PB97-964517
EPA/541/R-97/206
February 1998
EPA Superfund
Record of Decision:
Norton Air Force Base OU 3,
Site 19 Waste Drum Storage Area No. 1
San Bernardino, CA
6/25/1997
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SFUNO RECORDS CTR
3093-00464
NORTON AIR FORCE BASE
INTERIM RECORD OF DECISION
OU3JRPSITE19
WASTE DRUM STORAGE AREA NO. 1
JULY 21,1997
United States Air Force Headquarters
Air Force Base Conversion Agency
Norton Operating Location
San Bernardino, California 92408
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INTERIM RECORD OF DECISION
OU3, IRPSITE19
WASTE DRUM STORAGE AREA NO. 1
United States Air Force Headquarters
Air Force Base Conversion Agency
Norton Air Force Base
California 92409
July 21, 19^7
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TABLE OF CONTENTS
Page
FIGURES iii
IABLES iii
ACRONYMS jv
DECLARATION v
DECISION SUMMARY
1.0 SITE NAME, LOCATION. AND DESCRIPTION 1
1.1 LOCATION 1
1.2 POPULATION 1
1.3 LAND USE 1
1.4 CLIMATE 1
1.5 GEOLOGY 1
1.6 SOIL 4
1.7 SURFACE WATER 4
1.8 HYDROGEOLOGY 4
1.9 PRODUCTION WELLS 4
1.10 THREAT OF SITE 4
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
3.0 COMMUNITY PARTICIPATION . 7
4.0 SCOPE AND ROLE OF THE OPERABLE UNIT 8
5.0 SUMMARY OF SITE CHARACTERISTICS 9
5.1 SOURCES OF CONTAMINATION 9
5.2 CONTAMINATION AND AFFECTED MEDIA 12
6.0 SUMMARY OF RISK ASSESSMENT 13
6.1 HEALTH RISKS 13
6.2 ECOLOGICAL RISKS 13
6.3 CONCLUSIONS 14
7.0 DESCRIPTION ALTERNATIVES 15
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
8.1 THRESHOLD CRITERIA 17
8.2 PRIMARY BALANCING CRITERIA 18
8.3 MODIFYING CRITERIA 18
9.0 SELECTED REMEDY 20
10.0 STATUTORY DETERMINATION 21
10.1 PROTECTIVENESS OF HUMAN HEALTH AND THE ENVIRONMENT 21
10.2 COMPLIANCE WITH ARARs 21
10.3 COST EFFECTIVENESS 21
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY & TECHNOLOGIES) TO THE MAXIMUM
EXTENT PRACTICABLE fc ; 21
10.5 REFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT 21
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES 22
site19.fm ii October 27, 1995
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TABLE OF CONTENTS (continued)
12.0 BIBLIOGRAPHY 23
ATTACHMENTS
ATTACHMENT A - ADMINISTRATIVE RECORD INDEX FOR THE IRP SITE 19 ROD
ATTACHMENT B - RESPONSIVENESS SUMMARY
FIGURES
Number Page
1 Regional Map Showing Location of Norton Air Force Base 2
2 Central Base Area Features, Norton Air Force Base 3
3 Site 19 & Former Aircraft Washing Facility, General Features 10
TABLES
Number Page
1 Summary of Site 19 PCB Soil Data 9
2 Summary of Site 19 Soil Data (Excluding PCBs) 11
3 Summary of Costs 19
site19.fm iii October 27, 1995
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ACRONYMS
AF Air Force
AFB Air Force Base
Air Force United States Air Force
ARARs Applicable and/or relevant and appropriate requirements
CAL/EPA California Environmental Protection Agency
CBA Central Base Area
COM Federal COM Federal Programs Corporation
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
COC Chemical of Potential Concern
DD Decision Document
DOD Department of Defense
E&E Ecology & Environment
EIS Environmental Impact Statement
FS Feasibility Study
HAZWRAP Hazardous Waste Remedial Actions Program
IRP Installation Restoration Program
mg/kg milligrams per kilogram
NCP National Oil and Hazardous Subtstances Pollution Contingency Plan
OSWER Office of Solid Waste and Emergency Response
OU3 Operable Unit No. 3
PCB polychlorinated biphenyls
pCi/g pico Curie per gram
pCi/L pico Curie per liter
ppm parts per million
RAB Restoration Advisory Board
Rl Remedial Investigation
ROD Record of Decision
TCE Trichloroethylene
TCG Target Clean-up Goal
TPH Total Petroleum Hydrocarbons
Arg/kg micrograms per kilogram
USEPA United States Environmental Protection Agency
site19.fm
IV
October 27, 1995
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DECLARATION
SITE NAME AND LOCATION
Norton Air Force Base
Operable Unit Number 3
IRP Site 19 - Waste Drum Storage Area No. 1
San Bernardino, California
STATEMENT AND OF BASIS PURPOSE
This decision document presents the selected interim remedy for the Installation
Restoration Program (IRP) site 19 - the Waste Drum Storage Area No. 1 at Norton Air Force
Base. The selected remedy was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and Reauthorization Act of 1986, and to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
(40 Code of Federal Regulations (CFR) Part 300). This decision is based on information
contained in the administrative record for the site.
ASSESSMENT OF THE SITE
Threatened releases of hazardous substances from IRP site 19, if not addressed by
implementing the response actions selected in this Record of Decision (ROD), may present
an imminent and substantial endangerment to public health welfare, or the environment.
DESCRIPTION OF THE REMEDY
The response action addressed in this ROD addresses the principal public health and
environmental threats due to polychlorinated biphenyls (PCBs) in site soil by precluding
access to the soils and preventing uncontrolled releases. Through implementation of a
deed restriction, access to contaminated soils will be prevented. The remedy is deemed an
interim measure and an additional remedy may be considered when it is found necessary to
remove the concrete apron currently covering the contaminated soil.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The remedy does not involve treatment at this time,
but prevents mobility of contaminants through the continued use of an existing 24-inch
concrete layer over the contaminated soils. Because contaminated soils will remain in
place, controlled by a deed restriction, the 5 year review will be conducted on an ongoing
basis to ensure that the remedy continues to provide adequate protection of human health
and the environment. "
S19ROD2.TXT v September 12, 1996
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This Interin ROD has been reviewed and approved by:
Jff^-Jg \
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
1.1 LOCATION
Norton Air Force Base (AFB) (referred to herein as the "base" or "Site") is located in the
city of San Bernardino, San Bernardino County, California, 55 miles east of Los Angeles
and 60 miles west of Palm Springs (Fig. 1). Site 19 is located on the southern part of the
Central Base Area (CBA) just north of taxiway 8 and south of Building 763. Site 19 is
currently covered by a 24-inch thick concrete apron of the aircraft flightline (Fig. 2).
1.2 POPULATION
The population of San Bernardino County is 1,418,380 (U.S. Census, 1990), and consists
of both english- and spanish-speaking citizens. Currently only the officer's housing area of
the base is occupied by military personnel.
1.3 LAND USE
Current Land Use. Current land use at Norton AFB includes commercial and residential
activities. A portion of the base is still used for officer's housing. The airfield is being used
for public and commercial activities while the base is being converted to warehousing and
office park usage.
Land surrounding Norton AFB includes areas of residences, light and heavy industry, and
agriculture. Residential areas are located to the north and west. Light industrial areas are
located to the north, east, and to the southwest.
Future Land Use. Norton AFB was closed by the Department of Defense (DOD) on March
31, 1994. The property will be classified for some residential activities, but primarily for
commercial and industrial use after disposal. The area that incorporates IRP site 19 has
been classified for aviation and aviation support activities.
1.4 CLIMATE
The San Bernardino Valley is characterized by a semi-arid environment. The yearly average
high is 78°F and the yearly low 49°F. The average annual rainfall at Norton AFB is 1 2.72
inches.
Prevailing winds at Norton AFB are from the northwest. Annual average wind speed from
the west is 3 knots; maximum wind speed is 69 knots.
1.5 GEOLOGY
Norton AFB is located on a large apron of alluvium, characterized by great thickness, rapid
facies changes, and a wide range of fragment sizes.-The stratigraphy consists of
S19ROD2.TXT 1 September 12, 1996
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BERNARDINO
approximate seal*
! »!!«
S Regional Map Showing Location of Norton AFB
COM FEDERAL PROGRAMS CORPORATION Figure No. 1
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CENTRAL BASE AREA
SCALE IN FEET
-3V-
1500 L
J \
COM FEDERAL PROGRAMS CORPORATION
i «wtMO«f A Me*,**
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unconsolidated water-bearing deposits underlain by consolidated, virtually non-water
bearing rocks. Sediments underlying Norton AFB consist of unconsolidated, relatively
undisturbed gravels, sands, silts, and clays. The lithology varies across the base.
1.6 SOIL
Surface and subsurface soils at Norton AFB consist of loamy sands and sandy loams. The
soils are generally quite permeable and exhibit limited run-off and water erosion potential.
1.7 SURFACE WATER
The main surface water features near Norton AFB are City Creek, Warm Creek, the Twin
Creek flood control channel, and the Santa Ana River. The Santa Ana River flows
intermittently southwest along the southern base boundary. Site 19 is not within the 100
year flood plain.
Natural surface run-off flows into underground storm drains and natural surface drainages
at Norton AFB. There are eleven discharge points.
1.8 HYDROGEOLOGY
The groundwater aquifer system beneath Norton AFB is part of the Bunker Hill hydrologic
basin that is defined by three water-bearing zones (the upper, middle, and lower) and three
confining members (the upper, middle, and lower). The upper confining member, which
locally supports perched water zones, covers all but the eastern half of the base. Regional
groundwater flows towards the southwest. Recharge is supplied by runoff from the San
Bernardino Mountains.
1.9 PRODUCTION WELLS
The aquifer system provides drinking water in addition to water for agricultural and
commercial uses. The upper water-bearing zone has been affected by Norton AFB
operations, but not by contaminants from site 19. Drinking water is derived principally
from the middle and lower water-bearing zones.
1.10 THREAT OF SITE
The selected remedy addresses the principal threat from soils contaminated by PCBs.
S19ROD2.TXT 4 September 12, 1996
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
Norton AFB was activated in March 1942 as an engine repair center for the Army Air Corp,
U.S. Navy, and private industry aircraft. The base became a Military Airlift Command base
in 1966. In 1968, the Aerospace Audiovisual Services established its headquarters at the
base. Norton AFB provided airlift and maintenance capabilities for air and combat units
world-wide but was officially closed on March 31, 1994.
Site 19 was formerly used as a drum storage area and an aircraft washing facility (see Fig.
2). Drums of fuels, oils, electroplating solutions, trichloroethylene (TCE) and
trichloroethane sludge, and cyanide waste solutions were stored on a bare (earthen) fenced
lot. The area south of Building 763 (see Figure 2) was the general location of the original
aircraft washing facility. This facility was removed in 1966, and the area was resurfaced
with 24 inches of concrete to become part of the flightline.
Former waste disposal, handling, and discharge practices have resulted in soil
contamination. Documents presenting site investigation results are included in Appendix A,
the Administrative Record Index. A chronology of important site activities and
investigations that support remedy selection for the site 19 Interim ROD are as follows:
June 1980
October 1982
August 1987
September 1987
December 1988
June 1989
March 1991
DOD issues the Defense Environmental Quality Program Policy
Memorandum 80-6 requiring the identification of hazardous waste
sites.
Norton AFB issues the Phase I Records Search. Twenty IRP sites
including site 19, of potential contamination are identified.
Norton AFB is placed on the United States Environmental Protection
Agency's (USEPA) National Priorities List.
Norton AFB issues the Phase II Confirmation/Quantification, Stage 2
Final Report. Extent of contamination investigated at site 19.
Norton AFB issues the Stage 3 Final Report. Twenty-one of the 22
IRP sites are investigated.
The Air Force (AF) signs the Norton AFB Federal Facility Agreement
with the U.S. Environmental Protection Agency and the State of
California.
Norton AFB issues the Comprehensive Remedial Investigation and
Feasibility Study (RI/FS) Work Plan that identifies site investigation
field work to complete characterization of site 19.
S19ROD2.TXT
October 10, 1996
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February 1993
November 1994
January 1995
May 1995
January 1996
Norton AFB finalizes the Remedial Investigation Report for the
Installation Restoration Sites Rl Report presenting environmental data
for site 19.
Draft Interim Record of Decision for IRP Site 19 released to the
USEPA and California EPA for review on November 3.
Air Force receives comments from the California Department of Toxic
Substances Control on the Draft Interim ROD on January 10.
USEPA concurs with the decision for the need for a deed restriction
for IRP site 19 when it provided comments on the draft Soil Target
Cleanup Goal Technical Memorandum to the Air Force on May 31.
California EPA requests clarification from the Air Force on the entities
who will be responsible for site remediation should the land use
decision be changed and the concrete removed.
S19ROD2.TXT
September 12. 1996
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3.0 COMMUNITY PARTICIPATION
Norton AFB has conducted the following activities under the RI/FS process:
April 1990
July 1990
September 1990
June 1991
January 1994
July 17, 1996
July 31, 1996
August 27, 1996
August 30, 1996
Release of Community Relations Plan. Establish and notify
community of the location of information repositories.
Notification and request for participation in Community Relations
Workshop to discuss the Community Relations Plans and ensure
community involvement in the upcoming RI/FS.
Release of Fact Sheet discussing planned field activities for IRP
Sites Remedial Investigation and information on obtaining Technical
Assistance Grants.
Release of Fact Sheet discussing the Rl, on-going investigations,
the groundwater treatability study, the TCE Source Investigation,
and information on how the public can become involved.
Restoration Advisory Board established to obtain public input for
base cleanup issues.
Availability of the Site 19 Proposed Plan announced in local
newspapers.
Beginning of the public comment period on the Site 19 Proposed
Plan.
Community meeting held at the San Bernardino City Council
Chambers.
Close of the public comment period. Public comments are provided
in Appendix B.
S19ROD2.TXT
October 10, 1996
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4.0 SCOPE AND ROLE OF THE OPERABLE UNIT
This Interim ROD addresses the contaminated soils at site 19. Site 19 is defined as soil
containing PCBs above the CERCLA PCB Cleanup Policy action level of 10 mg/kg for
industrial sites. In addition, because PCBs are the primary contaminant of concern at site
19, the site is defined as soil containing PCBs above the soil target clean-up goal (TCG) of
0.19 and 0.025 milligrams per kilogram (mg/kg) for industrial and residential exposures
respectively. Soil TCGs were developed by the Air Force in conjunction with the USEPA
and the California Environmental Protection Agency (CAL/EPA) (CDM Federal, 1995). PCBs
in soils pose the principal threat to public health and the environment because of the risks
from possible ingestion or dermal contact with the soils. Should the concrete be removed,
the risk is predicted at 4.0 x 10"5. However, there is no current threat to human health from
PCBs provided there are no activities (i.e., concrete apron removal and soil excavation)
disturbing the subsurface. As long as the concrete apron is in place, the pathway is
incomplete. The purpose of this ROD is to address soil sources that pose a risk to public
health via direct contact and to prevent future exposure to the contaminated soils.
The Administrative Record Index is presented in Appendix A.
SOIL CONTAMINATION
PCBs have been identified as the primary contaminant of concern in soils at site 19. The
highest concentration of PCBs detected has been 62.4 mg/kg (CDM Federal, 1993).
Secondary contaminants of concern, which were detected above the soil TCGs, include
ethylbenzene, xylene, and chromium with maximum concentrations of 12 mg/kg, 180
mg/kg, and 209 mg/kg, respectively. These contaminants were detected above their
respective TCGs in only one or two samples. All other sample results were below the
respective TCGs. Other constituents detected in the soil that were below the soil TCGs
include TCE, 1,2-dichlorobenzene, 1,2,4-trichlorobenzene, cadmium, copper, lead, nickel
and zinc.
GROUNDWATER CONTAMINATION
PCBs are insoluble in water and adsorb strongly to soil particles. Site 19 is covered by
at least 24 inches of concrete preventing surface water infiltration. Therefore, PCB soil
contamination at site 19 does not threaten groundwater resources.
S19ROD2.TXT 8 October 10, 1996
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5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 SOURCES OF CONTAMINATION
Extent of soil contamination at IRP site 19 was investigated during the IRP Phase I and II
investigations (1985 to 1986) and during the IRP sites remedial investigation (1992 to
1993). A total of 29 shallow soil borings have been drilled at site 19 and 67 shallow (i.e.,
less than 5 feet below ground surface) soil samples analyzed for PCBs and other
constituents. PCBs were detected in 23 of the 67 samples analyzed. Only two of the
samples exceeded 10 mg/kg, with a maximum concentration detected of 62.4 mg/kg. The
majority of PCB detections were in the 0 to 6 inch interval below the concrete. PCS soil
data collected for site 19 are summarized in Table 1, with maximum concentrations
detected in each borehole shown on Fig. 3. Table 2 summarizes the maximum
concentrations detected and soil TCGs for constituents other than PCBs detected in soil
samples at site 19.
TABLE 1 SUMMARY OF SITE 19 PCB SOIL DATA
No. of Soil Borings
No. of Samples Analyzed
No. of Samples with PCBs
Range of PCB Concentrations
IRP Phase Il/Stage
2 & 3 Results
(E&E, 1988)
Results in mg/kg1
6
16
3
2.68 to 62.4
IRP Rl Site 1 9
Results
(COM Federal,
1993)
Results in mg/kg
23
51
20
0.003 to 28.0
mg/kg = milligrams per kilogram
S19ROD2.TXT
September 12, 1996
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+ B396
APPROXIMATE AREA OF FORMER
AIRCRAFT WASHING FACILITY
766
B3654.- B370
4004.
B362/B367/ * gf»
L./KO "/--,«??/.
B386 B347
ast» PCBs (ug/Kg)
RI SOIL BORING (B361 )
1RP SOIL BORING IB52)
A-LEVEL MONITORING WELLS (MW202)
B-LEVEL MONITORING WELLS (MW263)
COM FEDERAL PROGRAMS CORPORATION
a wtxldlary of Coop DTMMT % MdtM tw.
Site 19 & Former Aircraft Washing Facility
General Features
F igure
3
fSX.OOH
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TABLE 2 SUMMARY OF SITE 19 SOIL DATA (EXCLUDING PCBs)
CONSTITUENT
DETECTED
TCE
Ethylbenzene
Xylene
1,2-
Dichlorobenzene
1,2,4-
Trichlorobenzene
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
FREQUENCY OF
DETECTIONS
ABOVE
NORTON AFB
BACKGROUND1
2/24
1/24
2/24
1/24
1/24
2/24
3/24
1/24
1/24
1/24
2/24
MAXIMUM
DETECTION
FROM IRP Rl
SITE 19
RESULTS
(CDM Federal,
1993)
6 Mg/kg
(.006 mg/kg)
1 2,000 /zg/kg
(12 mg/kg)
1 80,000 Mg/kg
(180 mg/kg)
710 Mg/kg
(.71 mg/kg)
710 Mg/kg
(.71 mg/kg)
8.6 mg/kg
209 mg/kg
35.4 mg/kg
1 27 mg/kg
1 28 mg/kg
1 96 mg/kg
SOIL TARGET CLEAN-
UP GOALS FOR
INDUSTRIAL SITES
(CDM Federal, 1995;
USEPA, 1994)
3.3 mg/kg for human
health protection
10 mg/kg
20 mg/kg for
groundwater protection
and
980 mg/kg for human
health protection
4.3 mg/kg
5,000 mg/kg
650 mg/kg
1 50 mg/kg
63,000 mg/kg
1 ,000 mg/kg
10,680 mg/kg
1 00,000 mg/kg
1. Non-detect used as background for organic contaminants.
= micrograms per kilogram, mg/kg = milligrams per kilogram
S19ROD2.TXT
11
September 12, 1996
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5.2 CONTAMINATION AND AFFECTED MEDIA
SOILS
The soil results of the remedial investigations indicate that PCBs are present throughout
much of the area of site 19. It is suspected that regrading of the site 19 area to construct
the flightline apron redistributed the PCB-contaminated soil. Other constituents, such as
xylene and ethylbenzene, were very localized horizontally and vertically (i.e., present in only
one or two samples), and may have represented an isolated fuel spill on the aircraft flight
apron. Chromium was present at 209 mg/kg in only one sample; all other chromium results
were less than 84 mg/kg. Thus the 209 mg/kg value appears to be an outlier and the soils
at the site are not affected by the element.
PCBs are suspected human carcinogens. The primary route of exposure would be
adsorption through the skin from direct contact with contaminated soil, ingestion of soil
adsorbed to skin, and inhalation of fugitive dust. All pathways for contact with PCBs or
other constituents currently are incomplete due to the presence of the 24 inches of
concrete forming the flightline apron over site 19.
GROUNDWATER
Since PCBs are relatively immobile in soil and the site is covered with concrete and depth
to groundwater is 90 feet below ground surface, site 19 does not appear to be affecting
the groundwater quality.
S19ROD2.TXT 12 September 12, 1996
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6.0 SUMMARY OF RISK ASSESSMENT
Using data collected during the IRP Sites Rl2, the baseline risk assessment was prepared to
evaluate the potential human health risks associated with the site 19 in the absence of any
remedial (corrective) action. The no-action alternative is evaluated in accordance with
§ 300.430(d) of the NCR.
6.1 HEALTH RISKS
«
Chemicals of concern were selected based on frequency of detection, toxicity,
concentration in media, and comparison of levels found at the site to background
concentrations. PCBs were the only contaminant detected at site 19 that was deemed a
contaminant of concern in the baseline risk assessment. The exposure point concentration
for PCBs was calculated at 5.4 mg/kg and the risk determined to be 4.0 x 10"5.
Constituents, other than PCBs, that were potential chemicals of concern because
concentrations were detected above the soil TCGs include ethylbenzene, xylene, and
chromium. These constituents were eliminated as primary chemicals of concern because
elevated concentrations were detected infrequently and thus they did not appear to
represent widespread contamination. The exposure point concentrations for the three
contaminants were below their respective TCGs. Other constituents detected in the soil,
but eliminated as chemicals of concern because their maximum concentrations were
reported below the soil TCGs, include TCE, 1,2-dichlorobenzene, 1,2,4-trichlorobenzene,
cadmium, copper, lead, nickel and zinc (see Table 2).
Because land use plans for Norton AFB identify continued use of the base as an airfield and
other commercial purposes, the potential receptor for the site 19 risk assessment was the
light industrial worker. The principal exposure pathways by which this receptor could
potentially be exposed to site contaminants are inhalation of fugitive dust, ingestion of
contaminants in soils, and dermal contact with contaminants in soils. However this
pathway is currently incomplete because the site is covered with 24 inches of concrete.
Therefore, site 19, as it currently exists, poses no risk to human health. This conclusion
will need to be revisited should the decision be made to remove the concrete apron.
6.2 ECOLOGICAL RISKS
There are no streams or ponds immediately adjacent to site 19. Controlled storm water
drainage at Norton AFB generally consists of surface flow to diversion structures and
collection pipes discharging to local surface streams. The Santa Ana River wash is
immediately south of the base. There are two jurisdictional wetlands on the western
portion of Norton AFB. Neither the river wash nor the wetlands are associated with site 19
and no surface water to wetlands pathway exists.
2AII Rl data have been validated and the quality is acceptable to support the recommendation of this ROD.
S19ROD2.TXT 13 October 10, 1996
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No threatened or endangered plant species are associated with site 19. The burrowing
owl, listed as a State of California Species of Special Concern3, occurs as a year round
resident near runways and buildings at Norton AFB; there are no applicable and or relevant
and appropriate requirements (ARARs) for Species of Special Concern. The burrowing owl
is not present in any buildings near site 19 nor has it been observed near the flightline area
of site 19.
The distance from site 19 to the nearest vegetation is 210 feet. This vegetation represents
a clear zone adjacent to the runway, which is mowed to maintain a low cover. The surface
areas of Norton AFB associated with site 19 are all paved or urbanized/landscaped and
there is no discharge of groundwater to the surface at the present time. Therefore, there is
no exposure pathway by which a contaminant could move from a surface source to an
ecological receptor in the environment. In addition, it is not likely that an exposure point to
ecological receptors exists due to continued land use as an airfield.
6.3 CONCLUSIONS
Although the exposure pathway for site 19 is incomplete, the actual or threatened releases
of hazardous substances from this site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment. Therefore, deed restrictions are required to
preclude inadvertent or intentional removal of the concrete without first notification of the
Air Force, USEPA, and CAL/EPA of the action.
The risk to ecological receptors appears to be low. There is no available pathway from the
site 19 contaminants to ecological receptors.
3Species of Concern are not protected under the Endangered Species Act.
S19ROD2.TXT 14 September 12, 1996
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7.0 DESCRIPTION OF ALTERNATIVES
The remedial alternatives for soil that have been evaluated through a detailed analysis in
the site 19 ROD are presented below. PCBs in soil pose a potential future threat to public
health due to ingestion, inhalation, and dermal contact. There are three PCB shallow
subsurface soil alternatives.
ALTERNATIVE 1A - NO ACT/ON
This alternative, required for consideration by the NCP, involves no remedial actions to
address shallow subsurface soil contaminated with PCBs. No action is implemented. This
alternative will not comply with CERCLA because PCBs above health based standards will
be left potentially uncontrolled in soils.
ALTERNATIVE IB - DEED RESTRICTIONS
Prior to sale or transfer of any Norton AFB property overlying site 19, the AF will record a
land use restriction in accordance with California Health and Safety Code §25230. This
will serve as an institutional control to prohibit removal of the concrete runway apron and
preclude soil excavation in a manner that would not comply with Federal and State
regulations. It will also provide notice of this restriction in any purchase, lease, or other
agreement relating to that property.
AL TERNA TIVE 1C - EXCA VA T/ON AND OFF-SITE DISPOSAL
Demolition and reconstruction of existing facilities
Excavation of soil containing PCBs above the cleanup standard
Backfill of excavation with clean import or borrow soil
Testing of excavated soil
Transportation of soil offsite by licensed transporter
Disposal offsite to a licensed Subtitle C disposal facility
Shallow subsurface soil containing PCBs above the cleanup standard would be excavated.
Excavation would require demolition of part of the flightline to access the affected soil.
During excavation, dust suppression measures will be taken to control dust emissions.
Following excavation, the areas would be backfilled with clean import or borrow soil,
compacted, and restored to its previous condition.
The excavated soil will be immediately loaded onto trucks licensed for the transport of
contaminated soils, and transferred to a licensed Subtitle C disposal facility. The soil will
be treated at the disposal facility if the soil does not meet the disposal standards. The
disposal facility will be identified during the remedial design phase. Soil will be transported
in compliance with regulations pertaining to off-site transportation. Selection of a disposal
S19ROD2.TXT 15 September 12, 1996
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facility may affect transportation and disposal costs, but will not affect selection of this
remedy. The cost estimate for excavation, disposal and replacement of the concrete apron
is $1.7 million. The majority of the costs lie in the difficult task of removal of 24 inches of
reinforced concrete.
Residual PCBs below cleanup standards may remain at the site. These levels will not pose
a risk to human health or the environment, therefore long-term management or controls for
any residual PCBs are not necessary. The estimated time to implement this remedy and to
meet the cleanup standard is 3 months.
S19ROD2.TXT 16 September 12, 1996
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Media-specific alternatives are evaluated to determine which alternative provides the "best
balance" of tradeoffs with respect to the nine evaluation criteria required by the NCR and
CERCLA Section 121:
(1) Overall Protection of Human Health and the Environment
(2) Compliance with ARARs
(3) Long-term Effectiveness and Permanence
(4) Reduction of Toxicity, Mobility, or Volume Through Treatment
(5) Short-term Effectiveness
(6) Implementability
(7) Cost
(8) State Acceptance
(9) Community Acceptance.
8.1 THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment
Alternative 1B would be protective of human health and the environment because it would
preclude removal of the concrete apron through lease restrictions thereby preventing
unsuspected contact with or removal of contaminated soil. Alternative 1C would offer the
greatest protection through removal of the contaminated soil from the site and placement
at a controlled facility. Alternative 1A is potentially unprotective because it would allow
the possibility of uncontrolled soil contact and soil removal from the site if the concrete
apron is removed.
Compliance with ARARs
CERCLA guidance allows the leaving in place PCB contaminated material containing greater
than 10 mg/kg of PCBs as long as access to the material containing PCBs is limited.
Because the 24 inches of concrete meets the CERCLA definition for limited access,
Alternative B would comply with CERCLA.
Alternative 1C could be implemented to address all state and federal ARARs. Soil
containing greater than 50 mg/kg PCBs would be considered a Resource Conservation and
Recovery Act hazardous waste under State of California regulation and thus a portion of
the site 19 soil would require disposal in a hazardous landfill if excavated. Alternative 1A
would not comply with CERCLA because it would leave in place soil exceeding cleanup
goals in a potentially uncontrolled manner.
S19ROD2.TXT 17 September 12, 1996
-------
8.2 PRIMARY BALANCING CRITERIA
Long-Term Effectiveness
Long-term effectiveness for alternatives 1A and 1B would remain as long as the concrete
apron remains in place. Once the concrete apron is removed, neither alternative would be
protective. Alternative 1C would offer long-term protectiveness at the site because all soil
exceeding health-based standards would be removed. Because the contaminants are not
destroyed, risk is transferred to the facility receiving the soil.
Reduction of Toxicitv. Mobility, or Volume Through Treatment
None of the alternatives involved treatment, therefore reduction of toxicity or volume
would not be attained. As long as the concrete apron lernains, mobility of contaminants
will be controlled.
Implementability
All of these alternatives are implementable.
Short-Term Effectiveness
Alternatives 1A and 1B would be equally protective in the short-term because the concrete
runway apron will prevent soil access. Measures to prevent direct contact and dust
protection will need to be implemented if soil excavation is done under alternative 1C.
Costs
There are no costs related to implementing alternatives 1A and 1B. The cost of removal
and replacement of the concrete cover would be $1,700,000. Table 3 presents a summary
of the costs by major activity. These activities reflect the removal of the apron to access
contaminated soils, for soil removal and disposal, soil replacement, and for concrete apron
replacement. The costs do not include engineering design, oversight, or confirmation
sampling.
8.3 MODIFYING CRITERIA
Community Acceptance
It is assumed that alternative 1B will be acceptable to the local community.
State Acceptance
It is assumed that alternative IB will be acceptable to the State.
S19ROD2.TXT 18 September 12, 1996
-------
TABLE 3 SUMMARY OF COSTS
COST
COMPONENT
Concrete
Demolition
Concrete Removal
and Offsite
Disposal
Soil Excavation
Offsite Disposal
of Soil
Replace
Excavated Soil
with Clean Fill
Place Concrete
over area
TOTAL COST
UNIT
CY
CY
CY
CY
CY
SF
QUANTITY
6,000
6,000
9,000
9,000
9,000
75,000
UNIT COST
$164'
$36.752
$3.94'
$36. 752
$5.453
$1.101
TOTAL COST
$984,000
$220,500
$35,460
$330,750
$49,050
$82,500
$1,702,260
1. Means, 1995
2. BKK Landfill, 9/95
3. Corona Dee Gee, 8/95
S19ROD2.TXT
19
September 12, 1996
-------
9.0 SELECTED REMEDY
The selected remedy is the implementation of deed restrictions (Alternative 1B) for the site
19 area. The site is currently covered by 24 inches of concrete, which is a flightline apron
used for parking aircraft. Future use for the area will be continued use for aircraft parking.
There are no plans to remove or replace the concrete due to the costs for concrete removal
and replacement and the fact that the current concrete layer is adequate for its intended
purpose. The selected remedy therefore will be implemented to prevent uncontrolled
access to site soils. The Air Force recognizes that should land use plans change or the
need to replace the concrete be determined, this decision will need to be re-evaluated and a
soil removal action be fully considered.
Deed restrictions, in accordance with California State Law, will be written into all leases
and property deed transfer documents. Deed restrictions will remain in place as long as
contaminated soils remain at the site.
The Air Force has entered into a 55-year lease with the San Bernardino International Airport
Authority for the airfield portion of the former Norton AFB for the specific purpose of
operating and using the airfield for aviation and aviation support activities. During this
period the Air Force will work with the lessee or its successor to ensure that the cement
cap is protective of human health and the environment. This would involve regular
maintenance and repair of the concrete by the lessee. Should any new lessee or occupant
change the specified land use of the area above site 19 that would involve removal of the
concrete, it will be the responsibility of that entity to reevaluate the site and perform any
required remediation in compliance with appropriate state and federal regulations.
S19ROD2.TXT 20 September 12. 1996
-------
10.0 STATUTORY DETERMINATION
This section presents the manner in which the selected remedy meets human health
protectiveness, cost-effectiveness, and treatment of waste considerations.
10.1 PROTECTIVENESS OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy is protective through the identification of the area of contaminated
soils and the prevention of removal of the concrete apron and contaminated soils in an
uncontrolled manner.
10.2 COMPLIANCE WITH ARARs
The selected remedy will comply with the CERCLA requirement to limit access of workers
to media containing PCBs.
10.3 COST EFFECTIVENESS
The selected remedy does not result in any unnecessary cost expenditures prior to the time
it is determined that the concrete should be removed or replaced. There are no human
health or environmental threats at present and cost expenditures for an immediate soil
removal remedy are not warranted.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY & TECHNOLOGIES) TO THE
MAXIMUM EXTENT PRACTICABLE
The selected remedy is not a permanent solution. The selected remedy allows the
continued use of the existing concrete apron as a cost savings issue. Once the decision to
remove the apron is made, then this criterion will need to be further addressed as part of
the soil removal and treatment action.
10.5 REFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT
The selected remedy does not involve treatment. Treatment cannot be addressed until the
concrete apron is removed or an in situ PCB treatment technology is developed.
S19ROD2.TXT 21 September 12, 1996
-------
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan announcing this decision was released on July 17, 1996. There were
no significant issues raised by the public or the regulatory agencies that have affected the
Air Force Decision. Therefore there are no significant changes in the plan to implement the
selected remedy.
S19ROD2.TXT 22 September 12, 1996
-------
12.O BIBLIOGRAPHY
COM Federal Programs Corporation (COM Federal), 1993a. Remedial Investigation
Report, Installation Restoration Program Sites Operable Unit (15 Sites).
COM Federal Programs Corporation (COM Federal), 1995a. Development and
Evaluation of Soil Target Cleanup Goals Industrial/Commercial Reuse Scenario IRP
Sites Cleanup.
, 1993b. Central Base Area Operable Unit and IRP Sites Operable Unit Data
Validation Summary Report.
Ecology and Environment, Inc. (E&E, Inc.), 1987. Phase II -
Confirmation/Quantification, Stage 2 Technical Report.
, 1989. Installation Restoration Program, Stage 3.
Norton Air Force Base, 1990. Community Relations Plan.
, 1991. Fact Sheet, Installation Restoration Program June.
, 1996. Proposed Plan for IRP Site 19.
Roy F. Weston, Inc., 1985. Phase II, Stage I - Problem Confirmation Study.
United States Air Force, 1993c. Environmental Impact Statement.
, 1996. IRP Site 19 Proposed Plan.
United States Environmental Protection Agency, 1990. Remedial Actions for
Superfund Sites with PCB Contamination. (OSWER Dir/. 9355-4-01).
, 1994. Region IX Preliminary Remediation Goals (1994), Second Half
(August).
S19ROD2.TXT 23 September 12, 1996
-------
ATTACHMENT A
ADMINISTRATIVE RECORD INDEX
FOR THE IRP SITE 19 ROD
IRPSITE.ARI 10/27/95
-------
ADMINISTRATIVE RECORD INDEX FOR THE
IRP SITE 19 RECORD OF DECISION
DOCUMENT
DATE
10/82
7/85
7/85
8/8/86
9/9/86
10/10/86
11/14/86
1/29/87
3/10/87
9/87
9/87
9/87
SUBJECT OR TITLE
Phase I, Records Search
Phase II, Stage 1, Final Technical
Report, Problem
Confirmation/Quantification Study,
Volume I of II
Phase II, Stage 1, Final Technical
Repo/t, Problem
Confirmation/Quantification Study,
Volume II of II
Work Plan for Site 17
Phase IVA, Remedial Action Plan,
Task Report No. 2, Screen Control
Measures, Site 17
Phase IVA, Remedial Action Plan,
Task Report No. 11, Field
Investigation Report, Site 17
Regional Water Quality Control
Board letter to Norton AFB on
Cleanup and Abatement Order for
Industrial Wastewater Treatment
Plant Sludge Drying Beds
Regional Water Quality Control
Board Letter to Norton AFB
Approving Disposal of Dried Sludge
to Class II Landfill
Base Letter to Regional Water
Quality Control Board Providing
Status of Compliance with Cleanup
and Abatement Order
Phase II, Stage 3, Work Plan
Phase II, Stage 3 Quality Assurance
Project Plan
Phase II, Stage 2,
Confirmation/Quantification Report,
Volume I of VI
AUTHOR
Engineering-Science,
Inc.
Roy F. Weston, Inc.
Roy F. Weston, Inc.
IT Corporation
IT Corporation
IT Corporation
James R. Bennet,
California Regional
Water Quality Control
Board
James R. Bennet,
California Regional
Water Quality Control
Board
Col. David A. Voigt, 63
ABG/CC
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
.Environment, Inc.
FILE
NUMBER
2
11
12
37
40
42
30
53
59
82
83
84
A-1
-------
ADMINISTRATIVE RECORD INDEX FOR THE
IRP SITE 19 RECORD OF DECISION (continued)
DOCUMENT
DATE
9/87
9/87
9/87
9/87
9/87
1/12/89
11/89
11/89
11/89
11/89
11/89
11/89
SUBJECT OR TITLE
Phase II, Stage 2,
Confirmation/Quantification Report,
Volume II of VI, Appendices A-G
Phase II, Stage 2,
Confirmation/Quantification Report,
Volume III of VI, Appendix H, Soils
Data
Phase II, -Stage 2,
Confirmation/Quantification Report,
Volume IV of VI, Appendix H, Water
Data
Phase II, Stage 2,
Confirmation/Quantification Report,
Volume V of VI, Appendix H, Water
Data
Phase II, Stage 2,
Confirmation/Quantification Report,
Volume VI of VI, Appendices I-M
Informal Technical Information
Report, Volume II of II, QA/QC
Summary, Chain-of-Custody Forms,
Well Information, Field Sampling
Forms
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Volume I of III
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Volume II of III
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Volume III of III
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Appendices A-F
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Appendix G
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Appendix G
(Com.)
AUTHOR
Ecology & '
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
EA Engineering,
Science, and
Technology, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
Ecology &
Environment, Inc.
FILE
NUMBER
85
86
87
88
89
173
253
254
255
256
257
258
A-2
-------
ADMINISTRATIVE RECORD INDEX FOR THE
IRP SITE 19 RECORD OF DECISION (continued)
DOCUMENT
DATE
11/89
11/89
11/14/89
2/91
3/91
3/91
3/91
11/11/91
12/91
6/4/92
6/4/92
6/4/92
11/4/92
1 1 /4/92
SUBJECT OR TITLE
Phase II, Stage 3, Final Draft Report,
Sep 87 - Dec 88, Appendices H-K
Conceptual Design for Remedial
Activities
Conceptual Design for Remedial
Activities Presentation Slides
Package/Information
Remedial Investigation/Feasibility
Study, Final Comprehensive Work
Plan
Remedial Investigation/Feasibility
Study, Final Quality Assurance
Project Plan
Remedial Investigation/Feasibility
Study, Final Field Sampling Plan,
Volume I of II
Remedial Investigation/Feasibility
Study, Final Field Sampling Plan,
Volume II of II
Technical Memorandum, Rational for
Comprehensive Groundwater
Sampling, Dec 1991
Final Monitoring Well Replacement
Plan
Draft Remedial Investigation Report,
IRP Sites Operable Unit, Volume VII
Draft Remedial Investigation Report,
IRP Sites Operable Unit, Volume VIII
Draft Remedial Investigation Report,
IRP Sites Operable Unit, Volume X
Draft Final Remedial Investigation
Report, IRP Sites Operable Unit,
Baseline Risk Assessment, Volume III
Draft Final Remedial Investigation
Report, IRP Sites Operable Unit,
Volume IV, Appendices
AUTHOR
Ecology &
Environment, Inc.
COM Federal Programs
Corp.
COM Federal Programs
Corp.
COM Federal Programs
Corp.
COM Federal Programs
Corp.
COM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
-Corp.
FILE
NUMBER
259
260
261
470
495
496
497
667
673
815
816
818
984
985
A-3
-------
ADMINISTRATIVE RECORD INDEX FOR THE
IRP SITE 19 RECORD OF DECISION (continued)
DOCUMENT
DATE
11/4/92
11/4/92
11/4/92
3/17/93
3/17/93
6/93
2/1 5/94
3/29/95
3/29/95
9/1/94
9/27/94
7/17/96
SUBJECT OR TITLE
Draft Final Remedial Investigation
Report, IRP Sites Operable Unit,
Volume V, Appendices
Draft Final Remedial Investigation
Report, IRP Sites Operable Unit,
Volume VI, Appendices
Draft Final Remedial Investigation
Report, IRP Sites Operable Unit,
Volume IX, Appendices
Final Remedial Investigation Report,
IRP Sites Operable Unit, Volume I of
II
Final Remedial Investigation Report,
IRP Sites Operable Unit, Volume II of
II
Final Environmental Impact
Statement
Groundwater Monitoring Plan
Second Annual Groundwater Data
Trends Report, Volume 1
Final Second Annual Groundwater
Data Trends Report, Volume II,
Appendices A-1 and A-2
Draft Second Annual Groundwater
Data Trends Report, Volume III,
Appendices A-3 and A-4
Technical Memorandum,
Development and Evaluation of Soil
Target Cleanup Goals,
Industrial/Commercial Reuse
Scenario, IRP Sites Cleanup
Site 1 9 of Proposed Plan
AUTHOR
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
CDM Federal Programs
Corp.
Department of the
United States Air Force
CDM Federal Program
Corp.
CDM Federal Program
Corp.
CDM Federal Program
Corp.
CDM Federal Program
Corp.
CDM Federal Programs
Corp.
United States Air Force
FILE
NUMBER
986
987
988
1121
1122
Not
Available
1256
1232
1233
1234
1208
A-4
-------
ATTACHMENT B
RESPONSIVENESS SUMMARY
IRPSITE.ARI 10/27/95
-------
Responses to
Department of Toxic Substance Control Comments
Dated January 10.1995 from Manny Alonzo on the
DRAFT PARTIAL RECORD OF DECISION OPERABLE UNIT (OU) 3, IRP SITE 19 -
DRUMMED WASTE STORAGE AREA NO. 1
Prepared by CDM Federal Programs Corporation
September 22, 1995
GENERAL COMMENTS
"Cal/EPA does not object to the interim remedy proposed, deed restriction, provided
there are no threats to groundwater and that Polychlorinated Biphenyls (PCBs) are the only
chemicals of concern at the site. The Region IX/DTSC modified soil PRGs for PCBs
developed for this site should be referenced in the Partial Record of Decision in order to
document the necessity of a deed restriction. PCBs were detected in site 19 soils far
exceeding Region IX/DTSC Modified soil screening values (PRGs) for unrestricted or
industrial use. The situation could be exacerbated in the future should land use change
and the concrete apron be removed. This could lead to future exposure above levels
considered prudent by DTSC and U.S. EPA.
The document does not discuss any chemicals of concern nor presents data for any
chemicals other than PCBs. All chemicals detected at the site should be discussed."
SPECIFIC COMMENTS
1. "Page 7, Table 1 (Page 8) and Figure 3 (Page 9). The concentration for PCBs
reported at the site are above soil PRGs of 0.19 and 0.025 ppm for industrial and
residential exposures respectively. Office of Scientific Affairs (OSA) and U.S. EPA
toxicologists have jointly agreed upon these residential and industrial PRGs for PCBs at this
site as documented in the memo of December 5, 1994 from Jeffrey Paul! of Region IX to
Steve Daneke of Norton AFB. This information should be presented in the Partial Record
of Decision.
Also, it is stated that PCBs are the primary contaminant of concern at the site. The
Partial Record of Decision should describe whether or not other secondary chemicals of
concern are present at the site."
Section 4, page 8 discusses the soil target clean-up goals (soil TCGs), as well as, other
constituents found in the soil at site 19. A second table (Table 2 on page 11} lists the
maximum concentrations detected for constituents other than PCBs and the corresponding
soil TCGs.
-------
2. "Section 6.1 Health Risks. This section states that PCBs were the only
contaminant detected at site 19 that was deemed contaminant of concern in the baseline
risk assessment. Please clarify if other chemicals were detected at site 19, if they were
eliminated as chemical of concern, and why."
Constituents, other than PCBs, that were potential chemicals of concern because
concentrations were detected above the soil TCGs include ethylbenzene, xylene, and
chromium. These constituents were eliminated as primary chemicals of concern because
they did not appear to represent widespread contamination. For example, xylene and
ethylbenzene, were very localized horizontally and vertically, and may have represented an
isolated fuel spill on the aircraft flight apron. Other constituents detected in the soil, but
eliminated as chemicals of concern because concentrations were detected below the soil
TCGs, include trichloroethylene (TCE), 1,2-dichlorobenzene, 1,2,4-trichlorobenzene,
cadmium, copper, lead, nickel and zinc.
3. Section 6.2 Ecological Risks, Page 11. This section asserts that due to the
urbanized/landscaped nature of the site and the concrete covering, no contact of
contaminants with ecological receptors will occur. This section indicates that the
burrowing owl is not present in any buildings associated with Site 19. Are there any other
animals who may live on the edges of the concrete areas and possibly burrow into
contaminated areas?
According to the Ecological Risk Assessment (COM Federal, August 1995), there is no
vegetation associated with the site and there is a complete absence of wildlife habitat.
The distance to the nearest vegetation is 210 feet. This vegetation represents a clear zone
adjacent to the runway which is mowed to maintain a low cover.
-------
TEL: Jun 17'96 13:47 No. 006 P.02
DEPARTMENT OF THE AIR FORCE
AIR FORCE BASE CONVERSION AGENCY
June 17,1996
AFBCA/SPEV
305 S. Tippecanoe Ave.
San Bernardino CA 92408
CAL-EPA
Dept. of Toxic Substances Control
ATTN: Mr. John Scandura, Chief, Southern California Operations
Office of Military Facilities
245 West Broadway, Suite 425
Long Beach, CA 90802-4444
RE; Draft Final Interim Record of Decision, IRP Site 19, Norton AFB, San
Bernardino, CA
This is in response to your January 31, 1996 letter regarding issues associated with
referenced document. We regret the delay in providing you a response. Your comments
included that you wanted the interim record of decision to clearly state who will perform
any revaluation and remediation should the future land use change at this site. We have
reviewed this issue with our legal staff and the following is provided in response to your
comments.
The Air Force will remain responsible to ensure that the cap is protective of human
health and the environment, and that the remedy is effective. The occupant of the
property, in this case the San Bernardino International Airport Authority, will maintain the
concrete surface through a program of regular maintenance or repair. Should a new
owner or occupant wish to change the use of the property, the owner or occupant will
become responsible for evaluating the site and responsible for the remedy in compliance
with all appropriate rules and regulations. If you have any questions, please contact me at
(909) 382-5027.
THOMAS J. BARTOL
BRAC Environmental Coordinator
Norton Operating Location
Air Force Base Conversion Agency
-------
TEL: Jun 17'96 13: £8 No. 006 P.03
w.
AFBCA/SP, John Smith
AFBCA/SPE, Patti Warren
DISC, Manny Alonzo
SBIAA, Jim Monger
IVDA,BillBopf
-------
RECORD OF
COMMUNITY MEETING
S19ROD2.TXT September 12, 1996
-------
1
2
3
4 COMMUNITY MEETING FOR NORTON AIR FORCE BASE
5 IRP SITE 19
6 WASTE DRUM STORAGE AREA NO. 1 PROPOSED PLAN
7
8
9
10
11
12
13 DATE AND TIME: TUESDAY, AUGUST 27, 1996
7:00 P.M.
14
PLACE: SAN BERNARDINO CITY HALL
15 COUNCIL CHAMBERS
300 NORTH "D" STREET
16 SAN BERNARDINO, CALIFORNIA
17
18
19
REPORTED BY: PATRICIA A. SHAW, C.S.R. #5024
20
21
22
23
24
25
SHAW DEPOSITION SERVICES ** (909) 338-1300
-------
I
V
1 APPEARANCES
2 TOM BARTOL,
3 BASE ENVIRONMENTAL COORDINATOR, NORTON AIR FORCE
4 BASE
5
6 GLENN KISTNER,
7 PROJECT MANAGER, U.S. ENVIRONMENTAL PROTECTION
8 AGENCY
9
10 LINDA SPITZER,
11 COMMUNITY RELATIONS SPECIALIST, NORTON AIR FORCE
12 BASE
13
14 JOHN T. WONDOLLECK,
15 COM FEDERAL PROGRAMS CORPORATION
16
17 YOGESH SHETH
18
19 RICHARD HART,
20 MEMBER OF THE PUBLIC
21
22 PATRICIA A. SHAW,
23 CERTIFIED SHORTHAND REPORTER
24
25
SHAW DEPOSITION SERVICES ** (909) 338-1300
-------
1 SAN BERNARDINO, CALIFORNIA; TUESDAY, AUGUST 27, 1996
2 7 : 0 0 P . M .
3 -OOO-
4
5 MR. TOM BARTOL: GOOD EVENING. I AM TOM BARTOL
6 FROM THE AIR FORCE BASE CONVERSION AGENCY, NORTON
7 OPERATING LOCATION AT SAN BERNARDINO, CALIFORNIA.
8 .I'D LIKE TO OPEN UP THIS PUBLIC MEETING TONIGHT
9 ON THE AIR FORCE'S PROPOSED PLAN FOR SITE 19. BECAUSE
10 WE HAVE ONLY ONE MEMBER OF THE PUBLIC HERE, I WILL
11 FOREGO OUR PRESENTATION AND ASK MR. HART, WHO WISHES
12 TO SPEAK, TO GIVE HIS COMMENTS.
13 MR. RICHARD HART: GOOD EVENING. RICHARD HART,
14 939 EAST GILBERT, SAN BERNARDINO.
15 I BEGAN MY RESEARCH INTO THIS PROPOSED PLAN FOR
16 SITE 19 REUSE WHEN I SAW THIS AD IN THE PAPER. AND TO
17 ME AND MOST OF THE COMMON CITIZENS, I BELIEVE IT
18 SOUNDS THE SAME; IT SOUNDS BAD.
19 SITE 19 IS A FORMER DRUM WASTE STORAGE AREA NOW
20 COVERED WITH CONCRETE. THE SOIL BELOW THE CONCRETE IS
21 CONTAMINATED BY INDUSTRIAL POLUTANTS CONTAINING
22 POLYCHLORINATED BIPHENYLS.
23 THE AIR FORCE PROPOSED TO LEAVE THE CONCRETE
24 COVER OVER THE SOIL AND IMPLEMENT A DEED RESTRICTION,
25 PRECLUDING REMOVAL OF THE CONCRETE. SO TO ME IT'S
3
SHAW DEPOSITION SERVICES ** (909) 338-1300
-------
1 LIKE SAYING DILUTION IS THE SOLUTION. WE'RE LEAVING A
2 TOXIC WASTE UNDERNEATH THE NORTON AIR FORCE BASE SIT
3 AND IT'S JUST GOING TO SIT THERE UNTIL WE FORGET ABOUT.
4 IT AND SOMEBODY ELSE COMES ALONG AND CLEANS IT UP.
5 SO I RESEARCHED IT AND I STARTED TO LOOK AT
6 WHAT PCB'S ARE. AND THEY'RE POLYCHLORINATED BIPHENYLS j
7 WHICH BY THEIR NAME MEANS CHLORINE AND BIPHENYL, AND (
8 THEY'RE TOGETHER. AND YOU HAVE POLYCHLORINATED |
9 BIPHENYLS IN RANGES LIKE 12/42, WHICH IS 12 CARBON
10 ATOMS WITH 42 PERCENT CHLORINE BY WEIGHT; 12/54,
11 12 CARBON ATOMS WITH 54 PERCENT CHLORINE BY WEIGHT. I
12 SO AT FIRST YOU CAN STATE, OKAY, YOU HAVE
13 CHLORINE. WHAT'S CHLORINE AND BIPHENYL GOING TO BREAK I
14 DOWN INTO EVENTUALLY? I LOOKED UP THE TOXICOLOGIC
15 PROFILE FOR POLYCHLORINATED BIPHENYLS BY THE U.S.
16 DEPARTMENT OF HEALTH AND HUMAN SERVICES, AND IT STATES
17 OPTIMUM RATES OF PCB DECHLORINATION USUALLY OCCURRED
18 IN A CONCENTRATION RANGE OF 700 PARTS PER MILLION UP
19 TO 1,000 PARTS PER MILLION. SO YOU NEED A
20 CONCENTRATION OF PERHAPS AT LEAST 300 PARTS PER
21 MILLION IN ORDER FOR THIS TO BREAK DOWN THE CHLORINE
22 FROM THE BIPHENYL. I LOOKED UP THE HIGHEST
23 CONCENTRATION LOCATED AT THE BASE AND IT WAS 62 PARTS
24 PER MILLION. SO WE'RE NOT GOING TO HAVE A BREAKDOWN
25 OF CHLORINE, ESCAPING CHLORINE GAS INTO THE AIR EVEN
4
SHAW DEPOSITION SERVICES ** (909) 338-1300
-------
1 IF YOU GET THROUGH THE CONCRETE.
2 SO MY NEXT PROJECT WAS TO ASK HOW DOES PCB'S
3 AFFECT HUMAN HEALTH, AND THERE'S THREE WAYS:
4 INHALATION, ABSORPTION, AND CONTAMINATION. THE
5 ABSORPTION ISSUE WAS PRETTY MUCH COVERED BY THE FACT
6 THAT THE PCB'S ARE COVERED BY 2 FEET OF CONCRETE. TO
7 HAVE ABSORPTION YOU HAVE TO TOUCH THE PRODUCT.
8 NOBODY'S GOING TO BE DIGGING THROUGH 2 FEET OF
9 CONCRETE TO GET IN THERE AND TOUCH IT, SO WE'RE SAFE
10 FROM THAT.
11 THE NEXT IS CONTAMINATION OF FOOD AND WATER.
12 THIS IS WHERE MY BIG PUSH WAS, BECAUSE THE SANTA ANA
13 RIVER IS APPROXIMATELY 100 FEET BELOW THE SURFACE OF
14 THE SITE. SO I DID A COMPLETE HYDRAULIC SURVEY AND
15 DISCOVERED THAT THE SOIL ZONE, WHICH IS THE TOP LAYER
16 OF DIRT 1 TO 2 METERS BENEATH THE SURFACE, HAS A
17 POROSITY OF 55 PERCENT IN THIS AREA AND A RETENTION
18 FACTOR OF 15 PERCENT, WHICH MEANS THAT 55 PERCENT OF
19 THE DIRT RIGHT BENEATH THE SURFACE OF THE EARTH THERE
20 IS POROUS ENOUGH TO SUSTAIN HOLDING 45 PERCENT MORE
21 MATERIAL IN IT, AND IT WILL RETAIN 15 PERCENT OF THE
22 MATERIAL INDEFINITELY.
23 BENEATH THAT IS AN UNSATURATED ZONE AND AN
24 INTERMEDIATE ZONE WHICH WAS 20 TO 30 METERS BEYOND THE
25 SOIL ZONE. THOSE ARE NONSOLUBLE -- EXCUSE ME,
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UNSATURATED, SO THEY'RE THERE AND THEY CAN ABSORB
ALMOST ANY MATERIAL THAT WILL GO INTO THEM. AND I
FOUND OUT THAT PCB'S ARE NONSOLUBLE WATER, OR ALMOST
THEY'RE NOT TOTALLY NONSOLUBLE. AND THEY ALSO
DON'T LIKE TO MIGRATE OUT OF THE SOIL ZONE WHICH IS
THE TOP 6 FEET OF THE GROUND.
WITH A SPECIFIC GRAVITY OF 1.38 TO 1.39, EVEN
WITHOUT BEING WASHED BENEATH THE SURFACE, LEAD HAS A
SPECIFIC GRAVITY OF 11.34. AND YOU CAN SEE BY THE
DIFFERENCE IN THE WEIGHT RATIO THAT PCS'S ARE ACTUALLY
GOING TO TEND TO REMAIN TOWARD THE SURFACE AND THEY
WON'T BE GOING ANY DEEPER.
SO THAT LEFT ME WITH MY LAST THING,
INHALATION. I CALLED PORTLAND CEMENT AND ASKED THE
HOW LONG THEIR CEMENT'S GOING TO LAST OUT THERE AT THE
BASE. THEIR ANSWER WAS: INDEFINITELY. IT SHOULD
NEVER WEAR OUT. IT WON'T LEAK. IT'S NOT TOTALLY
IMPERVIOUS, BUT IT'S PRETTY CLOSE.
SO THEN I WAS WONDERING HOW YOU COULD INHALE
THIS STUFF. YOU COULD HAVE CRACKS IN THE CONCRETE,
WHICH I'M ASSUMING THAT THE NORTON REUSE COMMITTEE'S
GOING TO MAKE SURE THAT THIS CONCRETE'S MAINTAINED.
AND YOU ALSO HAVE EXHALATION THROUGH PLANTS, AND ON
NORTON AIR FORCE BASE THERE'S A PARTICULAR PLANT
1
CALLED THE WOOLLY STAR. AND IT'S AN ENDANGERED
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1 SPECIES. AND IT'S AT THE END OF THE RUNWAY AREAS, IN
2 BETWEEN RUNWAYS. SO YOU CAN'T TAKE THE WOOLLY STAR
3 OUT TO PREVENT IT FROM GETTING DOWN INTO THE PCB'S.
4 HOWEVER, IN THAT PARTICULAR AREA, THE PCB'S AREN'T
5 MIGRATING THROUGH, SO THERE'S NO PROBLEM. THEY'RE SET
6 THERE.
7 MY WHOLE CONCLUSION AFTER COMING DOWN HERE TO
8 RAIL AGAINST THIS PROJECT IS THE FACT THAT IT'S
9 ACTUALLY A GOOD PROJECT AND THERE'S NO OTHER WAY TO DO
10 IT BETTER. EITHER REMOVING THE SOIL NOW, EVEN THOUGH
11 IT'S NOT GOING TO HARM ANYBODY, JUST TO GET RID OF IT,
12 IT WOULD PUT MORE PCB'S IN THE AIR WITH
13 HEAVY-EQUIPMENT DUST AND WATER. TO WATER DOWN THE NEW
14 SOIL IT REPLACED WOULD ACTUALLY DRAG PCB'S DOWN TO THE
15 WATER TABLE. THE OPTIMUM SOLUTION IS TO LEAVE IT
16 ALONE.
17 THANK YOU.
18 MR. TOM BARTOL: THANK YOU, MR. HART.
19 THUS HAVING NO OTHER COMMENTERS, AT THIS POINT
20 WE WILL CONCLUDE THE MEETING; AND THE AIR FORCE
21 REGULATORY AGENCIES WILL PUT TOGETHER OUR FINAL
22 DOCUMENTATION ON THIS PROJECT. THANK YOU.
23 (THE PROCEEDINGS CONCLUDED AT 7:15 P.M.)
24 000--
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1 STATE OF CALIFORNIA )
) SS.
2 COUNTY OF SAN BERNARDINO )
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6 I, PATRICIA A. SHAW, CERTIFIED SHORTHAND
7 REPORTER, DULY QUALIFIED IN AND FOR THE STATE OF
8 CALIFORNIA, DO HEREBY CERTIFY:
9 THAT THE PUBLIC MEETING PROCEEDINGS IN THE
10 FOREGOING ACTION WAS TAKEN BEFORE ME AT THE TIME AND j
J
11 PLACE HEREIN SET FORTH;
12 I FURTHER CERTIFY THAT THE TESTIMONY AND
13 PROCEEDINGS WERE REPORTED STENOGRAPHICALLY BY ME AND
14 LATER TRANSCRIBED BY COMPUTER UNDER MY DIRECTION;
15 THAT THE TRANSCRIPT IS A TRUE AND CORRECT
16 TRANSCRIPTION OF MY STENOGRAPHIC NOTES.
17 I FURTHER CERTIFY THAT I AM NEITHER ATTORNEY OR
18 COUNSEL FOR, NOR RELATED TO OR EMPLOYED BY ANY OF THE
19 PARTIES TO THE ACTION IN WHICH THIS PROCEEDING IS
20 TAKEN.
21 IN WITNESS WHEREOF, I HAVE SUBSCRIBED MY NAME
22 THIS <^WA DAY OF AUGUST, 1996.
23
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25 PATRICIA A. SHAW ,
CERTIFIED SHORTHAND REPORTER, #5024 I
8 , I
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