAR
Determination"
A
4.5
RA
TBC
TBC
Comments
The DON has determined that SWRCB
Resolution 92-49 does not constitute an
ARAR for the OUs 1 and 2 remedial actions
because its pertinent requirements are not
more stringent than the ARAR provisions of
Title 22 Section 66264.94. The State does
not agree with the determination that
SWRCB Resolution 92-49 is not ARAR for
this ROD. However, the State agrees that
actions proposed in this ROD would comply
with Resolution 92-49 and compliance with
the Title 22 provisions should result in
compliance with Resolution 92-49. The
State does not intend to dispute the ROD,
but reserves its rights if implementation of
the Title 22 CCR provisions is not as
stringent as State implementation of
Resolution 92-49.
Discharge of treated groundwater to
oxidation ponds or infiltration galleries would
need to meet substantive discharge and
limits monitoring requirements. See Table
2- for the treated groundwater discharge
limitations.
K)
cn
w
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU v vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
Page 3 of 6
-------
CTO298\B70027\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Discharges of
waste to land
Requirement
Monitoring requirements for waste
management units; establishes water
quality protection standards for
corrective action including concentration
limits for constituents of concern at
background levels unless infeasible to
achieve. Cleanup levels greater than
background must meet all applicable
water quality standards, must be the
lowest levels technologically or
economically feasible, must consider
exposure via other media, and must
consider combined lexicological effects
of pollutants. A detection monitoring
program must be maintained except
during any periods when an agency
approved corrective action program is
underway.
Prerequisites
Citation
Title 23 CCR, Division
3,
Chapter 15,
Article 5, Sections
2550.0(a),
2550.1(a)(1),
2550.4(d), (e), (f)
ARAR
Determination"
A
RA
TBC
Comments
Not an ARAR; no more stringent than Title
22CCR66264.94(a)(1),
(a)(3), (c), (d). and (e). The State agrees
that actions proposed in this ROD would
comply with this ARAR and compliance
with the Title 22 provisions should result in
compliance with this ARAR. The State
does not intend to dispute the ROD, but
reserves its rights if implementation of the
Title 22 CCR provisions is not as stringent
as State implementation of this ARAR.
ro
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not Indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed In the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
Page 4 of 6
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CTO298VB
\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Requirement
Water Quality Monitoring Program.
Owners or operators of facilities that
treat, store, or dispose of waste at waste
management units must implement a
water quality monitoring program to
monitor the potential for releases from
the unit or to demonstrate the
effectiveness of a corrective action
program.
Prerequisites
Citation
Article 5, Sections
2550.3, 2550.4,
2550.5, 2550.7(e)
except (e)(12)(B),
2550.8, 2550.10
Article 5, Section
255.7 (e)(12) (B).
ARAR
Determination"
A
1
RA
TBC
Comments
Not ARARs; not more stringent than 22
CCR Sections 66264.93, 66264.94,
66264.95, 66264.97(e), 66264.98.
662264.100. The State agrees that actions
proposed in this ROD would comply with
this ARAR and compliance with the Title 22
provisions should result in compliance with
this ARAR. The State does not intend to
dispute the ROD, but reserves its rights if
implementation of the Title 22 CCR
provisions is not as stringent as State
implementation of this ARAR.
More stringent than Federal ARARs and
applicable for groundwater and vadoso
zone monitoring.
en
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging 7) Cap/cover of CAOC 35 landfill
Page 5 of 6
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CTO298\B70tw7\TAB-A-9.DOC
CLE-J02-01F298-B7-0027
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCLB Barstow, California
Action
Requirement
Prerequisites
Citation
ARAR
Determination"
A
RA
TBC
Comments
California Water Code*
Discharges to the
waters of the state
Authorizes the regional board to prescribe
the requirements under which a waste
discharge may take place. These are
referred to as Waste Discharge
Requirements (WDRs).
California Water Code.
Section 13263
4,5
CERCLA response actions taken entirely on
site are exempt from permitting requirements.
However, the OUs 1 and 2 remedial action
design will incorporate valid ARARs derived
from the substantive requirements of water
quality control plans, taking Into consideration
the beneficial uses to be protected, the water
quality objectives reasonably required for that
purpose, other pertinent waste discharges,
and the need to prevent.
s
A Applicable
ARAR Applicable or relevant and appropriate requirement
CCR California Code of Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
RA Relevant and appropriate
RWQCB California Regional Water Quality Control Board,
SWRCB California State Water Resources Control Board, Lahontan Region
TBC To be considered
Statutes and policies, and their citations, are provided as headings to Identify general categories of potential ARARs for the convenience of the reader Listing the statutes and policies does not indicate that
the Navy accepts all the Statutes or policies as potential ARARs. Specific potential ARARs are addressed In the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions. 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
Page 6 of 6
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JACOBS ENGINEERING GROUP INC
Pasadena. California
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2-64
-------
CTO298\B70027\RODFINALDOC ^ CLE-J02-01F296-B7-O027
Print Data: 30 March, 1998
Version: Final
Revision: 0
3.0 YERMO ANNEX PLUME (OU 1) DECISION SUMMARY
3.1 Summary of Plume Characteristics
3.1.1 Contaminants of Concern
3.1.1.1 Organics
The results of the groundwater Rl at MCLB Barstow indicate that VOCs are the
s
primary class of chemicals affecting underlying groundwater at the Yermo
Annex. VOC contamination may have reached groundwater in the Yermo
subbasin as long ago as 1961 when major industrial operations were moved
from the Nebo Main Base to the Yermo Annex. The most prevalent
contaminants are the solvents TCE and PCE, which have been used at the
Base primarily in cold cleaning, vapor degreasing, chemical paint stripping, and
painting operations. TCE and PCE have been detected at concentrations
exceeding federal and state drinking water standards in over a dozen
groundwater monitoring wells in the Yermo Annex area. Other VOCs detected
above federal or state standards include 1,1-dichloroethene (1,1-DCE),
benzene, and 1,2-dichloroethene (1,2-DCA).
Tables 3-1 and 3-2 show the maximum concentrations of VOCs detected in on-
and off-Base groundwater monitoring wells, respectively, along with their
associated MCLs. Contaminants exceeding drinking water standards are shown
at the top of the tables. The most commonly detected VOCs are TCE and PCE
that were found in 21 and 20 wells respectively, and 1,1-DCE that was detected
in seven wells. Other VOCs including 1,1-dichloroethane (1,1 -DCA), 1,2-
dichoroethane (1,2-DCA), 1,2-dichloroethene (1,2-DCE), 1,1,1-trichloroethane
(1,1,1-TCA), 2-butanone, xylenes, and Freons were detected in fewer than four
wells. Semivolatiles organic compounds (SVOCs) and total petroleum
hydrocarbons as diesel (TPH-D) were also detected at Yermo, but at much
lower concentrations and detection frequencies.
3-1
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CTO298\B70027\RODFINALDOC CLE-J02-01F298-B7-0027
Print Data: 30 March. 1998
Version: Final
Revision: 0
3.1.1.2 Inorganics
Various metal analytes are present in groundwater throughout the Yermo
Annex. These analytes are typically present in all natural waters in various
amounts depending on geologic setting, contact time between the water and
mineral-rich sediments or bedrock, and other factors.
Most of the metal analytes detected in groundwater at the Yermo Annex,
including common ions such as calcium, iron, magnesium, potassium, and
sodium, exhibit concentration distributions that can be explained simply as
natural variations due to heterogeneity of the subsurface environment.
Two metal analytes, nickel and chromium, were found to exceed MCLs and to
be elevated relative to their statistically defined background levels in several
wells near the highly industrial operations at Building 573 on the northern
section of the Yermo Annex (i.e., wells YS34-1, YS35-1, YEP-1, YS16-4, and
YS16-5). Three other metal analytes, antimony, thallium and aluminum, were
also detected in this area at slightly elevated levels relative to their background
concentrations. However, an evaluation of the spatial and temporal distributions
for these metals indicates that similarly elevated levels were also detected in
other on- and off-Base areas (e.g., Well Y8-1) not associated with industrial
activities.
In addition to spatial variation, large temporal variations in the concentrations of
these metals throughout 4 years of sampling suggest that turbidity or sampling
techniques may have also been a factor in the higher reported concentrations.
Turbidity during sampling has been an ongoing issue due to the nature of the
interbedded sands, silts, and clays in the alluvial aquifers at MCLB Barstow.
Changes in iron concentrations from each sampling event (an indicator of
sample turbidity) correlate closely to nickel and chromium concentrations in the
suspected wells. All five wells around Building 573 reported their highest iron
and chromium concentrations, and three of the five wells exhibited their highest
nickel concentrations, during the same January 1994 sampling event. The Rl
yielded inconclusive answers to the questions of whether the concentrations of
3-2
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CTO298\B70027\RODRNAl_DOC CLE-J02-01F298-B7-0027
Print Date: 30 March, 1998
Version: Final
Revision: 0
these five metals are naturally occurring or the result of Base activities. To
resolve this issue, the Marine Corps and regulatory agencies have agreed to
measure the concentrations of these five metals in a few selected groundwater
monitoring wells for a minimum of four additional quarters (1 year). MCLB
Barstow has agreed to amend this ROD to address cleanup options if metals
are determined to be a problem after this additional sampling.
3.1.2 VOC Contaminant Sources
VOCs constitute the only confirmed class of groundwater contaminants
originating from sources at three distinct areas of the Yermo Annex. The area!
extent of the VOC plume and location of contaminant sources are shown on
Figure 3-1.
The northern Yermo area of contamination appears to be a result of leaks and
breaks in the industrial wastewater treatment plant piping associated with CAOC
16 (Building 573), past disposal activities at CAOC 15/17 (former industrial
waste treatment plant), and possibly landfill activities at CAOC 35. The
maximum TCE and PCE concentrations in this area were 77 and 230
micrograms per liter (ug/L), respectively, in the general area of CAOC 16.
Maximum concentrations detected at the Base boundary downgradient from this
area were 74 ug/L for TCE and 66 ug/L for PCE (state and federal MCLs for
TCE and PCE are 5 \ig/L).
The southern portion of Yermo Annex VOC plume contamination appears to
have resulted from past landfill operations at CAOC 23. Maximum TCE and
PCE concentrations detected in this area were 34 and 18 ug/L, respectively.
The central and most upgradient portion of the Yermo Annex VOC plume is
attributed to discharges to a French drain at CAOC 26 (Building 533, Packaging
and Maintenance Shop). Maximum TCE and PCE concentrations in
groundwater in this area are 141 and 31 ug/L, respectively.
3-3
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Version: Final
Revision: 0
3.1.3 Location of Vadose Zone Contamination
Residual vadose zone contamination has been determined to be present in
subsurface soils above the groundwater table in the three general source areas
previously described. Vadose zone contamination can provide a continuous
source of contaminants to groundwater, which could increase overall aquifer
cleanup time and costs. Therefore, isolation, reduction or removal of vadose
zone contamination is part of the groundwater remedial actions.
Based on intense site scoping, soil gas and geophysical surveys, visual site
inspections, and soil and groundwater sampling, the Marine Corps narrowed the
suspected areas of vadose zone contamination at MCLB Barstow to a handful
of sites. Consistent with the spirit of CERCLA and the NCP to expedite
cleanup, the Marine Corps and regulatory agencies adopted a remediation-
based approach designed to shift the focus of the MCLB Barstow IRP away
from site characterization and towards cleanup. Based on this approach, the
extent of vadose zone and groundwater contamination were investigated to the
degree necessary to confirm the need for remedial action and support remedial
action decisions discussed as follows.
3.1.3.1 CAOC16
CAOC 16 comprises the Maintenance Center Barstow (MCB) (Building 573) and
its perimeter area (approximately 60 acres) (see Figure 3-1). Building 573 is the
main facility of the MCLB Barstow Repair Division. Activities conducted at this
facility include engine repair, rebuilding and testing, radiator and metal parts
cleaning, dynamometer testing, solvent cleaning of electronic parts, and
parkerizing of weapons. Because of potential significant disruptions to mission-
critical operations, very limited vadose zone characterization was conducted at
this site. However, based on the widespread area of VOC contamination in
groundwater at levels above federal and state MCLs, and the high concentration
of industrial activity at the site, the Rl conservatively concluded that VOC
contamination is present throughout the vadose zone underlying Building 573.
3-4
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Version: Final
Revision: 0
CAOC 16 was therefore included in the FS for evaluation of vadose zone and
groundwater cleanup remedial alternatives.
3.1.3.2 CAOC 15/17
CAOC 15/17 is a 13-acre rectangular area located between Building 573
(CAOC 16) and the Yermo Class III Landfill (CAOC 35) (see Figure 3-1). The
area encompasses the former industrial wastewater treatment plant (IWTP)
including 14 evaporation basins, four sludge drying beds, a temporary pond,
three oxidation ponds, the overflow area around the ponds, and a wet well. The
depth to groundwater in this area is approximately 140 feet bgs. The site has
been inactive since 1990.
Based on scoping information, an estimated 140,000 gallons of bilge water
contaminated with oil and gasoline were reportedly discharged to the ground
during regular operations between 1961 and 1970. In addition, an estimated
3,000 gallons of waste oil may have been spilled during the process of draining
and transferring used oil from vehicles to drums and to tank trucks. Sludge
drying beds reportedly stored both sludge from the evaporation basins for drying
and contaminated soil from fuel spills mixed with sludge. All residual sludge
was subject to a removal action in 1993 (Jacobs 1996).
Site characterization data including a near-surface soil organic vapor (SOV)
survey and soil sampling revealed localized VOC contamination with the highest
concentrations along the southern boundary with CAOC 16. Based on existing
data, there is no direct evidence that widespread VOC contamination is present
in the vadose zone at this CAOC, or that it represents an ongoing source of
VOC contamination to groundwater that warrants source removal. Although
there is uncertainty in this conclusion due to the limited vadose zone
characterization in the area, the existing information points to CAOC 16 as the
major source of vadose zone impacts to groundwater in the area (the highest
concentrations of VOCs in groundwater at the Yermo Annex have been
detected in wells near and downgradient of CAOC 16).
3-5
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CTO298\B70027\RODFINALDOC CLE-J02-01F298-B7-0027
Print Date: 30 March, 1998
Version: Final
Revision: 0
3.1.3.3 CAOC26
CAOC 26, which encompasses Building 533 (the Packaging and Maintenance
Shop) and the area around it, has also been identified as a major source of
VOC contamination in groundwater at the Yermo Annex (see Figure 3-1).
The shop operations include cleaning, repairing, preserving, painting, and
packaging various work pieces. The shop consists of a waterfall-type paint
booth, several dip tanks for cleaning and preservation operations, a vapor
degreaser, and a sandblasting unit. The perimeter area of Building 533
contains a steam cleaning rack, an oil/water separator, a darkly discolored area
to the west, and a French drain area (formerly misidentified as underground
storage tank [LIST] T-533). Wastes generated at the facility include solvents,
TCE, waste oil, paint wastes, and preservatives.
Significant soil gas concentrations of TCE, PCE, and cis-1,2-dichloroethene
(cis-1,2-DCE) were detected in the vadose zone in the area near the French
drain. A groundwater concentration of more than 140 ug/L TCE was also
reported. A leaching potential analysis using a vadose zone leaching model
(VLEACH) indicated that groundwater may be affected over the next 100 years.
CAOC 26 was included in the FS to evaluate vadose zone and groundwater
remedial alternatives on the basis of these results.
3.1.3.4 CAOCs 23 and 35 (Municipal Landfills)
CAOCs 23 and 35 at the Yermo Annex were primarily used as municipal
landfills (see Figure 3-1). Wastes disposed of at these sites consist primarily of
municipal trash, industrial solid waste, scrap metal, wood, paper, and plastic
packing materials. Consistent with the presumptive remedy approach, the
actual contents of the landfill areas were not sampled. However, soil samples
were obtained from areas beneath and around the disposal areas. The
potential for chemicals detected in these samples to leach to groundwater was
assessed using the Marshack and VLEACH models.
3-6
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Print Data: 30 March, 1998
Version: Final
Revision: 0
Based on downgradient groundwater monitoring data, these CAOCs are
believed to have been sources of groundwater contamination at one time. The
vadose zone modeling results indicate that the current chemical concentrations
detected in the soil samples collected will not affect groundwater. However,
these results cannot be considered representative of vadose zone conditions
throughout the entire landfill area. The presumptive remedy for these CAOCs
involves leaving the waste in place, capping, and long-term groundwater
monitoring. Capping remedial actions are being addressed under OU 3 for
CAOC 23 and OU 5 for CAOC 35. Groundwater monitoring under the
substantive RCRA landfill closure requirements for both CAOCs 23 and 35 have
been incorporated into this ROD.
3.1.4 Location of Groundwater Contamination
VOCs were detected in groundwater in and downgradient of the source areas
discussed above.
Figures 3-2 and 3-3 show maps of the distribution of PCE and TCE in
groundwater throughout the Yermo Annex. These maps, contoured using Lynx
Geosystem (a geostatistical model used to visualize the extent of migration of
each constituent), show the location of the three general source areas
discussed in Section 3.1.2 and the extent of their dissolved plumes. The data
(current as of December 1996) suggest that the dissolved plumes from the three
areas have commingled to form one large plume. Therefore, the three distinct
areas of groundwater contamination have been combined and designated as
the Yermo Annex plume.
The Yermo Annex plume, the largest of the three VOC plumes identified at
MCLB Barstow, spans an area of approximately 12,000 by 4,000 feet.
3.1.5 Contaminant Migration Routes
The following potential routes of contaminant migration were identified for OU 1:
3-7
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CTO29e\B70027\RODFINALDOC CCE-J02-01F296-B7-0027
Print Date: 30Marcft, 1998
Version: Final
Revision: 0
1) Vadose Zone Contaminant Transport:
a) Vertical transport through the soil by desorption of chemicals bound to
the surface of soil particles, and percolation of infiltrated water through
the contaminated soil column.
b) Vertical and horizontal transport of contaminant vapors through soil
pore space from either residual or re-vaporization of material
adsorbed/absorbed onto the soil particles. Vapors can potentially
recontaminate the groundwater or be emitted to the surface.
2) Groundwater Contaminant Transport: Vertical and horizontal
transport of contaminants through the groundwater matrix.
3.1.5.1 Vadose Zone Contaminant Transport
In general, VOC compounds have a high vertical mobility in soils. At the Yermo
Annex, VOCs have percolated into the top 40 feet of groundwater. The
available data indicate that PCE and TCE are the predominant groundwater
VOC contaminants in the Yermo Annex plume. PCE predominates in the area
of CAOCs 16,15/17, and 35, while TCE is more common at CAOCs 23 and 26.
Source leaching modeling was performed using VLEACH 2.0 (Turin 1990) to
assess the future impact to groundwater from vadose zone contaminants.
VLEACH modeling results for CAOC 26 indicate that vadose zone
contamination will pose a significant continuous threat to groundwater for the
next 100 years. VLEACH modeling results for CAOCs 16, 15/17, 23, and 35
were determined based on the limited vadose zone characterization conducted
at these CAOCs and can not be considered representative of the existing
vadose zone conditions. Because of this uncertainty, the Marine Corps has
conservatively assumed that vadose zone contamination is present at these
CAOCs and poses a threat to groundwater.
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3.1.5.2 Groundwater Contaminant Transport
As shown in Figure 3-1, the Yermo Annex VOC plume extends from CAOC 26
on the western side of the Annex to the current leading edge of the plume,
approximately 5,000 feet downgradient of the eastern Base perimeter. The
plume has migrated from west to east in the direction of groundwater flow at an
estimated rate of 60 to 70 feet per year. Contaminant levels above drinking
water standards have been detected off-Base about 2,000 feet downgradient of
the Base boundary. As discussed in Section 2.4, two private residence wells
located in this area have been provided with well-head carbon filtration
treatment systems as a precautionary measure. The next nearest known water
supply well is about 2,000 feet downgradient of the leading edge of the plume.
It is estimated that it would take approximately 30 years for the leading edge of
the plume to reach that well. The maximum concentration expected to ever
reach the well is estimated at 2.1 ug/L (which is below drinking water standards)
in approximately 100 years.
Groundwater samples from intermediate depth monitoring wells (screened from
40 to 60 feet below the groundwater table) resulted in mostly concentrations of
VOCs below detection limits. Therefore, a vertical extent of 40 feet was
determined to be the maximum depth of groundwater VOC contamination for
the purpose of designing the groundwater pump and treat system.
3.2 Summary of Yermo Annex Plume Risks
The major risk currently associated with OU 1 of MCLB Barstow is the ingestion of
contaminated groundwater underlying the affected on-Base and off-Base areas. Actual
or threatened releases of hazardous substances from the Yermo Annex, if not
addressed by implementing the response action selected in this ROD, may present a
threat to public health, welfare, or the environment.
3.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the
Yermo Annex have been managed, treated, and disposed of on site throughout
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the Base history. The chemicals measured in the vadose zone and
groundwater during the Rl were evaluated for inclusion as chemicals of potential
concern in the risk assessment by application of screening criteria.
Contaminants of concern identified in on- and off-Base groundwater at the
Yermo Annex (OU 1) are listed in Tables 3-1 and 3-2, respectively.
3.2.2 Summary of Toxicltv Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for
contaminants of concern in groundwater at the Yermo Annex (OU 1) are
provided in Tables 3-3 and 3-4, respectively.
3.2.3 Human Health Risk
For the groundwater under OU 1, the baseline risk assessment (BLRA)
reviewed a future hypothetical residential scenario for on- and off-Base
residents in the absence of further response action (see Section 2.7.2). The
BLRA showed that under this scenario for cancer risk, as many as 20 in 10,000
(2 x 10'3) additional persons for the on-Base portion of the plume, and 10 in
10,000 (1 x 10'3} additional persons for the off-Base portion of the plume that
exceeds drinking water standards, have the potential to develop cancer during
their lifetimes. These estimates were developed based on the conservative
exposure assumptions outlined in Section 2.7.2. Both these estimates are
above EPA's target range of 10"4 to 10*. For the off-Base portion of the plume
impacting groundwater at levels below drinking water standards, the risk drops
to 2 in 10,000 (2 xlO"4) additional persons, which is at the upper end of EPA's
target range. The chemicals of concern contributing the most to estimated
cancer risk are TCE, PCE, and 1,1-DCE.
Considerable uncertainty exists regarding the above estimates relative to the
cancer risk associated with 1,1-DCE, the largest contributor to risk. Specifically,
evaluation of all the animal cancer bioassays suggests that 1,1 -DCE is a
questionable animal carcinogen. When metabolic differences between animals
and humans are compared, the potential carcinogenicity of 1,1-DCE in humans
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is even more questionable. Therefore, the actual risk to humans may be much
less than the above estimates.
For noncancer health effects, the hazard indices for the on- and off-Base
portions of the plume above drinking water standards are 9.4 and 3.7,
respectively. In both cases, the hazard index exceeds EPA's acceptable
criterion of 1. For the off-Base portion of the plume below drinking water
standards, the hazard index is 0.33, which is below the acceptable criterion of 1.
The chemicals of concern contributing the most to estimated non-cancer health
effects are TCE, PCE, and 1,1 -DCE.
Based on the above results, groundwater containing VOC contamination above
drinking water standards is a medium of concern for remedial action. In
addition, the subsurface soil is a medium of concern because of potential cross-
media chemical transport from subsurface soil to groundwater.
3.2.4 Ecological Risk
An ecological risk assessment was independently performed by EPA Region IX
to evaluate potential effects on plants and animals from groundwater
contaminants at MCLB Barstow. At most areas of the Yermo Annex,
groundwater is found at depths greater than 100 feet and there is no surface
water. Exposure of potential ecological receptors to VOCs in groundwater is
unlikely because no groundwater discharges to local surface waters and is not
accessible to plants and animals. Therefore, no complete exposure pathway to
impact ecological receptors exists at the Yermo Annex (OU 1).
3.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make decisions regarding groundwater
and vadose zone cleanup decisions for the Yermo Annex.
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3.3.1 Groundwater Cleanup
The extent of VOC contamination at the Yermo Annex was determined during
the RI/FS. Because of the large extent of the plume (approximately 6.13 billion
gallons over a 12,000- by 4,000-foot area), remediation strategies were
developed to evaluate cleanup options on the basis of ARAR-driven remediation
goals (i.e., MCLs, background levels). The following remediation strategies
were evaluated in the FS.
1) Containment of groundwater contamination at the Base boundary. This
strategy captures over 90 percent of the total VOC mass estimated to
exist in the aquifer, and prevents further migration of contaminants off
Base, but leaves existing levels of VOCs above drinking water standards
off Base untreated.
2) Containment of groundwater contamination at the MCL boundary. This
strategy captures all contamination in excess of drinking water
standards (i.e., MCLs) on and off Base.
3) Containment of groundwater contamination at the background boundary.
This strategy captures all contamination in excess of background levels
on and off Base.
Illustrations of these three different containment areas are provided in
Figure 3-3. This figure shows that the Base boundary area is contained within
the MCL contour area, and the MCL area is in turn contained within the
background contour area. Target remediation volumes were determined for
each of the three containment areas, and alternatives developed to maximize
containment, extraction, and treatment effectiveness.
A technical and economical feasibility analysis (TEF) was conducted to evaluate
the three remediation strategies and determine the most cost-effective, ARAR-
compliant remedy that is protective of human health and the environment. The
TEF analysis, presented in Appendix J of the Draft Final FS for OUs 1 and 2
(Jacobs 1996a), involved an evaluation of the technical limitations, residual risk
(risk remaining in groundwater after cleanup goals have been achieved), and
cost/benefits of incremental risk reduction associated with each alternative. The
following summarizes the TEF analysis results and conclusions.
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1) Experience gained over the past decade has shown that restoring
groundwater to drinking water quality (i.e., to MCLs) or more stringent
standards (i.e., background) is much more difficult than expected due to
the complexities of hydrogeological and contaminant related factors.
Selection of realistic cleanup goals must consider the technical
limitations, economical practicality, and overall protectiveness to human
health and the environment.
2) Cleanup of contaminated groundwater to MCLs and background levels
would result in a residual risk of 2 x 10"* and 2x10"*, respectively.
These numbers are based on very conservative assumptions and
involve considerable uncertainties surrounding cancer risk estimates for
1,1-DCE (see Section 3.2.3). Excluding 1,1-DCE, these estimates would
be approximately 1 x 10"5 and 5 x 10"". Both these levels are within
EPA's risk management range and are considered protective of human
health and the environment.
3) Most of the VOC contaminant mass in groundwater is within the Base
boundary. Plume containment, extraction, and treatment at the Base
boundary is vital to halt contaminant migration, protect off-Base
resources and receptors, and accelerate groundwater cleanup.
Alternatives designed for this containment strategy can effectively
remove over 90 percent of the VOC contaminants in groundwater.
However, this strategy by itself is not ARAR-compliant because it does
not capture and treat off-Base contamination above MCLs.
4) Plume containment, extraction, and treatment at the Base and MCL
boundaries would require extraction and treatment of 17.7 billion gallons
of contaminated groundwater for about 30 years at an estimated present
worth cost of $27.2 million. This estimate includes AS/SVE at CAOC 26
and downgradient of CAOCs 16, 15/17, and 35. This strategy would
remove 95 percent of the total mass and achieve an incremental risk
reduction of over 90 percent to within EPA's risk management range
level. This strategy is ARAR-compliant because it captures and treats all
groundwater contamination above MCLs.
5) Plume containment, extraction, and treatment at the Base and
background boundaries would require extraction and treatment of 46.5
billion gallons of contaminated groundwater (over 2.5 times the MCL
volume), for about 55 years at an estimated present worth of $49.2
million. The cost estimate includes AS/SVE at CAOCs 26 and
downgradient of CAOCs 16, 15/17. and 35. This strategy would almost
double the time and cost of cleanup to MCLs, and only reduce VOC
mass by an additional 4 percent (to 99 percent), and human health risks
by an additional 9 percent (to 99 percent).
The cleanup duration and contaminant mass removal estimates used in the
above analysis are based in part on limited vadose zone data available,
particularly at CAOCs 16 and 15/17. Additional soil sampling and vadose zone
gas monitoring will be conducted at these and other CAOCs during
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implementation of the remedial action. The results of this sampling will be used,
among other tasks, to evaluate the long-term- and cost-effectiveness of the
selected remedy as described in Section 3.3.2. below.
In summary, both background levels and MCLs cleanup goals are considered
protective of human health and the environment. Remediating to background
levels versus MCLs would result in only a minimal incremental difference in risk
reduction and mass removal while doubling the cleanup costs and duration.
Based on these findings, and the technical limitations of extraction and
treatment technology, the TEF analysis concluded that cleanup to background
levels is technically and economically infeasible. Therefore, the Marine Corps
selected MCLs as the cleanup goal for the Yermo Annex VOC plume.
3.3.2 Source Reduction
Vadose zone contamination was determined to exist at five major CAOCs
underlying the Yermo Annex: 16,15/17,23, 26, and 35. Continued releases to
groundwater from these CAOCs could reduce the effectiveness of remediation
efforts and extend the duration of cleanup. This section documents the
rationale for determining the need for, and extent of, source reduction for each
CAOC.
3.3.2.1 CAOC 16
Tne Maintenance Center Barstow (Building 573 and its perimeter area) is the
most active and trafficked industrial area at the Yermo Annex. The entire
perimeter of Building 573 is used as a passageway for vehicular traffic and
testing, maintenance and storage of military equipment in the process of being
refurbished.
Several source reduction options were evaluated for this CAOC in the FS.
1) Soil excavation. This option is not feasible because of the depth of the
contamination (140 feet to groundwater) and the density of physical
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improvements (i.e., buildings, structures, equipment) and industrial
activity at Building 573.
2) In situ vertical AS/SVE. A small-scale AS/SVE pilot study conducted
during the RI/FS demonstrated that this technology would effectively
remove VOC contamination from the vadose zone and groundwater
underlying Building 573. However, the pilot study also evidenced
significant logistical problems during installation and operation of the
system due to the high traffic flow and concentration of industrial activity
and infrastructure at this CAOC. These problems would be compounded
in an attempt to install a full-scale system. The presence of numerous
underground utilities in the area would require clearance, dictate
placement of wells, and could cause significant disruptions to utility
service during system installation. Vertical clearance inside Building 573
is inadequate to accommodate the large drilling equipment required.
Overall, these problems would severely limit the efficiency and cost-
effectiveness of any system that could be installed. Based on these
limitations, the Marine Corps determined that installing a full-scale
vertical AS/SVE would result in major disruptions to mission-critical
operations, and that this option is not feasible under the current site
conditions.
3) In situ horizontal SVE and AS/SVE. This option was considered as a
way to overcome the limitations of vertical drilling. However, the
relatively deep groundwater table (140 feet), overall length of drilling
needed to provide coverage of the Building 573 area (1,000 feet), and
high cost of the technology ($500 per linear foot of drilling), make this
option largely ineffective and extremely cost-prohibitive. MCLB also
evaluated a variation of this option which involved SVE only. Under this
variation, samples needed for soil contamination characterization would
be collected using the horizontal drilling techniques. Following the
investigative stage, the same horizontal borings would be cased and
completed to function as soil vapor extraction wells. According to the
economic evaluation for this option, a total of approximately $26 to $38
million would be required for soil investigation and completion of the SVE
facilities. There is uncertainty in this initial capital cost, because the
characteristics of the required SVE wells are at the practical limits of the
technological for horizontal well construction. The estimated annual
operating cost for the horizontal SVE option is $400,000.
4) In situ vertical AS/SVE downgradient of CAOC 16. This last option
involved placing a vertical AS/SVE system off the handstand area,
downgradient of Building 573, to overcome the logistical problems
encountered by the other options. This option would intercept and
remove VOC contamination from groundwater as it passes through the
system flowing away from the facility. This option would not effectively
remove VOC contamination in the vadose zone directly under Building
573. The existing 10-inch-thick concrete stand provides an effective
protection barrier against potential leaching of vadose zone
contaminants into groundwater due to infiltration! However, VOC
contamination in the vadose zone could still migrate to groundwater
through the process of VOC vapor diffusion and dispersion of soil pores.
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Based on the existing conditions at CAOC 16, the Marine Corps determined that
the last option (Option 4: In situ vertical AS/SVE downgradient of CAOC 16) is
the most practical and cost-effective alternative to address VOC contamination.
The Marine Corps evaluation indicates the other options are not feasible at this
time, because of technical and economic reasons. Those options include
Option 1 (soil excavation), Option 2 (in situ vertical AS/SVE), Option 3 (in situ
horizontal AS/SVE), and the horizontal SVE variation of Option 3.
The DON and regulatory agencies have agreed not to include vadose zone
cleanup of this CAOC as part of the final remedy for the Yermo Annex plume
and to further evaluate the technical and economic feasibility of vadose zone
cleanup at this CAOC according to the criteria outlined in Section 2.8.7 of this
ROD.
3.3.2.2 CAOC 26
The Packaging and Maintenance Shop area has been identified as a major
source of vadose zone contamination and included in the groundwater NTCRA
being conducted at the Yermo Annex. The following source reduction options
were evaluated for this CAOC in the FS.
1) Soil excavation. This option is not feasible because of the depth of the
contamination (140 feet to groundwater) and the presence of physical
improvements (i.e., buildings, structures, equipment).
2) In situ vertical AS/SVE. This option involves installing and operating a
full-scale AS/SVE system designed to provide complete coverage of the
vadose zone and groundwater source areas at CAOC 26. This option
was selected as the preferred remedy at CAOC 26 based on the results
of the AS/SVE pilot study conducted at CAOC 16 during the RI/FS,
which demonstrated that this technology is effective in removing VOC
contamination from the vadose zone and groundwater. AS/SVE is
expected to be effective at CAOC 26 because of its similar
hydrogeologic characteristics to CAOC 16. The AS/SVE system is being
implemented as part of the Yermo Annex groundwater NTCRA and
incorporated into the selected remedy for OU 1 documented in this ROD.
Because the existing system's SVE wells at CAOC 26 are screened at depth
(i.e., within 10 feet of the groundwater table), there is some uncertainty at this
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time regarding the efficiency of the SVE system to effectively remove
contamination from the near-surface soils. Because of this, there exists the
potential for residual VOC contamination in the near-surface soils to impact
future receptors at the site, either through direct soil contact or through vapor
migration and inhalation. To address this, the Navy will perform an evaluation to
determine if residual vadose zone contamination represents a threat to
potential future on-site receptors. If the evaluation demonstrates that a potential
threat to human hearth exists, then the Navy will include in a written notification
to the FFA signatories i) an evaluation of the need for any additional remedial
action and ii) a description of the changes necessary to the selected remedy for
the Yermo Annex plume in the ROD for OU 1. The Navy will add appropriate
language to the MCLB Barstow Master Plan describing the potential threat,
along with any restrictions on site use. The language to be added to the Master
Plan will be provided to the FFA signatories for review and concurrence prior to
it being placed in the Master Plan.
The results of the vadose zone monitoring will be incorporated into the FFA
primary document to be submitted to the agencies as established in Section
2.8.12 of this ROD.
Vadose Zone Modeling to Determine AS/SVE System "Shut Off
Performance parameters for vadose zone modeling will be measured by using
the nested vapor probes located at 30-, 60-, and 90-foot depths in the vadose
zone at CAOC 26. The vapor probe data will provide an indication of the VOC
mass removal in the vadose zone and will be used to derive vadose zone soil
concentrations of VOCs for input to the vadose zone model. VLEACH or
another appropriate vadose zone fate and transport model will be used to
assess when residual VOC levels in the soil no longer pose a threat to
groundwater and to demonstrate whether vadose zone cleanup has been
achieved for Item 1 of Section 2.8.4 of this ROD.
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3.3.2.3 CAOCs23and35
These CAOCs were primarily used as municipal landfills and are believed to
have been sources of groundwater contamination at one time. These CAOCs
are no longer in use and are classified as inactive waste management units.
The presumptive remedy approach for CERCLA municipal landfills is capping
and long-term groundwater monitoring. Capping actions are being addressed
under OU 3 for CAOC 23 and OU 5 for CAOC 35. The capping options being
considered either eliminate or significantly limit infiltration thus eliminating or
minimizing further potential impacts to groundwater. Therefore, no further
vadose zone action is being considered for these CAOCs under OUs 1 and 2.
However, the groundwater monitoring requirements for CAOCs 23 and 35 are
being addressed under OUs 1 and 2.
3.4 Description of Remedial Action Alternatives, Yermo Annex Plume
Ten alternatives for the remediation of groundwater and vadose zone soil in OU 1 are
presented in this section. These alternatives are discussed in detail in the Draft Final
FS for OUs 1 and 2 (Jacobs 1996a) and summarized in this section. Alternative 7 was
screened out during the preliminary evaluation stage and is not included in the ten
alternatives discussed herein.
3.4.1 Alternative 1 - No Action
Under this alternative, no further action would be taken to dean up or control
contamination from vadose zone soil or groundwater. The existing site
conditions would not change. No costs are associated with this alternative. The
no action alternative provides a baseline for comparing the other alternatives.
3.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring
This alternative includes the implementing of institutional controls and initiating a
long-term groundwater monitoring program. This alternative relies on natural
processes such as dispersion degradation, sorption, and volatilization to reduce
VOC concentrations. Institutional controls will ensure that the affected
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groundwater will not be used in the future, thereby maintaining the current lack
of exposure to, and risks from, chemicals in groundwater.
Institutional controls include restrictions on the use of untreated groundwater for
drinking water, and provisions for wellhead treatment of affected water supply
wells within the Yermo Annex plume. The institutional controls to restrict access
to contaminated groundwater for on-Base areas will be documented in the Base
Master Plan, a document that MCLB Barstow uses to coordinate and plan future
activities (e.g., new construction). For off-Base areas, they could include but not
be limited to zoning ordinances implemented by county agencies that restrict
use of groundwater in these areas. The Marine Corps will provide the necessary
information to appropriate county agencies identifying the areas that have been
impacted by groundwater contamination exceeding MCLs. The Marine Corps
will support county agencies with any technical information needed for the
county to implement these restrictions.
This alternative also includes a long-term monitoring program to monitor
groundwater beneath and downgradient of contaminant sources. Groundwater
monitoring involves sampling existing and new monitoring wells as required to
monitor trends in contaminant concentrations, evaluate remediation progress
and contaminant migration patterns, and provide early warning to potentially
affected downgradient users. One of the goals of the long-term monitoring
program is to determine the effectiveness of the selected remedy. To support
this determination, the monitoring program will include vadose zone monitoring
at potential sources.
A Post-ROD vadose zone and groundwater monitoring plan for the Yermo
Annex remedial action will be prepared under the authority of this ROD outlining
the monitoring well network, sampling and analytical methods, sampling
frequency and major decision points to be made during monitoring (e.g., adding
or removing monitoring wells from the network, changing sampling frequency or
analytical parameters, etc.). The Post-ROD Monitoring Plan will be a primary
FFA deliverable to be submitted to the agencies within one year of the signing
of the ROD.
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The post-ROO monitoring plan will also include necessary post-closure
groundwater monitoring at CAOCs 23 and 35 landfills.
The cost for Alternative 2 includes approximately $250,000 in capital costs and
$140,000 in yearly operation and maintenance (O&M) costs to put in place
institutional controls and implement the long-term groundwater monitoring
programs for a total present worth cost of $2.5 million. Groundwater modeling
indicates that it would take this alternative over 500 years to naturally degrade
contaminants to levels below drinking water standards. Except for the no action
alternative, all alternatives include institutional controls and long-term
groundwater monitoring.
t
3.4.3 Alternative 3 - Groundwater Removal (Extraction Wells at Base
Boundary). Ex Situ Treatment, and Discharge
This alternative involves installing eight groundwater extraction wells at the
eastern boundary of the Base to capture the on-Base portion of the plume,
followed by activated carbon treatment of the extracted water. The treated
water is recharged into the aquifer via two infiltration galleries located
upgradient of the contaminant plume. MCLB Barstow estimates that this system
would extract 600 to 800 gallons per minute (gpm) of water from the top 50 feet
of the shallow aquifer. The main purpose of this alternative is to prevent the
higher groundwater contamination on-Base from moving into lower
contamination areas off-Base. This also would begin reducing concentrations of
VOCs in groundwater in the Yermo Annex area by removing the majority of the
contamination from the aquifer. The on-Base portion of the plume represents
about 90 percent of the total VOC contamination in the Yermo Annex area. The
major components of this alternative would consist of:
• Implementing institutional controls described in Alternative No. 2.
• Designing and constructing groundwater extraction wells (already in
place).
• Designing and installing an on-site aboveground treatment system and a
retention and recycling system including two infiltration galleries (already
in place).
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• Starting up and operating this system (already in operation).
• Transporting, regenerating, recycling, and disposing of the spent filters.
• Operating a long-term groundwater monitoring program (in progress).
The approximate volume of groundwater requiring remediation is estimated to
be 3.5 billion gallons. The cost for Alternative 3 includes $4.3 million in capital
costs to construct the treatment system (all of which has already been
constructed as part of the Yermo Annex NTCRA), and $410,000 in yearly O&M
costs to operate the system, for an estimated total present worth cost of $14.1
million. Groundwater modeling indicates that it would take this alternative about
190 years for the on-Base portion and over 500 years for the off-Base portion of
the VOC plume to degrade to levels below drinking water standards.
3.4.4 Alternative 4 - Groundwater Removal (Extraction Wells at Base
Boundary and Off-Base Background Boundary). Ex Situ
Treatment, and Discharge
This alternative is similar to Alternative 3, but includes 11 additional off-Base
wells to capture the entire plume at the background (leading edge) boundary.
MCLB Barstow estimates that this system would extract 1,400 to 1,900 gpm
from the aquifer. This alternative evaluates the option of cleaning up all VOC-
contaminated groundwater to background levels. The major components of this
alternative are the same as for Alternative 3. The approximate volume of
groundwater requiring remediation under this alternative is 6.13 billion gallons.
The cost for Alternative 4 includes $9.5 million in capital costs to construct the
treatment system (of which $4.3 million have already been constructed as part
of the Yermo Annex NTCRA), and $868,000 in yearly O&M costs to operate the
system, for an estimated total present worth cost of $30.1 million. Groundwater
modeling indicates that it would take this alternative about 320 years for the on-
Base portion and 70 years for the off-Base portion of the plume to clean up to
background levels.
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3.4.5 Alternative 5 - Groundwater Removal (Extraction Wells at Base
Boundary and Off-Base MCL Boundary). Ex Situ Treatment, and
Discharge
This alternative provides an intermediate option between Alternatives 3 and 4.
Alternative 5 is also similar to Alternative 3, but includes four additional off-base
wells to capture the off-Base portion at the MCL boundary. This system is
estimated to extract 900 to 1,200 gpm from the aquifer. This alternative
evaluates the option of cleaning up all VOC-contaminated groundwater to meet
federal and state drinking water standards. The major components of this
alternative are the same as for Alternative 3. The approximate volume of
groundwater requiring remediation under this alternative is 3.75 billion gallons.
The cost for Alternative 5 includes $6.4 million in capital costs to construct the
treatment system (of which $4.3 million have already been constructed as part
of the Yermo Annex NTCRA), and $643,000 in yearly O&M costs to operate the
system, for an estimated total present worth cost of $21.8 million. Groundwater
modeling indicates that it would take this alternative about 160 years for the on-
Base portion and 20 years for the off-Base portion of the plume to clean up to
levels below drinking water standards.
3.4.6 Alternative 6 - Groundwater Removal (Extraction Wells at Base
Boundary and CAOC 26 Boundary). Ex Situ Treatment, and
Discharge
This alternative is a variation of Alternative 3, designed to reduce the time to
dean up the on-Base portion of the contaminant plume to below drinking water
standards by 40 years, from 190 to 150 years. Alternative 6 involves four
additional on-Base groundwater extraction wells to intercept the portion of the
VOC plume originating from CAOC 26. This system would extract from 900 to
1,200 gpm from the aquifer. The major components of this alternative are the
same as for Alternative 3. The approximate volume of groundwater requiring
remediation under this alternative is 3.5 billion gallons. The cost for Alternative
6 includes $6.6 million in capital costs to construct the treatment system (all of
which has already been constructed as part of the Yermo Annex NTCRA), and
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$662,000 in yearly O&M costs to operate the system, for an estimated total
present worth cost of $19.3 million.
3.4.7 Alternative 8A - Groundwater Removal and Source Reduction
(Extraction Wells at Base Boundary and CAOC 26 Boundary.
AS/SVE at CAOC 26). Ex Situ Treatment, and Discharge
Alternative 8A, and all alternatives that follow, incorporate source removal into
the remedial action. These alternatives are designed to significantly reduce the
time to clean up the groundwater VOC contamination by removing contaminants
trapped in the vadose zone soils and groundwater underneath the original
source. The vadose zone is the area of unsaturated subsurface soil overlying
groundwater. Contaminants trapped in the vadose zone can provide a
continuous source of contaminants to groundwater for many years, thus
prolonging the cleanup efforts. Alternative 8A is a variation of Alternative 6,
which includes AS/SVE treatment at CAOC 26. This alternative is estimated to
further reduce the time of Alternative 6 to clean up the on-Base portion of the
plume to below drinking water standards by 110 years, from 150 to 40 years.
The cost for Alternative 8A includes $7.5 million in capital costs to construct the
treatment system (all of which has already been constructed as part of the
Yermo Annex NTCRA), and $787,000 in yearly O&M costs to operate the
system, for an estimated total present worth cost of $21.3 million.
3.4.8 Alternative SB - Groundwater Removal and Source Reduction
(Extraction Wells at Base Boundary and CAOC 26 Boundary.
AS/SVE at CAOC 26 and Downaradient of CAOCs 16.15/17. and
35). Ex Situ Treatment, and Discharge
Alternative 8B further expands on Alternative 8A by adding AS/SVE treatment
downgradient of CAOCs 16, 15/17, and 35. This alternative eliminates an
additional 10 years of treatment, reducing the total time to dean up the on-Base
portion of the plume to below drinking water standards to 30 years. The cost for
Alternative 8B includes $9.4 million in capital costs to construct the treatment
system (all of which has already been constructed as part of the Yermo Annex
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NTCRA), and $968,000 in yearly O&M costs to operate the system, for an
estimated total present worth cost of $22.1 million.
As mentioned above, Alternative 8B already is being fully implemented in the
form of a CERCLA NTCRA at the Yermo Annex. The objective of the removal
action is to stop all further migration of contaminants off of the Base, begin to
address the main sources, and accelerate groundwater cleanup.
3.4.9 Alternative BC - Groundwater Removal and Source Reduction
(Extraction Wells at Base Boundary. Off-Base MCL Boundary.
and CAOC 26 Boundary; AS/SVE at CAOC 26 and Downgradient
of CAOCs 16.15/17. and 35). Ex Situ Treatment, and Discharge
Alternative 8C is the same as Alternative 8B, except that it captures and treats
the off-Base portion of the VOCs plume above MCLs to meet federal and state
drinking water standards. The off-Base portion of the plume below MCLs will
not be captured; instead it will be allowed to naturally attenuate because it
already meets drinking water standards. The cleanup times to MCLs are
estimated at about 30 years. The cost for Alternative 8C includes $10.9 million
in capital costs to construct the treatment system (of which $9.4 million have
already been constructed as part of the Yermo Annex NTCRA), and $1.2 million
in yearly O&M costs to operate the system, for an estimated total present worth
cost of $27.1 million.
3.4.10 Alternative 8D - Groundwater Removal and Source Reduction
(Extraction Wells at Base Boundary. Off-Base Background
Boundary, and CAOC 26 Boundary; AS/SVE at CAOC 26 and
Downgradient of CAOCs 16. 15/17. and 35). Ex Situ Treatment.
and Discharge
This alternative is also similar to Alternative 8B, but involves full capture of the
off-Base plume at the background (leading edge) boundary and cleanup of the
entire VOCs contaminated groundwater to background levels. The cleanup
times is estimated at about 55 years. The cost for Alternative 8D includes $14.3
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million in capital costs to construct the treatment system (of which $9.4 million
has already been constructed as part of the Yermo Annex NTCRA), and $1.9
million in yearly O&M costs to operate the system, for an estimated total present
worth cost of $49.2 million.
3.5 Summary of Comparative Analysis of Alternatives
This section summarizes the evaluation of remedial alternatives conducted to select the
alternative that provides the best balance with respect to the nine statutory evaluation
criteria in the NCR and discussed in Section 2.9.
The selected alternative for addressing the groundwater contamination at the Yermo
Annex is Alternative 8C - groundwater removal and source reduction (extraction wells
at Base boundary, off-Base MCL boundary, and CAOC 26 boundary; AS/SVE at
CAOC 26 and downgradient of CAOCs 16, 15/16, and 35), Ex Situ Treatment and
Discharge. Based on the current information, this alternative appears to provide the
best balance of trade-offs among the alternatives with respect to the nine EPA
evaluation criteria.
The following analysis summarizes the evaluation of remedial alternatives under the
three criteria groups: threshold criteria, primary balancing criteria, and modifying
criteria (see Section 2.9). Table 3-5 presents a comparison between each of the
alternatives for achievement of a specific criterion.
3.5.1 Threshold Criteria
3.5.1.1 Overall Protection of Human Health and the Environment
The no action alternative does not provide adequate protection of human health
and the environment if the groundwater were to be used as drinking water in the
future. The institutional controls alternative (Alternative 2) provides protection
by restricting future use. The calculated human health risk for Alternatives 3
through 6, 8A, 8B, 8C, and 8D is at the upper end of the EPA's target risk
range. However, given the conservative nature of the risk assessment and the
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uncertainties in the lexicological data used to derive the risk estimates for 1,1-
DCE, it is likely that the actual risk posed to a hypothetical residential receptor
would be well within the EPA target risk range. Assuming that institutional
controls are effective, particularly in off-Base areas, all alternatives except the
no action alternative are considered to be protective of human health and the
environment. However, only Alternatives 3 to 80 use active measures to reduce
contamination, reduce the future threat to human health and the environment,
and more quickly remediate to cleanup levels.
3.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at
MCLB Barstow is provided in Section 2.10. All alternatives comply with location-
specific ARARs because no ecological, natural, or cultural resources are
threatened by the groundwater contamination. All alternatives also comply with
action-specific ARARs; specifically, state antidegradation ARARs for treated
groundwater discharges, VOC emissions control, and groundwater monitoring
requirements.
The Lahontan RWQCB has classified the aquifer underlying the Yermo Annex
as a potential drinking water source. Alternatives 2, 3, 6, 8A, and 8B do not
comply with the chemical-specific federal and state ARARs for drinking water
standards (i.e., MCLs, nonzero MCL goals, or risk-based concentrations)
because they do not capture the off-Base portion of the plume above MCLs.
Alternatives 4, 5, 8C, and 80 comply with all location-, action-, and chemical-
specific ARARs.
3.5.2 Primary Balancing Criteria
3.5.2.1 Long-Term Effectiveness and Permanence
Groundwater and vadose zone modeling were used to estimate how long it
would take to achieve MCLs or background concentrations at the point of
compliance for all the alternatives evaluated.
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All alternatives except Alternative 1 provide moderate to high long-term
effectiveness and permanence. The results indicate that Alternatives 2 through
6 would require a relatively long time to achieve remedial goals (150 to over 500
years). Alternative 2 can effectively reduce risk by restricting the use of
untreated groundwater for drinking water and providing wellhead treatment
when warranted. However, if these control measures cannot be implemented or
maintained, Alternative 2 would not comply with this criterion. Alternative 8C will
meet cleanup levels by providing a capture zone that will prevent migration of
contaminants exceeding drinking water standards, and will extract and treat all
contaminated groundwater above these standards in an estimated 30-year
timeframe. Levels of contamination present in the vadose zone at CAOCs 16
and 15/17 may affect the long-term effectiveness of the selected remedy and
result in increasing the 30-year remediation time estimate.
3.5.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2, the no action and institutional controls alternatives, would
not provide for a reduction in toxicity, mobility, and volume through treatment
because they are not treatment options. All other alternatives would achieve
moderate to high reduction of toxicity, mobility, or volume through active
extraction and treatment and AS/SVE remediation.
3.5.2.3 Short-Term Effectiveness
Due to the length of the remedial action, short-term risks are the same as
current risks. Except for the no action alternative, all alternatives rely on
institutional controls for short-term effectiveness of community protection. Such
controls are more effective on-Base. If off-Base controls cannot be maintained,
short-term effectiveness would be compromised.
The no action and institutional control alternatives would have the least
immediate harmful effect on human health and the environment, but would also
provide less protection in the short term. The active remediation alternatives
would slightly increase the risk of exposure by pumping and handling of
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contaminated groundwater. However, use of proper worker protection and
safety measures would reduce these risks to safe levels.
3.5.2.4 Implementabilrty
The no action alternative is the easiest to implement because there is nothing to
implement. Imposing institutional controls off-Base will require state, local, and
community involvement.
Extraction and treatment and AS/SVE are proven, commercially available,
readily implementable, and simple to operate technologies. As discussed in
Section 3.3.2, constructibility issues at or near Building 573 will prevent installing
an AS/SVE system directly underneath CAOC 16. In all other on-Base areas,
no problems are expected during installation of extraction wells and treatment
systems. Construction of off-Base extraction wells will require obtaining access
to private property through coordination with private land owners and local
officials.
3.5.2.5 Cost Effectiveness
The selected alternative (Alternative 8C) is the second most costly, with an
estimated present worth value of $27.1 million, exceeded only by Alternative 8D
with a present worth of $49.2 million. Alternative 8C costs more than most of
the other alternatives, but is the only groundwater remedy that meets the
threshold criteria for protection of human health and the environment and
complies with ARARs in an estimated 30-year time frame. The higher cost is
therefore justifiable and cost effective. Approximately $10 million in the capital
cost of alternative 8C and 1 year of O&M costs have already been incurred in
the implementation of the groundwater NTCRA at the Yermo Annex.
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3.5.3 Modifying Criteria
3.5.3.1 State Acceptance
The California State DISC and RWQCB have reviewed and approved the OUs
1 and 2 FS and Proposed Plan, and agree with the selected final remedy for
the Yermo Annex plume.
3.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed
actions for OUs 1 and 2. These comments are included on Page 27 of the
public meeting transcripts provided in Appendix C, and in Section 6,
"Responsiveness Summary.11
3.6 Summary of Selected Remedy For the Yermo Annex Plume
As required by CERCLA and the NCP, and based on the results of the detailed
analysis of alternatives presented above, MCLB Barstow selected Alternative 8C as the
final remedy to address groundwater and vadose zone contamination at the Yermo
Annex.
For the contaminated groundwater above MCLs, the selected remedy consists of
remediation of the contaminant plume by pump and treat, with ex situ treatment and
recharge of treated groundwater back into the aquifer, and enhanced by AS/SVE. This
remedy will consist of containing and extracting the contaminated groundwater from the
upper 50 feet of the aquifer, treating it on site through a carbon infiltration system and
recharging it back into the aquifer through two infiltration galleries at the upgradient
edge of the plume. Air sparge effluent from AS/SVE systems will be discharged to the
atmosphere after it has been filtered for organic compounds. Air discharges will comply
with the discharge standards and requirements of the local air pollution control district.
The used carbon filter media will be taken off site for recharge and reused.
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The groundwater extraction wells will be arranged at three areas consisting of four on-
Base extraction wells designed to capture the plume originating from CAOC 26, eight
wells at the eastern boundary of the Base to capture the on-Base portion of the plume,
and four off-Base wells at the MCL boundary of the plume to capture the off-Base
portion of the plume above MCLs. The four groundwater extraction wells for CAOC 26
and the eight wells on the eastern boundary of the Base have already been installed.
Locations, sizing, and pumping rates for these wells were determined by evaluating the
results of pumping tests conducted as part of the remedial design phase. The four off-
Base wells at the MCL boundary still need to be located and installed.
Contaminated groundwater will be pumped to the water treatment system, treated, and
recharged at the upgradient edge of the plume through the infiltration galleries. The
groundwater carbon filtration and AS/SVE treatment systems for CAOCs 26 and 16
have already been constructed and are currently operational. The four off-Base
extraction wells at the MCL boundary will eventually be connected to the existing
groundwater treatment system. Because the underlying aquifer is relatively slow
moving (60 ft/yr), the infiltration galleries will be used to help enhance movement of
contaminated groundwater toward the extraction wells. Extracting and treating the
groundwater will continue until the performance standards (see Table 2-1) are
achieved. Clean up of the contaminated groundwater at OU 1 to MCLs is estimated to
take 30 to 40 years.
This remedy includes periodic vadose zone and groundwater monitoring to track
changes in the level and extent of contamination. The major components consist of:
• Implementing institutional controls.
• Designing and constructing groundwater extraction wells, monitoring wells and
SVE wells, as necessary.
• Designing and constructing a groundwater extraction and monitoring system, a
groundwater treatment system, and two infiltration galleries.
• Designing and installing two AS/SVE systems, one at CAOC 26 and a second
one downgradient of CAOCs 16, 15/17, and 35, and conducting vadose zone
soil gas monitoring to assess the effectiveness of these systems.
• Starting and operating these systems.
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• Transporting, regenerating, recycling, and/or disposing of the spent filters.
• Operating and maintaining of a long-term vadose zone and groundwater
monitoring program that includes periodic monitoring of selected COCs in soil
vapor and groundwater monitoring and extraction wells, to be specified in a
post-ROD OU 1 Remedial Action Groundwater Monitoring Plan (OHM 1996a).
• Conducting quarterly sampling of groundwater for 1 year for five dissolved
metals (nickel, chromium, antimony, thallium and aluminum) at selected wells in
the area of CAOC 16 to ascertain if these metals are naturally occurring or the
result of Base activities.
• Closure criteria.
To ensure that human health and the environment are protected in the future,
institutional controls will be implemented that include access restrictions to prevent the
on-Base use of untreated groundwater for domestic use, which includes ingestion,
dermal contact and inhalation as routes of exposure. Wellhead treatment will be
provided for any existing water supply wells that fall within the area of the plume
exceeding MCLs. The DON will provide necessary information to appropriate county
agencies identifying off-Base areas impacted by groundwater contamination exceeding
MCLs. The DON will support county agencies with any technical information needed for
the county to implement restrictions on construction and use of wells in the affected
areas.
The written concurrence of the FFA signatories is required before the DON takes any
action at a CAOC that would be inconsistent with the prohibition against use of
untreated groundwater at the Yermo Annex for domestic use. If any such action is
proposed, the DON must provide the FFA signatories with written notification of such
proposed action. The notice shall include (i) an evaluation of the risk to human health
and the environment, (ii) an evaluation of the need for any additional remedial action as
a result of the proposed action, and (iii) a description of the changes necessary to the
selected remedy for the Yermo Annex plume in the ROD for OUs 1 and 2.
The written notice of proposed action shall be submitted to the FFA signatories at least
60 days prior to the commencement date for the proposed action. The EPA will advise
whether a ROD amendment or an Explanation of Significant Differences (ESD)
document is required. The response from the FFA signatories is due within 30 days of
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the DON'S written notice of proposed action. The DON may not commence any action
without the written concurrence of the FFA signatories.
The DON shall notify the FFA signatories of any plan to lease or transfer Yermo Annex
real property to a non-federal or federal entity, notify the transferee or lessee of the
prohibition on use of groundwater at the Yermo Annex for domestic use and include the
restrictions in the transfer or lease. Such notification shall be provided at least 45 days
in advance of the lease or transfer conveyance. The DON shall comply with Section
120(h)(3) of CERCLA in any such transfers.
The DON will also provide the FFA signatories with 30 days advance notice of any
amendment to the Master Plan that could affect either the substance or the language of
the Yermo Annex Master Plan groundwater use restriction amendment.
The MCLB Barstow Base Master Plan will be amended to incorporate the above-
mentioned restrictions on access to and use of contaminated groundwater for drinking
water purposes on-Base. The Master Plan amendments will include language that
1) prohibits the on-Base use of untreated groundwater for domestic use; 2) describes
the risk to human health and the environment from use of the contaminated
groundwater; and 3) references the MCLB Barstow OUs 1 and 2 RI/FS and ROD. The
language in the Master Plan amendments will also include the title and dates of the
above-listed documents and their storage location. These amendments to the Master
Plan will be completed by the DON within 1 year of signing the MCLB Barstow OUs 1
and 2 ROD. The FFA signatories will be provided with a draft copy for review and
comment of the amendments to the Master Plan reflecting the above languague.
The groundwater remedy for OU 1 is consistent with the requirements of Section 121 of
CERCLA and the NCP. The remedy will reduce the mobility, toxicity, and volume of
contaminated groundwater at the site. In addition, the remedy is protective of human
health and the environment, will attain all federal and state applicable or relevant and
appropriate requirements, is cost-effective, and uses permanent solutions to the
maximum extent practicable. The remedy for OU 1 is consistent with previous removal
actions at the site. Based on the information available at this time, the selected remedy
represents the best balance among the criteria used to evaluate remedies.
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3.6.1 Performance Standards for Groundwater and Source Reduction
Groundwater from the aquifer shall be monitored until cleanup goals
(performance standards) set for in Table 2-1 are achieved as agreed upon by
the DON and the regulatory agencies. See Sections 2.8 and 3.3. for discussion
of source reduction performance standards.
3.6.2 Infiltration Standards
Treated groundwater that will be recharged into the aquifer passed through the
infiltration galleries shall comply with the substantive general waste discharge
requirements for land disposal of treated groundwater, Lahontan RWQC6
Board Order No. 6-93-106. These requirements are listed in Table 3-6. Meeting
these requirements complies with SWRCB Resolution 68-16 and the Basin
Plan. The general discharge requirements of Board Order No. 6-93-106 have
monitoring requirements that verify compliance. A schedule for compliance
appropriate for this monitoring shall be established in the Yermo Annex
Remedial Action Groundwater Monitoring Plan.
3.6.3 Groundwater and Vadose Zone Monitoring
Groundwater and vadose zone monitoring shall be conducted for the Yermo
Annex plume during the remedial action in accordance with the Yermo Annex
Remedial Action Groundwater Monitoring Plan (see Section 3.4.2) to verify that
the remedial action is being effective towards achieving remedial action
objectives (RAOs). The Remedial Action Groundwater Monitoring Plan will
consists of existing and new groundwater monitoring wells if necessary, to
determine if RAOs are being met. Vadose zone monitoring will consist of the
existing soil vapor probes at CAOC 26, and three additional probes at CAOC 16
to be installed post-ROD. The DON will monitor the vadose zone and
groundwater as specified in the groundwater monitoring plan, until it is
demonstrated that the remedial action has effectively and permanently reduced
the VOC contamination to within the remedial goals (RGs) set forth in Table 2-1.
The criteria for assessing the effectiveness of the remedial action shall also be
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included in the groundwater monitoring plan. If monitoring indicates that RGs
have not been met in accordance with these criteria, the groundwater remedial
action will continue until the RGs are achieved. The results of the groundwater
monitoring will be evaluated every 5 years, and the duration and frequency of
the groundwater monitoring modified as appropriate until it is determined that
the remedial action has been completed.
Groundwater monitoring for CAOCs 23 and 35 will entail collection and analysis
of groundwater samples for compliance monitoring per OCR Title 22 (RCRA
landfill closure requirements). Compliance monitoring will involve quarterly
collection of one sample per well from at least two downgradient and one
upgradient monitoring wells for 2 years. Groundwater samples will be analyzed
for VOCs (EPA Method 8260) and general chemistry quarterly for 2 years. It is
assumed that the data gathered in the initial two years of monitoring will provide
adequate trend data of the groundwater plume, so that the frequency of
sampling events will be reduced to half (i.e., semiannual) for the following 28
years. The results of the groundwater monitoring will be reevaluated every 5
years, and the duration and/or frequency of the groundwater monitoring may be
further modified based on the results of the reevaluations.
As discussed in Section 3.1.1.2, groundwater monitoring will be conducted to
measure the concentrations of five metals (nickel, chromium, antimony, thallium
and aluminum) in a few selected groundwater monitoring wells in the area of
CAOC 16 for a minimum of four additional quarters (1 year). The exact wells to
be sampled and the sampling schedule will be specified in the Remedial Action
Groundwater Monitoring Plan for the Yermo Annex. Data will be provided to the
agencies in the Quarterly Groundwater Monitoring Report for the Yermo Annex.
The conclusions and recommendations resulting from this sampling will be
submitted to the agencies in a primary FFA document.
3.7 Statutory Determination
As a lead federal agency, the Marine Corps' primary responsibility at its CERCLA sites
is to undertake remedial actions that achieve adequate protection of human health and
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the environment. In addition, Section 121 of CERCLA established several other
statutory requirements and preferences. These specify that, when complete, the
selected remedial action for this site must comply with applicable or relevant and
appropriate environmental standards as established under federal and state
environmental laws unless a statutory waiver is justified. The selected remedy also
must be cost effective and use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
Finally, the statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal element. The following sections discuss how the selected
remedy meets these statutory requirements.
3.7.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
remediating the contaminant plume through extraction, ex situ treatment and
recharge of treated groundwater back into the aquifer. The selected remedy
protects human health and the environment by eliminating, reducing, and
controlling risk through remediation and institutional controls.
3.7.2 Compliance with ARARs
As stated in Section 2.10, remedial actions performed under CERCLA must
comply with all ARARs. The selected alternative for the Yermo Annex plume
was found to comply with all the ARARs presented in Tables 2-2 through 2-7.
3.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being
considered with their overall effectiveness to determine whether the costs are
proportional to the effectiveness achieved. The Marine Corps evaluates the
incremental cost of each alternative as compared to the increased effectiveness
of the remedy. The selected remedy for groundwater is remediation through
extraction, with ex situ treatment and recharge of treated groundwater back into
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the aquifer. The selected remedy includes groundwater extraction wells at the
Base boundary, at the off-Base MCL boundary, and at the CAOC 26 boundary.
It also includes AS/SVE at CAOC 26 and downgradient of CAOCs 15/17, 16,
and 35 to enhance the pump and treat remediation system.
Based on the information obtained, this selected remedy will provide the best
balance of trade-offs among the alternatives with respect to the nine criteria
provided by EPA to evaluate the alternatives. This remedy is more costly than
the other alternatives considered except Alternative 80. Alternative 8D would
remediate groundwater to background levels; however, it would take almost
double the time and cost of Alternative 8C while only marginally reducing the
human health risk. Alternative 8C is the only alternative projected to remediate
groundwater to MCL in 30 years, making Alternative 8C cost effective.
Therefore, the higher cost is justified and cost effective.
3.7.4 Use of Permanent Solutions to the Maximum Extent Practicable
MCLB Barstow, EPA, DTSC, and CRWQCB believe that the selected remedy is
the most appropriate remedial approach for the Yermo Annex groundwater and
vadose zone and provides the best balance among the evaluation criteria for
the remedial alternatives considered. The AS/SVE enhanced extraction and
treatment remedy for groundwater is a permanent remedy. The selected
remedy will return the groundwater back into the same aquifer, it meets the
statutory requirement to use permanent solutions and treatment technologies to
the maximum extent practicable.
3.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Yermo Annex will be met through
remediation of groundwater by AS/SVE enhanced extraction and treatment of
contaminated groundwater.
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3.8 Documentation of Significant Change
The final remedy for the Yermo Annex plume, Alternative 8C, has not been changed or
refined from the Proposed Plan.
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Table 3-1
Yermo Plum* • On-Base
Maximum Groundwater Concentration* of VOC* and Associated MCL*
'•-•:': I.'.'' •'::... :. ~ ':••• '• .' ' ' •'• . :,(',.' : •• . .•'• V. :. •' " • '• ' ' -f.
' •:•••• .•• • : ,::!::;"••< VOC ••:•• .-:-••: <.::•:. .:' •
Maximum
Oroundwatar
ConoarrtraDon
:(uorU
Federal
MCL
fUO/U
California
MCL
JUQ/L)
PRO*
(MM/I 1
Contaminants Exceeding Drinking Water Standard* (MCLa)
1.1-Dicriloroethene (1,1-OCE)
1 .2-Dfchtoroelhane (Ethytene Dfchlorlde or EDO) (1 .2-DCA)
1.2-Dtehloroetriene. Total
Benzene
Tetraehtoroethene (PCE)
Triohloroethene (TCE)
41
4
1
13
230
310
7
5
70
5
5
5
6
0.5
6
1
5
5
Contaminants Not Exceeding DrinMng Water Standard* (MCLs)
1.1,1-Trfchtoroe«hane
1.1-Olchkxoathane
1.1,2-Trlchk>ro-12.2-TrlfluofDthane (Freon 113)
cte-1,2-D(critoroetheoe (cte-1,2-DCE)
trans- 1 2-Dlchloroethene
2-Bulanone (methyl ethyl ketone)
2-Hexanone
4-M0thyt-2-Pontanone (methyl teobutyl ketone)
Acetone'
Bromoolonloromoth&ne
Bromotorm (Trlbromometnane)
Carbon Oisulfide
Carbon Tetrach bride
Chloroform'
Crikxomethane
Obromochkxomethane
1 ,2-Dlfluoro-l . 1 i,2-T«rachkxoethane (Freon 1 1 2)
1^-Ollluoro-1.12.2-Tetrafluoroetriane (Freon 112)
Methytene Chloride'
Toluene
Trichkxofluoromethane (Freon 11)
Xytene (Total)
2
4
4
35
0.5
19
8
7
11
17
34
0.1
1
1
10
2
2
3
6
130
0.8
200
.
-
70
100
-
.
-
4/Vt
lOU
100
-
OS
IflQ
-
100
&
15C
10000
200
5
1200
6
10
-
.
-
.
-
-
-
150
1750
19QQ
Not available
Jfifl
fllfl
.
a
.L5
-
' This chemical is a suspected laboratory or field contaminant and Is not considered representative of
plume conditions.
Data includes most recent groundwater monloring conducted by OHM Remedtalion Services, Inc. (OHM 1904.1995.1996).
Table 3-2
Yermo Plum* - Off-Base
Maximum Groundwater Concentration* of VOC* and Associated MCL*
VOC
Maximum
Oroundwater
-OofMMiiCrwion
(uarU
Federal
MCL
fuo/L)
California
MCL
Contaminants Exceeding Drinking Water Standards (MCLa)
Tetrachloroathene (PCE)
Trichloroethene (TCB
15
9
Contaminants Not Exceeding Drinking Water Standard* (
1.1-Dichloroethene (1.1-OCE)
1 ,2-Dichloroetnane (1 ,2-DCA)
15-Dichloro«tfiene Total (1.2-DCE, TOTAL)
cts-1.2- Dichtoroethene (cfe-1^ DCE)
Dibromochloromethane
1.1-Dichloroethane (1,1-DCA)
OS
1
6
5
0.3
0.3
5
5
5
5
MCLa)
7
5
70
70
100
-
6
5
6
6
-
5
Data Includes most recent groundwater monloring conducted by OHM RemedUtflon Services. Inc. (OHM 1994.1995.1996).
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Table 3-3
Carcinogenic Toxicity Values for Chemicals of Concern in Groundwater and
Vadose Zone at Yermo Annex
Contaminant
1.1,1-Trichk>roethane
(1,1,1-TCA)
1,1-Dichtoroetnane
(1.1 -DCA)
1,1-Dichtoroethene
(1,1 -DCE)
1 ,2-Dichtoroethane
2-Butanone
Bromoform
Chloroform
Dibromochloromethane
Tetrachloroethene (PCE)
Toluene
Trichtoroethene (TCE)
ingestion
Slope Factor*
(mg/kg-day)
MA
NA
0.6
0.091
NA
0.0079
0.0061
0.084
0.052
NA
0.011
inhalation
Slope Factor*
fmo/kft-dav)
NA
NA
0.18
0.091
NA
0.0039
0.081
0.084
0.002
NA
0.006
Dermal
::V': Slope Factor*; :;;
•'*'-"• (mo/kfl-dayj
NA
NA
0.6
0.091
NA
0.0079
0.0061
0.084
0.052
NA
0.011
mg/kg-day = milligrams per kilogram per day
NA = Not Available
'Source: Integrated Risk Information System (IRIS). 1996.
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Table 3-4
Noncarcinogenlc Toxictty Values for Chemicals of Concern in Groundwater and
Vadose Zone at Yermo Annex
Contaminant
1 ,1 ,1 -Trichloroethane
(1,1.1-TCA)
1,1-Dichloroethane (1,1-
DCA)
1 ,1-Dichloroethene (1,1-
DCE)
1 ,2-Dichtoroethane
2-Butanone
Bromoform
Chloroform
Dibromochloromethane
Tetrachloroethene (PCE)
Toluene
Trichtoroethene (TCE)
fngestion -:£
Reference Dose^
(mo/to-day)
0.09
0.1
0.009
NA
0.6
0.02
0.01
0.02
0.01
0.2
0.006
•:.;.; Inhalation •;
Reference Dose* I-
(mfl/kg-day) '
0.29
0.14
0.009
NA
0.29
0.02
0.01
0.02
0.01
0.11
0.006
Dermal
Reference Dose*
(mg/kfl-dav)
0.09
0.1
0.009
NA
0.6
0.02
0.01
0.02
0.01
0.2
0.006
mg/kg-day = milligrams per kilogram per day
NA = Not Available
'Source: Integrated Risk Information System (IRIS). 1996.
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Table 3-5
Summary of Comparative Analysis - Yermo Plume
MCLB Barstow
Critajfte
Overs! Protection of Human Health and the Environment
Compliance wtth ARARs
Long-Term Effectiveness and Permanence '.
Reduction ol Toricity. Mobility, or Vohm
Short-Tarm Effectiveness
Implemantabilty
Duration ol Remedy
Time to MCLs (years)
Tlrro to Background (years)
>res«>nt Cott ($ mfliiona) 20 Yaart Duration
Remediation to MCLs
Remediation to Background
Alternative*
Y-QW-1
No
•No
Low
Low
Low
High
>500
>500
0
0
0
Y-QW-2
Y-QW-3
Y-QW-4
Y-GW-5
Y-GW-fl
Within Risk Management
•No
Mod
Low
Mod
High
>500
>500
2.0
3.5
3.5
•No
Mod
Mod
High
HWi
*** 190
— 350
9.3
14.1
14.1
Yes
High
H&i
Mod
Low
180
320
20.3
30.1
30.1
Yes
High
Mod
Mod
Mod
160
260
14.7
21.8
21.9
•No
Mod
Mod
High
High
— ISO
"*285
14.8
19.3
19.4
Y-GW-8A
Range**
•No
Mod
Mod
High
High
— 40
— 70
18.3
21.3
232
Y-GW-8B
•No
Mod
Mod
High
Htoh
— 30
"•55
19.8
22.1
26.4
Y-GW-8C
Yea
High
High
Mod
Mod
30
55
242
27.1
32.6
Y-GW-8D
Yos
High
High
Mod
Low
30
55
35.9
40.8
492
r\J
• ARARt achieved over time through natural groundwater attenuation (<500 yean).
" Artamafvw Y-QW-2 trough Y-QW-8D all result In residual risks that fat within EPA'i risk managemBnt range of 104 to 10J. Cleanup to MCLs would result In an upper-bound Incremental risk ol approximately
2i10* (1 x to* without 1,1-DCE) while cleanup to background (0.5 ug
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Table 3-6
Treated Groundwater Discharge Limitations
Lahontan RWQCB Board Order No. 6-93-106
' <-;-'!' " '-'« '• :: •--, ,,; ,' : * -,
'-?*' „" Constituent v >-> * ';
Total Petroleum Hydrocarbons (C2-C46)
Benzene
Toluene
Ethylbenzene
Total Xylenes
Total Lead8
Naphthalene
MTBE
EDB
1.2-DCA
1,1,1-TCA
PCE
TCE
Trans-1.2DCE
Cis-1,2DCE
1.1 -DCE
1,2-DCE
1.1.2-TCA
Vinyl chloride
30-day Median ->•
fltt/y
-------
-------
Model (hows in areal view slice through PCE
contaminated groundwater it approximately
ISO tt below ground surface as el October,
1995. Color v«ri»llon» thow Intensity of PCE
concentration.
Model w» produced utIng LYNX Geoiyslemi
lo conceptualize the eitenl of the PCE plume.
Light blue ind gr»y ireM *re baled on
geosMltlteil ettlmaliona and represent val-
ue* detected below MCL (5 poA).
Color acate ihowt Intensity ol concentration
In mlcrograms per liter (uoAl-
PCE Plume In Groundwalpr
from CAOCs 15/17, 26. 35, and
~ . 573, Yermo
-------
Model thorn *n an»l «tm» «Nct through TCB
conuminjiltd proundwMw it *pprailm*lel;
ISO II. btloo ground turlcci ** ol Oetoocr,
1«9S. Color Mriillont *bo« taUiull; o< TCS
conetnUttlon.
Mod«l WM producvd y«lng ITNX Oeo»yotomo
lo conetptuoUn MM «ii«nl ol ttw TCE pkono.
Ught blu* *nd grty m*» tn bM«d on
g*o*laUitic>l itthMttont end raprcMnl »c4-
w* detected bcto* UCL (S |ioA).
Cater *c*4o thorn* Montlly ol «onc«nlmltan
In mlerogranu p*r Ht»r (|to/L).
MCOU iNomiiRMe G«OUP
iimitt cones lOCisfics BASt
• TCE Plumt In Oroundwelor
horn CAOCt 16/1T, 36.35, and
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4.0 NEBO NORTH PLUME
4.1 Summary of Plume Characteristics
4.1.1 Contaminants of Concern
4.1.1.1 Organics
The results of the groundwater Rl for the Nebo North plume indicated that VOCs
are the primary class of chemicals affecting the groundwater in the northern
Nebo Main Base area. The most prevalent contaminant is the solvent PCE,
which has been detected in six groundwater monitoring wells in the area at
concentrations exceeding federal and state drinking water standards. Table 4-1
shows the maximum concentrations of VOCs detected in groundwater in the
North Nebo area, along with the associated MCLs. Contaminants exceeding
drinking water standards are shown at the top of the table. PCE is the only
contaminant found to exceed its state and federal drinking water standards,
while benzene and 1,2-DCA exceeded the state standard. PCE was detected
at a maximum concentration of 80 ug/L, with benzene and 1,2-DCA detected at
maximum concentrations of 1.2 and 3.0 ug/L, respectively. TCE was the
second most common VOC detected but it did not exceed MCLs.
4.1.1.2 Inorganics
The evaluation of the nature and extent of metal concentrations at the Nebo
Main Base indicates that no metals are present above naturally occurring levels
in groundwater. The Rl concluded that there is no evidence that discharge of
wastes from the Base has resulted in metal concentrations above background
levels in the underlying groundwater in the northern Nebo Main Base area.
4.1.2 VOC Contaminant Sources
VOCs are the only confirmed class of groundwater contaminants in the northern
Nebo North plume area. The areal extent of the VOC plume and location of
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contaminant sources are shown in Figure 4-1. The Nebo North plume appears
to be the result of disposal activities originating as long ago as 1943 when major
industrial operations took place at Warehouse 2 (the Old Repair Facility) and
adjacent buildings. Warehouse 2 was constructed in 1942 and operated as a
repair facility until 1961 when operations were suspended and transferred to
Building 573 in the Yermo Annex. The operations at Warehouse 2 included
engine repair, rebuilding, and testing; and metal parts cleaning, etc., similar to
the present operations at Building 573. The Warehouse 2 building is currently
used as a general warehouse. Residual vadose zone VOC contamination in the
area of Warehouse 2 has been detected at the location of three former UST
sites (SWMU 10.43) identified as Solid Waste Management Units. Other
potential sources have been identified in the northern Nebo Main Base area
under the RCRA Facility Assessment (RFA) program, including SWMUs 10.1,
10.4, 10.5, 10.12, and 10.13. Although an analysis of the available soil data
from these sources indicates they do not pose a threat to groundwater, these
data points are generally from shallow soil samples (0 to 5 feet bgs) and there is
some uncertainty regarding the representativeness of these results for vadose
zone contamination.
4.1.3 Location of Vadose Zone Contamination
VLEACH modeling conducted with the soil data from SWMU 10.43, the three
UST sites at Warehouse 2, indicated that VOCs present in the vadose zone
soils may pose a continuing, long-term source of VOCs to groundwater.
Groundwater contamination by VOCs has been confirmed to exist at this site.
On the basis of these results, Warehouse 2 was included in the FS for
evaluation of vadose zone and groundwater remedial alternatives.
The three USTs were removed in 1992 under the RFA program. The results of
soil samples collected during the removal of the USTs indicated elevated VOC
levels in two of the three UST locations. Other SWMUs in the vicinity of
Warehouse 2 were also found to be contaminated with VOCs; however, the
results of the human health evaluations found no significant health risk.
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4.1.4 kocation of Groundwater Contamination
Groundwater contamination with VOCs was detected in and downgradient of
the source area, Warehouse 2, discussed in Section 4.1.3. Figures 4-2 and 4-3
show the distribution of PCE and TCE in groundwater in the area of the northern
Nebo Main Base plume. These maps, contoured using the Lynx Geosystem,
show the location of the source area and the extent of the dissolved VOC
plume. The Nebo North plume extends approximately 4,000 by 1,500 feet and
appears to be limited to the upper 20 feet of the aquifer.
In addition to the identified PCE and TCE plumes, various low-level VOC
detections have been reported in monitoring wells throughout the Nebo Main
Base. These detections are sporadic and essentially occur over the entire Nebo
Main Base. The results from multiple sampling events between March 1992 to
September 1995 indicate that no discernible plumes exist in these areas. Since
these areas are 1) generally below MCLs and health risk levels, and 2) have no
discernible sources, no further remedial action is necessary for these areas.
4.1.5 Contaminant Migration Routes
The following potential routes of contaminants migration were identified for the
Nebo North plume area:
1) Vadose Zone Contaminant Transport:
a) Vertical transport through the soil by desorption of chemicals
bonded to the surface of the soil particles and percolation of
infiltrated water through the contaminated soil column, and
b) Vertical and horizontal transport of contaminant vapors through
soil pore space from either residual or re-vaporization of material
adsorbed/absorbed onto the soil particles. Vapors can potentially
recontaminate the groundwater or be emitted to the surface.
2) Groundwater Contaminant Transport: Vertical and horizontal transport
of contaminants through the groundwater matrix.
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4.1.5.1 Vadose Zone Contaminant Transport
In general, VOCs have a high vertical mobility in soils. The data gathered from
the Nebo North plume area indicate that VOCs have percolated into the shallow
groundwater, and that PCE is the predominant constituent of groundwater
contamination.
Source leaching modeling was performed using VLEACH 2.0 (Turin 1990) to
assess the future impact to groundwater from vadose zone contaminants in the
northern Nebo Main Base area. The VLEACH results indicate that Warehouse
2 may continue to release contaminants to the groundwater for the next 28
years. However, this is based on a conservative model with limited data.
VLEACH results for other potential contaminant sources in the area indicate no
continuous threat to groundwater.
4.1.5.2 Groundwater Contaminant Transport
As shown in Figure 4-3, the VOC plume extends from Warehouse 2 on the
western side of the Nebo Main Base to the current leading edge of the plume at
the eastern Base perimeter. Based on the hydrogeological characteristics of
the aquifer and the estimated date of which the releases originated (1943),
groundwater modeling indicates that the plume should have migrated about
10,000 feet. However, the plume has remained very stable and has not been
observed to increase its size, volume, or mass over the course of 12 quarterly
sampling events conducted since 1992. Fate and transport modeling data
generated for the site indicate that shallow groundwater (approximately 20 to 30
feet), high fluctuation in water table elevations, and predominantly sandy soil
may be contributing to the natural degradation of this plume. As shown in
Figure 4-3, the plume appears to be contained within the Base boundary. The
nearest known water-supply well is about 3,000 feet downgradient of the
leading edge of the plume.
Groundwater samples from intermediate depth monitoring wells (screened from
40 to 60 feet below the groundwater table), resulted in mostly non-detect
concentrations of VOCs below detection limits throughout the Nebo Main Base.
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A vertical extent of 40 feet was conservatively assumed to be the average depth
of groundwater VOC contamination.
4.2 Summary of Nebo North Plume Risks
The major risk'currently associated with the Nebo North plume is the ingestion of the
contaminated groundwater underlying the affected on-Base area. Actual or threatened
releases of hazardous substances from the Nebo North plume, if not addressed by
implementing the response action selected in this ROD, may present a threat to public
health and the environment.
4.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the
Nebo Main Base have been managed, treated, and disposed of on site
throughout the Base history. By application of screening criteria, the chemicals
detected in the vadose zone and groundwater during the Rl were evaluated for
inclusion as chemicals of potential concern in the risk assessment.
Contaminants of concern identified in groundwater at the northern Nebo Main
Base area are listed in Table 4-1.
4.2.2 Summary of Toxicitv Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for
contaminants of concern in groundwater at the Nebo North plume area are
provided in Tables 3-3 and 3-4, respectively.
4.2.3 Human Health Risk
To evaluate the groundwater at the Nebo North plume under OU 2, the BLRA
used a hypothetical on-Base residential scenario.
The BLRA showed that under this scenario for cancer risk, as many as three
additional persons in 10,000 (3 x 10"*) could develop cancer during their
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lifetimes. Excluding the contribution from naturally occurring background
metals, the incremental cancer index is approximately 1 x 10"4 (one in ten
thousand). The majority of the risk results are from PCE. As discussed in
Section 3.2.3, the exposure assumptions used to estimate the risk are extremely
conservative and tend to overestimate risk.
For noncancer health effects, the hazard index for the Nebo North plume is
estimated to be 2.9, which exceeds the EPA's acceptable criterion of 1.
Approximately 1.4 is attributed to naturally occurring background metals, with
the remainder resulting primarily from PCE.
Hypothetical receptors were also evaluated, assuming exposure at the MCL and
background levels (analytical quantitation limit). At the MCL, the incremental
risk from both PCE and 1,2-DCA was estimated to be approximately 1 x 10"5
(one in one hundred thousand). The corresponding incremental risk at the
background level is approximately 5x10"*. The noncarcinogenic hazard index
is less than 1.0 from both chemicals.
Based on the above results, on-Base groundwater containing VOC
contamination above drinking water standards is a medium of concern for
remedial action. In addition, the subsurface soil is a medium of concern
because of potential cross-media chemical transport from subsurface soil to
groundwater.
4.2.4 Ecological Risk
An ecological risk assessment was independently performed by EPA Region IX
to evaluate potential effects on plants and animals from groundwater
contaminants at MCLB Barstow. An area of potential concern evaluated by the
EPA is the riparian habitat on the northeast comer of the Nebo Main Base.
Groundwater in this area surfaces and pools near the Mojave River, creating the
potential for a complete exposure pathway to ecological receptors. The riparian
habitat was investigated to assess the potential for contaminated groundwater
to have affected this area. However, an evaluation of surface waters and
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associated sediments in this area found that they do not pose an ecological
threat.
4.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make groundwater and vadose zone
cleanup decisions for the Nebo North plume.
4.3.1 Groundwater Cleanup
The areal extent of VOC contamination at the Nebo North plume was
determined during the RI/FS. As discussed in Section 4.1.5, the Nebo North
plume is very stable and does not appear to be increasing in size. In contrast
with the Yermo Annex plume, the MCL and background contour areas for the
Nebo North plume are relatively close together and contained on Base. Site
characterization and fate and transport modeling data generated for the site
support indications that the shallow groundwater, high fluctuation in water table
elevations, and predominantly sandy soil conditions in the northern Nebo Main
Base area may be resulting in the natural degradation of this plume. The
remediation strategy for this plume is to prevent the VOC contamination from
migrating off-Base. Two groundwater cleanup options were considered in the
FS under this remediation strategy.
1) Remediation of groundwater contamination at the MCL boundary by
institutional controls coupled with vadose zone source reduction and
natural contaminant degradation processes. Based on the evidence
that exists in support of plume degradation by natural processes, the
Marine Corps decided to include this process option in the remedial
alternatives evaluated for this plume. Because the RI/FS data collection
program was not designed with natural processes considered as a
possible remedy, the existing data are not sufficient to quantitatively
demonstrate how natural processes are actually occurring. However, 5
years of groundwater sampling since 1992 demonstrate that the plume is
at "steady state" (i.e., plume is not growing and VOC concentrations in
groundwater are stable). The data indicate that the plume is self-
contained. However, source reduction at Warehouse 2 will be
implemented under this strategy to enhance the cost-effective
containment and natural degradation of the plume. There are no
downgradient receptors at risk within 3,000 feet of the leading edge of
the plume.
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2) Containment of groundwater contamination at the MCL boundary by
active extraction and treatment technology. This process option was
evaluated to determine if extraction and treatment is a cost-effective
remedy to prevent plume migration and provide a permanent solution. A
pilot study consisting of eight extraction wells (four in the center of the
plume near the more highly contaminated area, and four at the leading
edge of the plume to provide containment) was conducted to analyze
mass removal rates and evaluate plume behavior. The pilot study
results indicate that the system removed ten times more VOC mass
than was predicted and can effectively remove VOC contamination from
groundwater. The results also support the assessment that the plume is
not migrating. As predicted, most of the VOC contamination was
removed at the upgradient wells. VOC concentrations decrease
significantly by the time they reach the downgradient wells and at least
two of these wells have consistently shown concentrations below
detection limits. Furthermore, there are no obvious upward or downward
trends in mass removal rates or VOC concentrations, which supports
earlier conclusions that the plume has reached a steady state condition.
The pilot study has proven that extraction and treatment can effectively contain
and remove VOC contamination from groundwater and could significantly
shorten cleanup duration. However, existing evidence also supports conclusions
that natural contaminant degradation processes are taking place at an effective
rate (e.g., stable plume) to prevent adverse health effects to potential receptors.
Because extraction and treatment would quadruple the cost of cleanup
compared to natural processes without commensurate benefits in risk reduction
to receptors, the Marine Corps prefers the source reduction and natural
attenuation option. However, based on the uncertainties associated with natural
attenuation at this time (e.g., limited source characterization and
definition/relative contribution of processes at work and rates of reduction), the
Marine Corps has decided to keep the existing extraction and treatment system
in place, fully maintained and on standby for startup as a fail-safe containment
option in case source reduction and natural attenuation fail to effectively contain
the plume. This decision is consistent with the intent of CERCLA and the NCR
that the final remedy be cost-effective and use permanent solutions and
alternative treatment technologies to the maximum extent practicable.
Selection of the appropriate remedial goal for the Nebo North plume was made
based on an evaluation of the technical and economic feasibility of achieving
MCL and background levels, the residual risk remaining in groundwater after
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achieving each deanup goal, and the costs/benefits of incremental risk
reduction. The following summarizes the TEF analysis results and conclusions.
1) Cleanup of contaminated groundwater to MCLs would reduce baseline
risks by 91 percent, resulting in a residual risk of 1 x 10'5. Cleanup to
background levels would reduce baseline risks by 95 percent, resulting
in a residual risk of 5x10"* (an incremental 4 percent reduction over
MCLs). Both cleanup levels are within EPA's risk management range
and are considered protective of human health and the environment.
2) Cleanup of contaminated groundwater to MCLs would remove 75
percent of the total estimated VOC mass, and take from 12 to 45 years
depending on the alternative selected. Cleanup to background levels
would remove 100 percent of the total estimated VOC mass (an
incremental 25 percent mass reduction over MCLs), but would take from
30 to 120 years for the same alternatives (an incremental 150 percent
duration over MCLs).
3) The estimated present worth costs of all alternatives evaluated range
from $1.0 to $5.8 million for cleanup to MCL, versus $1.1 to $7.3 million
for cleanup to background levels, a cost increase of 14 to 30 percent for
background over MCLs.
In summary, remediating to background levels rather than to MCLs would result
in only a minimal incremental difference in risk reduction and mass removal
while increasing cleanup duration by two- to three-fold and cleanup costs by
approximately 20 percent. Based on the proven technical difficulties of restoring
aquifer quality to background levels with existing technology discussed in
Section 3.3, and the fact that both MCLs and background cleanup goals are
considered protective of human health and the environment, the TEF analysis
concluded that cleanup to background levels is technically and economically
impracticable. Therefore, the Marine Corps selected MCLs as the cleanup goal
for the Nebo North plume.
4.3.2 Source Reduction
Vadose zone contamination that may pose a continuing, long-term source of
VOCs to groundwater has been determined to exist in the area around
Warehouse 2, the Old Repair Facility. Continued releases to groundwater from
this area could reduce the effectiveness of the remediation and extend the
duration of cleanup.
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The following cleanup options for the Warehouse 2 area were evaluated in the
FS.
1) Soil excavation. This option is not feasible to remove the residual
contamination in the soil because of the presence of physical
improvements (i.e., buildings, structures) around Warehouse 2.
2) In Situ Vertical AS/SVE. This option involves installing and operating a
full-scale SVE system (four AS and five SVE wells) to provide adequate
coverage of the vadose zone in the area of Warehouse 2. The relatively
sandy soils and shallow groundwater at this site provide ideal conditions
for AS/SVE. Such a system is readily implementable and could
conceivably shorten the remediation time for natural processes to
degrade the groundwater VOC plume by 30 years (from 45 to 15), at an
approximate cost of $700 K.
Based on the FS results, the Marine Corps has determined that source removal
in the northern Nebo Main Base area would be a cost-effective enhancement to
significantly reduce the estimated cleanup duration from 45 to 15 years and
accelerate the natural degradation processes. Therefore, the Marine Corps has
decided to implement source reduction (i.e., AS/SVE) in the northern Nebo
Main Base area as part of the selected final remedy.
Additional vadose zone characterization of Warehouse 2 is needed to delineate
the vadose zone source area sufficiently to design the AS/SVE system. The
characterization will be performed as part of the remedial design for this
remedy.
Vadose Zone Modeling to Determine AS/SVE System "Shut Off'
Performance parameters for vadose zone modeling to support AS/SVE shut off
decisions will be measured in a similar fashion to CAOC 26, using the criteria
described in Sections 2.8.4 to 2.8.6 and 3.3.2.2 of this ROD.
4.4 Description of Remedial Action Alternatives, Nebo North Plume
Five alternatives are presented in this ROD for remediating groundwater and vadose
zone soil in the Nebo Main North plume area. These alternatives are discussed in
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detail in the Draft Final FS for OUs 1 and 2 (Jacobs 1996) and summarized in this
section.
4.4.1 Alternative 1 - No Action
Under this alternative, no further action would be taken to clean up or control
contamination from vadose zone soils or groundwater. The existing site
conditions would not change. No costs are associated with this alternative. The
no action alternative provides a baseline for comparing the other alternatives.
4.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring
with Fall-Safe Extraction and Treatment Containment
This alternative includes implementing institutional controls and initiating a long-
term groundwater monitoring program. This alternative relies on natural
processes such as dispersion, degradation, sorption, and volatilization to reduce
VOC concentrations. Institutional controls will ensure that the affected
groundwater will not be used in the future, thereby maintaining the current lack
of exposure to, and risks from, chemicals in groundwater.
Institutional controls will include restrictions on the use of untreated groundwater
for domestic use and provisions for wellhead treatment of affected water supply
wells within the Nebo North plume area. The institutional controls to restrict
access to contaminated groundwater in this area will be documented in the
Base Master Plan.
This alternative also includes a long-term monitoring program to monitor vadose
zone and groundwater beneath and downgradient of contaminant sources.
Groundwater monitoring involves sampling existing monitoring wells to: 1) fully
understand the relative contribution and rates of reduction of the different
natural processes that have stabilized and are passively remediating the
plume(s); 2) monitor trends in contaminant concentrations; 3) evaluate
remediation progress and contaminant migration patterns; and 4) provide early
warning to turn on the existing fail-safe extraction and treatment system to
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prevent contaminant exposure to potentially affected downgradient users.
Vadose zone monitoring involves sampling of soil vapor probes to 1) monitor
trend in contaminant concentrations and 2) assess the effect of the vadose
zone contaminant on the effectiveness of the selected remedy.
A Post-ROD vadose zone and groundwater Remedial Action Monitoring Plan
for the Nebo North plume remedial action will be prepared under the authority of
this ROD, outlining the monitoring well network, sampling and analytical
methods, sampling frequency and major decision points during monitoring (e.g.,
adding/removing monitoring wells from the network, changing sampling
frequency or analytical parameters, etc.). The Post-ROD Monitoring Plan will be
a primary FFA deliverable to be submitted to the agencies within one year of the
signing of the ROD.
This alternative relies on the natural processes that appear to be occurring on
the Nebo North plume to passively remediate VOC contaminated groundwater
to meet federal and state drinking water standards (MCLs). The effectiveness
of natural degradation processes will be demonstrated through long-term
monitoring.
The cost for Alternative 2 includes approximately $1.22 million in capital costs
(including the cost of the existing pilot pump-and-treat system), and $55,000 in
yearly O&M costs to put in place institutional controls and install and monitor
groundwater monitoring wells, for a total present worth cost of $2.2 million.
Groundwater modeling indicates that it would take this alternative about 45
years for the VOC plume to naturally degrade to levels below drinking water
standards (MCLs). Except for the no action alternative, all alternatives include
institutional controls and long-term groundwater monitoring.
4.4.3 Alternative 3 - Groundwater Removal. Ex Situ Treatment, and
Discharge
This alternative involves operating the existing groundwater pump-and-treat pilot
study system, which includes eight existing extraction wells designed to fully
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capture the portion of the plume above federal and state drinking water
standards (MCLs). The extracted groundwater is passed through an activated
carbon filtration system, which will remove contaminants to meet regulatory
discharge requirements. The treated water is then recharged back into the
aquifer via two percolation ponds downgradient of the contaminant plume. This
system is estimated to extract and treat 300 to 400 gallons per minute (gpm)
from the plume. This alternative would actively remediate VOC-contaminated
groundwater to meet MCLs. The portion of the plume currently above MCLs
represents about 95 percent of the total VOC contamination in the Nebo North
area.
The approximate volume of groundwater requiring remediation is estimated to
be 0.65 billion gallons. The cost of Alternative 3 includes $2.4 million in capital
costs to construct the treatment system (all of which has already been
constructed as part of the extraction and treatment pilot study), and $234,000 in
yearly O&M costs to operate the system. The total present worth cost of this
alternative is estimated at $7.1 million, ($2.4 million of which has already been
spent). Groundwater modeling indicates that it would take this alternative about
42 years to clean up the groundwater to levels below MCLs.
4.4.4 Alternative 4 - Groundwater Removal. Ex Situ Treatment, and
Discharge with Source Reduction (AS/SVE) at Warehouse 2
This alternative combines the pilot study system from Alternative 3 with AS/SVE
at Warehouse 2. This alternative is designed to significantly reduce the time to
clean up the groundwater VOC contamination by removing the contaminants
trapped in the vadose zone soils directly underneath the original source.
Contaminants trapped in the vadose zone can provide a continuous source of
contaminants to groundwater for many years, thus prolonging the cleanup
efforts. This alternative is estimated to reduce the time to clean up the plume to
below MCLs by 30 years, from 42 to 12 years. The cost for Alternative 4
includes $3.2 million in capital costs to construct the treatment system (of which
$2.4 million have already been constructed as part of the pilot study), and
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$345,000 in yearly O&M costs to operate the system, for an estimated total
present worth cost of $5.8 million.
4.4.5 Alternative 5 - Source Reduction (AS/SVE) at Warehouse 2
This alternative is a variation of Alternative 2 and involves adding AS/SVE
source reduction at Warehouse 2 to enhance natural contaminant degradation
processes. This alternative significantly reduces the total time required to
passively remediate the ground water VOC contamination to below MCLs from
45 to 15 years. The cost for Alternative 5 includes capital costs of $773,000 to
construct the AS/SVE system, $1.2 million for the existing pilot pump-and-treat
system, and $166,000 in yearly O&M costs to operate the system and
implement institutional controls for an estimated total present worth cost of $ 3.0
million.
4.5 Summary of Comparative Analysis of Alternatives.
This section summarizes the evaluation of alternatives conducted to determine which
alternative provides the best balance with respect to statutory balancing criteria in
Section 121 of CERCLA and Section 300.430 of NCR. The NCR categorizes the nine
evaluation criteria into three groups as discussed in Section 2.9.
The following analysis summarizes the evaluation of remedial alternatives under these
three categories. Table 4-2 assesses each of the alternatives for achievement of a
specific criterion.
The selected alternative for addressing the groundwater contamination at the Nebo
North plume is Alternative 5 - Source Reduction (AS/SVE) at Warehouse 2 combined
with Institutional Controls/Groundwater Monitoring and fail-safe Extraction and
Treatment Containment. This alternative remediates the contaminant plume through
natural attenuation enhanced by AS/SVE at the source. The groundwater and vadose
zone monitoring program will provide an adequate understanding of these processes
and early warning triggers to start up the existing fail-safe extraction and treatment
system to prevent exposure to potential receptors. The practicality of the proposed
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remedy is supported by the results of the extraction and treatment pilot study recently
completed. Based on the current information, this alternative provides the best balance
of trade-offs among the alternatives with respect to the EPA's nine evaluation criteria.
4.5.1 Threshold Criteria
4.5.1.1 Overall Protection of Human Health and the Environment
The calculated human health risk for all alternatives is within the EPA's risk
management range. However, without institutional controls, the no action
alternative is at the upper bound of the risk range (10"*) and may not provide
adequate protection of human health and the environment if the groundwater
were to be used for domestic use in the future. The institutional controls
alternative provides protection by restricting future use and maintaining a fail-
rate extraction and treatment system. The calculated human health risk for
Alternatives 3, 4, and 5 is well within EPA's target risk range (1 x 10**).
Assuming that institutional controls are effective, all alternatives except the no
action alternative are considered to be protective of human health and the
environment. However, only Alternatives 3, 4, and 5 use active measures to
reduce contamination, reduce the future threat to human health and the
environment, and more quickly remediate to cleanup levels.
4.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at
MCLB Barstow is provided in Section 2.10. All alternatives comply with location-
specific ARARs because no ecological or cultural resources are threatened by
the groundwater contamination. All alternatives also comply with action-specific
ARARs; specifically, state antidegradation ARARs for treated groundwater
discharges, VOC emissions control, and groundwater monitoring requirements.
The Lahontan RWQCB has classified the aquifer underlying the Nebo Main
Base as a potential drinking water source. Based on the natural degradation
processes that appears to be occurring at the site, all other alternatives,
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including the no action and institutional controls alternatives, provide passive or
active remedies that will comply with the chemical-specific federal and state
ARARs for drinking water standards (i.e., MCLs).
4.5.2 Primary Balancing Criteria
4.5.2.1 Long-term Effectiveness and Permanence
All alternatives except Alternative 1 provide moderate to high long-term
effectiveness and permanence in a relatively short time frame (i.e., 12 to 45
years). Institutional controls (Alternative 2) can effectively reduce risk by
restricting the use of untreated groundwater for drinking water and providing
wellhead treatment fail-safe when warranted. Alternative 2 will meet cleanup
levels through natural contaminant degradation processes in approximately
45 years. As mentioned previously, the calculated human health risks are within
the protective range.
4.5.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment
The no action alternative would not reduce toxicity, mobility, or volume through
treatment because it is not a treatment option. All other alternatives would
achieve moderate to high reduction of toxicity, mobility, or volume through
extraction and treatment and AS/SVE remediation, and satisfy the statutory
preference for treatment. Alternative 2 can achieve this criterion through natural
contaminant degradation processes and contingent fail-safe extraction and
treatment.
4.5.2.3 Short-Term Effectiveness
Due to the length of remediation, short-term risks are the same as current risks.
All alternatives, except the no action alternative, rely on institutional controls for
short-term effectiveness of community protection.
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The no action and institutional control alternatives would have the least
immediate harmful effect on human health and the environment, but would also
provide less protection in the short term. The active remediation alternatives
would slightly increase the short-term risk of exposure by pumping groundwater
and handling contaminated soil. However, use of proper worker protection and
safety measures would reduce these risks to safe levels.
4.5.2.4 Implementability
The no action alternative is the easiest to implement because there is nothing to
implement. Imposing institutional controls off-Base will require state, local, and
community involvement.
Extraction and treatment and AS/SVE are proven, commercially available,
readily implementable, and simple to operate technologies. A full-scale
extraction*and treatment system already has been constructed and is operating
at the Nebo North plume. No constructibility issues that could affect installation
of an AS/SVE system at Warehouse 2 have been identified. All alternatives
involve reasonable cleanup durations.
4.5.2.5 Cost Effectiveness
The selected Alternative 5 is the second least costly alternative, not including
the no action alternative. The estimated present worth value for Alternative 5 is
$3.0 million. The estimated present worth value of Alternatives 4 and 2 are $5.8
million and $2.2 million, respectively. The selected alternative will meet the
threshold criteria for protection of human health and the environment, and will
comply with ARARs in about 15 years.
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4.5.3 Modifying Criteria
4.5.3.1 State Acceptance
The California State DISC and RWQCB have reviewed the approved FS and
Proposed Plan, and agree with the selected final remedy for the Nebo North
plume.
4.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed
actions for OUs 1 and 2. These comments are included on Page 27 of the
public meeting transcripts provided in Appendix C, and in Section 6,
"Responsiveness Summary."
4.6 Summary of Selected Remedy For the Nebo North Plume
As required by CERCLA and the NCP, and based on the results of the detailed
analysis of alternatives presented in the FS, MCLB Barstow selected Alternative 5 as
the final remedy to address groundwater and vadose zone contamination at the Nebo
North plume.
For the contaminated vadose zone and groundwater on site, the selected remedy
includes source reduction using an AS/SVE system at Warehouse 2 to enhance
remediation. In the implementation of this remedy, the DON shall perform sufficient
source characterization of the vadose zone to delineate the source at Warehouse 2, by
which to design the AS/SVE system. To ensure that human health and the environment
are protected in the future, institutional controls will be implemented that include access
restrictions to prevent the on-Base use of untreated groundwater for domestic use.
Wellhead treatment will be provided for any existing water supply wells that fall within
the area of the plume exceeding MCLs. The DON will provide necessary information to
•
appropriate county agencies identifying off-Base areas impacted by groundwater
contamination exceeding MCLs. The DON will support county agencies with any
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technical information needed for the county to implement restrictions on construction
and use of wells in the affected areas.
All requirements, procedures and restrictions established in Section 3.6 for
development and implementation of institutional controls, pursuant to Base Master Plan
amendment language, shall apply equally to this section.
Natural attenuation processes and source reduction at Warehouse 2 will be relied upon
to remediate VOC-contaminated soil and groundwater to met the cleanup goals
(performance standards) established in Table 2-1 of this ROD. A sampling protocol will
be developed and incorporated in the Nebo Main Base Remedial Action Groundwater
Monitoring Plan to periodically determine VOC degradation rates and monitor VOC
mass reduction in the vadose zone and groundwater plume to demonstrate the
effectiveness of the selected remedy.
The four downgradient extraction wells from the existing groundwater extraction and
treatment pilot study system will be activated if VOC concentrations in downgradient
monitoring wells exceed MCLs as established in the approved post-ROD groundwater
monitoring plan. The monitoring plan will contain a statistical approach for triggering
activation and deactivation of the system in accordance with US and California EPA
guidance developed for determining statistically significant changes in indicator
parameter values. The regulatory agencies will be notified when the pump and treat
system is activated. The system will extract contaminated groundwater from the aquifer
at a depth of 50 feet, treat it on site through a carbon filtration system, and recharge it
back into the aquifer through two percolation ponds downgradient of the plume. Spent
carbon filters will be taken off site for regeneration and will be reused. Extraction and
treatment of the groundwater will continue until the VOC concentrations in
downgradient monitoring wells no longer exceed MCLs, as established in the approved
groundwater monitoring plan.
The post-ROD monitoring plan, which will be a primary FFA document to be submitted
to the regulatory agencies within one year of the signing of this ROD, will specify the
wells that will be monitored to determine if an MCL has been exceeded, and the
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schedule and procedures for confirming that this excess is statistically significant as
described above.
The selected remedy includes periodic groundwater and vadose zone monitoring to
track changes in the concentrations and extent of contamination. The major
components of the remedy consist of:
• Implementing institutional controls
• Designing and implementing a sampling protocol to monitor and evaluate the
progress of natural processes in achieving performance standards
• Designing and constructing groundwater monitoring wells and SVE wells as
necessary
• Designing, installing and operating an AS/SVE system in the area of
Warehouse 2, and conducting vadose zone monitoring to assess the
effectiveness of the system
• Starting, operating, and shutting down the groundwater extraction and treatment
pilot study system on a contingency basis
• Transporting, regenerating, recycling, and/or disposal of the spent carbon filters
• Operating and maintaining a long-term groundwater monitoring plan, which
includes quarterly, semiannual or annual monitoring of selected COCs in the
monitoring and extraction wells to be specified in a post-ROD OU 2 Remedial
Action Groundwater Monitoring Plan
• Closure criteria.
The groundwater remedy for the Nebo North plume (OU 2) is consistent with the
requirements of Section 121 of CERCLA and the NCP. The remedy will reduce the
mobility, toxicity, and volume of contaminated groundwater at the Nebo North plume.
In addition, the remedy is protective of human hearth and the environment, will attain all
federal and state ARARs, is cost-effective, and uses permanent solutions to the
maximum extent practicable. Based on the information available at this time, the
selected remedy represents the best balance among the criteria used to evaluate
remedies.
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4.6.1 Performance Standards for Groundwater and Source Reduction
Groundwater from the aquifer shall be monitored until the cleanup goals
(performance standards) set forth in Table 2-1 are achieved as agreed upon
between the DON and the regulatory agencies. See Sections 2.8 and 4.3.2 for
discussion of source reduction performance standards.
4.6.2 Infiltration Standards
Treated groundwater that will be recharged back into the aquifer through the
percolation ponds shall comply with the substantive general waste discharge
requirements for land disposal of treated groundwater, set forth in Lahontan
RWQCB Board Order No. 6-93-106 as TBCs. These requirements are listed in
Table 3-6. Meeting these requirements shall ensure compliance with SWRCB
Resolution 68-16 and the Basin Plan ARARs. The general discharge
requirements of Board Order No. 6-93-106 have monitoring requirements that
verify compliance. A schedule of compliance appropriate for this monitoring
shall be established in the OU 2 Nebo Main Base Remedial Action Groundwater
Monitoring Plan.
4.6.3 Groundwater and Vadose Zone Monitoring
Groundwater and vadose zone monitoring shall be conducted for the Nebo
North plume during the remedial action in accordance with the Nebo Main Base
Remedial Action Groundwater Monitoring Plan (see Section 4.4.2) to verify that
the remedial action is being effective towards achieving RAOs. The DON will
monitor the groundwater and vadose zone as specified in the groundwater
monitoring plan until it is demonstrated that the remedial action has effectively
and permanently reduced the VOC contamination to within the RGs set out in
Table 2-1. The criteria for assessing the effectiveness of the remedial action
shall also be included in the remedial action groundwater monitoring plan. If
monitoring indicates that RGs have not been met in accordance with these
criteria, the groundwater and vadose zone remedial action will continue until the
RGs are achieved. The results of the groundwater and vadose zone monitoring
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will be evaluated every five years, and the duration and frequency of the
groundwater monitoring modified as appropriate and with the concurrence of the
FFA signatories, until it is determined that the remedial action has been
completed.
4.7 Statutory Determination
Under its legal authorities, the Marine Corps' primary responsibility at Superfund sites is
to undertake remedial actions that adequately protect human health and the
environment. In addition, Section 121 of CERCLA established several other statutory
requirements and preferences. These specify that, when complete, the selected
remedial action for this site must comply with applicable or relevant and appropriate
environmental standards as established under federal and state environmental laws
unless a statutory waiver is justified. The selected remedy also must be cost effective
and use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the statute includes
a preference for remedies that, as their principal element, employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of hazardous
wastes. The following sections discuss how the selected remedy meets these statutory
requirements.
4.7.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
remediating the contaminant plume through natural processes and AS/SVE
source reduction at the Nebo North plume. The selected remedy provides
protection to human health and the environment by eliminating, reducing, and
controlling risk through source reduction, natural processes and institutional
controls. The contaminated groundwater in the Nebo North plume will be
treated by natural processes to cleanup levels. In addition, institutional controls
and fail-safe extraction and treatment containment will be used if necessary
throughout the remediation process to protect human health and the
environment.
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4.7.2 Compliance with ARARs
As stated in Section 2.10, remedial actions performed under CERCLA must
comply with all ARARs. All alternatives considered for the Nebo North
groundwater plume were evaluated on the basis of the degree to which they
comply with these requirements. The selected alternative was found to comply
with all ARARs presented in Tables 2-2 through 2-7.
4.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being
considered with their overall effectiveness to determine whether the costs are
proportional to the effectiveness achieved. The Marine Corps evaluates the
incremental cost of each alternative as compared to the increased effectiveness
of the remedy. The selected remedy for groundwater and vadose zone is
source reduction, institutional controls, and remediation by natural degradation
processes and through fail-safe pump-and-treat. Based on the information
obtained, this selected remedy will provide the best balance of trade-offs among
the alternatives with respect to the nine criteria provided by the NCR to evaluate
the alternatives. The selected remedy is the second least costly of the
alternatives considered that meets the threshold criteria for protection of human
health and the environment and compliance with ARARs for groundwater
contamination removal.
4.7.4 Use of Permanent Solutions to the Maximum Extent Practicable
MCLB Barstow, EPA, DTSC, and CRWQCB believe that the selected remedy is
the most appropriate remedial approach for Nebo North groundwater and
vadose zone cleanup, and provides the best balance among the evaluation
criteria for the remedial alternatives considered. The source reduction/natural
processes remedy for groundwater and vadose zone is a permanent remedy.
The selected remedy meets the statutory requirement to use permanent
solutions and innovative treatment technologies to the maximum extent
practicable.
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4.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Nebo North plume will be met
through passive treatment of contaminated groundwater by natural processes
and removal of VOCs from the vadose zone by AS/SVE.
4.8 Documentation of Significant Change
The final remedy for Nebo North plume, Alternative 5, has not been changed or refined
from the Proposed Plan.
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Table 4-1
Nebo North Plume
Maximum Groundwater Concentrations of VOCa and Associated MCLs
" : . • --' :* " -•'- •, '
voc*
Maximum
Groundwater
Concentration
G»fl/L)
Federal
MCL
(ug/L)
Contaminants Exceeding Drinking Water Standards
1 ,2-Dichloroethane (1 ,2-DCA)
Benzene
Tettachloroethene (PCE)
3
1.2
80
5.0
5.0
5.0
California
MCL
(MO/L)
(MCLs)
0.5
1.0
5.0
PRO
(Htfr)
;
-
Contaminants Not Exceeding Drinking Water Standards (MCLs)
1,1 -Dion loroethane
1.1.1-TCA
2-Hexanone
1.2-Dichloroethene. Total (1.2- DOE)
2-Butanone (methyl ethyl ketone)
Acetone'
Carbon Disulfide
Chloroform
Chtoromethane*
Methylene Chloride'
Toluene
Trlchloroethene (TCE)
0.7
2
13
2
5
7
3
2
8.9
2
02
4
-
200
70.0
-
-
-
100'
-
5.0
1,000
5.0
5.0
200
6.0
-
-
-
-
-
-
150
5.0
^
Not available
^
1900
610
21
_:
L5
^
^
-
' TNs chemical Is a suspected laboratory contaminant and is not considered representative of plume
conditions.
' MCL is for total trihalomethanes.
Note: Data also include most recent groundwater monitoring conducted
by OHM Remediation Services. Inc. (OHM 1994,1995,1996).
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TABLE 4-2
Summary of Comparative Analysis - Nebo North Plume, NRF-1
MCLB Barstow
Criteria
Overal Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxtetty, Mobilty, or Volume
Short-Teim Effectiveness
Implementabflity
Duration of Remedy
Time to MCLs (years)
Time to Background (years)
Present Cost ($ millions) 20 Years Duration
Remediation to MCLs
Remediation to Background
Alternatives
NRF1-GW-1
No
•No
Low
Low
Low
High
45
120
0
0
0
NRF1-GW-2
NRF1-GW-3
NRF1-GW-4
NRF1-GW-5
Within Risk Management Range**
•No
Mod
Low
Mod
High
45
120
Lft
2^
Z£
Yes
Mod
Mod
Mod
High
42
110
5.3
7.1
7.9
Yes
High
High
High
High
12
30
6.6
5.6
7.3
Yes
High
High
High
High
15
38
?kl
Mi
ro
o>
* ARARs achieved over time only through natural groundwater attenuation.
•• Alternatives NRF1-GW-2 through NRF1-QW-5 all result In residual risks that fan within EPA's risk management range of 10* to 10"*. dean up to MCLs would
result in an upper-bound Incremental risk of approximately 1x10"* while dean up to background (0.5 ug/L) would result In a risk of approximately 5 x 10"".
Alternative NRF1-QW-1: No Action
Alternative NRF1-GW-2: Institutional Controls and Groundwater Monitoring with fall-safe Dumo-and treat
Alternative NRF1-GW-3: Groundwater Removal. Ex Situ Treatment, and Discharge
Alternative NRF1-GW-4: Groundwater Removal. Ex Situ Treatment, and Discharge with Source Reduction
(Air Sparging/Soil Vapor Extraction)
Alternative NRF1 -GW-5: Source Reduction (Air Sparging/Soil Vapor Extraction)
ARARs • Applicable or relevant and appropriate requirements.
Mod - Moderate.
NA- Not applicable.
-------
OPCRABU UNIT :-NC30 UAIN 8»S£
VOC 3LUUE BOUNDARIES
-------
Model (hows an area) view Bile* through PCE
contaminated groundwater at ipproilmalely
40 n. below ground turtieo at NRF-1 and IOC
fl. below ground I urtice il CAOC S ao ol
October, 1995. Color virlaltoni chow (nlonolly
of PCE corwenlritlon.
Model w»s> produced using LVNX Geosyslemg
to conceptualize the eitent of the PCE plume.
light blue ind gray areas »ro bated on
gvovlarlstlcal eallmatlona 0nd represent vol-
ue* detected below MCL (5 ug/L)-
Cnktr tcale show* Intensity ol concentration
In mterograms per tiler (ug/L).
JACOBS INGINKRIN6 GROUP INC
»AS»OfH« t«lirow
con"s\osisr'CS
PCE Plumes In Groundwaler
from NRF-1 and CAOC 6
Nebo Main Bese
-------
Mad»l thowi *n areil view tile* through TCE
contaminated groundwater it appro»lmately
40 ft. below ground surface it NOF-1 and 100
ft. below ground surface al CAOC 6 as of
October. 199S. Color variations ihow Intensity
of TCE concentration.
Model was produced using LYNX Geosyslems
to conceptualize the Client of the TCE plume.
Light blue and gray areas are based on
geostattstlcal estimations and represent val-
ue* detected betow MCL (S ug/l).
Cotor ecato shows Intensity ol concentration
In mtcroOTsms per liter |po/U.
4.000
fini:v'i«;5c TCE Plumes In Groundwaler
wrmimcnii from NRF-1 and CAOC 6
^SSie*.'- Nebo Main Base
»»">•' 'MfjJ "° Oi-f J99 YB flC'jng < i
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5.0 NEBO SOUTH PLUME
5.1 Summary off Plume Characteristics
5.1.1 Contaminants off Concern
5.1.1.1 Organics
The results of the groundwater Rl for Nebo South plume indicate that VOCs are
the primary class of chemicals affecting the groundwater in the southern Nebo
Main Base area. TCE, PCE, and 1,2-DCA have been detected at
concentrations exceeding their federal and/or state drinking water standards.
Other VOCs detected at levels not exceeding federal or state standards include
1,1-DCE, chloroform, bromoform, dibromochloromethane, and
bromodichloromethane.
Table 5-1 shows the maximum concentration of VOCs detected in the Nebo
South groundwater monitoring wells, along with their associated MCLs.
Contaminants exceeding drinking water standards appear at the top of the
table.
TCE appears to be the predominant contaminant in the groundwater at the
Nebo South plume and was detected in all seven wells in the plume area. PCE
was detected in three of the seven wells.
5.1.1.2 Inorganics
The evaluation of the nature and extent of metals concentrations at the Nebo
South plume indicates that metals are not present in the groundwater plume at
levels above the expected naturally occurring concentrations. The Rl concluded
that there is no evidence that discharge of wastes from the Base has resulted in
elevated metals concentrations in the groundwater at the southern Nebo Main
Base area.
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5.1.2 VOC Contaminant Source
VOCs are the only confirmed class of groundwater contaminants in the Nebo
South plume area. The areal extent of the VOC plume and location of
contaminant sources are shown in Figure 4-1. The groundwater contamination
plume at Nebo South plume appears to be the result of historical releases and
disposal practices for solvents at CAOC 6 between 1946 and 1952. Practices
included disposing of waste liquids in revetments at this CAOC. The maximum
concentrations of PCE and TCE detected in groundwater in this area are 17 and
422 ug/L, respectively.
5.1.3 Location of Vadose Zone Contamination
Although VOCs were not detected in soil samples at this CAOC during the Rl,
VLEACH modeling conducted on soil gas data collected from several vertical
profile borings indicated that organic vapors in the vadose zone soils pose a
continuing, long-term source of VOCs to groundwater. Groundwater
contamination by VOCs has been confirmed at this site. The vadose zone at
CAOC 6 has been targeted for remedial action under OU 2 on the basis of
these results. An air sparge/soil vapor extraction (AS/SVE) pilot study is being
conducted at CAOC 6 to evaluate the feasibility of this technology and to help
select the most practical and cost-effective remedial alternative for the Nebo
South VOC plume.
5.1.4 Location of Groundwater Contamination
VOCs were detected in groundwater at and downgradient of CAOC 6 as
discussed in Section 5.1.3. Figures 4-2 and 4-3 show the distribution of PCE
and TCE in groundwater in the area of the Nebo South plume. These maps,
contoured using Lynx Geosystem, show the location of the source area and the
extent of the dissolved VOC plume. The areal extent of the plume is
approximately 1,000 by 800 feet, and appears to be limited to the upper 40 feet
of the aquifer. The groundwater contaminant plume has migrated off Base;
however, the data suggest that the plume has not moved far off Base. The
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leading edge of the plume extends downgradient approximately 600 feet from
the Base boundary. In 1992, ICE concentrations above the MCL were found in
a private resident's well. The Base conducted a time-critical removal action to
remove the well from service and connect the residence to the Base water
supply system.
5.1.5 Contaminant Migration Routes
Two potential routes of contaminant migration were identified for the Nebo
South plume.
1) Vadose zone contaminant transport:
a) Vertical transport through the soil by desorption of chemicals bonded to
the surface of soil particles and percolation of infiltrated water through
the contaminated soil column.
b) Vertical and horizontal transport of contaminant vapors through soil pore
space from either residual or re-vaporization of material
adsorbed/absorbed onto the soil particles. Vapors can potentially
recontaminate the groundwater or be emitted to the surface.
2) Groundwater contaminant transport: Vertical and horizontal transport of
contaminants through the groundwater matrix.
5.1.5.1 Vadose Zone Contaminant Transport
In general, VOCs have a high vertical mobility in soils and can percolate into the
groundwater. The data gathered from the Nebo South plume area indicate that
VOCs have percolated into the groundwater and that TCE and PCE are the
predominant constituents of groundwater contamination.
Soil gas data collected during installation of the pilot study AS/SVE system
(OHM 1995b) was also used for the VLEACH modeling analysis. The results
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indicated that the maximum concentration of TCE (5.6 ug/L), which was slightly
above the MCL (5 pg/L), would reach groundwater in 1 year.
5.1.5.2 Groundwater Contaminant Transport
As shown in Figure 4-1, the Nebo South plume is restricted to the general
CAOC 6 area. The plume area is estimated at 800 by 1,000 feet. The
longitudinal transport of TCE extends 600 feet downgradient of the Base
boundary. The plume appears to have limited longitudinal and lateral migration.
This limited migration appears to be the result of relatively tight soils that slow
the contaminant migration and inhibit groundwater flow in this area.
Groundwater samples from intermediate-depth monitoring wells (screened from
40 to 60 feet below the groundwater table) resulted in mostly concentrations of
VOCs below detection limits through the Nebo Main Base. A vertical extent of
40 feet was conservatively assumed to be the average depth of groundwater
VOC contamination at the Nebo South plume.
5.2 Summary of Nebo South Plume Risks
The major risk currently associated with the Nebo South plume is the ingestion of the
contaminated groundwater underlying the affected on- and off-Base areas. Actual or
threatened releases of hazardous substances from the Nebo South plume, if not
addressed by implementing the response action selected in the ROD, may present a
threat to public health and the environment.
5.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the
Nebo Main Base have been managed, treated, and disposed of on site
throughout the Base history. By applying screening criteria, the chemicals
detected in the vadose zone and groundwater during the Rl were evaluated for
inclusion as chemicals of potential concern in the risk assessment.
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Contaminants of concern identified in groundwater at the Nebo Main Base are
listed in Table 5-1.
5.2.2 Summary of Toxicitv Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for
contaminants of concern in groundwater at the Nebo South plume area are
provided in Tables 3-3 and 3-4, respectively.
5.2.3 Human Health Risk
For groundwater at Nebo South plume under OU 2, the BLRA evaluated future
hypothetical residential scenario.
The BLRA showed that under this scenario for cancer risk, as many as 10
persons in 10,000 (1 x 10'3) have the potential to develop cancer during their
lifetimes. Excluding the contribution from naturally occurring metals and
laboratory contaminants, the incremental cancer risk is approximately 4x10"*.
The primary contributor to this risk is TCE.
These estimates were developed by taking into account the conservative
assumptions about the likelihood of a person being exposed to groundwater
contamination (see Section 2.7.2). The estimate is above the EPA's target risk
management range of 10"* to 10*.
Evaluations were also performed for hypothetical receptors assuming exposure
at the MCL and background levels (analytical quantitation limit). At the MCL, the
incremental risk from both PCE and TCE was estimated to be approximately
1 x 10'5. The corresponding incremental risk at the background level is
approximately 5 x 10"6. The noncarcinogenic hazard index is less than 1.0 for
both chemicals.
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5.2.4 Ecological Risk
EPA Region IX independently conducted an ecological risk assessment to
evaluate potential effects on plants and animals from groundwater contaminants
at MCLB Barstow. At Nebo South, the groundwater in most areas is found at
depths greater than 100 feet bgs and no surface water exists. Exposure of
potential ecological receptors to VOCs in groundwater is unlikely because
groundwater does not discharge to local surface water and is therefore not
accessible to plants and animals. Thus there is no complete exposure pathway
to impact ecological receptors at Nebo South.
5.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make groundwater and vadose zone
cleanup decisions for the Nebo South plume.
5.3.1 Groundwater Cleanup
The extent of groundwater VOC contamination at the Nebo South plume was
determined during the RI/FS. As discussed in Section 5.1.4, the Nebo South
plume is located in a relatively deep aquifer (about 180 feet) characterized by
fine-grained soil conditions that significantly inhibit plume movement. Site
characterization and fate and transport modeling data generated for the site
indicates that this plume is moving very slowly and will continue to migrate
indefinitely unless it is contained. The plume has already migrated off Base
about 600 feet east of the Base boundary. Due to the site conditions, this plume
is not likely to degrade by natural processes to concentrations below MCLs for
over 500 years. As with the Nebo North plume, the MCL and background
contour areas for the Nebo South plume are very dose together (within 300
feet).
Based on site conditions, the containment strategy selected for this plume is to
prevent any further migration of the VOC contamination at the leading edge of
the plume, which contains both the MCLs and background boundaries. This
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strategy captures 100 percent of the total VOC mass estimated to exist in the
aquifer. Two groundwater cleanup options were considered in the FS under this
containment strategy.
1) Containment of groundwater contamination at the leading edge of the VOC
plume by active extraction and treatment. This process option was evaluated
to determine if extraction and treatment is a cost-effective remedy to prevent
further plume migration and provide a permanent solution. Due to the
significant limitations posed on extraction and treatment technology by the
extremely low permeability of the aquifer (i.e., maximum well yields of 5
gpm), a limited containment system was determined to be more cost-
effective than a more aggressive full-scale system.
2) Removal of VOC contaminant source by AS/SVE at CAOC 6. This process
option was evaluated to determine if AS/SVE is a cost-effective remedy to
remove VOC contamination from the vadose zone and groundwater in the
source area and reduce the time required to cleanup the aquifer with the
extraction and treatment containment system. A pilot study consisting of two
nested sets of two air sparging wells (one shallow and one deep) and six
vapor extraction wells was conducted to analyze the effectiveness of
AS/SVE in removing VOC mass from the vadose zone and groundwater.
The pilot study yielded inconclusive results. Average radius of influence,
mass removal rates, vacuum levels and flow rates for both AS and SVE
wells were greater than expected, suggesting that coverage of the entire site
could be achieved with about half as many wells as originally anticipated.
However, the results also indicate significant variability from well to well for
some of the parameters, suggesting that localized subsurface conditions
could significantly affect the performance of a full-scale system. In addition,
many data gaps in the study make it difficult to fully assess the results.
Because of the inconclusive results of the AS/SVE pilot study so far, the Marine
Corps has decided to select the plume containment option as an interim
remedy at this time. The Marine Corps believes this interim remedy is
necessary to contain the plume while continuing the pilot study to obtain more
conclusive data to characterize the source area and assess the effectiveness of
AS/SVE to reduce remediation costs.
The Marine Corps anticipates that the results of the pilot study will provide data
that will allow for a more accurate determination of the source area and overall
cleanup time using the AS/SVE alternative. If it is determined that AS/SVE is
not the best alternative for remediation, the Marine Corps will recommend a
future course of action in the primary FFA deliverable. The Marine Corps feels
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that the selected interim remedy is the best option at this time, since it is fully
protective of human health and the environment, prevents downgradient
migration, and is cost effective.
The appropriate groundwater cleanup goal for the Nebo South plume was
selected based on an evaluation of the technical and economic feasibility of
achieving MCL and background levels, the residual risk remaining in
groundwater after achieving each cleanup goal, and the costs/benefits of
incremental risk reduction. The following summarizes the TEF analysis results
and conclusions.
• Cleanup of contaminated groundwater to MCLs would reduce baseline
risks by 98 percent resulting in a residual risk of 1 x 10"5. Cleanup to
background levels would reduce baseline risks by 99 percent, resulting
in a residual risk of 5x10"* (an incremental 1 percent reduction over
MCLs). Both cleanup levels are within EPA's risk management range
and are considered protective of human health and the environment.
• Cleanup of contaminated groundwater to MCLs would remove 93
percent of the total estimated VOC mass, and take from 55 to over 500
years depending on the alternative selected. Cleanup to background
levels would remove 100 percent of the total estimated VOC mass (an
incremental 7 percent mass reduction over MCLs), and would take from
130 to over 500 years for the same alternatives (an incremental 130
percent duration over MCLs).
• The estimated present worth costs of all alternatives evaluated range
from $1.3 to 15.1 million for cleanup to MCLs, versus $1.3 to 16.2 million
for cleanup to background levels, a cost increase of 1 to 5 percent for
background over MCLs.
Hydrogeological conditions in the Nebo South plume may pose significant
limitations to aquifer remediation due to the very low permeability of the aquifer.
These conditions can make cleanup of contaminated groundwater extremely
difficult and very unlikely to achieve either MCLs or background levels within a
reasonable time. Although the incremental costs of remediating to background
levels versus MCLs do not appear significant, this is largely due to the masking
effects of present worth analysis caused by the extremely long durations of the
remedial alternatives (the shortest time to achieve background is 130 years).
Cleaning up to background instead of to MCLs would result in only a minimal
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incremental difference in risk reduction and mass removal while increasing
cleanup duration by two- to three-fold. Based on the above rationale and the
fact that both MCLs and background cleanup goals are considered protective of
human health and the environment, the TEF analysis concluded that cleanup to
background levels is technically and economically infeasible. The Marine Corps
therefore selected MCLs as the cleanup goal for the Nebo South VOC plume.
5.3.2 Source Reduction
Vadose zone contamination that may pose a continuing, long-term source of
VOCs to groundwater has been determined to exist at CAOC 6. Continued
releases to groundwater from this area could potentially reduce the
effectiveness of remediation and extend the duration of cleanup.
The following cleanup options were evaluated for the CAOC 6 area in the FS:
1) Soil excavation: This option is not feasible to remove the residual
contamination in the soil because of the depth of the contamination (180
feet to groundwater) at CAOC 6.
2) In Situ Vertical AS/SVE: This option involves installing and operating a full-
scale AS/SVE system to provide adequate coverage of the vadose zone
and groundwater in the source area of CAOC 6. As discussed previously,
the initial results of the pilot study were inconclusive regarding whether
AS/SVE could effectively remove VOCs from the source area and reduce
the remediation time for the Nebo South plume. Therefore, the Marine
Corps has decided to continue to operate the pilot study until conclusive
results can be obtained.
5.4 Description of Alternatives
Five alternatives are presented in this ROD for remediation of groundwater and vadose
zone soil in the Nebo South plume area. These alternatives are discussed in detail in
the Draft Final FS for OUs 1 and 2 (Jacobs 1996a) and are summarized in this section.
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5.4.1 Alternative 1 - No Action
Under this alternative, MCLB Barstow would not take any action to dean up or
control contamination from vadose zone soils or groundwater. Existing site
conditions would not change. No costs are associated with this alternative. The
no action alternative provides a baseline for comparing the other alternatives.
5.4.2 Alternative 2 -Institutional Controls/Groundwater Monitoring
This alternative includes implementing institutional controls and initiating a long-
term groundwater monitoring program. This alternative relies on natural
processes such as dispersion, degradation, sorption, and volatilization to reduce
VOC concentrations, institutional controls will ensure that the affected
groundwater will not be used in the future, thereby maintaining the current lack
of exposure to, and risks from, chemicals in the groundwater.
Institutional controls include restrictions on the use of untreated groundwater for
drinking water, and provisions for wellhead treatment of affected water supply
wells within the Nebo Main Base South plume area. The institutional controls to
restrict access to contaminated groundwater in this area will be documented in
the Base Master Plan.
This alternative also includes a long-term program to monitor vadose zone and
groundwater beneath and downgradient of contaminant sources. Groundwater
monitoring involves sampling existing monitoring wells to: 1) monitor trends in
contaminant concentrations; 2) evaluate remediation progress and contaminant
patterns; and 3) provide early warning to prevent contaminant exposure to
potentially affected downgradient users. Vadose zone monitoring involves
sampling of soil vapor probes to 1) monitor trend in contaminant concentrations
and 2) assess the effect of the vadose zone contamination on the effectiveness
of the selected remedy.
A post-ROO vadose zone and groundwater monitoring plan for the Nebo South
plume remedial action will be prepared under the authority of this ROD, outlining
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the monitoring well network, sampling and analytical methods, sampling
frequency, and major decision points during monitoring (e.g., adding/removing
monitoring wells from the network, changing sampling frequency of analytical
parameters, etc.).
The cost for Alternative 2 includes approximately $90,000 in capital costs and
$55,000 in yearly O&M costs to put in place institutional controls and install and
monitor groundwater monitoring wells, for a total present worth cost of $1.3
million. Groundwater modeling indicates that minimal natural processes are at
work and that it would take this alternative over 500 years to degrade the
groundwater contamination to levels below drinking water standards. Except for
the no action alternative, all of the alternatives include institutional controls and
long-term groundwater monitoring.
5.4.3 Alternative 3 - Vadose Zone Source Reduction (AS/SVE at
CAOC 6)
This alternative involves operating the existing AS/SVE pilot study system. This
pilot-scale system does not prevent plume migration and will only remove VOCs
from vadose zone soils and groundwater within a limited portion of the plume.
This alternative is intended to reduce the time to dean up the groundwater VOC
contamination by removing contaminants trapped in the vadose zone soil and
groundwater underneath the source.
The cost for Alternative 3 includes $738,000 in capital costs to construct the
treatment system, (all of which has already been constructed as part of the pilot
study), and $110,000 in yearly O&M costs to operate the system. The total
present worth cost of this alternative is estimated at $3.3 million, of which $1
million has been incurred in the pilot study. Groundwater modeling indicates
that it would take this alternative over 500 years to degrade the groundwater
contamination to levels below drinking water standards.
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5.4.4 Alternative 4 - Groundwater Removal (Extraction Wells at
MCL/Background Boundary). Source Reduction at CAOC 6. Ex
Situ Treatment and Discharge
This alternative builds upon Alternative 3 by: 1) expanding the existing pilot
scale AS/SVE system to a full-scale AS/SVE treatment system to address
source removal at CAOC 6; and 2) adding a groundwater extraction and
treatment system to contain the leading edge of the plume.
The full-scale AS/SVE system would consist of ten nested sets of air sparge
wells, each containing a shallow and a deep well, and 30 soil vapor extraction
wells designed to collect the VOC gases released from the air sparging wells
and remove vadose zone contamination that may be acting as a source of
groundwater contamination.
The extraction and treatment system would consist of five groundwater
extraction wells spaced about 200 feet apart, and screened as deep as 60 feet
below the groundwater table to capture the deepest contamination. The
extracted groundwater would pass through activated carbon treatment and be
pumped via a pipeline to the percolation ponds used by the Nebo North plume
treatment system to recharge the groundwater. This system would only extract
groundwater at an estimated rate of about 25 gpm (5 gpm per well) due to the
very tight soil formation at this site.
Should AS/SVE be determined to be technically and economically feasible at
the conclusion of the pilot study, this alternative would considerably reduce the
total time to meet MCLs (from 500 to 55 years). The cost for Alternative 4
includes $3.3 million in capital costs to construct the treatment system (of which
$1 million has already been constructed as part of the pilot study) and $598,000
in yearly O&M costs to operate the system. The total present worth cost of this
alternative is estimated at $15.1 million.
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5.4.5 Alternative 5 - Groundwater Containment and Removal
(Extraction Wells at MCL). Ex Situ Treatment, and Discharge
This alternative provides an intermediate option between Alternatives 3 and 4.
Alternative 5 consists of the five groundwater extraction wells system in
Alternative 4 to contain and extract the groundwater at the leading edge of the
plume. The extracted groundwater would be treated with activated carbon and
then pumped to the percolation ponds to recharge the groundwater. This
alternative evaluates the option of cleaning up the VOCs contaminated
groundwater to meet federal and state drinking water standards without having
to address the source. This alternative is estimated to meet MCLs in
approximately 105 years.
The cost for Alternative 5 includes $892,000 in capital costs and $205,000 in
yearly O&M costs to construct and operate the treatment system, for an
estimated total present worth cost of $5.5 million.
5.5 Summary of Comparative Analysis of Alternatives
This section summarizes the evaluation of alternatives conducted to determine which
alternative provides the best balance with respect to statutory balancing criteria in
Section 121 of CERCLA and Section 300.430 of NCR. The NCR categorizes the nine
evaluation criteria into three groups, as discussed in Section 2.9. The following
analysis summarizes the evaluation of remedial alternatives under the three categories.
Table 5-2 compares the alternatives for achievement of a specific criterion.
The selected alternative for addressing the groundwater contamination at the Nebo
Main South is Alternative 5: Groundwater Containment and Removal (Extraction Wells
at the MCL/Background Boundary). This alternative was selected as an interim
remedy. Based oh current information, the Marine Corps believes plume containment
(Alternative 5) is a necessary interim action to stop any further plume migration. The
agencies agree with this conclusion and concur with the Marine Corps decision to
continue to run the pilot study for a longer duration until useable data are obtained to
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fully characterize the source area and assess the effectiveness of AS/SVE to shorten
cleanup times and reduce overall treatment costs.
5.5.1 Threshold Criteria
5.5.1.1 Overall Protection of Human Health and the Environment
The no action alternative does not adequately protect human health and the
environment if the groundwater were to be used as drinking water in the future.
The institutional controls alternative (Alternative 2) provides protection by
restricting future use. The calculated human health risk for Alternatives 3, 4,
and 5 is within EPA's target risk range. Assuming that institutional controls are
effective, particularly in off-Base areas, all alternatives except the no action
alternative are considered to be protective of human health and the
environment. However, only Alternatives 3, 4, and 5 use active measures to
significantly reduce contamination, the future threat to human health and the
environment, and more quickly remediate to cleanup levels.
5.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at
MCLB Barstow is provided in Section 2.10. All alternatives comply with location-
specific ARARs if the existing tortoise protection measures are followed for
alternatives requiring active remediation. No natural or cultural resources are
threatened by the groundwater contamination. All alternatives also comply with
action-specific ARARs; specifically, state antidegradation ARARs for treated
groundwater discharges, VOC emissions control, and groundwater monitoring
requirements. Only Alternatives 4 and 5 comply with chemical-specific federal
and state ARARs drinking water standards (i.e., MCLs).
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5.5.2 Primary Balancinq Criteria
5.5.2.1 Long-Term Effectiveness and Permanence
All alternatives except Alternative 1 provide moderate to high long-term
effectiveness and permanence. However, Alternatives 2 and 3 require a very
long time to achieve remedial goals (over 500 years). Institutional controls can
effectively reduce risk by restricting the use of untreated groundwater for
drinking water and providing wellhead treatment when warranted. Alternative 5
can significantly reduce the remediation time over Alternatives 2 and 3 from 500
to 105 years.
5.5.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
The no action and institutional control alternatives would not reduce toxicity,
mobility, or volume through treatment because they are not treatment options.
Alternative 3 would not comply with this criterion because it only provides active
AS/SVE treatment within a limited portion of the plume. Only Alternatives 4 and
5 achieve moderate to high reduction of toxicity, mobility, or volume through
active extraction and treatment and/or AS/SVE remediation and satisfy the
statutory preference for treatment. Alternatives 1, 2, and 3 reduce toxicity,
mobility, and volume through natural degradation of the contaminants over a
long time.
5.5.2.3 Short-Term Effectiveness
Due to the length of remediation, short-term risks are the same as current risks.
All alternatives except the no action alternative rely on institutional controls for
short-term effectiveness of community protection. Such controls are more
effective on-Base. If off-Base controls were not maintained, short-term
effectiveness would be compromised.
The no action and institutional control alternatives would have the least
immediate harmful effect on human health and the environment, but would also
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provide less protection in the short term. The active remediation alternatives
would slightly increase the short-term risk of exposure by pumping and handling
of contaminated groundwater and soil. However, use of proper worker
protection and safety measures would reduce these risks to safe levels.
5.5.2.4 Implementability
The no action alternative is the easiest to implement because there is nothing to
implement. Imposing institutional controls off Base will require state, local, and
community involvement.
Extraction and treatment and AS/SVE are proven, commercially available,
readily implementable, and simple-to-operate technologies. No problems are
expected during installation of on-Base extraction wells and treatment systems.
Construction of off-Base extraction wells will require gaining access through
coordination with private land owners and local officials. Alternatives 2 and 3
involve very long cleanup duration.
5.5.2.5 Cost Effectiveness
The selected Interim alternative (Alternative 5) is the second most costly, with an
estimated present worth value of $5.5 million, exceeded only by Alternative 4,
with a present worth of $15.1 million. Alternative 5 costs more than Alternatives
1,2, and 3, but is the least costly groundwater remedy that meets the threshold
criteria for protection of human hearth and the environment. Furthermore, it
significantly reduces cleanup time Therefore, the higher cost of Alternative 5 is
justifiable.
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5.5.3 Modifying Criteria
5.5.3.1 State Acceptance
The California State DTSC and RWQCB have reviewed the approved FS and
Proposed Plan, and agree with the selected interim remedy for the Nebo South
plume.
5.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed
actions for OUs 1 and 2. These comments are included on Page 27 of the
public meeting transcripts provided in Appendix C and in Section 6.0,
"Responsiveness Summary."
5.6 Summary of Selected Interim Remedy For the Nebo South Plume
As required by CERCLA and the NCP, and based on the results of the detailed
analysis of alternatives presented previously, MCLB Barstow selected Alternative 5 as
an interim remedy to address groundwater and vadose zone contamination at the Nebo
South plume.
The selected remedy is an interim remedy consisting of containment and removal of the
groundwater contaminant plume from the aquifer, followed by ex situ treatment and
recharge of treated groundwater back into the aquifer. Five extraction wells will be
arranged to contain the entire plume originating from CAOC 6. The actual locations,
sizing, and pumping rates for the wells will be determined by evaluating the results of
pump tests to be conducted as part of the remedial design phase.
Based on current information, the DON believes this interim remedy is a necessary
containment measure designed to stop any further migration of the VOC plume and
prevent the contamination from impacting unaffected waters of the state. The DON
has decided to implement this interim remedy while continuing to operate the AS/SVE
pilot study at CAOC 6 to obtain the data needed to assess the effectiveness of
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AS/SVE. The agencies agree with the above conclusions and concur with the DON'S
decision.
The results of the pilot study will be incorporated into an FFA primary document
deliverable to be submitted to the agencies as established in Section 2.8.12 of this
interim ROD.
To ensure that human health and the environment are protected in the future,
institutional controls will be implemented that include access restrictions to prevent the
on-Base use of untreated groundwater for domestic use. Wellhead treatment will be
provided for any existing water supply wells that fall within the area of the plume
exceeding MCLs. The DON will provide necessary information to appropriate county
agencies identifying off Base areas impacted by groundwater contamination exceeding
MCLs. The DON will support county agencies with any technical information needed for
the county to implement restrictions on construction and use of wells in the affected
areas.
All requirements, procedures, and restrictions established in Section 3.6 for
development and implementation of institutional controls, pursuant to Base Master Plan
amendment language shall apply equally to this section. The major components of the
selected remedy consist of:
• Implementing institutional controls
• Designing and constructing of groundwater extraction and monitoring wells
• Designing and installing a groundwater pumping and monitoring system and a
treatment system (the percolation ponds already exist)
• Starting and operating this system
• Transporting, regenerating, recycling, and/or disposal of the spent carbon filters
• Operating and maintaining a long-term groundwater monitoring program, which
includes quarterly, semiannual, or annual monitoring of selected COCs in
extraction and monitoring wells to be specified In the post-ROD OU 2 Remedial
Action Groundwater Monitoring Plan.
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The interim groundwater remedy for the Nebo South plume (OU 2) is consistent with
the requirements of Section 121 of CERCLA and the NCR. The interim remedy will
reduce the mobility, toxicity, and volume of contaminated groundwater at the Nebo
South plume.. The interim remedy for the Nebo South plume is consistent with
previous and projected removal actions at the site. Based on the information available
at this time, the selected remedy represents the best balance among the criteria used
to evaluate remedies.
The DON believes that the selected interim remedy is the best option at this time, since
it is fully protective of human health and the environment, prevents downgradient
migration of the contaminant plume, and is cost-effective. Because the selected interim
remedy is not a final remedy, a Proposed Plan and ROD for this plume will be provided
at a later date when a final remedy is decided. The Proposed Plan and ROD would be
required to go through public participation and agency approval pursuant to
CERCLA/NCP and the FFA.
5.6.1 Performance Standards for Groundwater
Groundwater from the aquifer shall be monitored until the cleanup goals
(performance standards) set forth in Table 2-1 are achieved, as agreed upon
between the DON and the regulatory agencies. See Sections 2.8 and 5.3.2 for
discussion of source reduction performance standards.
5.6.2 Infiltration Standards
Treated groundwater that will be recharged back into the aquifer through the
percolation ponds shall comply with the substantive general waste discharge
requirements for land disposal of treated groundwater, set forth in Lahontan
RWQCB Board Order No. 6-93-106 as TBCs. These requirements are listed in
Table 3-6. Meeting these requirements shall ensure compliance with SWRCB
Resolution 68-16 and the Basin Plan ARARs. The general discharge
requirements of Board Order No. 6-93-106 have monitoring requirements that
verify compliance. A schedule of compliance appropriate for the purpose of this
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monitoring shall be established in the OU 2 Nebo Main Base Remedial Action
Groundwater Monitoring Plan.
5.6.3 Groundwater and Vadose Zone Monitoring
Groundwater monitoring shall be conducted for the Nebo South plume during
the interim remedial action in accordance with the Nebo Main Base Remedial
Action Groundwater Monitoring Plan (see Section 5.4.2) to verify that the
remedial action is effectively achieving the interim plume containment goal.
The criteria for assessing the effectiveness of the interim remedial action shall
also be included in the groundwater monitoring plan. Criteria for long-term
groundwater and vadose zone monitoring will be incorporated into the plan
when the final remedy is selected.
5.7 Statutory Determination
As a lead federal agency, the Marine Corps' primary responsibility at its CERCLA sites
is to undertake remedial actions that adequately protect human health and the
environment. In addition, Section 121 of CERCLA established several other statutory
requirements and preferences. These specify that, when complete, the selected
remedial action for this site must comply with applicable or relevant and appropriate
environmental standards as established under federal and state environmental laws
unless a statutory waiver is justified. The selected remedy also must be cost effective
and use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment that permanently and significantly
reduce the volume, toxidty, or mobility of hazardous wastes as their principal element.
The following sections discuss how the selected interim remedy meets these statutory
requirements.
5.7.1 Protection of Human Health and the Environment
The selected interim remedy, Alternative 5, protects human health and the
environment by containing contaminated groundwater at the Nebo South plume.
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The selected interim remedy provides protection to human health and the
environment by eliminating, reducing, and controlling risk through containment
and institutional controls. The contaminated groundwater will be extracted,
contained, and treated to cleanup levels. In addition, institutional controls will
be employed throughout the treatment process to protect human health and the
environment.
5.7.2 Compliance with ARARs
As stated in Section 2.10, remedial action performed under CERCLA must
comply with all ARARs. All alternatives considered for the Nebo South
groundwater plume were evaluated on the basis of the degree to which they
comply with these requirements. The selected interim remedy was found to
comply with all ARARs presented in Tables 2-2 through 2-7.
5.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being
considered with their overall effectiveness to determine whether the costs are
proportional to the effectiveness achieved. The Marine Corps evaluates the
incremental cost of each alternative as compared to the increased effectiveness
of the remedy. The selected interim remedy for groundwater is containment,
extraction, and aboveground treatment for VOC removal and discharge of
treated groundwater back into the aquifer via the percolation ponds. The
selected interim remedy includes extraction wells at the leading edge of the
plume and institutional controls.
Based on the current information, the selected interim remedy will provide the
best balance of trade-offs among the alternatives with respect to the nine
criteria provided by the NCP to evaluate the alternatives. The selected interim
remedy is more costly than the other alternatives considered except
Alternative 4.
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5.7.4 Use of Permanent Solutions to the Maximum Extent Practicable
The DON, EPA, DTSC, and CRWQCB believe that the selected interim remedy
is the most appropriate interim solution for the Nebo South groundwater plume
at the present time, and provides the best balance among the evaluation criteria
for the remedial alternatives considered.
5.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Nebo South plume will be met
through treatment of contaminated groundwater to remove the VOCs.
5.8 Documentation of Significant Change
The permanent (i.e., pump and treat) portion of the interim remedy for the Nebo South
plume, Alternative 5, has not been changed or refined from the Proposed Plan.
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Table 5-1
Nebo South Plume
Maximum Groundwater Concentrations of VOCs and Associated MCLs
voc
Maximum
Gnxtndwater
%*onc6ntwiofi
(Wfc)
Federal MCL
&I0/L}
CkHfamJaMCJ.
torn OHM R»m«laUon S«vtow, Inc. (OHM 1994,1995,1996).
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TABLE 5-2
Summary of Comparative Analysis - Southern Nebo Plume, NEP-4
MCLB Barstow
Criteria
Overal Protection of Human Health and the Environment
Compiance with ARARa
Long-Term Effectiveness and Permanence
Reduction of Toxttty. MobHrty. or Volume
Short-Term Effectiveness
UTipjemeniaDWiy
Duration of Remedy
Time to MCLa (years)
Time to Background (years)
Present Cost ($ millions) 20 Yeara Duration
RemedationtoMCLs
Remediation to Background
Alternatives
NEP4-QW-1
No
•No
Low
Low
Low
High
>500
>500
0
0
0
NEP4-QW-2
NEP4-GW-3
NEP4-GW-4
NEP4-QW-5
WHhin Risk Management Range**
•No
Low
Low
Mod
High
>500
>500
0.8
1.3
1.3
Yes
Mod
Mod
Mod
High
>500
>500
2.1
3.3
3.3
Yes
High
High
High
Mod
55
130
10.6
15.1
16.2
Yes
Mod
Mod
Mod
Mod
105
240
3.5
5.5
5.5
V
• ARARs achieved over a very long lime only through natural contaminant degradation processes.
" Alternatives NRF1-QW-2 through NRFt-QW-5 all result in residual risks that fall within EPA's risk management range of 10* to 10*. Cleanup to MCLs would
result In an upper-bound Incremental risk of approximately 1x10* white cleanup to background (0.5 pot) would result in a risk of approximately 5x10*.
Alternative NEP4-GW-1: No action
Alternative NEP4-QW-2: Institutional controls and groundwaler monitoring
Alternative NEP4-GW-3: Vadcee zone source reduction (air sparging/soil vapor extraction)
Alternative NEP4-GW-4: Greundwatsr and vadcee zone source reduction (air sparging/soil vapor extraction)
and groundwater removal, ex s/fu treatment, and dncnargs
Alternative NEP4-GW-5: Qroundwatar removal, ex attu treatment, and Discharge
ARARs - AppHcabte or relevant and appropriate requirements.
MCLs • Federal and state maximum contaminant levels.
Mod - Moderate.
MA • Not applicable.
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6.0 RESPONSIVENESS SUMMARY
Two minor verbal questions were received from the public at the public meeting held on
November 12, 1997 concerning the proposed actions for OUs 1 and 2. These
questions are included on Page 27 of the public meeting transcripts provided in
Appendix C, and are reproduced below.
Question. Mr. Chavez: My name is Lewis Chavez. I just like to ask the question, this
plume that we have here, this Yermo, is this around the area of the Silver Valley High
School?
Response. Mr. Cox: No. Silver Valley is actually in the opposite direction.
Question. Mr. Chavez: On this side. Okay. So this plume is moving from west to
east?
Response. Mr. Cox: Yes.
Comment: Mr. Chavez: Okay. No further questions. Thank you.
No other questions or comments were received on the Proposed Plan at the public
meeting or any other time. The public comments did not result in any changes to the
proposed actions for OUs 1 and 2 presented in this ROD.
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7.0 REFERENCES
California Department of Water Resources (DWR). 1967.. Mojave River Ground Water
Basins Investigation. Bulletin No. 84.
Eccles, L.A. 1981. Ground Water Quality Along the Mojave River Near Barstow,
California. 1974-79. U.S. Geological Survey, Water-Resources Investigations
80-109. March.
Hardt, W. 1971. Hydrologic Analysis of Mojave River Basin, Using Electric Analog
Model. U.S. Geological Survey Open-File Report.
Jacobs Engineering Group Inc. (Jacobs). 1991. "Marine Corps Logistics Base, Barstow
California. Final Addendum Sampling and Analysis Plan, Remedial
Investigation/Feasibility Study for Operable Units 1 and 2." November.
Jacobs. 1993a. "Marine Corps Logistics Base, Barstow California. Operable Units 1
and 2 Results of Stage B Groundwater Investigation." Technical Memorandum
0012. Draft. 09 November.
Jacobs. 1993b. Action Memorandum. 12 March.
Jacobs. 1995a. "Marine Corps Logistics Base, Barstow California. Remedial
Investigation / Feasibility Study Remedial Investigation Report for Operable
Units 1 and 2." Draft Final. 31 October.
Jacobs. 1995b. "Marine Corps Logistics Base, Barstow California. Remedial
Investigation / Feasibility Study Feasibility Study for Operable Units 1 and 2."
Draft.
Jacobs. 1995c. "Marine Corps Logistics Base, Barstow California. Engineering
Evaluation / Cost Analysis for Operable Unit 1, Yermo Annex." Draft Final.
August.
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Revision: 0
Jacobs. 1996a. "Marine Corps Logistics Base, Barstow California. Proposed Plan for
Operable Units 1 and 2."
Jacobs .1996b. "Marine Corps Logistics Base, Barstow California. Feasibility Study for
Operable Units 5 and 6." Draft Final.
Miller, G.A. 1969. "Water Resources of the Marine Corps Supply Center Area,
Barstow, California. U.S. Geological Survey, Water Resources Division. Open-
File Report.
OHM Remediation Services (OHM). 1994. Preliminary Draft Technical Memorandum A.
Project No. 16405. December.
OHM. 1995. Working Draft Technical Memorandum B. Project No. 16405.
OHM. 1996. Working Draft Technical Memorandum B. Project No. 16404. December.
Working Draft Technical Memorandum B. Project No. 16405. December.
OHM. 1996a. Groundwater Monitoring Plan for Operable Unit 1. Draft.
OHM. 1996b. Groundwater Monitoring Plan for Operable Unit 2. Draft.
Turin, J. 1990. "VLEACH, One-Dimensional Finite Difference Vadose Zone Leaching
Model." Prepared by CH2M Hill, Reading, California, for EPA Region IX. August.
U.S. Environmental Protection Agency (EPA). 1990a. National Oil and Hazardous
Substances Pollution Contingency Plan. Final Rule (40 CFR 300). Federal
Register, Volume 55, No. 46. 08 March.
U.S. Geological Survey. (USGS). 1975. Professional Paper 878. "Evaluation of
Groundwater Degradation Resulting from Waste Disposal to Alluviums near
Barstow, California"
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Appendix A
DON Position on POC ARARs
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APPENDIX A
DON POSITION ON POC ARARs
Disclaimer: This Appendix represents the views of the
Department of the Navy and is not endorsed or
approved by the other FFA signatories.
This appendix discusses the DON'S position on the point of compliance (POC) with
respect to groundwater cleanup standards at MCLB Barstow. The DON has agreed, as
established in Section 2.8.2 of this ROD, that groundwater cleanup standards will be
attained throughout the contaminant plume, except for immediately below any source
area classified as a waste management unit (WMU) under Title 23 CCR, Division 3,
Chapter 15, for which cleanup standards will be attained at and beyond the edge of the
WMU. However, it is the DON'S position that the designation of a POC at the
downgradient edge of source areas not classified at WMUs would be appropriate and is
supported by CERCLA, the NCP, and the administrative record for this ROD. The DON
has decided not to make such designations for non-WMU source areas at this time for
reasons set forth in Section 2.8.2. The following sections provide the basis for the
DON'S position.
Regulatory Issues
The regulatory issues in question are whether or not the CAOCs at MCLB Barstow
addressed in this ROD are "waste management areas" under specific EPA policy and
State regulations relating to the POC for groundwater cleanup levels, and whether
designation of POCs at the CAOCs in this ROD is appropriate.
The National Contingency Plan
The origins of EPA policy regarding the POC regulatory mechanism can be traced to
early EPA RCRA regulations for groundwater monitoring and corrective action at RCRA
regulated units set forth in 40 CFR Part 264. Subpart F. See 40 CFR Section 264.95
and 47 Fed. Reg. 32273, 3229, July 26, 1982. The cited preamble to these regulations
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clearly state that groundwater cleanup standard and corrective action requirements
apply at and beyond the POC at the downgradient edge of regulated units.
EPA followed the RCRA regulatory model and adopted the POC when it established its
CERCLA groundwater cleanup policy in the 1990 NCP. EPA's CERCLA policy, set
forth in the NCP preamble at 55 Fed. Reg. 8753, March 8, 1990, states that "EPA
believes that remediation levels should generally be attained throughout the
contaminated plume, or at and beyond the edge of the waste management area when
the waste is left in place.' The NCP preamble on the same page discusses
groundwater cleanup levels and states that "Such restoration may be achieved by
attaining MCLs or non-zero MCLGs in the ground water itself, excluding the area
underneath any waste left in place".
EPA Region IX's position relative to MCLB Barstow is that a POC is only acceptable at
"RCRA-regulated units," and that groundwater cleanup standards must be achieved
throughout the contaminated plume at all other categories of sites. The DON disagrees
with EPA Region IX on this point. The NCP preamble refers to "waste management
area" as opposed to "RCRA regulated unit." After all, CERCLA was enacted in large
part to support remediation of sites that were created prior to the effective date of
RCRA and is generally intended to address sites that are not RCRA-regulated units.
The NCP preamble clearly indicates that EPA has adopted its early RCRA POC policy
for RCRA regulated units into its CERCLA Groundwater Policy for non-regulated unit
sites.
The policy reflected in the NCP preamble language quoted above was issued to
accommodate both scenarios, where: 1) complete "clean closure" is selected as a
remedial action using the nine NCP remedy selection criteria and cleanup throughout
the contaminant plume is an appropriate cleanup goal, and 2) the remedy selected
under those criteria support leaving some waste in place and containing it in
conjunction with a POC either for cost reasons or technical feasibility limitations on
complete treatment.
EPA's continued support for its POC policy for non-RCRA regulated unit sites is
supported by EPA's 1996 proposed RCRA corrective action rule for RCRA Solid Waste
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Management Units (SWMUs). The preamble for that proposed rule states, "For
groundwater, program implementors and facility owners/operators generally set the
POC throughout the area of contaminated groundwater or, when waste is left in place,
at and beyond the boundary of the waste management area encompassing the original
source(s) or groundwater contamination.' (61 Fed. Reg. 19450, May 1, 1996). This
preamble discussion goes on to reference the NCP preamble POC policy and states
EPA's intention to implement CERCLA and RCRA corrective action in a consistent
manner.
A review of past RODs in the ERD-ROD database located many RODs issued or
approved by other EPA regional offices addressing non-RCRA regulated unit sites in
which soil contamination/ waste was left in place (sometimes as residual contamination
following treatment of hot spots). The sites addressed included mining waste
impoundments, gravel pits, wood treatment sites, and general industrial areas impacted
by a range of types of repeated contaminant releases. These RODs have included the
establishment of a POC for groundwater at the downgradient edge of the waste
management area where the waste was left in place and required compliance with
groundwater cleanup standards at and downgradient from the POC. The EPA regional
offices issuing these RODs have adhered to the EPA POC policy set forth in the NCP
preamble and quoted above. The following RODs offer some examples:
1. Teledyne Wah Chang, USEPA R10, 6/10/94 (EDR-ID 1000201862)
2. Montana Pole & Treating Plant, USEPA R8, 9/21/93 (EDR-ID 1000396074)
3. Naval Air Station, Ault Field, USEPA R10, 12/20/93 (EDR-ID 1000141164)
4. Reilly Tar & Chemical, USEPA R5, 9/30/93 (EDR-ID 1000289722)
5. American Crossarm & Conduit, USEPA R10, 6/30/93 (EDR-ID 1000360942)
6. Reilly Tar & Chemical, USEPA R5, 6/30/92 (EDR-ID 1000289722)
In accordance with the NCP preamble, there may be certain circumstances where a
plume of groundwater contamination is caused by releases from several distinct
sources that are in close geographical proximity. In such cases, the most cost-effective
groundwater cleanup strategy may be to address the problem as a whole rather than
on a source-by-source basis and to draw a common point of compliance that
encompasses all the sources of release (55 Federal Register 8753, 8 March 1990).
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Based on the above provisions, the DON believes that the following designations of
points of compliance for MCLB Barstow WMAs/WMUs would be appropriate:
• CAOCs 15/17, 16, 23 and 35 at the Yermo Annex are contiguous
WMAs/WMUs. A common point of compliance for groundwater cleanup would
be defined at the downgradient edge of these CAOCs, as shown in Figure A-1.
• CAOC 26 at the Yermo Annex is not a contiguous WMA. An individual point of
compliance for groundwater cleanup would be defined at the downgradient
edge of this CAOC, as also shown in Figure A-1.
• Warehouse 2 arid CAOC 6 at the Nebo Main Base are not contiguous WMAs.
Individual points of compliance for groundwater cleanup would be defined at the
downgradient edge of these areas, as shown in Figure A-2.
State Regulations
State of California regulations contain POC provisions that are consistent with the
EPA's policy as set forth in the NCP preamble. These provisions are both potential
federal and state ARARs. The POC at Title 22 CCR 66264.95, which is essentially the
same as Title 23 CCR 2550.5, is defined as "a vertical surface, located at the
hydraulically downgradient limit of the waste management area that extends through
the uppermost aquifer underlying the regulated unit.'
These regulations were promulgated to conform to the RCRA regulated unit POC
requirements at 40 CFR Section 264.95. The current language in those provisions was
developed to support EPA's authorization of the State of California's RCRA Subtitle C
program in July 1992 (57 Fed. Reg. 32726, July 23, 1992) and was promulgated in
order to assure EPA that the State POC provisions were no less stringent than the
Federal requirements set forth In 40 CFR Section 264.95. (Note: Title 23 CCR Chapter
15 was reviewed as part of the RCRA authorization process because of its applicability
to Class I hazardous waste management units; the relevant language in Title 22 and
Title 23 is identical because of this "overlap" of authorities and because conforming
amendments to both titles were jointly promulgated).
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The POC provisions at Title 22 CCR 66264.95 are considered by the DON to be a
"relevant and appropriate" federal ARAR for the CAOCs addressed in this ROD.
Significantly, cross-references from Title 22 CCR Sections 66264.94 to 66264.93 to
66264.92 clearly indicate that both concentration limits and the POC are integral parts
of the RCRA groundwater protection standard. The POC provisions of Title 22 CCR
66264.95 provide that the water quality standard (including concentration limits) would
apply at the POC and other monitoring locations "determined pursuant to Section
66264.97". The language of Title 22 CCR 66264.97 provides that in the context of
corrective action such monitoring locations would be established at appropriate
locations to support evaluation of groundwater compliance with the water quality
standard for groundwater "passing the point of compliance* and downgradient from the
POC. See Title 22 CCR Sections 66264.94(d)(4); 66264.97(b)(1)(B)(1), (C)(1), and
(D)(1); and 66264.98(n).
The DON also considers the POC provisions of Title 23 CCR Section 2550.5 to be a
potential "applicable* state ARAR for the "dosed, abandoned or inactive* WMU
CAOCs through Title 23 CCR Section 2510(g) and to other Title 23 CCR Chapter 15
WMU CAOCs through Article 5. In addition, they are a potentially 'relevant and
appropriate" ARAR for non-WMU CAOCs.
In a manner identical to Title 22 CCR 66264.95, cross references from Title 23 CCR
Sections 2550.4 to 2550.3 to 2550.2 dearly indicate that both concentration limits and
the POC are integral parts of the groundwater protection standard. The language
relating to corrective action , POC, and monitoring locations set forth in Title 23 CCR
Sections 2550.4, 2550.7, and 2550.8 is identical to that referenced above for Title 22
CCR Sections 66264.94, 66264.97, and 66264.98. The POC provisions of Title 23
CCR 2550.5 provide that the water quality standard would apply at the POC and other
monitoring locations "determined pursuant to Section 1550.7*. Consistent with Title 22
CCR Section 66264.97, Title 23 CCR Section 1550.7 provides that, in the context of
corrective action, monitoring locations would be established at appropriate locations to
support evaluation of groundwater compliance with the water quality standard for
groundwater "passing the point of compliance* and downgradient from the POC.
A-5
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Vwiton: Final
Revision: 0
The current provisions in Title 23 OCR Chapter 15 relating to the POC and corrective
action requirements were promulgated in 1991 amendments to the provisions of "Article
5. Water Quality Monitoring and Response Programs for Waste Management Units*. A
December 17, 1990 "Statement of Reasons' (SOR) discusses the State's intent and
rationale for amending these regulations.
The language in the repealed POC provisions at the former Section 2553(a) had
stated: The "points of compliance" or "compliance points'are the points at which water
quality protection standards shall be applied, and at which monitoring shall be
conducted. They describe a surface usually located hydraulically downgradient of each
waste management unit, or cluster of contiguous waste management units, in both
saturated and unsaturated zones.' There was no language in the repealed regulations
implying that the water quality protection standard might apply upgradient of the POC.
The amended POC language in Section 2550(a) states: The point of compliance is a
vertical surface located at the hydraulically downgradient limit of the waste
management unit that extends through the uppermost aquifer underlying the unit. For
each Class I waste management unit, trie regional board shall specify monitoring points
at the point of compliance and additional monitoring points at locations determined
pursuant to section 2550.7 of this article at which the water quality protection standard
under section 2550.2 of this article applies and at which monitoring shall be
conducted."
In the SOR for these amendments the SWRCB explains that these amendments were
intended to conform to and demonstrate compliance/equivalency with the RCRA POC
provisions at 40 CFR Section 264.95. See discussion of "Factual Basis' for
amendments at Section 2550.5 and the response to the first comment on page 134 of
the SOR and the discussion of "Factual Basis" for amendments at Section 2550.5(a) on
page 137 of the SOR. There is no indication that there was any SWRCB intent to be
more stringent than 40 CFR Section 264.95 by requiring compliance with the water
quality protection standard upgradient of the POC. To the contrary, the SOR very
clearly states that it was the intent of the amendments to clarify an ambiguity under the
old regulations that could allow placement of the POC further downgradient than the
downgradient edge of the waste management area. Those regulations were less
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CT0298\B70027\RODFINAL.DOC CLE-J02-01F298-B7-0027
Print Date: 30 March. 1998
Verwon. Final
Revision: 0
stringent than RCRA requirements and would have jeopardized authorization of
California's hazardous waste management program under RCRA (Title 23 CCR Class I
facilities are hazardous waste facilities).
The SOR explains that the reason for adding the "additional monitoring locations'
language to Section 2550.5(a) was to clarify that downgradient monitoring locations
allowed under the repealed regulations would continue to be acceptable so long as the
POC was located at the downgradient edge of the waste management area in order to
ensure compliance with minimum RCRA requirements. This "combined" approach is
explained in the SOR in the response to the third and fifth comments in the discussion
of comments on Section 2550.5(a).
The SOR discussion of corrective action requirements now found at Title 23 CCR
Section 2550.10 is also relevant to interpretation of the POC provisions in Title 23 CCR
Section 2550.10. It has been argued by SWRCB counsel assigned to MCLB Barstow
matters that the current language in Title 23 CCR Section 2550.10(c) requiring
corrective action "throughout the zone affected by the release' supports the
interpretation that the water quality protection standard applies upgradient of the POC.
DTSC staff assigned to MCLB Barstow matters has made similar interpretations of the
identified! provisions of Title 22 CCR Section 66264.100(c). The State's interpretations
are not consistent with other provisions in Title 23 CCR Chapter 15, Article 5, and the
equivalent provisons of Title 22 CCR discussed above or with the intent of the SWRCB
as set forth in the SOR.
The SOR states that Title 23 CCR Section 1550.10 is based upon RCRA groundwater
corrective action provisions at 40 CFR Section 264.100. See discussion beginning on
page 306 of the SOR. The language throughout the zone affected by the release*
was added to the final rule as a result of comments received on the proposed rule
relating to the Board's authority to require corrective action beyond a facility boundary
when the "affected zone' of a release extends beyond that boundary. The federal
RCRA regulations made such corrective action conditional upon receipt of permission
from the adjoining landowner. In the SOR, the Board maintained that it had authority to
mandate such corrective action without such consent. In responding to comments on
Subsection 2550.10(f) on page 314 of the SOR, the Board states: "Rather than
A-7
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CTO298\B70Q27\RODF1NALDOC CL£-J02-OlF29fl-B7-OQ27
Print Ditr. aOMwcft. 1898
Vcnton: Final
Ftevitton: 0
continue to separate the requirements to implement corrective action measures bom at
the point of compliance and beyond the point of compliance, Subsection (c) has been
rewritten to require corrective action throughout the zone affected by the release" and
Subsection (e) has been deleted.' The Board's intent is unmistakably clear.
It is the DON'S position that the POC provisions of Title 22 OCR Section 66264.95 are a
"relevant and appropriate" federal ARAR, taking precedence over the equivalent
potential "applicable or relevant and appropriate" Title 23 OCR Section 2550.5 state
ARAR, for both WMUs as well as VOC-contaminated vadose zone source areas not
classified as WMUs in Section 2.8.2 of this ROD. The Title 22 OCR Section 66264.95
provision is an integral component of the water quality protection standard in Title 22
CCR Section 66264.92.
It is the DON'S understanding that the regulatory agencies concur that Title 23 CCR
Section 2550.5 is applicable to Title 23 CCR Chapter 15 WMUs including "closed,
abandoned or inactive" waste management units through Title 23 CCR Section
2510(g), but disagree that either Title 23 CCR Section 2550.5 or Title 22 CCR Section
66264.95 constitute ARARs for VOC-contaminated vadose zone areas that are not
classified as WMUs.
The DON'S position concerning these regulations is consistent with the EPA's position
discussed previously regarding POC for waste left in place as set forth in the NCP
preamble (55 Federal Register 8753, March 8, 1990). In addition, the DON considers
the POC provisions of Title 23 CCR Section 2550.5 and Title 22 CCR Section 66264.95
to apply as ARARs to both groundwater and vadose zone cleanup standards.
It is also the DON'S position that the potential "relevant and appropriate" provisions of
the state point of compliance regulations at Title 22 CCR 66264.95(b)(2) and Title 23
CCR 2550.5(b), which describe an approach to a "common point of compliance" for
contiguous regulated units and WMUs, are consistent with the NCP approach
described previously for sources in dose proximity. Title 22 CFR Section
66264.95(b)(2) provides as follows:
If the facility contains contiguous regulated units, and monitoring along a
shared boundary would Impair the Integrity of a containment or structural
A-8
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Print Date: 30 March. 1998
Version: Final
Revision: 0
feature of any of the units, the WMA may be described as an imaginary line
along the outer boundary of the contiguous regulated units. This provision only
applies to contiguous regulated units that have operated or have received all
permits necessary for construction and operation before July 1, 1991."
Title 23 OCR 2550.5(b) contains nearly identical language for WMUs.
Conclusion
Based on the DON'S agreement to comply with groundwater cleanup standards
throughout the contaminant plume for non-WMU sources, it does not appear that the
POC ARAR issue is significant in terms of any practical effect for this ROD. Complying
with the groundwater cleanup standards throughout the plume will be a conservative
means of demonstrating attainment at the POC. However, the DON is addressing the
POC issue with an "agree to disagree" compromise with the regulatory agencies.
Under this compromise, the DON reserves the right to propose POCs for non-WMU
areas in the future as provided in Section 2.8.2 of this ROD. In addition, the DON'S
agreement to the RAO for non-WMUs under this ROD shall not be construed as
establishing precedent for any other DON or DOD sites.
A-9
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Vcriion: Final
Fteviakxi: 0
(intentionally blank)
A-10
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Appendix B
Administrative Record Index
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT.DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
8< . 0055
NOTIFICATION OF CHANGE IN THE DEPARTMENT OF TOXIC
SUBSTANCES CONTROL'S REMEDIAL PROJECT MANAGER
OEPT OF TOXIC SUBSTANCE CONTROL MARINE CORPS LOGISTICS BASE 1.7.3.4.5.9.7
CORRESPONDENCE. TRIP REPO 3/1(493 5 1 . 0}t4 TRIP REPORT FOR SITE VISIT AT DTSC LONG BEACH RE TECH MEMO TM- SOUTHWEST DIVISION
0008 GROUNOWATER REMEDIATION ASSESSMENT
FILE
1.7
REPORT. GROUNDWATER
6/1*4 14 . 0001
GROUNOWATER OCCURRENCE AND QUALITY (OWR BULLETIN 106-1) US DEPT OF WATER RESOURCES
AND GEOLOGIC. HYOROtOGIC AND WATER QUALITY STUDY RESULTING
IN DELINEATION OF 55 GROUNOWATER BASINS
PUBLIC RELEASE
1.2
REPORT. GROUNDWATER 12«VW 14 . 0002
BARSTOW GROUNOWATER STUDY. CONCLUDES THAT THE
GROUNDWATER BELOW THE WASTE DISCHARGES IS STILL GRADED
AND EXTENDS 1 MILE FURTHER DOWNSTREAM CONDUCTED FROM MAY
CALIF OEPT OF PUBLIC HEALTH
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
REPORT. GROUNDWATCR
1/"69 1 4 . 0003
WATER RESOURCES OF THE MARINE CORPS SUPPLY CENTER AREA. US OEPT OF INTERIOR GEOLOGICAL
GROUNOWATER IN STORAGE IS THE ONLY DEPENDABLE SOURCE OF SURVEY WATER RESOURCES DIV
WATER AT MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
REGULATION. CITY
1M/70 1 1 . 0031 WASTE DISCHARGE REQUIREMENTS FOR THE CITY OF BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
CITY OF BARSTOW
1.2
REPORT. GROUNDWATER
6/1/70 1 4 . 0004 GROUNOWATER STUDY TO IDENTIFY CURRENT CONDITIONS AND CALIF OEPT OF PUBLIC HEALTH
UPDATE INFORMATION PRESENTED IN THE 19G6 REPORT
PUBLIC RELEASE
1.7
REPORT. GROUNDWATER 11/12(70 11. 0030 GROUNOWATER DEGRADATION STUDY IN THE BARSTOW AREA NAVAL FAClfTIES ENGINEERING COMMAND US DEPT OF INTERIOR
DESCRIBING FINDINGS ON THEIR PROPOSAL TO DO THE SUBJECT
STUDY
1.2
REPORT. WASTEWATER
101/71 14 . 0037 STUDY FOR DETERMINING THE FEASIBILITY OF CONNECTING BROWN AND CALDWELl
DOMESTIC AND INDUSTRIAL WASTE FLOW FROM THE SUPPLY CENTER
TO THE MUNICIPAL SEWERAGE SERVICE. MCLB BARSTOW
NAVAL FACILITIES ENGINEERING
COMMAND
1.7
COMMENTS. NFEC
12/10/73 11 . 0017 BASE REVIEW OF REGIONAL WATER QUALITY CONTROL BOARD'S NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
WASTE DISCHARGE REQUIREMENTS FOR MCLB AGENCY
1.7
MARCH 30. 1999
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOCi SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
GUIDANCE. RWOCe
1/10/74 16 . 0006
REVISED WASTE DISCHARGE REQUIREMENTS FOR MARINE CORPS REGIONAL WATER OUAIITY CONTROL
SUPPLY CENTER. YERMO. BARSTOW. MCLB MEET ING OF JANUARY 14, BOARD
1974. NO 6-74-8
NAVAL FACILITIES ENGINEERING
COMMAND
17
ENFORCEMENT. BOARD ORDER 2/22/74 16 . 0007
MONITORING REPORTING PROGRAM. «74-8 ft 74-9 FOR NEBO AND REGIONAL WATER QUALITY CONTROL
YERMO ANNEX. RESULTS OF TREATED DOMESTIC WASTEWATER BOARD
EFFLUENT, ETC. MONITORING EFFORT
NAVAL FACILITIES ENGINEERING
COMMAND
PUBLIC COMMUNICATION. NEW!
ARTICLE
6/9/74 < IB. 0002 "SO YEARS OF POLLUTION THREATENS DESERTS MOJAVE RIVER' L A TMES
PUBLIC RELEASE
1.1
REPORT. GROUNDWA1ER
1/1/75 14 . 0006
EVALUATION OF GROUNDWATER DEGRADATION RESULTING FROM US OEPT OF THE INTERIOR
WASTE DISPOSAL TO ALLUVIUM AND DISCUSSES NATURE AND EXTENT
OF CONTAMINATION
PUBLIC RELEASE
REPORT. INSPECTION
2/S/76 lit . 0011
ON-SITE INSPECTION OF YERMO AND NEBO WASTEWATER TREATMENT REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT. INSPECTION
3/4/76 111 . 0049 ON-SITE INSPECTION OF YERMO AND NEBO WASTEWATER TREATMENT REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
AND DISPOSAL PLANTS BOARD
17
REPORT. COMPLIANCE
3/76/76 22 . 0016 MONTHLY SEWAGE EFFLUENT TEST ANALYSIS RESULTS IN
COMPLIANCE WITH BOARD ORDER NOS 6-74-8 AND S-74-9
NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROt 17
BOARD
ENFORCEMENT. BOARD ORDER 2/1S/77 16 . 0019
BOARD ORDER NO 77-1. FOR CLEAN UP AND ABATEMENT AND REGIONAL WATER QUALITY CONTROL
RESCISSION OF WASTE DISCHARGE REQUIREMENTS UNDER BOARD BOARD
ORDERS OF 6-74-9.6-744. AND VIOLATION OF BOARD ORDER NOS 6-74-
MARINE CORPS LOGISTICS BASE
t.2
ENFORCEMENT. BOARD ORDER 4/14/77 Ig . 0017 BOARD ORDER It 6-77-49. CEASE AND DESIST WASTE DISCHARGES
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT. BOARD ORDER 4/14/77 16 . 0018 BOARD ORDER §6-77-50
REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
BOARD
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE OATE CAT . OOCf SUBJECT AUTHOR ADDRESSEE OP UNIT
REPORT. SLUDGE SM/77 ,4. 0053 INDUSTRIAL WASTE SLUDGE DISPOSAL AT NAVY AND MARINE CORPS NFEC ENVIRONMENTAL PROTECTION NAVAL FACILITIES ENGINEERING 1234
ACTIVITIES SUPPORT SERVICE COMMAND
REPORT WASTEWATER 12/15/77 22- 0015 MONTHLY DOMESTIC AND INDUSTRIAL WASTEWATER MONITORING NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL U
REPORTS IN COMPLIANCE WITH BOARD ORDER NOS 6-74-8 AND 6-74-9 BOARD
ENFORCEMENT. BOARD ORDER 4/14/78 ' IS. 0012 ORDER NO 6-7S-14 WASTE DISCHARGE REQUIRED SOLID WASTE REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE 1
DISPOSAL SITE BOARD
ENFORCEMENT. BOARD ORDER 12/26778 16 . 001S BOARD ORDER LAHONTAN REGION. REVISED WASTE DISCHARGE REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE *
REQUIREMENTS NO 6-78-73 BOARD
ENFORCEMENT. BOARD ORDER 12/28778 16. 0016 BOARD ORDER 8-78-74 DOMESTIC WASTEWATER REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE 2
BOARD
ENFORCEMENT. BOARD ORDER 1/10/80 16. 0014 BOARD ORDER NO 6-80-12 RESCINDING BOARD ORDER NO 6-77-49 REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE *
BOARD
COMMENTS. MCLB 4/11/80 11. 0024 APPROVAL OF A 1-TIME DISCHARGE OF INDUSTRIAL EFFLUENT FROM MARINE CORPS LOGISTICS BASE REGIONAL WATER QUALITY CONTROL '.2
NEBO ANNEX SANITATION FACILITY INTO OXIDATION POND *2 BOARD
REPORT. GROUNOWATER 10/22/80 16 - 0009 REVISED MONITORING AND REPORTING PROGRAMS FOR NEBO AND REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE "
YERMO ANNEX. REVISED 10/16/80 RESULTS OF FLOW MONITORING BOARD
EFFORT
REPORT. GROUNDWATER 3/1/81 14. 0007 RESUlTS OF GROUNDWATER QUALITY ALONG THE MOJAVE RIVER US DEPT OF THE INTERIOR WITH REGIONAL PUBLIC RELEASE 1.2
NEAR BARSTOW FROM 1974-1979. DEGRADATION OF GROUNDWATER WATER QUALITY CONTROL BOARD
QUALITY IS ATTRIBUTED TO WASTEWATER DISCHARGE PRACTICES
PERMIT. HAZARDOUS WASTE 4/8/81 11. 0013 DISPOSAL OF TOXIC OR HAZARDOUS WASTE BY UNDERGROUND MARINE CORPS LOGISTICS BASE NFEC 1 MCLB '.2
INJECTION WELLS. ENCLOSING SITE INSPECTION FORMS
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT - DOCt SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
61X191 1 1 . 0025
UNDERGROUND INJECTION CONTROl PROGRAM. ADVISING DELETION REGIONAL WATER QUALITY CONTROL
OF MCLB BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
1.1
REPORT. WASTEWATER
10/23/81 1 1 . 0018 DECSRIBES FURNISHING WASTEWATER TREATMENT PLANT
CLASSIFICATION
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROl 1.2
BOARD
ENFORCEMENT. NOTICE
11/70(81 • 11 1 . 0048 NEBO AND YERMO FACILITIES VIOLATIONS OF EFFLUENT LIMITATIONS REGIONAL WATER QUALITY CONTROl NAVAL FACILITIES ENGINEERING 1.2
BOARD COMMAND
ENFORCEMENT. BOARD ORDER 4/29/82 111 . 0047
ACTIONS IN RESPONSE TO VIOLATIONS OF INDUSTRIAL WASTEWATER MARINE CORPS LOGISTICS BASE
DISCHARGE REQUIREMENTS AT BARSTOW MCLB YERMO ANNEX
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
REPORT. WASTEWATER
8/3/82 22 . 0014
MONTHLY DOMESTIC AND INDUSTRIAL WASTEWATER MONITORING
REPORTS FROM 1979 THROUGH 1982
MARINE CORPS LOGISTICS BASE MCLB * RWOCB
1.2
REPORT. WASTEWATER
2/10/83 ie . 0010 REVISED WASTE DISCHARGE REQUIREMENTS FOR INDUSTRIAL REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
WASTEWATER BOARD
REPORT. INSPECTION
3/4/83 111. 0038 COMPLIANCE INSPECTION OF NEBO AND YERMO INDUSTRIAL REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
WASTEWATER. MCLB. BARSTOW BOARD
1.1
ENFORCEMENT. BOARD ORDER 3/4/83 111. 0042 COMPLIANCE INSPECTIONS OF NEBO» YERMO INDUSTRIAL REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
WASTEWATER FACILITIES. BOARD ORDERS 8-83 18 AND6-83 2O BOARD
12
REPORT. WASTEWATER
5/4/83 1 4 . 0049
CONCEPTUAL STUDY AND REPORT FOR WASTEWATER RECYCLING AT INTERNATIONAL CONSULTING ENGINEERS. MARINE CORPS LOGISTICS BASE
THE EXISTING VEHICLE WASHDOWN/STEAM RACK AREA ADJACENT TO INC
BUILDING 573
MEETING NOTES
9/15/83 1 1 . 0016
VEGETATION AND TREE REMOVAL AT NEBO DOMESTIC WASTEWATER MARINE CORPS LOGISTICS BASE
PERCOLATION PONDS. NOTES FROM THE 9/15/83 MEETING WITH DTSC
DISCUSSING VEGETATION CONTROL TECHNIQUES
DEPT OF HEALTH SERVICES
MARCH 30. 1998
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MARCH 30. 1998
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
PERMIT. WASTE
6/19/84 i 1 . 0023
UNDERGROUND CONTAINERS. HAZARDOUS SUBSTANCE STORAGE
STATEMENT
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
1.2.3.4
REPORT. DRINKING WATER
9/28/84 17. 0003 AS 1803 SAMPLING AND ANALYSIS OF DRINKING WATER RESULTS FROM SOUTHERN CALIFORNIA WATER CO
6 STATE WELLS AROUND MCLB AREA AND WELL CONSTRUCTION DATE
SAN BERNARDINO COUNTY
1.1
PLAN. WASTE
11/1/84 ' 14. 0042 HAZARDOUS SUBSTANCE MANAGEMENT PLAN AT MCLB TO IMPLEMENT J B YOUNG » ASSOCIATES
APPLICABLE REGULATORY REQUIREMENTS AND TO PROVIDE
INSTRUCTIONS FOR THE SAFE HANDLING Of HAZARDOUS MATERIALS
NFEC»MCLB
1.2.3.4.5.8.7
REPORT GROUNDWATER 11/1S/84 17 . 0002 AB 1803 SAMPLE ANALYTICAL RESULTS FOR GROUNDWATER ANALYSES STONER LABORATORIES
FROM STATE OWNED WELLS AROUND MCLB AREA AND WELL
CONSTRUCTION DATE FOR THESE 7 WELLS
YERMO WATER COMPANY
1.2
PERMIT. WASTE
17/31/84 11. 0010 HAZARDOUS WASTE. FACILITY PERMIT ISSUED BY DTSC. US EPA (Of MARINE CORPS LOGISTICS BASE
CA8170090023. YERMO ANNEX
DEPT OF HEALTH SERVICES
REPORT. GROUNDWATER
2/25/85 17 . 0004 AS 1803 SAMPLE RESULTS FOR GROUNOWATER. AND WELL
CONSTRUCTION DATE
CALIFORNIA WATER LABS INC
MARINE CORPS LOGISTICS BASE
1.1
REPORT. GROUNOWATER 3/29*5 14 . 0011
STAFF REPORT ON THE PROGRESS BEING MADE BY THE CITY OF REGIONAL WATER QUALITY CONTROL
BARSTOW TO CLEAN UP THE POLLUTED GROUNDWATER LOCATED IN BOARD
THE MOJAVE RIVERBED
PUBLIC RELEASE
1.2
REPORT. INSPECTION
6/1/85 lit. 0001
COMPLIANCE INSPECTION REPORT (ORDER NO 6-78-14) YERMO SOLID REGIONAL WATER OUALTTY CONTROL
WASTE DISPOSAL SITE BOARD
MARINE CORPS LOGISTICS BASE
REPORT. WATER * SOIL
7/16/85 17. 0013 ENVIRONMENTAL SAMPLE ANALYSIS AND RESULTS FOR SOILS AND A L BURKE ENGINEERS INC
GROUNOWATER AT SITE 2. 11.18. » 21
NAVAL FACILITIES ENGINEERING
COMMAND
GUIDANCE. RWOCB
7/19/95 lit. 0002 UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
SOLID WASTE DISPOSAL SITE. BOARD ORDER NO 8-78-14 BOARD
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
ENFORCEMENT BOARD ORDER 7/19/85 -16. 00?0
UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX REGIONAL WATER QUALITY CONTROL
SOLID WASTE DISPOSAL SITE BOARD CODE NO 6 78 14 BOARD
MARINE CORPS LOGISTICS BASE
POLICY. MCLB
«<«/B5 11). 0003 UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX MARINE CORPS LOGISTICS BASE
SOLID WASTE DISPOSAL SITE. BOARD ORDER NO 6-85 119
REGIONAL WATER QUALITY CONTROL 1
BOARD
ENFORCEMENT BOARD ORDER 8*/BS . 16. 0021 UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX MARINE CORPS LOGISTICS BASE
SOLID WASTE DISPOSAL SITE. BOARD ORDER NO 6-78-14
REGIONAL WATER OUA1FTY CONTROL
BOARD
REPORT. INSPECTION
8/15/85 111 . 0004 COMPLIANCE INSPECTION REPORT NEBOrfERMO ANNEXES FOR REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
INDUSTRIAL WASTE DISCHARGE BOARD
CORRESPONDENCE.
MEMORANDUM
11/5/85 111. 0043
NAVAL ASSESSMENT » CONTROL OF INSTALLATION POLLUTANTS
(NACIP) PROGRAM
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
1.J.3 4.5.8.7
REPORT. ASSESSMENT
1/8/86 11 . 0011
PHASE 2. STAGE 2 DRAFT FINAL REPORT MEETING * PRELIMINARY
ASSESSMENT SUMMARY
OS ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE 1.J.3.4.5.9.7
REPORT, GROUNDWATER
1M4/86 1 1 . 0007
MEMORANDUM RE GROUNDWATER QUALITY. NAVAL ASSESSMENT AND REGIONAL WATER QUALITY CONTROL
CONTROL OF INSTALLATION POLLUTANTS AT MCLB AND MEETING BOARD
MINUTES HELD ON 12/17/85
US ENVIRONMENTAL PROTECTION
AGENCY
1.2
REPORT. CONFIRMATION
2/1/86 1 3 . 0003 CONFIRMATION STUDY FOR CAOC 11 (VOl 3 OF 7)
A L BURKE ENGINEERS MC
NFEC » MCLB
REPORT. CONFIRMATION
2/1/8B 13. 0004 CONFIRMATION STUDY FOR CAOC 2 (VOL 2 OF 7)
A L BURKE ENGINEERS INC
NFEC ft MCLB
REPORT. CONFIRMATION
2/1/86 1 3 . 0005 CONFIRMATION STUDY FOR CAOC 18 (VOL 4 OF 7)
AI BURKE ENGINEERS INC
NFEC a MCLB
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOCH SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. CONFIRMATION
13- 0006 CONFIRMATION STUDY FOR CAOC 21 (VOL S OF
A I BURKE ENGINEERS INC
NFEC t MCLB
REPORT. NPl RANKING
3/1/86 1 1 . 0001
SITE RANKING FOR INCLUSION IN NATIONAL PRIORITIES UST WITH
BACKGROUND INFORMATION
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
REPORT. WASTEWATER
3/2S/86 • 11. 0022
WASTE CATEGORIES GENERATED AND WASTE STREAM INVENTORY
DATED 03/75/86
MARINE CORPS LOGISTICS BASE
DEPT OF HEALTH SERVICES
1.2.3.4
REPORT. COMPLIANCE
8/26/W 22 . 0001
NONSUBMITTAL OF QUARTERLY REPORTS REQUIRED BY MONITORING REGIONAL WATER QUALITY CONTROL
AND REPORTING PROGRAM BOARD ORDER NO 6-85-119 FOR USMC BOARD
YERMO CLASS III LANDFILL
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
GUIDANCE. EPA
10/1/B8 31 . 0001
DRAFT GUIDANCE ON REMEDIAL ACTIONS FOR CONTAMINATED
GROUNDWATER
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
1.2
GUIDANCE. EPA
101/86 31 . 0009 SUPERFUND PUBLIC HEALTH EVALUATION MANUAL
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
17.3.4.5.B.7
REGULATION. ACT
10/27/88 1 1 . 0027 TOXIC PITS CLEANUP ACT. CLOSURE REQUIREMENTS OF UNAPPROVEO REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE 1.2.34.58.7
SURFACE IMPOUNDMENTS ETC BOARD
REPORT HYOROGEOLOGICAL 11/1/86 14. 0013 HYOROGEOLOGICAl ASSESSMENT REPORT FOR INDUSTRIAL WASTE ALMGREN * KOPTIONAK MC
SURFACE IMPOUNDMENTS (2 OF 2)
NFEC « MCLB
1.2
CORRESPONDENCE
1/2O87 1 1 . 0012
TENTATIVE UPDATED WASTE DISCHARGE REQUIREMENTS FOR MCLB.
NE60 INDUSTRIAL WASTE TREATMENT PLANT. ANNOUNCEMENT OF A
02/10/87 WORKSHOP AND 03/12/B7 RWOCB BOARD MEETING
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
1.2
REPORT. INSPECTION
2/25/S7 i 4 . 0061
RCRA COMPLIANCE EVALUATION INSPECTION REPORT. CONTAINS A JACOBS ENGINEERING GROUP MC
SUMMARY OF MANAGEMENT PRACTICES. POTENTIAL VIOLATIONS. ETC
NFEC. MCLB. RWOCB. DTSC. » US EPA 1 3.4
MARCH 30. 199B
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
GUIDANCE. EPA
3/im? 3 I . 0006
DATA OUAIITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
DEVELOPMENT PROCESS
i.2.3.4.s.e,7
GUIDANCE. EPA
3/1/67 3 1 . 0016 DATA QUALITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES. US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
EXAMPLE SCENARIO (EPA) $40/0-67(004)
1.2.J. 4.5.8.7
ENFORCEMENT BOARD ORDER 3/17/87 • 18- 0002
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6-87-36. NEBO ANNEX
DOMESTIC WASTEWATER TREATMENT PLANT)
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT. BOARD ORDER 3/12/67 16 . 0003
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 647-37. YERMO ANNEX
DOMESTIC WASTEWATER TREATMENT PLANT)
REGIONAL WATER OUAIITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT. BOARD ORDER 3/12/87 16 . 0004
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6 87 38. NEBO ANNEX
INDUSTRIAL WASTEWATER TREATMENT PLANT) FACT SHEET
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT. BOARD ORDER 3/12/S7 , 6 . 0005
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 8-87.J9. YERMO ANNEX
INDUSTRIAL WASTEWATER TREATMENT PLANT) FACT SHEET
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT. BOARD ORDER 3/12/87 16 . 0011
WASTE DISCHARGE REQUIREMENTS FOR MCLB YERMO INDUSTRIAL
TREAT PLANT UPDATING BOARD ORDER f 8-fl7-39
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT. GROUNDWATER
5/1/87 14. 0012 INSTALLATION OF 2 GROUNDWATER WELLS AT YERMO ANNEX FOR A L BURKE ENGINEERS INC
MONITORING UPGRAOIENT AND DOWNGRADIENT OF THE SOLID WASTE
DISPOSAL SITE (1 OF 2)
MARINE CORPS LOGISTICS BASE
1.2
REPORT. GROUNDWATER
5/1/87 14 . 0029 INSTALLATION OF 2 GROUNDWATER MONITORING WELLS FOR YERMO AI BURKE ENGINEERS INC
ANNEX. DETAILS OF WELL INSTALLATION PROCEDURES IMPLEMENTED
AND PROCEDURES FOR OPERATION AND MAINTENANCE OF
MARINE CORPS LOGISTICS BASE
REPORT. WASTEWATER
11/S/87 14. 0016 RESULTS OF LABORATORY ANALYSIS AND LAB MONTHLY REPORTS ON MARINE CORPS LOGISTICS BASE
THE DOMESTIC AND INDUSTRIAL WASTEWATER TREATMENT PLANT
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT - DOCi SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. WASTEWATER
11/13/87 14 . 0039
DOMESTIC WASTEWATER OXIDATION PONDS STUDY TO EVALUATE THE AOUA RESOURCES INC
CAUSES OF HIGH MINERAL SALT CONTENT IN THE EFFLUENT OF THE
DOMESTIC WASTEWATER TREATMENT PLANTS AT NEBO AND YERMO
NFEC « MCIB
1.2
PLAN. MASTER
3/1/88 t 4 . 0038
MASTER PLAN UPDATE MCLB. CALIFORNIA DRAFT. 1988. SUMMARY OF MIRA1LES ASSOCIATES IN ASSOCIATION
ONE FULL YEAR'S STUDY OF EXISTING OPERATIONS AND FACILITIES. WITH CH2M HILL. GANNETT « FLEMING
TO EVALUATE THE CONTINUED EXISTENCE OF MCLB
MARINE CORPS LOGISTICS BASE 1.2.3.4.5.8.7
REPORT. INSPECTION
3/5/88 ' 111. 0032
RCRA INSPECTION REPORT INSPECTION OF RCRA FACILITY
CONDUCTED BY USEPA AT MCLB. BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
2.4
REPORT. WASTEWATER
3/17/88 17 . 0005
WATER SAMPLE TEST RESULTS. LEVEL OF CONTAMINATE METALS
PRESENT IN THE NEBO AND YERMO WASTEWATER TREATMENT
FACILITY PONDS
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
REPORT. GROUNDWATER
4/5/88 11 1 . OOOS POLLUTED GROUNOWATER NEAR BARS TOW
REGIONAL WATER QUALITY CONTROL
BOARD
TOPEKA AND SANTA FE RAILWAY
COMPANY
1.2
GUIDANCE. NFEC
5/1/88 3 t . 0007 NAVY INSTALLATION RESTORATION (IRP) MANUAL
NAVAL FACILITIES ENGINEERING COMMAND PUBLIC RELEASE
1.2.3.4.5.8.7
GUIDANCE. EPA
6/1/88 31 . 0004 COMMUNITY RELATIONS IN SUPERFUND A HANDBOOK (INTERIM US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
VERSION)
1.2.3.4.5.8.7
CORRESPONDENCE REQUEST 6/14/88 11 1 . 0006 REQUEST FOR SUBMITTAL OF GROUNOWATER INVESTIGATION PLAN BY REGIONAL WATER QUALITY CONTROL TOPEKA AND SANTA FE RAILWAY
THE CITY OF BARSTOW AND ATCHISON. TOPEKA « SANTA FE RAILWAYS BOARD COMPANY
1.2
ENFORCEMENT. NOTICE
S/15/B8 11 1 . 0013 SYSTEM DEFICIENCY RECORD (DEFICIENCIES IN DOMESTIC WATER DEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE
SUPPLY FACILITIES)
1.2
REPORT. WASTEWATER
9/1/88 14 . 0054 DOMESTIC WASTEWATER OXIDATION PONDS STUDY-CHAPTER 1 ONLY. AQUA RESOURCES INC
TO EVALUATE THE CAUSES OF HIGH MINERAL SALT CONTENT IN THE
EFFLUENT OF THE DOMESTIC WASTEWATER OXIDATION PONDS
NAVAL FACILITIES ENGINEERING
COMMAND
1?
MARCH 30, 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT OOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
GUIDANCE. EPA
10/1/88 3 1 . 0006
GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND
FEASIBILITY STUDIES UNDER CERCLA INTERIM FINAL
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
1.2.3.«.S.8.f
REPORT. GROUNDWATER 10/75/88 17 . 0001 BASE LANDFILL SAMPLING. GROUNDWATER SAMPLING PERFORMED AT MONTGOMERY LABORATORIES
TWO MONITORING WELLS MW-1 AND MW-2
MARINE CORPS LOGISTICS BASE
1.2
REPORT. POTABLE WATER 11/11/88 • 22. 0011 SAMPLE AND ANALYZE MONITORING AND POTABLE WATER WELLS INTERNATIONAL TECHNOLOGY CORP NFEC MCLB RWOCB DTSC & US EPA 12
(REPORT OF ANALYTICAL DAT A) AT YERMO ANNEX .....
REPORT. GROUNDWATER
1/4/89 17 . 0009 RESULTS OF GROUNDWATER ANALYSIS. PERFORMED VOA. METALS. SOUTHERN CALIFORNIA WATER CO MARINE CORPS LOGISTICS BASE 1
AND OTHER ANALYSIS PERFORMED ON SAMPLE FROM AGATE 4. 5. 6
REPORT. WASTE MINIMIZATION 1/22*9 1 4 . 0048
DRAFT WASTE MINIMIZATION ASSESSMENT OF BUILDING S37 REPORT. BATTELLE MEMORIAL INSTITUTE
BASED ON QUALITATIVE REVIEW OF BUILDING OPERATIONS AND THE
WASTEWATER TREATMENT SYSTEM CAPABILITY
MARINE CORPS LOGISTICS BASE
REPORT. SOI
2/9/89 1 4 . 0015
SOILS INVESTIGATION. PAINT COMBAT VEHICLE MAINTENANCE SHOP. BENTON ENGINEERING INC
SUPPLEMENT TO THE 05/27/88 REPORT
ATKINSON. JOHNSON. S SPURPIER. INC 1.1
REPORT. WASTEWATER
3/22/89 1 7 - 0006
SAMPLING VISIT REPORT. CONDUCTED ON MARCH 7-«. 1989 AT THE
INDUSTRIAL WASTEWATER TREATMENT PLANTS LOCATED IN YERMO
AND NEBO ANNEXES. MCLB. BARSTOW
A KEARNEY. INC • DPRA INC
US ENVIRONMENTAL PROTECTION
AGENCY
1.2
REPORT. INSPECTION
4/18/89 I 4 . 0041
RCRA INSPECTION REPORT AT NEBO ANNEX MCLB. BARSTOW BY EPA
REG 9 CONDUCTED ON MARCH 9-10. 1989
SCIENCE APPLICATION INTERNATIONAL
CORP
MARINE CORPS LOGISTICS BASE
ACTION MEMORANDUM
7/13/89 21 . 0001 REMOVAL OF VOLATILE ORGANIC CONTAMINANTS IN YERMO DRINKING MARINE CORPS LOGISTICS BASE
WATER SYSTEM
NFEC » MCLB
PUBLIC COMMUNICATION. PRES 7/14*9 95. 0034 "GEORGE. BARSTOW BASES PUT ON EPA HAZARD LIST"
RELEASE
SAN BERNARDINO SUN
PUBLIC RELEASE
12.3.458.7
MARCH X. 1996
10
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT nrPE
DATE CAT . DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
ENFORCEMENT. NOTICE
8/23/89 111. 0016
VIOLATION OF MONITORING ORGANIC CHEMICAL FOR THE WATER OEPT Of TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE
SYSTEM
1.2
ENFORCEMENT. BOARD ORDER 8/26/89 111 . 0017 NOTICE OF VIOLATIONS (BOARD ORDER NO 6-87-38 & 647.39. NEBO REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING
AND YERMO INDUSTRIAL WASTEWATER TREATMENT PLANTS). BOARD COMMAND
REQUEST FOR SUBMITTAl OF REPORT THAT HAVE NOT BEEN
1.2
CORRESPONDENCE
8/29/89 It . 0002 SOLID WASTE ASSESSMENT TEST PERFORMANCE FOR YERMO SOLID MARINE CORPS LOGISTICS BASE
WASTE DISPOSAL SITE. MCLB AND COMMENTS ON THE DUE DATES SET
IN THE RWOCB'S CORRESPONDENCE DATED05/15/89
REGIONAL WATER QUALITY CONTROL V5
BOARD
REPORT. GROUNDWATER
10/4/89 14. 0017 GROUNOWATER INVENTORY OF THE MOJAVE RIVER BASIN PRESENTED SUBSURFACE SURVEYS
TO THE TECHNICAL ADVISORY COMMITTEE
PUBLIC RELEASE
1.2
REPORT GROUNDWATER 10/12/89 17 . 0008 RESULTS OF GROUNDWATER ANALYSIS. 3 WELLS SAMPLED AND PACIFIC ANALYTICAL INC
ANALYZED FOR ATRAZINE. SIMAZINE EOB. OBCP. VOA
NAVY PUBLIC WORKS CENTER
1.2
REPORT. WATER INVENTORY 10/14(89 1 4 . 0018
INTERIM REPORT - MOJAVE RIVER BASIN WATER INVENTORY
INVESTIGATION. NORTHWEST OF HELENDALE. TO DETERMINE DEPTH
OF WATER TABLE WHERE WELL CONTROL IS SPARSE
SUBSURFACE SURVEYS
MOJAVE WATER AGENCY
1.2
REPORT. COMPLIANCE
10/18/89 22 . 0002
MONITORING REPORTS • BOARD ORDER NOS 6-87-36. 6-87-37. 6-87-38. NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL
AND 6-87-39 BOARD
1.2
REPORT. CARBON ABSORPTION 10/23/89 22 . 0003 MONITORING REPORT FOR THE GRANULAR CARBON ABSORPTION CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING 1
UNITS COMMAND
REPORT. WASTE MINIMIZATION 11/1/89 14 . 0019
INDUSTRIAL WASTE MINIMIZATION STRATEGY AND OPTIONS TO
EVENTUALLY MODIFY OR ELIMINATE THE INDUSTRIAL WASTE
TREATMENT PLANT OPERATIONS
NAVAL CIVIL ENGINEERING LABORATORY MARINE CORPS LOGISTICS BASE
12.3.4
PUBLIC COMMUNICATION. PRES 11/24/89
RELEASE
95 . 0035
'MARINE BASE ON FINAL SUPERFUND LIST" POLLUTED GROUNOWATER BAHSTOW DESERT DISPATCH
SOU SLATED FOR CLEAN UP
PUBLIC RELEASE
1.23.4.56.7
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
PLAN. GROUNDWATER
12/1/89 14. 0027 GROUNDWAtER MONITORING PLAN WITH ANALYTICAL OAT A JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. DTSC. t US EPA 1.2
PUBLIC COMMUNICATION. PRES
RELEASE
12/1/89 95 . 0036
XONT ANIMATION CLEAN UP PROGRESSES" CARBON TREATMENT OF MCLB BARSTOW TODAY
DRINKING WATER « LONG TERM CLEAN UP MEASURES CURRENTLY
UNDER STUDY FOR MCLB. BARSTOW
PUBLIC RELEASE
l.l
PLAN. RUTS
2/1/90 • 41 . 0001
SUMMARY REPORT REMEDIAL INVESTIGATWN/FEASIBlirY STUDY
WORK PLAN. MCLB. BARSTOW
JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. DTSC. I US EPA 1.2
REPORT. CARBON ABSORPTION 2/26/90 22- 0004 ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS NOi 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT. WASTEWATER
2/26/90 17. 0011 WASTEWATER ANALYSIS RESULTS. VOA». INORGANICS. ETC
NAVY PUBLIC WORKS CENTER. MARINE CORPS LOGISTICS BASE
ENVIRONMENTAL ENGINEERING LAB
I.I
PLAN. SAMPLING t ANALYSIS 3/1/90 42. 0011 SAMPLING PUBLIC AND PRIVATE DRINKING WATER WELLS. YERMO AREA JACOBS ENGINEERING GROUP WC NFEC. MCLB. RWOCB DTSC. t US EPA 1
REPORT. GROUNDWATER
3/1/90 1 4 . 0023
FINAL REPORT ASSESSMENT Of GROUNOWATER QUALITY NEAR
BARSTOW. APPENDICES A THROUGH H (2 OF 4)
GERAGHTY a MILLER INC
ATCHISON. TOPEKA « SANTA FE
RAILWAY COMPANY AND CITY Of
BARSTOW
1.J
COMMENTS. EPA
3*90 52 . 0035
REVIEW OF THE WORKPLAN FOR SAMPLING PUBLIC/PRIVATE DRINKING US EPA, DTSC. 1 RWOCB
WATER WELLS AROUND MCLB. BARSTOW
MARINE CORPS LOGISTICS BASE
1.1
PUBLIC COMMUNICATION PRES 3/17/90 95. 0017 "YERMO WELLS TO BE TESTED FOR GROUNDWATER QUALITY' MCLB BARSTOW TODAY
RELEASE
PUBLIC RELEASE
REPORT. GROUNDWATER 3/19/90
14. 0022 FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW. 4 NEW GROUNDWATER WELLS WERE INSTALLED AND
EXTENSIVE LAB ANALYSIS WAS CONDUCTED 11 OF 4)
GERAGHTY & MILLER MC
ATCHISON. TOPEKA * SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
1.2
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT - DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT, GROUNDWATER
3/19/90 I 4 . 0024
FINAL REPORT ASSESSMENT Or GROUND WATER QUALITY NEAR
8ARSTOW. APPENDIX I (3 OF 4)
GERAGHTY ft MILLER INC
ATCHISON. TOPEKA I SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
REPORT, GROUNDWATER 3/1*90 14 . 0025
FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW. APPENDICES J AND K (4 OF 4)
GERAGHTY ft MILLER INC
ATCMISON. TOPEKA ft SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
t.J
PUBLIC COMMUNICATION. PRES
RELEASE
3/28/90 ' 95 . 0003
'NICE TO SEE ACTION ON 8ARSTOW BASE CLEAN UP OF
GROUNDWATER CONTAMINATION-
BARSTOWDESERT DISPATCH
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES «I6/90 9 5 . 0021 'DMA INSTITUTES TEMPORARY PROCESS FOR INDUSTRIAL
RELEASE WASTEWATER DISPOSAL'
MCLB BARSTOW TODAY
PUBLIC RELEASE
1.2
REPORT. DRINKING WATER 4/19/90 64. 0013 DRAFT SAMPLING AND ANALYSIS REPORT FOR PUBLIC AND PRIVATE JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC t US EPA I
DRINKING WATER WELLS. YERMO AREA
REPORT. CARBON ABSORPTION 4/23/90 22. 0005 ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT. SOU
4/23/90 14 . 003S
SOIL INVESTIGATION. FY 1991, MCON PROJECT P 655, PAINT COMSAT BENTON ENGINEERING INC
VEHICLE MAINTENANCE SHOP. MCLB BARSTOW RESULTS Of SOIL
INVESTIGATION ARE PRESENTED THE PURPOSE WAS TO DETERMINE
ATKINSON, JOHNSON, ft SPURRIER INC 1
PUBLIC COMMUNICATION. PRES
RELEASE
5/7/90 95 . 0033 "MCLB TESTS INDICATE WELLS OFF -BASE NOT CONTAMINATED11 BARSTOW DESERT DISPATCH
PUBLIC RELEASE
REPORT. GROUNDWATER
5/7/90 14 . 0034 ALTERNATE DRINKING WATER SUPPLY STUDY TO JACOBS ENGINEERING GROUP MC
REPLACE/SUPPLEMENT THE GROUNDWATER AT YERMO ANNEX. MCLB.
BARSTOW
NFEC. MCLB. RWOCB. DTSC, « US EPA «
PUBLIC COMMUNICATION. PRES
RELEASE
5/8*90 95. 003? "SOME GOOD NEWS FOR YERMO WATER" WELLS CLEAN
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
1.2
MARCH 30. 1998
-------
DOCUMENT TYPE
DATE CAr-DOCi SUBJECT-
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
AUTHOR
ADDRESSEE
OP UNIT
PUBLIC COMMUNICATION. PRES
RELEASE
5/9/90 95 . 0030
•7ESTS SHOW MARINE WELLS NOT TAINTED WATER FROM PUBLIC AND SAN BERNARDINO SUN
PRIVATE WELLS EXCEEDS STATE DRINKING WATER STANDAKDS
PUBLIC RELEASE
1.2
PUBLIC COMMUNICATION. PRES
RELEASE
V9/90
95 . 0031 'MCLBWPROVES WASTE HANDLING WASTEWATER TRUCKED OFF SITE BARSTOW DESERT DISPATCH
FOR DISPOSAL TREATMENT-
PUBLIC RELEASE
1.J
PUBLIC COMMUNICATION. PRES
RELEASE
5/11/90 . 95 - 0029 "GROUNDWATER AT YERMO MEETS SAFE WATER STANDARDS' MCLB BARSTOW TODAY
PUBLIC RELEASE
REPORT. CARBON ABSORPTION S/21/90 22 . 0006
ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT. DRINKING WATER 5/29/90 64 . COM REPORT ON PUBLIC/PRIVATE DRINKING WATER WELLS YERMO AREA JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. » US EPA t.2
PLAN. SITE INVESTIGATION WOF. 6/1/90 41 . 0002 SITE INVESTIGATION WORK PLAN FOR THE YERMO ANNEX SANITARY JACOBS ENGINEERING GROUP MC NFEC MCIB RWOCB DTSC * US EPA t
LANDFILL
REPORT. DRINKING WATER 6/11/90 17. 001?
LETTER ENCLOSING REPORTING WATER ANALYSIS FROM FAUCET AT GROUNDWATER TECHNOLOGY INC
NE80 BASE IN 61DG 198
MARINE CORPS LOGISTICS BASE
GUIDANCE. STATE
6/72/90 31 . 0017
INTERIM GUIDANCE FOR PREPARATION OF ENDANGERMENT
ASSESSMENT REPORT
DEPT OF HEALTH SERVICES
PUBLIC RELEASE
t.2.3.«.5.9.7
REPORT. CARBON ABSORPTION 6/29/90 22 - 0007
ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
REPORT. DRINKING WATER 7/13/90 17 . 0014
THIRD QUARTER DRINKING WATER WELL ANALYSIS RESULTS. TITLE 22 K BANKS MONTGOMERY LABORATORIES MARINE CORPS LOGISTICS BASE
WATER TESTING
1.2
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. CARBON ABSORPTION 8/13/90 11 . 0008
ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND S
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN OAPP
9M/90 42 . 0001 DRAFT RI/FS QUALITY ASSURANCE PROJECT PLAN. MCLB. BARSTOW JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. OTSC. S US EPA 1.2
REPORT. CARBON ABSORPTION 9/6/90 2 2 . 0009
ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL CALGON CARBON CORPORATION
10 UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING 17
COMMAND
AGREEMENT. FEDERAL FACILITI 9/29/90 111 . 0023
FEDERAL FACILITY COMPLIANCE AGREEMENT MCLB NEBO. BETWEEN US EPA « MCLB
MCIB AND US EPA
MARINE CORPS LOGISTICS BASE 1.2.3.4.5 8.7
AGREEMENT. FEDERAL FACILITI 9/78/90 ill . 0030 FEDERAL FACILITIES COMPLIANCE AGREEMENT MCIB YERMO US EPA « MCLB
BETWEEN MCLB AND EPA
MARINE CORPS LOGISTICS BASE 1.2.3.4.9.6.7
AGREEMENT. FEDERAL FACILITIi 9/29/90 111 . 0024 RESPONSE TO THE US EPA ON THE FEDERAL FACILITIES COMPLIANCE MARINE CORPS LOGISTICS BASE
AGREEMENT
US ENVIRONMENTAL PROTECTION t.2.3.4.5.67
AGENCY
REPORT. CARBON ABSORPTION 10/9/90 22. 0010 ANALYTICAL RESULTS. OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
PUBLIC COMMUNICATION. PRES 10/10/90
RELEASE
95 - 0027
"PACTS SIGNED FOR CLEAN UP OF HAZARDOUS SITE AT MCLB.
BARSTOW
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
12.3.4.5.6.7
PUBLIC COMMUNICATION. PRES 10/19/90
RELEASE
95 . 0028
"TEMPORARY TREATMENT UNIT FOR INDUSTRIAL WASTEWATER
TESTED AT DEPOT MAINTENANCE ACTIVITY"
MCLB BARSTOW TODAY
PUBLIC RELEASE
1.2.34.5.6.7
CORRESPONDENCE.
MEMORANDUM
10/22/90 11 1 . 0044 FURTHER INVESTIGATION OF OFF-SITE CONTAMINATION OF
GROUNOWATER
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
1.2
MARCH 30. 1996
15
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT. DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
AGREEMENT. FEDERAL rACIllTI 10/24/90 til . 0076
FEOERAl f ACUITY AGREEMENT UNDER CERCLA SECTION 120
BETWEEN MCIB. USEPA AND CDMS
US EPA. DTSC4NFEC
MARINE CORPS LOGISTICS BASE 1.2.3,4.5.8.7
PUBLIC COMMUNICATION. PRES 1046/90 95 . 0026 "EPA, STATE AND NAVY SIGN FEDERAL FACILITY AGREEMENTS FOR MCLB BARSTOW TODAY
RELEASE MCLB. BARSTOW
PUBLIC RELEASE
1.2.3.4.5.6,7
AGREEMENT. FEDERAL FACMTi' 10/29/90 > 111 . 0025 RESPONSE TO us EPA ON THE FEDERAL FACILITIES COMPLIANCE MARINE CORPS LOGISTICS BASE
AGREEMENT
US ENVIRONMENTAL PROTECTION 1.2.3.4.5.6.7
AGENCY
REPORT. ANALYTICAL
10/30/90 1 7 . 0032
ANALYTICAL REPORT DATED SEPTEMBER 1990. WELL NOS 3 AND 5
(VWENCLI
CALGON CARSON CORPORATION NAVAL FACILITIES ENGINEERING
1.2
GUIDANCE. STATE
11/1/90 33 . 0001
PROCEDURES FOR ENDANGERED SPECIES ACT COMPLIANCE FOR THE US DEPT INTERIOR FISH AND WILDLIFE
MOJAVE DESERT TORTOISE SERVICE REGIONS 1.? AND 6
PUBLIC RELEASE
1.2.3.4.5.8.7
REPORT. GROUNDWATER 11/19/90 17 . 0010
RESULTS OF GROUNDWATER ANALYSIS. PERFORMED ANALYSIS FOR
REGULATED ORGANIC CHEMICALS AND RADIOACTIVE SUBSTANCES
MONTGOMERY LABORATORIES
MARINE CORPS LOGISTICS BASE
1.2
COMMENTS. DISC
11/21(90 52 . 0023
REVIEW OF THE DRAFT Riff S WORK PLAN FOR MCLB, BARSTOW. DATED DEPT OF TOXIC SUBSTANCES CONTROL
SEPTEMBER 1990
MARINE CORPS LOGISTICS BASE 1.2.3.4.5.6.7
COMMENTS. DTSC
11/27/90 52- 0024 RE VIEW OF THE DRAFT RI/FS SAP FOR MCLB. BARSTOW. DATED OEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE 1.2.3,4.5.6.7
SEPTEMBER 1990
COMMENTS. DTSC
11/27/90 52 . 0025
REVIEW OF THE DRAFT RUFS. HEALTH AND SAFETY PLAN FOR MCLB.
BARSTOW. DATED SEPTEMBER 1990
DEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE 1.2.3 4.5.8.7
COMMENTS. DTSC
11/27/90 52 . 0026
REVIEW OF THE DRAFT Riff S QUALITY ASSURANCE PROJECT PLAN FOR DEPT OF TOXIC SUBSTANCES CONTROL
MCIB. BARSTOW. DATED SEPTEMBER 1990
MARINE CORPS LOGISTICS BASE 1.2 3 4.5.8.7
MARCH 30.1996
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS. EPA
11(28/90 52 . 0005
REVIEW ON THE DRAF T WORK PLAN SAMPLING AND ANALYSIS PLAN. US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
QUALIFY ASSURANCE PROJECT PLAN AND COMMUNITY RELATIONS
PLAN FOR MCLB DATED SEPTEMBER 26. 1990
1,2.3.4.5.6.7
COMMENTS. DISC 11/26/90 52 . 0021 REVIEW OF THE RI/TS COMMUNITY RELATIONS PLAN. DATED 09/90 DEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE 1.2.3.4.56.7
COMMENTS. RWOCB
11/79/90 ' 52- 0022 REVIEW OF THE DRAFT RI/FS WORK PLAN FOR MCLB. BARSTOW. DATED REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE 1234567
SEPTEMBER 1990 BOARD
COMMENTS. RWOCB
11(3090 52 . 0007
REVIEW ON THE DRAFT RI/FS WORK PLAN. SAP. QUALITY ASSURANCE REGIONAL WATER QUALITY CONTROL
PROJECT PLAN. COMMUNITY RELATIONS PLAN HEAL TH AND SAFE TY BOARD
PLAN FOR MCLB
MARINE CORPS LOGISTICS BASE 1.2.3 4.5.6.7
PUBLIC COMMUNICATION. PRES 11/30/90
RELEASE
95 . 0024 'MCI B. BARS TOW HOSTS FIRST TRCMEETING'
MCLB BARSTOW TODAY
PUBLIC RELEASE
1.23.4.5.6.7
AGREEMENT. FEDERAL FACILITI 12/5/90 111 . 0029
SUBMITTAL TO THE US EPA IN RESPONSE TO FEDERAL FACILITIES
COMPLIANCE AGREEMENT
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION 1.2.3.4.5.S.7
AGENCY
REGULATION. SENATE BILL
"1/91 32 - 0001
CALIFORNIA STATE REQUIREMENTS FOR WATER WEIL DESTRUCTION • ENVIRONMENTAL HEALTH SERVICES.
SENATE BILL NO 1817 COUNTY Of SAN BERNARDINO
PUBLIC RELEASE
1.2
REPORT. WASTEWATER
1/3/91 64- 0017 LETTER REPORT ON THE SAMPLING OF SLUDGE LAGOON »1 NEBO BROWN AND CALOWELL
DOMESTIC WASTEWATER TREATMENT FACtllTY. MCLB. BARSTOW
NFEC. MCLB. RWQCB. DTSC. « US EPA I
COMMENTS RESPONSE
1/16/91 53. 0001 RESPONSE TO REGULATORY AGENCY COMMENTS ON RI/FS WORK JACOBS ENGINEERING GROUP MC NFEC MCLB RWQCB DTSC. 8 US EPA 1.2.34.56.7
PLAN. MCLB. BARSTOW SEPT 1990
CORRESPONDENCE
1(25/91 17 . 0016 ANALYTICAL REPORT DATED NOVEMBER 1990 ON WELL NOS 3 AND S CAtGON CARBON CORPORATION
MCLB. BARSTOW
NAVAL FACILITIES ENGINEERING
MARCH 30. 1998
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. WATER LEVELS
2/14/91 1 1 . 0014
RECORDS OF WAIER LEVELS IN WELLS TOWNSHIP 9N RANGE 1W US GEOLOGICAL SURVEY
THROUGH TOWNSHIP 9N RANGE PRINTED 2/14/91 IN RESPONSE TO
JEG'S REQUEST
NFEC « MCLB
PLAN. COMMUNITY RELATIONS 3/1/91 92 . 0001 DRAFT FINAL COMMUNITY RELATIONS PLAN. MCLB BARSTOW JACOBS ENGINEERING GROUP INC NFEC MCIB. RWOCB DTSC « US EPA 1.2.3.4.5,8.7
PLAN. RI/TS WORK
3/1/91 , 41.0003 DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK JACOBS ENGINEERING GROUP INC NFEC MCIB RWOCB DTSC * US EPA 1.23.4.587
PLAN. MCIB. BARSTOW
GUIDANCE. EPA
3/1/91 31 . 0019 GROUNDWATER ISSUE DENSE NON-AQUEOUS PHASE LIQUIDS US ENVIRONMENTAL PROTECTION AGENCY JACOBS ENGINEERING GROUP INC 1.2
REPORT. CONTAMINATION
RELEASE
3/7/91 1 1 . O015
RELEASE OF 55 GAUONS Of TRITIUM CONTAMINATED WATER INTO MARINE CORPS LOGISTICS BASE
YERMO ANNEX DOMESTIC SEWER SYSTEM AND DETAILS OF REASONS
WHY SPILL OCCURRED
REGIONAL WATER QUALITY CONTROL 1
BOARD
REPORT. ANALYTICAL
3/15V91 1 7 . 0030
ANALYTICAL REPORT DATED FEBRUARY 1991. WELL NOS 3 AND 5
(WIENCL)
CALGON CARBON CORPORATION NAVAl FACILITIES ENGINEERING
1.2
REPORT. ANALYTICAL
3/15/91 17. 0031 ANALYTICAL REPORT DATED JANUARY 1991. WELL NOS 3 ANDS CALGON CARBON CORPORATION
(W/ENCL)
NAVAL FACILITIES ENGINEERING
1.2
PLAN. HEALTH* SAFETY 3/27/91 46-0002 UTILITIES INSTALLATION HEALTH AND SAFETY PLAN. MCIB. BARSTOW JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC. » US EPA 1.2
COMMENTS. DTSC
3/27/91 52 . 0017
REVIEW OF THE DRAFT FINAL RI/FS WORK PLAN. MARCH 1991. MCLB.
BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAl FACILITIES ENGINEERING
COMMAND
1.2.34.5.9.7
COMMENTS. DTSC
3/27/91 52 - 001B
REVIEW OF THE DRAFT FINAL COMMUNITY RELATIONS PLAN. MARCH
1991. MCLB. BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
123456.7
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS. RWOCB
3/77191 52- 0028 REVIEWOF THE DRAM RI/FS WORK PLAN FOR MCIB. BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE 1.2.3.4.5.67
PLAN. RI/FS WORK
4/1/91 42 . 0002 DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY SAMPLING JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB DTSC S US EPA 1.2.1.4.5.67
AND ANALYSIS PLAN. MCLB. BARSTOW
REPORT. ANALYTICAL
4/2/91 ' 17. 0029 ANALYTICAL REPORT DATED MARCH 1991. WELL NOS 3 AND S (WENCL) CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING
1.2
CORRESPONDENCE
4/3/91 51 . 0007 TIMELY SUBMITTAL OF Rl/fS SCOPING DOCUMENTS
MARINE CORPS LOGISTICS BASE
DEPT TOXIC SUBSTANCES CONTROL 1.2.3.4.5.8.7
PLAN. SITE
4/15/91 42 . 0010 SITE MANAGEMENT PLAN FOR MCIB
JACOBS ENGINEERING GROUP WC NFEC. MCIB. RWOCB. DTSC. » US EPA 1.2.3.4.J.8.7
CORRESPONDENCE
4/29/91 51 . 0005 CONCERNS REGARDING TECHNICAL REVIEW COMMITTEE CHARTER DEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE 1. 2. 3. 4. S.6. 7
FOR THE RI/FS AND RFA ACTMRIES AT MCIB. BARSTOW
COMMENTS. RWOCB
4/29/91 52 . 0081 REVIEW OF THE RUTS SAMPLING AND ANALYSIS PLAN AND QUALITY REGIONAL WATER OUALrTY CONTROL MARINE CORPS LOGISTICS BASE 1234567
ASSURANCE PROJECT PLAN SAP AND OAPP. MCLB. BARSTOW BOARD
COMMENTS. EPA
4/30/91 52. 0015 CONDITIONAL APPROVAL AND REVIEWOF THE Rl/fS WORK PLAN AND US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE 1.2.3.4.5.87
SAMPLING AND ANALYSIS PLAN. MCIB. BARSTOW
REPORT. ANALYTICAL
4/30/91 17. 0076 ANALYTICAL REPORT DATED APRIL 1991, WELL NOS 3 AND S (W/ENCU CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING
1.2
COMMENTS. OHS
4/30/91 52 - 0080 REVIEWOF THE DRAFT FINAL RUTS SAMPLING AND ANALYSIS PLAN OEPT Of HEALTH SERVICES
AND QUALITY ASSURANCE PROJECT PLAN
NAVAL FACItlTIES ENGINEERING 1.2.3.4.5.6.7
COMMAND
MARCH 30. 1998
19
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT - DOC» SUBJECT AUTHOR ADDRESSEE OP UNIT
COMMENTS. EPA 5/3/91 52. 0009 REVIEWOF THE DRAFT FINAl REMEDIAL INVESTIGATION. FEASIB HITY US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 12345(7
STUDY WORK PLAN MARCH I. 199'. FOR MCIB. BARSTOW COMMAND
CORRESPONDENCE. RESPONSE 5/15/91 51. 0008 CONCERNING APPROVAL OF DRAFT COMMUNITY RELATIONS PLAN AND US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE 12345(7
HEALTH AND SAFETY PLAN FOR THE RI/FS AND RFA ACTIVITIES AT
MC16. BARSTOW
CORRESPONDENCE 5/15/91 51 . 0023 RKFS WORK PLAN. TIME EXTENSION SU8MITTAL FOR MCLB. BARSTOW US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 1.2.3.4.5.87
COMMAND
CORRESPONDENCE 5/72/91 51 . OOO4 TIME EXTENSION FOR SAMPLING»ANALYSIS PLAN SUBMITTAL FOR NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 1.2.3.4.5,6.7
THE RI/FS ACTIVITIES AT MCLB. BARSTOW AGENCY
CORRESPONDENCE. RESPONSE 5/22/91 51 - 0026 RESPONSE TO US £PA LETTER DATED MAY 15 1991. ON THE APPROVAL NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 123.4597
OF TIME EXTENSION FOR SAP SUBMITTAl AGENCY
CORRESPONDENCE 5/73/91 $1. 0006 RESPONSE TO THE CONCERNS OF DHS ON TECHNICAL REVIEW MARINE CORPS LOGISTICS BASE DEPT TOXIC SUBSTANCES CONTROL 12.3.45(7
COMMITTEE CHARTER FOR RI/FS AND RFA ACTIVITIES AT MCLB.
BARSTOW
REPORT. CARBON ABSORPTION 5/78/91 22 - 0020 RE VISED ANALYTICAL REPORTS. MARCH* APRIL 1991. CALGON CALGON CARBON CORPORATION MARINE CORPS LOGISTICS BASE 1.2
CARBON MODEL 10. WEILS §3*5
REPORT. CARBON ABSORPTION 6/3/91 22. 0018 REPORT FOR MAY 1991. CALGON CARBON MODEL 10. WELLS fMS. CALGON CARBON CORPORATION MARINE CORPS LOGISTICS BASE 1.2
PLAN. RI/FS WORK 6/15/91 41 . 0004 DRAFT REMEDIAL INVESTIGATION/FEASIBLITY STUDY WORK PLAN JACOBS ENGINEERING GROUP MC NFEC. MCLB. RWQCB. OTSC. 4 US EPA 1.2
EXPANDED SECTION ON REGIONAL HYDROGEOLOGY. SAMPLING AND
ANALYSIS RATIONALE FOR INVESTIGATION OF GROUNDWATER
REPORT PLANNING DOCUMENT 6/15/91 41. 0011 DRAFT RI/FS PLANNING DOCUMENTS SUBMITTAL TO REGULATORY SOUTHWEST DIVISION MARINE CORPS LOGISTIC BASE 1.2
AGENCIES (ENCLOSURE 2)
MARCH 30. 1996
20
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE "ATE CAT • OOC» SUBJECT AUTHOR ADDRESSEE OP UNIT
MEETING AGENDA 6/16/91 51 . 0003 MEETING NOTIFICATION AND TENTATIVE AGENDA NAVAL FACILITIES ENGINEERING COMMAND us ENVIRONMENTAL PROTECTION 1.2.3.4.5.8.7
AGENCY
CORRESPONDENCE. REQUEST 6/17/91 51 . 0079 REQUEST FOR TIME EXTENSION FOR SUBMISSION OF DRAFT REMEDIAL NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 1234587
INVESTIGATION REPORT AGENCY
CORRESPONDENCE 6/2O/91 ' 51 . 0030 TIME EXTENSION FOR CLARIFICATION TO NFEC LETTER DATED 6/3O/91 NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 1.2.3.4.5.6.7
AGENCY
REPORT. CARBON ABSORPTION 6/25/91 7?. 0019 REPORT FOR JUNE 1991. CALGON CARBON MODEL 10. WELLS «*S. CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING V?
COMMAND
REPORT. ANALYTICAL 6/25/91 17 . 007' ANALYTICAL REPORT DATED JUNE 1991 WEIL NOS 3 AND 5 (W/ENCL) CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING 1.2
MEETINGNOTES 6/77/91 St. 0013 DRAFT NOTES FROM PROJECT MANAGERS MEETINGS HELD ON 6/27. NAVAL FACILITIES ENGINEERING COMMAND US EPA. OTSC ft RWOCB 1.7.3.4.5.8
28/91. RE PROJECT SCHEDULE. YERMO SLUDGE REMOVAL. OU> 142
WORK PLAN AMENDMENTS. RI/FS WORK PLAN AMENDMENTS. WASTE »
MEETINGNOTES 7rt/91 51 . 0706 JUNE 27-28. 1991. MEETINGNOTES FROM PROJECT MANAGER'S SOUTHWEST DIVISION MARINE CORPS LOGISTICS BASE 1.2.3.4.5.8
MEETING. MARINE CORPS LOGISTICS BASE. BARSTOW
REPORT WATER QUALITY 7/10/91 22 . 0022 INDUSTRIAL WATER QUALITY MONITORING REPORT FOR THE MONTH MARINE CORPS LOGISTICS BASE REGIONAL WATER QUALITY CONTROL '.2
OF JUNE 1991 BOARD
PUBLIC COMMUNICATION, PRES 7/76/91 95 . 0019 INSTALLATION RESTORATION PROGRAM AT MCLB. BARSTOW MCLB BARSTOW TODAY PUBLIC RELEASE 1.2)4.567
RELEASE REVIEWED-
COMMENTS RESPONSE 8/1/91 S3- 0002 RESPONSE TO REGULATORY AGENCY COMMENTS ON DRAFT FINAL JACOBS ENGINEERING GROUP INC NFEC. MCL8. RWQCB. OTSC.«US EPA 1.23.4.5.6.7
WORK PLAN AND SAMPLING AND ANALYSIS PLAN APRIL 1. 1991
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT CARBON ABSORPTION 8/1/9! 22 - 0017
TREATED GROUNDWATER FOR IHE CALGON CARBON MODEL 10
WEILS 3 AND 5
CAIGON CARBON CORPORATION MARINE CORPS LOGISTICS BASE
1.2
GUIDANCE. EPA
9/1/91 3 1 . 0018 ESTIMATING POTENTIAL FOR OCCURRENCE OF DNAPl AT SUPERFUND US ENVIRONMENTAL PROTECTION AGENCY JACOBS ENGINEERING GROUP INC 1 2
SITES
COMMENTS. EPA
B/W91 • 52 . COM
REVIEW Or THE RI/FS FIELD SAMPLING PLAN AMENDMENTS FOR US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
OPERABLE UNITS 1 * 2. WASTE MANAGEMENT PLAN. RISK ASSESSMENT COMMAND
ON LINE AND SCHEDULED TELE-CONFERENCE CALLS OF JULY 9 AND 29.
1.2
REPORT. WASTEWATER
8/9/91 22 . 0012 INDUSTRIAL WATER QUALITY MONITORING RESULTS
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
COMMENTS. EPA
8/9/91 52 . 0036
REVIEW OF THE RISK ASSESSMENT SCHEDULE RVFS. MCLB. BARSTOW US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS. EPA
8/9/91 52 . 0037
REVIEW OF THE RISK ASSESSMENT OUTLINE FOR THE RI/FS AT MCLB. US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
BARSTOW COMMAND
1.2
COMMENTS. EPA
8/9/91 52 . 0038 REVIEW OF THE DATA MANAGEMENT PLAN FOR RI/FS AT MCLB. US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
BARSTOW COMMAND
1.2
COMMENTS. EPA
8/9/91 52 - 0039 REVIEW OF THE WASTE MANAGEMENT PLAN. RI/FS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS. EPA
8/9/91 52- 0040 REVIEW OF THE FIELD SAMPLING PLAN FOR OUs 1/2 RI/FS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 1.2
COMMAND
MEETING NOTES
8V9/91 SI . OW1 NOTES FROM CONFERENCE CALLS BETWEEN JEG AND US EPA ON US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
REMEDIAL INVESTIGATION/FEASIBILITIES STUDY. RE OUl 1U COMMAND
GROUNDWATER STAGES A»B OBJECTIVES
1.2
MARCH 30. 1998
22
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS I AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS. EPA
8/9/91 52 - 025?
REVIEW COMMENTS ON THE DRAFT Rt/FS PLANNING DOCUMENTS FOR US ENVIRONMENT Al PROTECTION AGENCY SOUTHWEST DIVISION
THE MCLB BARSTOW DATED JUNE 15. 1991
1.2,3.4.5.8
COMMENTS. EPA
8/9/91 52 . 0255 COMMENTS ON THE DRAFT RI/FS PLANNING DOCUMENTS FOR MCLB. US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DMSION
BARSTOW DATED JUNE 15. 1991 WITH ATTACHMENTS OF INTERIM FIELD
SAMPLING PLAN FOR OUs 1 AND 2. WASTE MANAGEMENT PLAN. DATA
1.1.
MEETING AGENDA
8/16/91 ' 51 . 0014 PROJECT MANAGERS MEETING NOTIFICATION ON RVFS ACTIVITIES AT NAVAL FACILITIES ENGINEERING COMMAND US EPA DTSC ft RWOCB
MCLB. BARSTOW
U.3.4.S.8.7
COMMENTS. RWOCB
8/1*91 52. 0003 REVIEW ON THE RVFS STUDY SUBMIT! ALTO REGULATORY AGENCIES REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
ENCLOSURES 1 AND 2. OPERABLE UNITS 1 AND 2. MCLB. BARSTOW BOARD
1.2
COMMENTS RESPONSE
8/23/91 S3. 0003 RESPONSE TO AGENCIES COMMENTS ON RVFS PLAN FOR OPERABLE NAVAL FACILITIES ENGINEERING COMMAND US EPA DTSC. » RWOCB
UNITS 1 AND 2
1.2
CORRESPONDENCE
8/27/91 51 . OJ06 DRAFT DETAILED PROJECT SCHEDULE FOR OUt 1.2.3.4.5.6. AND 7AT DEPT Of NAVY
MCLB BARSTOW OF JULY 24. 1991 LETTER
US ENVIRONMENTAL PROTECTION 1. 2. 3 4. 5.8. 7
AGENCY
CORRESPONDENCE. REQUEST 8/29/91 51 . 0011 TME EXTENSION FOR RVFS SAMPLING AND ANALYSIS PLAN
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING ' .2.3.4.5.8.7
COMMAND
REPORT. PLANNING DOCUMENT 8/30/91 4 1 . 0014 RESPONSE TO AGENCY COMMENTS VOLUME I DRAFT FINAL RVFS SOUTHWEST DIVISION
PLANNING DOCUMENTS
MARINE CORPS LOGISTIC BASE 1. 2. 3. 4. 5. 8. 7
REPORT. CARBON ABSORPTION 9/4/91 22. 0021 REPORT f OR AUGUST 1991. CALGON CARBON MODEL 10. WELLS »3»5 CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS
9/9/91 5Z - 0239
COMMENTS ON THE DRAFT RI/FS PLANNING DOCUMENTS FOR THE
MCLB BARSTOW DATED JUNE 15. 1991
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
1.2
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC« SUBJECT
AUTHOR
ADDRESSEE
OP UNIt
TECHNICAL MEMORANDUM 9/10/91 5 1 . 0033
TECHNICAL MEMORANDA FRACTURE TRACE ANALYSIS TM 001 FOR
MCI B. BARSTOW
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. OTSC. « US EPA 1.2
CORRESPONDENCE
9/11/91 51 . 0034 REGIONAL GROUNDWATER INVESTIGATION
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENTS IN YERMO AND 1.2
OAGGET
REPORT. GROUNOWATER 9/23/91 . 17. 0007
ANALYTICAL DATA FOR OFFSITE WELLS MCLB. DATED 11X25/90. FOR
OFF-BASE PRIVATE RESIDENT
US DEPT Of INTERIOR
CALIF GEOLOGICAL SURVEY
1.2
REPORT. ANALYTICAL
9/27/91 17. 0026 ANALYTICAL REPORT DATED SEPTEMBER 1991. WELL NOS 3 AND 5 CAIGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING
(WENCH
1.2
CORRESPONDENCE.
RECOMMENDATION
900/91 51 - 0027
PROPOSAL FOR SCHEDULE EXTENSIONS FOR OPERABLE UNITS 1. 2. 3. NAVAl FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AND 4. MCLB AGENCY
1.2.3.4
MEETING AGENDA
10/1(91 5 1 - 0028
AGENDA FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY PROGRAM NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AND WORKSHOP ON 1*03/91 AGENCY
1,2.3.4.5.8.7
CORRESPONDENCE. REQUEST 10/17/91 51 . 0075 INTENT TO EXTEND TIME FOR RESPONDING TO AGENCY COMMENTS NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 1.2
ON OPERABLE UNITS 1/7 SAMPLING » ANALYSIS PLAN FOR RI/FS. MCLB. AGENCY
BARSTOW
REPORT. ANALYTICAL
10/7901 17. 0024 ANALYTICAL REPORT DATED OCTOBER 1991. WELL NOS 3 AND S (WK> CALGON CARBON CORPORATION
ENCL)
NAVAL FACILITIES ENGINEERING
1.2
REPORT. ANALYTICAL
10/79/91 17 . 0075 ANALYTICAL REPORT DATED OCTOBER 1991. WELL NOS 3 AND 5 CAIGON CARBON CORPORATION
(W/ENCL)
MARINE CORPS LOGISTICS BASE
PLAN. WASTE MANAGEMENT 11/1/91 45. 0001 RVFS WASTE MANAGEMENT PLAN. MCLB. BARSTOW
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWQCB. DTSC. ft US EPA 1.2
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
GUIDANCE. EPA
11/1(91 31 . 0015
GUIDE TO MANAGEMENT Or INVESTIGATION DERIVED WASTES FOR US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
CERCLA SITES
1.2.3.4.5.9.7
PLAN. DATA MANAGEMENT 11W91 44. 0001 RI/FS. RCRA AND UST ACTIVITIES FINAL DATA MANAGEMENT PLAN. JACOBS ENGINEERING GROUP INC NFEC. MCLB RWOCB DTSC t US EPA 1.2
MCLB. BARSTOW
PLAN. SAMPLING I ANALYSIS 11/15/91 ' 42- 0001 FINAL ADDENDUM SAMPLING AND ANALYSIS PLAN OU» 1/2. MCLB. JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB OTSC ft US EPA 1.2
BARSTOW
MEETING AGENDA
t IMS/91 51 . 0021 PROJECT MANAGEMENT MEETING MCLB. TENTATIVE AGENDA NAVAL FACILITIES ENGINEERING COMMAND MCLB. RWOCB. OTSC. S US EPA 1.2.3.4.S.6.7
MEETING NOTES
11/21/91 94 . 0004
TECHNICAL REVIEW COMMITTEE MEETING NOTES HELD ON 11/21/91. NAVAL FACILITIES ENGINEERING COMMAND TECHNICAL REVIEW COMMITTEE
RE THERMAL INFRARED PHOTOGRAPHIC SURVEY. FRACTURE TRACE MEMBERS
ANALYSIS. GROUNDWATER i COMMUNITY RELATIONS EFFORTS
1.2
REPORT. ANALTYICAL
11/27/91 1 7 . 0023
ANALYTICAL REPORT DATED NOVEMBER 1991. WELL NOS 3 AND S
(W/ENCL)
CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING
1.2
COMMENTS. OTSC
12/991 52- 0030 REVIEW OF THE RI/FS WASTE MANAGEMENT PLAN FOR MCLB. BARSTOW DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 1.2.J.4.S.87
COMMAND
CORRESPONDENCE
12/10/91 S 1 . 0164
REQUEST FOR SCHEDULE EXTENSIONS FOR FEDERAL FACILITY NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGREEMENT (FFA) DELIVERABLES FOR THE MARINE CORPS LOGISTICS AGENCY
BASE. BARSTOW
1. 2. 3. 4. 5. «. 7
CORRESPONDENCE.
RECOMMENDATION
12/12/91 5 1 - 0048
PROPOSED REVISION FOR SAMPLING STRATEGY FOR RI/FS ACTIVITIES US ENVIRONMENTAL PROTECTION AGENCY NFEC MCLB RWOCB DTSC. ft US EPA 1.2 3.4 5.6 7
AT MCLB. BARSIOW
REPORT. USGS DATABASE 12/70/91 14. 0064 DATABASE OF USGS WELLS IN BARSTOW VICINITY AND DATABASE FOR US GEOLOGICAL SURVEY
UNIVERSE OF CHEMICALS OF CONCERN
NAVAL FACILITIES ENGINEERING
COMMAND
MARCH X. 1996
25
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT.OOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS RWOCB
12/31/91 5? . 0051
REVIEW OF ADDENDUM SAMPLING AND ANALYSIS PLAN FOR OUl 1/2/3/4 REGIONAL WATER QUALITY CONTROL
AND FINAL DATA MANAGEMENT PLAN FOR Rl/f S AT MCLB. BARSTOW BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
17.3.4
COMMENTS. RWOCB
12/31*1 52. 0059 REVIEWOF THE WASTE MANAGEMENT PLAN RI/FS MCLB. BARSTOW REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING
BOARD COMMAND
1.2.3.4.5.8.7
PLAN. OAPP
116/92 • 43. 000? QUALITY ASSURANCE PROJECT PLAN FOR RI/FS APPENDIX A FOR JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC « US EPA 1 2
MCLB BARSTOW
REPORT. ANALYTICAL
1/6/92 17 . OOJ2 ANAL YTICAl REPORT DATED DECEMBER 1991. WELL NOS SANDS CALGON CARBON CORPORATION
I Wit NCI)
NAVAL FACILITIES ENGINEERING
CORRESPONDENCE
RECOMMENDATION
1(6/92 51 . 003? PROPOSED REVISION FOR SAMPLING STRATEGY FOR RI/FS ACTIVITIES US ENVIRONMENTAL PROTECTION AGENCY Nf EC DISC S RWOCB
AT MCLB BARSIOW
1 2.3458.7
COMMENTS. EPA
. 0044 REVIEWOF THE FINAL ADDENDUM. SAMPLING AND ANALYSIS PLAN FOR US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
OUl 1 AND 2. AND WASTE MANAGEMENT PLAN. FOR RI/FS AT MCLB. COMMAND
BARSTOW
1.2
COMMENTS. DISC
1/6/92 52 . 0048
RE VIE W OF THE FINAL AMMENDMENT TO THE SAMPLING * ANALYSIS OEPT Of TOXIC SUBSTANCES CONTROL
PLAN FOR OUi 1 AND 2 FOR MCLB, BARSTOW
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
MEETING NOTES
1/13/92 51 . 0022
PROJECT MANAGERS TELE-CONFERENCE CALL HELD ON 1/13/9?. RE NAVAL FACILITIES ENGINEERING COMMAND US EPA. DTSC » RWOCB
OUl I&2 STAGE A. Oil 4 SAMPLING PLAN. REDUCED SAMPLING
REQUIREMENTS i FEDERAL FACILITIES AGREEMENT SCHEDULE
1.2.4
CORRESPONDENCE
1/15/92 81 . 0011
REGARDING CHANGES TO THE AMENDMENT OF THE SAMPLING » NAVAL FACILITIES ENGINEERING COMMAND OS ENVIRONMENTAL PROTECTION
ANALYSIS PLAN WHICH COULD RESULT IN REDUCED FIELD WORK. LAB AGENCY
TIME AND PROJECT COSTS
12.4
CORRESPONDENCE
1/17/92 51 . 0018 WELL LOGS OF A WELL IN NEBO AREA DRILLED 5/26*6 THRU 8/7«6 US GEOLOGICAL SURVEY
PUBLIC RELEASE
MARCH 30. 1998
?6
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT DOC» SUBJECT AUTHOR ADDRESSEE
TECHNICAL MEMORANDUM 1117/92 51 . 0043 SEISMIC REFLECTION/REFRACTION SURVEY DURING JULY 1991. JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC * US EPA 1.2
TECHNICAL MEMORANDUM TM 0002 FOR MCIB. 8ARSTOW
COMMENTS. EPA 1117*92 52. 0046 REVIEW Of RI/FS RCRA. AND UNDERGROUND STORAGE TANK US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 1.2.34.5.6.7
ACTIVITIES FINAL DATA MANAGEMENT PLAN FOR MCLB. BARSTOW COMMAND
PLAN. HEALTH s SAFETY 2/3/92 •
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS EPA
3/13/92 52 . 0043
REVIEW OF THE REVISED QUALITY ASSURANCE PROJECT PLAN FOR US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
RI/FS AT MCLB. BARSTOW COMMAND
17.3.4.5.97
PLAN. SAMPLING S ANALYSIS
3/16/9? 41 . 001? SAMPLING PUBLIC AND PRIVATE SUPPLY WATER WELLS. YERMO AND JACOBS ENGINEERING GROUP INC
DAGGETT AREAS (VOL 1 OF 2)
NFEC. MCLB. RWQCB OTSC. * US EPA 1
PLAN. SAMPLING S ANALYSIS 3/16/92 . 42 . 0013
SAMPLING PUBLIC AND PRIVATE SUPPLY WATER WELLS YERMO AND JACOBS ENGINEERING GROUP INC
DAGGET7 AREA (VOL 2 OF 2|
NFEC MCIB. RWOCB DTSC. 8 US EPA 1
PUBLIC COMMUNICATION PRES
RELEASE
3/26/92 95 . 0010
"CONTAINMENT AND TREATMENT OF SOLVENT SPILL ON MARCH 18.
1992. AT YERMO"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
1.2
PUBLIC COMMUNICATION. PRES 3/26/92 95 . 0011 'TOXIC DECREASING SOLVENT (PCE) SPUl AT YERMO DEPOT MARCH SAN BERNARDINO SUN
RELEASE 18. 1992"
PUBLIC RELEASE
1.7
REPORT. ORGANIC CHEMICAL 3/26/92 61 - 0028 ORGANIC CHEMICAL ANALYSES REPORT ON SAMPLES DATED 3/13/92 TRUESOAH LABORATORY INC
ANALYSIS
1.2
MEETING AGENDA
3/26/92 51 . 0042 LETTER ENCLOSING MEETING NOTIFICATION AND OVERVIEW OF NAVAL FACILITIES ENGINEERING COMMAND MCLB. US EPA. DMS. » RWQCB
PROJECT COSTS FOR RI/FS. MCLB. BARSTOW
1.7.3.4.5.87
CORRESPONDENCE
3/30/92 13 1 . 0005
FOLLOW UP ON PROPOSALS FROM MARCH 23. 1992 MEETING RE
DISPUTE RESOLUTION FOR MCAS EL TORO AND MCIB BARSTOW
CROSS REFER* 5 1
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
1.2.3.
REPORT. ANALYTICAL
4/2/92 17- 0019 ANALYTICAL REPORT DATED MARCH 1992. WELL NOS 3 AMDS (W/ENCl) CALGON CARBON CORPORATION NAVAL FACILITIES ENGINEERING
1.2
COMMENTS. EPA
4/6/92 52. 0012 REVIEW OF NEESA REQUIREMENTS FOR ANALYTICAL DATA AND DATA US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 12345.67
VALIDATION AT MCLB BARSTOW COMMAND
MARCH 30. 1998
?8
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT. DOCl SUBJECT AUTHOR ADDRESSEE OP UNIT
PERMIT 4/8/92 54. 0001 DRILLING PERMITS FROM COUNTY OF SAN BERNARDINO. OEPT OF JACOBS ENGINEERING GROUP INC OEPT OF HEALTH SERVICES « MCLB U
ENVIRONMENTAL HEALTH SERVICES
ARARS 4/8/92 82 . 0004 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR REGIONAL WATER QUALITY CONTROL DEPT OF TOXIC SUBSTANCES 1234587
THE RI/FS. MCLB. BARSTOW BOARD CONTROL
COMMENTS. RWOCB 4/8/92 ' 52 - 0042 REVIEW OF TECHNICAL MEMORANDUM TM-0002 AND TM«X>3. RI/FS. REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING 1234587
MCLB. BARSTOW BOARD COMMAND
COMMENTS. DTSC 4/8/92 52. 0082 RE VIE W OF TECHNICAL MEMORANDA TM-OCO? AND TM-0003. MCLB. OEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 1.2.3.4.5,8.7
BARSTOW COMMAND
MEETING MOTES 4/9/92 51 . 0012 PROJECT MANAGERS MEETING NOTES HELD ON 4/910/92 RE NAVAL FACILITIES ENGINEERING COMMAND US EPA DTSC « RWOCB 17.3.4.5.8.7
GEOPHYSICAL S SOIL GAS SURVEYS. FIELD AUDITS. DATA 4 WASTE
MANAGEMENT. OUl 1/2 GROUNDWATER STAGE MB. USGS STATUS.
PERMIT 4/13/92 54 . 0004 DRILLING PERMITS FROM THE COUNTY OF SAN BERNARDINO DEPT OF JACOBS ENGINEERING GROUP INC DEPT OF HEALTH SERVICES«MCLB I.?
ENVIRONMENTAL HEALTH SERVICES
COMMENTS. DTSC 4/29/92 96. 0001 REVIEW ON DRAFT FACT SHEET FOR MCLB. BARSTOW DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 1.2.3.4.5.8.7
COMMAND
PUBLIC COMMUNICATION. NEW! 4/30/92 95. 0038 "SOLVENT SPILL CLEAN UP AT YERMO ANNEX DOMESTIC TREATMENT MCLB BARSTOW TODAY PUBLIC RELEASE 1.2
ARTICLE PLANT SHOWING PROGRESS'
MEETING NOTES 5/5/92 51 . 0050 PROJECT NOTE 123- TELE-CONFERENCE CALL WITH BUREAU OF LAND JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. S US EPA M
MANAGEMENT
PLAN. WASTE MANAGEMENT 5/11/92 45. 0004 PROJECT NOTE 133 • INVESTIGATION-DERIVED WASTEWATER S JACOBS ENGINEERING GROUP INC NFEC S MCLB 1.234567
DISPOSAL OPTION TELECONFERENCE BETWEEN JEG » RWOCB HELD
ON 5/11/92. RE TREATED IOW WATER DISPOSAL OPTIONS * ANALYSIS
29
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT nrPE DATE CAT - DOC* SUBJECT AUTHOR ADDRESSEE OP UNIT
MEETING NOIES in 3/9? 51 . OO44 PROJECT MANAGERS TELE CONFERENCE MEETING NOTES HELD ON NAVAL F ACUITIES ENGINEERING COMMAND US EPA, DTSC 4 RWQCB 12
5/13/92. RE OUl 142 STAGE AtB WELL LOCATIONS FIELD AUDITS.
YERMO SLUDGE REMOVAL. WASTE MANAGEMENT t, OFF-SITE
COMMENTS. RWQCB 5/13/92 52. 0054 REVIEW OF THE WORK PLAN FOR SAMPIING PUBLIC AND PRIVATE REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING 17
WATER SUPPLY WELLS. YERMO AND DAGGETT AREA BOARD COMMAND
PUBLIC COMMUNICATION S/18/92 • 93. 0001 PROJECT NOTE 136 • UPDATED MAILING LIST FOR PUBLIC JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC * US EPA 1234567
PARTICIPATION IN RI/FS ACTIVITIES AT MCLB. BARSTOW
COMMENTS DTSC V76/92 52- 0053 REVIEW OF THE WORK PLAN FOR SAMPLING PUBLIC AND PRIVATE REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING 12
SUPPLY WATER WELLS. YERMO AND OAGGETT AREAS FOR MCLB. BOARD COMMAND
BARSTOW ;
PLAN. RISK ASSESSMENT WORK S/7S/92 48- 0003 DRAFT HUMAN HEALTH » ECOLOGICAL RISK ASSESSMENT WORK PLAN JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWQCB. DTSC. t US EPA 1.2
CORRESPONDENCE. RESPONSE 5/29/92 96. 0003 COMPLIMENTS ON THE OPEN HOUSE/COMMUNITY WORKSHOP HELD DEPT OF TOXIC SUBSTANCES CONTROL MARINE CORPS LOGISTICS BASE 1234567
ON MAY 12. 1992 FOR THE IRP AND RESPONSE TO REQUEST FOR
COMMENTS AND SUGGESTIONS FOR FUTURE COMMUNITY MEETINGS
TECHNICAL MEMORANDUM W9/92 51 . 0039 DRAFT QUALITY ASSESSMENT OF AERIAL PHOTO REVIEW TECHNICAL JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. 4 US EPA 1.2
MEMORANDUM TM-O04 FOR MCLB BARSTOW
PERMIT 6/3/92 54. 0002 PROJECT NOTE 145 - DRILLING AND GROUNDWATER MONITORING JACOBS ENGINEERING GROUP INC OEPT OF HEALTH SERVICES * MCLB 1.2
WELL INSTALLATION PERMIT ON SAN BERNARDINO COUNTY FLOOD
CONTROL DISTRICT PROPERTY
TECHNICAL MEMORANDUM SO/9? 51 . 0116 PRELIMINARY DRAFT RESULTS OF STAGE A GROUNDWATER JACOBS ENGINEERING GROUP MC NFEC MCLB. RWOCB. OTSC. t US EPA 1.2
MONITORING WELL « PIEZOMETER INSTALLATION DURING FEBRUARY
TO MARCH 1992. TECHNICAL MEMORANDUM 5. FOR OUt 1 « 2 (VOL 1 OF
TECHNICAL MEMORANDUM 6/3/92 ' 51- 0117 PRELIMINARY DRAFT RESULTS OF STAGE A GROUNDWATER JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB, DTSC. « US EPA '.2
MONITORING WELL » PIEZOMETER INSTALLATION DURING FEBRUARY
TO MARCH 1992. TECHNICAL MEMORANDUM 5. FOR OUl 1 « 2 (VOL 2 OF
MARCH 30. 1998
30
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MARCH 30. 1996
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
TECHNICAL MEMORANDUM
6/3/92 51 . 0118
PRELIMINARY DRAFT RESULTS OF STAGE AGROUNOWATER JACOBS ENGINEERING GROUP INC
MONITORING WELL « PIE/OME TER INSTALLATION DURING FEBRUARY
TO MARCH 1992 TECHNICAL MEMORANDUM 5. FOR OUl 1 & 2 (VOL 3 OF
NFEC. MCLB. RWQCB. DTSC. * US EPA V2
CORRESPONDENCE
6/10192 5 1 . 0240
ATTORNEY'S IE HER EXPRESSING CONCERN RE CIRCULATION OF RUTTER AND WllBANKS CORPORATION
REVIEWS OF SEISMIC REPORT (BISON INSTRUMENTS LETER ATTACHED)
JACOBS ENGINEERING GROUP 1.2.3.4.5.87
MEETING NOTES
6/22/92 ' 51. 0051
PROJECT NOTE 133 - INVESTIGATION DERIVED WASTE SOILS JACOBS ENGINEERING GROUP INC
MANAGEMENT AND DISPOSAL OPTION. TELE-CONFERENCE CALL HELD
ON 6/22/92. WITH JEG. EPA 4 RWQCB
NFEC. MCLB. RWOCB. DTSC. » US EPA 1.2
TECHNICAL MEMORANDUM
7M/92 5 1 . 0052
PRELIMINARY DRAFT STAGE B GROUNOWATER INVESTIGATION PLAN
OUl I AND 2. TECHNICAL MEMORANDUM TM-0006
JACOBS ENGINEERING GROUP INC NFEC. MCLB RWOCB OTSC. » US EPA 1.2
REPORT, GROUNDWATER
7/10/92 64 . 0018
PROJECT NOTE 15' • FIRST QUARTERLY GROUNDWATER
MEASUREMENTS « CONFIRMATION OF BASELINE GROUNDWATER
MONITORING DATA
JACOBS ENGINEERING GROUP INC NFEC MCLB RWQCB. OTSC. » US EPA 1.2
PERMIT
7/16/92 5« - 0005
PROJECT NOTE 166 - DRILLING PERMIT APPLICATION. BACKGROUND
FOR THE SAN BERNARDINO COUNTY FOR STAGE B GROUNDWATER
MONITORING WELLS LOCATED WITHIN BASE BOUNDARIES
JACOBS ENGINEERING GROUP INC DEPT OF HEALTH SERVICES 4 MCLB 1.2
PLAN. SAMPLING « ANALYSIS 7/16/92 4 2 . 0022
PROJECT NOTE 153 • SAMPLING AND ANALYSIS OF GROUNOWATER
FOR TOTAL METALS
JACOBS ENGINEERING GROUP MC NFEC. MCLB. RWOCB. DTSC * US EPA 1.2
COMMENTS RESPONSE
7/31/92 S3 - 0012
PROJECT NOTE 162 • RESPONSE TO AGENCY COMMENTS ON MARCH
16. 1992 WORK PLAN FOR SAMPLING PUBLIC AND PRIVATE SUPPLY
WELLS
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. « US EPA 1.2
REPORT. USGS DATABASE B/10/92 14 . 0065
WATER CHEMISTRY FROM USGS DATABASE • MULTIPLE STATION
ANALYSES
US GEOLOGICAL SURVEY
MARINE CORPS LOGISTICS BASE
1.2
MEETING NOTES
8/13/92 51 . 0053 PROJECT NOTE 222 - PROJECT MANAGERS' TELE-CONFERENCE CALL. JACOBS ENGINEERING GROUP MC
HELD ON 6/13/92. RE PUBLIC/PRIVATE WELLS. STAGE B INVESTIGTION.
Rl PHASE 1. BLDG 573. DESERT MIX. GEOPHYSICS I YERMO SLUDGE
NFEC. MCLB. RWOCB. OTSC. » US EPA 1.2 3 < 5.6 7
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NOTES
8/14/92 5 1 - 0054
PROJECT NOTE 221 • MINUTES Of PROJECT MANAGERS TELE- JACOBS ENGINEERING GROUP INC
CONFERENCE CAIL. HELD ON 8/M/92. RE PUBLIC/PRIVATE WELLS. Rl
PHASE 1. DESERT MIX. YERMO SLUDGE REMOVAL. WASTE
NFEC. MCLB. RWOCB. OTSC. « US EPA 1.2.3.4.5.8,7
REPORT. INVESTIGATION DERIV
WASTE
8/17/92 45 - 0002
PROJECT NOTE 183 • INVESTIGATION DERIVED WASTE FIELD
MANAGEMENT PROCEDURE FOR STAGE B
JACOBS ENGINEERING GROUP INC NFEC MCLB. RWOCB. DTSC. « US EPA 1.2
MEETING NOTES
8/27/92 • 5 1 - 0055
PROJECT NOTE 203 • COORDINATION AND ANALYSES FOR JOINT
SAMPLING OF THE US GEOLOGICAL SURVEY PIEZOMETER CLUSTERS
NEAR THE NEBO ANNEX. SPECIALLY STAGE A
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. » US EPA 2
PLAN. SAMPLING S ANALYSIS 9/7/9? 4 2 - 0071
PROJECT NOTE 204 . SAMPLING AND ANALYSIS OF GROUNDWATER
FOR PHASE I. STAGE B WELLS
JACOBS ENGINEERING GROUP INC NTEC MCLB. RWOCB OTSC. ft US EPA 1.2
REPORT. INVESTIGATION.OERIV
WASTE
9/3/92 64 . 0051
PROJECT NOTE 189 • WASTE MANAGEMENT INVESTIGATION DERIVED JACOBS ENGINEERING GROUP INC
WASTE EFFLUENT WASTEWATER ANALYTICAL RESULTS FROM STAGE A
DRILLING ACTIVITY FOR out i * 2. RESULTS INDICATE THAT THE
NFEC.MClB RWOCB DTSC » US EPA 1.2
REPORT IMVESTIGATION-DERIV
WASTE
9/15/92 82 . 0006
PROJECT NOTE 213 • TELE-CONFERENCE AGREEMENT ON
INVESTIGATION-DERIVED WASTEWATER DISPOSAL
JACOBS ENGINEERING GROUP
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NOTES
10/23/92 5 1 . 005*
PROJECT NOTE 723 • WELl INSPECTION BY SAN BERNARDINO COUNTY JACOBS ENGINEERING GROUP INC
DEPARTMENT OF HEALTH SERVICES
NFEC. MCIB. RWOCB. DTSC. & US EPA 1.2
REPORT. INVESTIGATION DERIV 11/5/92
WASTE
64 - 0022 PROJECT NOTE 225 - INVESTIGATION-DERIVED WASTE SOILS
LABORATORY ANALYTICAL RESULTS FROM 56 STAGE A WELLS AND
PIEZOMETERS (VOL 2 OF 2).
JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC. S US EPA 1.2
REPORT. INVESTIGATION OERIV
WASTE
11/5/92 64 . 0023
PROJECT NOTE 225 • INVESTIGATION DERfVED WASTE SOILS
LABORATORY ANALYTICAL RESULTS FROM 56 STAGE A WELLS AND
PEI2OMETERS (VOL 1 OF 2)
JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB, DTSC. » US EPA 1.2
MEETING NOTES
lift/92 51 - 0059
PROJECT NOTE 230 • PROJECT MANAGERS' MEETING NOTES HELD ON
11/S/92. RE YERMO SLUDGE REMOVAL. RCRA, STRATEGY FOR SOU.
SITE DATA. PROJECT BUDGET. WASTE MANAGEMENT. OUl 142
JACOBS ENGINEERING GROUP INC Nf EC. MCIB. RWOCB. OTSC. * US EPA 12.34567
PLAN. OAPP
11/12(92 43 . 0004
FINAL QUALITY ASSURANCE PROJECT PLAN APPENDIX A FOR
SAMPLING AND ANALYSIS PLAN FOR REMEDIAL INVESTIGATION
/FEASIBILITY STUDY
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. ft US EPA 1.2
MEETING NOTES
11/13/92 51 - 0060
MEETING NOTES HELD ON 11/13/93 BETWEEN USGS. NAVY « JACOBS
COOPERATIVE SAMPLING WELL EFFORTS
JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC. « US EPA 1.2
REPORT, GROUNDWATER 11/16/9? 51 . 0061 SU8MITTAL OF RESULTS FROM 56 STAGE A WELLS. VOt I AND II. MARINE CORPS LOGISTICS BASE
DATED lt/S/92
US EPA. OTSC. « RWOCB
1.2
GUIDANCE. STATE
11/20/92 32 - 0002 WELL DESTRUCTION. COMPLIANCE REQUIREMENTS
SAN BERNARDINO COUNTY JACOBS ENGINEERING GROUP INC
ENVIRONMENTAL HEALTH SERVICES
1.2
MEETING NOTES
11/25/92 51 - 0062
PROJECT NOTE 236 - PROJECT MANAGERS TELE-CONFERENCE CALL. JACOBS ENGINEERING GROUP INC
HELD ON 11/25/92 RE EE/CA FOR YERMO SLUDGE REMOVAL. RCRA.
PCE SPILL, CAOC 16 BOUNDARIES. SCHEDULE OF DATA. SPILL
NFEC, MCIB. RWOCB. DTSC. ft US £ PA 1.2.3 4.5 8.7
REPORT. GROUNDWATER
12/1/92 51 - 0063
RESULTS OF WELL TESTING ON PRIVATE PROPERTY AND THE INTERIM MARINE CORPS LOGISTICS BASE
ACTION TO SUPPLY BOTTLED WATER TO OFF-BASE RESIDENTS
OFF-BASE RESIDENT
1.2
MARCH 3O. 1998
33
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
OA1E CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NO1ES
12/4(9? 51 . 0065
PROJECT NOTE 7 • REMEDIAL PROJECT MANAGERS MEETING NOTES. JACOBS ENGINEERING GROUP INC
HELD ON 12/4/92. RE USGS UPDATE OUi 5*6 SAMPLING PROPOSAL.
COMMUNITY RELATIONS. YERMO SLUDGE REMOVAL. 4 CAOL 16
NFEC. MCLB. RWQCB. DTSC. ft US EPA 1.2.3.4.5.67
CORRESPONDENCE.
GROUNDWATER
12/11/92 51 . 0245
TRANSMITTAL FOR COMMENTS OF FINAL DRAFT TO GROUNDWATER MARINE CORPS LOGISTICS BASE
REMEDIATION ASSESMENT FOR OUI AND 2
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . OOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
1/75/93 5 t . 0071
LETTER ON THE CONNECTION Of THE PRIVATE PROPERTY TO MCLB'S MARINE CORPS LOGISTICS BASE
WATER SYSTEM. AND AUTHORIZATION TO PROCEED FROM PROPERTY
OWNER
OFF BASE RESIDENT
1.2
COMMENTS. RWOCB
1/25/93 52 . 0X4
REVIEW OF THE DRAFT WATER REMEDIATION ASSESSMENT TECHNICAL REGIONAL WATER QUALITY CONTROL
ME MORANDUM 8. DATE D 13192 BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
REPORT. INVESTIGATION.DERM
WASTE
1/26/93 ' 64 . 0040
PROJECT NOTE 238 . STAGE A/8 INVESTIGATION DERIVED WASTE
EFFLUENT WATER INDICATING THE TREATED WATER MEETS STATE
AND FEDERAL DRINKING WATER STANDARDS
JACOBS ENGINEERING GROUP INC
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
PUBLIC COMMUNICATION. NEW?
ARTICLE
1/27/93 95 . 0043 -RIVER FLOWERINGS WELL LEVELS UP'
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
1.2
CORRESPONDENCE. REQUEST 1/79/93 Si . 0077 REQUEST TO SIGN AGREEMENT FOR INSTALLATION AND MAINTENANCE MARINE CORPS LOGISTICS BASE
OF WELL EQUIPMENT ON PRIVATE PROPERTY
OFF BASE RESIDENT
1.2
CORRESPONDENCE
2/5/93 9 1 . 0001
TRANSMIT!Al. OF FACT SHEET ON TCE AND THE INSTALLATION
RESTORATION PROGRAM TO A PRIVATE CITIZEN WHO LIVED ON
PROPERTY WITH A WELL SUSPECTED OF BEING CONTAMINATED WITH
MARINE CORPS LOGISTICS BASE OFF-BASE RESIDENT
1.2
MEETING NOTES
2/W93 51 . 0073
PROJECT NOTE 8 • NOTES OF REMEDIAL PROJECT MANAGERS' JACOBS ENGINEERING GROUP INC
MEETING. HELD 2/8-10/93. RE OU« 1&2 GROUNDWATER. GEOPHYICAL »
SOIL GAS SURVEYS. CHEMICAL CONCERNS. OU« 5«6 OBJECTIVES 8.
NFEC. MCLB. RWOCB. DTSC. » US EPA 1.2.3.4.5.8.7
CORRESPONDENCE.
GROUNDWATER
2/11/93 52 - 0284
COMMENTS ON GWOUNDWATER REMEDIATION ASSESSMEENT TECH US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
MEMO (TM-0008). OU 1 AND 2
1.2
COMMENTS. OTSC
2/16/93 52 . 0085
REVIEW OF DRAFT GROUNOWATER REMEDIATION ASSESSMENT.
TECHNICAL MEMORANUM 8. DATED 12/92
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS. EPA
3/2/93 52 . 0069
REVIEW OF THE DRAFT GROUNDWATER REMEDIATION ASSESSMENT. US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
TECHNICAL MEMORANDUM 0008. OUl 1*2. DATED 12/92 COMMAND
MARCH 30. 1998
35
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . DOC« SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. INVESTIGATION DERIV
WASTE
3/15/93 64 . 0039
PROJECT NOTE 25? • STAGE B INVESTIGATION DERIVED WASTE
ANALYTICAL RESULTS
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL 1.2
BOARD
MEETING NOTES
3/17/93 S 1 . 0074
PROJECT NOTE 10 • REMEDIAL PROJECT MANAGERS' MEETING NOTES. JACOBS ENGINEERING GROUP INC
HELD ON 3/17/93. RE PROPOSAL NO FURTHER ACTION CAOCs. BLOC
573 MAY BE OU 8 . WASTE MANAGEMENT. OUt 3/4 PHASE 2 PLANNING
NFEC. MCLB. RWOCB. DTSC. I US EPA 1.2.3.4.5.6.7
REPORT. ANALYTICAL DATA 4/S/93 . 64 . 0041
OCTOBER 1992 ANALYSIS RESULTS FOR 6 PRIVATE AND 2 YERMO
ANNEX WELLS
MARINE CORPS LOGISTICS BASE US EPA. DTSC. * RWOCB
1.2
CORRESPONDENCE. REQUEST 4/9/93 81 . 0020
REQUEST TO REVIEW THE SCOPE OF WORK FOR THE ENGINEERING
EVALUATION/COST ANALYSIS AND CURRENT Rt/FS WORK BY OS/07/93
AND INCLUDES LIST OF TECHNICAL INFORMATION
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
REPORT. GROUNDWATER
4/70/93 81 . 0017
PROJECT NOTE 278 WELL DEVELOPMENT. SPECIFICALLY WELL
LOCATION AND CROUNDWATER ELEVATION DATA TO USGS. STAGE.B.
YERMOANNEXANDNEBO
JACOBS ENGINEERING GROUP INC US GEOLOGICAL SURVEY
12
CORRESPONDENCE.
GROUNOWATER
4/29/93 54 . 0015
TRANSMITTAI OF FULLY EXECUTED COPY OF RIGHT OF ENTRY PERMIT SOUTHWEST DIVISION
TO AUTHORIZE DRILLING GROUNDWATER TEST WELL ON PRIVATE
PROPERTY (W/ENCl)
M/MSIIER
1.2
REPORT. ANALYTICAL DATA 5/6/93 6 1 - 0019
PROJECT NOTE 282 • RI/FS OU» 1. 2. 3. 4. S. S 6 PHASE 1 GROUNDWATER JACOBS ENGINEERING GROUP INC
t SOIL ANALYTICAL LABORATORY RESULTS
NFEC. MCLB. FtWQCB. OTSC. I US EPA 123458
MEETING NOTES
5/6/93 51 - 0077
PROJECT NOTE 124 - PHONE CONVERSATION ON GROUNDWATER
MONITORING WELL INSTALLATIONS RE PHASE 1 STAGE B FIST 40
MONITORING WELL LOCATIONS
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC. * US EPA 1.2
CORRESPONDENCE. PERMIT 5/17/93 54 . 0014
2ND REQUEST FOR PERMISSIO TO DRILL A TEST WELL ON PRIVATE
PROPERTY (WTO ENCL|
SOUTHWEST DIVISION
R APPLING
1.2
CORRESPONDENCE
S/18/93 64.0104 PHASE I GROUNOWATER AND SOIL ANALYTICAL OATA FOR RI/FS OLT» 1 MARINE CORPS LOGISTICS BASE. BARSTOW US EPA OTSC. RWOCB
THRU 7 DATED MAY 6. 1993
1.7345.8.7
MARCH 30. 1998
36
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . OOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NOTES
5/19/93 5 1 . 0083
PROJECT NOTE 29 - MEETING NOTES FOR REMEDIAL PROJECTS JACOBS ENGINEERING GROUP INC
MANAGERS HELD ON 5/19-20/93. RE BLDG 573. DATA MANAGEMENT «
YERMO SLUDGE REMOVAL
NFEC. MCIB. RWOCB. DTSC. « US EPA 1.2.3.4.5.6.7
ENFORCEMENT. BOARD ORDER 7/1/93 16 - 0013
BOARD ORDER DISCHARGE REQUIREMENTS FOR LAND DISPOSAL OF REGIONAL WATER QUALITY CONTROL
TREATED GROUNOWATER «6-93-106 BOARD
MARINE CORPS LOGISTICS BASE
1.2
MEETING NOTES
""93 ' 51 - 0080
PROJECT NOTE 30 - MINUTES OF REMEDIAL PROJECT MANAGERS
MEETING HELD 7/1/93. RE RISK BASED CRITERIA. OUl 1«2
GROUNDWATER. OUl 5*6 REVISIONS » PROJECT SCHEDULE
JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. DTSC. » US EPA 1.2.5.6
CORRESPONDENCE. COMMENT! 7/OT3 52 . 0278
FAX RESPONSE TO REQUEST FOR REVIEW OF SAMPLE RESULTS FROM DEPT OF TOXIC SUBSTANCES CONTROL
6 DOMESTIC WELLS NEAR MCLB. DATED OCTOBER 1992
12
CORRESPONDENCE. WASTE 7/12/93 1 7 . 0034
REQUEST CONCURRENCE ON PROJECT NOTE 269. WASTE
MANAGEMENT. OUl AND 2 PHASE 1. STAGE B (IRP RI/FS STUDY
PROJECT NOTE) (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION 1.2
AGENCY
CORRESPONDENCE. WASTE 7/12/93 5 I . 0243
TRANSMITSAL FOR COMMENTS OF IRP RI/FS PROJECT NOTE 269 RE MARINE CORPS LOGISTICS BASE
WASTE MANAGEMENT. OU 1 AND 2 PHASE 1. STAGE B. WELLS IOW SOUS
ANALYTICAL RESULTS AND RECOMMENDATIONS (W/O ENCL)
VARIOUS AGENCIES
1.2
CORRESPONDENCE. PERMIT 7/13/93 54 . 0007
REQUEST PERMIT TO ALLOW JACOGS ENGR TO DRILL TEST WELL ON SOUTHWEST DIVISION
PROPERTY TO DETERMINE QUALITY OF GROUNDWATER IN VICINITY OF
MCLB
O JOHNSON AND MM WRIGHT
1.2
CORRESPONDENCE. PERMIT 7/13/93 54 . 0011
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY SOUTHWEST DIVISION
(W/O ENCL. RIGHT OF ENTRY PERMIT)
K AMOUR
1.2
CORRESPONDENCE. PERMIT 7/13/93 54 . 0012 REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY SOUTHWEST DIVISION
(W/O ENCL RIGHT OF ENTRY PERMIT)
0 JOHNSON AND M/M WRIGHT
1.2
CORRESPONDENCE. PERMIT 7/13/93 54 . 0013 REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY SOUTHWEST DIVISION
(W/O ENCL. RIGHT OF ENTRY PERMIT)
R ARIAS
1.2
MARCH 30. 1998
37
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . OOCt SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NOTES
8/5/93 ; 1 . 0079
PROJECT NOTE 3 . REMEDIAL PROJECT MANAGERS MEETING HE 10 8/5- JACOBS ENGINEERING GROUP INC
6/93. RE OU> It? PHASE 2 PLANNING. OUl 546 WORK PLAN REVISIONS
NFEC MCLB. RWOCB. DTSC. ft US EPA 1.2.5.8
MEETING NOTES
8/13/93 51 . 0092
PROJECT NOTE 8 - MEETING NOTES BETWEEN JACOBS ENGINEERING JACOBS ENGINEERING GROUP INC
AND THE REGIONAL WATER QUALITY CONTROL BOARD RE
INVESTIGATION DERIVED WASTE SOILS MANAGEMENT FOR OPERABLE
NFEC. MCL8. RWOCB. DTSC. » US EPA 1,2.5.8
MCE TING NOTES
8/19/93 . 51 . 0082
PROJECT NOTE 2 - INVESTIGATION DERIVED WASTE MANAGEMENT JACOBS ENGINEERING GROUP INC
APPROACH FOR OU> 5»6
NfEC. MCLB. RWO.C8. DTSC. « US EPA 1.2.5.9
REPORT. GROUNDWATER
8/24/93 64 . 0028 WEIL SAMPLING REPORT ON OFF-BASE GROUNDWATER
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT
1.1
MEETING NOTES
9/2/93 SI . 0087 PROJECT NOTE 318-REMEDIAL PROJECT MANAGERS MEETING NOTES JACOBS ENGINEERING GROUP INC
HELD 9/2/93. RE ECOLOGICAL RISK ASSESSMENT * BLDG 573 PLANNING
NFEC. MCLB. RWOCB. DTSC. » US EPA 1.2.5.8
TECHNICAL MEMORANDUM 9/2*93 51 . owe
DRAFT SEPTEMBER 1992 GROUNDWATER SAMPLING RESULTS
OPERABLE UNITS 1 AND 2 TECHNICAL MEMORANDUM 0013
JACOBS ENGINEERING GROUP WC NFEC. MCLB. RWOCB. OTSC. 8 US EPA 1.2
TECHNICAL MEMORANDUM 9/79/93 51 . 0088
DRAFT JUNE 1993 GROUNDWATER SAMPLING RESULTS OPERABLE
UNITS 1 AND 2 TECHNICAL MEMORANDUM 0011
JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. OTSC. S US EPA 1.2
CORRESPONDENCE.
GROUNDWATER
10/12/93 42- 0041 REQUEST FOR COMMENTS TO Rl/FS DRAFT PHASE II FIELD SAMPLING MARINE CORPS LOGISTICS BASE
WORK PLAN FOR OU 1 AND 2 (REGIONAL GROUNDWATER). DATED
OCTOBER IS. 1993 (W/0 ENCl)
VARIOUS AGENCIES
1.J
CORRESPONDENCE. COMMENT: 10/12/93 4;. 0044 REQUEST FOR COMMENTS TO RI/FS DRAFT PHASE 11 FIELD SAMPLING MARINE CORPS LOGISTICS BASE
WORK PLAN FOR OU 1 AND 2. DATED 10/15/93
VARIOUS AGENCIES
1.2
PLAN. QAPP
10/15/93 43. 0005 PROJECT NOTE 312 • ELIMINATION OF SPECIFIC CHEMICALS FROM THE JACOBS ENGINEERING GROUP MC
CHEMICALS OF CONCERN AND THE PROJECT TARGET ANALYTE LIST
NFEC. MCLB. RWOCB DTSC. * US EPA 1.2.3 4 5.6 7
MARCH 30. 1998
38
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
PLAN. RVFS WORK
1CV15/93 4} . 0018
RI/FS DRAFT PHASE II FIELD SAMPLING (WORK) PLAN FOR OPERABLE JACOBS ENGINEERING GROUP INC
UNIT SI AND 2
NFEC. MCLB. RWOCB DTSC. » US EPA 1.2
REMOVAL ACTION
11/3/93 J1 . 0071 ON-SITE COORDINATOR REPORT . REMOVAL ACTION OF JACOBS ENGINEERING GROUP INC NFEC MCIB RWOCB DTSC » US EPA 2
TRICHLOROETHENE CONTAMINATED OFF-BASE WELL AT NEBO ANNEX
MEETING NOTES
11/4/93 51 . 0090 PROJECT NOTE 322 -REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC * US EPA 1734
HELD 11/4793. RE PERSONNEL CHANGES. BLOC 573. OUl 142
GROUNOWATER FIELD SAMPLING. YERMO SLUDGE REMOVAL » USGS
REPORT. INVESTIGATION-OERIV 11/9/93 45. 0003 PROJECT NOTE 3J1 • INVESTIGATION-DERIVED WASTE SOIL FOR JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC * US EPA 1.2
WASTE MONITORING WELLS V7-1 ANOYB-1 TO DISCHARGE CUTTINGS WITH
OTSC CONCURRANCE
TECHNICAL MEMORANDUM H/9/93 51 . 0047 DRAFT RESULTS OF STAGE B GROUNDWATER INVESTIGATION JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC. * US EPA I.I
TECHNICAL MEMORANDUM 1? OUl 1/7
TECHNICAL MEMORANDUM 11/9/93 51 . 0089 DRAFT JANUARY 1993 GROUNDWATER SAMPLING RESULTS OU» 1/2 JACOBS ENGINEERING GROUP INC Nf EC MCIB RWOCB DTSC * US EPA 1.2
TECHNICAL MEMORANDUM 15
CORRESPONDENCE.
GROUNDWATER
11/16/93 1 7 . 0033 REQUEST FOR COMMENTS TO DRAFT JANUARY 1993 GROUNOWATER MARINE CORPS LOGISTICS BASE
SAMPLING RESULTS OUl AND 2 TECHNICAL MEMO TM-001S. NOVEMBER
9. 1992 (W/O ENCL)
VARIOUS AGENCIES
1.2
TECHNICAL MEMORANDUM
11/16/93 51 . 0111 SUBMITTAl OF DRAFT GROUNDWATER SAMPLING RESULTS OPERABLE MARINE CORPS LOGISTICS BASE
UNITS 1 AND 2 TECHNICAL MEMORANDUM 15 DATED NOVEMBER 9. 1993
US EPA. OTSC. & RWOCB
1.2
COMMENTS. EPA
12/1/93 52 . 0076
REVIEW OF THE DRAFT PHASE I REMEDIAL INVESTIATION REPORTS
OUl UNITS 3S4. DATED 9/93. DRAFT PHASE II RI/FS OUl 344 FIELD
SAMPLING PLAN. TECHNICAL MEMORANDUM 10. DATED 5/93. AND
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.7.3.4
COMMENTS. DTSC
12/2/93 52 . 0075
REVIEW OF THE DRAF T PHASE II RVFS SAMPLING WORK PLAN FOR OUl OEPT OF TOXIC SUBSTANCES CONTROL
112. DATED 10/93
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
MARCH 30. 1998
39
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NO1ES
12/8/93 94 . 0005
PROJECT NOTE 330 - TECHNICAL REVIEW COMMITTEE MEE TING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 12/06/93 AT THE MARINE CORPS LOGISTICS BASE. BARSTOW
NFEC. MCLB. RWOCB. DTSC. » US EPA 1.2.3.4.5.8.7
COMMENTS. RWOCB
12/15/93 52 . 0077 REVIEWOF RlffS DRAFT PHASE 2 FIELD SAMPLING (WORK) PLAN. REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING
DATED 10/93. AND REQUESTS INFORMATION BY 01/16*4 BOARD COMMAND
1.2
PLAN. HEALTH ft SAFETY
1/5/94 • 46 . 0004 HEALTH AND SAFETY PLAN FOR GROUNDWATER EXTRACTION PILOT JACOBS ENGINEERING GROUP INC
STUDIES AT YERMO ANNEX
NAVAL FACILITIES ENGINEERING
COMMAND
t.2
CORRESPONDENCE. REQUEST 1/7/94 81 . 0021 REQUEST FOR CONCURRENCE TO CONDUCT AN AQUIFER PUMP TEST MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
1.2.3.4
CORRESPONDENCE. APPROVAL 1/19/94 a 1 . 0022 WRITTEN APPROVAL TO CONDUCT AN AQUIFER PUMP TEST WITH REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
GUIDELINES BOARD
1.2
MEETING NOTES
2/4/94 51 - 0115
PROJECT NOTE 338 • REMEDIAL PROJECT MANAGERS' MEETING HELD JACOBS ENGINEERING GROUP INC
ON 02/04/94. RE PERSONNEL CHANGES. CHEMICALS OF CONCERN.
PHOT GROUNOWATER EXTRACTION STUDY. AGENCY COMMENTS ON
NFEC. MCLB. RWOCB. DTSC. ft US EPA 1.2.3.4.5.87
REPORT. GROUNOWATER
2/9/94 64 . 0048
PROJECT NOTE 334 • QUARTERLY SAMPLING * OFF-SITE WELLS
DRILLING. INVESTIGATION DERIVED WASTE EFFLUENT WATER
JACOBS ENGINEERING GROUP INC NFEC » MCLB
1.2
MEETING NOTES
3/10/94 51 . 0113 PROJECT NOTE 345-REMEDIAL PROJECT MANAGERS'MEETING HELD JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC ft US EPA 1.2J.4.5.8.7
ON 3/10-11/94. PCB STORAGE AREA. FUNDING. PROGRAM SCHEDULE.
PHASE 2 PLANNING. YERMO REMOVAL ACTION STUDY. RCRA FACILITY
COMMENTS RESPONSE
3/16/94 S3 . 0014 PROJECT NOTE 340 -RESPONSE TO OTSC. EPA AND RWOCB JACOBS ENGINEERING GROUP INC
COMMENTS ON THE DRAFT PHASE 2 FIELD SAMPLING WORK PLAN.
REMEDIAL INVESTIGATKDN/FEASIBLirv STUDY FOR OUl 1/2
NFEC. MCLB. RWOCB. DTSC. ft US EPA ' 1
TECHNICAL MEMORANDUM
3/16/94 51 . 0040 PRELIMINARY DRAFT APRIL 1993 GROUNDWATER SAMPLING RESULTS JACOBS ENGINEERING GROUP INC NAVAL FACILITIES ENGINEERING
FOR OUt 1 1 2. TECHNICAL MEMORANDUM 24 COMMAND
MARCH 30. 1998
40
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MARCH 30. 1998
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
3/21/94 133 . 0017
EPA REQUEST FOR 30-DAY EXTENSION FOR REVIEW OF MCIB DRAFT US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTIC BASE
OU142 RESULTS OF STAGE B GROUNDWATER INVESTIGATION TECH
MEMO -0012
I.I
COMMENTS. EPA
3/28/94 52-0082
REVIEW OF QUARTERLY GROUND WATER SAMPLING RESULTS FOR US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
JUNE AND SEPTEMBER 1992 AND JANUARY 1993. TECHNICAL COMMAND
MEMORANDA 11. 13. AND 15 X
1.1
COMMENTS. EPA
3/28/94 ' 52 . 0247
COMMENTS ON GROUNDWATER SAMPLING RESULTS AS DESCRIBED IN US ENVIRONMENTAL PROTECTIONS AGENCY SOUTHWEST DIVISION
DRAFT TECHNICAL MEMORANDUMS 11.13. AND 15. OU« 1 AND 2 MCLB
BARSTOW
1.2
COMMENTS. EPA
V29/94 52 - 0081
REVIEW OF DRAFT RESULTS OF STAGE B GROUNDWATER
INVESTIGATION. TECHNICAL MEMORANDUM 12
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS. EPA
3/29/94 52. 0083 REVIEW OF DRAFT PHASE J FIELD SAMPLING (WORK) PLAN
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.2
PLAN. QAPP
3/30/94 «3 . 0008 REVISED FINAL QUALITY ASSURANCE PROJECT PLAN FOR REMEDIAL JACOBS ENGINEERING GROUP INC NAVAL FACILITIES ENGINEERING
INVESTIGATION/FEASIBILITY STUDY COMMAND
1.2
REPORT
3/30/94 14 . 0066
PROJECT NOTE 347 - RESULTS OF A LITERATURE SEARCH RE
APPROPRIATENESS OF USING CENTRIGUGAl SUBMERSIBLE PUMPS
FOR SAMPLING GROUNOWATER AT MCIB BARSTOW
JACOBS ENGINEERING GROUP INC NFEC S. MCIB
COMMENTS. DTSC
4/1/94 53 . 0047
REVIEW OF THE DRAFT RESULTS OF STAGE BGROUNOWATkR DEPT OF TOXIC SUBSTANCES CONTROl NAVAL FACILITIES ENGINEERING V2
INVESTIGATION. TECHNICAL MEMORANDUM 12. DATED 11/W93.» THE COMMAND
DRAFT GROUNDWATER EXTRACTION PILOT STUDY FIELD WORK PLAN.
MEETING NOTES
4/13/94 51 . 0070 REMEDIAL PROJECT MANAGERS1 MEETING HELD ON 04/13/94-04M 4/94 NAVAL FACILITIES ENGINEERING COMMAND NFEC. MCLB. RWQCB. DTSC. ft US EPA 1.2.3.4.56.7
SAMPLING PLAN
4/21194 42- 0036 DRAFT FINAL PHASE II FIELD SAMPLING (WORK)PLAN FOR OU 1/2 MARINE CORPS LOGISTICS BASE
(REGIONAL GROUNDWATER)
VARIOUS AGENCIES
1.2
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
OA1E CAT-DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
PLAN RUTS WORK
4/79/94 41 . 0025
REMEDIAL INVESUGATION/FEASIBllITY STUDY ORAF T FINAL PHASE 2 JACOBS ENGINEERING GROUP INC
FIELD SAMPLING (WORK) PLAN FOR OUl 1/7. (Vol 1 <* 2)
NFEC. MCLB. RWOCB. OTSC. * US EPA 1.2
PLAN. SAMPLING « ANALYSIS 4/29/94 4 2 - 0026
PROJECT NOTE 350 • DRAFT FINAL PHASE 2 FIELD SAMPLING WORK
PLAN FOR OUi 1/2. PROGRAM CHANGES BASED ON REGULATORY
AGENCY COMMENTS
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
PLAN. RI/FS WORK
4/79/94 ' 42 . 0027
REMEDIAL INVESTIGATION/ FEASIBILITY STUDY DRAFT FINAL PHASE 2 JACOBS ENGINEERING GROUP INC
FIELD SAMPLING (WORK) PLAN FOR OUi 1/2. (VOL 2 OF 2)
NFEC. MCLB. RWOCB. DTSC. S US EPA 1.2
PLAN. SAMPLING ft ANALYSIS S/9/94 4 3 . 0009
PROJECT NOTE 353 . COMPARISON OF THE CHEMICAL OF CONCERN
LISTS OF ANALYTES IN THE SAMPLING * ANALYSIS PLAN VS THE
QUALITY ASSURANCE PROJECT PLAN
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
PLAN. PILOT STUDY
S/10/94 64 . 0047
PROJECT NOTE 15 . DESIGN PACKAGE SUMMARY OF WORK FOR THE
AIR SPARGE/SOIL VAPOR EXTRACTION PILOT STUDY
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
1.2
MEETING NOTES
5/11/94 51 . 0129
PROJECT NOTE 39 • REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 5/11 -12/94. DISCUSSIONS ON OU> 546 PHASE 1 RISK
ASSESSMENT VADOSE ZONE MODEL. PROJECT SCHEDULE. SITE
NFEC. MCLB. RWOCB. OTSC. » us EPA 1.2.3.4.5.8
COMMENTS. EPA
5/73/94 52 . 0008
REVIEW OF THE DRAFT FINAL PHASE 2 FIELD SAMPLING WORK PLAN
FOR OUi 1»2. DATED 4/29/94. FINDS IT AN ACCEPTABLE APPROACH.
SOME CHANGES MAY BE REQUIRED FOR BLDG 573
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
1.2
COMMENTS. EPA
5/23/94 52 . 0013
RE VIEW OF THE DRAFT GROUNDWATER EXTRACTION PILOT STUDY
FIELD PLAN. DATED 3/9/94, FINOS IT ACCEPTABLE ft OFFERS
SUGGESTIONS FOR IMPROVEMENTS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIE S ENGINEERING
COMMAND
1.2
COMMENTS. EPA
5/23/94 52 - 0014
REVIEW OF THE PRELIMINARY DRAFT GROUNDWATER 04/93 SAMPLING US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
RESULTS FOR OUl 1&2. TECHNICAL MEMORANDUM 24. DATED 3/94 COMMAND
17
PLAN. OAPP
6/8/94 43- 0006 ADDENDUM 1 TO PHASE 2 REMEDIAL INVESTIGATION FEASIBILITY JACOBS ENGINEERING GROUP INC NAVAL FACILITIES ENGINEERING
STUDY DRAFT QUALITY ASSURANCE PROJECT PLAN COMMAND
MARCH 30. 1998
42
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • OOCi SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS RESPONSE
6/8/94 53 . 0016
PROJECT NOTE 354 • RESPONSES TO EPA COMMENTS ON THE DRAF T JACOBS ENGINEERING GROUP INC
PHASE 2 FIELD SAMPLING PLAN FOR OUl 1 « 1 DATED 4/29/94
NFEC. MCLB. RWQCB. OTSC. ft US EPA 1.2
COMMENTS RESPONSE
6/3094 S3. 0013 PROJECT NOTE 355 • RESPONSE TO EPA COMMENTS ON THE DRAFT JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC « US EPA 1.2
GROUNDWATER INVESTIGATION. STAGES. OUi 1/2. TECHNICAL
MEMORANDUM 12. AND THE DRAFT GROUNOWATER SAMPLING
COMMENTS RESPONSE
7/7/94 ' 53. 0024 PROJECT NOTE 7 - RESPONSE TO AGENCY COMMENTS ON THE DRAFT JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWQCB OTSC » US EPA '.2
GROUNOWATER SAMPLING RESULTS FOR OU« 1 * 2. TECHNICAL
MEMORANDUM 24. DATED 04/93
CORRESPONDENCE
8/1/94 52 . 0285 APPROVAL OF RIGHT-OF-WAY RESERVATION CACA 31081 (W/ATTACH) US DEPARTMENT OF THE INTERIOR SOUTHWEST DIVISION
I.I
MEETING NOTES
6/3/94 5 1 . 0132
PROJECT NOTE 47 . RPM» MEETING NOTES HELD 8/3-4/94 RE TM 23. JACOBS ENGINEERING GROUP INC
VPB. GROUNOWATER SAMPLING 4 CLEAN-UP SCHEMATIC. INFRARED
THERMAL ANOMALIES. DLM. BASEWIOE SURVEY. INITIAL ASSESSMENT
NFEC. MCLB. RWQCB OTSC. ft US EPA 1.2.3.4 5.«
CORRESPONDENCE
9/20/94 is . 0029 REQUEST FOR EXTENSION ON SUBMITTAL Of OU2 DRAFT Rl REPORT SOUTHWEST DIVISION
FEDERAL FACILITIES SECTION
MEETING NOTES
1111/94 51 .. 0036
PROJECT NOTE 66 - REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGMEERMG GROUP MC
HELD ON 11/1-2794. RE CHEMICALS OF CONCERN. PHOT
GROUNOWATER REMOVAL ACTION. EE/CA». CAOC 10. FUNDING. OUl 5 *
NFEC. MCLB. RWQCB. OTSC. ft US EPA 1.2 3.4 5.»
CORRESPONDENCE. MEMO 1119/94 52 . 0263
DIFFERENCES BETWEEN EPA AND MCLB BARSTOW LISTS IDENTIFYING UNITED STATES ENVIRONMENTAL
COMPOUNDS OF CONCERNS PROTECTION AGENCY
SOUTHWEST DIVISION
1.2.3.4.5.8.7
MEETING NOTES
11/21/94 51 . 0133
PROJECT NOTE 73 • REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 11/71-22/94. RE CAOC 1 ANALYTICAL RESULTS. GEOPHYSICAL
ANOMALIES. RECOMMENDED NFIi. DESERT MIX. CAOC 19 1ST
NFECSMCLB
1.2.3.4.5.6
CORRESPONDENCE
11/2*94 5 1 . 0237
AGENDA FOR TECHNICAL REVIEW COMMITTEE MEETING OF 15
DECEMBER 1994
MARINE CORPS LOGISTICS BASE BARSTOW SOUTHWEST DIVISION
1.2.3.4
MARCH 30. 1998
43
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DAIE CAT-DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
12/7/94 1 6 - COM
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER SOUTHWEST DIVISION
SAMPLING AND INS'AILING WELL ON PRIVATE PROPERTY. AMEND
RIGHT-OF-WAY RESERVATION CACA 31081 TO INCLUDE ACCcS TO
BUREAU OF LAND MANAGEMENT
1.7
CORRESPONDENCE
12/17/94 16 . 0077
APPROVAL OF AMENDMENT TO RIGHT-OF-WAY RESERVATION CACA US DEPT OF INTERIOR
31081. APPROVES 3 ADDITIONAL GROUNDWATER MONITORING WEILS
(V15-1. Y16-1 AND Yl 7.1) AND ACCESS TO ADJACENT PUBLIC LANDS
SOUTHWEST DIVISION
1.2
MEETING NOTES
12/14/94 . 51 . 0038
PROJECT NOTE 69 • REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 12/14-15/94. RE OUl 1 I 2 GROUNDWATER MONITORING
PROGRAM. OUi 1 a 5 EE/CA, OU 1 PHOT TEST RESULTS. OUl 3 « 4
NFEC. MCIB. RWOCB. OTSC. » US EPA 1.2,3.4.567
PUBLIC COMMUNICATION.
NEWSLETTER
1/1/95 95 . 0050
MCIB BARSTOW COMMUNITY UPDATE. ISSUE «. FOR THE IRP
ACTIVITIES A ANNOUNCING A PUBLIC MEETING/OPEN HOUSE
SCHEDUIEDFOR 1/19/95
JACOBS ENGINEERING GROUP INC
PUBLIC RELEASE S IRP COMMUNITY 1.2.3.4.5.6
RELATIONS MAILING LIST
EE/CA
1/17/95 23 - 0002
DRAFT ENGINEERING EVALUATION/COST ANALYSIS FOR OU 1. YERMO JACOBS ENGINEERING GROUP INC
ANNEX (VOL 1 OF 2)
NFEC. MCIB RVW3CB. DTSC. » US EPA 1
EE/CA
1/17/95 23. 0003 DRAFT ENGINEERING EVALUATION/COST ANALYSIS FOR OU I. YERMO JACOBS ENGINEERING GROUP INC NFEC. MCL8. RWOCB DTSC » US EPA I
ANNEX (VOt 2 OF 2)
MEETING NOTES
1/18/95 51 . 0136
PROJECT NOTE 74 - REMEDIAL PROJECT MANAGERS' MEE TING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 01/18-20/95. RE RECORDS SEARCH. ABBREVIATED
FEASIBILITY STUDY. BUDGET, t EE/CA
NFEC. MCLB. RWQCB. DTSC. « US EPA 173456
COMMENTS. RWOCB
1/Z5/95 52 . 0091
REVIEW ON BACKGROUND SOILS INVESTIGATION. TECHNICAL
MEMORANDUM 23. DATED 9/26/94. NO COMMENTS
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
1.2.3.4.5.67
CORRESPONDENCE. REQUEST 1/31/95 62 - 0007
REQUESTS IDENTIFICAION OF POTENTIAL STATE CHEMICAL t
LOCATION-SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS FOR OUl 1 THROUGH 6
NAVAL FACILITIES ENGINEERING COMMAND DEPT OF TOXIC SUBSTANCES
CONTROL
123456
CORRESPONDENCE
2/1S/9S 52 - 0262
REQUEST FOR 30-DAY EXTENSION FOR SUBMITTING REVIEW
COMMENTS ON MCLB DOCUMENTS
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
SOUTHWEST DIVISION
1.34.5.6
MARCH 30 1996
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOC*
SUBJECT
AUTHOR
ADDRESSEE
Of UNIT
CORRESPONDENCE
2/22/95 16 - 0026
COMPLETION OF TASK B1 (GEOLOGIC MAP Or YERMO ANNEX AND US DEPT OF INTERIOR
VICINITY). 82 (FAULT TRENCHING) AND A (DIRECT CURRENT
RESISITMTY STUDY)
SOUTHWEST DIVISION
1.2
COMMENTS. EPA
3/15/95 52 - 0111
RE VIE WON THE DRAFT ENGINEERING EVALUATION/COST ANALYSIS US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
FOR OU 1. YERMO ANNEX (2 VOIS). FINOS THE DOCUMENT GENERALLY COMMAND
ACCEPTABLE. HOWEVER. THERE ARE SOME INCONSISTENCIES IN THE
MEETING NOTES
3/16/95 ' 51 . 0134
PROJECT NOTE 86 • REMEDIAL PROJECT MANAGERS MEETING NOTES JACOBS ENGINEERING GROUP INC
HELD ON 03/16-17/95. RE CAOC 23. CHEMICALS OF POTENTIAL
CONCERN (TM-27). FY 96 BUDGET. OUl 1 * 2 STATISTICAL
NFEC. MCLB. RWQCB. OTSC. a US EPA 1.2.3.4.5.8.
REPORT. WATER QUALITY
414/95 64 . 0059
PROJECT NOTE 31 • BACKGROUND WATER QUALITY DETERMINATION JACOBS ENGINEERING GROUP INC
AND ITS IMPACT ON CONCEPTUAL REMEDIAL DESIGN AT OU 1
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS. OTSC
4/10/95 52 - 0183
INTERNAL REVIEW OF THE DRAFT ENGINEERING EVALUATION/COST
ANALYSIS FOR OU 1 REMOVAL ACTION. PRIMARY REVIEW OF
GEOLOGICAL PORTION. ATTACHMENT TO DTSC'S LETTER DATED 4/25/95
DEPT Of TOXIC SUBSTANCES CONTROL
OEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE.
GROUNDWATER
4/12/95 16 . 0035
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER
SAMPLING AND INSTALLING WEIL ON PRIVATE PROPERTY
SOUTHWEST DIVISION
H WINKERLINO
CORRESPONDENCE
4/13/95 135 . 0004
REQUEST FOR RE-EVALUATION OF FUNDING PLANS AND
JUSTIFICATION FOR NOT PROVIDING FUNDING IN FY 95 FOR OUl
CLEANUP
REGIONAL WATER QUALITY CONTROL
BOARD
SOUTHWEST DIVISION
CORRESPONDENCE
4/13/95 8 1 . 0025
PROPOSED REMOVAL ACTION FOR OU 1. CONCERNS WITH SIGNIFICANT REGIONAL WATER QUALITY CONTROL
DELAYS IN THE REMOVAL ACTION FOR OU 1 MAY RESULT IN ADVERSE BOARD
IMPACTS TO DOWNGRADIENT RECEPTORS (WATER SUPPLY WELLS)
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS. RWQCB
4/13/95 52 . 0112
REVIEW ON THE DRAFT EE/CA FOR OU 1. DATED 01/17/951 THE
PRELIMINARY DRAFT CONCEPTUAL DESIGNS DATED 02/14/95 FINDS IT
MAY NOT BE SUITABLE AS THE FINAL REMEDIAL SOLUTION. EE/CA
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE
4/21/95 134 . 0006
DTSC REQUEST FOR ADDITIONAL INFORMATION RE ARARS ADDECTING DEPT OF TOXIC SUBSTANCE CONTROL
THE PROPOSED UPCOMING CERCLA ACTIONS
MCLB OUl * MAILING LIST
1.234.5.8
MARCH 30. 1998
45
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE.
GROUNDWATER
4/25/95 1 6 . 0034
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNOWATER SOUTHWEST DIVISION
SAMPLING AND INSTALLING WELL ON PRIVATE PROPERTY
MR AND MRS SltER
1.2
COMMENTS. OTSC
4/35/95 52 . 0113
REVIEW ON THE DRAFT EEfCAFOR OU 1. DATED 01/17/95. RECOMMEND OEPT OF TOXIC SUBSTANCES CONTROL
THE DRAFT BE APPROVED WITH MINOR CHANGES
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE. PERMIT 4/77/95 . 54 . 0010
RE APPROVAL FOR THREE NEW MONITORING WELLS AND ACCESS DEPT • COUNTY SURVEYOR. SAN
ROADS ON BLM PROPERTY (REF LETTER DATED APRIL 11. 199S TO 8LM) BERNARDINO
SOUTHWEST DIVISION
CORRESPONDENCE
S/V95 135. 000? GROUNOWATER SAMPLING RESULTS OU1 THROUGH 6. Rl REPORTS • REGIONAL WATER QUALITY CONTROL DEPT OF TOXIC SUBSTANCES
SAMPLE TABLE FORMATS ATTACHED BOARD CONTROL
U.3.4.5.8
COMMENTS. RWOCB
S/S/95 52 . OM9
INTERNAL MEMORANUM RE THE NEED TO INCLUDE GROUNDWATER REGIONAL WATER QUALITY CONTROL
SAMPLING RESULT TABLES IN REMEDIAL INVESTIGATION REPORTS FOR BOARD
OUl1 THROUGH 8
DEPT Of TOXIC SUBSTANCES
CONTROL
123458
CORRESPONDENCE
5/15/95 1 6 - 0025
CONCERN ABOUT IMPACT OF REUCTIONS IN DoO CLEANUP PROGRAM
FOR FY-95 AND FUTURE
DEPT OF TOXIC SUBSTANCE CONTROL
OFFICE OF UNDERSECRETARY OF
DEFENSE
1.2
CORRESPONDENCE.
GROUNDWATER
5/17/95 16 - 0033 REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER SOUTHWEST DIVISION
SAMPLING ON BUREAU OF LAND MGMT PROPERTY
COUNTY OF SAN BERNARDINO
1.2
CORRESPONDENCE. RESPONSE 5/30/95 81 . 0029
RESPONSE TO LETTER DATED 04/13/95 EXPRESSING CONCERN OVER NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL
THE DELAYS IN STARTING REMOVAL ACTION BOARD
PLAN. FIELD SAMPLING
5/30/95 42 - 0030
PROJECT NOTE 39 - DESCRIPTION i RATIONALE FOR ADDITIONAL FIELD JACOBS ENGINEERING GROUP INC
WORK ON OU« 14 2
NAVAL FACILITTES ENGINEERING
COMMAND
12
CORRESPONDENCE
5/30/95 8 1 - 0046 AGREES WITH RWQCB'S SUGGESTION TO RESAMPLE THE TWO NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL 1
DOWNGRADIENT WELLS AT OU 1 REMOVAL ACTION BOARD
MARCH 30. 1998
46
-------
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAI-DOCt SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS EPA
5/31/95 52 - 0155
REVIEW OF PROJECT NOTE 31. BACKGROUND WATER QUALITY US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
DETERMINATION. US EPA DOES NOT CONCUR WITH CONCLUSIONS COMMAND
CORRESPONDENCE. COMMENT! 6/2/95 51. 0233 TRANSMITTAL OF REVISION I . MINUTES OF RPM MEETING HELD 17 SOUTHWEST DIVISION
AND 18 MAY 1995 IN MCLB BARSTOW
DTSC. US EPA. RWOCB MCLB
1.2.3.4
COMMENTS RESPONSE
6/0/95 • 53 . COM
PROJECT NOTE 32 - RESPONSE TO RWOCB S COMMENTS ON EFFECTS JACOBS ENGINEERING GROUP INC
OF GROUNDWATER CONTAMINATION AT CAOC 26. OU 1 DRAFT
ENGINEERING EVALUATION/COST ANALYSIS
NAVAL FACILITIES ENGINEERING
COMMAND
REMOVAL RESPONSE.
CONCEPTUAL DESIGN
24 . 0002
FINAL CONCEPTUAL DESIGN S COST ESTIMATE FOR OU 1. YERMO
ANNEX. REMEDIATION SYSTEMS. REVISION 1
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN. FIELD SAMPLING
6/12*5 42 - 0034
PROJECT NOTE <3 - REVISION f 1 TO PROJECT NOTE 39 DATED 5/30/95 JACOBS ENGINEERING GROUP INC
DESCRIPTION & RATIONALE FOR ADDITIONAL FIELD WORK FOR Oils 1 «
2
NFEC. MCIB RWOCB. DTSC. « US EPA ' 3
COMMENTS. RWOCB
6/12/95 52 . 0161
REVIEW OF PROJECT NOTE 31. BACKGROUND WATER QUALITY
DETERMINATION AT OU 1. ATTACHMENT TO DTSC'S LETTER DATED
6M4/95
REGIONAL WATER QUALITY CONTROL
BOARD
OEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS. DTSC
6/13/95 52- 0163 INTERNAL REVIEW OF PROJECT NOTE 31. DATED 4/4/95
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE
6/14/95 131 . 0002
FINAL CONCEPTUAL DESIGN AND COST ESTIMATE FOR YERMO ANNEX MARINE CORPS LOGISTICS BASE
OU I REMEDIATION SYSTEMS
DEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS. OTSC
6/14(95 52 - 0156
REVIEW OF PROJECT NOTE 31. BACKGROUND WATER QUALITY
DETERMINATION AT OU 1
OEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS. OTSC
6/14/95 52. 0162 INTERNAL REVIEWOF PROJECT NOTE 31. BACKGROUND WATER DEPT OF TOXIC SUBSTANCES CONTROL DEPT OF TOXIC SUBSTANCES
QUALITY DETERMINATION AT OU 1. OATE04(5/95 CONTROL
MARCH 30. 1998
-------
MARCH 30. 1996
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. REMEDIAL
INVESTIGATION
& IS/95 64. 0066 DRAFT REMEDIAL INVESTIGATIONREPORT FOR OUl 1S2IVOL 1 OF 10) JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. DTSC. ft US EPA 12
REPORT. REMEDIAL
INVESTIGATION
6/15/95 64. 0067 DRAFT REMEDIAL INVESTIGATION REPORT FOR OUl 1 ft 2. APPENDIX A JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC ft US EPA 12
(VOL 2 OF 10)
REPORT. REMEDIAL
INVESTIGATION
6/15/95 • 64. 0068 DRAFT REMEDIAL INVESTIGATION REPORT FOR Out 1 ft 2. APPENDIX B JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC • US EPA 12
(VOL 3 OF 10)
REPORT. REMEDIAL
INVESTIGATION
6/15/95 64 . 0069
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUl 1 « 2. APPENDICES JACOBS ENGINEERING GROUP INC
C « O (VOL 4 OF 10)
NFEC. MCIB. RWOCB. DTSC. ft US EPA 1 2
REPORT. REMEDIAL
INVESTIGATION
6/IS/95 64 . 0070
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUS I ft 2. APPENDIX E. JACOBS ENGINEERING GROUP INC
PART 1 (VOL 5 OF 10)
NFEC. MCIB. RWOCB. OTSC. ft US EPA 1 2
REPORT. REMEDIAL
INVESTIGATION
6/15/95 64. 0071 • DRAFT REMEDIAL INVESTIGATION REPORT FOR OU* 1 ft 2. APPENDIX E. JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWOCB. OTSC. * US EPA <2
PART 2 (VOL 6 OF 10)
REPORT. REMEDIAL
INVESTIGATION
6/15/95 64. 0072 DRAFT REMEDIAL INVESTIGATION REPORT FOR OU« 1 * 2. APPENDIX E. JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWQCB. DTSC. * US EPA 12
PART 3 (VOL 7 OF 10)
REPORT. REMEDIAL
INVESTIGATION
6/15*5 64 . 0073
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUf 1 ft 2. APPENDIX E. JACOBS ENGINEERING GROUP INC
PART 4 (VOL B OF 10)
NFEC. MCIB RWOCB. DTSC. ft US EPA 1 2
REPORT. REMEDIAL
INVESTIGATION
6/15/95 64 . 0074
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUl 1 ft 2. APPENDIX E. JACOBS ENGINEERING GROUP INC
PART S (VOL 9 OF 10)
NFEC. MCLB. RWQCB. OTSC. ft US EPA I 2
REPORT. REMEDIAL
INVESTIGATION
6/15*5 64. 0075 DRAFT REMEDIAL INVESTIGATION REPORT FOR OUS1S 2. APPENDICES JACOBS ENGINEERING GROUP INC NFEC. MCIB. RWQCB. OTSC. ft US EPA 12
F. GH. SI (VOL 10 OF 10)
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
ARABS
CORRESPONDENCE.
GROUNOWATER
CORRESPONDENCE.
GROUNOWATER
DATE CAT DOCK SUBJECT AUTHOR
6/19/95 62. 001? RESPONSE TO REQUEST FOR APPLICABLE OR RELEVANT & OEPT Of TOXIC SUBSTANCES CONTROl
APPROPRIATE REQUIREMENTS FOR MCLB
7/12/95 I 6 . 0031 CONDUCT OF GROUNDWATER SAMPLING TO EVALUATE QUALITY Of SOUTHWEST DIVISION
GROUNDWATER IN OFF BASE WELLS NEAR MCLB FROM AUGUST 15
THRU SEPTEMBER 30. 1995
7/12/95 ' 16 . 0032 CONDUCT OF GROUNOWATER SAMPLING TO EVALUATE QUALITY OF SOUTHWEST DIVISION
GROUNOWATER IN OFF-BASE WELLS NEAR MCLB FROM AUGUST 15
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
SID HODGES
K YOUNT
OP UNIT
123458
t.2
1.2
THRU SEPTEMBER 30. 1995
COMMENTS. OTSC
7/14/95 52 . 0140
REVIEW OF THE OU 1 PRELIMINARY DRAFT FINAL ENGINEERING
EVALUATION/COST ANALYSIS. DATED 6/9/95
DEPT OF TOXIC SUBSTANCES CONTROl
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE
7/21/95 81 . 0045 NOTIFICATION OF THE DISCOVERY OF CONTAMINANTS IN AN OFF-BASE MARINE CORPS LOGISTICS BASE
MONITORING WELL (Y15-1) EAST OF YERMO ANNEX CONTAINS MAP
US EPA. OTSC. RWOCB COUNTY OF
SAN BERNARDINO
MEETING NOTES
7/26/95 5 1 . 0142
PROJECT NOTE 53 - REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC
CONDUCTED ON 07/76-27/95. RE REMOVAL ACTIONS. BACKGROUND
METALS. EEJCA, RAC DESIGN. ARARt. » SCHEDULE
NFEC. MCLB. RWOCB. DTSC. « US EPA 17345(7
PUBLIC COMMUNICATION, NEW!
ARTICLE
7/27/95 95 . 0059
"OFF-BASE GROUNDWATER MONITORING WELL NEAR YERMO ANNEX MCIB BARSTOW TODAY
REVEALS CONTAMINATION" FOR OU <
PUBLIC RELEASE
PUBLIC COMMUNICATION. NEW! 7/31/95 95. 0058 •MORE WATER POLLUTION FOUND NEAR YERMO"OU 1
ARTICLE
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
EE/CA
«/1«5 23 . 0004 DRAFT FINAL ENGINEERING EVALUTATION/COST ANALYSIS FOR OU1. JACOBS ENGINEERING GROUP INC NFEC MCLB. RWOCB. DTSC * US EPA 1
YERMO ANNEX
REPORT. ANALYTICAL DATA 8/7/95 84 . 0086
RESULTS OF WATER SAMPLES SHOW THAT VOLATILE ORGANIC MARINE CORPS LOGISTICS BASE
COMPOUNDS FOUND IN THE WATER ARE SLIGHTLY BELOW. OR AT THE
MCLl FOR DRINKING WATER. WILL CONTINUE TO MONITOR THE WELL
OFF-BASE RESIDENT «M
MARCH 30. 1998
49
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REMOVAL ACTION
8/3/95 2 1 . 0078
DRAFT OU 1 ACTION MEMORANDUM REMOVAL ACTION NOW TIME
CRITICAL
JACOBS ENGINEERING GROUP INC NFEC MCLB. RWOCB. OTSC. « US EPA I
PUBLIC COMMUNICATION. NEW! 8/3*5 95. 0081 "CONTAMINANTS FOUND IN VERMO WEIL- OU 1
ARTICLE
WCTORvaiE DAILY PRESS
PUBLIC RELEASE
PUBLIC COMMUNICATION. PRES
RELEASE
8/3/95 • 95 - 0062
"TWO VERMO RESIDENTIAL WELLS INVESTIGATED FOR
CONTAMINATION WERE DISCOVERED TO CONTAIN TRACES Of
CLEANING SOLVENTS-
MARINE CORPS LOGISTICS BASE
PUBLIC RELEASE
COMMENTS. RWOCB
8/14/95 52 - 0136
INTERNAL REVIEW OF DRAFT REMEDIAL INVESTIGATION REPORT FOR REGIONAL WATER DUALITY CONTROL
OUl t » 2 BOARD
OEPT OF TOXIC SUBSTANCES
CONTROL
12
REPORT. REMEDIAL
INVESTIGATION
8/15/95 64. 0076 DRAFT FEASIBILITY STUDY REPORT FOR OUl 1 « 2 (VOL 1 OF 2) JACOBS ENGINEERING GROUP INC NFEC. MCLB. RWOCB. DTSC « US EPA 12
REPORT. REMEDIAL
INVESTIGATION
B/tS/95 64 . 0077 DRAFT FEASIBILITY STUDY REPORT FOR OU» 1 » 2 (VOL 2 OF 2) JACOBS ENGINEERING GROUP WC NFEC. MCLB. RWOCB. DTSC. * US EPA 12
COMMENTS. EPA
8/15/95 52 - 0141 REVIEW OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY DRAFT US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
REMEDIAL INVESTIGATION REPORT FOR OUl 1 » 2. DATED 06/1S/95 COMMAND
12
CORRESPONDENCE
8/18/95 54 . 0009
MONITORING WELL INSTALLATION WILL BEGIN AUGUST 28. 1995 BASED MARINE CORPS LOGISTICS BASE
ON PREVIOUS APPROVAL (PREVIOUSLY SIGNED ENTRY PERMIT
ENCLOSED) (WH3ENCL)
M/M OE WERFF
1.2
COMMENTS. DTSC
8/18/95 52 . 0133
INTERNAL REVIEW OF MCIB DRAFT PROJECT NOTE ON STATISTICAL
ANALYSES. ATTACHMENT TO DTSC S LETTER DATED 8/28/95
DEPT Of TOXIC SUBSTANCES CONTROL
OEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS. DTSC
8/24/95 52 - 0135 INTERNAL REVIEW OF THE GEOPHYSICAL ASPECTS OF MCIB OU« 1 » 2 DEPT OF TOXIC SUBSTANCES CONTROL OEPT OF TOXIC SUBSTANCES
REMEDIAL INVESTIGATION REPORT. DATED 06/15/95 CONTROL
12
MARCH 30. 1998
50
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE OAIE CAT DOCt SUBJECT AUTHOR ADDRESSEE OP UNIT
COMMENTS, DTSC 8/28/95 55. 0132 REVIEW Of THE DRAFT PROJECT NOtE FOR MCL8 STATISTICAL OEPT OF TOXIC SUBSTANCES CONTROL NAVAi FACILITIES ENGINEERING 12
ANALYSIS ON GROUNDWATER METALS COMMAND
COMMENTS. DTSC 8/28/95 52 . 01*4 REVIEW OF OUl 1»2 DRAFT REMEDIAL INVESTIGATION REPORT. DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 12
DATED 06/15/95 COMMAND
REMOVAl ACTION 9/11/95 ' 2t . 003) PROJECT NOTE 58 • EFFLUENT DISCHARGE MONITORING PROCEDURES JACOBS ENGINEERING GROUP INC NFEC MCLB RWQCB DTSC 4 US EPA 1
FOR THE OU » VERMO GROUNOWATER REMOVAL ACTION. REFER TO
CAT-DOC » 5 t -0144 FOR THE DOCUMENT (ATTACHMENT M)
MEETING NOTES 9/12/95 51. 0144 PROJECT NOTE 100 • RPMi1 MEETING NOTES HELD ON 09/12-13/95. RE JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC * US EPA 123458/
BACKGROUND METALS. HUMAN HEALTH RISK ASSESSMENT. RCRA
FACILITIES ASSESSMENT. SCHEDULE. PROPOSED PLAN. OU« 3 » 4
MEETING NOTES 9/12/95 51 - 0145 PROJECT NOTE 101 • REMEDIAL PROJECT MANAGERS' MEETING NOTES JACOBS ENGINEERING GROUP INC NFEC MCLB RWQCB DTSC t US EPA 123458
HELD ON 09/12-13/95. RE OVERALL GOALS * OBJECTIVES OF THE
HUMAN HEALTH BASEW1OE BASELINE RISK ASSESSMENT
CORRESPONDENCE. COMMENT! 9/15/95 51 . 0242 TECHNICAL ISSUES RAISED BY EPA COMMENTS ON OUl AND OU2 Rl JACOBS ENGINEERING GROUP INC VARIOUS AGENCIES 1.2
REPORT
COMMENTS 9/16/95 53. 0050 COMMENTS ON USEPA REVIEW OF MCLB BARSTOW EE/CA OU 1 DRAFT US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION 1
FINAL REPORT DATED AUGUST 14. 1995
COMMENTS.EPA 9/18/95 52 - 0124 REVIEWOF THE ENGINEERING EVALUATION/COST ANALYSIS f OR OU 1. US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 1
YERMO. DRAFT FINAL REPORT. DATED 08/14/95 COMMAND
MEMO, COMMENTS. REMOVAL 9/18/95 52-0282 COMMENTS ON DRAFT REMOVAL ACTION MEMO FOR MCLB OU1. DATED DEPT Of TOXIC SUBSTANCES CONTROL JACOBS ENGINEERING GROUP 1
SEPTEMBER 7. 1995
REMOVAL ACTION. MONITORING 9/19/95 22. 0013 PROJECT NOTE 58 - EFFLUENT DISCHARGE MONITORING PROCEDURES JACOBS ENGINEERING GROUP INC NFEC MCLB. RWOCB. DTSC 1 US EPA 1
PROCEDURES FOR THE OU t YERMO GROUNDWATER REMOVAL ACTION
MARCH 30. 1998
51
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX TOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . OOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
REPORT. FEASIBILITY STUDY 9119*5 g< .
PROJECT NOTE 48 . PROPOSED CLEANUP LEVELS FOR REMEDIATION JACOBS ENGINEERING GROUP INC
Of GROUNDWATER CONTAMINATION OU» 1 * 2 DRAFT FEASIBILITY
STUDY TABLE OF CONTENTS
NFEC. MCLB. RWQCB. DTSC. & US EPA 1 2
CORRESPONDENCE
9/21/95 134 . 0003
ON-SCENE COORDINATOR'S REPORT FOR REMOVAL ACTION AT MCLB OEPT OF TOXIC SUBSTANCE CONTROL
BARSTOW OU 3 CAOC 34
SOUTHWEST DIVISION
1.1
REPORT. ANALYTICAL DATA 9/22/95 64 . 0084 TEST RESULTS FROM WATER SAMPLES. TRACE AMOUNTS FOUND BUT MARINE CORPS LOGISTICS BASE
ARE NOT CONSIDERED HAZARDOUS TO HUMAN HEALTH
OFF-BASE RESIDENT f 1
REPORT. ANALYTICAl DATA 9/72/95 64 - OOK TEST RESULTS FROM WATER SAMPLES. TRACE AMOUNTS FOUND BUT MARINE CORPS LOGISTICS BASE
ARE NOT CONSIDERED HAZARDOUS TO HUMAN HEALTH
OFF.BASE RESIDENT »2
MEETING NOTES
9/25/95 51. 0143 PROJECT NOTE 99 - ACTION ITEMS FROM THE REMEDIAL PROJECT JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB DTSC ft US EPA 1234
MANAGERS MEETING HEID ON 9/12 13/95
CORRESPONDENCE
10/16/95 133 . 0006
USEPA REQUEST FOR A 5 WORKING DAY EXTENSION TO THE COMMENT US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
PERIOD FOR MCLB REMEDIAL INVESTIGATION/FEASIBILITY STUDY
DRAFT FEASIBILITY STUDY REPORT OUt 1 AND 2 CROSS REFER* 5 3
1.3
REMOVAL ACTION
10/16/95 2 1 . 0027
DRAFT FINAL ACTION MEMORANDUM FOR GROUNDWATER REMOVAL JACOBS ENGINEERING GROUP INC
ACTION FOR OU 1 AT THE YERMO ANNEX; NON-TIME CRITICAL
NFEC. MCLB RWOCB. DTSC. I US EPA
CORRESPONDENCE. REQUEST 10/16/95 81 . 0031 REQUESTS A 5-OAY EXTENSION TO COMMENT PERIOD ON REMEDIAL US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
INVESTIGATION/FEASIBILITY STUDY DRAFT REPORT FOR OUl 1 » 2 COMMAND
12
COMMENTS. EPA
10/23/95 52- 0179 REVIEW OF THE DRAFT RI/FS REPORT FOR OU 1 4 2 DATED 8/15/95 US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
12
COMMENTS RESPONSE
10/24/95 5 3 . 0035 PROJECT NOTE 40 - RESPONSE TO EPA'S COMMENTS ON THE DRAFT JACOBS ENGINEERING GROUP INC NFEC MCLB. RWOCB OTSC ft US EPA 1
FINAL OU 1 ENGINEERING EVALUATION/COST ANALYSIS DATED 09/15/95
MARCH 30. 1998
52
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT - DOC* SUBJECT AUTHOR ADDRESSEE OP UNIT
COMMENTS RESPONSE 10/30/95 53- 003? PROJECT NOTE 56 . RESPONSE ERAS COMMENTS DATED 08/15/95. JACOBS ENGINEERING GROUP INC NFEC MCIB RWQCB DISC ft US EPA 12734
RWOCB'S COMMENTS DATED 08/14/95. ft OTSC'S COMMENTS DATED ' '
06/15/96 ft 08/24/95. ON THE REMEDIAL INVESTIGATION REPORT FOR
REMOVAL ACTION 10O1/95 21 . 0026 FINAL ACTION MEMORANDUM FOR REMOVAL ACTION AT PRfVATE MARINE CORPS LOGISTICS BASE PUBLIC RELEASE 1
RESIDENCES DOMESTIC WATER SUPPLY WELLS LOCATED EAST OF THE
YERMO ANNEX. TIME CRITICAL
REPORT. RI/FS 10O1/95 ' 64 - 0111 DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY Rl REPORT JACOBS ENGINEERING GROUP INC MARINE CORPS LOGISTICS BASE 1 2
OPERABLE UNITS 1 AND 2 REVISION 0. (VOL Ml * 10 REVISED FROM B7.
0004 DTD 6/15V95DRFT VOL 1-10) AND VOL 11 & 12 ADDED TO VOLS
REPORT. RI/FS 10/31/95 64. 0112 DRAFT FINAL REMEDIAL INVESTIGATION* EASI8HITY STUDY Rl REPORT JACOBS ENGINEERING GROUP INC MARINE CORPS LOGISTICS BASE 12
OPERABLE UNITS 1 AND 2 VOLUME 12 OF 12 ADDENDUM APRIL 199SGW
SAMPLING EVENT
COMMENTS. DTSC 11M/95 52 . 0125 REVIEW OF DRAFT FEASIBILITY STUDY REPORT FOR OUi 1 A 2 DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 12
COMMAND
REPORT. TREATMENT SYSTEM 1115/95 64. 0065 PROJECT NOTE 63 • DISCUSSION OF THE EFFECTS OF METALS ON THE JACOBS ENGINEERING GROUP tNC NFEC. MCLB. RWOCB OTSC ft US EPA I
YERMO GROUNDWATER TREATMENT SYSTEM AT YERMO ANNEX
COMMENTS. DTSC 11/8/95 81 . 0033 DTSC REQUEST FOR DELAY ON CONCURRENCE OF DRAFT FINAL DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 12
REMEDIAL INVESTIGATION FOR OUl 1 ft 2. DATED 10/31/95 COMMAND
AGREEMENT. FEDERAL FACILITf 11/15/95 at . 0042 PROPOSES AN EXTENSION FOR ALL REMAINING FEDERAL FACILITIES NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 17
AGREEMENT SUBMITTALS OF OUl 1 S 2 AGENCY
AGREEMENT. FEDERAL FACHITI1 11/15/95 81 . 0044 PROPOSES AN EXTENSION FOR ALL THE REMAINING FEDERAL FACILITY NAVAL FACILITIES ENGINEERING COMMAND DEPT OF TOXIC SUBSTANCES 12
AGREEMENT SUBMITTAL FOR OUl 1 « 2 CONTROL
CORRESPONDENCE 11/15/95 81 . 0047 COMMENDS THE EXCELLENT WORK PERFORMED BY NFEC IN THE US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 1
RAPID EXECUTION OF A TIME-CRITICAL REMOVAL ACTION FOR OU 1 COMMAND
MARCH 30. 1998
53
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT • OOCi SUBJECT AUTHOR ADDRESSEE OP UNIT
AGREEMENT. FEDERAL FAClim I1M5/95 81 . 0048 PROPOSAL TO EXTEND All REMAINING DELIVERABLES IN THE FEDERAL NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION 12
FACILITIES AGREEMENT FOR OUl 1 » 1 AGENCY
MEETING NOTES 11/72/95 51. 0147 PROJECT NOTE N • NEW TEXT RE PROTECTIVENESS OF RESIDUAL JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC * US EPA 12
RISKS. RESPONSE TO ACTION ITEM til FROM THE 12/5-6/95 REMEDIAL
PROJECT MANAGERS' MEETING
AGREEMENT. FEDERAL FACMTI 11/27/95 • ei. owo RESPONSE TO NFECS REQUEST TO EXTENDING ALL REMAINING us ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 12
FEDERAL FACILITIES AGREEMENT SUBMITTAIS FOR OUl 1 « 2. WILL COMMAND
DETERMINE DATES PROPOSED AFTER THE RPMS MEETING ON 12/5-6/95
AGREEMENT. FEDERAL FACHITI 11/30/95 81 . 0038 RESPONSE TO NFEC'S REQUEST FOR AN EXTENSION OF THE FEDERAL DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING 12
FACILITIES AGREEMENT REMAINING SUBMITTALS OF OUl 1 S 2. COMMAND
EXTENSION IS GRANTED
COMMENTS RESPONSE 11/30/95 53- 0040 PRELIMINARY RESPONSES TO KEY ISSUES IN EPA S OTSC'S COMMENTS JACOBS ENGINEERING GROUP INC NFEC MCLB RWQCB DISC * US EPA 12
ON THE OUl 1 t 2 ORAF T F EASIBILITY STUDY FOR DISCUSSION AT THE
12/5-6/95 MEETING. REFER TO CAf-OOC • 5 1-01SOFOR THE DOCUMENT
COMMENTS EPA 11/30/95 52- 0174 SUBMITTAL OF ANY EPA COMMENTS ON THE REMEDIAL INVESTIGATION US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING 12
FOR om 1« 2 WILL FOLLOW THE 12/5-6/9$ RPM-S MEETING COMMAND
REMOVAL ACTION 12/1/95 21 - 0030 GROUNDWATER EXTRACTION * TREATMENT SYSTEM. REMOVAL OHM REMEDIATION SERVICES CORP NFEC. MCLB. RWOCB. DTSC.«US EPA 2
ACTION PILOT STUDY FOR WAREHOUSE 12, NEBO MAM BASE. REFER
TO CAT-OOC K 14150 FOR THE DOCUMENT (ATTACHMENT J)
REPORT 12/1)95 21 . 0034 DRAFT REMOVAL ACTION SITE CLOSEOUT REPORT. TME-CRITICAL OHM REMEDIATION SERVICES-IRVINE SOUTHWEST DIVISION t
REMOVAL ACTION AT PRIVATE RESIDENCES DOMESTIC WATER SUPPLY
WELLS LOCATED EAST OF THE YERMO ANNEX. MCIB BARSTOW DATED
MEETING NOTES 12/5/95 94. 0006 PROJECT NOTE 104 - TECHNICAL RE VIE W COMMITTEE MEETING NOTES JACOBS ENGINEERING GROUP MC TECHNICAL REVIEW COMMITTEE 1234567
CONDUCTED ON 12/5/95 MEMBERS
MEETING NOTES 12/5/95 SI - 0141 PROJECT NOTE 102 -ACTION ITEMS GENERATED FROM THE REMEDIAL JACOBS ENGINEERING GROUP MC • NFEC. MCIB. RWOCB. DTSC. * US EPA 512
PROJECT MANAGERS' MEETING CONDUCTED ON 12/5-6/95
MARCH X. 1998
54
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT - DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
MEETING NOTES
1215/95 51 . 0150
PROJECT NOTE 78 • RPMf MEETING NOTES HELD ON 12/5/95. RE RFA. JACOBS ENGINEERING GROUP INC
CAOC 21 * 20, PROPOSED PLAN. 1.1-OCE. BACKGROUND METALS.
REMOVAL ACTIONS. RISK MANAGEMENT. PLUME BOUNDARIES. VOCl.
NFEC. MCLB. RWOCB. OTSC. & US EPA 1234
ENFORCEMENT. BOARD ORDER 12/11/95 16 - 0006
TENTATIVE AMENDMENT TO WASTE DISCHARGE REQUIREMENTS FOR REGIONAL WATER QUALITY CONTROL
YERMO ANNEX DOMESTIC WASTEWATER TREATMENT FACtlTIY. BOARD BOARD
ORDERS *6-94.24A1 ft 6-94-29
MARINE CORPS LOGISTICS BASE <. 2
COMMENTS. OTSC
12/19/95 ' 52 . 0172
REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION REPORT FOR DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING
OUt 1 ft 2. GENERALLY ACCEPTS THE REPORT. DTSC WILL REQUIRE COMMAND
SAMPLING OF THE MONITORING WELLS AROUND THE CONTAMINATION
12
COMMENTS. EPA
12/20/95 52 . 0170
REVIEW Of THE DRAF T FINAL REMEDIAL INVESTIGATION REPORT FOR US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
OUt 1 ft 2. APPROVAL IS CONTINGENT ON MONITORING OF COMMAND
GROUNDWATER
12
PLAN. CONSTRUCTION
t/t/96 49 . 0001
FINAL CONSTRUCTION PLAN FOR GROUNDWATER EXTRACTION ft
MONITORING WELLS. GROUNDWATER REMEDIATION ft RECHARGE
SYSTEM FOR OUt
OHM REMEDIATION SERVICES CORP NFEC ft MQB
PLAN. CONSTRUCTION
1(1/96 49 - 0002
FINAL CONSTRUCTION PLAN FOR OU 1. GROUNDWATER REMEDIATION OHM REMEDIATION SERVICES CORP
SYSTEM
NFEC. MCLB. RWOCB. OTSC. ft US EPA I
PLAN. ENVIRONMENTAL
PROTECTION
1/1/98 48 - 0004
FINAL ENVIRONMENTAL PROTECTION PLAN. GROUNDWATER OHM REMEDIATION SERVICES CORP
REMEDIATION S RECHARGE SYSTEM FOR OU1. NOTE REFER TO CAT-
DOC *4 94002 TINAL CONSTRUCTION PLAN FOR GROUNDWATER
NFEC • MCLB
PLAN. HEALTH ft SAFETY
1/1/96 ' 46 . 0007
FINAL SITE HEALTH ft SAFETY PLAN. REV 1. GROUNDWATER OHM REMEDIATION SERVICES CORP
REMEDIATION ft RECHARGE SYSTEM FOR OU1. NOTE REFER TO CAT-
DOC *4 9-0002 TINAL CONSTRUCTION PLAN FOR GROUNDWATER
NFEC ft MCLB
PLAN. QUALITY CONTROL
1/1(96 43 . 0010
FINAL CONTRACTOR QUALITY CONTROL PLAN ADDENDUM. OHM REMEDIATION SERVICES CORP
GROUNDWATER REMEDIATION ft RECHARGE SYSTEM FOR OU 1. NOTE
REFER TO CAT-DOC M 9-0002 TINAL CONSTRUCTION PLAN FOB
NFEC ft MCLB
REPORT, DNAPL
1/26/96 64 . 0083
DENSE NON-AOUEOUS PHASE LIOUIDES (DNAPl) EVALUATION FOR
CAOCt6. 7.23. 26. ft 35
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
MARCH 30. 1998
55
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
Of UNIT
COMMENTS. EPA
1/26/96 52 - 0178
REVIEW OV THE 65* DESIGN CAOC 26 REMEDIATION SYSTEM FOR OU US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
1. MAJOR CONCERN IS THE FAILURE OF THE SYSTEM TO ACTIVELY COMMAND
REMEDIATE EXISTING PCE CONTAMINATION IN THE VADOSE ZONE
15
CORRESPONDENCE
2/5/96 SI . 0232 TRANSMITTAl OF REVISED PROJECT SCHEDULE FOR FFA DOCUMENTS MARINE CORPS LOGISTICS BASE 8ARSTOW CRWOCB US EPA. OTSC.
I.2.3.*
AGREEMENT. FEDERAL FACILITI 2/14/96 • 8 1 - OD50 FEDERAL FACILITIES AGREEMENT SCHEDULE UPDATE
MARINE CORPS LOGISTICS BASE US EPA. OTSC. * RWOCB
1734
REPORT. GROUNDWATER
2/16/96 84. 0087 PROJECT NOTE 82 • SUMMARY OF GROUNDWATER CONTAMINANT FATE JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC 1 US EPA 12
I TRANSPORT MODELING RESULTS FOR OUl 1 a 2
COMMENTS
J/21/96 53- 0046 COMMENTS ON OUt 1 AND 2 DRAFT FINAL REMEDIAL INVESTIGATION REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
REPORT AND DRAFT FEASIBILITY STUDY MCLB BARSTOW BOARD
1.2
COMMENTS. RWOCB
2/7 "96 52 . 0164
REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION REPORT &
DRAFT FEASIBILITY STUDY. NEED MORE JUSTIFICATION TO SUPPORT
ALTERNATIVES FOR oui i» 2
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
12
REPORT. COMMENTS
2/76/96 5 2 - 0281 RWQCB COMMENTS REVIEW MEETING ON OUI AND 2 DRAFT FS
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
COMMENTS
2/28/96 53 . 0045
TRANSMISSION OF COMMENTS ON SAMPLE COLLECTION AND
ANALYSIS PLAN OF THE SYSTEM START-UP AND TESTING PLAN. GW
EXTRAC ETC
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
t.2.3.4
COMMENTS. EPA
2/78/96 52 . 0166
REVIEW OF THE SAMPLE COLLECTION > ANALYSIS PLAN OF THE US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
SYSTEM START-UP > TESTING PLAN. GROUNDWATER EXTRACTION S COMMAND
TREATMENT REMOVAL ACTION PILOT STUDY. WAREHOUSE 2. NEBO
CORRESPONDENCE.
GROUNDWATER
3/2/96 52 - 0280
COMMENTS TO NOVEMBER 1995 SYSTEM STARTUP AND TESTING PLAN REGIONAL WATER QUALITY CONTROL
FOR OU2 BOARD
SOUTHWEST DIVISION
MARCH 30. 1996
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT OOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE. COMMENT! 3/22/96 52 . 0279
COMMENTS TO FUNDING AND TARGETED SCHEDULES FOR
COMPLETING SOME PROJECTS AT MCIB AND MCMWTC
REGIONAL WATER QUALITY CONTROL
BOARD
SOUTHWEST DIVISION
1.2
REPORT. DNAPL
3/2706 64. 0088 PROJECT NOTE 89 . EVALUATION OF DENSE NON AQUEOUS PHASE JACOBS ENGINEERING GROUP INC NFEC MCLB RWOCB OTSC ft US EPA 12.5.6
LIQUIDS FOR CAOC« 6. 7. 23 28. a 35 PREPARED BY EPA DATED 1/26/96
CORRESPONDENCE
4/2/96 ' 131 . 0007 REQUEST FOR AN EXTENSION OF All REMAINING FFA SUBMITTALS OF MARINE CORPS LOGISTICS BASE
OUf 1.2.3. »4 AT MCIB
SOUTHWEST DIVISION
1. 2. 3. 4
CORRESPONDENCE. FFA.
SCHEDULE
4/2/96 51 . 0274 MCLB REQUEST EXTENSION FOR ALL FFA SUBMITTALS OF OUS 1.2. 3. MARINE CORPS LOGISTICS BASE JACOBS ENGINEERING GROUP INC. 17.3.4
AND 4
REPORT. TCFIA
4/4(96 49 . 0002
FINAL ON SITE COORDINATOR REPORT . TCRA AT PRIVATE
RESIDENCES DOMESTIC WATER SUPPLY WELLS LOCATED EAST OF
YERMO ANNEX
OHM REMEDIATION SERVICES- IRVINE MARINE CORPS LOGISTICS BASE
REPORT
4/4/96 2 1 . 0033
FINAL ON SITE COORDINATOR REPORT- TIME-CRITICAL REMOVAL
ACTION AT PRIVATE RESIDENCES DOMESTIC WATER SUPPLY WELLS
LOCATED EAST OF THE YERMO ANNEX. MCIB BARSTOW
OHM REMEDIATION SERVICES • IRVINE SOUTHWEST DIVISION
COMMENTS
4/4/96 S3 . 0042
COMMENTS ON OU 2 NORTH NEBO PLUME GROUND WATER
EXTRACTION AND TREATMENT REMOVAL ACTION PILOT STUDY
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
PLAN. CONSTRUCTION
4/B/96 49 - 0003
FINAL CONSTRUCTION PLAN. INSTALLATION OF A GROUNDWATER
EXTRACTION. TREATMENT t RECHARGE SYSTEM
OHM REMEDIATION SERVICES CORP NFEC. MCIB. RWOCB. DTSC. » US EPA I
CORRESPONDENCE
4/11(96 133 - 0004
MCLB REQUEST FOR EXTENSION FOR EXISTING FEDERAL FACILITY US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTIC BASE
AGREEMENT FOR OUi 1. 2. 3. S 4
1.2. 3.4
CORRESPONDENCE
4/16/96 134. 0001 EXTENSION OF THE FFA SCHEDULE OF OUl 1.2 3 AND 4 AT MCLB DEPT Of TOXIC SUBSTANCE CONTROL MARINE CORPS LOGISTIC BASE
BARSTOW
1. 2. 3. 4
MARCH 30. 1996
57
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
RESPONSE TO REQUEST
4/16/96 5J . 0191
EXTENSION OF THE FFA SCHEDULE FOR OPERABLE UNITS 17.3 AND 4 DEPARTMENT OF TOXICS SUBSTANCES
AT MCLB BARSTOW CONTROL
MCLB BARSTOW
1. 2.3.4
MEETING NOTES
S/7/96 94 . 0007 MEETjNG NOTES. SPECIFICALLY REMEDIAl PROJECT MANAGER'S JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
MEETING HELD ON MARCH 7. 4 8. 1996 IN SAN FRANCISCO
1.2
CORRESPONDENCE
5/22/96 . 135 . 0001
RWOCB APPROVAL OF EXTENSION FOR REMAINING FFA SUBMITTALS REGIONAL WATER QUALITY CONTROL
FOROU1.2.344 BOARD
MARINE CORPS LOGISTIC BASE
1.2.3.4
CORRESPONDENCE
S/72/96 5J . 0235 FFA EXTENTION LETTER FROMCRWOCB ONOU« 1.2.3. « 4
REGIONAL WATER QUALITY CONTROL
BOARD
MCLB BARSTOW
1.2.3.4.
MEETING NOTES
5/79/96 94. 0010 MEETING NOTES MAY 29-30. 1996 RPM MEETING IN BARSTOW JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.2.3.4.5.6
RESPONSE TO COMMENTS S/29/96 53 . 0057
RESPONSE TO AGENCIES COMMENTS ON THE out i AND 2 DRAFT FS JACOBS ENGINEERING GROUP me
AMD DRAFT FINAL Rl REPORTS
SOUTHWEST DIVISION
1.2
CORRESPONDENCE. RESPONSE 5/29/96 53 . 0069
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 DRAFT FS AND JACOBS ENGINEERING GROUP INC
DRAFT FINAL Rl REPORTS
1.2
CORRESPONDENCE
6*/96 131 . 0006
REGARDING EXTENSION REQUEST RPtti ARE PRE SENTLY ROUTING MARINE CORPS LOGISTICS BASE
FOR SIGNATURE AN ADDENDUM TO THE FFA FOR THE SCHEDULE
EXTENSION
REGIONAL WATER QUALITY CONTROL
BOARD
1.2.3.4
CORRESPONDENCE. FFA.
SCHEDULE
6/6/96 51 - 0275 FFA DOCUMENT SCHEDULE EXTENSION CLARIFICATION
MARINE CORPS LOGISTICS BASE
VARIOUS AGENCIES
1.23.4
COMMENTS
6/14/96 52 - 0196
GROUNDWATER MONITORING PLAN AS PRESENTED AT THE REMEDIAL EPA REGION ix SAN FRANCISCO
PROJECT MANAGERS MEETING OF MAY 29 AND 30. 1996 AT BARSTOW
CALIFORNIA
SOUTHWEST DIVISION
I 2
MARCH X. 1996
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT FVPE
DATE CAT. DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE. COMMENT: en9/96 5? . 0322
CRWQCB COMMENTS TO OU 7 DRAFT RCRA FACILITIES ASSESSMENT REGIONAL WATER QUALITY CONTROL
REPORT BOARD
MARINE CORPS LOGISTICS BASE
REPORT. RI/FS
6/70/96 64 . OHO MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY STUDY. JACOBS ENGINEERING GROUP INC
FEASIBILITY STUDY REPORT OU 1 AND 2 DRAFT FINAL. REVISION 0.
DATED JUNE 21. 1996 (TRANSMITTAL ONLY)
SOUTHWEST DIVISION
1.2
CORRESPONDENCE
7/10/96 ' 133 . 0001 REQUEST FOR DELAY ON REVIEWOF DRAFT RCRA FACILITY
ASSESSMENT FOR MCLB BARSTOW
MARINE CORPS LOGISTICS BASE SOUTHWEST DIVISION
1.2. 4.5.«
CORRESPONDENCE PROJECT
NOTE
51 . 0256 PROJECT NOTE 103-PILOT STUDY MONITORING PLAN ONA SCHEDULE. JACOBS ENGINEERING GROUP. INC
GROUNDWATER EXTRACTION SYSTEM OU 2. NEBO NORTHERN PLUME
(NRF-I)
SOUTHWEST DIVISION
COMMENTS
7/75/96 52 . 0202
COMMENTS ON MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY EPA REGION IX SAN FRANCISCO
STUDY DRAFT FINAL FEASIBILITY STUOV REPORT OU 1 » 2
SOUTHWEST DIVISION
1.2
PROJECT NOTE NO 102/CTO2 7/26/96 51 . 0152
PROJECT NOTE NO 102/CTO 298 REGARDING MCLB BARSTOW
OPERABLE UNITS 1 AND 2 TECHNICAL AND ECONOMICAL FEASIBILITY
(TEF) OF GROUNDWATER CLEANUP
JACOBS ENGINEERING GROUP INC SOUTHWE ST DIVISION
1.2
COMMENTS
7/31/96 52 . 0203 COMMENTS ON DRAFT FINAL FS REPORT OUS I AND 2: AND OUS 5 AND EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
I. 2. 5. 8
CORRESPONDENCE. RESPONSE 8/7/96 5 3 . 0067 RESPONSE TO USEPA NATIONAL RISK MANAGEMENT RESEARCH JACOBS ENGINEERING GROUP. INC SOUTHWEST DIVISION 17
LABORATORY COMMENTS ON NATURAL ATTENUATION FOR OUS 1 AND
2. DATED MAY 6. 1996
PLAN
8/28/96 42 . 0039 FINAL CHEMICAL DATA ACQUISITION PLAN. GROUNDWATER OHM REMEDIATION SERVICES-SAN DIEGO SOUTHWEST DIVISION
REMEDIATION AND RECHARGE SYSTEM OU 1. YERMO ANNEX MCLB
BARSTOW
MEETING MINUTES
9/4/96 94. 0008 MEETING NOTES. REMEDIAL PROJECT MANAGERS MEETING OF JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
SEPTEMBER 45. 1996
1256
MARCH 30. 1996
59
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
52 . 0205
USEPA REVIEW OF YERMO ANNEX OU I DRAFT GROUNOWATER
MONITORING PLAN
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
1.2
CORRESPONDENCE
9/9/96 52 . 0206
USEPA REVIEW OF MCIB CALIFORNIA DRAFT RCRA FACILITY
ASSESSMENT REPORT
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
7.1. 2
COMMENTS
9/9/96 • 52 - 0233
COMMENTS ON REVIEW OF YERMO ANNEX OU 1 DRAFT
GROUNDWATER MONITORING PLAN
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
1.2
PROJECT NOTE NO 105
9/18/96 51 . 0153 CTO 298 PROJJECT NOTE NO 105 REGARDING NEP-4 DATA FOR OUS1 JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
AND2
1.2
RESPONSE TO COMMENTS 9/26/96 53. 0055 RESPONSE TO COMMENTS ON THE OU» 1 AND 2 PROPOSED PLAN JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.2
PROPOSED PLAN
10/1/96 95 . 0065 ORAFT-MCLB OUf 1 AND 2 PROPOSED PLAN
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.7
CORRESPONDENCE
10/4/96 52 . 0211 COMMENTS ON DRAFT RCRA RACILITY ASSESSMENT
DEPARTMENT OF TOXICS SUBSTANCE
CONTROL
OTSC LONG BEACH
1.2.3.4.5.8.7
CORRESPONDENCE. RESPONSI 10/18/96 53 . 0070
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 DRAFT FINAL FS JACOBS ENGINEERING GROUP INC
REPORT. REVISION 0
1.2
CORRESPONDENCE. RESPONSE 10/29/96 53. 0066 RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 PROPOSED PLAN. JACOBS ENGINEERING GROUP. INC. SOUTHWEST DIVISION
DATED OCTOBER 1998
1.2
COMMENTS
1099/96 5 2 . 0221 COMMENTS ON THE OUl 1 AND 2 PROPOSED PLAN
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
1.2
MARCH 30. 1998
60
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT DOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS
10/29/96 5? . 0227
COMMENTS ON MCIB BARSTOW INSTALLATION RESTORATION
PROCaAM OUl 1 AND 1 PROPOSED PLAN DATED OCTOBER 1996
DEPARTMENT Or TOXIC SUBSTANCES
CONTROL
SOUTHWEST DIVISION
1.2
COMMENTS
10/79/96 5?. 0228 COMMENTS ON THE REVIEWOF MCLB OUl 1 AND 2 DRAFT PROPOSED EPA REGION IX SAN FRANCISCO
PLAN
SOUTHWEST DIVISION
1.2
PROPOSED PLAN
11/1/96 ' 95- 0064 DRAFT FINAL OUl 1 AND 2 PROPOSED PLAN
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.2
CORRESPONDENCE. COMMENT: 11/S/96 52 . 0268
US EPA COMMENTS ON OPERATION S MAINTENANCE MONITORING US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
DATA SUMMARY GROUNDWATER EXTRACTION & TREATMENT REMOVAL
PILOT STUDY AT NE80
1.2.3.4
MEETING MINUTES
11/6/96 94 . 0009
MEETING AGENDA. REMEDIAL PROJECT MANAGERS MEETING OF
NOVEMBER 7. 1996
MARINE CORPS LOGISTICS BASE
BARSTOW
1.2.3. 4. S.6
MEETING MINUTES
1116/96 94 . 0012 NOVEMBER 6. 1996. REMEDIAL PROJECT MANAGERS MEETING MINUTES JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.2.3.4.5.8
CORRESPONDENCE
11/8/98 51 . 0156
FINAL SITE HEALTH AND SAFETY PLAN OF OPERABLE UNITS 1 AND 2
(CROSS REFER 134)
NAVAL FACILITIES ENGINEERING COMMAND DTSC LONG BEACH
1.2
MEETING NOTES
11*6/96 5 1 . 0254
NOVEMBER 6-7. 1996 REMEDIAL PROJECT MANAGERS MEETING
MINUTES
JACOBS ENGINEERING GROUP INC MARINE CORPS LOGISTICS BASE 1.2.3.4.58
PROJECT NOTE NO 109/CTO 29t 11/21/96 51 . 0154
PROJECT NOTE 109/CTO 296 REGARDING EVALUATION OF
PERFORMING VADOSE ZONE CLEANUP AT CAOC IS/17
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
CORRESPONDENCE
12/70/96 133 . 0020
RESPONSE TO LETTER OF OCTOBER 31.1996 EXPRESSING CONCERNS DEPT OF TOXIC SUBSTANCE CONTROL
OVER THE STATE OF CALIFORNIA'S COMPLIANCE WITH THE FFA FOR
THE MARINE CORPS LOGISTICS BASE BARSTOW
MARINE CORPS LOGISTIC BASE V 2. 3. 4 5, 6
MARCH 30. 1998
61
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT.OOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
COMMENTS EPA
12/24/98 52 . 0244
COMMENTS ON DRAFT FINAL OU9 1 AND 1 PROPOSED PLAN MARINE US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
CORPS LOGISTICS BASE BARSTOW
1.1
COMMENTS EPA
12/2 1 AND 2. DRAFT FINAL PROPOSED PLAN MARINE
CORPS LOGISTICS BASE BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
1.2
COMMENTS. OTSC
12/27196 52 . 0246
COMMENTS ON REVIEW OF THE DRAFT FINAL PROPOSED PLAN FOR
OUt 1 AND 2 MARINE CORPS LOGISTICS BASE BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.2
CORRESPONDENCE
1/22/97 51 . 0230
PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE
UNITED STATES MARINE CORPS LOGISITICS BASE OUl 1 AND 2
PROPOSED PLAN. BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
1.1
COMMENTS. OEPT OF INTERIOR 2/6/97 5; . 0259
COMMENTS ON THE DRAFT FINAL OUl 1 AND 2 PROPOSED PLAN FOR
APPROVAL AT MCLB BARSTOW
DEPT OF INTERIOR
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
PROPOSED PLAN
2/14/97 65 . 0004 DRAFT FINAL PROPOSED PLAN MARINE CORPS LOGISTICS BASE REGIONAL WATER QUALITY CONTROL OEPT OF TOXIC SUBSTANCES
BARSTOW OUl 1 AND 2 BOARD CONTROL
REPORT. FS
2/14/97 64. 0108 DRAFT FINAL FEASIBILITY STUDY REPORT ON OUS 1 AND 2 REVISION 1 JACOBS ENGINEERING GROUP MC VARIOUS AGENCIES
1.2
COMMENTS. REQUEST
2/14/97 52- 0758 REQUEST FOR AN EXTENSION OF DUE DATE FEBRUARY 14. 1997 TO REGIONAL WATER QUALITY CONTROL DEPT OF TOXICS SUBSTANCE 1.2
ALLOW INPUT BY THE RGIONAL BOARD AT THEIR APRIL 3. 1997 BOARD CONTROL
MEETING ON DRAFT FINAL PROPOSED PLAN OUl 1 AND 2 MCLB
MARCH 30. 1998
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE "AFE CAT.DOC» SUBJECT AUTHOR ADDRESSEE
OP UNIT
REPORT. ROD 2/27/97 71 . 0005 DRAFT OUs t AND 2 RECORD OF DECISION (ROD) REVISION 0 DATED JACOBS ENGINEERING GROUP. INC SOUTHWEST DIVISION 1J
FEBRUARY ?8. 1997
TECHNICAL MEMORANDUM 3/3/97 St. 0731 PROJECT NOTE NO 116-ECONOMC ANALYSIS OF VAOOSE ZONE JACOBS ENGINEERING GROUP. INC SOUTHWEST DIVISION 12
CLEANUP AT MCLB BARSTOW DATED 7/78/97
COMMENTS. RESPONSE 3/7/97 ' S2. 0760 RESPONSE TO ADDITIONAL US/EPA COMMENTS ON THE DRAFT FINAL JACOBS ENGINEERING GROUP. INC SOUTHWEST DIVISION 12
OU 1 AND 2 PROPOSED PLAN. COMMENTS DATED DECEMBER 24. 1996
CORRESPONDENCE 3/13/97 4, . 0017 OPERABLE UNITS 1 AND 2 DRAFT FINAL FEASIBILITY STUDY AND DRAFT DEPARTMENT OF TOXIC SUBSTANCES SOUTHWEST DIVISION 12
FINAL PROPOSED PLAN CONTROL
COMMENTS. DTSC 3/13/97 52. 0270 COMMENTS ON THE OVl 1/2 DRAFT FINAL ADDENDUM AND DRAFT DEPT OF TOXIC SUBSTANCES CONTROL SOUTHWEST DIVISION 1.2
FINAL PROPOSED PLAN
COMMENTS DTSC EPA RWQCB 3/13/97 52 . 0271 COMMENTS FROM VARIOUS AGENCIES ON THE OV» 5 AND 6 DRAFT DEPT OF TOXIC SUBSTANCES CONTROL SOUTHWEST DIVISION 567,12
PROPOSED PLAN AND DRAFT FINAL FS
CORRESPONDENCE. RESPONSE 3/10/97 52 . 0297 RESPONSE TO COMMENTS ON OU 1 AND 2 PROPOSED PLAN AND REGIONAL WATER QUALITY CONTROL BUREAU OF LAND MANAGEMENT 1.2
DRAFT RECORD OF DECISION BOARD
CORRESPONDENCE 3/71/97 71 . 0012 PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE 1.7
OPERABLE UNITS 1 AND 2 DRAFT RECORD OF DECISION
CORRESPONDENCE 3/24/97 17.0036 ADDITIONAL SOIL SAMPLING AT CAOC 15/17 AND SOIL VAPOR SOUTHWEST DIVISION VARIOUS AGENCIES 1.2
MONITORING AT CAOC 16
CORRESPONDENCE. REQUEST 4/14/97 51 . 0246 REQUEST TO ATTEND THE MCLB AND SWD STRATEGY MEETING FOR SOUTHWEST DIVISION US ENVIRONMENTAL PROTECTION 1.2
THE RECORD OF DECISION (ROD) ON OITS 1t 2 AGENCY
MARCH 30. 1996
63
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOCi SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
4/15/97 7 I . 0010
COLLABORATIVE POSITION FOB OPERATIVE UNITS 1 AND 2 RECORD OF SOUTHWEST DIVISION
DECISION (ROD)
US ENVIRONMENTAL PROTECTION 1.2
AGENCY
CORRESPONDENCE. REQUEST 4/28/97 51 . 0273 EXTENSION REQUEST FOR AGENCY REVIEW OF MCIB BARSTOW DRAFT US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
ROD FOR OU t AND 2
1.2
COMMENTS
4/79/97 • 71 . ooo? REVIEW OF THE DRAFT RECORD OF DECISION (ROD) FOR ou 1/2 DEPT OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.2
CORRESPONDENCE. COMMENT: 5/1/9? 52 . osos COMMENTS TO DRAFT RECORD OF DECISION FOR ousi AND 2 CALIFORNIA STATE WATER RESOURCES REGIONAL WATER QUALITY CONTROL 12
ROD CONTROL BOARD BOARD
MEETING NOTES
5*6/97 $1 . 0262 FEBRUARY 10-11. 1997 REMEDIAL PROJECT MANAGERS MEETING NOTES JACOBS ENGINEERING GROUP, INC SOUTHWEST DIVISION
1.7.1.4.1.6.7
MEETING NOTES. ROD
5/13/97 5 1 . 0281
APRIL 17. 1997 RPM MEETING NOTES RE OU 1O DRAFT RECORD OF
DECISION
JACOBS ENGINEERING GROUP. INC SOUTHWEST DIVISION
1.2
CORRESPONDENCE. MEETING 5/19/97 51 . Q272
INVITATION TO ATTEND REMEDIAL PROJECTS MANAGERS MEETING ON SOUTHWEST DIVISION
71-22 MAY 1997
VARIOUS AGENCIES
1.7.3.4.5.8
CORRESPONDENCE. COMMENT! S/30/97 52- 0302 FINAL COMMENTS FOR OU 1 AND 2 RECORD OF DECISION. DATED REGIONAL WATER OUAUTY CONTROt MARINE CORPS LOGISTICS BASE
FEBRUARY 26 1997 BOARD
1.2
CORRESPONDENCE. COMMENT! S/30/97 52 . 0309
REQUEST FOR EXTENSION OF COMMENT PERIOD ON DRAFT RECORD US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
OF DECISION TO 5/30/97
1.2
PROPOSED PLAN
8/1/97 e 5 - 0009 REVISED DRAFT FINAL COPY OF THE PROPOSED PLAN
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
1.2
MARCH 30.1998
64
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAI-OOCf SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE. COMMENT! 8/6/97 52. 03« COMENTS TO REVISED DRAFT FINAL PROSED PLAN ON OUS 1 AND 7 US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
1.2
CORRESPONDENCE. COMMENT! O6/97 57 . 0315 COMMENTS TO REVISED DRAFT PROPOSED PLAN. DATED AUGUST REGIONAL WATER OUAIITY CONTROL VARIOUS AGENCIES
1997. GROUNOWATER AND DEEP SOILS BOARD
1.2
CORRESPONDENCE
8/7/97 • 71 . 0016 REQUEST FOR SCHEDULE EXTENSION TO FFA DEADLINES FOR HOD SOUTHWEST DIVISION
AND PROPOSED PLAN
VARIOUS AGENCIES
1.2
CORRESPONDENCE. PERMIT 8/70/97 5 4 . 0008 REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY SOUTHWEST DIVISION
|W7O ENCl. RIGHT OF ENTRY PERMIT)
K AMOUR
1.2
CORRESPONDENCE
8/78/97 5 2 . 0377 COMMENTS ON SVE SYSTEM LETTER REPORT OF 7(78/97
OEPT OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.7
CORRESPONDENCE
8/29/97 5 1 . 0779 STAFF REPORT ON OU 1/2 OF 8/27/97
REGIONAL WATER QUALITY CONTROL MCLB BARSTOW
BOARD. LAHONTAN
1.2
PROPOSED PLAN. CLEANUP 9/1/97 4 9 . 0004 IRP OPERABLE UNITS 1 AND 2 PROPOSED PLAN FOR CLEANUP MARINE CORPS LOGISTICS BASE
PUBLIC
1.2
RFA PLANNING DOCUMENT
9/1/97 47 . 0009 DRAFT STRATEGIC PLAN FOR RFA AND LUFT SITES
BECHTEl NATIONAL INC
VARIOUS AGENCIES
1.2.3.4.5.6
CORRESPONDENCE. COMMENT! 9/4/97 52 - 0316
COLLECTIVE COMMENTS TO DRAFT FINAL PROPOSED PLAN BY
VARIOUS AGENCIES
JACOBS ENGINEERING GROUP MC
1.2.S.6
CORRESPONDENCE. COMMENT! 9/5/97 52 - 0317
COLLECTIVE COMMENTS TO DRAFT FINAL FEASIBILITY STUDY AND
DRAFT FINAL PROPOSED PLAN BY VARIOUS AGENCIES
JACOBS ENGINEERING GROUP INC
1.23.456
MARCH 30. 1998
65
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MARCH 30.1996
MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT . OOCt SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
9/17/97 S3. 00?? REQUEST FOR CLARIFICATION OF SVE CLEANUP GOALS
SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION 1.2
AGENCY
CORRESPONDENCE
9/22/97 5 2 . 0331 COMMENTS ON RI/FS AND BOO FOR OU 1/2. CONCURRENCE WITH Riff S DEPT OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.2
CORRESPONDENCE
9/26/97 • 52. 0328 COMMENTS ON AIR SPARGE AND SVE PILOT STUDY DRAFT TECH MEMO REGIONAL WATER DUALITY CONTROL MCLB 8ARSTOW
OF 7/31/97 BOARD. LAHONTAN
1.2
CORRESPONDENCE
9/79/97 5 1 . 0278 COMMENTS ON CRWOCB S STAFF REPORT OF 8/79/97
MCLB BARSTOW
CALIF REGIONAL WATER QUALITY
CONTROL BOARD
12
CORRESPONDENCE
10/2/97 52. 0379 CONCURRENCE WITH DRAFT FINAL PROPOSED PLAN FOR OU 1/2 OEPT OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.2
CORRESPONDENCE
10/3/97 74 . 0003
SOLICITATION OF USEPA INTERPRETATION OF CLEANUP STANDARDS SOUTHWEST DIVISION
FOR SVE SHUT-OFF CRITERIA
U S ENVIRONMENTAL PROTECTION
AGENCY
1.2
CORRESPONDENCE
10/10/97 52 . 0333 COMMENTS ON WORKING DRAFT ROD FOR OU 1/7
DEPT. OF TOXIC SUBSTANCE CONTROL SOUTHWEST DIVISION
1.2
COMMENTS. RESPONSE
HVH/97 53 . 0081
RESPONSES TO AGENCY COMMENTS ON OPERABLE UNITS (OUt) 1/2
WORKING DRAFT FINAL RECORD OF DECISION (ROD) REV 1 DATED
AUGUST 1997
JACOBS ENGINEERING GROUP MC SOUTHWEST DIVISION
1.2
CORRESPONDENCE
10/1*97 52 . 0325 COMMENTS ON WORKING DRAFT ROD FOR OU1/2
REGIONAL WATER QUALITY COWTWX
BOARD. LAHONTAN
MCLB BARSTOW
1.2
CORRESPONDENCE
10/14/97 52 . 0326 COMMENTS ON WORKING DRAFT ROD FOR OU1/2
US ENVIRONMENTAL PROTECTION SOUTHWEST DIVISION
AGENCY REGION 9
1.?
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT-DOC* SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
PROJECT NOTE
11/12/97 51 . 0281
PROJECT NOTE 123 MINUTES Of THE REMEDIAL PROJECT MANAGERS JACOBS ENGINEERING GROUP
(RPM) MEETING HELD ON NOVEMBER 12. 1997
SOUTHWEST DIVISION
1. 2. 3. 4. 5. 6
CORRESPONDENCE. REQUEST 12/2/97 71 . 0019 REQUEST f OR EXTENSION FOR SUBMITTAl OF OPERABLE UNITS 1 AND DEPARTMENT OF THE NAVY
2 DRAFT FINAL RECORD OF DECISION FOR MCLG
OEPT OF TOXIC SUBSTANCES
CONTROL
1.1
CORRESPONDENCE. REQUEST 12/2/97 71 . 0020 REQUEST FOR EXTENSION FOR SUBMITTAl OF OPERABLE UNITS 1 AND DEPARTMENT OF THE NAVY
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
US ENVIRONMENTAL PROTECTION
AGENCY
1.2
CORRESPONDENCE. REQUEST 12/2/97 7) . 0021 REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND DEPARTMENT OF THE NAVY
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
1.2
RECORD OF DECISION
12/2/97 71 . 0024 REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND SOUTHWEST DIVISION
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
REGIONAL WATER QUALITY CONTROL V 2
BOARD
PLAN. PLANNING DOCUMENTS 12/24/97 47. 0011 DRAFT FINAL STRATEGIC PLAN FOR RFA AND LUFT SITES
BECHTEL NATIONAL INC
SOUTHWEST DIVISION
t.2.3.4.58
RECORD Of DECISION
1/14/98 7 1 . 0072
DRAFT FINAL COLLABORATIVE REVIEW LANGUAGE OUi 1/2 RECORD OF JACOBS ENGINEERING GROUP
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MARINE CORPS LOGISTICS BASE. BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT • OOC» SUBJECT
AUTHOR
ADDRESSEE
OP UNIT
CORRESPONDENCE
2/12/98 1 / . 0038
LIMITED CROUNDWATER SAMPLING RESULTS AT NORTHERN HE BO
PLUME
OHM REMEDIATION SERVICES - IRVINE SOUTHWEST DIVISION
1.2
REPORT. RECORD OF DECISION 2/15/98 71 . 0025 DRAFT FINAL RECORD Of DECISION REPORT ON OPERABLE UNITS 1 JACOBS ENGINEERING CROUP INC SOUTHWEST DIVISION
AND2
1.2
REPORT. SURVEYING
2/27/9* . 13. 0010 LAND PARCEL SURVEYING AT MCIB BARSTOW. NEBO MAIN BASE AND OHM REMEDIATION
YERMO ANNEX
SOUTHWEST DIVISION
1.2
PLAN. MEMO WORK PLAN
2/28/98 41 . 0023 MEMO WORK PLAN FOR OPTIMIZATION OF THE GROUNDWATER OHM REMEDIATION
REMEDIATION AND RECHARGE SYSTEMS AT YERMO ANNEX. OU 1
DATED 2/27/98
SOUTHWEST DIVISION
PLAN. MEMO WORK PLAN
3*/98 41 . 0024 MEMO WORK PLAN FOR OPERATION OF THE GROUNDWATER OHM REMEDIATION
TREATMENT SYSTEM AT NEBO NORTH. NEBO MAIN BASE. OU 2. DATED
1/6/98
SOUTHWEST DIVISION
RESPONSE TO COMMENTS
4/3/98 53. 0082 RESPONSE TO AGENCY COMMENTS ON DRAFT FINAL RECORD OF JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
DECISION ON OPERABLE UNITS 1 AND 2
1.2
MARCH 30. 1998
68
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Appendix C
Transcript for Public Meeting
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CERTIFIED COPY
MCLB Barstow
Installation Restoration Program
Marine Corps Logistics Base
Barstow, California
Public Hearing
Date: Wednesday, November 12, 1997
Location: Holiday Inn
1511 East Main Street
Barstow, California
Reported by: Mary L Anderson, CSR 10319
Alpha-Omega
Certified Court Reporters
Quality Service from Beginning to End!
2048 Orange Tree Lane. Suite 107, Redlands. CA 92374 • Toll Free (888) 335-7171
SERVING SOUTHERN CALIFORNIA
SPECIALIZING m CONSTRUCTION, MEDICAL/TECHNICAL, REAL TIME
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1 INDEX
2
3
4 SPEAKER: PAGE
5
6 MR. DAWSON 3
7 MR. .COX 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
ALPHA-OMEGA COURT REPORTERS
(909) 890-3642 (888) 335-7171
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1 BARSTOW, CALIFORNIA
2 WEDNESDAY, NOVEMBER 12, 199*7
3 7:38 P.M.
4
5 LT. KEVIN MORONEY: Good evening. I'm
6 Major Kevin Morony. I'm the environmental officer
7 at MCLB Barstow. On behalf of our commanding
8 officer/ Colonel McBride, I welcome you to this
9 public meeting for the proposed plan for
10 Operable Units 1 and 2. The purpose of this meeting
11 is to provide you, the public, with the opportunity
12 to ask questions and provide input to plans the
13 Marine Corps plans on implementing in order to
14 continue the cleanup of the base.
15 With that I'm going to turn the
16 meeting over to Mr. Dave Dawson, who will be the
17 facilitator for tonight's meeting.
18 MR. DAHSON: Sharp haircut this guy
19 has. As Kevin mentioned, my name is Dave Dawson. I
20 work with Southwest Division. I provide
21 environmental support for the Marine Corps Logistic
22 Base Barstow. I'm the facilitator for this
23 evening's meeting.
24 As you may notice we have a court
25 reporter who's here preparing a transcript of the
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1 meeting. That transcript will be recorded and
2 placed into the administrative record file, which
3 you are more than welcome to look at. One's located
4 at Warehouse 3 at the base. The other one's located
5 at the Barstow Public Library.
6 I'd like to introduce some people here
7 who play an instrumental role in the Installation
6 Restoration Program. Mr. Mike Cox, he is the Base's
9 IR Program Manager. On my left, Mr. Shawn Monahan,
10 he's the IR Program Field Manager for the Base. He
11 also have with us Ms. Anna-Marie Cook, she's the
12 representative of the United States EPA.
13 Mr. Steven Baxter, the representative of California
14 Department of T.oxic Substances Control. Curt
15 Shifrer, he's part of the California Regional Water
16 Quality Control Board.
17 What we would like to do tonight is
18 overview the Marine Corps' Installation Restoration
19 Program. I'll start off with a breif overview of
20 CERCLA, then we'll discuss our proposed remedial
21 actions for some of the emanating groundwater that
22 you heard us discuss earlier in our technical review
23 meeting.
24 I'll start off with the CERCLA
25 overview, and then I'll turn it over to Mr. Michael
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1 Cox to give the presentation on the Installation
2 Restoration Program as well as some proposed
3 alternatives for cleanup at the site. We ask at the
4 end of all this, Mike will take any questions you
5 ask. Please hold all questions until the end. Jot
6 it down/ and we'll address it at the end of the
7 presentation. With that, I'll give a brief
8 background on CERCLA.
9 CERCLA the acronym stands for
10 Comprehensive Environmental Response, Compensation
11 and Liability Act. It is the broadest environmental
12 statute which regulates the cleanup of past
13 hazardous waste sites. Sometimes you hear it in the
14 papers referred to as Superfund.
15 CERCLA was enacted in 1980. As part
16 of that, Department of Defense and the Marine Corps
17 began Installation Restoration Program, which is
18 meant to go out and investigate potential sites and
19 cleanup those sites as required by CERCLA. The
20 CERCLA program starts off with a process that begins
21 what we call "Site Discovery." In our case tonight,
22 Operable Units 1 and 2 we are talking about
23 contaminated groundwater. Diverse discovery of the
24 contaminated groundwater at the Yermo Annex of the
25 base.
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1 As a result of this, based on the
2 samples taken of the groundwater, as well as the
3 quality of the groundwater. The Federal EPA ranks
4 the site on what we call a hazard ranking system for
5 those sites that are worthy of being regulated by
6 the EPA placed on what we call the National
7 Priorities List, which is sometimes referred to as
B the NPL. Barstow was placed on the NPL in November
9 of 1989.
10 Following the site discovery, proceed
11 to the remedial investigation. The goal of the
12 remedial investigation is commonly referred to as
13 the RI. This is to evaluate the nature and extent
14 of all this contamination. In our case it ended up
15 being one plume in the Yermo Annex, two plumes at
16 the Nebo Annex.
17 Following RI, we proceed on to an FS
18 or Feasibility Study whose goal is to evaluate
19 different alternatives to clean up waste found on
20 the site. Finally, after evaluating several
21 alternatives, we proceed with the proposed plan for
22 the site, which is why we're meeting here tonight.
23 This lists the recommended alternatives, gives a
24 short background on those that were looked at in the
25 Feasibility Study.
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Once we've public-commented the
proposed plan, which as mentioned is part of
tonight's meeting, proceed with what we call "Record
of Decision" or ROD. This legally documents our
decision for the cleanup at the site. Following
signature of the ROD, we proceed with remedial
design and remedial action, which is the cleanup of
the site.
For those of you who aren't familiar,
Barstow is divided in three portions. Pictured here
we have the Yermo Annex. Yermo consists of mostly
industrial operations on the base. The heart of the
Yermo Annex, what we call Building 573, your
maintenance center Barstow, it's the one-stop shop
where vehicles and military equipment is repaired
rehabed and stored on the site. This is pretty much
the industrial annex of the base.
Second portion of the base is the
Nebo Annex. This portion consists mostly of the
administrative buildings on the Base, base housing,
some recreation and activities on the Base.
Finally, we have the rifle rage portion of the Base,
which will not be addressed in tonight's public .
meeting.
What we do for each alternative, back
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1 in the FS or the Feasibility Study I mentioned, we
2 take each alternative and compare it against
3 nine NCP criteria. The goal of this is to get a
4 fair comparison of each of the cleanup alternatives
5 that were evaluated.
6 Listed here on my overhead are the
7 nine NCP criteria that it was compared against. We
8 take each alternative and evaluate its overall
9 protection of human health in the environment. Its
10 compliance with ARARs. ARARs is just an acronym for
11 local, state or federal regulation that we need to
12 make sure we comply with as we conduct the cleanup.
13 We evaluate each alternative for
14 short-term and long-term effectiveness at the site.
15 We also evaluate to see if an alternative has a
16 reduction in mobility, toxicity or volume of the
17 site. This shows the EPA's preference for reducing
18 the mobility, toxicity or volume of the
19 contamination at the site. Finally, we look at
20 implementability, whether or not a remedial action
21 is able to actually be put in at a site.
22 We compare each alternative on the
23 basis of cost. We look for state acceptance of the
24 alternative, and finally, we look to the public,
25 which our proposed plan is part of tonight, for the
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public's acceptance of our recommended
alternatives.
With that, I'll turn it over to
Hike Cox who will give you an overview of the
Installation Restoration Program.
MR. COX: Good evening. The slide
you're currently reviewing is a description of the
Operable Units for the Marine Corps' Logistic Base,
and they're grouped together. You'll notice each
operable unit is broken out.
Yermo Annex groundwater is listed
OU 1. Nebo main base groundwater is listed as 00
2. OU 3 is the Yermo Annex with some
preinvestigative data that was done prior to the
investigation occurring. OU 4, Nebo main base, also
had some preinvestigative data. OU 5 and 6 are soil
sites also that had no investigative data, which
means there was no information. It was very limited
data at all. Mostly just information packets and
stuff with people telling you about the site or some
information, but nothing real hard evidence to tell
us what happened there. OU 7 is the Yermo, Nebo
sites that are remaining from the RCRA Facility
Assessment; These are sites that are going to be
grouped later on after the main one was done
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1 The typea of chemical waste that were
2 found at Barstow during the investigation included
3 petroleum hydrocarbons, solvent materials which are
4 very prevalent in plumes. There were pesticides,
5 herbicides, plating wastes activity from industrial
6 activity, PCBs, metals, as low as solid waste from
7 industrial and domestic facilities.
8 At this time I'd like to provide you a
9 little overview of the major events that brought us
10 to this point today. June 1983 we had initial
11 assessment study done. This was basically a
12 prework-up that was done as part of a Navy process
13 to look at the sites and determine if there were
14 contaminants present. This process noted some
15 contaminant sites.
16 October 1980 groundwater contamination
17 was detected at the Marine base. And November of
18 '89 MCLB Barstow was placed on the National
19 Priorities List, often called NPL, and in October of
20 1990, a Federal Facility Agreement was signed
21 between the Marine Corps and federal and state
22 regulatory agencies.
23 Other major events include 1994 a
24 COAC 16 Air Sparge/Soil Vapor Extraction System
25 Pilot Study. This was done to determine the
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1 effectiveness of the technology in remediating soils
2 and groundwater at the eastern Yermo Annex.
3 October 1995, remedial investigation
4 for groundwater was completed. 1995 and '96
5 separate pilot studies were conducted at the Nebo
6 main base to evaluate the effectiveness of cleanup
7 technologies. And the beginning of 1996 a
8 Non-Time-Critical Removal Action has been underway
9 at the Yermo Annex and begun to clean up
10 contaminated groundwater.
11 Most recent activities have included
12 the finalizing of the Feasibility Study in February
13 of 1997. The Feasibility Study evaluated various
14 alternatives for cleaning up the groundwater
15 operable units.
16 Last month, OU 1 and 2 Proposed Plan
17 was issued to the public and your being here tonight
18 is part of that process to solicit your input, and
19 in December 1997 we are scheduled to complete a ROD
20 or Record of Decision on these operable units.
21 For the next few minutes I'd like to
22 discuss the Proposed Plan and provide a brief
23 discussion on the alternatives evaluated to each of
24 the groundwater OUs. The Yermo groundwater, Yermo
25 Annex, is OU 1 and OU 2 is the Nebo groundwater
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Plume, which includes the north and south Plume. If
you notice the maps on the other side very quickly,
you can notice that for Nebo and Yermo, the plumes
are delineated in the pink areas.
I would like to begin my discussion by
talking about the Yermo Annex Plume. This is the
largest of three groundwater contaminant plumes at
MCLB Barstow. The most prevalent contaminants are
chlorinated solvents. This is a cleaning solvent
typical with industrial-type activity. These
chemicals were used as a degreaser and cleaner in a
wide variety of applications in the auto repair
shops over at the maintenance center Barstow and
other locations aboard the Base.
These chemicals were used primarily
for cold cleaning, vapor degreasing, et cetera. The
plume originated from past disposal activities at
the following locations: CAOC 35, which is a
landfill, CAOC 15/17 which is an industrial waste
area, CAOC 23 which is a landfill and a french drain
location at CAOC 26. Also included are breakage and
leakage within the drainage system at Building 573,
which is all through portions of the maintenance
center Barstow. The plume itself spans 12,000 feet
in length and about 4,000 feet wide, traveling at an
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1 estimated 60 to 70 feet per year.
2 First I will discuss the alternatives
3 that were evaluated to address the contamination in
4 groundwater at the Yermo Annex. He evaluated
5 10 remedial alternatives. Each alternative was
6 assessed based on the previously discussed criteria
7 defined in the NCP. These criteria were used to
8 determine which alternatives would provide the most
9 benefits.
10 Again, the assessment criteria are:
11 Overall protection of human health and the
12 environment; compliance with ARARs, these are state
13 and federal regulations; effectiveness of long-term
14 and short-term; reduction of toxicity, mobility or
15 volume; implementability; cost; state acceptance and
16 community acceptance, which is your activity
17 tonight, why you're here.
18 Each of the alternatives have to be
19 evaluated against the criteria except community
20 acceptance. Again, the purpose of this meeting
21 tonight is to get your input into that process.
22 For OU 1, Yermo Annex Plume,
23 Alternative 1 is No Action Alternative. This
24 alternative is required by the NCP. It's basically
25 a baseline to evaluate all other alternatives that
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1 are presented. Existing site conditions remain the
2 same and no costs are associated. This means we
3 actually do nothing at all, and everything else is
4 based upon that.
5 Alternative 2 is Institutional
6 Controls of groundwater monitoring. This would
7 restrict the use of untreated groundwater for
8 drinking at the Yermo Annex. It would provide
9 wellhead treatment of affected wellhead water
10 supplies. This alternative would also require
11 sampling of selected wells to monitor the
12 contaminant migration. Present cost of this, worth
13 cost of this -- implementing this option would be
14 $3.5 million.
15 Alternative 3 or Yermo Annex Plume
16 would involve the installation of eight groundwater
17 extraction wells at the eastern boundary. The
18 extracted water would be treated with activated
19 carbon and subsequently recharged via two
20 infiltration galleries. I don't know if we have
21 anything on the site. Could you go point out the
22 infiltration galleries at the opposite end of the
23 Base? The alternative would require an estimated
24 190 years to clean the on-Base and 500 years to
25 clean the off-Base plume. The present worth cost of
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1 this alternative would be $14.1 million.
2 Alternative 4 utilizes the component
3 of Alternative 3 -- and one thing I want to clarify,
4 tonight you're going to hear a number of
5 alternatives and many of them incorporate
6 information from the other alternatives. So you're
7 going to hear me say this incorporates Alternative 3
8 and 2, whatever, means that when I go to
9 Alternative 5 and I say that 3 and 2 are
10 incorporated, it is part of that one. So they're
11 rolling over into that part of it too.
12 Alternative 4 utilizes components of
13 Alternative 3, which are eight extraction wells
14 installed on the eastern Base boundary and adds
15 11 wells off-Base to capture the entire plume at the
16 background boundary. The difference between this
17 alternative and Alternative 3 is that it would clean
18 all of the contaminated groundwater to background
19 levels. Treatment time required is an estimate of
20 320 years for the on-Base cleanup and 70 years for
21 the off-Base. The total present worth cost of this
22 alternative would be $30.1 million.
23 Alternative 5 for the Yermo Annex
24 Plume is the same as Alternative 3 with four
25 additional wells for off-Base capture of the
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off-Base plume above the drinking water standards.
There would be a total of eight extraction wells
along the eastern Base Boundary and four off-Base
wells at the drinking water standard boundary.
Cleanup time for Alternative 5 would be 160 years
for on-Base and 20 years for the off-Base plume.
The present worth cost would be $21.8 million.
Alternative 6 would involve
installation of eight extraction wells along the
eastern boundary from Alternative 3, along with four
additional wells on the Base at CAOC 26. The
alternative would not treat the off-Base portion of
the plume. The cleanup of the on-Base plume would
take 150 years/ and the present worth cost would be
$19.3 million.
Alternative 8A is the same as
Alternative 6 with the addition Air Sparge/Soil
Vapor Extraction treatment at CAOC 26.
Specifically, there would be eight extraction wells
along the eastern Base boundary, four wells
downgradient of CAOC 26, and AS/SVE system at
CAOC 26. The AS/SVE would clean up the Vadose zone
near CAOC 26, which is providing an ongoing source
of contamination to groundwater. The time to clean
up the on-Base portion of the plume to below
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1 drinking water standards would be reduced to
2 40 years. The total present worth cost would be
3 $21.3 million.
4 Alternative 8B is the same as
5 Alternative 8A, with the addition of an AS/SVE
6 system downgradient of CAOCs 16, 15/17 and 35. The
7 purpose of the AS/SVE systems at these locations is
8 to further accelerate the groundwater cleanup time.
9 The time to clean the on-Base plume is estimated to
10 be 30 years to a total present worth cost is
11 $22.1 million.
12 Alternative 8C is the same as
13 Alternative 8B, except it captures and treats the
14 off-Base portion of the contaminant plume above the
15 drinking water standards. The cleanup time to
16 drinking water standards would be 30 years on-Base
17 and 20 years off-Base. The total present worth cost
18 would be $27.1 million.
19 Alternative 8D is the same as
20 Alternative 8B with the capture of entire off-Base
21 plume at the background boundary and cleanup of all
22 contaminated groundwater to background levels. The
23 cleanup time for the on-Base portion of the plume is
24 estimated to be 55 years and 70 years for the
25 off-Base plume. The total present worth cost would
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1 be $49.2 million.
2 For the Yermo Annex Plume the
3 preferred alternative is 8C, which includes
4 extraction wells at the Base boundary at the
5 off-Base drinking water standard boundary and
6 downgradient of CAOC 26 and Air Sparge/Soil Vapor
7 Extraction at CAOC 26 and downgradient of CAOC 16,
8 15/17 and 35. This alternative complies with all
9 ARARs.
10 Alternative 8C is protective of human
11 health by achieving safe drinking water standards
12 throughout the entire plume. It controls short-term
13 exposure to contaminated groundwater through
14 monitoring of the plume movement and restricting the
15 use of untreated groundwater for drinking.
16 It provides for source reduction at
17 CAOC 26 to shorten the overall remediation time.
18 Cleanup time for drinking water standards is
19 estimated to be 30 years on-Base and 20 years for
20 the off-Base portion of the plume. The total
21 present worth cost is $27.1 million.
22 Next, I'm going to talk about the
23 Nebo North Plume, which is in 00 2. This plume is
24 the result of operational releases around Warehouse
25 2. The vadose zone contamination in the vicinity of
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1 Warehouse 2 may pose an ongoing long-term threat to
2 groundwater. Chlorinated solvents are the most
3 prevalent contaminants at this site.
4 The Nebo North Plume is approximately
5 4,000 by 1500 feet and appears limited to the upper
6 20 feet of the aquifer. The plume is contained
7 within the Base boundary and appears to be naturally
8 attenuating as a result of shallow groundwater, high
9 fluctuation in water table elevations and sandy soil
10 conditions.
11 Five alternatives were evaluated
12 against NCP criteria for the Nebo North Plume.
13 Briefly, I'd like to discuss each alternative
14 evaluated.
15 Again, Alternative 1 would involve No
16 Action. There would be no action to cleanup the
17 groundwater, and site conditions would remain the
18 same. There's no costs associated with this
19 alternative against its baseline.
20 Alternative 2 is Institutional
21 Controls with Natural Attenuation and fail-safe
22 pump-and-treat containment. This alternative would
23 require access restrictions to prevent the use of
24 untreated groundwater for drinking water purposes.
25 It also requires wellhead treatment for existing
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1 water supply wells that would be impacted by the
2 plume. There would be long-term groundwater
3 monitoring to tract the movement of the plume and
4 monitor mass reduction, which is expected to occur
5 as as a result of natural attenuation. This
6 alternative would also utilize a fail-safe
7 pump-and-treat system that was constructed as part
8 of the existing pilot study. The system would be
9 activated in the event that drinking water standards
10 were exceeded but the downgradient monitoring wells
11 at the site. It would take an estimated 45 years
12 for the contaminant plume to naturally attenuate to
13 levels below the drinking water standards. The
14 total present worth cost of Alternative 2 would be
15 $1 million.
16 Alternative 3 utilizes the existing
17 pump-and-treat system from the pilot study to
16 actively remediate the contaminated groundwater to
19 meet federal and state drinking water standards. It
20 would take about 42 years to cleanup the groundwater
*
21 to levels below drinking water standards, and the
22 present worth cost of this alternative is
23 $7.1 million.
24 Alternative 4 would be the same as
25 Alternative 3 with the addition of AS/SVE source
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1 reduction around Warehouse 2. This alternative
2 would combine the pilot study pump-and-treat system
3 with AS/SVE system at Warehouse 2. The removal of
4 contaminants in the vadose zone underneath
5 Warehouse 2 is expected to decrease the cleanup time
6 of this plume. Estimated cleanup time for
7 Alternative 4 is 12 years, and the total present
8 worth cost would be $5.8 million.
9 The last remedial alternative
10 evaluated for the Nebo North Plume is Alternative 5,
11 which is the same as Alternative 2, with the
12 addition of AS/SVE at Warehouse 2. Alternative 2
13 included natural attenuation with the fail-safe
14 pump-and-treat and groundwater monitoring. This
15 alternative would clean the groundwater in 15 years,
16 and a total present worth cost of $1-8 million.
17 Each of these alternatives were evaluated against
18 the NCP criteria.
19 The No Action alternative is the only
20 alternative which is not protective of human health
21 and the environment, and therefore, was not
22 considered for further analysis. All other
23 alternatives would be in compliance with ARARs and
24 provide moderate to high long-term effectiveness and
25 performance. They would achieve moderate to high
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1 reduction in toxicity, mobility or volume. All
2 remaining alternatives rely on institutional
3 controls for short-term effectiveness of community
4 protection. They would comply with worker
5 protection requirements and result in minimal
6 environmental impact. Each of the alternatives is
7 readily implemented. The cost range for the various
8 alternatives is from $2.2 to $7.1 million.
9 The preferred alternative for the
10 Nebo North Plume is Alternative 5. This includes
11 Institutional Controls with Natural Attenuation and
12 AS/SVE Source Reduction at Warehouse Number 2. This
13 alternative significantly reduces the total time
14 required to passively remediate the groundwater
15 contamination to levels below the drinking water
16 standard. The total cleanup time is estimated at
17 15 years.
18 Additionally, this alternative is
19 protective of human health, complies with all ARARs,
20 and is cost-effective. The estimated total present
21 worth cost is $1.8 million.
22 Next, I'm going to talk about the
23 Nebo South Plume, which is the result of disposal of
24 cleaning solvents at CAOC 6. Again, chlorinated
25 solvents are the predominant contaminants in these
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1 locations.
2 This plume is approximately 1,000 feet
3 by 800 feet. The leading edge of the plume is
4 downgradient approximately 600 feet from the Base
5 boundary, and it is traveling generally in an east
6 to west direction at 10 to 20 feet per year. Five
7 alternatives were evaluated for the Nebo South
8 Plume.
9 The first alternative is the No Action
10 Alternative. MCLB Barstow would not take any action
11 to cleanup groundwater or limit contaminant
12 migration. Again, this is the baseline. There is
13 no associated costs associated with this. No
14 monitoring or anything else.
15 Second alternative evaluated is
16 Institutional Controls/Groundwater Monitoring. This
17 alternative would require access restrictions to
18 prevent the use of untreated groundwater for
19 drinking water purposes. Periodic long-term
20 groundwater monitoring would also be conducted to
21 tract movement of the contaminant plume, monitor the
22 progress contaminant mass reduction and provide
23 advance warning to potentially affected downgradient
24 users. Those are people downstream. It would take
25 over 500 years for the contaminant levels in the
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groundwater to drop to levels below the drinking
water standards with Alternative 2. The present
worth cost of this alternative would be
$1.3 million.
Alternative 3 for the Nebo South Plume
is Groundwater and Vadose Zone Source Reduction at
CAOC 6. This alternative involves the existing
AS/SVE pilot study system, which is in the vicinity
of CAOC 6. This system would not prevent migration
of the plume. It would only remove contaminants
from the vadose zone soils and groundwater within a
limited portion of the plume. This alternative
would require over 500 years to cleanup the
groundwater and contaminant levels below drinking
water standards. The present worth cost of this
alternative is $3.1 million.
Alternative 4 utilizes Alternative 3
and expands on the existing pilot scale AS/SVE
system to a full-scale AS/SVE treatment system to
address source removal at CAOC 6. A groundwater
pump-and-treat system is also added to contain the
leading edge of this plume. The total time to
cleanup the groundwater at Nebo South Plume using
this alternative would be 55 years. The present
worth cost of this alternative would be
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1 $15.1 million.
2 The last alternative evaluated
3 includes extraction wells at the plume boundary.
4 This alternative provides an interim remedy to
5 contain the contaminant plume until a more effective
6 remedy can be determined. This alternative requires
7 installation of five groundwater extraction wells to
8 contain and extract the groundwater at the
9 downgradient boundary of the plume. The extracted
10 groundwater is treated with activated carbon system
11 and then pumped to the percolating pump to recharge
12 the groundwater. This alternative would take
13 105 years to cleanup the entire plume to levels
14 below drinking water standards. The present worth
15 cost of this alternative is $5.5 million.
16 Each of the five alternatives were
17 evaluated using the criteria previously mentioned on
18 the NCP. Alternative 1, Mo Action, would not be
19 protective of human health and the environment.
20 Alternatives 2 and 3 for the Nebo South Plume would
21 not be in compliance with ARARs. These two
22 alternatives do not reduce the chemical-specific
23 contaminant levels to below the federal or state
24 drinking water standards. Alternatives 4 and 5
25 provide long-term effectiveness and permanence and
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1 they reduce toxicity, mobility and volume.
2 Institutional controls are used to minimize
3 short-term risks. Since groundwater cleanup actions
4 require a long-term effort to restore the aquifer,
5 the short-term risks are the same as the current
6 risks. The costs associated with each of the
7 alternatives ranged from $1.3 million for
8 Alternative 2 to $15.1 million for Alternative 4.
9 Alternative 5 is the preferred
10 alternative for the Nebo South Plume. Alternative 5
11 was evaluated and chosen as interim remedy to
12 contain the plume until a final remedy can be
13 determined. This remedy includes groundwater
14 removal and treatment at the downgradient edge of
15 the contaminant plume.
16 This remedy also provides a
17 cost-effective way of preventing further spreading
18 of the contaminated groundwater from this site. The
19 total present worth cost is $5.5 million and would
20 take 105 years to cleanup the entire plume if no
21 further action were taken.
22 This concludes my portion tonight, and
23 I want to thank you. Dave, back to you.
24 MR. DAWSON: This concludes the formal
25 portion of our briefing. I want to respond to any
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1 questions or comments you may have at this time. I
2 would ask that before you ask questions that you
3 state us your name and where you're from so it will
4 help create a complete transcript for the
5 administrative record.
6 Are there any questions or comments?
7 MR. CHAVEZ: My name is Lewis Chavez.
8 I just like to ask the question, this plume that we
9 have here, this Yermo, is this around the area of
10 the Silver Valley High School?
11 MR. COX: No. Silver Valley is
12 actually in the opposite direction.
13 MR. CHAVEZ: On this side. Okay.
14 So this plume is moving from west to
15 east?
16 MR. COX: Yes.
17 MR. CHAVEZ: Okay. No further
18 questions. Thank you.
19 MR. DAWSON: Any other questions or
20 comments? If not, that will conclude our public
21 meeting. Thank you for attending.
22 (Whereupon, at 8:12 p.m., the public
23 hearing was adjourned.)
24
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1 CERTIFICATE
2 OF
3 COURT REPORTER
4
5 I, MARY ANDERSON, C.S.R. No. 10319, in and
6 for the State of California, do hereby certify:
7 That, prior to being examined, the witness
8 named in the foregoing deposition was by me duly
9 sworn to testify the truth, the whole truth and
10 nothing but the truth;
11 That said deposition was taken down by me in
12 shorthand at the time and place therein named, and
13 thereafter reduced to typewriting under my
14 direction, and the same is a true, correct and
15 complete transcript of said proceedings;
16 I further certify that I am not interested in
17 the event of the action.
18 Witness my hand this 12th day of November,
19 1997
20
2 1
7
22 Certified Shorthand
23 Reporter for the
24 State of California
25
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ALPHA-OMEGA COURT REPORTERS
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