PB95-964512
EPA/ROD/R09-95/144
August 1996
EPA Superfund
Record of Decision;
Fort Ord (O.U. 1),
Fort Ord, CA
9/29/1995
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Record off Decision
Operable Unit 1, Fritzsche Army Airfield
Fire Drill Area
Fort Ord, California
July 25, 1995
United States Department of the Army
Sacramento Corps of Engineers
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Record of Decision
Operable Unit 1, Fritzsche Army Airfield
Fire Drill Area
Fort Ord, California
This document was prepared by Harding Lawson Associates (HLA Project
No. 23366 02772) at the direction of the U.S. Army Corps of Engineers (COE) for the
sole use of the COE and the signatories of the Federal Facilities Agreement, including
the Army, the U.S. Environmental Protection Agency, the California Environmental
Protection Agency, including the Department of Toxic Substances Control (formerly,
the Toxic Substances Control Program of the Department of Health Services), and the
Regional Water Quality Control Board, Central Coast Region, the only intended
beneficiaries of this work. No other party should rely on the information contained
herein without prior written consent of the COE and Army. This report and the
interpretation, conclusions, and recommendations contained within are based, in part,
on information presented in other documents that are cited in the text and listed in
the references. Therefore, this document is subject to the limitations and
qualifications presented in the referenced documents.
A38359-H United States Department of the Army II
July 25, 1995
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CONTENTS
1.0 DECLARATION 1
1.1 Site Name and Location 1
1.2 Basis and Purpose 1
1.3 Site Assessment 1
1.4 Description of the Remedy 1
1.5 Statutory Determination 1
2.0 DECISION SUMMARY 3
2.1 Site Description 3
2.2 Site History 3
2.3 Enforcement and Regulatory History 3
2.4 Highlights of Community Participation 3
2.5 Scope and Role of Operable Unit 4
2.6 Site Characteristics 4
2.6.1 Summary of the RI/FS 4
2.6.2 Groundwater and Soil Treatment System Construction 5
2.6.3 GWSTS Monitoring Program Summary 5
2.6.4 Remediation Confirmation Study 5
2.7 Summary of Site Risks 6
2.7.1 Soil Health Risks 6
2.7.2 Groundwater Health Risks 6
2.8 No Further Action for Soil 7
2.9 The Remedial Action for Groundwater 8
2.10 The Remedy's Compliance with CERCLA 9
3.0 RESPONSIVENESS SUMMARY 10
3.1 Overview 10
3.2 Background on Community Involvement 10
3.3 Summary of Comments Received during the Public Comment Period and
Department of the Army Responses 10
3.3.1 Summary and Response to Local Community Concerns 10
3.3.1.1 Public Comments Regarding Community Relations 10
3.3.2 Summary and Response to Written Technical Questions 11
3.3.2.1 Reprint of, and Army Response to, the Letter Received from a
Local Citizen 11
3.3.2.2 Reprint of, and Army Response to, the Letters Received from
UCSC 13
4.0 REFERENCES 15
TABLES
1 Chemicals of Concern in Groundwater and Aquifer Cleanup Goals
2 The Remedy's Compliance with CERCLA Guidance
3 Chemicals Detected in Soil Prior To and After Excavation and Preliminary Remediation Goals
A38359-H United State* Department of the Army ill
July 25, 1995
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PLATES
1 Fort Ord Location Map
2 Site Plan
3 Groundwater Extraction System
4 Confirmation Boring and Surface Sample Locations
APPENDIX
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR THE REMEDY
A38359-H United States Department of the Army Iv
July 25, 1995
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1.0 DECLARATION
1.1
Sit* Nam* and Location
Fort Ord is located near Monterey Bay in
northwestern Monterey County, California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28,000 acres
adjacent to the cities of Seaside, Sand City,
Monterey, and Del Key Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord, separating the beach
front from the rest of the base. Laguna Seca
Recreation Area and Toro Regional Park border
Fort Ord to the south and southeast, respectively.
Land use east of Fort Ord is primarily
agricultural.
1.2
Basis and Purposo
This Record of Decision (ROD) addresses the
Fritzsche Army Airfield Fire Drill Area (FDA) and
groundwater plume, also known as Operable
Unit 1 (OU 1), in the northern portion of
Fort Ord (see Plate 1). The ROD summarizes
other decision documents pertaining to OU-1 and
completes the Administrative Record which
makes OU-1 available for property transfer
consideration. Prior to the placement of Fort Ord
on the National Priorities List (NPL), and prior to
the signing of the Federal Facility Agreement
(FFA), remedial investigations and cleanup at
OU 1 were performed. This decision document
presents the selected remedial action for OU 1
and underlying aquifer (A-aquifer). The remedy
was selected in accordance with the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendment and
Reauthorization Act (SARA), and, to the extent
practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based on the Administrative
Record for Fort Ord. A summary of the remedial
alternatives evaluated is presented in the
Operable Unit 1 Feasibility Study (HLA, 1995).
The United States Environmental Protection
Agency (EPA) and the California Environmental
Protection Agency concur with the selected
remedy.
1.3
Slto Assessment
Actual or threatened releases of hazardous
substances at the FDA, if not addressed by
continuing implementation of the response action
selected in this ROD, may present a current or
future threat to public health, welfare, or the
environment.
1.4
Description of the Remedy
The remedy described in this ROD addresses
current or potential significant risks to human
health and the environment posed by OU 1 at
Fort Ord, California. The remedy involves the
extraction, treatment (via carbon adsorption), and
recharge of groundwater that contains volatile
organic compounds (VOCs) from the A-aquifer at,
and downgradient of, the FDA. This action
removes VOCs from groundwater that pose
threats to human health and the environment.
Soil remediation at OU 1 is considered complete,
and no further action is selected.
1.5
Statutory Determination
The selected remedy is protective of human
health and the environment, complies with
federal and state applicable or relevant and
appropriate requirements for this action, and is
cost effective. The remedy is intended to fully
address the statutory mandate for permanence
and treatment to the maximum extent practicable
for the FDA and underlying A-aquifer. The
remedy utilizes permanent solutions and
alternative treatment (or resource recovery)
technologies to the maximum extent practicable
and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Because this remedy (when completed) will not
result in hazardous substances remaining onsite
above health-based levels, the five-year review
will not apply to this action.
A38359-H
July 25, 1995
United States Department of the Army 1
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Declaration
Da Mettee-McCutchon Date
Colonel, U.S. Army
Garrison Commander
Presidio of Monterey
Gail Youngblood Date
Acting BRAC Environmental Coordinator
Presidio of Monterey
U.S. Environmental Protection Agency
Anderson Date
irector, Federal Facilities Cleanup Office
U.S. Environmental Protection Agency,
Region DC
California Environmental Protection
Agency
Anthony'). Landis, P.E.
Date
Chief of Operations, Office of Military Facilities
California Environmental Protection Agency
Department of Toxic Substances Control
Roger W. Briggs ' Date
Executive Officer
California Environmental Protection Agency
Central Coast Regional Water Quality Control
Board
A38359-H United States Department of the Army
June 7.1995
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Declaration
United State Department of the Army
Toni B. Wainwright
Assistant Deputy Chief of Staff
for Base Operations Support
United States Army Training and Doctrine Command
Roger W. Briggs Date
Executive Officer
California Environmental Protection Agency
Central Coast Regional Water Quality Control
Board
lla
Colonel
Garrison Commander
Presidio of Monterey
(Jail Youngbloody
BRAC Environmental Coordinator
Presidio of Monterey
Date
U.S. Environmental Protection Agoncy
Julie Anderson Date
Director. Federal Facilities Cleanup Office
U.S. Environmental Protection Agency,
Region DC
California Environmental Protection
Agency
Anthony ]. Landis. P.E. Date
Chief of Operations. Office of Military Facilities
California Environmental Protection Agency
Department of Toxic Substances Control
A383S9-H
lulv 25. 1995
United States Department of the Army
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2.0 DECISION SUMMARY
2.1
Sit* Description
Fort Ord is located near Monterey Bay in
northwestern Monterey County, California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28,000 acres
adjacent to the cities of Seaside, Sand City,
Monterey, and Del Key Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord, separating the beach
front from the rest of the base. Laguna Seca
Recreation Area and Toro Regional Park border
Fort Ord to the south and southeast, respectively.
Land use east of Fort Ord is primarily
agricultural. The Fire Drill Area (FDA) is located
adjacent to Fritzsche Army Airfield, in the
northern portion of the base (Plate 1).
2.2
Sit* History
Since its opening in 1917, Fort Ord has primarily
served as a training and staging facility for
infantry troops. No permanent improvements
were made until the late 1930s, when
administrative buildings, barracks, mess halls,
tent pads, and a sewage treatment plant were
constructed. From 1947 to 1975, Fort Ord was a
basic training center. After 1975, the 7th Infantry
Division (Light) was assigned to Fort Ord. Light
infantry troops are those that perform their duties
without heavy tanks, armor, or artillery. Fort Ord
was selected for closure in 1991. The majority of
the soldiers were reassigned to other Army posts
in 1993. The property remaining in the Army's
possession was redesignated as the Presidio of
Monterey Annex on October 1,1994. Although
Army personnel still operate the base, no active
army division is currently stationed there.
The FDA was established in 1962 as a training
area for the Fort Ord Fire Department. A site
plan is shown on Plate 2. The FDA consisted of
an unlined burn pit, a drum loading area, a
storage tank, and underground piping connecting
the storage tank to a discharge nozzle. Fuel was
discharged from the storage tank into the pit,
ignited, and extinguished as part of firefighting
training exercises. Approximately 90 percent of
the fuel burned at the FDA was reported to be JP-
4 helicopter fuel that was either contaminated
with water or outdated. Other substances burned
at the site included hydraulic and lube oils,
gasoline, diesel fuel, and small quantities of
industrial solvents. Training activities at the
FDA were discontinued in 1985.
2.3
Enforeomont and
Regulatory History
Environmental investigations began at Fort Ord
in 1984 at FAAF under Regional Water Quality
Control Board (RWQCB) cleanup or abatement
orders 84-92, 86-86, and 86r315. Investigations
indicated the presence of residual organic
compounds from fire drill burning practices at
the FDA. The subsequent Remedial
Investigation/ Feasibility Study (RI/FS) for OU-1
was completed in 1988, and cleanup of soil and
groundwater began. A plan describing the
cleanup process was presented to the public in
June 1987. In 1990, Fort Ord was placed on the
U.S. Environmental Protection Agency's (USEPA)
National Priorities List (NPL), and a Federal
Facility Agreement (FFA) under CERCLA
Section 120 was signed by the Army, USEPA,
DTSC, and RWQCB. The FFA establishes
schedules for commencing remedial
investigations and feasibility studies, and
requires completion of remedial actions as
expeditiously as possible. The basewide RI/FS
began in 1991, and Fort Ord was placed on the
Base Realignment and Closure List (BRAG). The
Army submitted the Draft and Draft Final
versions of the Basewide RI/FS for agency review
on August 1,1994 and December 5,1994,
respectively.
2.4
Highlights of Community
Participation
On November 18, 1994, the United States Army
presented the Proposed Plan for Operable Unit 1
at Fort Ord to the public for review and comment
(HLA, 1994d). The Proposed Plan presented the
preferred alternative and summarized
A38359-H
July 25. 1995
United States Department of the Army 3
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Decision Summary
information in the OU 1 RI/FS and other
documents in the Administrative Record. These
documents are available to the public at the
following locations: Chamberlain Library,
Building 4275, North-South Road, Fort Ord,
California, and Seaside Branch Library,
550 Harcourt Avenue, Seaside, California. The
administrative record is available at 1143 Echo
Avenue, Suite F, Seaside, California.
Comments on the Proposed Plan were accepted
during a 30-day public review-and-comment
period that began on November 22 and ended on
December 22,1994. A public meeting was held
on December 8,1994, at the Hyatt Regency,
1 Old Golf Course Road, in Monterey, California.
At that time, the public had the opportunity to
ask representatives from the Army, USEPA, and
Cal/EPA questions and express concerns about
the plan. In addition, written comments were
accepted during the public comment period.
Responses to the comments received during the
public comment period are included in the
Responsiveness Summary presented in
Section 3.0 of this document.
2.5
Scop* and RoU of Oparabli
UnH
A basewide RI/FS has been completed to evaluate
environmental contamination at Fort Ord
(HLA, 1994e). Within Fort Ord, two Operable
Units have been identified for separate, expedited
investigation and cleanup: which includes the
OU 1 the Fritzsche Army Airfield FDA and the
OU 2 which includes the Fort Ord Landfills. The
term "operable unit" refers to specific
investigations that address a geographic portion
of a site or a specific site problem.
OU 1 contamination consists of two components:
(1) a soil unit (0-30 feet) within the FDA, and
(2) the A-aquifer. The first component, soil, has
been remediated as described in the following
sections to cleanup levels protective of human
health and the environment The second
component, the A-aquifer, is not currently used
to supply drinking water. However, it is
identified in the Water Quality Control Plan -
Central Coast Basin (November 1989) as a
potential drinking water source. In other areas of
Fort Ord, the A-aquifer is also in hydraulic
communication with the underlying 180-foot
aquifer, which is a drinking water source. The
primary remedial objectives for the A-aquifer are
hydraulic control and containment of
contaminated groundwater in the A-aquifer, and
extraction and treatment of groundwater
exceeding aquifer cleanup levels. Remedial
actions for these two components are intended to
be final remedial solutions to risks posed by
contaminants present within these units. The
risks are described in Section 2.7.
JLt Sit* Characteristics
2.C.1 Summary of tha RI/FS
The results of the RI at the FDA indicated the
following:
• The primary chemicals of concern in
groundwater were benzene, trans-1,2-
dichloroethene (DCE), methyl ethylketone
(MEK), and trichloroethene (TCE). The
highest concentrations were detected in water
from wells within and downgradient (north)
of the bum pit.
• The primary chemicals of concern in surface
and shallow soil were light and heavy total
petroleum hydrocarbons (TPH). The TPH-
contaminated soil was generally confined to
the central portions of the burn pit and the
drum storage area. Soil generally contained
low concentrations of TPH (light or heavy)
with only sporadic detections of VOCs.
Details of these investigations are presented in
the Soil RI/FS Report (HLA, 1986), Soil RI/FS
Addendum (HLA, 1987a), and the Groundwater
RI/FS Report (HLA, 1987a).
The Soil RI/FS Report and Soil RI/FS Addendum
evaluated remedial alternatives for soil at the
FDA using regulatory guidance available in 1987.
Onsite bioremediation was selected as the
remedial alternative for treatment of surface and
shallow soil by the Army.
The Groundwater RI/FS report evaluated
remedial alternatives for groundwater at the FDA
using regulations and guidance available in 1987.
Groundwater extraction and treatment by carbon
adsorption was selected by the Army as the
preferred remedial alternative.
A38359-H
July 25. 1995
Unit** StaUs Department of th» Army 4
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Decision Summary
2.6.2 Oroundwater and Sell
Treatment System
Construction
Following approval of the remedial alternatives
by the RWQCB, a Groundwater and Soil
Treatment System (GWSTS) was constructed and
operation began in August 1988. Details of the
construction of the GWSTS are presented in the
Construction Report (HLA. 1989). Construction
of the GWSTS was completed in several phases.
Approximately 4,000 cubic yards of TPH-
contaminated soil was excavated and temporarily
stockpiled. The maximum depth of the
excavation was 31 feet below ground surface
(bgs). Following excavation activities and
demonstration that TPH was not detected in soil
samples collected from the excavation side walls
above 200 milligrams per kilogram (mg/kg), the
excavation was backfilled to the original ground
surface with clean soil. The excavated,
stockpiled soil removed from the FDA was placed
in an aboveground biotreatment area.
Biotreatment of the contaminated soil progressed
incrementally in 1-foot layers of soil, or lifts, and
was completed by August 1991. As each lift was
remediated, it was removed and transported to
the Fritzsche Army Airfield (FAAF) soil borrow
area for use as fill in construction projects at
Fort Ord.
The groundwatei extraction and treatment system
(GET) consists of two extraction wells and four
piezometers screened in the A-aquifer,
14 monitoring wells, a granular activated carbon
treatment system, a nutrient supplement tank,
and an effluent spray system (Plate 3). Nutrients
were added to the treated groundwater and the
water sprayed on the soil in the biotreatment area
to optimize growth of microbes that consume
hydrocarbons.
Upon completion of biotreatment activities,
nutrient enrichment of the effluent spray was
discontinued and effluent was redirected to the
recharge area.
2.6.3 GWSTS Monitoring Program
Summary
The FDA GWSTS monitoring program has
provided quarterly and annual assessments of
soil and groundwater treatment progress. Soil
monitoring was discontinued upon completion of
soil bioremediation. Quarterly groundwater
monitoring (water-level measurements and
chemical analyses of groundwater samples)
continues.
In general, the analytical results for the
groundwater samples show that organic
compounds, mainly VOCs, have been detected
primarily in three wells, within or immediately
downgradient of the former bum pit.
Contaminants in other wells have been detected
sporadically at lower concentrations. The
groundwater system has been operating
effectively for over 5 years, and VOC
concentrations have generally decreased over
60 percent since the startup of the extraction and
treatment system. The groundwater plume with
flow directions is shown on Plate 2.
2.S.4 Remediation Confirmation
Study
In 1993, a remediation (cleanup) confirmation
study was undertaken to (1) demonstrate that the
HI defined the nature and extent of soil
contamination and that soil cleanup is complete,
and (2) demonstrate that the lateral and vertical
extent of groundwater contamination has been
characterized and that operation of the
groundwater extraction system is adequate and.
effective.
Confirmation sampling locations are shown on
Plate 4. The results of the field investigation.
indicated that low concentrations of several
organic chemicals remain in soil at the site.
However, confirmation sampling results
indicated that cleanup goals for soil were
achieved. These chemicals include: 1,3-
dichlorobenzene; methylene chloride; toluene;
xylenes; chlorinated dioxins and furans; and TPH
as diesel and gasoline. Lead was also detected in
soil samples just above natural background
concentrations in several samples (Table 3).
Groundwater capture analysis of the extraction
wells and aquifer indicate that groundwater
capture is adequate at the FDA and contaminated
groundwater is not migrating offsite.
A38358-H
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United States Department of the Army 6
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Decision Summary
2.7
Summary of Site Risk*
The future land use for the FDA is as a research
and habitat management area. As such, no
residential or commercial development will occur
in the area, but may occur offsite. Based on this
land use, soil cleanup is complete but continued
groundwater cleanup is necessary, as discussed
below.
2.7.1
Sell Health Risks
A Risk Assessment (RA) for soil was performed to
evaluate possible adverse future impacts to
human health and the environment from soil
contaminants detected during the Remediation
Confirmation Study. A RA calculates risks using
mathematical models to evaluate the ways that
humans, or other receptors, are exposed to
chemicals at the site based on known toxic
effects of the chemicals of concern.
To evaluate exposures that might occur during
the identified future land use the human health
risk assessment for soil used three hypothetical
receptors:
• A worker, to address possible exposure to
maintenance workers, park rangers, and
others engaged in similar activities at the site.
• A student, to address possible exposure that
might result from colleges or universities
using the site for field research.
• A child visitor, to address possible exposure
to children who might play at the site on a
regular basis.
The ecological risk assessment used three
receptors to evaluate possible ecological
exposures which might occur during the future
land use described above:
• Plant species typical of Coastal Live Oak
Woodland, the habitat that surrounds the
OU 1 area.
• The dusky-footed woodrat, which is known
to live in live oak trees in the area.
• The great horned owl, a raptor known to live
in the area and prey on the dusky-footed
woodrat.
For protection of human health and the
environment, the evaluations were designed to
overestimate potential risks associated with
potential exposures of the hypothetical receptors
to the chemical residues present in soil at the
site. The multiple exposure scenarios evaluated
in the human RA were ingestion of soil, dermal
contact with soil, and inhalation of airborne soil
particles. Ecological exposures were evaluated
using standard, EPA-accepted methods. The RA
identified chlorinated dioxins and furans as the
chemicals of concern (COG) for the human
health assessment, and chlorinated dioxins,
furans, and lead as the chemicals of concern for
the ecological assessment.
The results of the RA indicated that human
health and ecological risks associated with
chemical residues remaining in soil at OU 1 are
acceptably low. The resulting excess risk
estimated for existing site conditions indicate an
additional excess cancer risk of 2 x 10" to 1 x 10"'
(less than one in one million). In other words, if
human receptors identified above were exposed
to soil at the FDA less than one out of one
million people would be at risk of developing
cancer. These excess cancer risks are over ten
times lower than the 1(P to 10"* levels (one in ten
thousand to one in a million) identified in the
National Contingency Plan (NCP) as acceptable
residual risks for Federal Superfuhd sites. Thus,
no further soil treatment activities for the
intended land use are warranted. In addition,
even if the Site was used for unrestricted use,
risks from exposure to soils would be 3 x 10*,
which is within the acceptable risk range.
2.7.2
QreundwaUr Health Risks
A Baseline Risk Assessment (BRA) was
conducted for groundwater at the FDA. The BRA
identified the chemicals of concern for human
health and the environment as those that have
been consistently detected in groundwater. The
objective of the BRA was to qualitatively evaluate
and characterize the potential human health
impacts associated with conditions at the site as
it existed prior to any remedial efforts associated
with the GET. However, due to limitations in
A38359-H
July 25, 1995
United States Department of the Army
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Dedelon Summary
the data collected prior to implementation of the
GET, exposure point concentrations and resultant
chemical intakes and health risks associated with
these intakes could not be quantified. Therefore,
the BRA presents a qualitative evaluation by
comparing the maximum detected concentrations
of the 10 chemicals of concern with Preliminary
Remediation Goals (PRGs) developed by EPA
Region DC (EPA. 1995).
The maximum concentrations, as shown in
Table 1, ever detected for benzene; chloroform;
1.2-dichloroethane (1,2-DCA); 1.1-dichloroethene
(1,1-DCE); total 1.2-dichloroethene (tl.2-DCE);
tetrachloroethane (PCE); and trichloroethene
(TCE) exceeded groundwater PRGs.
Concentrations of the remaining COCs were all
below PRGs. This evaluation indicates that
cleanup of the groundwater was justified based
on the exceedance of conservative human health-
based guidance values.
Although some impacts to shallow groundwater
were documented in the original RI/FS, no
evidence exists to indicate that offsite migration
of the contaminant plume took place. In
addition, no private water supply wells have
been documented in the immediate vicinity of
the site. These facts, combined with the
installation of recovery wells that prevent any
downgradient migration as part of the GET, make
the possibility of offsite exposure to impacted
groundwater remote.
Monterey Bay is approximately 1.5 miles
downgradient; upgradient surface-water bodies
are further from the site. Impacts to groundwater
quality have been documented at the site, but the
possibility for subsurface and downgradient
transport of COCs at concentrations sufficient to
cause adverse impacts to aquatic biota is
considered remote. This is due to the
degradation, attenuation, and dilution of
chemicals that would naturally occur, and the
distance between the point of release and any
potential point of discharge.
A post cleanup human health risk assessment
(HHRA) was performed for the groundwater at
the FDA. The purpose of the HHRA was to
evaluate potential health risks associated with
ingestion of tapwater (i.e, groundwater) at the
proposed Aquifer Cleanup Goals (Table 1). The
methods used to conduct the HHRA were
consistent with EPA recommended guidance.
Although it is unlikely that onsite groundwater
will be used as a drinking water source, the
exposure pathway evaluated was a child and
adult receptor that might be exposed to the COCs
through ingestion of tapwater (groundwater).
The results of the HHRA indicated that human
health risks associated with chemicals in
groundwater at the Aquifer Cleanup Goals will
not result in adverse human health effects. The
resulting excess cancer risk estimated for site
conditions at the time that Aquifer Cleanup
Goals are achieved is 2 x 10* to 3 x 10J. In
other words, if the human receptors identified
above were exposed to groundwater at the FDA
less tban three out of one hundred thousand
people would be at risk of developing cancer.
These excess cancer risks are within the 104 to
10* identified in the NCP as acceptable residual
risks for Federal Superfund sites.
In summary, even if unlimited use occurred at
this site, the resultant risks from exposure to
soils and groundwater at remediation would be
no greater than that described above for
groundwater, and no institutional controls (i.e.,
deed restrictions) are needed. However, actual or
threatened releases of hazardous substances for
this site, if not addressed by continued
implementation of the groundwater remedy, may
present an imminent and substantial
endangerment to public health, welfare, and the
environment.
2.8
No Further Action for Soil
The results of the Remediation Confirmation
Study field investigation and subsequent risk
assessment indicated that the chemicals
remaining in soil do not present an unacceptable
risk to human health or to ecological receptors
under the proposed land use and do not threaten
groundwater quality.
The potential threat to groundwater from the
TPH as diesel concentrations detected in soil at
the site is predicted to be negligible. The results
of a two-step modeling process performed as part
of the (HLA, 1994b) Draft Technical
Memorandum: Approach to Evaluating Potential
Groundwater Quality Impacts indicated that the
A38359-H
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United States Department of the Army 7
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Decision Summary
heavy alkane components of a mixture containing
500 mg/kg TPH would not be found at
concentrations above 1 /ig/1 in groundwater
80 feet below the contaminated soil during a
100-year period. Consequently, because the
depths to groundwater and geologic materials at
OU 1 are comparable to those simulated in the
Technical Memorandum, TPH as diesel
concentrations of up to 560 mg/kg are not
considered to represent a threat to groundwater.
Therefore, soil remediation at the site is
considered complete, and no further action is
selected.
2.9
Tit* lUnwdlal Action'
Qroundwatar
To protect human health and comply with
federal and state applicable or relevant and
appropriate requirements (ARARs), groundwater
must be returned through cleanup to a condition
that will allow beneficial uses to occur, including
future potential use as a drinking water source,
without unacceptable risks to the users. Thus,
the remedial cleanup goals for groundwater
include cleaning up the contaminated
groundwater to at least maximum contaminant
levels (MCLs), as shown on Table 1. ARARs for
the groundwater remedy are included in the
Appendix.
Currently, no on or offsite residents are exposed
to the COCs, because no residents or consumers
of affected groundwater occupy or are
immediately adjacent to the FDA. Furthermore,
based on projected land use, commercial or
residential development will not be allowed at
the FDA. Nevertheless, the site at remediation is
suitable for unrestricted use.
Table 1 presents the COCs identified in the OU I
Feasibility Study that have been detected in
groundwater at OU L The maximum
concentration ever detected in groundwater is
presented for each detected COC along with the
maximum concentration detected in 1994.
Remediation goals are presented for COCs
currently detected at the site.
It may become apparent, during implementation
or operation of the groundwater extraction system
and its modification, that contaminant levels
have ceased to decline and are remaining
constant at levels higher than the remediation
goal over some portion of the contaminated
plume. In such a case, the system performance
standards and/or the remedy may be reevaluated.
The selected remedy will include groundwater
extraction for an estimated period of 30 years,
during which the system's performance will be
carefully monitored on a regular basis and
adjusted as warranted by the performance data
collected during operation. Modifications may
include any or all of the following:
• Discontinuing pumping at individual wells
where cleanup goals have been attained
• Alternating pumping wells to eliminate
stagnation points
• Pulse pumping to allow aquifer equilibration
and to allow adsorbed contaminants to
partition into groundwater; and
• Adding additional extraction wells to
facilitate or accelerate cleanup of the
contaminant plume.
The points of compliance for the remediation
goals are any monitoring wells within the plume
area. Remedial Design/Remedial Action
documentation will define at what point the
remediation goals will be considered to have
been attained. To ensure that remediation goals
continue to be maintained, the aquifer will be
monitored in the vicinity of wells where
pumping has ceased until the Army, EPA, and
the State agree that cleanup is complete.
Remediation goals for chemicals present in
contaminated groundwater are either based on
ARARs or on values determined by the BRA and
are presented in Table 1.
The estimated maximum total aggregate excess
cancer risk for all chemicals at their respective
remediation goals is 3 x 10J. This cumulative
risk is within acceptable range, and is health
protective.
A38359-H
July 25. 1995
United States Department of the Army
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Decision Summary
2.10
Th« Remedy's Compli
wtth CERCLA
The 1987 RI/FS considered three alternatives for
groundwater extraction and treatment and soil
treatment: Alternative A involved air stripping
with vapor phase carbon treatment of effluent
and biodegradation of soil; Alternative B involved
air stripping with vapor phase carbon off-gas
treatment, aqueous carbon polishing of effluent,
and biodegradation of soil; and Alternative C
involved aqueous carbon effluent treatment and
biodegradation of soil. Alternative C was the
selected, approved, and implemented alternative.
The RI/FS for groundwater and soil
contamination followed CERCLA regulations
available at the time, which did not include
screening alternatives using the current nine
established criteria. The selected alternative for
groundwater in the original FS, nevertheless,
satisfies these nine screening criteria. Table 2
summarizes the evaluation of the remedy against
the nine screening criteria.
Furthermore, the selected remedy meets the
requirements of Section 121 of CERCLA to:
• Be Protective of Human Health and the
Environment — The remedy is protective of
human health and the environment by
maintaining hydraulic control of the
contaminant plume and by actively reducing
containment levels.
• Comply with Applicable or Relevant and
Appropriate Requirement* (ARARs) — The
remedy complies with the promulgated
standards and regulations listed in the
Appendix.
• Be Cost Effective — The remedy is cost
effective, especially because significant
capital and O&M costs have already been
invested in the GET.
• Utilize Permanent Solutions and Resource
Recovery Techniques to the Maximum Extent
Practicable — The remedy is a permanent
solution to contamination at the site.
Infiltration of treated groundwater constitutes
resource recovery. Carbon treatment unit
canisters are to be recycled.
• Uae Treatment that Reduces Toxkity,
Mobility, or Volume as a Principal Element
— The remedy uses groundwater extraction
with treatment as a principal element.
The alternative selected (and successfully
implemented) in the June 5,1987, Remedial
Investigation/Feasibility Study is still an
effective, viable solution today. The selected
alternative for soil has been successfully
implemented. No further cleanup is required for
soil at OU 1.
A383SS-H
July 25. 1095
United States Department of the Army
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3.0 RESPONSIVENESS SUMMARY
3.1
Overview
This Responsiveness Summary provides a
summary of the public comments and concerns
regarding the OU 1 Proposed Plan at Fort Ord,
California. At the time of the public review
period, the Army had implemented a remedy for
OUl.
On the basis of the verbal and written comments
received, the Army's Proposed Plan for OU 1 was
generally accepted by the public and it was
determined that no significant changes to the
remedy, as identified in the Proposed Plan, were
necessary. However, some citizens and/or
organizations expressed concern regarding the
level of public involvement in the overall
process.
3.2
Background on Community
Involvement
The Army has implemented a progressive public
relations and involvement program for
environmental activities at Fort Ord. A plan
describing the initial soil and groundwater
cleanup process was presented to the public in
June 1987. The Advance is a newsletter
published by the Army and sent to the public
that highlights the status of ongoing and planned
remedial activities at Fort Ord. The Army also
conducts monthly Restoration Advisory Board
meetings to involve the public in decisions made
regarding remedial actions. In addition, a
toll-free number (800/491-3230) is available for
concerned citizens to comment and receive
answers regarding the environmental restoration
and transfer of Fort Ord property.
The Army held a public comment period on
OU 1 actions from November 22,1994, through
December 22,1994. Over 700 copies of the
Proposed Plan were mailed for public review and
comment to interested parties and were placed in
the Chamberlain Library, Building 4275,
North-South Road, Presidio of Monterey Annex,
California and Seaside Branch Library,
550 Harcourt Avenue, Seaside, California. This
Proposed Plan also invited readers to a public
meeting to voice their concerns. The public
meeting was held on December 8,1994 to
discuss the proposed plan for OU 1.
No comments were received from the public
regarding OU 1 prior to the publication of the
Proposed Plan and the start of the comment
period. Comments received during the comment
period are addressed below.
3.3 Summary of Comments
Received during the Public
Comment Period and
Department of the Army
Responses
Comments raised during the Fort Ord OU 1
Proposed Plan public comment period are
summarized below. The comments received
during the comment period are categorized by
relevant topics.
3.3.1
Summary and Response to
Local Community Concerns
Comments from the local community were
voiced at the Public Meeting, and are
summarized and addressed below. Three written
comment letters were received from the
community during the public comment period
and are reprinted and addressed in Section 3.3.2.
3.3.1.1 Public Comments Regarding
Community Relations
Comment: If there's a concern over public
involvement, perhaps setting up a kiosk would
be beneficial.
Army Response: The Army regularly sets up
display boards containing information about the
cleanup process at numerous locations
throughout the community (e.g., Monterey
County Library in Seaside, Monterey County
Social Services in Salinas). Additionally,
information sheets, brochures, and newsletters
are also distributed to the public that summarize
cleanup activities at Fort Ord. The Army also
conducts monthly Restoration Advisory Board
A383S9-H
July 25.1995
United StaUs Department off the Army 10
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n*apon*lv*n«M Summary
meetings to involve the public in the decision
making process regarding remedial actions at
Fort Ord.
Comment: A survey of the community should be
conducted to obtain community opinion
regarding the Superfund cleanup process and
community concerns.
Amy RMponac: An initial survey was
conducted in February 1991 to gather
information from the community to develop the
Community Relations Plan for Fort Ord. A
questionnaire was developed to assess the
community's knowledge and concerns about
contamination at Fort Ord and identify
appropriate means of communicating with the
community. In early February 1991, the
questionnaire was mailed to 61 individuals, local
elected officials, and representatives of public
agencies. The questionnaire was accompanied by
a letter Inviting responses and describing the
Superfund process and related activities at the
base. Followup phone calls lead to an initial
round of 13 interviews which were conducted in
mid-February 1991. Five written responses to the
questionnaire were received. As a consequence
of the initial interviews, names and addresses of
approximately 25 additional private residents,
special and environmental interest groups, and
public agencies were added to the mailing list,
and some were interviewed. The results of the
interviews and surveys were incorporated into
the Community Relations Plan which established
procedures for (1) disseminating accurate and
timely information to the community about the
cleanup process; (2) developing ongoing two-way
communication with the community;
(3) encouraging community involvement; and
(4) monitoring and responding to community
concerns. The Community Relations Plan is
available for public review in the information
repositories and Administrative Record. The
current mailing list for the public Includes over
700 names and addresses of individuals and/or
special interest groups and regulatory agencies.
The public also has the opportunity to provide
input at the Restoration Advisory Board
meetings, and numerous other public meetings.
A Community Relations Coordinator has been
established for Fort Ord and can be reached by
calling 1-408-242-8017. A 24-hour hotline for the
Army Corps of Engineers is available at
1-800-491-3230.
S.&2 Summary and Response to
Written Technical Questions
3.3£.1 Reprint of, and Army
Response to, the Letter
Received from a Local
Citizen
Reference is made to your November 18,1994
report regarding "The cleanup of Fritzsche Army
Airfield Fire Drill Area Site at Fort Ord.
California".
The report recognizes that "the Army is the
responsible party and lead agency for conducting
Remedial Investigations, reporting and
implementing cleanup actions at Fort Ord".
There is no stated deadline for the completion of
this process and rightfully so since the cleanup
process, no matter how long term, will never
provide complete safety for the occupation of
Fort Ord. Thus, my concern for the rush,
without any confirmed economic or educational
necessity, to allow its immediate development.
The deeding of Fort Ord property by the Army
will never remove the legal or moral liability of
the Army for the safety of occupants whether on
the conveyed property or elsewhere on Fort Ord.
"Future Land Use", as reported, is based upon
Tort Ord Reuse Authority (FORA) preliminary
plan" and "that Operable Unit i (OU 1) Fritzsche
Army Airfield Fire Drill Area (FDA) will be
within a habitat management unit protected by
the University of California Natural Reserve
System for use by the University of California,
Santa Cruz (UCSC) as a research area, and will
not be developed for commercial or residential
use." This statement Indicates that you recognize
the residual danger of ever using the property for
any use that would entail occupancy by
individuals and would record deed covenants
outlawing such use. Deed covenants do not
eliminate the danger of trespass, which could
have dire consequences.
Certainly deeds of conveyance should not be
executed until FORA's plan is finalized.
A3S359-H
July 25, 199S
United State* Department of the Army 11
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Responsiveness Summary
Certainly a California Environmental Impact
Report is necessary for UCSC to accept property.
Certainly the University of California should
recognize and accept the liability to not only
protect their students but also any other
individual who happens on the subject property
or other properties conveyed to them.
Certainly our citizenry should recognize the
increased danger inherent with the immediate
development of Fort Ord.
The Report recognizes the impossibility of
eliminating all contaminated groundwater but
makes the questionable statement
"...contaminated groundwater is not migrating
offsite." While this may be true at the moment,
geological occurrences could drastically change
the situation and endanger offsite properties.
While you consider that the dangers of cancer
resulting from the human exposure to chemical
toxics, of the ingestion of contaminated
groundwater, of the possible adverse impacts on
the aquatic biota of our Marine Sanctuary, are
remote, you cannot say that the cleanup has
eliminated these risks.
The lack of any confirmed urgency and the
ability of our natural elements over a period of
years to dissipate the dangerous materials that
have evaded cleanup, dictates that the Army
maintain security at Fort Ord and the
development of Fort Ord be postponed
indefinitely until the danger to occupants is
further minimized to a rational and acceptable
level.
Army1* fto*pon«o to Comment*
The schedule for cleanup actions underway at
Fort Ord are mandated in a Federal Facilities
Agreement that was signed by the Department of
the Army and the regulatory agencies. All areas
of Fort Ord that require investigation and cleanup
are in various stages of the cleanup process.
Under the federal Superfund law (CERCLA),
properties that are clean or have been cleaned up
to the satisfaction of the U.S. Environmental
Protection Agency) are eligible for transfer to
other parties.
The Army recognizes that it is responsible to
provide for the safe occupation of Fort Ord. As
such, the Army has undertaken an aggressive
investigation and cleanup program for
contaminated sites within Fort Ord.
The future land use for the Fire Drill Area (OU 1)
reported in the Proposed Plan is based on the
Army's understanding of the Fort Ord Reuse
Authority Preliminary Plan. The FDA will be
within a habitat management unit protected by
the UC Natural Reserve System because of the
presence of endangered plant and wildlife
species, not because chemicals at the site pose a
risk to human health. The Risk Assessment
summarized in the Proposed Plan evaluated the
risk to students, a child visitor, and a worker
(including maintenance workers or park rangers).
The risk resulting from exposure to chemicals
remaining in soil at the site were found to be less
than one in a million (the EPA's target risk range
for Superfund sites is one in ten thousand to one
in one million). The groundwater is currently
being cleaned up, and will continue being
cleaned up until the concentrations of chemicals
remaining in groundwater are reduced to levels
that pose an acceptable human health risk.. The
risk to trespassers has been adequately evaluated
in the risk assessment in the worker, student.
and child visitor receptor scenarios. In addition,
at cleanup the risks are protective for
unrestricted use of the site.
The purpose of the Proposed Plan was to
describe the selected remedial alternative for OU
1, not to discuss general land use issues, the
moral obligation of UC to protect its students, or
the general development of Fort Ord.
The groundwater extraction and treatment system
currently operating at OU l has been proven
effective at capturing and containing the
chemical contaminant plume, and eliminating
off-Site migration of groundwater containing
chemicals. A detailed study of the geologic and
hydrogeologic characteristics of the site was
conducted prior to designing the groundwater
remediation system. The groundwater extraction
and treatment system was designed for maximum
effectiveness given site-specific conditions.
While the cleanup of contaminated groundwater
will reduce the overall concentrations of
A38359-H
July 25. 1995
United State* Department of the Army 12
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Responsiveness Summary
chemicals in the groundwater aquifer, it is
unlikely that all of the detectable concentrations
of chemicals will be completely eliminated.
However, aquifer cleanup goals have been
established that have been shown to be protective
of human health and the environment and are
within the EPA's target risk range for Superfund
sites. The existing groundwater remediation
system is designed to operate until the aquifer
cleanup goals are achieved.
As stated above, the cleanup process is part of a
Federal Facilities Agreement-established timeline
and the transfer of property is consistent with the
Superfund laws of this country.
3.3.2.2 Reprint of, and Army
Response to, tho Letter*
Received from UCSC
December 20, 1 994, Loiter
We have reviewed the report issued
November 18,1994 outlining the proposed plan
for cleanup of the Fritzsche Army Airfield Fire
Drill Site, also known as the "Burn Pit." As you
may be aware, the Memorandum of Agreement
between the U.S. Army and the University of
California specifies this property for conveyance
to the University upon the completion of its
cleanup. To this end we have acute interest in
the proposal.
In order to be able to respond to the notice, we
need additional information. In particular, we
request the following:
Soils:
1. Concentrations of all organic compounds and
lead in the soil at the completion of treatment
and baseline concentrations used in making
the soil health risk assessment.
2. Details of the biotreatment process: what
organisms; duration; concentrations of
organics and metals before versus after
biotreatment.
3. Copy of the "Draft Technical Memorandum:
Approach to Evaluate Potential Groundwater
Quality impacts in which it was concluded
that the OU 1 site does not need the kind of
impermeable cap that OU 2 does.
Groundwater:
1. Details of the groundwater extraction and
treatment system; number and location of the
monitoring and extraction wells; character of
nutrients added to the treated groundwater.
2. Concentrations of the volatile organics
through time (5 years), and evidence that the
plume is confined to the A-aquifer and not
migrating offsite.
3. The treatment process appears to be
ineffective for tetrachloroethane and
incomplete for trichloroethane. This clearly
requires further work before the OU 1
property would be acceptable to UC even if it
is eligible for transfer under CERCLA. Do
you (sic) more information you can share
with us on these treatment processes.
As you may also be aware, the University cannot
take on the obligation to continue the cleanup
activities that are prescribed. At some point we
would like to further discuss the Army's
intention to convey given the extension of the
cleanup activities and the schedule for
conveyance. Thank you for your help in this
matter.
Army* Response to Docombor 20, 1994,
UCSC Loiter
Specific to your request for additional
information, baseline chemical concentrations
used in the soil health risk assessment and
chemical concentrations at the completion of soil
treatment are presented in the OU I Remediation
Confirmation Study, Fritzsche Army Airfield Fire
Drill Ana. Fort Ord, California. May 1994.
Details of the groundwater extraction and
treatment system, concentrations of contaminants
with time, and evaluation of the groundwater
extraction system are presented in the
Groundwater and Soil Treatment System
Evaluation Report. August 1988 • May 1991.
Fritzsche Army Airfield Fire Drill Area, Fort Ord,
California. Jufy 1992. The Army has transmitted
copies of these documents to UCSC.
Additionally, these reports and others referenced
A383S9-H
July 25, 1995
United States Department of the Army 13
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Reaponslveness Summary
in this document detailing the investigations
conducted at OU 1 are available for public review
at two information repositories located at the
Chamberlain Library, Building 4275, North-South
Road, Presidio of Monterey Annex (formerly
Fort Ord), California, and at the Seaside Branch
Library, 550 Harcourt Avenue, Seaside,
California. Copies of these reports are also part
of the OU 1 Administrative Record, which is
located at Harding Lawson Associates, 1143 Echo
Avenue, Suite E, Seaside, California.
The groundwater extraction and treatment system
is effectively removing volatile organic
compounds, including tetrachloroethane and
trichloroethane. Based on current information, it
is estimated that aquifer cleanup goals may be
met after ten years of continued system
operation.
The federal Superfund Law (CERCLA) states that
property can be transferred once the property is
cleaned up or a remedy is in place and operating
effectively to the satisfaction of the EPA. The
Army will retain the responsibility for operating
the groundwater remediation system and will
retain right of access to the treatment system and
wells at OU 1. The Army will address the
schedule for conveyance with UCSC in future
discussions held at the convenience of both
parties.
December 21, 1994, Latter
This letter is to clarify issues surfaced in my
12/20/94 transmittal, and to reiterate our
intention to respond to the information presented
for review regarding the Army's plan to continue
remedial action at OU 1. The University of
California anticipates eventual acceptance of this
property, subject to completion of the cleanup
activities.
We have requested information that is substantial
in content and will require some time to
evaluate. We do not anticipate sending written
response, beyond the limited concerns in my
12/20/94 transmittal, until after the close of the
published comment period. It is not necessary
for you to alter the comment period to receive
our response, but you should be aware that we
may have written remarks to forward early next
year.
As mentioned in my prior letter, we will not
absorb the responsibility of the cleanup activities
that are prescribed for remediation at OU l,
given that we are prepared to discuss the Corps
of Engineer's intention to convey.
Army's Response to December 21,1994,
UCSC Utter
The Army acknowledges that UCSC will be
providing additional correspondence regarding
cleanup activities at OU 1. This correspondence
will not be received during the public comment
period and therefore will not be addressed in this
ROD. As stated above, the Army will retain the
responsibility for operation and maintenance of
the groundwater remediation system.
A383S9-H
July 25. 1995
United States Department of the Army 14
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4.0 REFERENCES
Harding Lawson Associates, 1986. Remedial
Investigation/Feasibility Study of Soil
Contamination, Fire Drill Area, Fort Ord,
California. Report prepared for the Department
of the Army, Corps of Engineers, Sacramento
District. April 14.
, 1987a. Addendum, Remedial
Investigation/Feasibility Study of Soil
Contamination, Fire Drill Area, Fort Ord,
California. Report prepared for the Department
of the Army, Corps of Engineers, Sacramento
District. June.
, 1987b. Remedial Investigation/ Feasibility
Study of Groundwater Contamination, Fritzsche
Army Airfield Fire Drill Area, Fort Ord, California.
Report prepared for the Department of the Army,
Corps of Engineers, Sacramento District. June.
, 1989. Construction Report, Groundwater
and Soil Treatment System, Fritzsche Army
Airfield Fire Drill Area, Fort Ord, California.
Report prepared for Department of the Army,
Corps of Engineers, Sacramento District. May.
, I994a. OU 1 Remediation Confirmation
Study, Fritzsche Army Airfield Fire Drill Area,
Fort Ord, California. Report prepared for the
Department of the Army, Corps of Engineers,
Sacramento District. May.
, 1994b. Draft Final Technical
Memorandum, Applicable or Relevant and
Appropriate Requirements, Existing Carbon
Adsorption Groundwater Extraction and Treatment
System, Operation Unit 1. May.
, 1994C. Draft Final Technical
Memorandum, Preliminary Remediation Goals,
Fort Ord, California. June 24.
, I994d. Proposed Plan for the Fritzsche
Army Airfield Fire Drill Area (OU 1), Fort Ord,
California. Completion of Soil Treatment
Activities and continued Groundwater Extraction
and Treatment Proposed for the Cleanup of
Fritzsche Army Airfield Fire Drill Area Site at
Fort Ord, California. Prepared for Sacramento
COE. November 18.
, 1994e. Draft Final Remedial Investigation/
Feasibility Study, Fort Ord, California. December.
, 1994f. Draft Third Addendum to the
Technical Memorandum, Preliminary Remediation
Goals, Fort Ord, California. December 15.
Jones and Stokes, 1994. Installation-Wide
Multispecies Habitat Management Plan for Fort
Ord, California. Report prepared by Corps with
assistance from Jones & Stokes. February.
US Environmental Protection Agency (EPA),
1995. Memo from Standford J. Smucker, Region
K Preliminary Remediation Goals (PRGs) First
Half 1995. February 1.
A383S9-H
July 25, 1995
United States Department of the Army 15
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TABLES
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Table 1. Chemicals of Concern in Groundwater and Aquifer Cleanup Goals
Chemicals of Concern
Federal
MCL
(ppb)
State
MCL
(ppb)
Maximum
Concentration
Detected
(ppb)
Maximum
Concentration
Detected
(1994) (ppb)
Aquifer
Cleanup
Goals
(ppb)'11
Discharge
Limits for
Treated
Water"1
(ppb)
Benzene
Chloroform
1.1-Dichloroethane
1.2-Dichloroethane
1.1 -Dichloroethene
Total 1,2-dichloroethene
Methyl Ethyl Ketone
Tetrachloroethene
1.1,1-Trichloroethane
Trichloroethene
5
100
5
7
5
200
5
5
0.5
6
S
200
5
76
3.2
40
1.2
19
170
1.700
8
110
650
ND (<0.5)
0.57
1.4
ND (<1.0)
3.2
8
400
S
8.2
20
1
2.0'"
5
0.5
6
6"'
1.900141
5
200
5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
(l) The combined, or additive effect of exposure to all chemicals at the levels listed was found to range
from 2 x 10"* to 3 x 10'*. This cumulative risk is within the acceptable risk range, and is health
protective.
(2) Aquifer cleanup goal lower than federal or state MCL selected based on risk calculations.
(3) Cleanup goal based on the lowest MCL for isomers.
(4) Based on Preliminary Remediation Goal (EPA. 1995) from Region DC Preliminary Remediation Goals
First Half 1995. February 1. 1995.
(5) Discharge to areas overlying contaminated groundwater plume need only meet aquifer cleanup
goals. Discharges to waters outside the contaminated plume will be treated to "non-detected" as
measured by EPA Method 502.2.
ND Chemical not detected during 1994 sampling events.
ppb Parts per billion.
MCL Maximum Contaminant Level.
A38359-H
JuJy 25. 1995
United State* Department of the Army
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Table 2. Th« Remedy's Compliance with
CERCLA Guidance
CERCLA Screening Criteria
Overall Protection of Human
Health and the Environment
Compliance with ARARs
Short-Term Effectiveness
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
Implementability
Regulatory Agency
Acceptance
Community Acceptance
Estimated Cost (NPV)J
The Remedy: Groundwater Extraction and Treatment by Carbon
Adsorption and Soil Bioremediation
Currently protective of human health and the environment
through containment and treatment of the groundwater plume.
Soil is protective of human health and the environment.
Complies with applicable or relevant and appropriate
requirements.
Effective in the short-term; already has reduced groundwater
contaminant concentrations by approximately one half. Soil
treatment is complete.
GCT = 10 years
Achieving final aquifer cleanup goals for groundwater may be
technically impractical. Soil cleanup goals have been achieved.
Reduces the toxicity, mobility, and volume of contaminants in
groundwater and soil through treatment.
Already has been implemented at OU 1.
The State of California and the U.S. EPA accept this alternative.
Based on comments received during the public comment period,
the public generally accepts the remedy.
$950,000.
Cost effective. Furthermore, capital cost for the installed
treatment system has already been invested.
1 GCT = Groundwater cleanup time
2 NPV = Net present value costs are provided in 1994 dollars.
A38359-H
July 25. 1995
United States Department of the Army
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Table 3. Chemicals Detected In Sell
Prior To and After Excavation and
Preliminary Remediation Goals
Fort Ord
Maximum Maximum Preliminary
Concentration Prior Concentration After Remediation Goal
to Excavation (ppm) Excavation (ppm) (PRG)t (ppm)
Benzene
Methyl Ethyl Ketone
Toluene
Ethyl Benzene
Xylenes
1,1,1-Trichloroethane
Trichloroethene
Methylene Chloride
1 ,4/1,2-Dichlorobenzene
1 ,3-Dichlorobenzene
2,3,7,8-TCDD **
Lead
0.012
2.9
0.048
0.027
0.051
0.047
0.076
0.008
0.007
<0.001
NA*
470
ND (0.001)
ND (0.005)
0.001
ND (0.001)
0.002
ND (0.001)
ND (0.001)
0.003
ND (0.001)
0.001
3.5X10"6 *
75.07
1.4/a/
620
190
830
130
200
1.1
0.90
7.4/a,b/
330
1.2X10"6
240
* 2,3,7,8-Tetrachlorodibenzo-p-dioxin-toxic equivalent concentration.
** Only COPC identified for soil in the Confirmation Study Risk Assessment.
NA Not analyzed for prior to excavation.
ppm Parts per million.
t Fort Ord PRGs are based on unrestricted use. The development of the PRGs is presented in
Technical Memorandum (HLA, 1994c, HLA, W94j}.
la/ EPA, 1995. Region K Preliminary Remediation Goals (PRGs), First Half 1995.
/b/ Value is the lower of 1,2- and 1,4-dichlorobenzene.
A38359-H
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United States Department of the Army
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PLATES
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PLATE 1. FORT ORD LOCATION MAP
Record of Decision
Operable Unit 1
Fort Ord, California
DEL RE
OAKS \X
MONTEREY
APPROXIMATE
SCALE IN MILES
-------
PLATE 2. SITE PLAN
Record of Decision
Operable Unit 1
Fort Ord, California
MW-OU1-09-A
MW-OU1-17./L-
MW-OU1-09-A.5
MW-OU1-11-A
5
MW-OU1-10-A
EXPLANATION
Extraction Well, Uppermost Aquifer
Monitoring Well, Uppermost Aquifer
Piezometer, Uppermost Aquifer
Well Screened in First Water-Bearing Zone
Below the Uppermost Aquifer
Approximate Boundary of Former
Biotreaiment Area
Approximate Fence Location
^
Farmer Drum Storage Area
Former Bum Pit Area
jijlii:!!! Treatment System Area
T Approximate Groundwater Row Direction
^— Acoroximate Extent of VOCs in Groundwater
200
400
SCALE IN FEET
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PLATE 3. GROUNDWATER EXTRACTION SYSTEM
Record of Decision
Operable Unit 1
Fort Ord, California
Activated Carbon
Adsorption of Volatile
Organic Chemicals
EXPLANATION
Jt System Sampling
IT Port
~~ISoll Tftitmem Sections
_Jol Sysum AieNoim
Ooenuon
(Soil Remeoiition
Complete)
Microbial Nutrient
Augmentation
1
Groundwater
Extraction
4
Spray
Irrigation
Recharge
Area
Microbial Consumption'
of MEK and
Hydrocarbons BIOTREATMENT
AREA
Groundwater
Table
Groundwater
Recharge
23366 02772
060695U
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PLATE 4. CONFIRMATION BORING AND SURFACE
SAMPLE LOCATIONS
Record of Decision
Operable Unit 1
Fort Ord, California
^CB-OU1-14
\
CB-OU1-08 \
A. N
MW-OU1-07-A
CB-OU1-07j
SS-OU1-01 ,
EXPLANATION
Monitoring Well. A-aquifer
Soil Boring
Surface Soil Sample
Maximum Extent of 1988 Excavation
Biotreatment Area Perimeter
Former Bum Pit Perimeter
Approximate Extent of Drum Unloading Area
Approximate Extent of Excavation
of Contaminated Soil
Approximate Fence Location
50
SCALE IN FEET
23366 0277!
060695LZ
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APPENDIX
APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR
THE SELECTED ALTERNATIVE
-------
APPENDIX
CONTENTS
Al.O ACTION-SPECIFIC ARARS 1
A2.0 CHEMICAL-SPECIFIC ARARS 3
A3.0 LOCATION-SPECIFIC ARARS 4
A38359-H United States Department of the Army All
July 25, 1995
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APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
FOR THE REMEDY
The promulgated standards described below are
action-, chemical-, and location-specific ARARS
for the remedy. The standards described below
are "applicable," or "relevant and appropriate," for
groundwater remediation. These standards are
designed to be protective of human health and
the environment and to be technically achievable
with existing analytical and treatment
technologies.
A1.0
ACTION.SPECIFIC ARARS
Remedial action at OU 1 consists of an existing
groundwater extraction and carbon adsorption
treatment system, with surface reinfiltration of
treated groundwater. Under this action, treated
groundwater is reused; and onsite reuse does not
require a water reclamation permit from the
RWQCB. Treated water could also be used
offsite for irrigation, subject to approval from the
Monterey County Water Resources Agency;
however, onsite reuse has been the only practice
to date. To maximize the opportunity for
effective management of treated water and
minimize chemical concentrations in discharges,
the Army will treat groundwater impacted with
volatile organic compounds (VOCs) to Maximum
Contaminant Level (MCL) concentrations or to
method detection limits. These discharge limits
were chosen for OU 1 after considering
site-specific conditions, including the
contaminants to be discharged and the
designated beneficial uses of the receiving waters,
available treatment technologies and cost, as
discussed in the OU 1 Proposed Plan
(HLA, 1994d).
A list of ARARs are discussed below:
• National Pollutant Discharge Elimination
System (NPDES) Permit (40 CFR 122)
NPDES substantive permit requirements must
be met for effluent discharges to surface
water. If a selected remedial action results in
a discharge to surface waters, compliance
with NPDES requirements must be achieved.
However, at present, the existing GET system
does not discharge directly to surface waters
or storm drains.
National Primary and Secondary Ambient Air
Quality Standards (NAAQS), 40 CFR 50
The federal Clean Air Act, 42 USCA
7401-7642 defines National Primary and
Secondary Ambient Air Quality Standards
(NAAQS), which are listed in 40 CFR 50.
Under certain circumstances, these may be
applicable; however, the Monterey Bay
Unified Air Pollution Control District
(MBUAPCD) requirements, if applicable,
would be the standard because they are more
stringent.
Monterey Bay Unified Air Pollution Control
District (MBUAPCD) Regulation U (New
Sources) and Regulation X (Toxic Air
Contaminants)
The MBUAPCD regulates New Sources under
requirements described in Regulation n,
Rule 207, and restricts specific discharges of
organic compounds to the atmosphere
through remedial actions (such as fugitive
odors from consolidation of waste and
removal of organic compounds from
groundwater) in accordance with Rule 1000
of the above-mentioned regulation. The
MBUAPCD requirements may limit emissions
of total and individual organic compounds
on a site-specific basis and/or may require
emission controls.
Under Rule 207, emissions of most
individual organic compounds are generally
restricted to 25 Ibs/day using Best Available
Control Technology (BACT). In addition, the
MBUAPCD regulates releases of certain
identified or potential air toxics at levels
determined to be "appropriate for review." In
some cases, a Risk Assessment may be
required. The MBUAPCD requirements
would be ARARs for treatment of
groundwater by methods generating
emissions; however, the existing GET system
using carbon adsorption does not generate
emissions.
A3B3S9-H
July 25. 1995
United States Department of the Army A1
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Applicable or Relevant and Appropriate Roqulromonta for tho Romody
Health and Safety Standards for Management
of Hazardous Waste, CCR Title 22, Divisions
4.5, Chapter 14, Article 9,
Sections 66264.170-178
These standards apply to owners and
operators who store hazardous waste for
longer than 90 days in containers. They
cover use and management of containers,
containment, inspection, and closure. These
standards are applicable to spent carbon
drums that are stored at OU 1 awaiting offsite
regeneration only if they contain hazardous
levels of VOCs and exceed 90 days of storage.
Standards for owners and operators of
hazardous waste treatment, storage, and
disposal facilities sections, CCR Title 22,
Division 4.5, Chapter 14, Article 16,
66264.600-603
Applies to owners and operators of facilities
that treat, store, or dispose of RCRA
hazardous waste in miscellaneous units.
Covers environmental performance standards,
monitoring, inspections, and post-closure
activities. These standards are applicable to
spent carbon drums that are stored at OU 1
awaiting offsite regeneration only if they
contain hazardous levels of VOCs and exceed
90 days of storage.
Adsorbents and other solid materials used for
treatment of water containing VOCs, such as
activated carbon, may contain levels of
chemicals after use that are considered to be
hazardous waste. Title 22 regulations
pertaining to the treatment, storage, or
disposal of such hazardous wastes will be
applicable to the extent that wastes are
managed on site.
Standards for owners and generators of
hazardous watte treatment, storage, and
disposal facilities, CCR Title 22, Chapter 14,
Article 2, Section 66264.14
Owners and operators of hazardous waste
treatment, storage, or disposal (TSD) facilities
must prevent the unknowing entry of persons
or livestock onto the active portions of the
facility and warning signs must be posted.
Standards for owners and generators of
hazardous waste treatment, storage, and
disposal facilities, CCR Title 22, Chapter 14,
Article 7, Section 66264.119.
This standard requires that certain notices
may be placed in a deed.
Land Disposal Restriction, CCR Tide 22,
Chapter 18, Article 1, Section 66268.7
These restrictions requires laboratory analysis
of wastes intended for landfill disposal to
establish that the waste is not restricted from
landfill disposal.
Standards Applicable to Generators of
Hazardous Waste, CCR Title 22, Chapter 12
Article 3, Section 66262.34
Establishes standards for generators of
hazardous waste. If hazardous waste is
generated at the site, the substantive portions
of these regulations will apply, such as
labelling and manifesting waste prior to
disposal. A generator may accumulate
hazardous waste for 90 days or less.
Hazardous Material Release Response Plans
and Inventory (Health and Safety Code,
Division 20, Chapter 6.95; 19 CCR, Chapter 3,
Subchapter 3): Emergency Response Actions
An emergency response plan (ERP) and
inventory must be in place during remedial
actions involving hazardous waste if carbon
drums contain hazardous levels of chemicals.
Water Quality Control Plan, Central Coast
Basin
The Basin Plan establishes numerical and
narrative water quality standards. The Plan
also contains requirements for
implementation plans or action plans for
attaining compliance with these standards.
The requirements of the Basin Plan are
applicable to groundwater remediation
activities. Each Regional Board promulgates
and administers a Water Quality Control Plan
for ground and surface water basin(s) within
its region. The State Board also promulgates
statewide water quality control plans that the
regional boards administer. The Plans
establish water quality standards (including
beneficial use designations, water quality
objectives to protect these uses, and
implementation programs to meet the
A38359-H
July 25. 1095
United Statoa Department of th* Army A2
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Applicable or Relevant and Appropriate Requirement* for th« Remedy
objectives) that apply statewide or to specific
water basins.
Portions of the Central Coast Region Basin
Water Quality Control Plan (RWQCB, 1989)
are ARARs. The Basin Plan classifies
groundwater based on beneficial uses. This
classification is based on "data collected by
the local agencies and/or dischargers
regarding the quality and use of waters in
their vicinity." The State Water Resources
Control Board Resolution 88-63 is also
incorporated into the Basin Plan to provide
guidance for determining "sources of drinking
water." Under this guidance, groundwater is
generally considered to be potential drinking
water unless it fails one or more of three
criteria in Resolution 88-63 (discussed
below).
State Water Resources Control Board
Antidegradation Policy, Resolution No. 68-16
The State Water Resources Control Board's
(SWRCB) Resolution No. 68-16 Statement of
Policy with Bespect to Maintaining High
Quality of Waters in California is an ARAR if
a discharge to high quality waters of the state
occurs. Resolution 68-16 is not a 'zero
discharge' standard but rather a statement
that existing quality be maintained when it is
reasonable to do so. Specifically, where any
activities result in discharges to high quality
waters, dischargers shall use the best
practicable treatment or control of the
discharge necessary to avoid pollution or
nuisance and to maintain water quality
consistent with maximum benefit to the
people of the State. Discharges to high
quality waters (outside the contaminated
plume) will be treated to "nondetected" as
measured by EPA Method 502.2. Discharges
to water overlying the groundwater plume are
not considered discharges to high quality
water and will be treated to MCLs. Discharge
levels (Table 1) were chosen for OU 1
considering site-specific conditions, including
the contaminants to be discharged and the
designated beneficial uses of the receiving
water, available treatment technologies, and
cost.
Sources of Drinking Water Policy, Resolution
No. 88-63
This resolution specifies that all ground and
surface water is an existing or potential
source of drinking water unless TDS are
greater than 3,000 ppm, the well yield is less
than 200 gallons per day from a single well,
or the groundwater is unreasonable to treat
using best management practices or best
economically achievable treatment practices.
This resolution is applicable to OU 1. The
resolution can be used to establish a general
criteria for designating water use.
Groundwater in the upper aquifer at the FDA
site is not currently used for drinking water;
however, the upper aquifer has been
identified as having beneficial uses including
domestic, agricultural, and industrial water
supplies.
State Water Resources Control Board,
Resolution No. 92*49, KLg.
Authorizes Regional Water Boards to ensure
that dischargers are required to clean up and
abate the effects of discharges in a manner
that promotes attainment of either
background water quality or the best water
quality which is reasonable if background
levels cannot be restored. This requirement
is applicable to the aquifer cleanup levels.
Cleanup to the MCLs or lower risk-based .
level satisfies this requirement.
Discharges of Waste to Land, CCR Title 23,
Division 3, Chapter 15, Article 5,
Sections 2550.4
This title regulates discharges of waste to
land. Groundwater cleanup requirements
under this chapter may be relevant and
appropriate to the GET system operated at
OU 1. Article 5 includes requirements for
monitoring and cleanup. Cleanup to the
MCLs or lower risk-based level satisfies the
requirements.
A2.0
CHEMICAL-SPECIFIC ARARS
From the list of all chemicals detected at OU 1,
chemicals of potential concern were identified in
groundwater in the Rl/FS (HLA, 1986; 1987a, b)
and were used to identify ARARs and target
cleanup levels for the FDA site. Chemicals of
potential concern are listed in Table 1 of the .
main text.
A383S9-H
July 25, 1995
Unite* States Department of the Army A3
-------
Applicable or Relevant and Appropriate Requlromente for tho Remedy
National Primary Drinking Water Standards
(40 CFR Part 141)
Chemical-specific drinking water standard
MCLs have been promulgated under the Safe
Drinking Water Act (SDWA). Drinking-water
MCL goals (MCLGs) have also been
promulgated under the SDWA. MCLGs
above zero are considered chemical-specific
ARARs under the NCP (40 CFR
300.430[e][2][i)[B]). When MCLGs are equal
to zero (which is generally the case for any
chemical considered to be a carcinogen), the
MCL is considered to be a chemical-specific
ARAR, instead of the MCLG (40 CFR
300.430[e)[2][i][C]). These requirements are
considered relevant and appropriate.
California Safe Drinking Water Act CCR
Title 22, Division 4, Chapter 15, Articles 4,
5.9, and 8
California primary drinking water standards
establish enforceable limits for chemicals that
may affect public health or the aesthetic
qualities of drinking water. However, only
those State requirements that are more
stringent than federal standards are ARARs.
These requirements (State MCLs) are
summarized in the RI/FS and Proposed Plan
for OU 1.
Identification and Luting of Hazardous
Wastes Title 22, CCR Chapter 11
The Cal/EPA identification and listing of
hazardous wastes may be an ARAR if
chemicals are identified at hazardous levels.
Establishes and defines procedures and
criteria for identification and listing of
Resource Conservation and Recovery Act
(RCRA) and non-RCRA hazardous waste.
This ARAR is applicable if hazardous levels
of chemicals are present.
A3.0
LOCATION'SPECIFIC ARARS
The following location-specific ARARs are
considered for OU 1:
• Fault Zone
Under 40 CFR 264.18a, new hazardous waste
treatment, storage, or disposal (TSD) units are
prohibited from being located within 200 feet
of a geologic fault displaced in Holocene
time. The FDA site is located within a
seismically active region, but not near such a
fault. Therefore, this regulation does not
apply to the site.
• Floodplain
Requirements under 40 CFR 264.1 eb state
that a hazardous waste TSD facility should
not be located within a 100-year floodplain
unless it is design to prevent washout of any
waste by a 100-year flood. The FDA site is
not located within a 100-year floodplain;
therefore 40 CFR 264.18b is not an ARAR.
• Archaeological Areas
Remedial actions that may cause irreparable
harm, loss, or destruction of significant
artifacts are restricted under the National
Historical Preservation Act (16 USC 469).
The law requires action to recover and
preserve such artifacts. The FDA site is not
known to be located within a historically
significant area. Therefore, this statute is not
an ARAR.
• Critical Habitat for Endangered Species
The Endangered Species Act of 1973
(16 USC 1531 et seq.) requires action to
conserve endangered species and preserve or
restore a critical habitat. The FDA site is not
• known to be a critical habitat for any
endangered species; therefore, this statute is
not an ARAR.
• Coastal Zone
The Coastal Zone Management Act
(16 USC 1451 et seq.) requires activities
conducted within the coastal zone to be
conducted in a manner consistent with the
state-approved management program. The
FDA is not within the coastal zone; therefore,
this statute is not an ARAR.
• Areas Affecting Streams or Rivers
The Fish and Wildlife Coordination Act
(16 USC 661 et seq.) requires fish and
wildlife to be protected if remedial actions
modify the drainage channel or other features
of the stream or river. No foreseeable
remedial action at the FDA site would modify
a drainage or other stream feature.
Therefore, this statute is not an ARAR.
A38359-H
July 25, 1995
United States Department off the Army A4
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AGENCY COVER LETTERS
-------
RPR 10 '96 03: 45PM . P. 2
UNITED STATES ENVIRONMENTAL PROTECTION AOENCY
75 Hawthorn* Sirt*t
Sin Fflnetooo, CA
29, 1995
Commander
u.s, Army DLZFLC and POM (Fort ora)
ATTN: ATZP-2P (flail Youngblood)
Presidio of Monterey, CA, 93944-5006
Re i fort Ord ftuperfuad lite
Final ROD- operable Unit 1
Fritrsche Army Airfield FDA
Dear Ms. Youngbloedi
Att»ch*d ic EPA'c eonourrenoe eigmtur* for tha OU 1 ROD for
the Fritzcohe Aray Airfield Fire Drill Area. Our concurrence ie
based on the draft final ROD dated June 7, 1995 and received at
EPA on June 6, 1995. Under the terae of the Federal Facility
Agreement for Fort Ord, the document became final on July 8,
1995.
It if our understanding that the final ROD haa not been
aigned by the Army, pending aone non-aubatantive change• in the
ROD text. Please forward a copy of the proposed modifications to
the ROD to John Chesnutt prior to eignature.
If you have any questions about this issue, please contact
John Ch«»nutt at (415)-744-2367.
Sincerely
V*'Julia Anderson
Directori Federal
Facilities Cleanup Office
Attachment: Signature Page of OU 1 ROD
cci Mr. Jim Austreng. CA DTSC
Pritiitd on
|10-Apr-96 7;46pl
-------
flPR 10 '96 03: 46PM
' P. 3
Declaration
He Mettee-McCutchon
Colonel, U.S. Amy
Garrison Comoender
Presidio of Monterey
Dota
Gail Ycungblood Dale
Acting BRAC Envtronmentel Coordinator
Preaidio of Monterey
UiS. Environmental Protection
nAndnson Bett
ftrector, Federal Pacilitios Qtanup Office
U.S. EovlronmiQUl Protectioa Agency,
Regioa DC
California Environmental Protection
Agency
Anthony J. i-*^", P.E.
Date
Chief of QperttlQU, OfTice of Military Facilities
California Environmental Protection Agency
Department of Toxic SubJtaacu Control
Roger W. Brfggs Date
Executive Officer
CaJifomla Environmental Protection Agency
Central Gout Rtgtona] Water Quality Control
Board
A3B35B-H
June 7, 1B9S
United Statee Department ol the Army
|10-Apr-96
-------
STATE Of CMIfOHNU—CMIfOHNIA ENVIRONMENTAL CBOTtCTlON AGENCY PETE WIISON,
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
REGION I
10131 CROYDON WAY. SUITE 3
SACRAMENTO. CA 93827-2106
(91S) 255-3545
May 9, 1996
Department of the Army
Commander, DLIFIC and POM (Fort Ord)
Attention: AT2P-S? {Ms. Gail Youngblood)
Presidio of Monterey, California 93944-5006
OPERABLE UNIT 1 RECORD OF DECISION, FORT ORD
Dear Ms. Youngblood:
This letter transmits four copies of the June 7, 1995
version of the Operable Unit One Record of Decision. Each of the
copies contains a signature page with original signatures by
Mr. Anthony Landis, of the Department of Toxic Substances Control
and Mr. Roger Briggs, of the Central Coast Regional Water Quality
Control Board. Upon signing by the United States Army, please
return one copy with original signatures to me and one to
Mr. Grant Himebaugh, of the Regional Water Quality Control
Board. One copy should also be sent to Ms. Lida Tan, of the
United States Environmental Protection Agency.
If you have any questions, please call me'at (515} 255-3738.
Sincerely,
-/r
JO-' William Kilgore
Project Manager
Office of Military Facilities
Enclosure
cc: Mr. Grant Himebaugh (w/o enclosure)
Regional Water Quality Control Board
Central Coast Region
61 Higuera Streec, Suite 200
San Luis Cbispo, California 93401-5414
BK:«-- is.'.:;!-*-"--'- *"»
-------
Ms. Gail Youngblood
May 9, 199S
Page Two
cc: Ms. Lida Tan (H-9-4) (w/o enclosure)
United States Environmental Protection Agency
Region IX
75 Hawthorne Street
San Francisco, California 94105
BK14W.056Yljs-a:wardttl
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