United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R09-89/032
June 1969
£EPA
Superfund
Record of Decision
            Raytheon, CA

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Sb272-101
1 REPORT DOCUMENTATION i. REPORT NO.
PAGE EPA/ROD/R09-89/032
r^TWeendSuMMe
MfcuPERFUND RECORD OF DECISION
^HKaytheon, CA
First Remedial Action
7. Authors)
9. Performing Org*Jnua«on Nune end Addreee

12. Sponsoring Orgenlzitlon Neme and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460


18. Abemct(Umte200worde)
The Raytheon site is one of three Superfund s:
concurrently. The other two are Fairchild Senu
View Plant) . The sites are located in the Midc
Santa Clara County in the city of Mountain Viev
^^rimarily light industrial and commercial, wit*
^Btural surface drainage features within or sui
^Intercepted by a storm drain system and dischai
industrial activities were conducted in the vie
manufacturing, metal finishing operations, pai
other activities requiring the use, storage, ar
particularly solvents . Site investigations at
and 1982 revealed significant contamination by
and ground water. The primary causes of the cc
and lines, and poor management practices. Befc
investigations, which were conducted under a 1!
activities were conducted at the site by Faircl
actions included tank removals, soil removal at
(See Attached Sheet)
17. Document Aneryet* s. Descriptor*
Record of Decision - Raytheon, CA
First Remedial Action
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, TCA, tolu
b. IdontHlera/Open-Endod Terms
tjATt Held/Croup
nMty Statement

2. 3. Recipient's Acceeeion No.
S. Report 0«t»
06/09/89
*.
S. Performing Orguriatlon Rept No.
10. ProlMtfTMk/WocfcUnHNo.
11. C«ttncl(C)orGr*nt(a)No.
(C)
(0)
IX Typ» of Report 4 Period Cowed
800/000
14.


ttes that are being remediated
iconductor (Mt. View) and Intel (Mountain
ilefield/Ellis/Whisman (MEW) Study Area in
i, California. Land use in the area is
i some residential areas. There are no
rrounding the site; most of the runoff is
:ged to an off site creek. Various
:inity of the site including semiconductor
:ts cleaning, aircraft maintenance, and
id handling of a variety of chemicals,
several of these facilities during 1981
toxic chemicals, primarily VOCs, in soil
sntamination were leaking storage tanks
jre and during additional site
385 Consent Order, interim cleanup
aild, Intel, and Raytheon. Cleanup
id treatment, well sealing, construction
ene, xylenes) , organics (phenols)

19. Security CU«. (Thta Report) 21. No.o(P»ge«
None 95
20. Security d*m (Thte Pige) 22. Price
None
 (See ANSVZM.18)
                                                              See Instruction* on H»v*nt
OPTIONAL FORM 272 (4-77)
(Formerty NTIS-OS)
Department of Commerce

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EPA/ROD/R09-89/032
Raytheon,  CA
First Remedial Action

16.  Abstract (Continued)


of slurry walls, and hydraulic control and treatment of local ground water.  The primary
contaminants of concern affecting the site are VOCs including PCE, TCE, TCA, toluene,
and xylenes; and other organics including phenols.

 The selected remedy for this site includes in situ vapor extraction with treatment by
vapor phase GAC of contaminated soil found within the Fairchild and Raytheon slurry
walls.  There may be some limited soil excavation and treatment by aeration for some
areas outside of the slurry walls, with onsite disposal of residues in the excavated
area; ground water pumping and treatment using air stripping, and in some cases liquid
phase GAC, with emissions controls consisting of GAC vapor phase carbon units, followed
by reuse of the ground water (reuse options including reinjection are being developed)
and, if necessary, discharge to surface water; sealing of any conduits or potential
conduits to protect the deep aquifer; and ground water monitoring.  The present worth
cost for this remedial action is $49,000,000 to 56,000,000, which includes O&M costs.

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     FAIRCHILD, INTEL. AND RAYTHEON SITES
MIDDLEFIELD/ELLIS/WHISMAN (MEW) STUDY AREA
           MOUNTAIN VIEW, CALIFORNIA
     RECORD  OF  DECISION
       United States Environmental Protection Agency
           Region DC - San Francisco. California
                    June 9. 1989

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   JA1RC3ILD, XMT1L, AMD RAYTHZOM SITZS
MXDDLB7XZLD/ZLLZ8/WHXBMAM  (KZW)  ITTJOT
         MOOKTAJM VIEW,
     BBCORO  OF   DBCZ0ZOV
  Unitad Seat** Bxrrlroox«nt«l Proccetioa

      l«gi0B ZZ -- S*n rraneiaco, California

                   May 19S9

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                        EBOOBD OF D1CISIOW
                        fltBLB OF COWOann
SECTION                                                      PAGE;
     Table of Contents                                          i
     Table of Figures and Tables                               ii
     Declaration                                              iii
1.0  Site Location and Description                              1
2.0  Site History                                               2
3.0  Enforcement                                                3
4.0  Community Relations                                        4
5.0  Decision Scope                                             4
€.0  Nature and Extent of Contamination                         5
7.0  Baseline Site Risks                                        6
8.0  Changes to the Proposed Plan                               8
9.0  Description of Alternatives                                9
10.0 ARARs                                                     14
11.0 Other Criteria Considered                                 18
12.0 Summary of Alternatives Analysis                          21
13.0 The Selected Remedy                                       22
14.0 Statutory Determinations                                  24

                        — Attachments —
                   Administrative Record Index
                     Responsiveness Summary

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                        UCOftD 07 DBCISIOM
                        TABLB 07 COHTOTTfl
                          •- Figures —
                                                        >uTNG PAGE
1-1  ---  Sit* Location                                         1
1-2  —  Building Occupants                                    1
6-1  —  Location of MEW Plum*                                 5
9-1  —  Schematic of Subsurface Zones                         9
                           — Tables —
6-1   —• Chemicals of Concern                                 5
10-1  — Federal and State Groundvatar Standards             15
11-1  — Groundvater Criteria To Be Considered               19
12-1  	 Criteria for the Evaluation                    .     21
                    of Remedial Alternatives
                                ii

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                        S1CORD 07 D1CIBTOM

                           D1CIARATIOM
Site Hnmit and Location
Fairchild, Intel and Raytheon Sites, Middlefield/Bllis/Whisman
(MEW) study Area, Mountain View, California

Statement of Basis and Purpose?

This decision document presents the selected soil and groundwater
remedial actions for the Fairchild, Intel, and Raytheon National
Priority List (NPL) Sites in the Middlefield/Ellis/Whisman (MEW)
Study Area of Mountain View, California. The selected remedial
actions will also apply to the area-vide groundwater
contamination and to other areas of soil contamination in the MEW
Study Area, as appropriate. The remedial actions have been
developed in accordance with the Comprehensive Environmental
Response, Liability, and Compensation Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA), and, to
the maximum extent practicable, the National Contingency Plan
(NCP). This decision is based upon the administrative record for
this site. The attached index identifies the items which comprise
the administrative record upon which the selection of the
remedial actions are based.

Description of the Remedies

The selected soil remedy is in-situ vapor extraction with
treatment by vapor phase granular activated carbon, and
excavation with treatment by aeration. Most of the vapor
extraction will taJce place within the existing Fairchild and
Raytheon slurry walls which contain the bulk of the site soil
contamination. Several smaller areas outside of the slurry walls
will also be remediated by in-situ vapor extraction. The cleanup
goals for soils are 1 part per million  (ppm) trichloroethene
(TCE) inside the slurry walls and 0.5 ppm TCE outside of the
slurry walls. The soil cleanup goal is based on the amount of
contamination that can remain in the soil and still maintain the
groundwater cleanup goal in the shallow aquifers  (outside the
slurry walls). Further explanation of the different cleanup goals
is provided on page 22 of this document, in Section 13 on The
Selected Remedies«

The groundwater remedy is extraction and treatment. Extracted
groundwater will be treated by air stripping towers. Airborne
emissions will meet all Bay Area Air Quality Management District
emission standards. It is anticipated that emission controls by
granular activated carbon will be required once the full remedy
is implemented. The extracted groundwater will be reused to the

                               iii

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aaxinua extant feasible, with a goal of 100% reuse, extracted
vatar which cannot be reused will ba dlachargad to local atraaas.
Allowable discharges to local atraaaa will ba ragulatad by the
National Pollutant Oiacharga Elimination Syatan (NPDES) of tha
Claan Watar Act.

Tha groundvatar claanup goal* ara 5 part* par billion  (ppb) TCE
for tha anallow aquifars (which ara not currently used for
drinJcing water) and 0.8 ppb TCE for the deep aquifers which ara
used for drinJcing water. Attainment of these levels will also
assure cleanup of the other volatile organic compounds to at
least their respective Maxinua Contaminant Levels (MCLs). The
shallow aquifer cleanup goals also apply to the aquifars inside
the slurry walls.

The remedy includes the identification and sealing of any
potential conduit wells. Several abandoned agriculture walls
which acted as conduits for contamination to migrate from the
shallow aquifers to the deep aquifers have already been sealed.
Additional wells have been identified for sealing and others may
be identified which will also require sealing.

The remedy also includes maintaining inward and upward hydraulic
gradients (by pumping and treatment) inside the slurry walls and
regular monitoring of aquifars within and adjacent to the slurry
walls to monitor the integrity of each slurry wall system-.
Maintaining inward and upward hydraulic gradients will control
contaminants from escaping due to slurry wall failure. Selected
wells will be monitored for chemical concentrations and water
levels.

The soil remedy is expected to be in operation between 1 to 6
years. The groundwater remedy for the shallow aquifars may be in
operation for as long as 46 years or into the indefinite future,
because of the physical and chemical nature of the aquifars. The
groundwater remedy for the deep aquifars is estimated to be in
operation for at least 2 years and possibly as long as 45 years.
There will be regular monitoring of the groundwatar and slurry
vails during the life of the remedy.
                                iv

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Declaration

The selected remedies arc protective of human health and the
environaent, attain Federal and State requirements that are
applicable or relevant and appropriate to the remedial actions,
and are cost-effective. With respect to contamination in
groundvater and soil, the statutory preference for remedies that
employ treatment, reduce toxicity, mobility or volume as a
principal element, and utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable is satisfied.

Because of the anticipated length of time to achieve the cleanup
goals and the uncertainty whether the cleanup goals can be
achieved, both the technologies and the cleanup goals will be
reassessed every 5 years.
iel
                                   Danel W. McGovern
                                   Regional Administrator

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                        UCOBD OF DBCX8XOV

                         DICXSIOM SU1OCXAT


 1.0  SITE  LQCATTOM AND  DESCRIPTION


 The Middlefield/Ellis/Whisaan  (MEW) Study Area i» located in
 Santa Clara County in the city of Mountain View, California.
 The site is divided into a Local Study Area (LSA) and a Regional
 Study Area (RSA). Figure 1-1 identifies the LSA and RSA, along
 with local roads and landaarks. The LSA consists of three
 National Priority List  (NPL) sites (Fairchild, Intel and
 Raytheon), as veil as several  non-Superfund sites. The LSA
 encoapasses about 1/2 square aile of the RSA and contains
 priaarily  light  industrial and coaaercial areas, with soae
 residential areas vest  of Whisaan Road. The RSA encompasses
 approximately 8  square  ailes and includes Moffett Naval Air
 Station  (an NPL  site) and NASA Ames Research Center, along with
 light industrial, coaaercial,  agricultural, park, golf course,
 undeveloped land, residential, motel and school land uses.

 Various owners or occupants in the area around the intersections
 of Middlefield Road, Ellis Street, Whisaan Road, and the Bayshore
 Freeway  (U.S. Highway 101), are or were involved in the
 manufacture of semiconductors, metal finishing operations, parts
 cleaning,  aircraft maintenance, and other activities requiring
 the use of a variety of chemicals. Local facilities with current
 occupants  are presented on Figure 1-2. Site investigations at
 several of these facilities have revealed the presence of toxic
 chemicals  in the subsurface soils and groundwater. To investigate
 the extent of groundwater contamination emanating froa the LSA,
 and soil contamination  at their respective facilities, Fairchild,
 Intel, and Raytheon performed  a Remedial Investigation and a
 Feasibility Study of potential remedial alternatives under the
 direction  of EPA.

 There are  no natural surface drainage features within the Local
 Study Area. The  nearest significant natural surface drainage
 features of the  Regional Study Area are Stevens Creek to the vest
 and Calabazas Creek to  the east. Calabazas Creek is located
 approximately four ailes east  of the MEW Study Area. Stevens
 Creek forms the  western boundary of the Regional Study Area. Both
 discharge  into the San  Francisco Bay. Surface water runoff  from
aost of the RSA  and all of the LSA south of the Bayshore Freeway
 is intercepted by a storm drain systea and is discharged into
 Stevens Creek. To the north of the Bayshore Freeway, aost of- the
 runoff froa Moffett Field Naval Air Station is collected by a
 storm drain systea that ultimately discharges to Guadalupe  Slough
 of San Francisco Bay. Runoff froa the northwestern portion  of
Moffett Field discharges into  Stevens Creek.

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         v   LIMITS  OF
           -— O ff /* i /•TVfVi—
      MOFFETT
       FIELD
MOUNTAIN VICV* CALIFORNIA


       - ELLIS- WHISMAN AREA

     SIU Location
      Flgurt 1-1

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     BUILDING  OCCUPANTS
   MOUNTAIN V€W. CALIFORNIA


        Flgur* 1-2


MIOOLfFlEU>-EU.I3-MM3MAN  AREA
sesuFM
•M $MmB]
lorUHMB
| « on-
                             itn

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 The Local and Regional Study Areas are underlain by a thick
 sequence of unconsolidated sediments deposited into a structural
 depression. The sediments are coaprised of alluvial fan,
 estuarine, and bay mud deposits. Repeated.variations in s«a
 levels resulted in a complex sedimentary sequence characterized
 by irregular interbedding and interfingering of coarse and fine
 grained deposits.

 Groundwater aquifers at the site are subdivided into shallow and
 deep aquifer systeas, separated by a laterally extensive  regional
 aquitard. The shallow aquifer systea comprises aquifers and
 aquitards to a depth of approximately 160 feet: below the  surface.
 Within the shallow systea four priaary hydrogeologic aquifer
 zones have been identified based upon the occurrence of aquifer
• material and a siailar depth below the surface. The shallow
 aquifer systea is comprised of the A-aqulfer and the underlying
 B1-, B2- and B3- aquifers. The regional B-C aquitard separates
 the B3-aquifers froa the C-aquifer and the deep aquifer system.
 Current groundwater flow in aquifer zones above the B-C aquitard
 is generally to the north, toward San Francisco Bay.


 2.0  SITE HTSTQRY


 During 1981 and 1982, preliminary investigations of facilities
 within the LSA indicated significant concentrations of
 contaainants in soil and groundwater. By 1984, the Fairchild,
 Intel and Raytheon sites, located within the LSA, were proposed
 for the Federal National Priorities List (NPL). By 1985,  five
 companies within the LSA (Fairchild, Intel, Raytheon, NEC, and
 Siltec)  initiated a joint investigation to document and
 characterize the distribution of chemicals eaanating froa their
 facilities. In April 1985, the California Regional Water Quality
 Control Board - San Francisco Bay Region (RWQCB) adopted Waste
 Discharge Requirements (WDRs) for each of the five companies. The
 primary cause of the subsurface contaaination was froa leaking
 storage tanks and lines, and poor waste management practices.

 On August 15, 1985, Fairchild, Intel, and Raytheon entered into a
 Consent Order with the EPA, the RWQCB, and the California
 Department of Health Services (DBS). Since signing of the Consent
 Order, the three coapanies have carried out an extensive Reaedial
 Investigation and Feasibility Study (RI/FS) of chemicals
 emanating froa the LSA and soil contaaination at their respective
 facilities. Work has been performed under the supervision of EPA,
 the RWQCB,  DHS, and the Santa Clara Valley Water District
 (SCVWD).  Prior to and during the site investigation, the
 coapanies have been conducting interia clean up activities at the
 site.  These interia reaedial actions include tank removals, soil
 removal and treatment, well sealing, construction of slurry

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walla, and hydraulic control and treatment of local groundwatar.
NEC and Siltac declined to enter into the Concent Order and were
placed under RWQCB enforcement authority.

The three coapaniee followed an approved Quality Assurance and
Quality Control  (QA/QC) Plan and approved Sampling Plane. Zn
addition, eplit  samples were collected by EPA froa aelected walls
and these result*  were compared with the companies' eaapling
results. EPA determined that the companies* data quality was
adequate for the purpose of the RI/FS.

The MEW Remedial Investigation Report was concluded in July,
1988. The draft  Feasibility Study and EPA's Proposed Plan were
presented to the community for review and public comment in
November, 1988.  In May 1989, Special Notice letters for the
Remedial Design/Remedial Action (RO/RA) Consent Decree were sant
out to the five  (5) original companies and twelve (12) other
Potentially  Responsible Parties (PRPs).


3.0 ENFORCEMENT


The Regional Water Quality Control Board - San Francisco Bay
Region (RWQCB) was the lead agency until April 1985, when the
Board referred the five companies to EPA for cleanup under
Superfund. In May, 1985, EPA sent general notice letters,
pursuant to  Section 106 of CERCLA, to the five companies. NEC and
Siltec chose not to participate in the RI/FS negotiations and
were referred back to the RWQCB. Zn August 1985, Fairchild,
Intel, and Raytheon signed an Administrative Order on Consent
with EPA, to conduct an RI/FS of the MEW area. The RWQCB and
California Department of Health Services were cosignees of the
Consent Order.

The Consent  Order  and WorJc Plan called for a comprehensive
groundwater  investigation of the MEW area and site specific
(source) investigation at Fairchild, Zntal, and Raytheon. The
RWQCB issued Waste Discharge Requirements (WDRs) for NEC and
Siltec which paralleled the Consent Order schedule and
requirements.

During the course  of the RZ/FS, EPA gathered new information and
evaluated existing information concerning other PRPs.

During December  1987 and January 1988, EPA issued twenty-four
(24) RCRA 3007/CERCLA 104 information request letters to various
other parties in the MEW area. Zn July 1988, SPA issued a RCRA
3013 Unilateral  Order to GTE to begin an investigation of its
property, to determine if the company had contributed to the MEW
groundwater  plume. After evaluating the 3007/104 response
letters, EPA sent  General Notice Letters to seventeen  (17)  PRPs

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 in September 1988. An initial PRP meeting vac sponsored by EPA in
 October 1988,  to explain the Superfund process to the noticed
 PRPs.  EPA issued seven (7) additional General Notice and/or
 information  request  letters in March 1989. EPA subsequently
 issued Special Notice Letters for conducting the selected
 reaedies in  May  1989.


 4.0 eOMMONITY MIATTOMS


 The coaaent  period for the Proposed Plan opened Noveaber 21,
 1988,  and closed January 23, 1989. A public meeting was held on
 December 14,  1988 at the Crittenden Middle School in Mountain
 View and was attended by approximately 75 people.

 Prior  to the beginning of the public conaent period, EPA
 published notices in "The View**, "The Los Altos Town Crier", "The
 Tiaes  Tribune",  and  the "San Jose Mercury News** (Peninsula Extra
 Edition).  The notices briefly described the Proposed Plan and
 announced the public coaaent period and the public aeeting. The
 notice also  announced the availability of the Proposed Plan for
 review at the information repository established at the Mountain
 View Public  Library.

 A  fact sheet describing the Proposed Plan was delivered to the
 Mountain View Public Library in Noveaber, 1988. Copies of the
 fact sheet were  also Bailed in November, 1988 to EPA's MEW
 Bailing list,  which  contains members of the- general public,
 elected officials, and PRPs.

 In addition, EPA held several worJcshops and briefings-in November
 and December,  1988 for various community groups, the Mountain
 View city Council, and the Santa Clara County Board of
 Supervisors. The workshops were used to brief community groups
 and elected  officials on the results of the MEW RI/FS and to
 describe EPA's proposed reaedial alternatives.

 EPA has prepared the attached response summary, which provides
Agency responses to  coaaents submitted in writing during the
public coaaent period.  Also attached is a transcript of the
proceedings  of the Deceaber 14, 1988 coaaunity meeting.


5.0  DECISION SCOPE


As discussed in  the  Declaration and Site History, the selected
reaedial  actions that are presented in this decision  document are
designed to  protect  the local drinking water supplies, restore
the -shallow,  and deep aquifers to Beet MCLs and a 10** risk level
respectively,  control and remediate contamination in  subsurface

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•oils, and prevent vertical migration of contamination in the
aquifers. The difference in decision on cleanup goals for the
shallow and deep aquifers is provided on page 22 of this
docuaent, in Section 13 on Tha s«l acted
The reaedial actions, pumping and treating groundvater and
conduit sealing, will address the area-vide groundvater
contamination. The reaedial actions, in-situ soil vapor
extraction, and excavation and treatment vill address soil
contamination at the Fair-child, Intel, and Raytheon NPL sites and
other areas' of soil contamination identified in the MEW study
Area.


6.0  MATURE AND EXTENT OF CONTAMINATION


Industrial activities conducted within the MEW Study Area
required the storage, handling and use of a large number of
chemicals, particularly solvents and other chemicals used in a
variety of manufacturing processes. Significant quantities of
volatile organic chemicals vere used for decreasing, process
operations, and for general maintenance. Raw and waste solvents
and other chemicals were piped and stored in underground systems .
The presence of chemicals in the subsurface soils and
groundwater, that originated from facilities in the MEW area, are
primarily the result of leaks from these subsurface tanks and
lines, sumps, chemical handling and storage areas, and utility
corridors. Chemical releases occurred, for the most part, below
the ground surface and migrated downward into the aquifer system.

Investigations at the site have revealed the presence of over 70
compounds in groundwater, surface water, sediments, and
subsurface soils. The vast majority and quantity of these
compounds are found in groundwater and subsurface soils. Three
major classes of chemicals were investigated during the RI:  (1)
volatile organic compounds, (2) semi-volatile acid and
base/neutral extract able organic compounds, and (3) priority
pollutant metals. Of these three classes, volatile organics are
the most prevalent. Table 6-1 presents chemicals of concern,
frequency of defection, and maximum concentrations.

An extensive area of groundwater contamination has been defined
in the RI and is presented in Figure 6-1. Current site data
indicate that chemicals are present primarily in the A-, B1-, and
B2-aquifer zones. To a much lesser degree, chemicals have been
detected in localized areas of the B3-, C-aquifer, and deeper
aquifer zones. Contamination of the C-aquifer and deeper aquifers
appears to have resulted from chemicals migrating downward from
shallow areas containing elevated chemical concentrations,
through conduit wells, into groundwater of the deep aquifer
system. The C and Deep aquifers most affected by contamination

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 Chemical
                             TABLE 6-1

                       CHEMICALS OF CONCERN
               JUDDLEFIELD/ELLIS/WHISMAN STUDY AREA
Frequency of
 Detection*
Geometric Mean    Maximum
Concentration"  Concentration6
  (*g/liter)      (*g/liter)
Organ iqa
Chloroform
1 , 2-Dichlorobenzene
1 , 1-Dichloroethane
1, 1-Dichloroethene
1 , 2-Dichloroethene
Freon-113
Phenol
Tetrachloroethene . .
1, 1, 1-Trichloroe thane
Trichloroethene
Vinyl Chloride
Inorganics
Antimony
Cadmium
Arsenic
Lead

71/384
13/384
98/384
133/384
200/384
181/384
21/273
64/384
184/384
278/384
17/384

15/205
26/205
34/292
44/292

0.002
0.003
0.005
0.006
0.030
0.009
0.002
0.003
0.017
0.175
0.008

0.052
0.006
0.004
0.002

3.3
5.2
10.0
20.0
330.0
46.0
50.0
3.7
420.0
1000.0
25.0

0.600
0.050
0.040
0.043
a/   Values for organic* are number of detects/number of samples
     for the fourth round of groundvater campling. Values  for
     inorganics are the number of detects/number of veil sampled
     for dissolved metals.

b/   Values reported are for all groundvater samples for each
     chemical.

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                    Showing
         TCE OMp Aqua* contairtnattan
Location of MEW Plume

       Figure 6-1

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 are in the  areas  of the so-called Rezendes Wells, located near
 Fairchild Building 20, and the Silva Well, located at 42 Sherland
 Avenue. These wells have subsequently been sealed. The closest
 Municipal water supply well, Mountain View 118 (MV 18), is
 located approximately 1800 feet to the southwest of the Silva
 Well.  Groundwater sanples are collected front MV 18 on a regular
 basis. No contaainants have been identified in any water samples
 froa MV 18. As part of the Remedial Design and Remedial Action
 (RD/RA) soae additional groundwatar investigations pay be
 necessary,  particularly in the Silva Well area.

 Subsurface  soil contamination has been found at the Fairchild,
 Intel, and  Raytheon facilities, along with the facilities of
 other  PRPs  within the RSA. Trichloroethene (TCZ), 1,1,1-
 trichloroethane (TCA), trichlorotrifluoroethane (Freon-113), 1,1-
 dichloroethene (1,1-DCZ), 1,2-dichloroethene (1,2-DCE), aethylene
 chloride, toluene,  acetone, and xylene are the cheaicals most
 commonly  detected in subsurface soils in the LSA. Cheaicals
 associated  with activities in the RSA appear to b* concentrated
 in  shallow  soils  above approximately 50 feet or roughly extending
 to  the Bl-aquifer.  Cheaicals are'not found in surface soil
 samples (upper one foot of soil) and do not appear in soils and
 clay of the B-C aquitard. Chemical found in subsurface soil
 samples are generally similar to those found in adjacent
 groundwatar samples. As part of the Remedial Design and Remedial
 Action some additional soil investigations may be necessary in
 certain areas.
7.0  BASELINE SITE RISKS


An Endangeraent Assessment prepared by EPA as part of the RI/FS
was used to evaluate the ramifications of the no-action remedial
alternative and to determine if an actual or threatened release
of a hazardous substance froa the site may present an imminent or
substantial endangerment to public health, welfare, or the
environment.

Large areas of the site are contaminated. The bulk of the
contamination is present in groundwater and subsurface soils.
Investigations at the site have revealed the presence of over 70
compounds. Because of the large number of cheaicals detected at
the site, a selection process was used to determine the cheaicals
of primary concern at the site. The organic cheaicals that were
selected are: trichloroethylene, 1,1,1,-trichloroethane, vinyl
chloride, 1,1-dichlproethane, l-,l-dichloroethylen«, 1,2-
dichloroethylene (cis and trans isomers), dichlorobenxene,
chloroform, Freon 113, tetrachloroethylens, and phenol. Metals
were detected infrequently. Overall metals are  of less concern at
the site that the volatile organic cheaicals. Several of the
selected contaainants (trichloroethylene, chloroform.

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 dichlorobenzene, tetrachloroethylene) have been shown to b«
 carcinogenic in animals and have been classified by EPA as
 possible or probable human carcinogens. Vinyl chloride is a known
 huaan carcinogen. The other contaminants have been shown to cause
 systemic toxicity under certain exposure conditions.

 The results of the Endangeraent Assessment indicate that exposure
 to contaminated groundwater poses the greatest public health
 concern.  Risks to public health were estimated by combining
 information on exposure at possible exposure points with toxic
 potency  of  the groundwater contaminants. Drinking water from
 hypothetical wells to the west of Nhisman Road for a lifetime
 would be associated with an upperbound excess lifetime cancer
 risk  of  6(10)*s  (average case) and 2(10)** (maximum case).
 Drinking water from a well to the north of the LSA in the A-
 aquifer  would be associated with an upperbound excess lifetime
 cancer risk of 9(10)**  (average case) and 4(10)**  (maximum case).
 Drinking water from a Bl-aquifer well in the same area would pose
 an upperbound excess lifetime cancer risk of 1(10)"2  (average
 case)  and 5(10)*2  (maximum case). In addition, estimated  intake
 of noncarcinogenic compounds from groundwater at these locations
 would exceed reference dose levels (RfDs).

 Contaminants are not present at elevated levels in exposed
 surface  soils. Consequently, substantial exposure via direct
 contact with contaminated soils or via inhalation of volatile
 compounds from soil or contaminated fugitive dust is considered
 unlikely under current land-use conditions. If redevelopment of
 the site  was to occur for residential or other uses, significant
 exposure  to contaminants can occur if localized areas of
 contamination remained uncovered. Short-term excavation
 activities  at the site could lead to inhalation of volatile
 organic compounds or contaminated fugitive dust, but exposure
 would probably be of short duration and frequency, and therefore
 would not pose a significant public health concern.

 Low concentration-levels of several chemicals were detected in
 Stevens Creek, at the western boundary of the RSA. Any exposure
 to these  chemicals would probably be of short duration and
 frequency,  and therefore the risk would be negligible.

The Endangeraent Assessment also indicates that "environmental"
 (flora and  fauna) exposure to chemicals from the MEW site is
negligible.

In summary,  the results of the baseline risk assessment  for the
no-action alternative indicate that exposure to contaminants in
groundwater poses the greatest potential public health concern.

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8.0  CHANCgS TO THg PROPOSED PIAM


1.   The Proposed Plan identifies vapor extraction as the
     preferred alternative to addreas contaainatad aoila.
     However, because aoil excavation and traataant by
     aaration has baan effectively iapleaented at MEW in tha
     past (at Zntal), and othar pRPs have expressed intarast
     in exploring this altarnativa for thair sites, tha
     salactad reaedy for soils will also allow soil
     axeavation to ba iapleaented, providad federal, state,
     and local air standards can ba »at. In addition to
     local air standards, Bast Oaaonstratad Availabla
     Tachnology (BOAT) traataant standards aay also ba
     required depending upon how tha axcavatad soil is
     handlad. Tha addition of soil axeavation and traataant
     by aaration allows flexibility during tha RD/RA phasas
     for othar PRPs to usa a cost affaetiva altarnativa for
     thair particular sitas whila also protaeting huaan
     haalth arid tha anvironaant. Soil axeavation and
     traataant by aaration would aost likely ba> suitabla for
     saall loealizad araas of contaaination.

2.   Tha Proposad Plan appaars to ba aabiguous in tha
     claanup goal for aquifars within the- slurry walls.
     Whila tha Proposad Plan claanup goal for tha shallow •
     aquifars is 5 ppb for TCZ, howavar, tha plan also
     statas that tha shallow aquifar zona is dafinad as
     thosa shallow aquifars locatad outsida tha slurry
     walls.

     Although tha aquifars confinad by tha slurry walls ara
     disconnectad froa tha outsida aquifars (whan hydraulic
     control is aaintainad by pumping aquifars insida tha
     slurry walls) a elaanup goal of 5 ppb for TCS  (tha MCL)
     will also ba established for aquifars insida tha slurry
     walls. This goal is aora protective of tha public
     health and tha environment and is consistent with
     cleanup goals set by tha RWQCB for another site in
     Santa Clara Valley.

3.   Identification and sealing of potential conduits was
     discussed in text of tha Feasibility Study (FS) and in
     Appendix L of tha FS, but not specifically noted in EPA's
     Proposad Plan. Potential conduits will be identified,
     evaluated, and sealed if necessary.
                                8

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 9.0  DESCRIPTION OF ALTERNATIVES


 The MEW Feasibility study identified an array of remediation
 technologies that verm potentially applicable and then screened
 those technologies based  on their applicability to site
 characteristics,  compatibility with site-specific chemicals, and
 anticipated performance.  After the technology screening process,
 alternatives were formulated using combinations of feasible
 technologies that are capable of meeting remedial objectives.
 These alternatives were evaluated based on their public health
 and environmental impacts and on order of magnitude cost
 considerations.  The short- and long-term effectiveness of each
 alternative was  also assessed. After this initial screening of
 remedial alternatives,  a  detailed analysis of the selected
 alternatives was performed. This section of the Record of
 Decision will present the alternatives evaluated in the detailed
 analysis of remedial alternatives.

 To  evaluate the  remedial  alternatives, the MEW Study Area was
 divided into five subsurface zones, as show in Figure 9-1. The
 first subsurface zone (Zone 1, the "cohesive shallow layer")
 consists of soil stratum  that begins at the ground surface and
 extends to  the water table. The upper foot of the cohesive
 shallow layer is not included in the analysis of alternatives
 based upon  the conclusion set forth in the Endangerment
 Assessment  that  there are no health risks from exposure to
 surface soils. The second subsurface zone (Zone 2A, the
 •unsaturated disconnected aquifers") consists of the unsaturated
 zone  within the  area bounded by the existing slurry walls. The
 Fairchild slurry walls extend into the A/B aquitard. The Raytheon
 slurry wall extends through the A/B and B1/B2 aquitards and into
 the B2  aquifer.  The third subsurface zone (Zone 2B, the
 "saturated  disconnected aquifers") consists of the saturated zone
 within  the  slurry walls.  The fourth subsurface zone (Zone 3, the
 "shallow aquifers")  consists of the shallow aquifer system
 outside of  the slurry walls. The fifth subsurface zone  (Zone 4,
 the "deep aquifers")  consists of the C-aquifer and deeper aquifer
 zones.

 The range of potential  remedial alternatives are presented for
 each  subsurface  zone:  Zone 1 Soils; Zone 3 Shallow Aquifers; Zone
 4 Deep  Aquifers;  and Zones 2A and 2B Slurry Wall System.

 Zone  1  -  Soils

Ho Further  Action:

The Ho Action alternative serves as a "baseline* against which
other alternatives are  compared. For soils, only soil monitoring
would be  conducted,  and all soil pilot study activities would be
discontinued.

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                                 SURFACE  LAYER
SLURRY WALL
                         ZONE  3
                                SLURRY  WALL

                      CONFINING  AQUITARO
                    '3-C' AOUITARD
                         ZONE  4
  LEGEND:

       GROUND WATER LEVEL
       SLURRY  WALL EXTENSION
       THROUGH AQ'JITARO
  ZONE DEFINITIONS:

            COMC5IVC  SHALLOW
                   OISCONNCCTCO

            SHALLOW AQUIFERS

            BEEP
                 SCHEMATIC  OF SUBSURFACE
                    ZONES AT MEW SITE
                       SLURRY  WALL
OBCONNCCTO AOUIFERS  MOUNTAIN  VIEW,  CALIFORNIA
                         pftCPAftco ron
            REMEDIAL INVESTIQAT10N/FEASIBIJTY  STUDY
               MIOOLEFJ ELD-ELLIS-WHISMAN AREA

                         Figure  9-1

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 In-situ Vapor Extraction and Treatment:

 Soil vapor extraction involves removing the volatile soil
 contaminants  without excavating the soil itself. This would b«
 accoaplished  by installing vapor extraction wells through which
 air containing Volatile Organic Compounds (VOCs) is pumped from
 the soil. Contaminants in the extracted air are then removed
 using carbon  treatment, if necessary, and the treated air is
 released. The treatment process is designed to meet all
 applicable air emission standards.

 Partial Excavation and Ambient Temperature Aeration:

 This alternative involves excavating and aerating the soil, which
 causes the VOCs to volatilize. Treated soils are then placed back
 in their original locations. The areas that would be excavated
 are those with the highest level of contamination. Treatment by
 ambient temperature aeration would be conducted inside a
 controlled atmosphere enclosure where necessary. This enclosure
 would prevent the migration of fugitive dust and chemicals vapors
 from the treatment area. Chemical vapors would be captured by
 activated carbon, if necessary. The primary disadvantages of this
 alternative are that soils located under buildings and other
 structures could not be excavated and. treatment of the air
 emissions is  difficult.

 Partial Excavation and Ambient Temperature Aeration with In-Situ
Vapor Extraction:

This alternative involves a combination of the previous two
cleanup alternatives. Excavation and aeration would be used at
those soil contamination zones that are accessible. Vapor
extraction would be used for selected contamination zones that
are not easily accessible, such as soil contamination zones
 located under buildings.

Zone 3 - Shallow Aquifers

Ho Further Action:

The No Action alternative for the shallow aquifers would involve
only groundvater monitoring; no additional cleanup activities
would be conducted.

Hydraulic Control by Groundwatar Extraction and Treatment:

This alternative Involves low-rate pumping of the affected
aquifers with monitoring of the plume, and represents the  lowest
level of active restoration evaluated for the shallow groundwater
system. Recovery wells would be installed in appropriate
locations along the periphery of the plume. The extraction well

                                10

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 would-operate at a puaping rate sufficient to insure that the
 pluae would not expand laterally. Extracted groundwater would be
 treated using air stripper-based treatment systems and vapor-
 phase carbon adsorption (where necessary) which would be operated
 under applicable alar and water quality requirements. The treated
 water would be discharged  to Stevens Creek via the storm sewer
 systea.  A network of monitoring wells would be used to determine
 any changes in the extent  of the pluae.

 Hydraulic Remediation by Groundwater Extraction and Treataent:

 This alternative involves  puaping the affected aquifers at a rate
 sufficient to achieve an accelerated reduction in the extent of
 the pluae and reduction of chemical concentrations in the
 groundwater.  This alternative would also utilize a network of
 monitoring wells to verify remediation progress. Extraction wells
 would be installed in locations around the periphery and in the
 plume. Extracted groundwater would be treated using air stripper-
 based treatment systems and vapor-phase carbon adsorption if
 necessary,  which would be  operated to meet applicable air
 emission limitations.  Treated water would be discharged to
 Stevens  Creek via tae stora sewer systea.

 Vertical Iaperaeable) Barriers:

 This alternative involves  constructing a vertical iaperaeable
 barrier  around the entire  MEW pluae, in order to hydraulically
 isolate  the shallow aquifers. This alternative would not result
 in  a permanent reduction of chemicals currently in the shallow
 aquifer  systea,  unless implemented in conjunction with other
 remedial alternatii

 Zone 4 — Deeo
No Further Action:

The No Action alternative, which is used as a baseline for
evaluation of remedial alternatives, consists of monitoring the
existing groundwater pluae.

Hydraulic Remediation by Groundwatar Extraction and Treatment:

Elements of this alternative are described above for shallow
aquifers and are essentially the same for the deep aquifers.

Zone 2A — Uhsaturatsd Disconnected Aquifers  fSlurry Wall.  System)

No Further Action:

The No Action alternative involves no further treatment of Zone
2A soils, located within the area bounded by the existing slurry
walls. Under this alternative, the unsaturated disconnected

                                11

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 aquifer •oil* would  remain contained laterally by the slurry
 cutoff walla.  Long-term monitoring of vatar levels and cheaical
 concentrations in th« saturated disconnected aquifara (Zona 2B)
 and  tha shallow aqulfar (Zona 3) water-bearing zones outaida
 (beneath and  around) tha alurry valla would b« raquirad to datact
 aigration of  cheaicals  froa tha unsaturatad soil* within tha
 alurry walls.

 In-Situ Vapor Extraction:

 This altamativa for raaadiation of tha unsaturatad disconnected
 aguifar soils involvas  aarating tha Zone 2A soils by vacuum
 axtraction, traating tha extracted air in accordanca with
 applicable air quality  raquiramants. Extractad volatilas would
 pass through  an emission control systaa consisting of vapor-phase
 carbon adsorption for raaoval of tha VOCs froa tha axtractad air
 prior  to discharge to tha ataosphara in accordanca with
 appropriate air requirements. This alternative would also use
 existing axtraction .walls to remove tha groundwatar necessary to
 aaintain desired water  levels. Tha extracted groundwatar would be
 treated using air strippers or carbon adsorption to remove voc's
 prior  to discharge of tha extracted groundwatar to Stevens Creek.

 Maintain Inward and Upward Gradients:

 This alternative involves pumping limited quantities of
 groundwater from the saturated portions' of tha aquifers within
 the  slurry walls.  This  process will aaintain a hydraulic gradient
 inward  across  tha slurry walls and upward, thereby restricting
 the  movement of chemicals outward into tha shallow aquifer zone
 (Zone 3). The  use of hydraulic control in conjunction with the
 slurry  walls ensures that contaminates will be kept localized
 (within tha confines of each slurry wall) and add an additional
 level of protection if  a slurry wall failure was to occur. The
 conjunctive use of slurry walls and hydraulic control is referred
 to as a slurry wall systaa. Tha extracted groundwater would be
 treated using  air stripping or carbon-adsorption prior to
 discharge to Stevens Creek.

 Flushing:

This alternative,  for reaadiation of unsaturatad aquifers within
the  slurry walls (Zona  2A), involves the extraction of water from
tha  saturated  soils, re-saturation of tha unsaturatad soils,
treatment of extracted  groundwatar by air stripping, and
rainjaction of tha treated water into rasaturatad soils within
tha  slurry walls.  Tha unsaturatad soils would ba raaadiatad by
flushing  using a  network of water injection and axtraction wells.
Extractad groundwatar would ba treated by air stripping prior to
rainjaction through tha injection wall network.
                                12

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 Partial Excavation and Ambient Temperature Aeration:

 This  alternative for 2A •oil* involves the partial excavation of
 highly localized areas of cheaicals containing unsaturated
 disconnected  aquifer coils. Treatment by aabiant temperature
 aeration would be conductad inside a controllad atmosphere
 enclosure vhara  necessary. This anclosura would pravant tha
 •igration of  fugitiva  dust and chaaicals vapors froa tha
 traatnant araa.  Chaaical vapors would ba capturad by activated
 carbon,  if nacassary.

 Zone  2B - Saturated Disconnected Aquifers fSlurry Wall Svatenl

 No Purthar Action:

 Tha No  Action altamativa involvas no furthar traatnant of tha
 containad soils  or hydraulic gradiant control within tha araa
 boundad by tha slurry  walls. Long-tarn monitoring of watar levels
 and chemical  concentrations in tha saturated disconnected
 aquifers (Zone 2B)  and tha shallow aquifer (Zona 3) water-bearing
 zones outside (beneath and around) the slurry walls would be
 required to detect migration of cheaicals froa the unsaturated
 soils within  the slurry walls.

 Zn-Situ Vapor Extraction With Oewataring:

 This  alternative for remediation of saturated aquifer soils
 involves dewatering the aquifers within the area bounded by the
 slurry  walls, aerating the dawatared soil pore spaces by vacuum
 extraction, treating tha extracted air, if required, with vapor-
 phase carbon  adsorption, treating the extracted groundwatar with
 air stripping, and discharging the treated air and watar in
 accordance with  applicable air and watar quality requirements.
 The extracted groundwatar would be treated using air strippers or
 carbon  adsorption to raaove VOCs prior to discharge of the
 extracted groundwater  to Stevens Creek.

Maintain Inward  and Upward Hydraulic Gradients:

This  hydraulic control alternative for saturated aquifers within
the slurry walls (Zona 2B), involves pumping relatively saall
quantities of watar froa within the slurry wall areas for the
purpose of lowering the interior water table to produce inward
and upward hydraulic gradients. The inward and upward hydraulic
gradients would  preclude the outward migration of cheaicals
present  with  the zone  contained by the slurry wall areas. The
saall quantities of groundwatar pumped froa within the slurry
walls would be treated using on-sita air stripper-based systems
or carbon adsorption,  which would be operated in accordance with
applicable air and watar quality requirements. The required
monitoring for this alternative would be the same scope as that

                                13

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required under the "No Further Action" (monitoring only)
alternative.

Flushing:

This alternative for reaediation of saturated aquifers within the
slurry wall areas involves the extraction of water from the
saturated soils, treatment of extracted groundwater by air
stripping, and reinjection of the treated water into saturated
soils within the slurry walls. Extracted groundwater would be
treated using air strippers or carbon adsorption prior to
reinjection through the injection well network.
10.0 APPLICABLE Q^ P^I-FVANT AND APPROPRIATE REQUIREMENTS f ARARs)


Under Section 121 (d) of CERCLA, as amended by SARA, the selected
remedy must achieve a level or standard of cleanup that assures
protection of human health and the environment. In addition,
CERCLA requires that remedial actions achieve a level. or standard
of cleanup that meets legally applicable or relevant and
appropriate requirements, standards, criteria or limitations
(ARARs).

ARARs associated with the site have been generally separated into
three categories: (1) ambient or chemical specific requirements
that set health or risk-based concentration limits or ranges for
particular chemicals; (2) performance, design, or action-specific
requirements that govern particular activities; and (3) location-
specific requirements. For this site the selection of ARARs is
dependant on the defined beneficial use of groundwater as a
source of drinking water.

Beneficial Use of Local Groundwater as a Source of Drinking Water

The regulatory framework associated with the cleanup of
groundwater and soil at the site is driven by the beneficial
(current or potential) use of local groundwater. As stated in 40
CFR 300 of the Federal Register on page 51433  (December 21,
1988), "The goal of EPA's Superfund approach is to return usable
ground waters to their beneficial uses within a timeframe that  is
reasonable*. Drinking water is considered to be the highest
beneficial use and affords the greatest level of protection and
cleanup.

As required- by the California Portor-Cologne Water Quality
Control Act, the Regional Water Quality Control Board - San
Francisco Bay Region defines the beneficial uses of various water
bodies in the greater San Francisco Bay Area. Water bodies and
their beneficial uses are presented in The San Francisco  Basin
Plan. This regional plan has been promulgated  and  is  an ARAR  for

                                14

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this sit*.  In the Basin Plan the Regional Board classifies the
shallow aquifers in the area of the MEW plume as a "potentially
suitable  for municipal or domestic water supply". In addition,
the Basin Plan states that the "use of waters in the vicinity
represent the best information on beneficial uses". Currently,
the C and Deep aquifers at the site are used as a municipal
drinking  water supply.


CHEMICAL-SPECIFIC ARAM

Chemical-specific ARARs for the MEW site are Federal and State of
California  drinking water standards. Each is relevant and
appropriate to set cleanup standards at the site. A list of
Federal and State drinking water standards are presented in Table
10-1.

Federal Drinking Water Standards

Potential drinking water standards at the site include Maximum
Contaminant Level Goals (MCLGs) and Maximum Contaminant Levels
(MCLs) :

Rs stated in CERCLA Section 121 (d)(1), MCLGs are mentioned as
potential cleanup standards when these levels "are relevant and
appropriate under the circumstances". After weighing all factors,
EPA has determined that they are not relevant and appropriate for
the site.

The relevant and appropriate standards to establish groundwater
cleanup levels at the site are the Federal Maxlmtim Contaminant
Levels  (MCLs), as presented under Safe Drinking Water Act. EPA
bases this  decision on the fact that MCLs are fully protective of
human health and, for carcinogens, fall within the established
acceptable  risk range of 10'4 to 10  .  MCLs  are ARARs  for
groundwater at the site and are also used to establish soil
cleanup levels.

State Drinking Water Standards

California  Drinking Water Standards establish enforceable  limits
for substances that may affect health or aesthetic qualities  of
water and apply to water delivered to customers. The state's
Primary Standards are based on federal National  Interim Primary
Drinking  Water Regulations. Currently, California has promulgated
MCLs for  cadmium, arsenic and lead, and some) of  the organics  of
concern.
                                15

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                            TABLE 10-1
              FEDERAL AND STATE GROUNDWATER STANDARDS
               MIDDLEFIELD/ELLIS/WHISMAN STUDY AREA
Cheaical
      Federal
Maximum Contaminant
   Levels (MCLs)
     (ag/liter)
  State
   MCLs
(mg/liter)
Oraaniea
  Chiorofora
  1,2-Diehlorobenzene
  1,1-Dichloroethane
  I,l-Diehloro«th«ne
  1,2-Dichloroethene
  Freon-113
  Phenol
  Tetrachloroethene
  1,1,1-Trichloroethane
  Trichloroethene
  Vinyl Chloride
Inorganics
  Antimony
  Cadmium
  Arsenic
  Lead
        0.100
        0.007
        0.200
        0.005
        0.002
        0.010
        0.050
        0.050
   0.006
   0.200
   0.005
   0.0005
   0.010
   0.050
   0.050

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 ACTIOW SP1CITXC AJtAft*

 Groundwater extraction and treatment involves pumping, treating,
 and discharging the treated groundwatar and/or rain j act ing it
 into the aquifer.  Soil remediation can include excavation and/or
 in-eitu treataent. with groundvatar treatment and in-aitu vapor
 extraction,  Volatile Organic Chemicals (VOCs) would be moved by
 •ir stripping and/or Granular Activated Carbon (GAC) adsorption.
 Air stripping requires consideration of ARARs tar VOC eaissions,
 GAC use requires consideration  of ARARs associated with carbon
 regeneration or disposal,  and discharge or reinjection Bust meet
 specific ARARs.

 Discharge to Surface Water

 Substantive  National Pollutant  Discharge Elimination Systea
 (NPDES)  permit requireaents would apply to treated effluent
 discharging  to surface waters.  These would primarily be effluent
 limitations  and monitoring requireaents. The RWQCB regulates
 NPDES discharges.  Ambient  Hater Quality Criteria are used by the
 State of California to set Water Quality Standards in the San
 Francisco Bay Regional Basin Plan. Standards in the Basin Plan
 are used by  the RWQCB to aet NPDES effluent discharge
 limitations.

 Section 402  of the Clean Water .Act, as amended in 1987, will
 result in the prohibition  of discharge of non-storm waters to the
 City of Mountain View storm sewer system by 1991.

 Reinfection  of Treated Effluent Into Aquifers

 If  treated groundwater is  reinjacted, regulations governing
 underground  injection may  apply. Specifically, the Federal Safe
 Drinking Water Act requires an  Underground Injection Control
 (UIC)  program.  In  California, the DIG program is administered by
 U.S.  EPA.  The UIC  program  prohibits treated effluent from being
 injected,  into or  above a  source of drinJcing water. Except when
 it  is pursuant to  a CZRCLA cleanup UIC regulations do not
 regulate the concentration of constituents, rather they regulate
 only the method and location of the injection. These. Federal
 requirements regarding injection may be "relevant: and
 appropriate* to the site.

 Federal  RCRA requirements  and the State's Toxic Injection Well
 Control  Act  of 1985 (Cal.  Health « Safety Code Section 25159.10
£& IfliLJ  might also be "relevant and appropriate" to the
 reinfection  of treated groundwater.
                                16

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 Dlgeharoa to Sanitary Sewers

 Discharge of treated  groundwater to the local sanitary fever
 systea requires  coapliance with the City's of Mountain View's
 Industrial Waste Ordinance and the Clean Water Act Pretreataent
 Standards. The City's Ordinance sets forth effluent quantity and
 discharge concentration limits, along with standards for
 •onitoring and reporting. Substantive requireaents are "legally
 applicable"  for  on-site discharges of the treated water. The
 Clean  Water  Act  allows aunicipalities to detemine pretreataent
 standards for discharges to Publicly Owned Treatment Works
 (POTWs),  within  its jurisdiction.

 Air Stripping «•  Air galasJen Standards

 Any new source that emits toxic chemicals to the atmosphere at
 levels determined by  the San Francisco Bay Area Air Quality
 Management District (BAAQMO) "to be appropriate for review" oust.
 have authorization to construct and operate. Although on-sita
 treatment facilities  are exeapted by CERCLA froa the
 administrative requireaents of the permit, emission liaits and
 monitoring requireaents imposed by the BAAQMO permit must be met.

 Carbon Adsorption

 Use of granular  activated carbon (GAC) for reaediation of VOCs
 can trigger  requireaents associated with regeneration or disposal
 of the spent carbon.  If the spent carbon is a listed waste or a
 characteristic waste  then it is regulated as a hazardous waste
 under  RCRA and California's hazardous waste control laws.
 Disposal  of  contaainants can trigger RCRA land disposal
 restrictions. For disposal, the spent carbon would need to be
 treated to aeet  Best  Deaonstrated Available Technology  (BOAT)
 treatment standards,  and RCRA off-site Subtitle C disposal
 restrictions would also apply.

Regeneration of  activated carbon, using a high-temperature
thermal process, is considered "recycling" under both Federal and
California hazardous  waste regulations. Transportation, storage,
and generation of hazardous waste for recycling aust comply with
requireaents in  RCRA  and California hazardous waste control
regulations.  Performance standards for hazardous waste
incinerators can also be requirements for on-site carbon
reactivation. On-site storage of contaminated carbon may trigger
substantive  requireaents under municipal or county hazardous
materials ordinances. If the spent carbon is a hazardous waste,
construction and monitoring requirements for storage facilities
may also apply.
                                17

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Excavation. Above—Ground Trea^pnent and Disposal of Soil

Excavated contaminated soils will require on-site treatment or
disposal off-site. On-site treatment by above-ground soil
aeration, will need to comply with the substantive provisions of
the BAAQMD and possibly RCRA land disposal restrictions.
Excavated soil classified as a hazardous waste can also trigger
RCRA, state and local requirements. EPA land disposal
restrictions may be applicable for off-site disposal. RCRA
Subtitle C may apply to disposal of soils on-site.

For the on-site treatment of soils, the BAAQMD regulates aeration
of soil containing over 50 ppb of organics. The BAAQMD sets rates
at which soil can be aerated depending upon the level of
chemicals. BAAQMD Regulation 8, Rule 40 on the treatment of soil,
assuming it is a hazardous waste, may also trigger RCRA land
disposal restrictions and BOAT treatment requirements.


LOCATION SPECIFIC ARARs

Fault Zone

The MEW sites are not located within 61 meters (200 feet) of a
fault. Therefore, the fault zone requirement of 40 CFR Part 264
is satisfied.

Floodplain

A hazardous waste treatment facility located in a 100-year
floodplain must be designed, constructed, operated, and
maintained to prevent washout of any hazardous waste by a 100-
year flood. The MEW site is not located in a floodplain,
therefore these requirements are neither applicable or relevant
and appropriate.


11.0 OTHER CRITERIA CONSIDERED


In establishing selected remedial alternatives, EPA considers
various procedures, criteria and resolutions. These "to be
considered" criteria (TBCs) do not raise to the level of ARARs,
but are relevant to the cleanup of the site. The  following
discussion presents selected criteria relevant to the selection
of remedial alternatives.
                                18

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 Criteria Establishing Local Groundwater as a Source of DrlniHn«
 Various  criteria were used to establish that th« shallow, c, and
 0«sp aquifers are a source of drinking vatsr. EPA's groundwater
 classification systaa was used. Using the "EPA Guidelines for
 Ground-Water Classification" as a guide, EPA determined that the
 A- and B-aquifers in the NEW area are classified as "potential
 drinking water sources*. Currently, the C-aquifer and Deep
 aquifers are used for drinking water and therefore would be
 classified as a current drinking water source. As stated in the
 ARARs section, the Regional Water Quality Control Board
 classified the shallow groundwater as "potentially suitable for
 municipal or domestic water supply". The RWQCB determined that
 this classification is consistent with the State Water Resource
 Control  Board's Resolution No. 88-63, which describes criteria
 for designating sources of drinking water.

 State Criteria for Groundwater Cleanup

 California has criteria for evaluating drinking water quality and
 groundwater  cleanup: advisory Drinking Water Action Levels, and
 advisory Applied Action Levels.

 Drinking Water Action Levels are health-based concentration
 limits set by DHS to limit public exposure to substances not yet
 regulated by promulgated standards. They are advisory standards
 that would apply at the tap for public water supplies, and do not
 rise to  the  level of ARARs. Nonetheless, they have been
 considered in developing cleanup standards for the MEW site.

Applied  Action Levels (AALs) were developed by DHS for use with
 the California Site Mitigation Decision Tree. AALs are guidelines
 that DHS uses to evaluate the risk a site poses to certain
 biologic receptors. They are neither enforceable, nor ARARs, but
have been considered in developing cleanup standards for the MEW
 site.

Groundwater  criteria, to be considered for determining cleanup
 levels,  are  presented in Table 11-1.

California Resolution 68-16

Resolution 68-16 is California's "Statement of Policy With
Respect  to Maintaining High Quality of Waters in California". EPA
regards  Resolution 68-16 as criteria to establish groundwater
cleanup  levels. The policy requires maintenance of existing water
quality  unless it is demonstrated that a change will benefit the
people of the state, will not unreasonably affect beneficial uses
of the water,  and will not result in water quality less than
prescribed by other state policies.

                                19

-------
                            TABLE 11-1
              GROUNDWATER CRITERIA TO BE CONSIDERED
               MIDOLEFIELD/ELLIS/WHISMAN STUDY AREA
Cheaical
    State
Drinking Wat«r
Action Levels
  (•g/liter)
    State
   Applied
Action Levels*
  (•gyiitar)
Oroanies
  Chloroform
  1,2-Dichlorobenzene
  1,1-Diehloroethane
  1,l-Dichloro«th«n«
  1,2-Dichloro«th«n«
  Freon-113
  Phenol
  Tetrachloro«then«
  1,1,l-Trichloro«than«
  Trichloro«th«na
  Vinyl Chloride
Inorganics
  Antimony
  Cadmiua
  Arsenic
  Lead
    0.020
    0.130
    0.020

    0.016
   18.000

    0.004
     0.006
a/   Applied Action Level for water for huaan receptors.

-------
A beneficial use of the groundvater in the shallow and deep
aquifer systea is drinking water. Establishing a cleanup level
which maintains this beneficial use should attain the
requirements of Resolution 68-16.

Remediation Levels for Soils

A standard for the remediation of contaminated soils was reached
during  the Feasibility study by using a simple percolation-
transport model with the concepts presented in California's Site
Mitigation Decision Tree. The model was used to determine
concentrations in soil based upon transport downward into
groundwater. Based upon the analysis from the model, a soil
remediation goal of 100 times the groundwater remediation level
is appropriate to set cleanup standards in soil.

Health  Advisories

EPA considers that for a remedial action of a drinking water
source  to be protective, it'should have a cumulative risk that
falls within a range of 10"* to 10   individual  lifetime excess
cancer  risk. To evaluate the risk to public health posed by
recommended cleanup goals, health advisories were used to
establish cumulative risk. Lifetime average daily doses (LAOO)
were calculated by multiplying a concentration by 2 liters per
day and dividing by 70 kilograms. Cancer risk for a constituent
of a given concentration was determined by multiplying the LADD
by its  Cancer Potency Factor (CPF). Ratios of contaminants in
aquifers of the site were then calculated in relation to TCE. A
summation of risk for carcinogens in each aquifer were calculated
for a given concentration of TCE. For a 5 ppb  (MCL) .cleanup goal
for TCE in the A-, B1-, and B2- aquifers the cumulative estimated
carcinogenic risk falls within a range of 1.3(10)"5 to  7.4(10)  .
In the  C- and Deep aquifers the cleanup goal of 0.8 ppb
corresponds to a cumulative estimated carcinogenic risk of
1.0(10)"4. Supporting calculations are presented in the
Feasibility Study.

Cleanup goals in the shallow aquifers, above the B/C aquitard,
are set at 5 ppb for TCE. Cleanup goals in the C and Deep
aquifers,  below the B/C aquitard, are set at 0.8 ppb for TCE.
Assuming the ratios of carcinogen remain relatively constant,
attainment of these goals will result in achieving EPA's
acceptable risk range of 10*4 to  10   upon completion of the
remedial action.

Air Stripping Control Policies

Any existing and new source(s) that emit toxic chemicals will
have to comply with any EPA, BAAQMD, or Air Resources  Board
policies on control of air emissions from air-strippers.

                                20

-------
 12.0 SUMMARY OF ALTERNATIVES ANALYST^


 This section presents  an analyses of the alternatives, evaluated
 in the detailed analysis of reaedial alternatives, with respect
 EPA's evaluation criteria. Design eleaents of the alternatives
 are presented in Section 9.0. Table 12-1 provides a summary of
 the advantages and disadvantages of each alternative's
 performance  and cost.

 State and  community  acceptance are discussed below:

 State Acceptance

 The State  (of California) generally , supports EPA's proposed
 cleanup plan.  The state consented, however, that the cleanup
 goals for  soils and  groundwater inside the boundary of the
 existing slurry walls  should be 0.5 ppa TCZ for soil and 5 ppb
 TCE for the  groundwater; the saae goals as for outside of the
 slurry walls.

 In the Responsiveness  Sunaary, EPA stated that the slurry walls
 in conjunction with  pumping and monitoring will be protective of
 the public health and  the environment, with the 1 ppa TCE cleanup
 goal for soils bounded by the slurry walls. This monitoring and
 pumping strategy will  liait the amount of contaaination that can
 leach into the shallow aquifers, outside of the slurry walls. EPA
 did respond  to the State's request of a 5 ppb TCE cleanup goal
 for all shallow aquifers, by establishing the 5 ppb TCE cleanup
 goal for the aquifers  inside of the slurry walls.

           Acceptance
The coaaunity agrees with EPA's proposed reaedial alternatives,
although there is concern with the length of time estiaated to
achieve the shallow aquifar cleanup goals. The use of the "hazard
index" was urged to establish cleanup goals instead of MCLs. EPA
explained in the Responsiveness Summary that the hazard index was
not applicable to the MEW area.

In addition, reuse of the extracted groundwater was recoaaended
by the coaaunity. As stated in the Responsiveness Summary, reuse
of extracted groundwater will be evaluated and is a component of
the ROD.

The Responsiveness Summary (attached) addresses these concerns
and others in aore detail.
                                21


-------
                                                                     Table 12-1
                                                      Criteria for  the Evaluation ol Remedial Alternatlvi
                                                                     (conlInued)
AIJIRNAiltt

lONt 21

NO fURlHfR AC 11 ON
IN SHU SOIL AHU1ION
 WIIH CARtON
AOSORPIION MO
REfifNIRAIION)
MAINUM
UftMtO KIORAUIIC
CRADIINIS  IUIIH
tRfAIMNf  Of
IIIRACICO  UAIfR)
HUSHING  (UHH
IRf AIMNI Of
IIIRACltO NAUR)
SHORMtm
HftCJlttNISj
NO IfffCl IN
SHORMCRM
CffCCtlVC IN
SHDRMCRM
CffCCIIVC IM
SHDRI-HRN
NOI CffCCllVC
IN SHORMfM
IONG HUH
iffCCIIVfNISS
AND MttUNIMCC
AllOVS CONI'O
NICRA1ION
HRMANfNI
SOIUIION
KRNANCNI
SOIUIION OUI
RCQUIRCS
COMIINUCO
riMflNG
rCRMANINI
SOIUIION If
NO CNfNICAl
HIGRAIION
RfOUCIS IOIICI1V.
HDBIilll. fOJUMC
NO ACIIVI RIOUC
1ION IN IOIICII*.
HORItllf OR VOIUNC
RIOUCIS 101 1C HI.
HOIIlllf AND
VOIUHC
REOUCIS tOIICIIf,
NORIlltf AND
VOIUNC
RIOUCIS IQllCllf,
NDBIllIf AND
VOIUHC If NO
CHIHICAI NICRAIION
INPLININIARiiilf
NO ICCHNICAl
IINHAIIONS
NO IICNNICAl
IINHAIIONS
NO IfCMNICAl
tlNHAIIONS
NOI fCASIHC OUC
10 comii site
SIRAIIGRAraf
CONPIIANCC
HUH ARARi
DOCS NOI
HECI All
ARARs
comics
WITH ARARl
comics
HUH ARARi
comics
NUN ARARl
lONC-ICRN
fHOICCIION Of
HUNAN HIAIIH AND
rmicciioN
novioco if
UMIIORIIK omi
noviocs
htOUCllON
rROVIHS
NOUCIION;
NCCOS
INSIIIUIIONAl
CONIUOt
PtOIICIlON
IINIICO If
CHCNICAl
MlfiRAIIW
Aoori
CAMIAl
COSIS
JOM'SI
II
I.Bil
to
t.MI
I
1.011
ANNUM
OIN
COSIS
10831
IM
l.tft
io
Mf!
S9S
I.4S9
WSINI
NORIH
(ro«Mlt4.
OM'sl
I.MO
4.100
to
9.900
1.000
11,000

-------
 •n
 t"
                                              Tabla 12-1

                              Criteria for lha Evaluation of RamadlaJ Aliarnallvat
 HIIRNAIIVC
 IONC tA

 n IURIHCR MI ION
 SHORMCM
 tfff.CIIVf.HCSS
MO Iff1C! II
SHOftl HIM
tone- urn
irrfcuvfNfss
AND MMUHIMCt
MIOW
CONIINUCO
HIGRA1ION
                MODUS loncnv.
                MOBIUH. VOLUMC
               NO ACIIVf IfOUCIION
               IN 10IIU1V.
               NOtlllll M VOLUME,
 IMKIMIMIARlim
NO 1ICHNICAL
UNIIA1IONS
COMF1lANCf
NIlHAIMl
001$ NOI
MilI All
AMIS
                                                                                                          lONG-HM
                                                                                                          PROIKIION Of
                                                                                                          HUMAN MlALIM AND
                                                                                                          IHt fMHNOMMfNI
                                                                                                          PftOUCIION
                                                                                                          HMVIDCO If
                                                                                                          NONIIMIN6 ONll
       ANNUAl  rtCSINI
CATIIAl • I N  WMIH
COSIS   COSIS  Irwmdc
IBOO'Si IQM'H  OQQ'tl
                 N/A
 9N-SIIU SOIL AflAIION
  UBtN CAUON
 U3SMP1ION AND
 llfifltflUtlON)
ffffCtlVI IN
SHORI-IINN
ffKNAWNI
SOIUIION
               MOUCfS IOIICIIV.
               MOIILIIV ANO
               VOlUMC
NO IfCHNICAl
IINIIAlIONS
coxnifs
NIIH AftAlt
                                                                                                          MOVIMS
                                                                                                          MWHCKON
 101     IM
 MINIAIN INUARO ANO
JPUAftO HIWUUHIC
 •RAOICN1S (HUM
 IRCAINCNI Of
 (IIRACHO NAUR)
                       tfflClItt IN
                       SHORMIM
                  HNNANINI
                  SOIUIION Ml
                  MOUIMS
                  CONIINUCO
                  NMTING
                •[OUCiS lOIICIIt.
                HMIllll ANO
                VOlUMC
                                  NO HCHNICAL
                                  UNIIA1IONS
                   CONPLICS
                   NIIH AMIl
            NOVIKS
            milCIIONi
            NCCOS
            INS1IIUIIONAI
            CONIMN.S
  •     40S    4,100
 FLUSHING (NUN
 llfATHCMI Of
 IIIIACIIO NAUR)
NOI CffCCIIVI
IN SHMMCIM
NNNMIfNI
SOLUIION If
NO CHtMICAl
HIUAIION
               MOUCfS SOIICIIt,
               MOIILIIV ANO VOLUtf
               If NO CHINICAL
               MUUIION
NOI fCASIILI OUf
10 CONPLCI SI1C
SIMIICIAMf
CONPLICS
NIIH ARARl
                                                                                                          NOICCIION
                                                                                                          IINIIf0 IV
                                                                                                          CHEMICAL
                                                                                                          HIUAIION
       Ml     I.SOO
 MANUAL IICAVAIION
 IIIN AMIINI
 IfHPCMIUOr AfMIION
 NIIH CAUON
 lOSMMION ANO
HfUNIMIION)
CffCCIIVf. Ml
INCRf ASCO IIMSURC
DURING IICAVAIION
                                           KMANCNI
                                           UIION
                MOUCfS IOIICIIV.
                MMIUIV ANO
                VOlUMC
                                  OlfflCULI 10
                                  CONIROl AIR
                                  IMNISSIONS
                   COMPLICS
                   NIIH ARARt
            rmviocs
            MOIfCllON

-------
                                                                     Tabla 12-1


                                                  Criteria for lha Evaluation oi Hamadlal Allarnatlvat
                                                                      (continued)
AllHBUlItt

10NC 4

NO flMtHCI ACIIM
HlOJUItlC R1NIOIAIION
II CftOUMO UAltl
I1IIAC1ION AND
IMAINCNI
SHMMIMI
NO iifici IN
SHOftl-HIN
[fffCHVr. IN
SHOAI-HM
ION6-1IRN
imCMVfNfSS
AUOMS
CONIINUfO
NIGRAIION
fCMANINI
SOiUIION
itoucis ioi ic m,
NOBItlfl. KOlUHf
NO ACIIVf MDUCIION
IN I01ICIIV.
NlWIlllf M KMUHC
NIOUCIS I01ICIII.
HOB U II* AND
•
NO IICHNICAl
I IHI1 AIIOHS
NO IICHNICAl
UNIIAHONS.
•!• in ^^^^ifn
DOCS NOI
MI! Alt
ARAIs
COMF1 US
MIIH ARAMs
ION6-1INN
MOIICIION Of
HUHAN HfAllH MB
IHt IMilMNNINi
KOlfCIION
raovioiB •«
NONIIMlNfi 0*1
fROVIMS
                                                                                                                             AODI't ANNUM  NESCNI
                                                                                                                             CANIAl 0 I N   IMIN
                                                                                                                             COSIS  COSIS   (r«Mndt4,
                                                                                                                             1000*SI  ""	  	"
                                                                                                                                 It
                                                                                                                                131
III    t.OOO
«•§
                                                         VOIUHC
1.100
 io
4.200
(!)
         NOI APrtlCAMI

-------
Table 12-1
Criteria lor the Evaluation ol Remedial Alternatives
|CMtlMI«4|
AIltMUIIM
10* )
': NO lUtUHtl ACIION
NlDMIftlC CONINOl II
IIIIACIION
AMD IftlAIMNI
NIOBAUUC MNfOIAIION
II UOUNO NAItl
If IIACIJON MB
IIIAININI
ttlllCM iMNNJCAUf
UUUIIUS
SHOII -KM
ItllCIIIINIli
NO IIIICI M
SHOII KM
IIIICIIM IN
SHMMIIN
IfflCtll! IN
SHMMIAN
IIIICIIIE. Mil
roiiniM lot
iirosutf DMIINJ
ION6-IIM
HriciiviMss
AMD MMANIMff

AllOWS
CONIINUIO
riMANtNl
SOiUIIM INI
icquiics
CONIINUfO
NMPIN8
rCIVMNlNI
SOtUIION
NOI A
eWJffJI
NIION
MOUCIS 1011(111.
HMItilr. IQllttf
NO ACIIII MOUCIION
IN lOllCllff.
NOOUIIf M MNUNI
UOUCIS lOHCIIt.
HOIlillt AND
I01UMI
MDUCIS IOIICIIV,
NOOILIIV AND
fOLUHt
DOES NOT |
MEET CMTCRIA
iMMIMINIAaifUlf
NO IICNNICM
UNIIAIIONS
NO IICNNICM
tlNHAIIONS
NO IICHNICM
UNIIAIIONS
IINIASIIU PUC
10 IICHNICM
IMIMIIONS
COMniANCE
NUN ARAAi

MIS NOI
Mil Ml
AMIl
com iis
NUN ARAIi
com iis
Ml IN ARAii
DNS NOI
NEH Ml
AIMS
IONC urn Mori AHUM
MOIICIION or CACIIM 0 1 N
NUNAN MM IN AND COSIS COSIS
IK IHIIiMtm HfiUl mf^ii
NOIICIION SIO IM
rnotioto ii
MMIIMINB OJtl
MUM f.fii i.in
NOHCIIONS HIM
CONIMIS
NOVIMS I.Sfl f.SOJ
NOUCIIOM ' *
rAIIIAl 1S.4II I
raoiiciioNi Mits
INSIIINIIMM
MISINI
NORIN
MM'il
W9^m ^ •
MM
If.SM
"if
II.MO .
JS.4M
                   CONSItUCIION
CONINOIS
Note: Section 121(b) ol CERCLA stales a pralerence for treatment which permanenlly and
slgnNfcanlly reduces the volume. loxteHy or moblldy ol (he conlamlnanls. The use ol vertical
Impermeable barriers (I.e., slurry walls) by themselves Is oomalrtment and source control, and
does nol constitute treatment. Only with the addition ol groundwaler extraction and treatment
does this alternative meet statutory criteria. While this evaluation differs somewhat from the
evaluation found In (he fS. II does nol ailed EPA's remedy selection.

-------
                                                Criteria for  the Evaluation ol Ramadlal AllarnallvM
 AMiRNAIIVI

 lout  I

 NO rURIHtl AC II ON
 SHORMIM
 imcntmm
Ml IfffCf IH
SHORMIRN
lONC-IERM
trrcciiviNCSs    RIOUCIS lonciiv,
AND MRMAMtNM   HQRIllll. VQtUMt
MUMS
CONIIMUfO
MICRAHON
 NO ACIIVt RfOUC-
 IION IN IOI1CIIV.
 NOIIUIf M VMUNC
 NO IICHNICAI
 UNIIAIIONS
                                                      CONPUANCt
                                                      HUH ARARt
                                                     DOCS NOI
                                                     NCU All
                                                     ARARs
                                                  lONG-HRM
                                                  moitcuoN or
                                                  HUNAN HIAIIH MO
                                                  IHEJMMlAQNNiNI
 MOIKflON
 NOVIMO IV
 NONIIMIN6 OMV
                                                 MVI't  ANNUM.
                                                 CANIAl 0 I N
                                                 COSIS   COS!
                                                 IQOQ'SI IQOO'SI  OOO'il
                                                                                                                                         MCSINI
                                                                                                                                         WMIH
 IN SHU SOU  AfMIION
 IUIIH CAMON
 MSOiFIION AND
 •CCCNfMIIONI
imciivc IN
SHMMIIIN
KMIANtNl
SMUIION
 UOUCIS IOIICIIV.
 NMIlllV AND
 VOiUNC
NO UCWICAI
IINIIAIIONS
                                                     COW |£$
                                                     HUH ARMS
MOVIOfS
MOIICIION
 !.!•'
  lo
 1,1 JJ
llf    I.
 10    io
Ml    5,000
        IICAVAIION
HUH ANIItNl
KNKRAIUiC AtlAIION
(HUH CAJUMM
AOSORfllON AND
R(fiCNIMtlON)
imcuvi. tut
roiiNMAi rot
INCRCASCO
firOSURC OURIH6
IICAVAIION
HRNANCNI Mil
HOI A CONKIIf
SOIUIION
RfOUCIS IOIICIIV,
HOBILIIV AND
VOlUNf
oirncmi 10
CONIIOL All
INISSIONS *J*P Alt
INPACICO SOIll
NOI •INfOlAlli
                                                     OOfSNOI
                                                     NCU ARARs
                                                     fOR UNII-
                                                     CAVAUO
                                                     SOUS
CHINICAIS Iff!
IN SOUS COWO
HICRAIC 10
SHAltOH
AQUIflRS
      i.ioo
fARIIAl fICAVAIION
HUH ANRltNl
IINMRAIURE AIRAIION
AM IN-SIIU SOU
AfRAHON
IHMH CARBON
AOSORfllON AND
RffiCNfAAIION)
irflCIIVI. Ml
INCREASfS
IIPOSURt OURINS
IICAVAIION
MRNANiHI
SOIUIION
RfOUCIS IOIICIIV,
HDBIIIIV AND
VUUNI
01 ff ICWI 10
CONIROl AIR
INISSIONS
                                                     COWlltS
                                                     HUH ARARi
MOVIOfS
NOIICHM
i.m
 to
        tio
         to
i.m    MI   R.MO
      i.soo
       io

-------
13.0 THB SELECTED


The selected remedies for soils are: 1) in-situ vapor extraction
with treatment by vapor phase granular activated carbon ((SAC),
and 2) excavation and treatment by aeration to meet federal,
state, and local air standards. Most of the vapor attraction will
be performed on soils inside of the existing Fairchild and
Raytheon slurry vails, where the highest concentrations of soil
contamination are found. The vapor extraction is estimated to be
in operation froa 1 to 6 years. The excavation and treatment of
contaainated soils aay invoice RCRA Landban requirements which
would also require treatment to aeet BOAT standards. Intel has
previously excavated and aerated their contaainated soil under
RWQCB orders. These selected remedial alternatives will likely be
used at other potential sources in the HEW area. EPA expects soil
remediation to be implemented by the PRPs.

The soil cleanup goals for the MEW area are: 0.5 parts per
million (ppm) TCE for all soils outside of the slurry walls and 1
ppm TCE for soils inside the slurry vails. The cleanup goal for
soils outside of the slurry walls is based upon the amount of
contamination that can remain in the soil, leach into the
groundvater and still achieve the cleanup goal for the shallow
aquifers. The rationale for the use of a higher cleanup goal for
soils bounded by the slurry, walls is presented in the following
discussion* Although the aquifers bounded by the slurry walls are
considered potential drinking water sources, this groundvater is
effectively isolated when local hydraulic control is implemented
by pumping inside the confines of the slurry walls. This
isolation of contaminated groundwatar and soil bounded by the
slurry walls provides an additional level of protection of the
significantly larger drinking water source outside of the slurry
walls. This additional level of protection through the use of a
slurry vail system (slurry wall and hydraulic control) allows for
a higher soil cleanup goal for soils confined by the slurry
walls. But, the use of the 1 ppm TCE cleanup level for these
soils is dependent upon the continued operation of a pumping
systea which maintains local hydraulic control of groundvater
inside the slurry vails. If local hydraulic control by pumping
vas to cease, then the lover soil cleanup goal of 0.5 ppm TCE
vould need to be attained. In summary, the soil cleanup goal is
higher inside of the slurry vails because of the extra degree of
protectiveness provided by the slurry vails in conjunction with
the maintenance of inward and upward gradients into the area
confined by the slurry vails, with a systea of hydraulic control
by pumping of groundvater. To ensure that the slurry vail system
is effectively vorking, regular monitoring vill be performed  of
local groundvater quality and water elevations. During the


                                22

-------
 duration of the remedy, there will be an evaluation of the remedy
 and cleanup goals at least every five years.

 The selected groundvater reaedy is hydraulic reaediation by
 groundvater extraction and treataent. The groundvater cleanup
 goals by puaping and treataent are: 5 ppb TCE for the shallow
 aquifers (including the aquifers inside the slurry vails) and 0.8
 ppb TCE  for the C and Deep aquifers. The cleanup goal is acre
 stringent for the C and Deep aquifers, because they are currently
 used as  a supply for aunicipal drinking vater and will be
 technically easier to reaediate than the shallow aquifers. The
 0.8 ppb  cleanup goal corresponds to a 10** cumulative  (human)
 cancer risJc.

 Although the shallow aquifers are not currently used for drinking
 vater, they are a potential source for drinking vater and
 therefore a 5 ppb TCE cleanup goal has been established which
 corresponds to  between a 10  and 10"5 excess cancer risk, which
 is  within EPA's acceptable risk range. Cancer risks have been
 screened for all aquifers and the cheaical ratio of TCE to other
 chemicals found at the site is such that achieving the cleanup
 goal for TCE will result in cleanup of the other site chemicals
 to  at least their respective NCLs.

 The estimated time to reach the deep aquifer cleanup goal is
 between  2 to 45 years. The tiae to reach the shallow aquifer
 cleanup  goal  may be considerably longer, possibly froa 46 years
 or  into  the indefinite future, because of the physical and
 cheaical nature of the shallow aquifers. They are low yielding
 and contain soils with a high clay content which attract and
 retain the  site chemicals. During the duration of the remedial
 effort,  both shallow and deep aquifers will be regularly
 monitored for water quality and groundvater elevations.

 The extracted groundwatar will be treated largely by air
 strippers,  although some companies (e.g., Intel) may use their
 existing liquid phase GAC units. The three currently operating
 air strippers have been permitted by the Bay Area Air Quality
 Management  District and are not using emissions controls. The air
 stripper stacks have been designed to meet risk levels of <10
 excess cancers.  He anticipate that with the additional air
 strippers to  be installed and the increased flow rates during
 full scale  reaediation, emissions controls will likely be needed
 to aeet  more stringent air district standards. The  emissions
 controls vill consist of GAC vapor phase carbon units.

The extracted groundvater vill be reused to the maximum  extent
 feasible, with  100% reuse as a goal. The remaining extracted
groundvater vill be discharged under NPDES requirements  to
Stevens  Creek.  Work has already commenced on various  vater  reuse
options,  which  vill be presented and  implemented during  the RD/RA
phase.

                                23

-------
The remedy also includes the identification and sealing of any
conduits or potential conduits, using the decision process
outlined in the FS. Several identified abandoned agriculture
wells have allowed contamination to migrate from the shallow
aquifers to the deep aquifers. These wells have subsequently been
sealed. Additional wells have been identified for sealing and
other wells may also be identified during RD/RA phase which will
require sealing.

To evaluate the effectiveness of remedial actions and to
determine when cleanup goals are attained, regular monitoring of
chemical concentrations and water elevations is required at
selected wells across the site. For soil cleanup, EPA will need
to concur on a method to determine when the required cleanup
goals have been achieved.

The estimated costs of the selected remedies are provided in
Table 12-1 and include the use of emissions controls, well
sealing, and monitoring. The total cost of the remedies, in
present worth dollars, is estimated to be between $49M to $5€M.


14.0 STATUTORY DETERMINATIONS


The selected remedies are protective of human health and the
environment — as required by Section 121 of CERCLA — in that
contamination in groundwater is treated to at least MCLs and
falls within EPA's acceptable risk range of 10*4  to 10*7.  In
addition, the remedy at least attains the requirements of all
ARARs, including Federal and State MCLs.

Furthermore, as shown on Table 12-1, the groundwater remedy -
pumping, and treating with air strippers and the soil remedy -
vapor extraction, are oost effective technologies. Soil
excavation with aeration has also been shown to be cost effective
when it was used at the Intel facility, and may also be used at
other facilities.

The selected remedies will permanently and significantly reduce
the toxicity, mobility, and volume of hazardous  substances with
respect to their presence in soils and groundwater. The use of
vapor extraction for soils is an innovative treatment technology
for removing VOCs.

Contamination is controlled and removed from the groundwater,
thereby reducing the potential threat to the nearby  public water
supply wells and also restoring the aquifers to  meet drinking
water standards. The slurry walls in conjunction with pumping  and
treatment reduces toxicity, volume and mobility  of contamination
to migrate from major source areas. The sealing  of conduit wells

                                24

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will reduce the likelihood of vertical migration of
contamination.

Emissions from soil vapor extraction will be controlled by vapor
phase GAC. Emissions from air stripping towers will meet local
air district requirements, which are anticipated to be a 10"6
risk level, and therefore will likely require vapor phase GAC.
The regeneration of spent carbon from the GAC emission controls
will meet all Federal, State, and local requirements.
                                25

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SUXXARY

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        RESPONSIVENESS SUMMARY FOR THE FAIRCHILD. INTEL. AMD RAYTHEON SITES
                   MIDDLEFIELD-ELLIS-WHISMAN (M-E-tf)  STUDY AREA
                            Mountain View, California
 I.  COMMUMITY RELATIONS HISTORY

    EPA haa carried on an active coaaunity relations prograa at tha Middlafield-
 Ellis-Whisaan (MEV) Study Area.

    In early  1986, EPA, in conjunction with Santa Clara County, initiated monthly
 aaetings  for all agencies involved in hazardous waata investigation and cleanup
 to  review and coordinate activities.  Representativea of local, state and federal
 agencies, elected officials, business and induatry and public interest groups
 attend the aeetings.   Tha aeetings continue on-a quarterly basis.

    In tha spring of 1986, new eontaaination was found in Mountain View's deep
 aquifer   This discovery aarkad tha first time eontaaination had been detected at
 those depths in that  part of Santa Clara County.  In response to coaaunity
 concerns  and questions about the safety of tha drinking water supply, EPA
 prepared  a fact sheet describing the situation and distributed it to the site
 Bailing list.

    In May 1986, EPA worked with Fairchild Semiconductor Corp. to prepared a 4-
 page insert  for Mountain View's The Vlaw to explain Fairehild's proposal to
 construct three slurry walls in order to confine their site's contaminated soils
 and to pump  and treat water confined by the walls.

    In February 1987,  Raytheon and EPA worked together to prepare another insert
 for The View that described Raytheon's proposed slurry wall to contain
 eontaaination around  their site.

    Zn June 1987, EPA  worked with Raytheon, Intel and Fairchild to produce an
 insert for The View describing the draft Reaedial Investigation (RI) report.

    In November 1988,  EPA released a Feasibility Study (FS) on the Middlefield-
 Ellis-Vhisaan Study Are to the public.  The report described and evaluated
 various clean-up alternatives based on data and support documents available at
 the time.  EPA's preferred alternatives were:  vapor extraction and  treatment for
 soils, pumping and treating for shallow and deep aquifers; and vapor extraction,
 groundwater  control and treatment for the slurry wall systeas.

    In fulfillment of  coaaunity participation requirements, EPA held  a public
 comment period from Noveaber 21. 1988, through January 23, 1989; briefings  of
 local officials and coaaunity members; and a community meeting.  EPA also
prepared a Propoaad Plan face sheet which outlined tha range of cleanup
 alternatives,  cleanup goals, and EPA's preferred alternative for distribution  to
 tha site mailing list.  Prior to tha fact sheet. EPA also released a press
 advisory announcing the range of alternatives and EPA's preferred alternative.

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   The community meeting was held December 14, 1988, to present clean-up
alternatives, to answer questions and to take comments on the FS.  Comments
centered on the length of the cleanup period and on who would do the cleanup.

   Written comments on EPA's Proposed Plan focussed on the following issues:
cleanup levels for soil and groundwater, length of public comment period,
variations in the text of the FS report, and length of cleanup time.  Responses
to public contents are addressed in the attached response summary.  Most of the
comments were submitted by Potentially Responsible Parties.


II.  SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES

        1 Comments
1.  CffBaftnt:  Several comments concerned the number and location of recovery
wells to be placed in the MEW area.

EPA Response:  The Feasibility Study (FS) and Proposed Plan are not design
documents.  The exact number and location of recovery wells will be determined
during the remedial design phase.

2.  Comment:  NASA-Ames Research Center.had several concerns:  1.  how the
proposed treatment system would handle groundwater contaminated with fuel, 2.
how other cleanup actions may be influenced by the proposed recovery wells, 3.  .
the effects that the proposed hydraulic remediation may have on existing
contamination at NASA-Ames and the adjacent Moffett Naval Air Station.

EPA Response: The above concerns will be addressed during the Remedial design and
Remedial Action (RD/RA) phases.  Obviously, a large degree of cooperation and
coordination will be required by the affected parties during RD/RA, to ensure a.
successful remediation program.

3.  Comment:  "The FS proposes to remediate soils using in situ soil aeration.
Air inlet wells may also be installed to increase the efficiency of the soil
aeration system. It is suggested that if air inlet wells are to be installed chey
should be used to control the extent of an in situ negative soil air pressure
field, not to increase soil air flow through the contaminated soils. If they are
installed solely for the purpose of increasing airflow across the contaminated
soil particles, their use is questionable."

EPA Response:  VOC's have a marked tendency to partition into the soil
atmosphere. The rate of desorption into pore space is principally a function of
chemical diffusion in response to a concentration gradient. Sweeping of clean air
through a soil matrix increases the concentration gradient and therefore
increases partitioning and the overall efficiency of the in situ soil aeration
system.  The result of creating a negative air pressure field, with an in  situ air
stripping system, does have a minor effect on soil-air partitioning, but  the
field tends to be localized around the extraction well(s) and the overall effect
is negligible. The key to an efficient in situ vapor extraction system is
increasing the airflow across contaminated soil particles and not simply  to

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 eoncrol the negative  soil  air pressure field. The use of air inlec wells will be
 analyzed further during the  RD/RA phases of this project.
 1.   C«i«iM«g?   Several  commenters who are Potentially Responsible Partiee (PRPs)
 stated that the  comment period was too short to adequately review the FS end
 Remedial  Investigation (RI)  report.  Requests were made to extend the comment
 period.

 gPA  Response:  The National  Contingency Plan (NCP) requires that the RI, FS and
 Proposed  Plan  be provided to the public for review and comment for a period of at
 least  21  calendar days.   The new proposed NCP requires a utttiumi 30 calendar day
 public comment period.

 EPA  has exceeded both  of* these requirements by providing a 64 calendar day public
 comment period on the  RI.  FS and Proposed Plan.  The comment period was extended
 (at  the December 14, 1988 public hearing) to January 23, 1989, from the original
 January 9,  1989  deadline.

 2.   Commene:   Several  PRPs.stated that the RI report and FS were not readily
 available for  review.

 EPA  Response:  A draft RI report has been available to the general public at EPA
 since  July  1987  and also  in  the City of Mountain View public library since
 August, 1987.  The final  RI  report has been available at these respective
 locations since  July,  1988.   Furthermore, EPA in its general notice letters
 issued in August and September, 1988, notified the commenters and others of che
 availability of  an administrative record that contained supporting documentation
 for  the MEW study area.   The FS was made available to the public in the EPA and
 Mountain  View  libraries at the beginning of the comment period November 21, 1988.
 In addition, copies of the FS were also available for purchase from Canonle
 Engineers,  the preparers  of  the FS.

 3.   Comment;:   Several  PRPs claimed that there were "inconsistences" .between FS
 reports on  reserve at  the Mountain View Public Library, the FS report at the EPA
 library,  and copies provided by Canonie Engineers.

 EPA  Response;  EPA acknowledges these concerns, however, we believe any
 differences to be minor in nature and would not affect the scope of the FS
 report.   Copies  of the  FS report were reedily available for review at the EPA
 library during the entire public comment period.
4.  ^flTifflTlSr  One comaenter wrote that EPA announcements regarding the review and
comment period and public meetings needed to be more widely distributed.

EPA Response;  Announcements regarding the MEW public  comment period and the
public meeting were published  in "The View", "The Los  Altos Town Crier",  "The
Times Tribune", and the  "San Jose Mercury News" (Peninsula Extra Edition).   In
addition. EPA's Proposed Plan,  which also announced the public comment period and
public meeting, was sent to EPA's MEW mailing list  that consists of over 100

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 IUUMS.   We will also be periodically updating our Bailing  list and will contact
 local officials and community groups for assistance  in updating  that list.
 5.   Caiaffflt;.  A number of commenters  claimed that  th«y were not PRPs.  Some of
 these commentars also citad references  to  other PRPs or inferred sources, in the
 RI  report.

 EPA Response:   The determination of who is or who  is not a PR? is not relevant co
 the selection  of a reoedy.   Furthermore, in  its August 8, 1988 approval of the RI
 report,  'EPA neither agrees nor disagrees  with the assumptions or assertions
 regarding 'inferred sources or other  PRPs' as presented in the RI report."  EPA
 makes its own  determination of liability independent of the RI/FS process.
 6.  CTBTCflnt ;   Several commenters  who  are PRPs wanted to know hov other PRPs will
 be dealt with, hov cleanup costs  will be allocated, and who  is responsible for
 cleanup.

 EPA Response:  EPA is currently evaluating PRPs  to determine who will receive
 Special Notice letters for Remedial Design and Remedial Action (RJD/RA) to 17
 parties.  The  responsibility for  cleanup lies with whomever  EPA  determines to be
 a PRP.  The allocation of cleanup costs are usually decided  among  the PRPs.
 7.  Comment:   Two  PRPs wrote that remediation of the C and deep  aquifers should
 be addressed as a  separate operable unit.  The reasons given were  that the C and
 deep aquifer contamination is limited to localized areas, the contamination was
 not caused by  the  respective commenters, and, operation and  maintenance cost will
 be increased.

 EPA Response:-  EPA does not designate operable units to separate cost allocations
 among various  PRPs.   The  commenters have offered no compelling technical or
 environmental  reasons why there should be  a separate operable unit for the C and
 deep aquifer remediation.   EPA believes that including the deep  aquifers in Che
 comprehensive  remedial plan for the entire MEW Study Area is the most efficient
 use of agency  and  PRP resources.   Furthermore, 40 CFR Section 300.6 simply
 defines an operable unit,  "as a discrete part of the entire  response action that
 decreases a release,  threat of release, or pathway of exposure.*
The Following Selected Co"""ents  Concerning EPA'a  Process Were  Submitted bv Stltec

1.  Comment:  Page 1.  Siltec  claims  that a copy  of the final  RI was not made
available to them until January  13, 1989.   Siltac has  not  had  a reasonable
opportunity to review or comment on all  of RI's contents.

EPA Response;  A draft RI has  been in the Mountain View public library since July
1987.  The final RI was delivered in  July, 1988,  to EPA and the Mountain View
Public Library.  Siltec has had  ample time to review the RI since EPA stated at
the October 1988 "kickoff meeting attended by Siltec  representatives, that the
final RI was available for review in  the EPA and  Mountain  View libraries.

Siltac seems to be arguing that  EPA should have had a separate public notice for
the RI, citing U.S. v. Sevmour Recycling Corp. 679 F. Supp. 859 at 864.  If thac

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 is Siltec '* contention,  EPA disagrees.  EPA notes that • separata Rl review
 process is slaply not conteaplatad by CERCLA nor U.S. v. Sevaour
 679 F.  Supp 939 (S.O.Ind.  1987).  In clue CM*. the eourc notes that, pursuant to
 CERCLA as amended by SARA,  the generator defendant* are entitled to coaaant on
 the selection of a  reaedy before the reaedy is selected.  In P.S. v. Savaour
 Reeve liny Carp.,  a* here. EPA provided the generator defendants an opportunity to
 coaaent on the reaedy before a selection of the reaedy has been Bade.
EPA also notes  that Siltec was given notice that it was a potential responsible
party in the MEW area  in May, 1985 and was given an opportunity to participate in
the RI/FS process.  Thus, Siltec was on notice that the RI/FS was being prepared,
and therefore,  Siltee  should have been tracking the progress of the RI/FS.
2.  CamMtig;  Pages 3-4.  Siltee has been unable to eoaaent on the FS because of
substantial uncertainty about the accuracy and validity of the FS distributed for
public coaaent.                            .

EPA Response:  EPA disagrees with the statement that "there is substantial
uncertainty about the accuracy and validity of the FS distributed for public
comment."  As stated above, the FS was available to the public in the EPA and
Mountain View libraries at the beginning of the coaaent period, November 21,
1988.  In addition, copies of Che FS were also available for purchase froa
Canonie Engineers.  Any inconsistency between the copies was ainor in nature.

3.  Comment;  Siltec stated that "(TJhe opportunity for meaningful coaaent is
coaproaised where coaplete copies of relevant agency documents have not been made
available in a timely fashion* citing the case of U.S. v. Rohm and Haas Co. Inc.
669 F. Supp. 672, 683.

EPA Response:  The facts of U.S. v. Rohn and Haas Company. Inc. are very
different than here.  In particular, the public we* given 5 days to submit
comments in U.S. v. Rohm and Haas Company. Inc.  Here the public, including
Sileec, was given 64 days to submit comments.

4.  Commentr  Siltee recommends that cleanup of the C aquifer (the areas below
the B-C aquitard) should be addressed as a separable operable unit as the term is
defined at 40 CFR Section 300.6 and as permitted by 40 CFR Section 300.68(c).

EPA Response:  40 CFR Section 300.6 simply defines an operable unit as "a
discrete part of the entire response action that decreases a release, threat of
release, or pathway of exposure."  EPA fails to see the benefit of addressing the
C aquifer as a separate operable unit solely for cost allocation purposes.


The Following Selected CommenC* Concerning EPA*a Process Were Submitted bv Air
Products

1.  Coaaunf-  "EPA does not have the power to create or affect liability of
persons at a 'Superfund site' slaply by drawing the 'site boundary' at one
location versus another.*

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 EPA Response:  The  FS does not address the liability of persona ae the MEW site.
 EPA notes  that liability is determined by CERCLA Section 107, not the drawing of
 site boundaries.
 2.   Comang ?  "EPA  lacks the authority under Section 104 to order Air Produces to
 require  testing."
EPA Raaponaa:  Orders requiring  testing under Section 104 are not addressed in
the RI and FS.  EPA notes Air Product's legal opinion.


Comments Concerning the Proposed Cleanup Coals

1.  Comment:  The Regional Water Quality Control Board (RWQCB) commented that the
cleanup goal for the groundwater inside the slurry walls should be set at 5 parts
per billion (ppb) -• the same goal set for the groundwater outside of the slurry
walls.  The Board commented that EPA's groundwater classification applies to all
aquifers including aquifers within slurry walls.

EPA Response:  EPA's Proposed Plan recommended a 5 ppb cleanup goal for the
shallow aquifers.  Although not  specifically stated, this 5 ppb goal would also
apply to the aquifers within the slurry walls.

2.  Comment;  The RWQCB also commented that the cleanup goal for soils within che
slurry walls should be set at .5 parts per million (ppm) -• the same level for
soils outside the slurry walls.  The Board was concerned about relying solely on
slurry walls to prevent migration of contamination 'because the long term
integrity of slurry walls has not been demonstrated."

EPA Response:  In addition to pumping within the slurry walls (to assure an
inward gradient), there will be  continuous monitoring of water levels and
chemical concentration inside and outside of the slurry walls.  Performance
monitoring will be an integral part of any RD/RA Consent Decree.  In the event of
a slurry wall failure, additional measures can be taken such as, modification of
the walls and pumping rates, or  applying more stringent cleanup levels inside che.
slurry walls.

3.  Comment:  The Santa Clara Valley Water District  (SCVWD) commented that they
would not prevent a well from tapping the shallow aquifers.

EPA Response:   Comment acknowledged.

4.  CTBBgnt:  The SCVWD is concerned that a cleanup  goal has not been established
for che aquifers within the slurry walls.

EPA Response;  See EPA response  to comment no. 1.

5.  Comment;  The SCVWD commented that specific protocol should be developed  for
reviewing and evaluating the performance of the selected remedy.

EPA Response;   The RD/RA process will incorporate specific criteria  for
evaluating the cleanup goals and the effectiveness of the remedy.  The  cleanup
goals and remedy will be evaluated at least once every 5 years.

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 6.  SSttUSSLL Th«  SCVUD  recommended  that • cleanup goal of 0.8 ppb also be
 established for the  shallow aquifers.

 gPA R«at»ana«;   A 5 ppb cleanup  goal  is protective of huaan health, especially
 since  these aquifers are not currently used for drinking water.  The 5 ppb level
 also falls  within  EPA's  acceptable risk range of 10"*  to 10"7.

 In addition, the cleanup goal may not even be technically feasible because the
 aquifers are relatively  "tight" (low water bearing zones) and have a high clay
 content, thereby making  cheaical reaoval difficult and costly.

 7.  Comment:  The  League of Women Voters urged EPA to use a  "hazard index* to
 establish cleanup  goals  instead of the Maximum Contaminant Level (MCL) for TCE.
 The League  is concerned  about the "mixtures of chemicals" and their effects and
 cited  the IBM and  Fairchild sites in San Jose where the hazard index was used.

 EPA Response:   EPA believes that a 5 ppb TCE cleanup goal for the shallow
 aquifers is protective of human health.  See EPA response to the SCVWD.

 The ratio of TCE to  other chemicals  (found at the site) is high enough that a 5
 ppb cleanup of  TCE will  result  in a  cleanup of the other chemicals below their
 corresponding MCLs.   The 5  ppb  cleanup goal takes into account the additive
 effects of  the  chemicals found  at the site, and the resulting risk falls within
 EPA's  acceptable range of 10"* to 10*7.

 The IBM and Fairchild San Jose  sites have TCA as the dominant chemical.  Drinking
 water  wells have also been  affected  at the IBM and Fairchild sites in San Jose,
 while  no drinking  water  wells have been impacted at MEW.

 8.  Comment1  One  commenter wrote that Alternative Concentrations Limits (ACLs)
 would  be appropriate "if no health risk occurs through exposure by contact or
 through ingestion  of the contaminated groundwater."  The comaenter questioned
 whether such exposures can  be prevented.

 EPA Response:   EPA is not proposing  the use of ACLs at this  time.  The
 applicability of ACLs will  be determined during subsequent review periods, once
 Che remedy has  been  implemented and  periodically evaluated.


 The Following SelecCed Co""«ar>gs Concerning Cleanup Coals Were Submitted Bv
 Crosby. Heaflv.  Roach and Mav.  a Law Flna Representing Sobrato Development

 1.  C?mtnt:  Th*  5  ppb  cleanup level for the shallow aquifers  "is not necessary
 to protect huaan health  and safety", and the cleanup level "is unreasonably
burdensome and  cose  inefficient.  The firm also wrote that the shallow aquifers
 •are not reasonably  anticipated to become suppliers of drinking water in the  near
 or distant  future",  and  that the enforcement of existing institutional controls
 can be used to  protect human health. Therefore, less stringent  standards should
 be applied  to the  shallow aquifers namely 500 ppb.

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 gPA Response:   It should first be noted that EPA has proposed cleanup goals
 rather than cleanup 1 avals.  These goals end eh* noodles will be evaluated
 periodically to determine if they ere technically practical, and therefore they
 •ay be subject to modification.

 EPA baaed its proposed cleanup goals on several factors:  1. The shallow aquifers
 are potential drinking water sources even though they are not currently being
 used for drinking.  This determination is also consistent with the Regional Water
 Quality Control Board's Basin Plan and Non-Degradation Policy which are designed
 to  protect natural resources;  2.  The 5 ppb goal Beets EPA's acceptable risk
 range  of 10"* to 10"7:.   The 300 ppb cleanup level which the commenter is
 proposing would exceed this  acceptable risk;  3.  It is unlikely that all of the
 abandoned agriculture  wells  which are currently acting aa conduits or are
 potential conduits threatening the deep (current drinking water) aquifers will
 ever be located and properly sealed.  Experience has shown that abandoned wells
 (e.g.,  Rezendes Veils) can cause significant contamination to migrate from the
 shallow aquifers to the deep aquifers.  Therefore, absent sealing all of the
 abandoned wells,  it becomes  necessary to reduce the contamination in the shallow
 aquifers.   The 5 ppb level would then be the Maximum level that could potentially
 migrate to the deep aquifers.

 2.   Comment:   "The worst case scenario soil remediation application is
 inappropriate."  The commenter objected to uniform application of the worst-case
 scenario to the entire MEW area.  The commenter also stated that future use
 assumptions of the MEW site  are inconsistent with the City of Mountain View
 General Plan and with  California Health and Safety Code institutional controls.

 EPA  Response;   Because multiple sources have impacted a common groundwater area
 with commingled contaminant  plumes (which threaten a current drinking water
 supply),  EPA believes  that a uniform application of a reasonable "worse-case"
 scenario and a uniform application of cleanup goals is the most efficient aechod
 to assure the  protection of  public health.  This is also consistent with the
 approach taken at other sites in Santa Clara Valley and the country.  Although
 the  City of Mountain View's  General plan may currently call for
 industrial/commercial  use of the site, General Plans and land use are subject to
 change.   The site is also presently bordered by residences west of Whisman and on
 Moffett Naval  Air Station, and a change in the electronics industry may make
 residential use of the site  plausible in the future.  Other than deed
 notifications,  it is not clear to which institutional controls of the California
 Health  and Safety Code the commenter is referring.


 Response  To Selected CoBments From Sobrato
1.  Coitm»^'  "The MEW FS purports to apply a percolation rate of 2  inches/year
in calculating the allowable contamination concentrations in the soil.  Such a
percolation rate is considered extremely unlikely  in properties,  like SOBRATO' a,
which have been covered and contained by asphalt.  In addition, surface  runoff at
the site is comprehensively routed to storm sewers and drains. Therefore,
percolation rates on the SOBRATO properties should be  expected to approach nearly
zero."
                                        8

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EPA Response;  Although field studies have not been conducted at the MEW site Co
determine the amount of water infiltrating through the topeoil, the literature
describes exponentially decreasing infiltration rates following a rainstorm.
However, acre water nay infiltrate to the aquifers in periods of long storms,
especially following extended dry periods.

The scenario of calculating soil remediation levels, by assuming potential
residential use rather than current industrial usage, is EPA policy.  This policy
has been consistently applied throughout other regions under similar
circumstances. The rationale supporting this policy is that surface coverings and
land use may change and, over the long term,, institutional controls may be
unreliable.  The 2 inch/year percolation rate is applied consistently throughout
the HEW area.

2.  Cqmnant;  "We (Sobrato) would like to point out that if the rationale used as
the basis for the California Assessment Manual (Ca. Admin. Code Title 22,
Division 4. Chapter 30, Article 11) criteria is applied to the subject
properties, the soil cleanup level would be, at a minimum, 5.0 mg/kg.*

EPA Responser  The criteria presented in the cited California Administrative Code
defines a regulated hazardous waste and is not appropriate for determining a soil
cleanup level.


The Following Selected C*?Bffl?nC5 Were Submitted bv Heller. Ehnnan. White &
MeAuliffe. Attorneys for NEC Electronics. Inc.

1.  Cflnn*nfi'  The intended application of the "No Further Action" (monitoring
only) alternative is unclear, since it is discussed primarily for Zone 1 soils
located inside slurry walls.

EPA Response:  EPA does not understand the comment, as we believe the application
of the "No Further Action* alternative is adequately explained for each of the
remedial alternatives in Chapter 8 of the FS.

2.  Comment:  No estimates of the remediation periods for "Partial Excavation
with Ambient Temperature Aeration" (Alternative 3) and "Partial EXcavation and
Ambient Temperature Aeration with In Situ Soil Aeration" (Alternative 4) are
provided.

EPA Response:  The time frame for this alternative would be governed by  the
factors identified in Appendices G and H of the FS, which state that the
remediation of excavated soils requires 48 hours of disking soils in six inch
lifts.  The number of lifts required would depend upon the volume of soil  to be
remediated.  Table 0-22 of Appendix 0 provides the volume of soils  to be
excavated and remediated.

3.  Conmenc:  NEC Electronics requested the "latitude" to explore other  "options"
including those remedial methods outlined in  the FS, and other methods  in order
to achieve the ROD cleanup goals for vadose zone soils.

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 EPA Response:  EPA anticipates that the MEW FS will be applied as appropriate co
 other sites in tha MEW area.  Tha reaedy, in-sieu vapor extraction, was selected
 based on a thorough •valuation of the alternatives.  In addition, soil excavation
 and treataent by aeration was also selected, based on prior iapleaantation in
 MEW.  If new information or alternatives are brought to the attention of the
 agency in the future, the EPA nay consider thea.

 4.  Comment:  le is highly unlikely that contamination in the Rezendes Veils
 could have cone from NEC's 501 Ellis Street facilities.

 EPA Response:  The specific origin* of the Rezendes Wells' contaaination is not
 an issue in the selection of a raaedy, nor is liability for the deep aquifers,
 sine* Superfund liability is strict, joint, and several.

 5.  foment •  When shallow groundwater is nixed with deep aquifer groundwater in
 the saae treataent systsa, thar* will be a "deleterious effect on the water so
 treated."  This aixad groundwatar will have liaited uses "if surface discharge is
 rejected as an alternative after treataent."

 EPA Response|  While this appears to be aainly true for the A and Bl aquifers,
 aose of the B2 and B3 aquifers would not require treataent for aajor ions and
 colifora bacteria.  See Table 1-6 (Volume X) of the Reaedial Investigation
 Report.  Furthermore, the "deleterious effects* of mixing the deep and shallow
 ground waters in a treatment systea will ultimately be determined by the end use
 of the water.

 6.  Comment:  The effects of long term pumping of the shallow aquifers should be
 carefully evaluated in light of recent experience with, a similar systea at other
 sites in th« region.  It is not clear if recharge rates and aquifer yields have
 been evaluated.

 EPA Response:  While it is not clear to which other sites in the region the
 coaaenter is referring, aquifer yields and recharge rates will be thoroughly
 evaluated during RD and befora "any full scale remediation beings.  In addition,
water levels, subsidence, etc. will be carefully monitored during RA.

 7.  Comment:  There is no indication that scaling and biological growth in the
 air stripping columns have been considered in treetaent facility design or in the
 operation and maintenance costs (Otif) shown in the FS.

 EPA Response:  The operation and maintenance cost estimates for the treataent
 systems include packing replaceaent and acid feed systea maintenance, which are
 intended to solve or prevent scaling and biological growth problem*.  (Appendices
J and K).

8.  Comment:  'Thar* is no indication that the FS has considered the costs of
complete replaceaent of treataent units in the annual 06M coats or the capital
costs for the facilities."
                                                  •
EPA Response;  The annual operation and maintenance costs for each treatment
systea includes replaceaent costs (a.g.. $6,000 for blower repair or raplaceaent,


                                        10

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$11,500 for packing replacement, $14.000 to $22,000 for the acid feed system,
$1,000 for electrical control*, and $3,000 to $4,000 for the air stripper tower).
Reaoonaa To Selected Coaaofnfs From Stltee

Comments on Soil Remediation Levels

1.  General Comment:  The proposed soil remediation level of 0.5 ppa TCE for
•oils throughout the MEW site which lie outside the slurry walls is not
adequately supported by the FS. We (Siltec) believe that a 0.5 ppa TCE soil
remediation level is incorrectly calculated and incorrectly expressed for several
reasons .

2.  CffBBftTlt-  The FS states that supporting justification and analysis for
selection of a soil remediation level is based on a "worst case" hypothetical
exposure scenario where the MEW site would be converted to an unpaved residential
area characterized by open lawns and unsewered roof drains allowing maximum
infiltration and subsequent percolation (FS, Appendix Q, p. Q-10). tfe (Siltec)
believe the RI/FS errs in using the worst case analysis to identify the soil
remediation level. An appropriate analysis should consider other more probable
scenarios as the basis for selection of soil remedy for the MEW Study Area.

EPA Response co Comments 1 and 2:  The scenario of calculating soil remediation
levels by assuming  potential residential exposure is EPA policy.  This policy
has been consistently applied throughout other regions under similar
circumstances. The rationale supporting this policy is that land use can change
and, over the long term, institutional controls (e.g., zoning and local planning)
may not be reliable.
     •
In addition, the modeling scenario in Appendix Q is certainlynot an extreme
worst case.  The following items are examples:

   The model allows for instantaneous dilution with the groundwater aquifers
   below the contaminated soil zone.  In the real world, instantaneous mixing
   would not occur leading to higher concentrations in the upper portion of
   the aquifer than predicted by the model.  The instantaneous mixing given by
   the model allows for a dilution of 89 times (0.0112).  At many sites
   throughout the country, where similar evaluations are performed, no
   groundwater dilution would be allowed.  The given model assumes the
   receptor to be at the boundary of the contaminated zone.  In many
   instances, a theoretical receptor's well would be modeled directly below
   the site.  If all of the examples given above were incorporated into the
   model, much higher receptor concentrations would be predicted. The result
   would be much lower soil clean up levels.

Because of the facts given above, the model is considered  a reasonable worst  case
scenario, not an extreme worst case.  This is consistent with  EPA guidance.

3.  Comment :  Further time sensitive analysis such as the  analysis provided  in
Table Q-9 is useful to evaluate the degree of potential harm as  measured  by
various conservative assumptions. Table Q-9, for example,  shows  that health based

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 levels of TCE in Ch« aquifer would be approached for only one year in a thirty-
 year period and that otherwise the level of TCE in groundwatar would be below
 those levels.
EPA B««p.gnj^;  Table Q-9 represents one ease (conservative in concentration and
percolation, not conservative in Kd) from the potential cases given on Table Q-3.
Other cases could be performed. Given different scenarios, (e.g., longer areas,
higher soil concentrations and lower dilution), long tern elevated groundwater
concentrations could easily be greater than 5 ug/L.

4.  Cement:  The worst-case analysis used to support a soil remediation level of
0.5 ppa TCE in soil assuaes a percolation rate of 2 inches/year.  However, the
EPA approved model used to arrive at percolation rates is stated to result in
•virtually no percolation to the saturated zone."  The FS use of a 2 inch
percolation rate is based on a theoretical possibility of the effect of prolonged
Pacific frontal systems.  No justification for or analysis of the effect of the
frontal system is given by the FS.  If a worst case analysis is used at all, the
soil remediation level analysis should be calculated using a lower percolation
rate.

EPA Reaconaa:  Although field studies have not been conducted at the MEW site to
determine che amount of water infiltrating through the topsoil, the literature
describes exponentially decreasing infiltration rates following a rainstorm.
However, more water may infiltrate to the aquifers in periods of long storms,
especially following extended dry periods.
                                                                        •
Assumptions used in the EPA model resulted in calculating little or no
infiltration in the MEW area.  This model uses average monthly precipitation and
temperatures to calculate average monthly evapotranspiration rates and
percolation rates.  As a result, the percolation model does not consider the
single storm event.  Infiltration calculations based on single storm events may
yield higher computed percolation rates.  Also, the percolation model uses only
precipitation as *a water input.  Additional surface water recharge can be caused
by irrigation related to landscaping.  Based on these factors and conservative
engineering judgment, the FS used a percolation rate of two inches/year.
S.  C?nnatnE;  Th* worst-case scenario is inconsistently applied for soil
remediation levels.  The 1 ppm TCE soil remediation level for inside the slurry
walls is based on the implicit assumption that those areas will remain under
industrial/commercial control necessary Co maintain effectiveness of the slurry
walls.

EPA Reaoonaa!  A residential reasonable worst-case scenario was uniformly  applied
throughout the MEV area.  The 1 ppm TCE cleanup goal was based on the added
degree of protection provided by the slurry walls and the continued monitoring
and pumping which will be part of the overall remedy, regardless of the existing
or potential land use.

6.  Comment:  The worst case assumption stated in the FS at Appendix Q uses  a
retardation factor of 6.0.  Based on Appendix P-A, the worst case retardation
factor discovered by the analysis lies at a minimum range of 6.5-8.5 as measured


                                        12

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by laboratory data and at  7.0 aa measured by field data.  Any calculation*
involving worst case a*«uaptions should ua« thasa higher retardation factors.

EPA Raaponae!  Table Q-9 is based on R of 12.0.  Usa of a R of 6.0 is
conservative  but certainly not worst case. Many adsorption R values may be as low
as 2.2  for  ICE. Oesorption R values nay be ouch higher. "Worst ease* analysis
should  use  lower R values  not higher as implied.
 7.  cinrnnTn'  The soil remediation analysis is ostensibly calculated so as to
 demonstrate protection of  the underlying aquifer as measured by a health based
 concentration of 5 ppb TCE in the aquifer. On this basis, the FS concludes that
 O.S ppm TCE in soil is an  appropriate soil remediation level. However, the
 solution  to the equations  provided in the analysis have apparently been solved to
 result in no more than 4.85 ppb TCE in the underlying aquifer.

 EPA Response:  The difference between 4.85 and 5.0 and the use of "standard
 scientific conventions*  (i.e., significant figures) versus "nonstandard
 convention* is trivial and meaningless to argue over given the accuracy of Che
 methodology and the assumptions.  For example, the difference between 0.0111 and
 0.0112 (the dilution factor) is not meaningful or the difference is not
 significant.

 8.  Comment:  "... the FS incorrectly calculates the value for (Q ln)H.  .  ."

 EPA Response:  The referenced calculations have been reviewed and found to be
 correct.   A typographical error exists in (Qin)R. which should be expressed in
 ftVyear.   Despite the typographical error, the correct units were actually used
 and the calculation in the FS are correct as stated.
9.  Comjatnt '  "... the actual analysis provided to support  the soil
remediation level is expressed as a concentration of TCE in soil per specified
unit of available square surface area  through which percolation nav occur.  Based
on this analysis, it is inadequate to  express the remediation  level for  the
entire site without reference to the corresponding surface area."

EPA Response:  Using the site specific approach given in Appendix Q requires
areas of contamination to be used in the calculations. A similar calculation can
be made using percolation through a unit surface area through  a given mass
resulting in flux into groundwatar. The remediation levels calculated from these
approaches are presented in terms of mg/kg.  Soil clean- up levels need to be in
terms of mg/kg for application of an area-wide clean-up goal and for verification
of remediation.

10.  Comment :  The FS is unclear as to the use of recommended  soil cleanup levels
(RSCLs).

EPA Response:  RSCLs were not used to  determine soil cleanup levels at MEV.  In
fact, RSCLs are outdated and are no longer used, even by the California
Department of Health Services.
                                        13

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 11.   Com«ne:   Siltac recommended that a cleanup level greater than 1 ppm for TCE
 be aet, baaed  on aoil cleanup lave la "found at" other relevant Superfund sites.
 The  aitaa  referred to are found in New Hampshire, Rhode la land and Michigan.

 EPA  R««non«ft'   A cleanup level establiahed for one aita (especially in another
 part of the country) ia not naeoeaarily adequate at other altaa.  Site
 characteriatics can vary greatly (e.g., aoil, groundwatar, geology, affected
 populations, etc.)  and, therefore, each aite must be evaluated on a caae-by-case
 baaia.

 11.   Comaene:   The  RZ report incorrectly stated that Siltac used TCA.

 EPA  Response:   Comment noted, however, EPA in its) August 8, 1988 approval letter
 for  the RZ atatad,  "EPA neither agrees nor disagreea with the assumptions or
 aasertiona regarding 'inferred aoureaa' or 'other PRPs' as praaented in the RI
 report."

 13.   Comaene:   "... TCE contamination in the groundwatar is not attributable to
 leaks from an  above ground atorage tank and groundwatar flow beneath Siltec
 property is to the  northeaat."

 EPA  Response:   See  above response.  In its RZ approval latter, EPA alao stated,
 "EPA neither agrees nor disagreea with the configuration and boundaries of the
 chemical plumes, or with the graphical interpretation of the potentiometric
 surface/water  table of each aquifer as preaented in the RZ report."  "The
 configuration  and boundariea are, however, adequate to evaluate remedial
 alternativea."  The pointa raised by Siltec are minor since they deal with only a
 small portion  of the MEW area, and therefore are unlikely to have any bearing on
 the  selection  of remedial alternatives for the overall area.  Furthermore, veil
 elevation data and  TCE concentration contour plumaa have been reviewed and the
 data substantiates  that the groundwatar (in the ahallow aquifers) flows in a
 north or northwest  direction, consistent with the RZ report.

 14.   Comment;   Soil remediation at Siltec would be unnecessary if soil
 remediation levels  were "properly derived", therefore, the statement in the FS
 that  on-site soil remediation is necessary at Siltec ahould be stricken from the
 text.

 EPA Response:   Soil remediation levels for the MEW area have been properly
 derived.  Individual sites which will require soil remediation will be determined
 by EPA on a case-by-caae baais.

 IS.  Comment:   Siltec believes that the effects of sanitary and storm sewers as
 potential conduits  in the local study area (LSA) have not been adequately studied
 and  that further investigation nay show that sewers in the LSA do  act aa
 conduits.

 EPA Response;  An adequate evaluation of potential horizontal conduits waa
performed by Fairchild, Intel, and Raytheon as part of the RZ.  The  reaults of
 the investigation were included in the RZ report.  The report concluded  that
horizontal conduita (at leaat within the local study area) are not a problem.   If
Siltec wlshea  to perform an additional study, it may do ao during  RD/RA.

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Ttiu Following Selected Comments Were Submitted bv the League of Women Voters

1.  Comment:  Identification of all the responsible parties should be expedited
to increase the financial resources needed for cleanup.  "Close monitoring by EPA
is also essential to guarantee that all polluters have been identified and are
participating in the cleanup."

EPA Response:  EPA has issued "Special Notice" letters for cleanup liability to
17 Potentially Responsible Parties (PRPs) in the MEW area.  Agency negotiations
with the PRPs for cleanup and oversight costs will commence shortly.  In
addition, as cleanup progresses, monitoring data will be evaluated to determine
if other sources have contributed or are contributing to the MEW contamination.

2.  C?nBftnt:  The League agrees with the "pump and treat alternative* for the
shallow aquifers.

EPA Response;  Comment noted.

3.  C.grayiT;:  The Proposed Plan should identify ways of reusing extracted
groundwater.

EPA Response:  Groundwater reuse is currently being evaluated and will be
incorporated into the ROD and the RD/RA Consent Decree.


The Following Comment3 Uere Submitted bv the U.S. Maw

Ceneral Comments

1. "Unlike other FS reports, this report does not present supporting engineering
calculations on treatment sizing, pumping requirements, simulated drawdown cones,
or construction materials and methods.  As such, the document is generic in
nature and essentially requires the reader to assume that the black box system is
optimal."

EPA Response:  Such detailed design information is  cypically n££ provided in  the
FS because it is unnecessary, and consequently will be presented during Remedial
Design (RD).

2. "The report does not present specific design information for water  treatment,
soils aeration, and several other alternatives discussed.  Without  this
fundamental information, it is impossible to critique  the authors conclusions."

EPA Response:  The Information presented in the report is sufficient for
evaluating various alternatives.  Specific design information will  be  presented
during RD.

3. "A groundwater model is not specified, and pumping  specifics  (e.g., rate,
duration, equipment) are not provided."


                                        15

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 EPA Response:  The  information regarding the groundvatar model can be found in
 Appendix  P of  the Feasibility Study.

 4. "Offsic* remediation  ia mentioned throughout the document in a cursory manner,
 yet a number of pumping  trail* ar« ahown on MAS Moffett Fiald property and a
 treatment system ia ahown on  NASA property.  How waa the information gathered in
 the MAS Moffott Field Remedial Investigation incorporated into the treataenc
 designa and ground  water extraction schemes?"

 EPA Response:  Aa the FS report states, the number and location of pumping walla
 and treatment  systems is for  costing estimates only.  The actual number and
 location  of these units  will  be provided during RD.  Also, site specific sources
 on Moffatt Field were not incorporated into the treatment designs and extraction
 schemes.

 5. 'The document does not present information as to die potential timing for
 installation of off site or on site remediation. Due to other investigations
 currently ongoing,  extensive  coordination is needed.  To data, what coordination
 is proposed?*

 EPA Response:  Timing and coordination for well installation will be part of the
 Remedial  Design and Remedial  Action (RD/RA) negotiations process, and therefore
 are not incorporated into the FS.

 6. "It waa difficult to  determine if the unsaturated zone model is accurate
without supporting  calculations.  In addition, how is differentiation made
between vapor  phase transport and liquid phase transport?"

 EPA Response:  Supporting calculations for the unaaturatad zone model are found
 in Appendix P  of the FS.  Vapor phaae transport waa not considered.


 Executive Summary

 I. "ES-1.  Uncontrolled  sources are cited aa present and impacting potential
 remediation.   These sources are not clearly defined in the text nor are their
 impacts."

 EPA Response:  Uncontrolled sources will be defined during the RD/RA phase and as
other PRPs are included  in the process.

2. "ES-1.  It  is stated  that  the FS ia designed to adequately address unknown or
uncontrolled sources of  pollution.  No reference waa found in the text that
presents how uncontrolled sources are handled in the FS design process."

EPA Response;  See  response above.

1. "ES°2.  Chemicals have been detected in all S aquifers.  Waa  there  any
investigation  aa to the  vertical distribution of chemicals in any of the
aquifers, particularly the C  aquifer?"
                                        16

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 EPA Response:  Section 4.0  of  the Remedial Investigation Report (July, 1987 and
 revised June,  1988) contains the results of a thorough investigation of the
 cheaical  distribution in soils and groundwater in all aquifers.


 4. "ES-2.  How was the total volume of TCE, TCA, etc. calculated?  This was noc
 described in the  text."

 EPA Response:  The estimation  of volunes of chemicals in various aquifers is
 described  in Section 4.3.2  (pp. 4-63  through 4*66) of the RI Report.

 5. "Shallow aquifers beneath the sita are eitad by the RWQCB as being a potential
 drinking water source.   This argument appears unfounded since the general water
 quality is poor and the  aquifers thin, discontinuous, and low yielding.  How much
 potential  does EPA or RWQCB see for the shallow aquifers being utilized as a
 drinking water source?"

 EPA Response:  While the water quality and yields of the shallow aquifers may be
 lesser  in  relation to the deep aquifers, the shallow aquifers near the site have
 been used  for  drinking water in the past, according to the Santa Clara Valley
 tfacer District.  Although currently no one is using the shallow aquifers for
 drinking water, the aquifers do meet  EPA's groundwater classification criteria
 for potential  drinking water sources  and are also protected under the RWQCB's
 Basin Plan and Non-Degradation policy.  Both agencies regard the shallow aquifers
 as a resource  that should be protected and restored.

 6. "ES-5.  The upper foot of soil is  not considered for remediation bas«ci on
 health  risk.   Was potential leaching  of these materials and subsequent
 concentrations in lower  zones  considered?"

 EPA Response:  The Endangeraent Assessment prepared~by EPA concluded that there
 is very little contamination present  in surface soils, therefore, leaching (from
 the surface soils) is unlikely to be  a problem.

 7. "ES-7.  Throughout the document, maintaining an inward and upward hydraulic
 gradient has been discussed.   However, calculations on how much water should be
 pumped  to  establish this gradient or  exactly what minimum magnitude of the
 gradient is necessary but not  present.*

 EPA Response:  Water pumpage will be  determined during RD/RA.

 Chapter 1

 1. "P12.  Recent groundwater extraction from within the slurry walls  is
presented.  There does not  appear to  be any reference in the text as  to  the
 quantity of water being  pumped or the quality of effluent.  This type of
 information is critical  in  evaluating appropriate remedial alternatives.   No
reference  is made as to  the established NPDES levels to Stevens Creek or the
POTV.   This information  is  vital in establishing cost effective disposal
options."
                                        17


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 EPA Response:   EPA does  not believe that this information is necessary for the TS
 report.  The  information will be provided during the RO phase.  NPDES levels may
 be  obtained froa the RWQCB.

 Chapter 2

 1.  "P-17.   Three additional recovery wells were added in 198S.  What was the
 rationale behind their installation?  Where are they?  Do they all couple into
 one treataent system? If so, was the original system redesigned?  Where is the
 treataent aystea?"
                                           *
 2.  "P-17.   Twenty-one (26?) recovery wells are apparently now operating.  A
 scheaatie of the operating systea(s) is essential along with design details and
 rationale.  Nona of this information is provided y^lrg a good review of
 additional  pump and treat scenarios difficult."

 3.  "P-18.   Three stripping towers are said to treat some portion of the recovered
 water.  What portion goes to the POTW and to Stevens Creek?"

 EPA Response:   The  above information is not necessary for the FS and will be
 provided during the RO phase.

 4.  "P-22.   The  Raytheon  slurry vail is said to partially penetrate the B2
 aquifer.  Why was the wall keyed into permeable materials?*

 EPA Response:   This information may be obtained by reading the Raytheon "Slurry
 Wall Construction Report" Colder Associates, January 1988, which is-on file at
 EPA and is  also part of  the* administrative record.

 5.  "P-23.   1,300 Ibs.  and 230 Ibs. of VOCs were removed from two plots.  What
 percentage  recovery of VOCs was achieved?"

 EPA Rasponsa-L   This will not be known until the remedy has been completed.

 6.  "P-24.   In-situ  tests apparently suggest an effective radius of influence of
 40  feet for venting wells.  The specifics of these tests were not presented.
 What were the physical soil properties?  Soil moisture and temperature?  Total
 concentration of chemicals in the soil?  Generally, in the fine grained soils.
vent veils  are  placed on 5 to 10 feet centers.  Although it is not possible to
 check the authors'  calculations, previous experience suggests that the vent
 system as given may not  be adequate."

 EPA Response:   The  information may be found in a report titled, "Soil Vapor
 Extraction  Study".  Raytheon Company, prepared by Harding Lawson Associates dated,
February 8, 1998.   The report is available for review at EPA  and is  also part of
 the administrative  record.

 7.  "P-26.  The  slurry wall around Fairchild building 9 appears  to be built
 through a highly contaminated area.  Why?  (See figure 2-1.6)"

EPA Response:   This information is not relevant to  the proposed cleanup plan.


                                        13

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8.  'P-27.  Metals have been detected in the groundwatar but are essentially
discounted because of the statement:  "Metals...are not very mobile in
groundwatar.. .V  The presence of iMCals in the soils and groundwatar should be
considered in the design of treataent alternatives.  Metals present in the high
ppb range may have adverse affects on potential treataent options such as
biological reactors and promote scaling in air stripping towers.*

EPA Response:  Metals will be considered during RD.

9.  'P-33.  Chemical concentrations were detected in Stevens Creek.  What were Che
concentrations of these chemical*?  How were these chemicals addressed in NPDCS
permitting at the site?"

EPA Response:  This information is- not relevant to the FS.  NPDES permitting
requirements  may be obtained from the RVQCB.

10."P-33.  How were the synergistic and antagonistic effects of the various non
target chemicals addressed when designing water treataent systems?  For example,
is  fouling of the aeration tower packing material due to high levels of
Inorganics a  potential problem at the MEW remediation area?

EPA Response:  This information will be developed during' RD.

11. "P-34.  Chemicals detected in samples below 10X or 5x associated field blanks
are reported  as non-detected.  Which specific compounds other than the four
chemicals listed fell under the 10X rule?  On what basis was the SX rule chosen?"

EPA Response;  This information can be found in the "Endangerment Assessment"
report available at EPA and in the City of Mountain View Public Library.

12. "P-36.  The mobility of metals is again mentioned yet there is no discussion
on  the redox  potential, precipitation or exchange of these chemicals in the
presence of soil components such as humic acids.  Lead for example can be
solubilized by some naturally occurring acids and some lead compounds produced
are classified as soluble.  If lead is able to come in contact with esmarine
benthic microbes through surface water transport or shallow groundwater flow,
these microbes can methylate lead to form tetraaethyl lead which is volatile and
more toxic.  Although situations like the one described are not common, a more
comprehensive review of metals contamination should be considered."

EPA Response:  See above response and response to comment 8.


Chapter 3

1.  "P-54.  In paragraph 2, soil remediation levels are left open, yet all
remedial alternatives are based on 1 ppa and O.S ppa TCE cleanup  levels.   This
apparent inconsistency needs clarification."

EPA Response:  Soil remediation levels inside the slurry walls  are  "left open"
only if Alternative Concentration Levels (ACL*) are chosen  as cleanup  levels for


                                        19

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 aquifers  inside  the  slurry walls.  EPA has chosen Maximum Contaminant Levels
 (MCLs)  for the shallow aquifers including those located inside slurry walls.

 2.  "P-37.   The federal pre-treataent guidelines for toxics of 1.37 ppa froa
 manufacturing facilities would be relevant only if the local treataent works
 would agree to use this guideline."
gPA R««pon«a;  Correct.

Chapter 3

1. "P°92/106.  In*situ biological treataent is considered only to a very limited
extent.  Specifically, the authors address biodegradation in an undisturbed
state.  Further they discount this option quickly by citing a single study
performed by Stanford University.  No significant conclusions were drawn froa
this work.

Aerobic biodegradation can be perforaed using an above grade landfaraing
technique.  This technique is very successful with aroaatie hydrocarbons and
would augment soil aeration.  The technique can be used with similar farm
equipaent employed by the aeration alternative.  Although biodegradation alone is
not a plausible solution, biodegradation using marine bacteria, sewage sludge or
some strains of soil bacteria can enhance the remove of chlorinated alphatics
sorbed to the soil matrix and should be considered."

EPA Response:  Comment noted.

2. "P-95.  On site treataent options deal exclusively with volatile compounds.   «.
The extracted water streaa will contain numerous other eheaicals such as iron,
magnesium, calcium carbonate, and heavy metals.  These compounds must be treated
prior to entry into an aeration tower to prevent fouling and to promote treataent
to the limits set.  Treataent units including precipitation tanks and mixers, in
line filtration, and multimedia filtration should be addressed."

EPA Response:  This will be addressed during RD.

3. "P-101.  The cheaical characteristics listed are properties associated with
volatilization and sorption.  Characteristics such as pH, TDS, BOO and TSS need
to be quantified prior to design of water treataent."

EPA Response:  Comment noted.

4. "P-103.  The contention that additional surface capping would have a minimal
influence on infiltration should be supported by calculations provided in the
document."

EPA Response^  Most of the site (approx. 80%) is already capped.  Therefore,
additional capping will have little, if any, influence.

5. "P-104.  It is contended that excavation would require demolition of several
buildings.  Which buildings?"


                                        20

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 EPA Raaoonae:   Potentially,  any building .situated over soil contamination.

 6.  "P-105.   Limited space available  for stockpiling toils is given as a reason to
 discard excavation, yet landf arming  soils for volatilization of organic* is
 passed through for consideration.  If space is limited, where would the above
 grade landfaraing be accomplished?'

 BPA Reaoon««;   This information will be developed during RD.

 7.  "P-108.   Aeration is described  as not being effective on phenol.  However, no
 treatment method is offered  for phenol in lieu of aeration.  Why?*

 EPA Response;   As phenols in soil  have not been quantitatively defined,
 information  will be developed during RD, and incorporated as necessary into the
 treatment methods.

 8.  *P-108.   What constitutes successful dewatering? (para 4).  If vapor
 extraction is  to be successful,  what is the maximum residual water content in
 sandy soils?  Cohesive  soils?"

 EPA Response:   This information will be developed during RD.

 9.  "P-108.   Adverse settling due to  dewatering was encountered.  What was the
 magnitude of this settlement?  Why was this situation not reviewed in Chapter 9
 with respect to the long term pumping scheme?*

 EPA Response;   It is not known  if  settlement was due in part, solely, or at all
 because of dewatering.   Additional information will be developed during RD/RA.

 10.  "P-108.  It is  stated that  settling will not affect slurry wall integrity.
 Were calculations performed  to  support this contention?*

 EPA Response:   The  FS Report states  that settlement conditions are not expected
 to  affect the  integrity of the  slurry walls.  Calculations to support this
 conclusion were performed by consultants for Raytheon independent of the FS
 report.'

 11.  "P-109.  The report claims  that  in-situ aeration is applicable to soils
 beneath buildings.   It  is not clear  from the supplied figures how soils beneath
 buildings are  being remediated.*

 EPA  Response:   Soils beneath buildings are not currently being remediated.  Those
 areas will be  addressed during  RD/RA.

 12.  "P-109.  What are the serious  concerns about steam injections?*

 13.  "P-109.  What are the potential  adverse effects of steam flushing?  They are
not presented  in the discussion.*

EPA Response:   The  concerns  about  steam injections are that the  levels of
development  and field experience are minimal.  Massive injections of steam would
result in the  significant elevation  of subsurface soil temperatures and pore

                                        21

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pressures under structures on the site.  These temperatures and pressures could
result  in possible  injuries to personnel and disruption of industrial operations
due  to  1.  heave or settlement and/or 2.  the accidental uncontrolled release of
steam to the surface.

14.  *P-H2.  The arguments that flushing may increase the boundaries of chemical-
bearing groundwater and that the flow injected water cannot be controlled are not
valid.  If injection wells are properly placed upgradient of the plume and
extraction wells placed downgradient, a closed loop system can be maintained.
Flushing incrasses  the hydraulic gradient and can substantially reduce
remediation time.   Further, flow controllers connected to sensors in monitor
wells can maintain  a predetermined hydraulic head.*

g?A Response:  Sections 5.3.11, 5.3.25, 6.2.9, 7.2.2.4, and 7.2.3.4 of the FS
explain why flushing is not considered for site remediation.

15.  *P-112.  1. It  is stated in the FS that it is unlikely that enough water
could be injected to alter the piezometric surface.  This argument contradicts
the previous statement regarding complex stratigraphy.  The aquifers are low
yielding, discontinuous and relatively thin bedded.  All of these physical
characteristics suggest an induced head could be applied.  2.  Were calculations
performed or a flow model used to show the effects of water injection?*

EPA Response:  1.   The text of the FS does not contradict the above statement.
The text does state that due to the 'extremely variable permeabilities ... it
(is) impossible to  ensure that adequate flushing rates can be maintained in all  .
. . areas.  Also, it is unlikely that it will be possible to inject groundwater
at a rate that would significantly alter water levels or piezometric surfaces in
areas not in the immediate vicinity of the injection well*.  2.  No.

Chapter 7

1. "P-160.  An 80 foot square grid would be required according to section
7.2.1.2.  Earlier in the report, a 35 foot spacing was presented.*

EPA Response:  The  exact spacing is unknown st this time, but will be determined
during  RA.

2. "P-160.  In figures 7.2-1 a-c, extraction wells are shown but air inlet wells
are not shown.  The text describes inlet/extraction wells.  Is this a pump in,
pull out process or just vapor extraction?*

EPA Response:  The  process will be determined during RD.

Chapter 9

1. "P-260.  Stevens Creek is proposed as the ultimate receptor for  treated
groundwater although it is not specifically stated in this  chapter.  How will  the
added flow affect the stream channel?*

EPA Response?  AS described in Section 2.2 (pp 2-4) of the  RI Report.  Stevens
Creek is an intermittent stream.  Therefore, the addition of a year-round flow of

                                        22

-------
 treated groundvatar from MEW Area remedial Actions might change portions of the
 creek downstream of groundvatar discharge points to a perennial condition, to the
 extent that  the discharge flow exceeded local stream bed percolation capacity.
 However,  the proposed  flow of treated groundwater is not expected to be large
 enough, when compared  to normal stom run off, to materially affect the channel.

 2.  "P-260.   Haw channel hydraulics been modelled using the HEC-1 or similar
 flood routing scheme to ensure that the added vater trill not create a local
 flooding  problem?"

 EPA Response:  No.

 3.  "P-243.   Seven tenths of a pound of TCE is considered to be de minimus.  How
 is  this value calculated (weight or volume basis)?  What criteria is used for
 determining  the volume or weight to test?*

 EPA Response:  The term "de minimus* was developed by Fairchild, Intel, and
 Raytheon  to  describe certain "minor" contaminated areas.  EPA does not use this
 terminology  to describe contaminated areas.  Calculations and criteria may be
 found in Appendix 0 of the FS report.

 4.  "P-245.   How was the pumping scheme outside the slurry walls designed to
 ensure that  an upward  gradient is maintained inside the slurry walls?  If the
 groundwater  surface is sufficiently suppressed outside the walls then inside
 pumping is negated."

 EPA Response:  The gradients are currently being monitored and will be monitored
 during RD/RA.

 S.  "P-260.   Why are only Bl and A aquifer wells proposed offsite in the
 downgradient direction?"

 EPA Response:  Because there is no contamination downgradient in the B2 and B3
 aquifers.

 6.  "P-260.   What is the rationale for placement of wells within NAS Moffett
 Field?  Vas  flow modelling performed?"

 EPA Response:  Veils were placed in relation to the contamination plume.  Flow
 modelling was not performed.

 7.  "P-260.   Since chemical transport modelling was accomplished in only two
 dimensions,  how were the effects of drawdown of chemicals through shallow
 aquitards considered?"

 EPA Response:  The effects of drawdown of chemicals through shallow aquitards
were not considered since the model assumes that the aquifer is confined.

 8. "P-261.  Air stripping and activated carbon filtration are listed  as treaonenc
components.  Will these systems require continuous monitoring?"

EPA Response•  No.

                                        23

-------
9. "P-261.  What ara the eatimated carbon uaa rataa and packing Ufa apana?  Vhae
other componenta coapriaa tha treatment ayatama?  How awch araa will ba
required?"

10. "P-261.  How will utilieiaa ba handlad for tha off aiea aystema?"

11. "P-266.  Vhae la tha rationale for tha placaaant of tha thraa "C* aquifer
walla?  What ara tha propoaad pumping rataa?  Will tha higher volume pumped from
tha "C" aquifar have a tendency to dilute the waata atraaa from tha lower
yielding upper aquifar walla?  If aot what la tha expected average concentration
of ehemicala on tha influent aide of the air a tripper?"

EPA Raaponae:  The information for quaationa 9-11 will ba developed during RD.

12. "P-267.  Tha Operation and Maintenance coata are not well defined in the
appendieea.  How waa tha 2.9 million dollars of annual 0£M derived for the off
aite remediation acheme?  How many treatment ayatama ara included in the off alte
program?*

EPA Reaoonaa:  The O&M coata ara adequate for the purpoaea of tha FS.  The axacc
number of treatment ayatama will be developed during RD.

13. 'Figure 9.2-4.  Some fairly axtanaive piping la ahown on HAS Hoffatt Field
property.  How would this piping be inatalled?  Have the numeroua aubgrade
utilitiaa on the facility been factored into the eatimatad coat?"

EPA Reaponaa:  The drawn piping la a conceptual daaign and tha Installation will
be refined during RD.  Yea.
                                        24

-------
ADMINISTRATIVE RECORD IMDBX

-------
REVISION BATE: 05/22/89
                                         Niddlefield-EKia-wfciaMan ATM Superfund Sit*
                                                  Mountain view,  California
                                            «•• AdBiniatratiwa Record Index •••
                                                                                                                PACE:  t
  t       04/11/76  NatcoiMI
                    Santa Clara Valley water Oiat.
County Sanitarian*
well Seating Inatruetion*
         02/08/85   Roger I. Jamt
                       n
                       Mr l««fan
                                        T«nt«tf«* Ordtr
         03/20/85   PIMM Mrkfra
                    i.v.a.e.i.
                    Sf B«y ffcgian
Oanctd 0«(k»
t.v.o.e.i.
SF B«y Bcflian
        ••part* for
Nowitain vf«w
         M/22/85   Thaw* MHtfn*,  lottr           >o««r JMH
                    F«(dMn, Lwrtne* Kotb           R.U.fl.C.B.
                    R.U.Q.C.B.  Sf fey ••gion         SF Say Region
                                Faircfeild,  Intel. MCC,
                                ••yttMon, Siltae, Mountain
                                Vfm, Santa Clara Co.
         Ot/30/85   I.U.a.C.I.
                    SF fay Region
         07/26/85   Gordon Snow                     Ctam rfatntr
                    RaMurec* Agency 91 California   EPA Region 9
                                Fairenild, Intel, M6C,
                                laytfMon, Si I tee. Mountain
                                Vfen, Santa Clara County
                                            for Site Cleanup
                                State Review of Mountain View
                                Five Superfund Project
         08/15/85   Harding, lawaon Aaaoe.;
                    Canonie Engineers
 8       08/15/85   EPA  Region 9
EPA Region 9
Intel, Fairdiild t Raytfceon
Work Plan ReMdial Invcstig.
Feaaibility Study and Oper-
ational unit Feaaibility Study
Niddlefield EUiftfiiaawi Area
Adafniatrative Order on
Conaant
75
22
         08/15/85  Koyd R. Day
                   Cooler, ffodMard, Caatro,
                   Nuddleaon « Tatu*
Crfc a. lappaia
Harding,
Mountain View RI/FS
O.U.F.S.
         08/31/85   Terrene* J. NeManua
                   Intel
Clewv Kiatner
EPA Region 9
Project Schedule
It'       09/06/85   Terrene* NeManua
                   Intel
filam Kiatner
EPA Region 9
Project Schedule

-------
REVISION DATE:  05/22/89
                                         Niddlefleld-EUIa-Vhiaasn ATM ****** Site
                                                  Mountain View, California
                                             •*• Adainiatrative Record Irate ••»•
                                                                                                                 PACE:   2
         09/25/85   Cmnie Engineers
                                            TO/OtCAM12ATIOM
                                            ETA Region 9
                                                                 OCSOHPTIOJI/SUSJECT
                                                                 Addendum QAIQC Plan Existing
                                                                 Monitoring  Walls RIFS  Niddle-
                                                                 flold-EUia-WhiaaBn (MEW)
                                                                 Area
                                                                  PACES
                                                                  175
 13       09/25/83   Steve OobHjevic.  Phillip
                    AntoaBeria
                    Canonic Engineers
                                            Intal
                                                                 Monitoring Report Remedial
                                                                 Investigation Feasibility
                                                                 Study Data Through July 1985
                                                                                                              175
 14       10/28/85   Jawa NeClura,  Erie Lappala
                    Harding Lawson Aaaoe.
                                           EPA Region 9
                                                                 Technical  Mem:  Well  Inventory
                                                                 Niddlefield-EUia-Whii
                                                                 Study Area RI/FS
                                                                   25
 15
 11/15/85   Canonie Engineers
                                 Intel,  Fail-child ft Raytheon
                                Soil Evaluation Report
                                Remedial Investigation
                                Feasibility Study
                                Voluaa I
                                                                                                                       175
 16
11/15/85   Canonie Engineers
                                 Intel,  Fair-child ft Raytheon
                                Soil Evaluation Report
                                Reaadial Investigation
                                Feasibility Study
                                Voluaa II
                                                                                                                       175
         11/15/85   Canonie Engineers
                                            Intel Fairchild ft Raytheon
                                                                 Soil Evaluation Report
                                                                 Remedial Investigation
                                                                 Feasibility Study
                                                                 Voluw III
                                                                   150
 18       11/22/85   JaaM NcClure,  Eric Lappala
                    Harding,  lauson Assoe.
                                           EPA Region 9
                                                                 Technical Mean: Potential
                                                                 Conduits Evaluation Middle-
                                                                 field Ellis-UhisMn Study Area
                                                                   35
19
11/26/85
Clam Kistner
EPA Region 9
                                                    Terrence NcManus
                                                    Intal
                                EPA CosMnts on the Database
                                MeneojSBant  Systaai Plan,
                                Hydrogeologic Model Plan,
                                Wall  Inventory
20
12/00/85   Canonie Engineers
                                 Intal,  Fairchild ft Raytheon,
                                 Si Itec
                                 Puaping Test, City of
                                 Mountain Vie*
                                 Wall  Mo. 18
                                   200
21
12/20/85
Glenn Kistner
EPA Region 9
Terrenes
Intel
Preliminary Definition of
Remedial Action Objectives
MEW study Area
Mountain View. CA (caver Itr)
22
22
01/00/86   Canonie Engineering
                                 Fairchild
                                 Puaping Teats Interia Reaedial
                                 Prograai Mountain View Facility
                                 Voluw 1 of 2
                                                                                                    300

-------
REVISION DATE: 05/22/89
OOC f       gATJ
 23       01/00/86   Canoni* fflfinaars
                                                                                                                PAGE:  3
                                                           Maaan ATM Suparfund Sit*
                                                  Mountain Vfw,  California
                                                Administrative Racerd Indai •••
                                           TO/ORCA«I2AT10M
                                           Fatrchlld
                                                                           Puiping Taats  tntaria
                                                                           •••dial Progrs*) Mountain V{«M
                                                                           Facility VOluaa 2 of 2
                                                                  300
 2*       01/28/96  fitam Kistnar
                    EPA Region 9
                                           Intai
                                9ft taaaanri to tha Niddla-
                                ffatd^tlfc-tfifnan Stuoy Araa
                                •Soil Cwatuation Kaport*
          01/28//86  61am rfstnar
                    EPA laaion 9
                                           Them Trapp
                                           Lanaala Kpiay I Oi
                                Additional E»A
                                eanearnina ttia •Soil
                                Evaluation Raport" and
                                Fairehild
 27
 28
 29
30
31
         01/30/86   Clann Ktttnar
                    EPA Raaion 9
02/00/86   Canonfa
02/25/86   CatnaHna Hanridi,
           Erie Lappala
           Harding LatMon Assoe.
02/25/86   Harding lawon Assoe.
02/27/86   Canonia Enginaar*
           for Intal, Pairetiild t
02/27/86   Ptiiltp U rttzHatar
           Hardinf UMon Assoe.
                                           Tarranea MeHanua
                                           Intal
Intal. Pairdifld A Isytfcaon
                                                    EPA Ration 9
EPA Ration 9 .
                                                    U.S.  EPA
                                                    Clam Clstnar
                                                    EPA Ration 9
                                EPA Oaavants on ttia "Existing
                                Data taviaM" for tha Niddla-
                                fialct-ClliS'UhisMn Study Area
                                    Mai Inwaatigation
Historic now Analysis
Rydrogaologic Nodal Oaserip*
lion Raaadial Invastigation
FaaaiMlity Study
Third Quarterly Raport "Re
ial Investigation Feasibility
Study Nfddlefield-EUis-
Wnisaen Study Araa

Tables Third Quarterly Raport:
Remedial Investigation/Feasi-
bility Study Niddlefietd-EUis
Uhisaan Study Araa

Respensee to EPA Conaents on
the Niddlefleld-EUis-Vhisoen
Are* RI/FS Soil Evaluation
Raport

Transsrittal: Reports In reply
to EM caeBents on the "Soil
Eveluatlo
                                  17
                                                                                                                      100
                                                                  60
                                                                  .15
32       03/12/86   Clam Kistnar
                    EPA Ragion 9
                                           Larry Avon
                                           Fairchild
                                EPA and Coapany Agraaawits
33       03/26/86   Catharina Harwich,
                    Erie Lappala
                    Harding lawaon Assoe.
                                           Clam Kistnar
                                           EPA Ration 9
                                Transaittal: Chronology of
                                Evants and Chaaieal Rasults
                                fraa SUI-230. RJC and 84C

-------
REVISION DATE: OS/22/89
                                         MlddUfiald-Ellfs-UMaaan ATM Superfund sit*
                                                   Mountain view. California
                                             ••» Administrative Record In** •*•
                                                                                                                 PAGE:  4
QOC f       DATE     FROM/0»aunZATIOM
 34       03/28/86   Ql«n Kleiner
                     CM legion*
                                            TO/mCAKtZATiai
                                            Larry Asian
                                            Intel
                                                                            Initial  Screening of
                                                                            Alternatives
                                  PACES
                                  4
 35       04/03/86   Clam rtstner
                    EPA Region 9
                                            tarry
                                            Fairchild
                                                                            Delay re Aqulfior Taat Report
          04/04/86   Cltm KUtrwr
                    EM Raaion 9
                                            Larry Aaon
                                            FaircftUd
                                                                            EPA'a draft eoMMnts on:
                                                                            •Monitoring Network u«tl
                                                                            SxaMf)• Historic  Flow Anal-
                                                                            ysis  Hydrogaotogie Model
                                  10
 37       04/04/86   Ronald Stoufer t Phillip
                    Fftzwater
                    Harding Lauaon Aasoe.
                                           Raytheon
                                                                            Ptias* IV Siteurfaee Investi-
                                                                            gation Raytheon 350 Ellis St.
                                                                            Mountain view,  Ca.
                                  150
 38      04/07/86   JaMS Wilson, Erie Lappala      EPA Region 9
                    Harding Lawaon Assoe.
         05/00/86   International Tedinology        Intel
                                                                            Quality Assurance/Quality Con-
                                                                            trol  Plan:  Remedial  Investi-
                                                                            gation Feasibility Study and
                                                                            Operable Unit-Feasibility
                                                                            Subsurface Soil Re
                                                                            Intel
                                                                            Mountain view, CA
                                                                                                Jiation
                                                                                                              135
                                  310
40       05/02/86   Michael Rosa
                    Raytheon
                                           Glenn Kistner
                                           EPA Region 9
                                                                            RI/FS Schedule
41       05/09/86   Clem Kistner
                    EPA Region 9
                                           Michael Roaa
                                           Raytheon
                                                                            Deep Well Monitoring Program
42
05/13/86   Canonic Engineers
                                           Fairdittd
Investigation of Welt 652V22A3
Silva Well, Remedial Investi-
gation Feasibility Study
Middtefield-EUis-Whisaan Area
32
43       05/20/86   Michael  I.  Rosa
                    Raytheon
                                           Jiai Crove
                                           EPA Region 9
                                                                            Deep Aquifer Monitoring
                                                                            Prograai
05/21/86   Dennis Fesoire
           Canonie Environasntai
                                                    File
                                                                            Attachawtt • Contact with
                                                                            Garcia Well and Puap Ca.

-------
 KEVISIOft DATf: 05/22/89
                                                                                                        PAGE:  5
                                         Ntddlefleld-ffllis-Whiessn Are* Superfund site
                                                   Mountain View,  California
                                             *** Administrative^ Record Index •**
ooc f
 45
09/27/86
05/27/86
                     Steve) Oobrijevfc
                     Mil dp Antocavrla
                     Canonic Engineers
                     Stevo Oobrijevle
                     PnilllpAntomeria
                     Cemanle Engineers
          06/00/86   Canonic
                                           Palrcftlld
                                                    Larry Awn
                                                    Fofrenltd
                                                     Inttl.
                                                           « Icythoon
Statw lopart rolrehitd
Nouttaln Vf«H raelllty 9/1/89
thraajn 3^1/86
Vol. I

Status Hport rsfrdiltd
Mountain V|«M Facility
9/1/89 ttirouBh 3/31/86
Vol. 2
                                                                                             t«Mdlal Iiwntigation
                                                                                     Feasibility Study
                                                                                                              300
                                                                                                                        15
          06/00/86   Canonic Engineers
 49       06/00/86   Canonic Engineers
 50      06/00/86   Canonic Engineers
                                           Fairdtild
                                           Fairehild
                                           Fairdiild
                                                                                    Draft Report:  Interim Rcaodial     10
                                                                                    Actions Fairchild Scaiconduct.
                                                                                    Nt. View Facility
                                                                                    Voluac  1 of 3

                                                                                    Draft Report:  Interiai Roaedial     200
                                                                                    Actions Falrchild Seaiconduet.
                                                                                    Nt. View Facility
                                                                                    Vol. 2  of 3

                                                                                    Draft Report:  Interiai Raaodial     400
                                                                                    Actions Fairchild Seaiconduct.
                                                                                    Nt. View Facility
                                                                                    Vol. 3  of 3
 St       06/02/86   Bryan lector
                    Intel
 52       06/05/86   Nicnaet losa
                                           Glenn Kistner
                                           EPA legion 9
                                           61cm Kfstncr
                                           EPA Region 9
                                                                                     Intel  Grounduater laaadial          250
                                                                                     Actions Attached: GroundMoter
                                                                                     Rcaadial Actions Finsl  Ptiaae
                                                                                     3/19/86

                                                                                     Schedule for Saopling Round        200
                                                                                     3.5 Nlddlefield-£llis*Whisaan
                                                                                     RI/n
53       06712/86   P.JC. ChattopsaHysy
                    ecology « Envl
                                           Jla Wilson
                                           Harding tataon Assee.
                                                                                     Roqusst for Laboratory
                                                                                     Analytical ROM Oata
                                                                                     Mountain Vie* site
54       06/16/86   Robert P. Stern
                    EPA legion 9
                                                                           Mountain View Cleanup
35       06/17/86   Terry Wilson
                    CPA legion 9
                                           Press <
                                                                Rel
 EPA Request Public
 On Falrchild Groundueter
 Cleanup Plans in Mountain view

-------
•EVISION DATE: 05/22/89
                                         Middlefleld-EIKs-UMesen Area Super*** Sit*
                                                   Mountain View, California
                                             •*• Administrative Record Irate *••
                                                                                                                 PAGE:  6
30C*      gATJ
 56       06/25/86   Michael
 57       07/00/86
                                                     Glenn Kiatner
                                                     CM Reg Ion 9
                                                                           Notification of Additional
                                                                           Grounduater sampling for tho
                                                                                     •I/PS
                                                                                                             i Arto
                                                                                     RI/FS Utii Inwitory Stawry
                                                                                     Production Woii*
                                                                                                                       28
 58       07/00/86  Canonio Enginters
 59
 60
07/00/86   Canonio Enginmr
07/07/86   Niehoot Kont
           Citizom for a totter
                                           Foirctittd
                                                    Fairetiild
                                                    lobort Storn
                                                    EPA
                                                                            Parking Structure Private Well
                                                                            Investigation* and Proposed
                                                                            Well  Sealing Plan NEW
                                                                            Area, Nt.  View,  California

                                                                            Deep Wet l  clutter Muaber 3 OW3
                                                                            Installation t Puaping Chrono-
                                                                            logy Niddtefield-Ellia-Whisman
                                                                            Area Mountain View, CA

                                                                            FaircHHd (nteria Remdtal
                                                                            Action Proposal
         07/08/86   fit am Kistner
                    EPA tegion 9
                                           Michael Kosa
                                                                                     Well  Inventory i Potential
                                                                                     Conduits Evaluation
07/23/86   Harry Seraydarian
           EPA Region 9
                                                    Larry
                                                    Oiamd (
                                                                            Interiai ft
                                                                            Report
                                                                                                  ial Actions
63       07/24/86   Phillip Antcewia
                    Canonie Engineers
66       07/28/86   Michael IOM
                    taytneon
                                           Raytheon
                                           Glenn Cfstner
                                           EPA legion 9
                                                                                     8-C Acuitard Soil  Cheaicat
                                                                                     Analysis Results Niddlefield'
                                                                                     EttiS'WhisaHjn Area Mountain
                                                                                     View,  CA

                                                                                     Draft  Nap showing distribution
                                                                                     and classification of walls in
                                                                                     NEW study Area
                                                                                                              .60
65       07/29/86   Michael «o
                    Raytheon
                                           Clam Kistner
                                           EPA Region 9
                                                                                     Lost Wells
         08/00/86   Canonie Engineers
                                           Intel, Fairchild A Raytheon
                                                                                     Soil Saapling and Analysis
                                                                                     Remedial Investigation
                                                                                     Feasibility Study

-------
REVISION OATf: 05/22/89
                                                                                                                PAGE:  7
                                         NiddlefUld-EUU-UJiiaaan Area Superfund sit*
                                                  Mountain vie*. California
                                            ••• Administrative Record If
ooc •
 67
          08/20/86   Eugenia ZoHdl
                    Harding
TO/ORSAMIIATiai
aiom Kistner
EPA Ration 9
Tranaaittal of Status Report
Uatar Quality Suaaary 350
Cilia St. Mountain view, CA
8-8-86
PACES
135
 68
         08/23/86   Mi duel Roaa
6lam Klatnar
EM Ration 9
         to July 8 KM lattar
on fotantial Conduits
15
 69      09/04/86   Harding lanon Assoc.
 70      09/OS/86   Canonia EnvironMntal
 71       09/17/86   Glann Ktttnar
                    EPA Ragion 9
                                                    EPA Ration 9
                                                    Fairdiild
                                                    Nlenaal 8. Roaa
                                                    Raythaon
                                Saaplint Plan: Rawdiai  Inv««-
                                tigation Faaaibility Study
                                Niddlaf f atd»EU is-WhisMan
                                Study Araa Mountain V{*M,  CA

                                Evaluation Raport Stavana
                                Crack Reeharga: GroundMatar
                                Traataant Fairdiild Mountain
                                Viaw Facility

                                8*27-86 Taehnical Maating of
                                tna Aaanciaa and Coapaniaa
                                   210
         09/26/86   Clam Kiatnar
                    EPA Ration 9
                                                    Nfchaal Roaa
                                Short and Loot Tara Aquifiar
                                Taat Raport
                                   11
73      . 09/30/86   David K.  Rogara
                    Tha Mark  Group
                                                    Iryan Raetor
                                                    Intal
                                Transarittal of Suaaary Report
                                Soil And Grounduatar Data
                                Intal Sita Mountain Vim, CA
                                   200
74       10/07/86   Stavo Oobrijavie & Phillip       Hiehaal Roaa
                    Antoaaaria                       RaytHaon
                    Canonia Enginaara
                                                                                             to EPA Coaaanta on
                                                                                    tna Construction Out Multiple
                                                                                    Monitoring Walla in a Single
                                                                   25
         10/U/86   Stavo OobHJavic
                    Phillip AhtoBBaria
                    Canonia Environaantal
                                                           larkina
                                                    R.U.O.C.I.
                                Additional tnfonaation
                                Pertainint to Stavana Creak
         10/20/86   Stavo Oobrijavic
                    Canoni* Environaantal
                                                    C.R.  loatic
                                                    Fairehild
                                •on-RI/FS Uatar Quality Data
                                FaircHild Mountain View, CA
                                                                                                                       100
77       10/20/86   Eugenia Zorich
                    jaaaa McClure
                    Harding Lawaon Auoc.
                                                    EPA Region 9
                                 Intaria Round Uatar Quality
                                 Sampling Raport:  Raavdial
                                 Investig./Feaaibility StuaV
                                                                                                                       163

-------
REVISION DATE: OS/22/89
                                        Niddlefield-Ellfa-Whisaan Arc* Superfund sit*
                                                  Mountain View, California
                                            *•• AoMnlstratlv* Record Index •*•
                                                                                                               PACE:  8
           DATE
 78       10/21/86   Demis L. Currtn
                    Canonic Environaantal
TO/arCAHIZATtO*
Glenn Kistner
B»A tcgion 9
                                                                                   Inporv* to 9A
                                                                                   T«dnfeal
                                                                                   tur* PriviM y»((
                                                                                   tfom with
                                                                                                          stnx-
                                                                                                             PACES
                                                                                                             20
 79      10/21/86   Oomis Curren
                    Canonl* Environasntal
 80      11/21/86   Ptiillip AntaMssrie
                    Steve Oobrijevic
                    Canonie EnvtrorMental
81       11/21/86   C.R. Bostic
                   Fairehild
6Um Klitnw
C»A «t«ion 9
C.I. tMtie
                                                    Clam Kistner
                                                    EPA Region 9
                                                                                            to 6PA CoaMnt* T«di>
                                                                                  nleat N«n •«rfcln0 Structure
                                                                                  •rfvvt* Util IrMMtlaations
                                                                                  And PropOMd Welt SM(Ing f»l»n
                                                                                                             10
                                                                           Technical Meao Well Inventory
                                                                           and Evaluation Update Niddle-
                                                                           fleld-Ellis-UMssan Area
                                                                           Renodiel Investigation

                                                                           Responses to Aquifer Test
                                                                           Report Coswnts
                                                                  11
                                                                  IS
         11/24/86   Steve Oobrijevie
                    Camnfe Enviporawntal
C.R. lostie
Fa i reft i Id
                                                                                   TrartMittal: Observation yells
                                                                                   Pafrehfld Nountsfn view, CA
                                                                                                             100
         11/26/86   C.X. ftostfc
                    Fairdiild
         12/00/86  Caap Dresser & HcKee
Ctam Clstner
EPA Region 9
EPA Region 9
                                                                                   Water Lewi Oats Frost 1*86
                                                                                   Ttirough 12/86 for  the 'c' and
                                                                                   Deeper Aquifer Metis, Remedial
                                                                                   Investigation Feasibility Stdy

                                                                                   Final CoiBunitv Relations Plan
                                                                                   Kiddlefield-€llis-UMsa»n Area
                                                                                   Mountain view, CA
85       12/19/86   Oemis J. Currtn
                   Canonie Envirorawitai
Clem Kistner
EPA Region 9
                                                                                   Tranaaittal Historic Water
                                                                                   level Data RI/FS
                                                                                   Study MEW Area
                                                                                                             200
         00/00/00
                                                    out of
12/24/86   Kent Kitcfti
           EPA Region 9
                                                   Alexis Sti
                                                   EPA Region 9
                                Review of Analytical Data Re:
                                Mountain View Sit* utilizing
                                Organic* Analysis
                                Attachments
                                                                                                                     65
         12/30/86
                                Wells Reeoaajendad Seeled By
                                tne Companies as of 11/21/86
                                Mountain View MEU Site

-------
REVISION OATB:  05/22/89
                                                                                                                PACE:  9
                                         N1ddlefleld»eUls*VJiiaaan ATM Superfund site
                                                  Mountain view,  California
                                            ••• Adainlstratlva Record Index •••
  OATt;
01/02/87   Robert Will!
           Ecology
                                         ,  Inc.
                                                    TOAKCMIIZATiai
                                                                                    OtiCf.IPTtO»V««JCCT
                                                                                    GroundMater Sampling Audit
                                                                                    MM Stud? Area
 90      01/22/87   Eugenia Zorieh
                    Javaa NeCtur*
                    Herding Lmitan
 91       01/22/87   Harding I
                                                    EFA
                                                    EPA
                                                                           Pourtft MC«r Quality Svpiing      156
                                                                           lound Mpart fMdUt Invnti'
                                                                           Oation Faaaibility Study
                                                                           Nfddlcffatd-eUta-Whftaan Area

                                                                           Fourth Vatar Quality Saapling      360
                                                                           lound Report laMdial Investi-
                                                                           gation Ftaaibitity Study
                                                                           Niddtafiald-EUia-Uhisnan Arta
 92       01/22/87   Terranca NeManua
                    Intal
                                                    6tam Kiatnar
                                                    EPA legion 9
                                                                                   to EM'S
                                                                          Oatanaination of a Clean Wei I
                                                                          Letter of 12/24/86
18
93       01/29/87   Kant N. Kttcfti
                    EPA Region 9
         02/01/87   Canonie Environmental
95       02/04/87   Clem Kistnar
                    EPA legion 9
                                                    Alaxia  Strauas
                                                    EPA legion 9
                                                    EPA legion 9
                                                    C.X.  toatic
                                                    Fairehild
                                                                           Ravi en of Analytical Data
                                                                           Quality Aaauranca Reports
                                                                           1/6 through 1/29/87
                                                                           Separata Attachments
325
                                                                           Technical Naav DIM Wall
                                                                           Cluster Installation NEW Area
                                                                           Remedial  Investigation
                                                                           Feasibility Study

                                                                           Request for Round 3 Laboratory
                                                                           Data
ISO
96       02/05/87   Clam Kistnar
                    EPA Region 9
                                                    Michael  Rosa
                                                                           Intaria laaadial Measures
97
         02/06/87   C.I.  IflStie
                                                    alem Kistnar
                                                    EPA legion 9
                                                                           Mountain Vie* II/EA/FS
                                                                           Schadulea
99
         02/10/87   Kant Kitchi
                    EPA legion 9
         02/13/87   E.I.  leatic
                    Fairehild
                                                    Jaevs Grove
                                                    EPA legion 9
                                                    Glenn Kistner
                                                    EPA Region 9
                                                                           Review of Analytical Data,
                                                                           Quality Asauranea Reports
                                                                           2/3/87 thru 2/10/87
                                                                           Separata laporta

                                                                           Detailed Feasibility Study
                                                                           Analysis
                                                                                                                       60

-------
 REVISION DATE: 05/22/89
                                                                                                                 PACE: 10
                                         Ntddlefield-eilU-uhiaaan ATM Superfund site-
                                                   Mountain Vie*,  Cat if omit
                                             •*» Adainiatrative Record Index *••
DOC *      OATE     FROM/OiOAaiZATIOM
          02/23/87  Craig Wan targan
                         Oreaaar 4 McKaa Inc.
                                                     TO/qtCAII12ATIC«
                                                     Clam Kiatner
                                                     EPA Ration 9
                                                                                    Review of Raythaon Intarii
                                                                                         Hal Mmuri(a)
                                  PA6ES
                                  3
101      03/00/87   Colder Aaaoc.
                                                     Raythaon
Interia) Reaadial
       I
                                                                                                                       360
 102       03/00/87   Colder Asaoe.
                                                     Raythaon
                                                                                     Intariai Ra
                                                                                     VoitaM II
             ial Naasuraa
400
 103       03/02/87   C.R.  loatie
                     Fairchild
                                                     Glann Kistnar
                                                     EPA Ragion 9
Tranaarittal SHtae Araa Uatar
Quality Data Mountain Viaw,  CA
104       03/03/87   C.R.  toatie
                     Fairehitd
          03/11/87   61am Kfatnar
                     EPA  Ration 9
                                                     Clam Kfttnar
                                                     EPA Ragion 9
                                                    C.R. loatic
                                                    Fairdiild
         to Tachnieal
Short and long tare Aquifar
Taats Raaadial Invaatigation
Faaaibility NEW Study Area

Potantial Conduita Evaluation
("Daciaion Traa")
                                                                                                                       250
106       03/23/87   Stavo Oobrijavic
                     Phillip Antoaaavia
                     Canonia Enviromantal
                                                    C.R. Boatie
                                                    Fairehild
Statua Report Faircftild
Mountain View Facility 4/1/86
through 12/31/86
Vol. I
                                                                                                                       125
107       03/23/87   Stavo Oobrijevic
                     Phillip Antonaaria
                     Canonia Envlronaantal
                                                    C.R. Ooatie
                                                    Fairehitd
Statua Report Fairehild
Mountain View Facility 4/1/86
through 12/31/86
Vol. 2
                                                                                                                       300
108       03/30/87   61am Ktatner
                     EPA Ragion 9
                                                    C.t. loatic
                                                    Fairehild
Raqunt  for Rounda 3.5 and 4
Laboratory Data
109      04/00/87  Meredith Soli « Aaaoc.
                                                                                     Expanded Pf> Search Mountain
                                                                                     View Sita April 1987
                                                                                     Voluaa I
                                   300
         04/00/87  Meredith loli 4 Aaaoc.
                                                                                     Expanded PtP Search
                                                                                     Mountain VieM Site
                                                                                     April 1987
                                   2SO

-------
 REVISION OATS: 05/22789
                                         Nlddlefleld-Ellls-Whlsaan ATM ****** sit*
                                                   Mountain Via*. California
                                             *** Adainfstrativs (coord Index ***
                                                                                                                 PAGE: 11
 DOC •      OATt     fiai/OiBAM12ATia»
 111       04/02787   61cm Kistnsr
                     EM teflon f
TO/OROAMIZATIOM
C.i. Sostle
Paircaild
                                                                                     Sealing of Potential Conduits
 PACES
 3
 112      04/06/87   rod
                     Silicon Valley Toxics
                     Cooiition •
Robert P. Stem
ETA loflion 9
                                                                                     Nomuin VIoM Ctoonup
 113      04/10/87   Jothut I/ Pi
                     H«U«r, Ehmn.
                     NeAuliff*
Clorn Kistmr
EPA logion 9
                                                                                     Tour tof. Ho. T-1-3
.2
 114       04/13/87   NidMoi  Kont
                     Citizom for • lotti
                     Emit
Rob Stvrn
EPA Region 9
                                                                                     Intori* Clean i^ Proposal
                                                                                     by RayttMon Nouttain view
 115       04/13/87   C.I. lootie
                     Faireftild
Glenn Klstner
CPA Region 9
                                                                                     Data Verification of Sample
116       04/13/87   Joanua I. Motai
                     Heller, Ehraan, Uhite
                     X NeAuliffe
Otem Kistrar
EPA Region 9
                                                                                     Raytheon Slurry Well
117       OS/12/87   Jeff Zelikson
                     EPA Region 9
Michael Ra
Raytheon
                                                                                     Interia) Raaadial Measures
118       OS/19/87    John Mast
                     Intel
119       06/05/87   Phi It (p MtZMtar
                    Lesle*
                    Harding t
Glenn Klstner
EPA Region 9
                                                                                     Transarittal  Laboratory Data
                                                                                     Validation Water Quality Samp-
                                                                                     ling Rounds  3.5 «  4
                                                                                     RI/FS MCW Area

                                                                                     Status Report: Water Quality
                                                                                     and Water Laval Oata
                                                                   250
         06/12/87   John Mast
                    Intel
Clem Klstner
EPA Region 9
                                                                                     Tranaarittal Selected Organic
                                                                                     ft Inorganic Chearfcals
                                                                                     RI/FS MEW Area
  200
121       06/26/87  Colder Assoc.
                                                                                     Status Report Soil Soring and
                                                                                     Monitoring Well Prograa
                                                                   258

-------
 REVISION MTE: 05/22/89
                                                                                                                 PAGE:  12
                                         Mtddlefteld-Ellia-UiiaMn Area Suparfund Sit*
                                                   Mountain View, California
                                             •*• Adainiatrative Record Indn *~
123
          06/29/87   Ju( (• T
                     Phillip •fenarter
                     Harding
06/29/87   Harding lauaon Aaaoe.
                                           TO/OtQU»MTIO»
                                           Intel,  Raytfceon 4 Fair-child
                                         Intel, laytnaon ft Fairchiid
OfSOHPTIOayMJCCT
Mountain Vim Wall  18 NV18
Aojuifier Teat NEU Study Arm
Mountain Vi«M. CA
Vol.!

Mountain ViaM wad  18 (NV18)
Aquiftar Taat (NEW) study Araa
Mountain Via*, CA
Vol. II
                                                                                                           PACES
                                                                                                           30
                                                                                                                       400
124       06/29/87  Anthony lurgaaa
                    Solder Aaaoc.
                                           Clam Kiatnar
                                           EPA laaion 9
                                                                        Oaap Soil rnvmtioation 365
                                                                        Eaat Middlafiled (toad
                                                                        Mountain Vtaw, CA
                                  20
125       06/30/87  JMM ». Otivar
                    Phillip FitztMtar
                    Harding L
                                           Clam Kiatnar
                                           EPA Baflion 9
                                                                         Intal Soil Soring Data
                                                                         Mountain Viaw, CA
                                  2CO
126       07/00/87   Niddlaftald'EUia-Uhi
                    Coapaniaa
127      07/21/87   Gtann Kiatnar
                    EPA lagion 9
                                           EPA fagion 9
                                           John Maati
                                           Intal
                                                                        •I Vol. 1*3 I 9 Does 4 Vol. 2-
                                                                        8 (aviaad Matariala fn Racord
                                                                        (Vol. 4-8 Avail, at Mt. Viaw
                                                                        Public Lib. 4 EPA lagion 9.)

                                                                        Additional Oaap Monitoring
                                                                        Hal la
                                   2102
         07/21/87   Phillip Htzuatar
                    Harding tataon Aaaoe.
                                           Michaal Rosa
                                           Raythaon
                                                                         Tranaaittai of final Phaaa III
                                                                         Subaurfaca Invaatigation
                                                                         Report
                                   225
         07/24/87   John NaatarMn
                    Intal
                                           Glam Kiatnar
                                           EPA Region 9
                                                                         Intal Raaponaa  to EPA
                                                                         6/11/87 eoaawtta on Raaadial
                                                                         Invaatigation
                                   41
 <0       08/04/87   John Naa
                    Intal
                                           Clam Kiatnar
                                           EPA Ragion 9
                                                                        Additional Oaap Monitoring
                                                                        Ualla
         08/04/87   Jeff Zalikaon
                    EPA Ragion 9
                                          Oava Oaardorf
                                          Raythaon
                                                                         Vapor Extraction Work
11/87   Kant KltehingMn
        EPA Ragion 9
                                                    A*y Ziaphar
                                                    EM Ragion 9
                                                                           Ravian of Analytical Data

-------
KVISION DATE: 05/22/89                                 .        .                                        PACE: 13
                                                         m Arw
                                             Noutuin Vf«n. California
oocf     OATJ    nKn/amuimTiai              To/aMamzATiai                oesctiprttti/auMgeT              PACES
133      00/00/00                                                            Orgwie OtMical AmlyvU         2

-------
 i>»0* MO.    - i
 12/29/88
                                     Niddlefieid-eiila-ttieaan ATM Superfund Sit*
                                              Mountain Vf«f, California
                                             AOMIHISTRATIVf RECORD INMX
ooc. *
              OATI
                FRON/OKAJIfZATiaN
                           TO/atfiANIZATION
                                                                                                               PACES
10
tt
12
           11/14/86
           03/02/87
           11/01/87
           12/04/87
           01/04/88
           01/00/88
           01/27/88
           02/00/88
           02/04/88
02/08/88
03/03/88
03/10/88
                     N. Oliver
               JMM a. MeClur*
               Harding LaMMn
               Associate*

               Stevo Doorijcvic
               Canoni*
               Environaantal

               Canonic
               Harding LaMon
               icr •
               C.I. Bostic
               Fairdiild Corp.

               Keith A. Takat*
               EPA Region 9

               Canonic
61am I. Klatnar
EPA Region 9


David P. Nodflutft
Harding LaMaon

^•nnia L. Curran
Canoni*
C.t. toacte
Pairdiitd
                         O»ft lagion 9
                         C.t. loatfe
                         Fairdiild
                         Saarieonduetor Corp.
                         EPA
                         Caap Or****r A
                         NcCa*. Inc.  ' .

                         Glam I. Kiatnar
                         EPA Region 9

                         C.I. tactic
                         Feirenild

                         EPA Region 9
C.I. tactic
Fairdiild

RaytlMon
                                                  Clem I. Kfatner
                                                  EPA Region 9
Clam I. Klatner
EPA Region 9
                        Tednical Nam Franeia Uell
                        TIM Series Teat RI/FS
                        Siltee Area Uatar Quality Data
                        On-Site Coneantrations of Metals
                        in Ground Uatar

                        Occurrence of Antiacny, Arsenic,
                        Cadaiue and Lead in PUbticty
                        Saapled Water Supply Uclls and
                        Water Siaiply Syataw. Santa
                        Clara Cowty, CA.  RI/FS
                                                                                        (Draft)
                        Ltrj Aduiniatrativc Record for
                        ROD

                        Ltr: ua* the Upper Aquifers (A t,
                        I) in Nt. View
Report: Rexendea Well  23C*2
Pusping Test Fairdiild Nt. View
Facility

Ltr re: Adainiatrative Record
for the Sit*

Soil Vapor Extraction Study
Ltr: Monitoring Wall Locations
and Screen Intervale, Additional
•gi- Walla North of tayanore

Report: Potential Conduits Study
        dietion laundery
                                       37
                                                                                                       26
                                                                                        187
                                                               228
                                                               127
260

-------
Paae MO.
12/29/88
ooc. •
13
14
15
16
17
18
19
20
21
22
23
24
25
26
•2
OATH
03/11/88
03/11/88
03/24/88
04/04/88
04/05/88
04/05/88
04/06/88
04/14/88
04/15/88
04/25/88
04/27/88
05/09/88
05/18/88
05/20/88
Niddlefield-EUIs-UMsssfl Ares Sup
Mountsln View, Californi<
ADMIMISTRATlVf RECORD IMDI
Tupplsssnt He. 1
FRON/ORCAMIZATIOM
Intel. Feirchild t
Intel, Feirchild A
Raytheon
Erie 6. Lappala
Harding LaMeon
Erie 6. Lappala
Harding Lemon
Clem R. Kietner
EPA Region 9
C.R. Bostie
Feirchild
Jess* C. NcClurs
Harding Lawson
Canonie
Oemis L. Curran
Canonie
Ctem R. Kietner
EPA Region 9
Intel
C.R. Bostie
Feirchild
* *
Clem 8. Kistner
EPA Region 9
Otein Ping Kao
CDHS
TO/ORGAHIZATIOM
EPA Region 9
EPA Region 9
'Intel. Feirchild A
Intel. Feirchild A
Raytheon
C.R. Bostie
Fairchild
Clam R. Kistner
EPA Region 9
C.R. Beetle
Feirchild
EPA Region 9
C. Robert Bostie
George Cut leg*
Clem R. Kistner
EPA Region 9
Roger B. James
Regional Uster
Quality Control
Boerd
%£?*"*
Helen McKlnley
EPA Region 9
     OeSCRIPTItt/SUBjeCT
Selection of Netele of Concern
         on
Ltr: CON Modeling for the RI/FS
Ltr: 3/3/88 Meeting with COM On
Modeling For the RI/FS

Itr: EPA Review of the
•Potential Conduit* Study and
(eradiation Boundary Report",
3/88

Itr: Computer Modeling for the
eite
Utr:
3/88
             of Activities  for
Water Quality Test Remits

Ltr: Monthly Statue Report 3/88


Ltr: Data Validation
Ltr: Response to Specific RI
Report Coswnts by EPA

Seeiemuel Status Report:
Feirchild 7/1/87 • 12/31/87
Ltr: Response To Companies'
Letter On OroundMoter Modeling

Ltr: State ARAM for the site
                                    PAffiS
                                        18

                                         1
                                       180

-------
r-eae Mo.
12/29/88
ooc. *
27
28
29
30
31
32
33
34
35
• 3
OATI
06/14/88
06/15/88
06/24/88
07/05/88
07/11/88
08/08/88
08/12/88
09/02/88
10/12/88
Niddlefield-Ellis-Uhisman Are* Superfund Sit*
Mountain View, California
ADMINISTRATIVE RECORD IMDCX
FROM/ORGANIZATION
Eric 8. Lappala
Harding Laueon
George A. Gullag*
Dennis L. Curran
Canonie
C.R. Boatie
Fairchild
George R. Gultage
Raythaon
Phil Betel
EPA Region 9
Gtcm R. ristner
EPA Region 9
1C* • Claaant
C. R: Bostie
Fairchild
TO/QMANIZATIOM
Intel, Fairchild ft
Raythaon
Glenn R. Clstner
EPA Region 9
C.R. Bostic
Fairchild
Gtam R. Ktstner
EPA Region 9
Gtam R. Kistner
EPA Region 9
Gaorga Gullaga
Raythaon
Gaorga Gullaga
Raytheon
Caap Oraaaar ft MeJCee
Steven R. Ritchie
Regional Water
OCSOMPTIOM/SUUCCT
Ltr: Requirements for Additional
Information to Adequately Review
Ground-Water Flow and Transport
Modeling Performed by ON
Ltr: Rl Report • 6/15/88
Revision RI/FS
Ltr: Information Needed on COM
Silva Well Model
Ltr: COM Modeling Reports
Ltr: Preliminary Responses to
EPA Comments on FS
Ltr: Approval Of 6/15/88 RI
Report
Ltr: Camp Oreasar and McKee's
Grounduater Modeling
Endangarmmnt Aasaaammnt
Semiannual Status Report:
Feirchild 1/88 • 6/88
36
37
38
39
10/21/88


11/01/88


11/01/88



11/01/88
                                                   Quality Control
                                                   Beard
 Caap Orasaar i Me*


 Glenn R.  Kistnar


 EPA Ragion 9

I

 Canonia
:*a     EPA
       Fairehild, Intel ft
       Raythaon
Evaluation of Potential Conduits
in the Local Study Area

Guidance Documents For
Administrative Record

Fact Sheet: EPA Announces
Proposed Plan to Clean Up N-E-W
Suparfund Si tea

Draft Rpt: Feasibility Study,
M-E-W Area, Nt. Via*, CA
                                                                                                                PACES
                                                                                                                   13
215

123




 22
                                                                        10
                                                                      1100

-------
P99* «0.     *                                       •
12/29/88
                                   Niddlof tot •opart for *•!-« Arm, Nf.
                                                                        Vfow, 6A. trtth Cavmta

-------
 Pag* No.
 05/25/99
                                        N1ddlaf(eld-CUIs-Uiia*an Suparfund Sit*
                                              Mountain view, California
                                             AMINISTRATIW HOMO  INMX
                                                              Mo. 2
   OATI
OOC. f
       AUTHOR
                                      RfCIPIWT
     oescti»TioM/SMjtcT
                                                                                                              PAGES
 02/01/86
 02/01/86
 02/01/86
 OS/01/86
 07/07/86
07/21/86
07/28/86
 EPA-9
EPA-9
RoMdial Raspanso
Peogra*)

EPA-9
RaMdial Ri
                 0.00
  1.00
  2.00
  3.00
  4.00 " EPA-9
5.00     Nicnael Kant
         Research Assoc.
         Citizens for a
         Better Environment

6.00     Chat Leudmar
         Oirector •
         Facilities Planning,
         tnt'l Ops..  Si Itec
         Corp

7.00     Tad Saitft
         Executive Director
         Silicon Valley
         Toxic* Coalition
                                   lobart Starn
                                   EPA CoHJiity
                                   Satationa
                                   Coordinator EPA-9

                                   Ctam Kiatnar
                                   EPA-9
                                   Rotaart Starn
                                   EM Co*B«iity
                                   Ralation*
                                   Coordinator EPA-9
                                                         Guidanea Oocuamt* for              1
                                                         AdBiniatrativ* Racord

                                                         Motional Prioritiaa Liat (NPl)       28
                                                         Sit* Raythaon Corp., Mtn. vitw,
                                                         CA

                                                         National Prioritiaa Liat (HPL)       24
                                                         Sit*, Intal Corp., Ntn.  Viaw, CA
                                                         National Prioritia* Liat (NPl)       10
                                                         Sit* fairchitd Canra «
                                                         Inatruaant Corp., Ntn. Viaw,  CA
                                                                        IMU92
                                                           ContaMination Fowd  in Ntn.
                                                           Vlaifa 0*ap Aquifar. w/aap.
                                                          on Fairehild
                                                 ToBJcondigror Intaria Ri
                                                 Action Proposal.
                                                                                                    lial
                                                 Coananta on "Intari* Reaadial
                                                 Actiona, Farichild Sa*iconauctor
                                                 Corporation, Ntn.  Viaw Facility
                                                 • Draft Report by  Canoni* 6/86
                                                          on Fairchild
                                                 SOBrfconductor Intaria) Claanup
08/22/86
10/01/86
01/09/88
 8.00
 8.10
 8.90
                             •agion 9
CDN
Olanm NcKann*
Santa Clara, Soard
of SiBiarvlMr
                         Ot*t Uuchmr
                         Slltw
                                 Gtam Klatnar
                                 EPA Rnion 9
                                                         ttn Raspona* to 7/21 ft 08/07/86
                                                         Ltr. about Fairenild Slurry wall

                                                         Soil Stapling ft Tank Inventory
                                                         Data Compilation.
Ltr:
Plan
on til* Claan-up
                                     153

-------
 Page NO.
 05/25/89
   DATE
OOC. f
                                        MloWefloloVEUfa-VMaaan Superfund Sit*
                                               Mountain View, California
                                              ADMINISTRATIVE RECORD INDEX
                                                    tupplaaant No. 2
                 AUTHOR
                                                       RECIPIENT
                                                                                 DESCRIPTION/SUBJECT
                                                                                                                PAGES
•02/04/88         9.00     C.  Retort loatic
06/01/88        10.00     Lorsnce 0. Wilson
                          Santa Clara Valley
                          Water Oiatrict

06/15/88        11.00     Clem Kistner
                          RPN
                          EPA-9

06/22/88        12.00     Roger • Joan
                          Executive Officer
                          CRMC8-SF
                                   Glorm t. Kistner
                                   CM Region 9
                                                   Clam R. Kistner
                                                   EM Region 9
                                                   George Cullage
                                                   Proj. Coordinator
                                                   Ratftaon Co.

                                                   Philip label
                                                   EPV9
                                                           Interis) Decision Procasa
                                                           Potential Conduits fvaluation
                                                           Rpt Mitfi cower latter

                                                           Ltr: Closure of Fransia * Silve
                                                           Uella
                                                            General  Coajaenta on Draft  FS for
                                                            NEW Study Area, M/TL  to George
                                                            Gullage  6/15/88
                                                                     on the MEW Feaaibility
                                                            Study by Canonio  5/3/88
 06/24/88
06/28/88
09/00/88
 13.00
          Glenn Kfstner
          RPN
14.00     NEC Electronics.
          Inc.
15.00     Geraghty t Miller
                                                  George Gullage
                                                  Pro/. Coordinator,
                                                  MEW Study Area,
                                                  Rayttieon Coapeny
                                                            EPA Ccaaawtta On The MEW              10
                                                            Feasibility Study W/TL  to George
                                                            Gullage 7/24/88
                                                            Technieai  Review Coaaants            21
                                                            Raaadial Investigation Report
                                                            Rt/PS NEW Area,  Mtn.  View  CA
                                                            M/LTR to Glenn Kistner 6/28/88.
                                                            M/cherts A
                                                                            Intel RI/EA/FS Vol. 1-4 with
                                                                                 letter
                                                                                                   2000
09/14/88        16.00     George A. Gullage
                          Raythecn

09/15/88        17.00     lie* Robison
                          l«f. I • Toxle
                          .Sutetancea Control
                          Olvieon
                          CAOONS

10/00/88        18.00     Canonle
10/13/88        19.00     George A. Gullage
                                   Glam Kistner
                                   EM teflon 9

                                   Glenn Cistner
                                                           Ltr: CoaBsnta on Final Draft
                                   Nark Harris
                                   City of Nt. View
                                                           CAOONS Cnaaann on NEW Draft FS
                                                           Report 8/16/88 Revision
                                                           Rpt: Saapling Man Addandua No.
                                                           2 walker Drive  Investigation
                                                           Rf/FS

                                                           Ltr: A auaawy  of MTI8 •§• and
                                                           •Veep* Aquifer  Monitoring
                                                           Activities with a Distribution
                                                           List

-------
Pag* NO.
05/33/89
  OAte
               ooc. *
                                       Nlddlefleld-Ellta-uMaaan Superfund SfM
                                              Mountain View. California
                                             AMMISTUTIVI RECORD INDEX
                                                   SuppieMnt Me. 2
                                AUTHOR
                             RECIPIENT
                              OCSOUPTlOH/SUMfCT
                                                                                                              PACES
10/13/88
10/19/88
10/21/88
10/23/88
10/2S/88
                20.00     Clem KUtner
                          CM legion 9
                21.00
                21.10
Steve Nor**
CRMCI

CBN
                22.00     Terrenee J.  NcManua
                          Intel

                23.00     Bryan N. Rector
                        Gaorg* A. Guilf
                        Raytheon
Clem Klatner
EM Region 9
                        Philip Sobel
                        EPA Region 9

                        Clem Kfctner
                        EPA Region 9
Cower Ltr of Seep*ing Plan
AoMnBLaW No* 2 tfftti •
Oistribucion list

Itr: Draft «, 10/07/88 Reviaion
                        Evaluation of Potential Conduit*
                        in the Local Stuay Area, MEW
                        (Update of 5/9/88 Oocuaent).

                        Itr: Roqueat to CaMent on
                        RI/EA/FS A Sign Separate ROD

                        Intel Nt. Vfew Ground Uater Data
                        laa* Rpt. Froai 10/86 • 7/88
                        attached with Lab Analytical
                        Rpta, Cover letter, Airbill,
                        Tranaarittal Letter
                                       850
 11/00/88

 11/10/88
11/21/88
11/23/88
11/25/88
12/01/88
               24.00     EPA

               25.00     Clam R. Kfatner
                         EPA Region 9
               26.00     C. Robert 8o*tic
                         Schluaborger

               27.00     Phil tobet
                         EPA Region 9

               28.00     Clem Klatner
                         EPA legion 9
               29.00     Ceorge Cullage
                        Public

                        Ceorge Gullage
                        Raytheon
                        Philip Babel
                        EPA Region 9

                        George Culleg*
12/02/88
               30.00     Clam R. Kfatner
                         EPA legion 9
                        Clem Staber
                        CA Off fee of
                        Pleming 4 tee«arcn

                        Qlem Kfatner
                        EPA Region 9
                        Ceorge Culleg*
                        Feet StMet

                        Ltr: Approval of Sampling Plan
                        Addandua Mo. 2 Walker Drive
                        Inveatigation Rf/FS But Mot of
                        Objective of the Plan

                        Ltr: Intel'* RI/EA/FS for Lot
                        & Concern about Separate ROD

                        Ltr: Approval of Reviled FS
                        under S Caveat*
                        Ltr: Cover Ltr of FS for
                        Itr: Confirmation of the
                        Saeplfng Plan Addandu* Mo. 2
                        Walker Oriv* Inveatigation,
                        RI/FS, with a Ofatributfon Li*t

                        Ltr: Roua* of Crounduater

-------
 Pag* Ho.
 05/25/89
   OATI
MC. •
                                       mddl*fl*ld-Cllfs-Uii*BBn Sunerfund sit*
                                              Mountain vie*. California
                                                                  i
                                                             No. 2
RECIPIENT
                                                                                                              PACES
 12/09/88        31.00     Cordon C. Atkinson
                          Coolcy CodMsrd
                          CMtro Huddleson ft
                          ran*
                                   David He*
                                   CM Region 9
                   ttr: Intel's If/IA/rs Lot IS *
                   Separata MO
12/14/88
12/14/88
12/14/88
12/21/88
01/04/89
01/04/89
01/09/89
01/10/89
01/17/89
01/17/89
32.00
33.00
34.00
35.00
36.00
37.00
38.00
40.00
41.00
42.00
Susan Nisbet
Crangla ft Assn.
Laura T. Tarquinio
League of Uoaan
Voters
Nlchele I. Corash.
Morrison ft Foerstar
•«
Gordon P. Snoit
Th* Resources Agency
of CA
George A. Cull age
Raytheon
Margaret R. Oollbeua
Folgor ft Levin
George A. Gull age
Raytheon
Phil label
EPA Region 9
PHI I label
EPA Region 9

Clem Kistner
EPA Region 9
A*y Zispfer
EPA Region 9

Clem Ktstner
EPA Region 9
Clem I. Kistner
EPA Region 9
Clem Kistner
EPA Region 9
Clem R. Ktstner
EPA Region 9
TfM*CgWe) •)• MCMiVaUS
Intel
• ^M*4n^MMB
•Bytneon
CoBBunity Meeting
Ltr: CUBBSIU on the Proposed
Cleanup Plan
Ltr: Request Extension of
CoBBant Period on Draft FS
Water Elevation Rot.
Ltr: State has no cosBants on
SutaBittal of Technical Report
Extracted Grounduater Use
Ltr: Lltronix Meeds More Tine
Review Draft FS
Ltr: Propose Inter {• ReaBdial
Actions of OW-3 Cluster and
Packing of Silva Wall
Ltr: CoBBsnts on RI/FS/EA for
Intel Lot *3
Ltr: Authorization to work on
at th* OW-3 Well Cluster ft




FS
on
to


RA
                                                                                                                  81
01/18/89        43.00     Sanoy Olliga*            Clam Ktatnar
                          ABM  Research Canter     EPA Region 9

01/20/89        44.00     David C. Keahn           Clem Clstner
                          Air Products             EPA Region 9
                                                                                   and Treatment of
                                                                           CroundMter.
                                                            Ltr: On Behalf of NASA-
                                                                    n FS
                                                to
                                                            Ltr:  Cnaaancs on Draft FS and
                                                            Propose Selection of Raieoy for
                                                            th* Sit*

-------
      NO*
 05/25/89
  DAT!
01/20/89
01/20/89
01/23/89
01/23/89
01/23/89
01/23/89
01/23/89
01/23/89
01/23/89
01/23/89
01/24/89
01/24/89
DOC.
 45.00
 44.00
 47.00
 48.00
 49.00
 50.00
 51.00
 52.00
 53.00
 54.00
 55.00
 54.00
                                        Niddlefieid-€llls*VM*ean Staierfund Sit*
                                               Nouttaln VfoM, California
                                                                   I
                                                              •*. 2
AUTHOR
     RECIPIENT
Stanaly T. Meyers
SI I tec
Ware 4 Freiederich
Thoaas E. Hookane
Crosby, Heofey,
Roach 4 Nay
Steven R. Ritchie
CCUOCS-SF
Retort C. Ttioapeon
Grahoa 4- Jean
Jonathan S. Lao
Heller, Ehraan,
White 4 NeAuliffe
Carie Goodasn
NcKfmey
NcCutchen, Doyle,
Brown 4 Enersen
Robert S. Roaborouoh
Pilltbury, Madison 4
Sutro
Bert 0. Dome
Tracer
Louie* T. LOM
II S Dept. of Navy
Santa Clara Valley
8lem Kistner
EPA Region 9
atom Kietner
EPA Ration 9
Gtam Kiatnar
EPA Ration 9
Glam Kistner
EPA Ration 9
Glam Kistner
EPA Ret Ion 9
Glenn Kiatnar
EPA Ration 9
Gtem Klstnar
EPA legion 9
Glenn Klstnar
EPA Ration 9
Glam Kistner
EPA Ration 9
Glam Kistner
EPA Reflon 9
Glam Kistner
EPA Ration 9
Ltr: Caeaint on 81 (06/88) 4
Draft FS (11/88) and Propose
Cleanup Reaedy for the Sit*
Ltrj Coaaants of Renault 4
Handlay Group on Draft FS
Ltr: Coaaant on FS of Cleanup
Alternative on Behalf of
Sobratoto
Ltr: Coaaant on Proposed Cleanup
Plan
Ltr: Coaaants of Tri-Oata on
Draft FS
Ltr: Coaaants of NEC Electronics
on Draft FS Attached Mith
Technical Review Coaaants
* Ltr: Request RI/FS/EA (10/23/88)
to be Included in A.R.
Coaaants of Spectra-Physics on
Draft FS
Ltr: Coeaent on Draft FS And
Object Any Responsibility to
Pollute th* Sit*
C Meant! on Draft FS Attached
Mith Cover Ltr.
Ltr: Coaaant on Proposed Plan
Attached Mith Rocoeaandad
                          Vatar OlatHet
           V*r«ar
Tracer X-Ray Inc.
                                           Position of  Santa Clara Vallay
                                           Water District on IBM Raaadial
                                           Action Plan

                                           Rots Investigation of Soil
                                           Contaainatlon at 345 Nlddlefield
                                           Rd. Attached Mith Letter to
                                           Glam Kistner.
                                                                                                               PACES
                                                                                                17
                                                             13
                                                                  82

-------
 Pag* Mo.
 05/25/89
                                        Ntddlefield-illle-Wbiaaan Suparfund sit*
                                               Nountain View, California
                                              MNINISTMTIW RfOORD II
                                                              •a. 2
   OAT!
OOC. f
       AUTHOR
     RECIPIENT
                                                                                                                PAGES
 01/30/89
 01/31/89
 02/07/89
02/22/89
03/02/89
03/06/89
03/15/89
03/21/89
04/12/89
 57.00
 58.00
 59.00
 60.00
 61.00
62.00
63.00
64.00
65.00
Qlom I. Kfatner
CM legion 9

George A. Gut tag*
Nark RarHa
     of Nt. vi*M
Phil total
EPA legion 9

Philip label
atief-laaadial IP.
Superfund Prog.
EPA-9

George Gut tag*
Proj. Coordinator
laytheon Co.

EPA-9
6«org* Gut tag*
Proi. Coordinator
laythaon Co.

Gaorg* Gut tag*
Proj. Coordinator
layttwon Co.

Canoni*
fitam Klatnar
EPA lagion 9
Gaorg* Gut tag*
•aythoon

Tarry NeManua
NgT'Corearat*
Environaantat
Affairs, Intat Carp.

Oiatribution.
61am Kiatnar
6PA-9
Oiatribution
       Gut lag*
Proj. Coordinator
•artfcoon Co.
Ltrj Poraiaafon to Soal tha city
Park and lacraation wall

GroundMtar Laval Nonitori«ig<>C
Aquifar and Uatar Quality laault
• Sltva Watt ctuatar Attaehad
Covar Latter

Itr: Hotiea of Sealing Wells and
Liability for the Cost
Intat
                                                                                        a on NCV FS.
Public CIMHHIH on Nell Area FS
ttport M/TL to Glam Kistnar
3/2/89
         If: PhiIp
letter of 2/7/89
                         Environaantal  Hewat  EPA Plans  to
                         seat no Near-by Walla, (2)
                                                                                                  I'
Public Ccwinca on the MEW Area
FS leport M/TL to Glem Kistner
3/21/89.

lot: Walker Drive Investigation
•I/PS NEW Study Are* Ntn. View,
CA
                                                                                                                    19

-------
06/12/W
                                       Nloo'lefteld*EUt«-uhtaaan Suparfund sit*
                                              Mountain Vie*. California
                                             ADNHISTMTIVC KGOR0 IIBCX
                                                  SUppaUaant MO. S
OAT!
DOC.*
AUTHOR
OeSdtPTIOH/SUBJECT
PAGES
04/Z5/89       1 B«y ArM Air Quality           intar«t«d p*rti<
                           District
                                                                  Toxic Air Peiluum Source     SO
                                                                  Mnnaant Manual for
                                                                  California Air Pollution
                                                                  Control OiatHcta ("CAPCOA
                                                                  ouioanca*) Auguat 19«7.

                                                                  Uorkahop Notica: Propoaad      3
                                                                  ••aulacion 8, tula 4o. Air
                                                                  Stripping ft Soil Vapor
                                                                  Extraction Operation.
   Total

-------