EPA Superfund Record of Decision: Tracy Defense Depot (USARMY) EPA ID: CA4971520834 OU 01 Tracy Ca 04/14/1998


                                    EPA/ROD/R09-98/030
                                    1998
EPA Superfund
     Record of Decision:
     TRACY DEFENSE DEPOT (USARMY)
     EPA ID: CA4971520834
     OU01
     TRACY, CA
     04/14/1998

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EPA 541-R98-030


                                    FINAL

            DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN  (DDJC), TRACY SITE
                              TRACY, CALIFORNIA

                 SITE-WIDE COMPREHENSIVE RECORD OF DECISION

                                VOLUME 1 OF 2
                                    (TEXT)



                                Prepared for:

                        U.S. Army Corps of Engineers
                       Engineering and Support Center
                             Huntsville  (CEHNC)
                           4820 University Square
                       Huntsville, Alabama 35816-1822
                              Attn: CEHNC-PM-ED

                                 Prepared by:

                             Radian International
                          10389 Old Placerville Road
                         Sacramento, California 95827

                                 April 1998

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                         TABLE OF CONTENTS - TRACY ROD
                                                                                          Page

DECLARATION FOR THE RECORD OF
DECISION	D-l
      D.I   Site Name and Location	D-l
      D. 2   Statement of Basis and Purpose	D-l
      D.3   Assessment of the Site	D-l
      D.4   Description of the Remedy	D-l
      D. 5   Statutory Determinations	D-l

DS.O  DECISION SUMMARY	DS-1
DS.l  SECTION 1.0: SITE DESCRIPTION	DS-1
DS . 2  SECTION 2.0: SITE HISTORY AND ENFORCEMENT ACTIVITIES	DS-1
DS.3  SECTION 3.0: HIGHLIGHTS OF COMMUNITY PARTICIPATION	DS-1
DS.4  SECTION 4.0: SCOPE AND ROLE OF THE RESPONSE ACTION	DS-1
DS . 5  SECTION 5.0: SUMMARY OF SITE CHARACTERISTICS	DS-1
DS . 6  SECTION 6.0: SUMMARY OF SITE RISKS	DS-2
DS . 7  SECTION 7.0: DESCRIPTION OF ALTERNATIVES	DS-2
DS.8  SECTION 8.0: COMPARATIVE ANALYSIS OF ALTERNATIVES	DS-2
      DS . 8 .1 Threshold Criteria	DS-2
      DS . 8 . 2 Primary Balancing Criteria	DS-2
      DS . 8 . 3 Modifying Criteria	DS-2
DS.9  SECTION 9.0: SELECTED REMEDY	DS-2
DS . 10 SECTION 10.0: STATUTORY DETERMINATIONS	DS-2
DS . 11 SECTION 11.0: REFERENCES	DS-3
DS . 12 SITE-SPECIFIC CROSS REFERENCES	DS-3

1. 0   SITE DESCRIPTION	1-1
      1.1    Site Location	1-1
      1. 2    Facility Description	1-1
      1. 3    Meteorology	1-1
      1. 4    Geology/Hydrology	1-1
      1. 5    Land and Water Use	1-2
      1. 6    Cultural and Historic Resources	1-2
2 . 0   SITE HISTORY AND ENFORCEMENT ACTIVITIES	,
      2.1    Preliminary Environmental Investigations, Records Search, and Initial
Investigations	2-1
             2.1.1   Soil Gas and Groundwater Sampling	2-1
             2.1.2   Industrial Waste Lagoons and IWPL Investigations	2-1
             CERCLA Activities	2-2
             2.2.1   Operable Unit 1 Remedial Investigation/Feasibility Study	2-2
             2.2.2   OU 1 Record of Decision	2-3
             2.2.3   OU 1 Well Monitoring Program	2-3
             2.2.4   OU 1 Well Abandonment Program	2-4
             2.2.5   OU 1 Remedial Action	2-4
             2.2.6   Comprehensive Remedial Investigation/Feasibility Study	2-4
             2.2.7   Selection of Sites for Feasibility Study	2-5
             2.2.8   Sites Studied for Feasibility of Remedial Action	2-5
             2.2.9   Sites Recommended for No Further Action	2-5
             2.2.10  Day Care Center	2-6
             2.2.11  Proposed Plan	2-6
             Non-CERCLA Investigations	2-6

3.0   HIGHLIGHTS OF COMMUNITY PARTICIPATION	3-1

4 . 0   SCOPE AND ROLE OF THE RESPONSE ACTION	4-1

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5 . 0   SUMMARY OF SITE CHARACTERISTICS	5-1
      5 .1    Background	5-1
      5.2    Groundwater	5-2
      5.3    Soil	5-3
      5 . 4    Group A	5-4
             5.4.1   SWMU I/Area 2—Old Sewage Lagoon/Drum Storage Area (Group A)	5-4
             5.4.2   Area 1 Building 237 (Group A)	5-6
             5.4.3   Area 3—Drum Storage Area (Group A)	5-8
      5.5    Group B	5-10
             5.5.1   SWMU 4—Storm Drain Lagoon (Group B)	5-10
             5.5.2   SWMU 6—Building 28 Sump (Group B)	5-13
             5.5.3   SWMU 7—Burn Pit No. 1 (Group B)	5-15
             5.5.4   SWMU 8—Burn Pit No. 2 (Group B)	5-17
             5.5.5   SWMU 20: Aboveground Solvent Tank and Area 1 Building 10 (Group B)....5-19
             5.5.6   SWMU 24 — Petroleum Waste Oil Tank (Group B)	5-21
             5.5.7   SWMU 27—Building 206 Roundhouse Sump/Area 1 Building 206 (Group B)...5-23
             5.5.8   Building 30 Drum Storage Area (Group B)	5-25
             5.5.9   Surface and Near-Surface Soils-Northern Depot Area (Group B)	5-27
      5. 6    Group C	5-29
             5.6.1   SWMU 2—Sewage Lagoons and SWMU 3 — Industrial Waste Lagoons	5-29
             5.6.2   SWMU 3 — Industrial Waste Lagoons	5-31
             5.6.3   SWMU 33 — Industrial Waste Pipeline (Group C)	5-33
      5.7    No Further Action	5-35
             5.7.1   SWMU 5—Old Industrial Lagoon,  Building 255  (No Further Action)	5-35
             5.7.2   SWMU 9—Subsistence Waste Pit (No Further Action)	5-37
             5.7.3   SWMU 10—Medical Waste Burial Pit (No Further Action)	5-38
             5.7.4   SWMU 10A—Possible Medical Waste Burial Pit  (No Further Action)	5-39
             5.7.5   SWMU 11—Burial of Lime/Foot Bath (No Further Action)	5-41
             5.7.6   SWMU 12—Embalming Fluid Dump (No Further Action)	5-42
             5.7.7   SWMU 14—Lube Oil Dump (No Further Action)	5-43
             5.7.8   SWMU 15 — Pesticide Waste Trench (No Further  Action)	5-44
             5.7.9   SWMU 16—Possible Waste Disposal Area (No Further Action)	5-45
             5.7.10  SWMU 21—Battery Acid Dump (No Further Action)	5-46
             5.7.11  SWMU 22—Previous Hazardous Materials Storage Area(No Further Action).5-47
             5.7.12  SWOU 23—Building 26 Recoup Operations (No Further Action)	5-48
             5.7.13  SWMU 25—Boundary Roads (No Further Action)	5-49
             5.7.14  SWMU 29—Used Motor Oil Pit (No Further Action)	5-50
             5.7.15  SWMU 30 — Salvage Area (No Further Action)	5-51
             5.7.16  SWMU 31—Wood Preservation Area (No Further  Action)	5-52
             5.7.17  SWMU 64—Waste Oil Pit (No Further Action)	5-53
             5.7.18  Area 1 Building 236 (No Further Action)	5-54
             5.7.19  Building 15 Drum Storage Area (No Further Action)	5-55
             5.7.20  Building 22 Drum Storage Area (No Further Action)	5-56
             5.7.21  Building 23 (No Further Action)	5-57
      5.8    Day Care Center (Excavation and Disposal—Time Critical Removal Action)	5-58

6 . 0   SUMMARY OF SITE RISKS	6-1
      6.1    BRA Methodology	6-1
      6. 2    Identification of COPCs for Humans	6-1
             6.2.1   Current and Future Land Use	6-1
             6.2.2   COPCs and Media of Concern	6-2
      6. 3    Human Exposure Assessment	6-2
             6.3.1   Human Receptors and Exposure Pathways	6-2
             6.3.2   Exposure Concentrations	6-2
             6.3.3   Assumptions Used to Calculate Chemical Exposure	6-2
      6. 4    Human Toxicity Assessment Associated with COPCs	6-3
      6. 5    Human Risk Characterization	6-3
      6. 6    Ecological Risk Assessment	6-6
             6.6.1   Background	6-6
             6.6.2   Identification of COPECs	6-6
             6.6.3   Exposure Assessment	6-6
             6.6.4   Toxicity Assessment	6-7
             6.6.5   Risk Characterization	6-7

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      6.7    Evaluation of Threats to Groundwater Quality	6-8
      6. 8    Conclusion	6-8

7 . 0   DESCRIPTION OF ALTERNATIVES	7-1
      7 .1    General Overview	7-1
      7 . 2    Applicable or Relevant and Appropriate Requirements	7-1
             7.2.1   Background	7-1
             7.2.2   Definition of ARARs and Other Criteria or Guidelines to be Considered.7-1
             7.2.3   Identification of ARARs	7-2
             7.2.4   Chemical-Specific ARARs	7-2
             7.2.5   Location-Specific ARARs	7-3
             7.2.6   Action-Specific ARARs	7-3
             7.2.7   Identification of Other Guidance and Criteria to be Considered	7-6
      7 . 3    Operable Unit 1 Groundwater	7-7
             7.3.1   Background	7-7
             7.3.2   Remedial Action Obj ectives	7-10
             7.3.3   Remedial Alternatives	7-10
      7 . 4    Group A Sites	7-10
             7.4.1   Remedial Action Obj ectives	7-10
             7.4.2   Remedial Alternatives	7-10
      7 . 5    Group B Sites	7-10
             7.5.1   SWMU 4 - Storm Drain Lagoon	7-11
             7.5.2   SWMU 6 - Building 28 Sump	7-11
             7.5.3   SWMU 7 - Burn Pit No. 1	7-11
             7.5.4   SWMU 8 - Burn Pit No. 2	7-12
             7.5.5   SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and
                     Area 1 Building 10	7-12
             7.5.6   SWMU 24 - Petroleum Waste Oil Tank	7-13
             7.5.7   SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206	7-13
             7.5.8   Building 30 Drum Storage Area	7-14
             7.5.9   Surface and Near-Surface Soils - Northern Depot Area	7-14
      7 . 6    Group C Sites	7-14
             7.6.1   SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons	7-15
             7.6.2   SWMU 33 - Industrial Waste Pipeline	7-15
      7.7    No Further Action Sites	7-15

8 . 0   COMPARATIVE ANALYSIS OF ALTERNATIVES	8-1
      8 .1    Background	8-1
      8.2    Analysis of Remedial Alternatives for OU 1 Groundwater	8-1
             8.2.1   Remedial Alternatives	8-1
             8.2.2   Overall Protection of Human Health and the Environment	8-2
             8.2.3   Compliance with ARARs	8-2
             8.2.4   Long-Term Effectiveness	8-3
             8.2.5   Reduction of Toxicity,  Mobility, and Volume through Treatment	8-3
             8.2.6   Short-Term Effectiveness	8-3
             8.2.7   Implementability	8-3
             8.2.8   Cost	8-3
             8.2.9   State and Community Acceptance	8-3
      8 .3    Analysis of Remedial Alternatives for the Group A Sites	8-4
             8.3.1   Remedial Alternatives	8-4
             8.3.2   Overall Protection of Human Health and the Environment	8-4
             8.3.3   Compliance with ARARs	8-4
             8.3.4   Long-Term Effectiveness	8-5
             8.3.5   Reduction of Toxicity,  Mobility, and Volume through Treatment	8-5
             8.3.6   Short-Term Effectiveness	8-5
             8.3.7   Implementability	8-5
             8.3.8   Cost	8-5
             8.3.9   State and Community Acceptance	8-5
      8.4    Analysis of Remedial Alternatives for SWMU 4--Storm Drain Lagoons	8-6
             8.4.1   Remedial Alternatives	8-6
             8.4.2   Overall Protection of Human Health and the Environment	8-6
             8.4.3   Compliance with ARARs	8-6
             8.4.4   Long-Term Effectiveness	8-6

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      8.4.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-6
      8.4.6    Short-Term Effectiveness	8-7
      8.4.7    Implementability	8-7
      8.4.8    Cost	8-7
      8.4.9    State  and Community Acceptance	8-7
.5     Analysis of Remedial Alternatives  for SWMU  6—Building  28  Sump	8-7
      8.5.1    Remedial  Alternatives	8-7
      8.5.2    Overall Protection of  Human  Health  and  the Environment	8-8
      8.5.3    Compliance with ARARs	8-8
      8.5.4    Long-Term Effectiveness	8-8
      8.5.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-8
      8.5.6    Short-Term Effectiveness	8-8
      8.5.7    Implementability	8-8
      8.5.8    Cost	8-8
      8.5.9    State  and Community Acceptance	8-9
      Analysis of Remedial Alternatives  for SWMU  7—Burn Pit  No. 1	8-9
      8.6.1    Remedial  Alternatives	8-9
      8.6.2    Overall Protection of  Human  Health  and  the Environment	8-9
      8.6.3    Compliance with ARARs	8-10
      8.6.4    Long-Term Effectiveness	8-10
      8.6.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-10
      8.6.6    Short-Term Effectiveness	8-10
      8.6.7    Implementability	8-10
      8.6.8    Cost	8-10
      8.6.9    State  and Community Acceptance	8-11
.7     Analysis of Remedial Alternatives  for SWMU  8—Burn Pit  No. 2	8-11
      8.7.1    Remedial  Alternatives	8-11
      8.7.2    Overall Protection of  Human  Health  and  the Environment	8-11
      8.7.3    Compliance with ARARs	8-11
      8.7.4    Long-Term Effectiveness	8-12
      8.7.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-12
      8.7.6    Short-Term Effectiveness	8-12
      8.7.7    Implementability	8-12
      8.7.8    Cost	8-12
      8.7.9    State  and Community Acceptance	8-12
.8     Analysis of Remedial Alternatives  for SWMU  20--Aboveground
      Solvent Tank/Building 26 Recoup Operations  and  Area  1 Building  10	
      8.8.1    Remedial  Alternatives	
      8.8.2    Overall Protection of  Human  Health  and  the Environment	
      8.8.3    Compliance with ARARs	
      8.8.4    Long-Term Effectiveness	8-14
      8.8.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-14
      8.8.6    Short-Term Effectiveness	8-14
      8.8.7    Implementability	8-14
      8.8.8    Cost	8-14
      8.8.9    State  and Community Acceptance	8-14
      Analysis of Remedial Alternatives  for SWMU  24 — Petroleum Waste  Oil Tank	8-14
      8.9.1    Remedial  Alternatives	8-14
      8.9.2    Overall Protection of  Human  Health  and  the Environment	8-15
      8.9.3    Compliance with ARARs	8-15
      8.9.4    Long-Term Effectiveness	8-15
      8.9.5    Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-16
      8.9.6    Short-Term Effectiveness	8-16
      8.9.7    Implementability	8-16
      8.9.8    Cost	8-16
      8.9.9    State  and Community Acceptance	8-16
.10    Remedial Alternatives for SWMU 27—Building 206 Roundhouse Sump/Area  1
      Building 206	8-17
      8.10.1   Remedial  Alternatives	8-17
      8.10.2   Overall Protection of  Human  Health  and  the Environment	8-17
      8.10.3   Compliance with ARARs	8-17
      8.10.4   Long-Term Effectiveness	8-17
      8.10.5   Reduction of Toxicity,  Mobility,  and Volume  through  Treatment	8-17

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             8.10.6  Short-Term Effectiveness	8-18
             8.10.7  Implementability	8-18
             8.10.8  Cost	8-18
             8.10.9  State and Community Acceptance	8-18
      8.11   Analysis of Remedial Alternatives for Building 30  Drum Storage Area	8-18

             8.11.1  Remedial Alternatives	8-18
             8.11.2  Overall Protection of Human Health and the Environment	8-18
             8.11.3  Compliance with ARARs	8-19
             8.11.4  Long-Term Effectiveness	8-19
             8.11.5  Reduction of Toxicity,  Mobility,  and Volume through Treatment	8-19
             8.11.6  Short-Term Effectiveness	8-19
             8.11.7  Implementability	8-19
             8.11.8  Cost	8-19
             8.11.9  State and Community Acceptance	8-19
      8.12   Analysis of Remedial Alternatives for Surface and  Near-Surface Soil-Northern
             Depot Area	8-20
             8.12.1  Remedial Alternatives	8-20
             8.12.2  Overall Protection of Human Health and the Environment	8-20
             8.12.3  Compliance with ARARs	8-20
             8.12.4  Long-Term Effectiveness	8-20
             8.12.5  Reduction of Toxicity,  Mobility,  and Volume through Treatment	8-21
             8.12. 6  Short-Term Effectiveness	8-20
             8.12.7  Implementability	8-21
             8.12.8  Cost	8-21
             8 .12 . 9  State and Community Acceptance	8-21
      8.13   Remedial Alternatives for SWMUs 2 and 3—the Sewage and Industrial
             Waste Lagoons	8-21
             8.13.1  Remedial Alternatives	8-21
             8.13.2  Overall Protection of Human Health and the Environment	8-22
             8.13.3  Compliance with ARARs	8-22
             8.13.4  Long-Term Effectiveness	8-22
             8.13.5  Reduction of Toxicity,  Mobility,  and Volume through Treatment	8-22
             8.13.6  Short-Term Effectiveness	8-22
             8.13.7  Implementability	8-22
             8.13.8  Cost	8-22
             8.13.9  State and Community Acceptance	8-22
      8.14   Analysis of Remedial Alternatives for SWMU 33 — Industrial  Waste Pipeline
             8.14.1  Remedial Alternatives
             8.14.2  Overall Protection of Human Health and the Environment
             8.14.3  Compliance with ARARs
             8.14.4  Long-Term Effectiveness
             8.14.5  Reduction of Toxicity,  Mobility,  and Volume through Treatment	8-24
             8.14. 6  Short-Term Effectiveness	8-24
             8.14.7  Implementability	8-24
             8.14.8  Cost	8-24
             8.14.9  State and Community Acceptance	8-24

9 . 0   SELECTED REMEDIES	9-1
      9.1    Monitoring Program	9-1
      9.2    No Further Action Sites	9-2
      9. 3    Day Care Center	9-2
      9. 4    Cleanup Standards	9-2
      9.5    OU 1 Groundwater	9-2
      9. 6    Group A Sites	9-5
      9. 7    Group B Sites	9-7
             9.7.1   SWMU 4 - Storm Drain Lagoon	9-7
             9.7.2   SWMU 6 - Building 28 Sump	9-11
             9.7.3   SWMU 7 - Burn Pit No. 1	9-12
             9.7.4   SWMU 8 - Burn Pit No. 2	9-14
             9.7.5   SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and
                     Area 1 Building 10	9-16
             9.7.6   SWMU 24 - Petroleum Waste Oil Tank	9-18

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             9.7.7   SWMU 27 - Building 206 Roundhouse Sump and Area 1 Building 206	9-20
             9.7.8   Drum Storage Area - Building 30	9-22
             9.7.9   Surface and Near-Surface Soil - Northern Depot Area	9-23
      9.8    Group C Sites	9-24
             9.8.1   SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons	9-24
             9.8.2   SWMU 33 - Industrial Waste Pipeline (IWPL)	9-26
      9. 9    Five-Year Review Process	9-28
      9.10   Post-ROD Documents	9-28

10 . 0  STATUTORY DETERMINATIONS	10-1
      10 .1   Sites Recommended for No Further Action	10-1
      10 . 2   Statutory Reguirements	10-1
      10.3   Operable Unit (OU)  1 Groundwater	10-1
             10.3.1  Protection of Human Health and the Environment	10-1
             10.3.2  Compliance With ARARs	10-1
             10.3.3  Cost-effectiveness	10-2
             10.3.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-2
             10.3.5  Preference for Treatment as a Principal Element	10-2
      10 . 4   Group A Sites	10-2
             10.4.1  Protection of Human Health and the Environment	10-2
             10.4.2  Compliance With ARARs	10-2
             10.4.3  Cost-effectiveness	10-3
             10.4.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-3
             10.4.5  Preference for Treatment as a Principal Element	10-3
      10 . 5   SWMU 4—Storm Drain Lagoon	10-3
             10.5.1  Protection of Human Health and the Environment	10-3
             10.5.2  Compliance With ARARs	10-4
             10.5.3  Cost-effectiveness	10-4
             10.5.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-4
             10.5.5  Preference for Treatment as a Principal Element	10-4
      10. 6   SWMU 6—Building 28 Sump	10-4
             10.6.1  Protection of Human Health and the Environment	10-4
             10. 6.2  Compliance With ARARs	10-5
             10.6.3  Cost-effectiveness	10-5
             10.6.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-5
             10.6.5  Preference for Treatment as a Principal Element	10-5
      10.7   SWMU 7—Burn Pit No. 1	10-5
             10.7.1  Protection of Human Health and the Environment	10-6
             10.7.2  Compliance With ARARs	10-6
             10.7.3  Cost-effectiveness	10-6
             10.7.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-6
             10.7.5  Preference for Treatment as a Principal Element	10-7
      10.8   SWMU 8—Bum Pit No. 2	10-7
             10.8.1  Protection of Human Health and the Environment	10-7
             10.8.2  Compliance With ARARs	10-7
             10.8.3  Cost-effectiveness	10-7
             10.8.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-7
             10.8.5  Preference for Treatment as a Principal Element	10-8
      10.9   SWMU 20 Aboveground Solvent Tank Building 26 Recoup Operations
             and Area 1 Building 10	10-8
             10.9.1  Protection of Human Health and the Environment	10-8
             10.9.2  Compliance With ARARs	10-8
             10.9.3  Cost-effectiveness	10-8
             10.9.4  Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-8
             10.9.5  Preference for Treatment as a Principal Element	10-9
      10.10  SWMU 24 — Petroleum Waste Oil Tank	10-9

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             10.10.1 Protection of Human Health and the Environment	10-9
             10.10.2 Compliance With ARARs	10-9
             10.10.3 Cost-effectiveness	10-9
             10.10.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-9
             10.10.5 Preference for Treatment as a Principal Element	10-10
      10.11  SWMU 27—Building 206 Roundhouse Sump/Area 1 Building 206	10-10
             10.11.1 Protection of Human Health and the Environment	10-10
             10.11.2 Compliance With ARARs	10-10
             10.11.3 Cost-effectiveness	10-10
             10.11.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-10
             10.11.5 Preference for Treatment as a Principal Element	10-11
      10.12  Building 30 Drum Storage Area	10-11
             10.12.1 Protection of Human Health and the Environment	10-11
             10.12.2 Compliance With ARARs	10-11
             10.12.3 Cost-effectiveness	10-11
             10.12.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-12
             10.12.5 Preference for Treatment as a Principal Element	10-12
      10.13  Surface and Near-Surface Soils—Northern Depot Area	10-12
             10.13.1 Protection of Human Health and the Environment	10-12
             10.13.2 Compliance With ARARs	10-12
             10.13.3 Cost-effectiveness	10-12
             10.13.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-12
             10.13.5 Preference for Treatment as a Principal Element	10-13
      10.14  SWMUs 2 and 3 — Sewage and Industrial Waste Lagoons	10-13
             10.14.1 Protection of Human Health and the Environment	10-13
             10.14.2 Compliance With ARARs	10-13
             10.14.3 Cost-effectiveness	10-13
             10.14.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-13
             10.14.5 Preference for Treatment as a Principal Element	10-14
      10.15  SWMU 33 — Industrial Waste Pipeline (IWPL)	10-14
             10.15.1 Protection of Human Health and the Environment	10-14
             10.15.2 Compliance With ARARs	10-14
             10.15.3 Cost-effectiveness	10-14
             10.15.4 Utilization of Permanent Solutions, Alternative Treatment,
                     and Resource Recovery	10-14
             10.15.5 Preference for Treatment as a Principal Element	10-15

11.0
REFERENCES	11-1

                                       APPENDICES

Appendix A - Administrative Record File Index
Appendix B - Figures
Appendix C - SWMU 4 Technical Memoranda
Appendix D - Risk Calculations for SWMU 4
Appendix E - Well Monitoring Program
Appendix F - Analytical Methods and Reporting Limits Proposed for DDJC-Tracy Site-Wide
             Comprehensive Record of Decision
Appendix G - DI-WET Results and Recommendations for the Former Sewage and Industrial Waste
             Lagoons at DDJC-Tracy

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                         LIST OF TABLES

                                                                                        Page
D-l    Selected Remedies for Each Site at DDJC-Tracy	D-3
D-2    Detailed Components of Selected Remedies  for Sites  Requiring Action	D-4

DS-1   Maj or Topics by Site	DS-4

1-1    DDJC-Tracy,  Stratigraphic and Hydrostratigraphic Nomenclature	1-3

2-1    Background Of Solid Waste Management Units  and Soil Areas	2-7
2-2    Summary of Current Site Status,  DDJC-Tracy	2-10
2-3    Status of the UST Sites,  DDJC-Tracy,  Comprehensive  RI/FS  and UST  Site
       Investigations	2-15

3-1    DDJC-Tracy Public Meeting Attendees	3-2

5-1    Summary of Fate and Transport and Risk Data for SWMU I/Area  2	5-5
5-2    Estimated Volume and Mass of COCs in Soil for SWMU  I/Area  2	5-5
5-3    Summary of Fate and Transport and Risk Data for Area 1  Building 237	5-7
5-4    Estimated Volume and Mass of COCs in Soil for Area  1 Building  237	5-7
5-5    Summary of Fate and Transport and Risk Data for Area 3	5-9
5-6    Estimated Volume and Mass of COCs in Soil for Area  3	5-9
5-7    Summary of Fate and Transport and Risk Data for SWMU 4	5-12
5-8    Estimated Volume and Mass of COCs in Soil for SWMU  4	5-12
5-9    Summary of Fate and Transport and Risk Data for SWMU 6	5-14
5-10   Estimated Volume and Mass of COCs in Soil for SWMU  6	5-14
5-11   Summary of Fate and Transport and Risk Data for SWMU 7	5-16
5-12   Estimated Volume and Mass of COCs in Soil for SWMU  7	5-16
5-13   Summary of Fate and Transport and Risk Data for SWMU 8	5-18
5-14   Estimated Volume and Mass of COCs in Soil for SWMU  8	5-18
5-15   Summary of Fate and Transport and Risk Data for SWMU 20	5-20
5-16   Estimated Volume and Mass of COCs in Soil for SWMU  20	5-20
5-17   Summary of Fate and Transport and Risk Data for SWMU 24	5-22
5-18   Estimated Volume and Mass of COCs in Soil for SWMU  24	5-22
5-19   Summary of Fate and Transport and Risk Data for SWMU 27 and  Area  1  Building  206...5-24
5-20   Estimated Volume and Mass of COCs in Soil for SWMU  27 an Area  1 Building  206	5-24
5-21   Summary of Fate and Transport and Risk Data for Building  30  Drum  Storage  Area	5-26
5-22   Estimated Volume and Mass Of COCs in Soil for Building  30  Drum Storage Area	5-26
5-23   Summary of Fate and Transport and Risk Data for Northern  Depot Soils	5-28
5-24   Estimated Volume and Mass of COCs in Soil for Northern  Depot Area	5-28
5-25   Summary of Fate and Transport and Risk Data for SWMU 2	5-30
5-26   Summary of Fate and Transport and Risk Data for SWMU 3	5-32
5-27   Estimated Volume and Mass of COCs in Soil for SWMU  2 and  3	5-32
5-28   Summary of Fate and Transport and Risk Data for SWMU 33	5-34
5-29   Estimated Volume and Mass of COCs in Soil for SWMU  33	5-34
5-30   Summary of Fate and Transport and Risk Data for SWMU 5	5-36
5-31   Summary of Fate and Transport and Risk Data for SWMU 9	5-37
5-32   Summary of Fate and Transport and Risk Data for SWMU 10	5-38
5-33   Summary of Fate and Transport and Risk Data for SWMU 10A	5-40
5-34   Summary of Fate and Transport and Risk Data for SWMU 11	5-41
5-35   Summary of Fate and Transport and Risk Data for SWMU 12	5-42
5-36   Summary of Fate and Transport and Risk Data for SWMU 14	5-43
5-37   Summary of Fate and Transport and Risk Data for SWMU 15	5-44
5-38   Summary of Fate and Transport and Risk Data for SWMU 16	5-45
5-39   Summary of Fate and Transport and Risk Data for SWMU 21	5-46
5-40   Summary of Fate and Transport and Risk Data for SWMU 22	5-47
5-41   Summary of Fate and Transport and Risk Data for SWMU 23	5-48
5-42   Summary of Fate and Transport and Risk Data for SWMU 25	5-49
5-43   Summary of Fate and Transport and Risk Data for SWMU 29	5-50
5-44   Summary of Fate and Transport and Risk Data for SWMU 30	5-51
5-45   Summary of Fate and Transport and Risk Data for SWMU 31	5-52
5-46   Summary of Fate and Transport and Risk Data for SWMU 64	5-53

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5-47   Summary of Fate and Transport and Risk Data for Area 1 Building 236	5-54
5-48   Summary of Fate and Transport and Risk Data for Building 15 Drum Storage Area	5-55
5-49   Summary of Fate and Transport and Risk Data for Building 22 Drum Storage Area	5-56
5-50   Summary of Fate and Transport and Risk Data for Building 23	5-57
5-51   Summary of Fate and Transport and Risk Data for Day Care Center	5-58

6-1    Exposure Units, DDJC-Tracy	6-10
6-2    Summary of Current Pathways Evaluated in Detail	6-11
6-3    Summary of Potential Future Pathways Evaluated in Detail	6-12
6-4    Summary of Human Health Risks to Current Receptors,  DDJC-Tracy	6-14
6-5    Summary of Potential Health Risks to Future Receptors, DDJC-Tracy	6-16
6-6    Summary of Cancer Risks at EU 8	6-18
6-7    Summary of Risks at EU 10	6-19
6-8    COCs That Reguire Remediation for the Protection of Human Health	6-20
6-9    Basis for Soil Cleanup Standards to Protect Groundwater	6-21

7-1    Groundwater Chemicals of Concern: Detection Freguency, Remedial Decision Rationale,  and
       Risk Characterization, DDJC-Tracy	7-17
7-2    Remedial Alternatives for OU 1 Groundwater	7-35
7-3    Remedial Alternatives for SWMU I/Area 2, Area 1 Building 237 and Area 3	7-38
7-4    Remedial Alternatives for SWMU 4 - Storm Drain Lagoon	7-41
7-5    Remedial Alternatives for SWMU 6 - Building 28 Sump	7-43
7-6    Remedial Alternatives for SWMU 7 - Burn Pit No. 1	7-45
7-7    Remedial Alternatives for SWMU 8 - Burn Pit No. 2	7-48
7-8    Remedial Alternatives for SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup
       Operations and Area 1 Building 10	7-51
7-9    Remedial Alternatives for SWMU 24 - Building 247 Petroleum Laboratory Waste Oil
       Tank	7-54
7-10   Remedial Alternatives for SWMU 27 - Building 206 Roundhouse Sump/Area 1
       Building 206	7-58
7-11   Remedial Alternatives for Building 30 Drum Storage Area	7-60
7-12   Remedial Alternatives for Surface and Near Surface Soil - Northern Depot Area ....7-62
7-13   Remedial Alternatives for SWMUs 2/3	7-64
7-14   Remedial Alternatives for SWMU 33	7-66
7-15   No Further Action Sites	7-69

8-1    National Contingency Plan (NCP) Evaluation Criteria	8-25
8-2    Comparative Analysis of Alternatives by Site	8-26

9-1    Selected Remedies	9-29
9-2    Performance Monitoring Network	9-31
9-3    Dieldrin in OU 1 Groundwater, Alternative 3 - Groundwater Extraction and
       Treatment	9-36
9-4    SWMU I/Area 2 - Aboveground Solvent Tank/Building 26 Recoup Operations
       Alternative 3 - Soil Vapor Extraction	9-38
9-5    Area 1 Building 237 Alternative 3 - Soil Vapor Extraction	9-39
9-6    Area 3 Alternative 3 - Soil Vapor Extraction	9-40
9-7    Groundwater Monitoring Reguirements (Ig/L)  for DDJC-Tracy	9-41
9-8    SWMU 4 - Storm Drain Lagoon Alternative 3 - Limited Excavation and Disposal of
       Sediments	9-46
9-9    SWMU 6 - Building 28 Sump Alternative 4A - Excavation and Class II Disposal	9-47
9-10   SWMU 6 - Building 28 Sump Alternative 4B - Excavation and Class I Disposal	9-48
9-11   SWMU 7 - Bum Pit No. 1 Alternative 2 - Institutional Controls	9-49
9-12   SWMU 8 - Bum Pit No. 2 Alternative 4 - Excavation and Class I Disposal	9-50
9-13   SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and Area 1
       Building 10 Alternative 3 - SVE,  Excavation and Class I Disposal	9-52
9-14   SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Alternative 3 - Bioventing..9-54
9-15   SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206 Alternative 3 - Excavation
       and Class I Disposal	9-55
9-16   Drum Storage Area - Building 30 Alternative 2 - Institutional Controls	9-56
9-17   Surface and Near-Surface Soils - Northern Depot Area Alternative 3 - Asphalt Cover
DDJC-Tracy	9-57

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9-18   SWMUs 2/3 - Sewage and Industrial Waste Lagoons Alternative 3 - Excavation and Class I
     Disposal	9-58
9-19   SWMU 33 - Industrial Waste Pipeline Alternative 3 - Excavation, Grouting,  and
Institutional Controls	9-59

10-1   Compliance with Location-Specific ARARs	10-16
10-2   Compliance with Action-Specific ARARs for OU 1 Groundwater Remediation	10-17
10-3   Compliance with Action-Specific ARARs for Soil Remediation	10-30
10-4   Determination of Soil Cleanup Standards for SWMU I/Area 2,  DDJC-Tracy	10-56
10-5   Determination of Soil Cleanup Standards for Area 1 Building 237	10-57
10-6   Determination of Soil Cleanup Standards for Area 3	10-58
10-7   Determination of Soil Cleanup,  Standards for SWMU 4	10-59
10-8   Chemical-Specific Reguirements for Disposal of Soil/Sediment, DDJC-Tracy	10-60
10-9   Determination of Soil Cleanup Standards for SWMU 6	10-61
10-10  Determination of Soil Cleanup Standards for SWMU 7	10-62
10-11  Determination of Soil Cleanup Standards for SWMU 8	10-63
10-12  Determination of Soil Cleanup Standards for SWMU 20 and Area 1 Building 10	10-64
10-13  Determination of Soil Cleanup Standards for SWMU 24	10-65
10-14  Determination of Soil Cleanup Standards for SWMU 27	10-66
10-15  Determination of Soil Cleanup Standards for Drum Storage Area Building 30	10-67
10-16  Determination of Soil Cleanup Standards for SWMU 2 and SWMU 3	10-68
10-17  Determination of Soil Cleanup Standards for SWMU 33	10-69

B-l    Summary of Data Flags and Figure Abbreviations	B-l

                              LIST OF FIGURES

1-1    Site Location,  Defense Depot San Joaguin - Tracy Site
1-2    Facility Map, Defense Depot San Joaguin - Tracy Site
1-3    On-Site Surface Water, Defense Depot San Joaguin - Tracy Site
2-1    Solid Waste Management Units Investigated During the Comprehensive RI/FS,  Defense Depot
       San Joaguin - Tracy Site
2-2    Soil Contamination and Drum Storage Areas Investigated During the Comprehensive RI/FS,
       Defense Depot San Joaguin - Tracy Site
2-3    Approximate Locations of Underground Storage Tank Sites Investigated During the
       Comprehensive RI/FS, Defense Depot San Joaguin - Tracy Site
2-4    CERCLA Process

5-1    SWMUs and TCE Contamination at DDJC-Tracy
5-2    SWMUs and PCE Contamination at DDJC-Tracy
5-3    SWMUs and Dieldrin Contamination at DDJC-Tracy
9-1    Operable Unit #1 (OU-1)  Groundwater Treatment System, Existing and Proposed Facilities,
       Defense Depot San Joaguin - Tracy Site
9-2    Proposed Locations of Extraction Wells for Remediation of Dieldrin in Groundwater,
       Defense Depot San Joaguin - Tracy Site
9-3    SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area Conceptual Site Layout of Full-
       Scale SVE System, Defense Depot San Joaguin - Tracy Site
9-4    Area 1 - Building 237 Conceptual Site Layout of Full-Scale SVE System,  Defense Depot San
       Joaguin - Tracy Site
9-5    Area 3 - Conceptual Site Layout of Full-Scale SVE System,  Defense Depot San Joaguin -
       Tracy Site
9-6    SWMU - 4 Conceptual Excavation Footprint, Defense Depot San Joaguin - Tracy Site
9-7    SWMU 6 - Building 28 Sump Conceptual Excavation Footprint,  Defense Depot San Joaguin -
       Tracy Site
9-8    SWMU - 8 Conceptual Excavation Footprint, Defense Depot San Joaguin - Tracy Site
9-9    SWMU 20 - Conceptual Excavation Footprint and Full-Scale SVE System,  Defense Depot San
       Joaguin - Tracy Site
9-10   SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank Conceptual Site Layout for
       Bioventing System,  Defense Depot San Joaguin - Tracy Site
9-11   SWMU - 27/Area 1 Conceptual Excavation Footprint Defense Depot San Joaguin - Tracy Site
9-12   Soil Contamination in the Northern Depot Investigated During the Comprehensive RI/FS,
       Defense Depot San Joaguin - Tracy Site
9-13   Selected Alternative for SWMUs 2 and 3, Defense Depot San Joaguin - Tracy  Site

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B-l    SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area TCE Concentrations Detected in
       Soil-Gas Samples,  Defense Depot San Joaguin - Tracy Site
B-2    SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area VOCs,  Metals,  and Petroleum
       Hydrocarbons Detected in Soil and Groundwater Samples,  Defense Depot San Joaguin - Tracy
       Site
B-3    SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area SVOCs  and Pesticides/PCBs
       Detected in Soil Samples, Defense Depot San Joaguin - Tracy Site
B-4    SWMU I/Area 2 - Old Sewage Lagoons/Drum Storage Area Site Location Map, Defense Depot
       San Joaguin - Tracy Site
B-5    Area 1 - Building 237 Constituents Detected in Soil, Soil Gas, and Groundwater Samples,
       Defense Depot San Joaguin - Tracy Site
B-6    Constituents Detected in Soil and Groundwater Samples,  Defense Depot San Joaguin - Tracy
       Site
B-7    Area 3 - Distribution of PCE and TCE in Soil, Defense Depot San Joaguin - Tracy Site
B-8    SWMU 4 - Storm Drain Lagoon Organic Constituents and Metals Detected in Soil and Sediment
       Samples, Defense Depot San Joaguin - Tracy Site
B-9    SWMU 4 - Storm Drain Lagoon Constituents Detected in Surface Water and Groundwater
       Samples, Defense Depot San Joaguin - Tracy Site
B-10   SWMU 4 - Storm Drain Lagoon Analytes Detected in Soil at Depth,  Defense Depot San
       Joaguin - Tracy Site
B-ll   SWMU 6 - Building 28 Sump Constituents Detected in Soil and Groundwater Samples,  Defense
       Depot San Joaguin - Tracy Site
B-12   SWMU 7  (North Area) - Burn Pit No. 1 Organic Constituents Detected in Surface Soil and
       Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-13   SWMU 7 - (South Area) - Burn Pit No. 1 Constituents Detected in Soil and Groundwater
       Samples, Defense Depot San Joaguin - Tracy Site
B-14   SWMU 8 - Burn Pit No. 2 Constituents Detected in Soil and Groundwater Samples, Defense
       Depot San Joaguin - Tracy Site
B-15   SWMU 8 - Trench 8-1 Organic Constituents and Metals Detected in Soil Samples, Defense
       Depot San Joaguin - Tracy Site
B-16   SWMU 8 - Trench 8-2 Organic Constituents and Metals Detected in Soil Samples, Defense
       Depot San Joaguin - Tracy Site
B-17   SWMU 20 - Above Ground Solvent Tank, SWMU 23 - Building 28  Recoup Operation, and Area
       1 Building 10 Constituents Detected in Groundwater, Surface Water,  and Sludge Samples,
       Defense Depot San Joaguin - Tracy Site
B-18   SWMU 20 - Above Ground Solvent Tank SWMU 23 - Building 28 Recoup Operation and Area 1
       Building 10 Constituents Detected in Soil Samples,  Defense  Depot San Joaguin - Tracy Site
B-19   SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank  Organic Constituents and
       Metals Detected in Soil and Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-20   SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building  206 Constituents Detected in
       Surface Soil and Soil Boring Samples,  Defense Depot San Joaguin - Tracy Site
B-21   SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building  206 Constituents Detected in
       Soil Boring Samples, Defense Depot San Joaguin - Tracy Site
B-22   SWMU 27 Building 206 - Roundhouse Sump and Area 1 Building  206 Constituents Detected in
       Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-23   Building 30 - Drum Storage Area Constituents Detected in Soil Samples,  Defense Depot San
       Joaguin - Tracy Site
B-24   Surface Soil Results (0-0.5 Feet bgs), Defense Depot San Joaguin - Tracy Site
B-25   Near Surface Soil Results  (0.5-1.5/2.0 Feet bgs), Defense Depot San Joaguin - Tracy Site
B-26   SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Organic Constituents
       Detected in Soil and Sediment Samples, Defense Depot San Joaguin - Tracy Site
B-27   SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Metals Detected in Soil and
       Sediment Samples,  Defense Depot San Joaguin - Tracy Site
B-28   SWMU 2/SWMU 3 - Present Sewage Lagoons/Industrial Lagoons Constituents Detected in
       Surface Water and Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-29   SWMU 33 - Industrial Waste Pipeline Constituents Detected in Soil Samples,  Defense Depot
       San Joaguin - Tracy Site
B-30   SWMU 5 - Old Industrial Lagoon, Building 255 Constituents Detected in Soil and
       Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-31   SWMU 9 - Subsistence Waste Pit Organic Constituents and Metals Detected in Soil and
       Groundwater Samples, Defense Depot San Joaguin - Tracy Site
B-32   SWMU 10 - Medical Waste Burial Pit Organic Constituents and Metals Detected in Soil and
       Groundwater Samples, Defense Depot San Joaguin - Tracy Site

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B-33   SWMU 10A - Possible Medical Waste Burial Pits Site Location Map,  Defense Depot San
       Joaquin - Tracy Site
B-34   SWMU 11 - Burial of Lime/Foot Bath Site Location,  Defense Depot San Joaquin - Tracy Site
B-35   SWMU 12 - Embalminq Fluid Dump Constituents Detected in Soil and Groundwater Samples,
       Defense Depot San Joaquin - Tracy Site
B-36   SWMU 14 - Lube Oil Dump Orqanic Constituents and Metals Detected in Soil Samples,  Defense
       Depot San Joaquin - Tracy Site
B-37   SWMU 15 - Pesticide Waste Trench Constituents Detected in Soil and Groundwater Samples,
       Defense Depot San Joaquin - Tracy Site
B-38   SWMU 16 - Possible Hazardous Waste Disposal Area Site Location Map and Constituents
       Detected in Soil and Groundwater Samples,  Defense Depot San Joaquin - Tracy Site
B-39   SWMU 21 - Battery Acid Dump Constituents Detected in Soil and Hydropunch Samples,
       Defense Depot San Joaquin - Tracy Site
B-40   SWMU 21 - Previous Hazardous Material Storaqe Area Constituents Detected in Soil and
       Groundwater Samples, Defense Depot San Joaquin - Tracy Site
B-41   SWMU 25 - Boundary Roads Constituents Detected in Soil Samples,  Defense Depot San
       Joaquin - Tracy Site
B-42   SWMU 29 - Used Motor Oil Disposal Pit Site Location Map,  Defense Depot San Joaquin -
       Tracy Site
B-43   SWMU 30 - Salvaqe Area Site Location Map,  Defense Depot San Joaquin - Tracy Site
B-44   SWMU 30 - Salvaqe Area Orqanic Constituents and Metals Detected in Soil Samples,  Defense
       Depot San Joaquin - Tracy Site
B-45   SWMU 31 - Wood Preservation Area Constituents Detected in Soil and Groundwater Samples,
       Defense Depot San Joaquin - Tracy Site
B-46   SWMU 64 - Waste Oil Pit Constituents Detected in Soil and Groundwater Samples,  Defense
       Depot San Joaquin - Tracy Site
B-47   Area 1 - Buildinq 236 Constituents Detected in Soil Samples, Defense Depot San
       Joaquin - Tracy Site
B-48   Drum Storaqe Area Buildinq 15 Constituents Detected in Soil Samples,  Defense Depot San
       Joaquin - Tracy Site
B-49   Buildinq 22 - Drum Storaqe Area Constituents Detected in Soil and Groundwater Samples,
       Defense Depot San Joaquin - Tracy Site
B-50   Day Care Center Orqanic Constituents and Metals Detected in Soil Samples,  Defense Depot
       San Joaquin - Tracy Site
C-l    Storm Water Detention Pond, Defense Depot San Joaquin - Tracy Site
C-2a   Cross Section of Soil and Sediment Samplinq Results for SWMU 4 Orqanic Constituents,
       Defense Depot San Joaquin - Tracy Site
C-2b   Cross Section of Soil and Sediment Samplinq Results for SWMU 4 Orqanic Constituents,
       Defense Depot San Joaquin - Tracy Site
E-l    Groundwater Monitorinq Well Samplinq Frequency Decision Flowchart
E-2    SWMUs and Well Locations, DDJC-Tracy
E-3    New and Pre-Existinq Monitorinq Wells Intended for Downqradient Monitorinq at SWMUs 7
       and 8 and Drum Storaqe, Buildinq 30

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                             LIST OF ACRONYMS
CFR         Code of Federal Regulations
COG         Chemical of Concern
COPC        Chemical of Potential Concern
COPEC       Chemical of Potential Ecological Concern
DCC         Day Care Center
1,1-DCE     1,1-dichloroethene
1,2-DCE     1,2-dichlcroethene
DDD         Dichlorodiphenyldichloroethane
DDE         Dichlorodephenyldichloroethene
DDJC        Defense Distribution Depot San Joaguin
DDRW        Defense Distribution Region West
DDT         Dichlorodlephenyltrichloroethane
DDTR        DDD, DDE, and DDT
DHS         Department of Health Services
DI WET      De-Ionized Water-Waste Extraction Tests
DLA         Defense Logistics Agency
DoD         Department of Defense
DSERTS      Defense Site Environmental Reporting and Tracking System
DTSC        Department of Toxic Substances Control
EE/CA       Engineering Evaluation/Cost Analysis
EQP         Eguilibrium Partitioning
ERA         Ecological Risk Assessment
BSD         Explanation of Significant Differences
EU          Exposure Unit
FFA         Federal Facilities Agreement
FS          Feasibility Study
GAG         Granular Activated Carbon
gpm         gallons per minute
HHRA        Human Health Risk Assessment
HI          hazard index
ILCR        Increased Lifetime Cancer Risk
IRM         Interim Remedial Measure
IRP         Installation Restoration Program
IWPL        Industrial Waste Pipeline
LOEL        Lowest Observable Effect Level
LUFT        Leaking Underground Fuel Tank
MCL         maximum contaminant level
MEK         methyl ethyl ketone
mg/Kg       milligrams per kilogram
mg/kg/day   milligrams per kilogram per day
mph         miles per hour
msl         mean sea level
NC          not calculated
NCP         National Contingency Plan
NFA         No Further Action
NOAEL       no observable adverse effect level
NOEL        no observable effect level
NPL         National Priorities List
O&M         operations and maintenance
OP          organophosphorus
PAH         polycyclic aromatic hydrocarbon
PCB         polychlorinated biphenyl
PCE         tetrachloroethene
PCP         pentachlorophenol
POW         Prisoner of War
ppb         parts per billion
ppbv        parts per billion volume
ppm         parts per million
RAGS        Risk Assessment Guidance for Superfund
RAO         Remedial Action Objective
RAWP        Remedial Action Work Plan

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RCRA        Resource Conservation and Recovery Act
RfD         reference dose
RI          Remedial Investigation
RI/FS       Remedial Investigation/Feasibility Study
RI/RA       Remedial Investigation/Risk Assessment
ROD         Record of Decision
RWQCB       Regional Water Quality Control Board
SAL         state action level
SARA        Superfund Amendments and Reauthorization Act
SCFM        standard cubic feet per minute
SL          slope factor
STLC        soluble threshold limit concentration
SVE         soil vapor extraction
SVOCS       semivolatile organic compounds
SWMU        Solid Waste Management Unit
SWRCB       State Water Resources Control Board
TCE         trichloroethene
TCPA        temporary children's play area
TPH         total petroleum hydrocarbons
TPHD        total petroleum hydrocarbons as diesel
TPHG        total petroleum hydrocarbons as gasoline
TPH-MO      total petroleum hydrocarbons as motor oil
U.S. EPA    United States Environmental Protection Agency
UCL         upper confidence limit
Ig/dl       micrograms per deciliter
Ig/L        micrograms per Liter
USAGE       U.S. Army Corps of Engineers
USAEHA      U.S. Army Environmental Hygiene Agency
USATHAMA    U.S. Army Toxic and Hazardous Materials Agency
USC         United States Code
UST         Underground Storage Tank
VOC         volatile organic compound
WCC         Woodward Clyde Consultants
WDR         Waste Discharge Reguirements
WMP         Well Monitoring Program
WQSA        Water Quality Site Assessment

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DECLARATION FOR THE RECORD OF DECISION

D. 1 Site Name and Location

Defense Depot San Joaquin (DDJC)-Tracy,
Tracy, California.

D.2 Statement of Basis and Purpose

D.2.1 This decision document presents the selected remedial action for the DDJC-Tracy Site in
Tracy, California, developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments with
Reauthorization Act (SARA). The selected action is also in compliance with the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR Part 300) and Chapter 6.8 of the
California Health and Safety Code (Section 25300 et seq.). Further, these actions are beinq
taken in response to the California Water Code (Section 13300 et seq.). The selection of
remedies is based on the administrative record for this site.

D.2.2 The U.S. Environmental Protection Aqency (U.S. EPA) and the State of California concur on
the selected remedies.

D.3 Assessment of the Site

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementinq the response actions selected in this Record of Decision (ROD), may present an
imminent and substantial endanqerment to public health, welfare, or the environment.

D.4 Description of the Remedy

D.4.1 This Comprehensive ROD is the final action for DDJC-Tracy. An earlier ROD, coverinq
Operable Unit 1 (OU 1), involved remediation of volatile orqanic compounds (VOCs) in
qroundwater. This ROD includes a comprehensive evaluation of all qroundwater issues and
addresses all sites with soil contamination.

D.4.2 Twenty-one sites are recommended for no further action. Sixteen on-depot sites were
considered for further action in the feasibility study (Montqomery Watson, 1996a). The selected
remedies for each of the sites are summarized in Table D-l. A description of the selected
remedies for sites requirinq action is provided in Table D-2.

D.5 Statutory Determinations

D.5.1 The selected remedies are protective of human health and the environment, comply with
federal and state requirements that are leqally applicable or relevant and appropriate to the
remedial action, and are cost-effective. These remedies use permanent solutions where possible
and satisfy, to the extent practicable, the statutory preference for remedies that employ
treatment and reduce toxicity, mobility, or volume as a principal element. The remedies for
SWMUs 2/3, SWMU 4, SWMU 6, SWMU 7, SWMU 8, SWMU 27, SWMU 33, Drum Storaqe Area/Buildinq 30, the
Day Care Center, and Northern Depot Area soils do not include treatment. Because treatment of
the principal threats at these sites was not found to be practicable, the remedies for these
sites do not satisfy the statutory preference for treatment. Institutional Controls were
selected for SWMU 7 and Drum Storaqe Area/Buildinq 30 because potential threats to qroundwater
quality have not been confirmed throuqh historical modelinq. Pavinq was selected as a remedy for
Northern Depot Area soils to prevent depot workers in this active storaqe area from beinq
exposed to contaminated surface soils.

D.5.2 Five-year reviews will be conducted in accordance with CERCLA Section 121(c). The
five-year review is required for sites with institutional controls that restrict use and for
sites (i.e., qroundwater) where cleanup standards will not be attained within five years.
Five-year reviews will also be required for sites where contaminants remain in place, unless it
can be shown that they pose no further threat to human health and the environment.

-------
Table D-l. Selected Remedy for Each Site at DDJC-Tracy
DSERTS
Number
31
1
2/3
4

5
6
7
8
9
10
3/3
11
12
14
15
16
20

21
22
23
24
25
27
29
30
70
65

64
N/A
66
68
N/A
N/A
N/A
69
67
N/A

DDJC
DSERTS
SWMU
N/A
Solid Waste Management
Area/Soil Area
OU 1 Groundwater
SWMU I/Area 2
SWMU 2/3
SWMU 4

SWMU 5
SWMU 6
SWMU 7
SWMU 8
SWMU 9
SWMU 10
SWMU 10A
SWMU 11
SWMU 12
SWMU 14
SWMU 15
SWMU 16
SWMU 20

SWMU 21
SWMU 22
SWMU 23
SWMU 24
SWMU 25
SWMU 27/Area 1
SWMU 29
SWMU 30
SWMU 31
SWMU 33

SWMU 64
Area 1 Building 236
Area 1 Building 237
Area 3
Building 15 Drum Storage Area
Building 22 Drum Storage Area
Building 23
Building 30 Drum Storage Area
Depot Wide Surface and Near
Surface Soils, Northern Depot
Area
Day Care Center
Selected Remedy
Groundwater Extraction, Treatment, Injection and Monitoring
Soil Vapor Extraction and Monitoring
Excavation with Off-Site Disposal and Monitoring
Excavation with Off-Site Disposal of Sediments, Installation
of Sediment Controls and Monitoring
No Further Action
Excavation with Off-Site Disposal and Monitoring
Institutional Controls and Monitoring
Excavation with Off-Site Disposal and Monitoring
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
No Further Action
Soil Vapor Extraction, Limited Excavation with Off-Site
Disposal, Natural Attenuation, and Monitoring
No Further Action
No Further Action
No Further Action
Bioventing and Monitoring
No Further Action
Excavation with Off-Site Disposal and Monitoring
No Further Action
No Further Action
No Further Action
Pipe Grouting, Limited Excavation, Institutional Controls,
and Monitoring
No Further Action
No Further Action
Soil Vapor Extraction and Monitoring
Soil Vapor Extraction and Monitoring
No Further Action
No Further Action
No Further Action
Monitoring
Asphalt Cover
Excavation with Off-Site Disposal
Defense Depot San Joaguin
Defense Site Environmental Reporting and Tracking System
Solid Waste Management Unit
not applicable
-------
Table D-2. Detailed Components of Selected Remedies for Sites Requiring Action
Solid Waste Management
Area/Soil Area

OU 1 Groundwater
SWMU I/Area 2
SWMUs 2/3
SWMU 4
SWMU 6
SWMU 7
SWMU
SWMU 20
SWMU 24
SWMU 27/Area 1
SWMU 33
Area 1 Building 237
Area 3
Building 30 Drum Storage Area
Northern Depot Area
Components

Extraction wells (including 7 new wells to capture dieldrin)
Air stripper for VOC removal
Wellhead granular activated carbon for pesticides
Injection facilities
Compliance monitoring

Soil vapor extraction (approximately 10 wells)
Compliance monitoring of groundwater

Excavation (approximately 10,000 cubic yards)
Off-site disposal
Supply 3 inches of clean backfill and a geofabric material to protect
ecological receptors (pending additional risk assessment)
Compliance monitoring of groundwater

Excavation (approximately 2,500 cubic yards)
Off-site disposal
Supply 3 inches of clean backfill and a geofabric material to protect
ecological receptors (pending additional risk assessment)
Construct overflow weir and install sediment trap on northern pond inlet
Compliance monitoring of groundwater and surface water

Excavation (approximately 100 cubic yards)
Compliance monitoring

Land-Use Restrictions for Buildings 19 and 21
Two additional monitoring wells
Compliance monitoring

Excavation (approximately 8,000 cubic yards)
One additional monitoring well
Compliance monitoring

Soil vapor extraction (approximately 2 wells)
Excavation (approximately 510 cubic yards)
Off-site disposal
Compliance monitoring

Bioventing (approximately 1 well)
Compliance monitoring

Excavation (approximately 130 cubic yards)
Off-site disposal
Compliance monitoring

Limited excavation (approximately 10 cubic yards)
Off-site disposal
Pipe grouting
Institutional controls
Compliance monitoring

Soil vapor extraction (approximately 5 wells)
Compliance monitoring
Soil vapor extraction (approximately
Compliance monitoring

Compliance monitoring
Asphalt cover
wells)
-------
DS.O DECISION SUMMARY

The Decision Summary is the second and main component of the Record of Decision. It discusses
the site characteristics, the alternatives evaluated, and the selected remedy. The Decision
Summary also explains how the selected remedy fulfills statutory requirements. The Decision
Summary comprises eleven sections:

• Section 1.0: Site Description;

• Section 2.0: Site History and Enforcement Activities;

• Section 3.0: Highlights of Community Participation;

• Section 4.0: Scope and Role of the Response Action;

• Section 5.0: Summary of Site Characteristics;

• Section 6.0: Summary of Site Risks;

• Section 7.0: Description of Alternatives;

• Section 8.0: Comparative Analysis of Alternatives;

• Section 9.0: Selected Remedies;

• Section 10.0: Statutory Determinations; and

• Section 11.0: References.

The purpose of each of these sections is briefly described below. All tables and figures are
provided at the end of each section.

DS.l SECTION 1.0: SITE DESCRIPTION

This section provides a general overview of the site. Major surface and subsurface features, the
local geography, and topography are summarized. The adjacent land use and nearby populations are
also discussed.

DS.2 SECTION 2.0: SITE HISTORY AND ENFORCEMENT ACTIVITIES

A phased approach was used by Defense Depot San Joaguin (DDJC)-Tracy to address issues under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This section
summarizes the various investigations and corrective actions that have taken place (see Figure
2-4). Table 2-1 summarizes the past waste handling and disposal practices at DDJC-Tracy. Table
2-2 summarizes the present status of each of the sites.

DS.3 SECTION 3.0: HIGHLIGHTS OF COMMUNITY PARTICIPATION

This section documents public notices and participation in the CERCLA process. The notice and
public meeting regarding the Proposed Plan (Montgomery Watson, 1997a) are discussed in
particular. Further details are provided in the Responsiveness Summary.

DS.4 SECTION 4.0: SCOPE AND ROLE OF THE RESPONSE ACTION

This section defines the scope and role of this Record of Decision. This is a comprehensive
Record of Decision that addresses all contaminants in all media. The decision of a previous
Record of Decision for Operable Unit 1 (groundwater) is modified and reaffirmed in this Record
of Decision. All soil issues are also addressed.

DS.5 SECTION 5.0: SUMMARY OF SITE CHARACTERISTICS

This section summarizes the nature and extent of contamination at each of the sites. Areas of
groundwater contamination are identified along with their suspected sources. Each Solid Waste
-------
Management Unit (SWMU) and soil area is described, contaminants are identified; and impacts to
groundwater, human health, and ecological receptors are identified.

DS.6 SECTION 6.0: SUMMARY OF SITE RISKS

This section discusses how contaminants of concern (COCs) were identified and provides the basis
for determining appropriate cleanup standards. Sections 6.1 through 6.5 summarize the human
health risk assessment. Both carcinogenic and non-carcinogenic health risks are discussed.
Section 6.6 discusses risks to ecological receptors (plants and animals). In Section 6.7,
impacts to beneficial uses and background groundwater guality are discussed. Sites that reguire
remediation to address threats to human health, ecological receptors, and water guality are
identified in each of the respective subsections outlined above.

DS.7 SECTION 7.0: DESCRIPTION OF ALTERNATIVES

This section begins with a general discussion of Applicable or Relevant and Appropriate
Reguirements (ARARs) and other non-promulgated guidance To Be Considered (TBCs). These
regulations and guidance were used in the development of alternatives to address the sites at
DDJC-Tracy. Remedial action objectives are identified for each site and alternatives are
developed in this section. Table 7-1 summarizes the screening of chemicals of potential concern
(COPCs) in groundwater and the remedial decision for these chemicals. The treatment components,
containment or storage components, groundwater components, general components, and major ARARs
are identified in Tables 7-2 through 7-14. Table 7-15 provides the rationale for soil sites
where no further action is recommended.

DS.8 SECTION 8.0: COMPARATIVE ANALYSIS OF ALTERNATIVES

Nine evaluation criteria are used to evaluate alternatives for CERCLA sites. These criteria
are:

DS.8.1 Threshold Criteria

• Overall protection of human health and the environment; and

• Compliance with ARARs.

DS.8.2 Primary Balancing Criteria

• Long-term effectiveness and permanence;

• Reduction of toxicity, mobility, or volume through treatment;

• Short-term effectiveness;

• Implementability; and

Cost.

DS.8.3 Modifying Criteria

• State support and agency acceptance; and

• Community acceptance.

Each alternative was evaluated against these nine criteria. This evaluation is summarized in
Section 8.0.

DS.9 SECTION 9.0: SELECTED REMEDIES

This section describes the selected remedies. Points of compliance and remediation goals (i.e.,
cleanup standards) are identified, along with the basis for the remediation goals. The capital
and operation and maintenance cost for each selected action is provided.
-------
DS.10 SECTION 10.0: STATUTORY DETERMINATIONS

CERCLA Section 121 has five statutory requirements. The selected remedy selected by the lead
agency must:

• Be protective of human health and the environment;

• Comply with ARARs (or justify a waiver);

• Be cost effective;

• Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and

• Satisfy the preference for treatment that reduces toxicity, mobility, or volume as a
principal element, or provide an explanation as to why this preference was not
satisfied.

• Each selected remedy was compared to these requirements and a detailed evaluation of
ARARs is provided in Section 10.0.

DS.ll SECTION 11.0: REFERENCES

This section provides a list of references.

DS.12 SITE-SPECIFIC CROSS REFERENCES

Table DS-1 is designed to assist the reader who is only interested in one or a few sites at
DDJC-Tracy. The reader should first locate the site of interest in the table rows. The columns
specify the major topics addressed in the ROD and the specific sections and tables that the
reader should consult for information on those topics.
-------
Table DS-1. Major Topics by Site
Site
OU 1
Groundwater
GROUP A
SWMU I/ Area 2
Area 1 Building.
237
Area 3 Drum
Storage Area
GROUP B
SWMU 4 - Storm
Drain Lagoon

SWMU 6 -
Building 28
Sump
SWMU 7 - Burn
Pit No. 1
SWMU 8 - Burn
Pit No. 2

SWMU 20 -
Aboveground
Solvent
Tank/Bldg. 26
Recoup
operations
Site
Past Site Characterization
Activities Summary
Sections Section 5.2
2.2.1-2.2.5
Section 5.4.1 Section 5.4.1
Table 2-1
Section 5.4.2 Section 5.4.2
Table 2-1
Section
Table

Section
Table

Section
Table
2-
Section
Table

Section
Table

5.4.3 Section 5.4.3
1

5.5.1 Section 5.5.1
1

5.5.2 Section 5.5.2
1

5.5.3 Section 5.5.3
1
5.5.4 Section 5.5.4
1

5.5.5 Section 5.5.5
1

Ecological
Human Risks Risks
Table 2-2, 6-8 Table 2-2
Section 5.4.1 Section 5.4.1
Table 2-2, 6-4,
6-5
Section 5.4.2 Section 5.4.2
Tables 2-2, 6-5,
6-6
Section
Tables

Section
Tables
6-5
Section
Tables

Section
5.4.3 Section 5.4.3
2-2, 6-7

5.5.1 Section 6.6.5.4
2-2, 6-4,

5.5.2 Section 5.5.2
2-2, 6-7

5.5.3 Section 5.5.3
Table 2-2
Section
Tables
6-8
Section
Tables

5.5.4 Section 5.5.4
2-2, 6-7,

5.5.5 Section 5.5.5
2-2, 6-6

Threats to
Groundwater
Sections 2.2.1-
2.2.5
Section 5.4.1
Table 6-9
Section 5.4.2
Table 6-9
Section
Table

Section
Table

Section
Table
6-
Section
Table

Section
Table

5.4.3
9

5.5.1
9

5.5.2
9

5.5.3
9
5.5.4
9

5.5.5
9

Remedial
Alternatives
Section 7.3,
Table 7-1, 7-2
Section 7.4,
Table 7-3
Section 7.4,
Table 7-3
Section 7.4,
Table

7-3

Section 7.5.1,
Table

7-4

Section 7.5.2,
Table

7-5

Section 7.5.3,
Table
7-6
Section 7.5.4,
Table

7-7

Section 7.5.5,
Table

7-8

How Selected
Comparison Remedy Meets
of Remedial Selected Statutory
Alternatives Remedy Reguirements
Section 8.2, Section 9.5 Section 103
Table 8-2
Section 8.3, Section 9.6 Section 10.4
Table 8-2
Section 8.3, Section 9.6 Section 10.4
Table 8-2
Section 8.3, Section 9.6 Section 10.4
Table 8-2

Section 8.4.1, Section 9.7.1 Section 10.5
Table 8-2

Section 8.5, Section 9.7.2 Section 10.6
Table 8-2

Section 8.6, Section 9.7.3 Section 10.7
Table 8-2
Section 8.7, Section 9.7.4 Section 10.8
Table 8-2

Section 8.8 Section 9.7.5 Section 10.9

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Table DS-1. (Continued)

Site
SWMU 24 -
Petroleum Waste
Oil Tank
SWMU 27 -
Area 1 Bldg. 206

Bldg. 30 Drum
Storage Area
Northern Depot
Area

GROUP C
SWMUs 213 -
Sewage Lagoons
and Ind. Waste
Lagoon
SWMU 33 - Ind.
Waste Pipeline
No Further
Action Sites

Site
Past Site Characterization
Activities Summary
Section 5.5.6 Section 5.5.6
Table 2-1

Section 5.5.7 Section 5.5.7
Table 2-1

Section 5.5.8 Section 5.5.8
Table 2-1
Section 5.5.9 Section 5.5.9
Table 2-1

Sections Section 5.6.1, 5.6.2
2.1.2, 5.6.1,
5.6.2
Table 2-1
Section 5.6.3 Section 5.6.3
Table 2-1
Sections Sections 5.7.1-
5.6.1-5.6.20 5.7.20
Table 2-1

Ecological
Human Risks Risks
Section 5.5.6 Section 5.5.6
Tables 2-2, 6-4,
6-5, 6-8
Section 5.5.7 Section 5.5.7
Tables 2-2, 5-6,
6-8
Section 5.5.8 Section 5.5.8
Table 2-2
Section 5.5.9 Section 5.5.9
Tables 2-2, 6-4,
6-5, 6-8

Section 5.6.1, Section 6.6.5.3
5.6.2
Tables 2-2, 6-4,
6-5
Section 5.6.3 Section 5.6.3
Tables 2-2, 6-5
Sections 5.7.1- Sections 5.7.1-
5.7.20 Table 2-2 5.7.20

Threats to
Groundwater
Section 5.5.6
Table 6-9

Section 5.5.7
Table 6-9

Section 5.5.8
Table 6-9
Section 5.5.9
Table 6-9

Section 5.6.1,
5.6.2
Table 6-9

Section 5.6.3
Table 6-9
Sections 5.7.1-
5.7.20

Comparison
Remedial of Remedial
Alternatives Alternatives
Section 7.5.6, Section 8.9
Table 7-9

Section 7.5.8, Section 8.10
Table 7-10

Section 7.5.8, Section 8.11
Table 7-11
Section 7.5.9, Section 8.12
Table 7-12

Section 7.6.1 Section 8.13
Table 7-13

Section 7.6.2, Section 8.14
Table 7-14
Section 7.7,
Table 7-15

How Selected
Remedy Meets
Selected Statutory
Remedy Requirements
Section 9.7.6 Section 10.10

Section 9.7.7 Section 10.11

Section 9.7.8 Section 10.12

Section 9.7.9 Section 10.13

Section 9.8.1 Section 10.14

Section 9.8.2 Section 10.15

Section 9.2 Section 10.1

Day Care Center
Sections Section 5.7.21
2.2.10, 5.6.21
Table 2-1
Section 5.7.21 Section 5.7.21
Tables 6-4, 6-5
Section 5.
Section 9.3 Section 10.1
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1.0 SITE DESCRIPTION

1.1 Site Location

Defense Depot San Joaquin (DDJC)-Tracy is located in an unincorporated area of San Joaquin
County, 1.5 miles southeast of Tracy, California; approximately 20 miles southwest of Stockton,
California; and 60 miles east of San Francisco, California (Fiqure 1-1).

1.2 Facility Description

DDJC-Tracy is primarily a storaqe and distribution facility for various supplies common to U.S.
military services in the western U.S. and throuqhout the Pacific. The operatinq portion of the
depot covers a 448-acre trianqular parcel, and the recently added Tracy Annex consists of 460
acres of aqricultural land north of the operatinq portion. The topoqraphy at DDJC-Tracy is
qently downward to the north-northwest from an elevation of about 115 feet above mean sea level
(msl) at the southern corner to an elevation of 45 feet above msl at the northern edqe of the
Tracy Annex (Fiqure 1-1). South Chrisman Road borders the west edqe of the facility, Banta Road
borders the east, and Eleventh Street borders the north. About 75 percent of the operatinq
portion is covered with buildinqs (primarily warehouses), asphalt, or concrete. Numerous smaller
buildinqs in the northwest corner of the depot house administration and operations (Fiqure 1-2).
A larqe storm water pond and two sewaqe laqoons are also located in the northwestern portion of
the depot. The storm water pond receives runoff from the depot's storm drain system. The sewaqe
laqoons receive treated wastewater from the depot's wastewater treatment plant (Fiqure 1-3). The
only landscaped area is in the northwest corner near Buildinq 100. All other unpaved surfaces
contain weeds and qrass, which historically have been removed reqularly with herbicides (types
and quantities were not recorded) and/or by qradinq.

1.3 Meteorology

DDJC-Tracy has an averaqe annual rainfall of approximately 14 inches; over 90 percent of the
rain falls between November and April. Summer temperatures commonly exceed 100 deqrees
Fahrenheit 5F) durinq the day and drop to as low as 605F at niqht. Winter temperatures ranqe
from 30 to 505F. The averaqe wind speed is 10 miles per hour and blows primarily from the west
in the summer and from the southeast in the winter. Dense foq often forms at niqht durinq the
fall and winter.

1.4 Geology/Hydrology

1.4.1 The uppermost sedimentary deposits at DDJC-Tracy consist of the Tulare Formation and the
overlyinq Quaternary alluvium (Table 1 - 1). The top of the Tulare Formation is eroded and
overlain by essentially horizontal sandy and qravelly Pleistocene and Recent alluvium. The
Tulare Formation is separated into three rouqhly horizontal zones: the Lower and Upper Tulare
and the Corcoran Clay layers. The relatively impermeable Corcoran Clay separates (and forms an
aquitard between) the poorly sorted alluvial and fluvial sediments in the Lower and Upper
Tulare. The Upper Tulare and Lower Tulare layers are primary sources of fresh, inexpensive
qroundwater in the San Joaquin Valley, so they will hereafter be called the Upper Tulare and
Lower Tulare aquifers (Montqomery Watson, 1996a).

1.4.2 The Upper Tulare aquifer has been the primary focus of remedial investiqations. The water
table lies approximately 10 feet below qround surface (bqs) in the northern portion of the annex
and 45 feet bqs in the southern corner of the depot. The potentiometric surface (water table
elevation) slopes qently toward the north-northeast. Generally, the averaqe linear velocity of
qroundwater in the aquifer is an estimated 15 to 500 ft/year toward the north-northeast. The
Upper Tulare Aquifer is approximately 200 feet thick near Tracy and contains fresh water under
semi-confined and unconfined conditions. Some locally confined pockets exist.

1.5 Land and Water Use

1.5.1 The land surroundinq DDJC-Tracy (and the Tracy Annex) is used primarily for aqricultural
purposes, includinq both irriqated cropland and pasture for livestock qrazinq.

1.5.2 Common farminq practices in these areas include reqular applications of fertilizers and
pesticides. Across Chrisman Road to the west, there are five sinqle family homes and a peach
-------
orchard. Immediately east of the depot, two major railroad lines intersect. The Northern,
Pacific track runs along the northern boundary of the operating portion of the site, and the
Union Pacific track runs along the southeastern boundary. There are more orchards south of the
depot across the tracks, and land to the east is designated for general industrial use. Some
rural residential developments exist within a three-mile radius with small areas of commercial
and industrial land use (Figure 1-1).

1.5.3 The unincorporated areas of Tracy, the unincorporated community of Banta, and other rural
neighborhoods are within a three-mile radius of DDJC-Tracy. In many of these areas, private
wells and septic tanks provide drinking water and sewage disposal, respectively. The community
of Banta, located two miles northeast of the site, includes an elementary school, about 30
residences, and commercial and industrial businesses. Another rural residential development
(Stoneridge) 2.5 miles northeast of the site contains 60 residences.

1.5.4 At DDJC-Tracy, three water supply wells provide all potable water, process water, and
fire water for the depot.

1.6 Cultural and Historic Resources

Southern Pacific Railroad founded the city of Tracy in 1878 and developed it as a maintenance
and supply facility for trains moving to and from the San Francisco Bay area. During the 1940s,
agriculture slowly became the primary industry, displacing rail transportation. The oldest
buildings at DDJC-Tracy were built in 1942. During World War II, a German prisoner of war (POW)
camp existed in the southern corner of the depot, but only written records, including plan
drawings, of this POW camp remain. No building or location at the site is being considered for
the National Registry of Historic Sites.
-------
Table 1-1. Defense Depot San Joaquin-Tracy
Stratigraphic and Hydrostratigraphic Nomenclature
Stratigraphic Units

Alluvium

Holocene fan and terrace deposit
Fine-grained deposits from
the ground surface to a
depth of 25 or 35 feet
below ground surface
Gravel quarry spoils and disturbed ground
Tulare Formation Upper Tulare Aguifer- Upper Horizon Relatively coarse-grained
Upper waterbearing zone; deposits found between
contains water under depths of 25 and 60 feet
semiconfined and below ground surface
unconfined conditions.

Upper Tulare Member Interbeded gravel, Upper/Middle Aguitard
sand, silt, and clay.

Middle Horizon Relatively coarse-grained
deposits found between
the depths of 55 and 85
feet below ground surface

in northern portions of the
depot and between the
depths of 75 and 115 feet
below ground surface in
southern portions of the
depot.

Middle/Lower Aguitard
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Table 1-1 (Continued)
Description
Horizon
Description
Tulare Formation
(Continued)
Lower Horizon
The top of these relatively
coarse-grained deposits
are found at 110 feet
below ground surface in
northern portions of the
depot and at 135 feet
below ground surface in
southern portions of the
depot.
Sandy, clay, silty clay,
silt, and clay
interbedded with fine-
grained sand.
Lower Tulate Member
Lenticular and
interfingering beds of
gravel, sand, and clay.

Deposited in alluvial
and fluvial
environments.
Lower Tulare Aguiler-Lower
water-bearing zone; contain
freshwater under confined
conditions to an estimated
depth of 490 feet below round
surface in the DDJC-Tracy
Area.
Lower Tulare
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Defense Logistics Agency (DLA) has operated Defense Depot San Joaguin (DDJC)-Tracy since
1942. DDJC-Tracy is a storage and distribution depot for various supplies common to U.S.
military services in the western U.S. and throughout the Pacific. In late 1992, the DLA
purchased approximately 460 acres north of the operating portion of DDJC-Tracy, called the
Tracy Annex.

2.1 Preliminary Environmental Investigations, Records Search, and Initial Investigations

In early 1980, a records search by the U.S. Army Toxic and Hazardous Materials Agency
(USATHAMA) first identified 25 waste sites (solid waste management units [SWMUs], 1 through 23,
2A, and 10A) at DDJC-Tracy that contained contaminants that could migrate to off-depot locations
(Figure 2-1). The study concluded that past waste disposal practices between 1940 and the
mid-1970s-including the use of burning sites, underground sumps/tanks, and unlined drainage and
sewage leaching ponds-caused the contamination. The available information on geology and
potential contaminant sources indicated a potential for contaminants to migrate to the water
table and downgradient into the sand layers of the uppermost aguifer (USATHAMA, 1980). Because
of the potential for contaminants to migrate to groundwater, 12 monitoring wells (LM001AU
through LM012AU) were installed in July 1980 and sampled for metals and general water guality
parameters (USATHAMA, 1980). Additional analytical parameters (for example, volatile organic
compounds [VOCs]) were included in subseguent sampling, and in May 1984, the Central Valley
Regional Water Quality Control Board (RWQCB) was advised that trichloroethene (TCE) and
tetrachloroethene (PCE) concentrations in three monitoring wells exceeded the California
Department of Health Services (DHS) action level of 5 micrograms per liter (Ig/L). Ultimately, a
remedial investigation/feasibility study (RI/FS) was conducted to address the groundwater plume
(see Section 2.2.1) .

2.1.1 Soil Gas and Groundwater Sampling

In 1985, Radian Corporation was contracted to determine the following:

• Existence of any off-depot migration of contaminated groundwater;

• Location of contaminant sources on the depot; and

• Additional work reguired to assess the environmental impacts of groundwater
contamination.

Radian identified six contaminant areas (Radian. 1986), which were later confirmed by Woodward
Clyde Consultants (WCC, 1992a). These were Areas 1 through 6 (Figure 2-2). Additional SWMUs were
Identified in a Resource Conservation and Recovery Act (RCRA) Assessment Report (U.S. EPA,
1990a). Thirty-two active or inactive underground storage tanks (USTs) were also identified
during environmental investigations (Figure 2-3).

2.1.2 Industrial Waste Lagoons and IWPL Investigations

2.1.2.1 In October 1988 and January 1989, before removing and disposing of industrial waste,
samples were collected from each of the two lined industrial wastewater lagoons (SWMU 3)
(Canonie, 1989). Numerous metals, including barium, chromium, copper, lead, and zinc, were
detected above Soluble Threshold Limit Concentrations (STLCs) in the sludge samples. Of those
analyzed, the only organics detected were chlordane from the sludge and diazinon in the sludge
and the liguid.

2.1.2.2 In 1991, Advanced Engineering and Planning Corp., Inc. (AEPCO) conducted an industrial
process system assessment to identify waste treatment and disposal operations, processes, and
technigues at the depot to minimize waste generation and/or eliminate compliance problems.
During the associated investigations, soil and water samples were collected from the current
wastewater management system, the industrial waste pipeline (IWPL), and the lined waste lagoons
(SWMU 3). Concentrations of heavy metals, pesticides, and solvents exceeded regulatory levels
(AEPCO, 1991).

2.2 CERCLA Activities
-------
In 1991, DDJC-Tracy was listed on the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) National Priorities List (NPL) as a Superfund site. On 27 June 1991,
DDJC-Tracy, the U.S. EPA Region IX, and the California Department of Toxic Substances Control
(DTSC) signed a Federal Facilities Agreement (FFA) for DDJC-Tracy. This FFA has enforceable
schedules and ensures that environmental impacts from past and present operations are thoroughly
investigated and that appropriate cleanup actions are taken to protect human health, welfare,
and the environment. The U.S. EPA, DTSC, and the RWQCB provide regulatory oversight consisting
of technical support, review, and comment on all investigative work and cleanup work at DDJC-
Tracy. The following sites were identified as potential threats to human health and the
environment:

36 SWMUs;

• 10 drum storage areas with soil contamination;

28 UST sites;

• Contaminated groundwater associated with Operable Unit (OU) 1;

• The Day Care Center; and

• Other areas with surface and near-surface soil contamination.

Past practices at these sites are shown in Table 2-1. The CERCLA process is summarized in Figure
2-4.

2.2.1 Operable Unit 1 Remedial Investigation/Feasibility Study

2.2.1.1 The contaminated groundwater within the upper Tulare Formation was considered the most
pressing concern and was identified as OU 1. The first phase of the DDJC-Tracy CERCLA program
focused on OU 1.

2.2.1.2 Between 1986 and 1992, WCC was under contract to conduct an RI/FS at DDJC-Tracy as
reguired by CERCLA (and subseguent Superfund Amendments and Reauthorization Act [SARA]
guidelines). In 1992, as a result of the WCC investigation, the OU 1 plume was identified as an
area of contaminated groundwater emanating from DDJC-Tracy. The OU 1 plume affected groundwater
both on and off depot. Chemicals of concern (COCs) included VOCs, pesticides, and potentially
metals; TCE and PCE were detected most extensively in the groundwater.

2.2.1.3 The maximum TCE concentration in the groundwater was 560 Ig/L, and the maximum PCE
concentration was 410 Ig/L. The TCE and PCE plumes are moving north-northeast at approximately
80 and 40 ft/year, respectively. During the OU 1 Remedial Investigation/Risk Assessment (RI/RA) ,
WCC concluded that past solvent storage, handling, and use practices at DDJC-Tracy led to TCE
and PCE contamination; however, specific source areas were not identified.

2.2.1.4 The baseline human health risk assessment (WCC, 1992b) found that the OU 1 plume posed
insignificant risks to depot personnel, off-depot agricultural workers, and consumers of
agricultural crops. The risk assessment also found that residents downgradient of the depot may
have been at risk because they used well water and were close to the OU 1 groundwater plume.
Unless remedial action was taken, the risk for nearby residents was expected to increase with
time as contaminants in groundwater continued to migrate off site. The ecological risk
assessment concluded that the primary potential exposure pathway for plants and animals from the
OU 1 groundwater plume would be through flood irrigation water supplied by the agricultural
wells located on the private property immediately north of the depot.

2.2.1.5 The OU 1 Feasibility Study (FS) (WCC, 1992c) included background information used to
develop and screen remedial technologies for OU 1 groundwater contamination. Remediation goals
were health-risk based. Water guality reguirements were also considered, especially for defining
discharge reguirements. Several technologies for groundwater treatment were evaluated based on
effectiveness, implementability, and relative cost.

2.2.2 OU 1 Record of Decision
-------
2.2.2.1 In August 1993, the final OU 1 Record of Decision (ROD) (WCC, 1993) was signed. The ROD
stated that the OU 1 remedial action would address "the principal threat posed by the
(groundwater contaminant) plume by prioritizing action at OU 1 over any additional cleanup
associated with other potential sources of contamination at the depot" (WCC, 1993). The impact
to a residential drinking water well and the potential impact to a second residential well by
TCE and PCE were the principal threats posed by the groundwater contamination. To eliminate
these threats and to protect human health and the environment, the ROD prioritized the
remediation of TCE, PCE, and 1.1-dichloroethene (1,1-DCE) in the groundwater. Extraction wells
were to be strategically placed to:

• Remediate "hot spots" (the portions of the plume with the highest concentrations);

• Minimize contaminant transport off depot; and

• Minimize plume migration and clean up the plume to the federal Maximum Contaminant
Levels (MCLs) for TCE and PCE and the California MCL for 1,1-DCE (WCC, 1993).

2.2.2.2 As the OU 1 ROD describes, the selected alternative was to extract, treat, and reinject
the contaminated groundwater. In addition, the OU 1 ROD set aguifer cleanup levels of 5 Ig/L for
TCE and PCE and 6 Ig/L for 1,1-DCE. The OU 1 ROD also specified effluent treatment standards for
carbon tetrachloride, chloroform, 1,1-DCE, dieldrin, PCE, TCE, and total VOCs (halogenated
hydrocarbons).

2.2.2.3 In addition to the effluent treatment standards specified in the OU 1 ROD, the RWQCB
specifies effluent treatment standards in a Waste Discharge Reguirements (WDR) permit based on
the State Water Resources Control Board (SWRCB) Resolution 92-49 ("Policies and Procedures for
Investigation and Cleanup and Abatement of Discharge"). The effluent treatment standards for
several VOCs and pesticides not included in the OU 1 ROD were adopted into the OU 1 ROD through
an Explanation of Significant Difference (BSD)(Montgomery Watson, 1995). An BSD is reguired as
documentation when significant changes are made to the final ROD. The WDR permit prescribes
effluent standards for the following compounds: carbon tetrachloride, chloroform, total
chromium, 1,1-DCE, PCE, TCE, dieldrin, ODD, DDE, DDT, chlordane, monuron, diuron, and total
VOCs.

2.2.2.4 The OU 1 BSD also modified the technology for removing VOCs from the aguifer to include
dispersion (encompassing metabolism and volatilization). This modification resulted from a
comparative analysis of the most cost-effective approaches for achieving ROD-stipulated
objectives while minimizing capture of an off-site chloroform and carbon tetrachloride plume and
eliminating off-site extraction facilities. This particular off-site chloroform and carbon
tetrachloride plume appears to be emanating from an off-site source (other than DDJC-Tracy);
however, this ROD does address additional chloroform contamination attributed to the depot.

2.2.3 OU 1 Well Monitoring Program

The Well Monitoring Program (WMP), which has been conducted at DDJC-Tracy since May 1991,
provides complete and current groundwater data from wells throughout the depot and vicinity.
These data allow seasonal variations of groundwater levels to be evaluated; the data also allow
the nature and extent of groundwater guality variations to be determined.

2.2.4 OU 1 Well Abandonment Program

Drinking water wells 1 (in Area 1) and 2 (near SWMU 2) were previously abandoned to eliminate
exposure to contaminated groundwater and to control contaminant migration. The OU 1 RI/FS also
identified three agricultural supply wells (AG-1, AG-2, and AG-3) that may have served as
conduits and created a vertical hydraulic gradient for contaminants to migrate downward. Eleven
wells had a history of turbid samples, were suspected of being damaged or improperly installed,
or had been dry for several years. The OU 1 RI/FS recommended that these wells be abandoned. The
Final Well Abandonment Work Plan provides general procedures for well abandonment (Montgomery
Watson, 1994a). Abandonment of the above wells was completed from October 1994 to June 1995. The
abandonment of the wells is documented in the DDRW-Tracy Final Well Abandonment Engineering
Report (Montgomery Watson, 1996f).

2.2.5 OU 1 Remedial Action
-------
2.2.5.1 Starting in 1990, ENSOTECH, Inc. installed the OU 1 interim remedial measure (IRM)
system. The IRM system controls the migration of the contamination, reduces levels of VOCs, and
provides data to evaluate the effectiveness and potential use of the selected remedial
technology for the full-scale design. The system includes six extraction wells, an air
stripper, three injection wells, two piezometers, and 10 monitoring wells (ENSOTECH, 1991).
Later, DDJC-Tracy expanded the IRM to increase the influent flow from the contaminated portion
of the TCE and PCE plumes from 125 gallons per minute (gpm) to greater than 350 gpm, and
constructed two infiltration galleries (injection wells performed poorly) for discharging
treated water. The modified IRM system will be integrated with the final full-scale groundwater
remediation system for OU 1.

2.2.5.2 The design of the full-scale OU 1 pump-and-treat system was completed in April 1996. The
full-scale OU 1 groundwater remediation system is presently being constructed.

2.2.5.3 The full-scale system design includes liguid-phase granular activated carbon (GAG)
wellhead treatment for removing pesticides at existing extraction wells EW-2 and EW-5 to comply
with waste discharge reguirements (Montgomery Watson, 1996c).

2.2.6 Comprehensive Remedial Investigation/Feasibility Study

2.2.6.1 The comprehensive Remedial Investigation/Feasibility Study (RI/FS) report reevaluated
and reaffirmed the OU 1 ROD and BSD and addresses all areas that were not addressed as part of
the OU 1 RI/FS. Montgomery Watson performed the Comprehensive Site-Wide RI/FS (Final RI/FS) as
part of the Department of Defense's Installation Restoration Program (IRP). The purpose of the
Comprehensive RI/FS was to investigate potential sources of environmental contamination at
DDJC-Tracy and to collect data to support the following activities:

• The evaluation and selection of remedial alternatives;

• The baseline human health risk assessment:

• The ecological assessment; and

• The design of the selected remedy.

2.2.6.2 The Comprehensive RI/FS at DDJC-Tracy was conducted from 1993 through 1995 (Montgomery
Watson, 1995a). The following sites were investigated:

OU 1;

• 66 sites;
28 SWMUs,
10 Soil Contamination Areas, and
28 UST sites;

• The Day Care Center; and

• Surface and near-surface soils (Montgomery Watson, 1996a).

2.2.6.3 The history of waste disposal practices at the SWMUs and other contaminated sites is
summarized in Table 2-1. Table 2-2 summarizes the status of all sites investigated in the RI/FS.
Table 2-3 summarizes the status of the UST sites.

2.2.6.4 The following eight SWMUs were not investigated in the comprehensive RI/FS because they
were recommended and approved for no further remedial investigation in the Final Comprehensive
RI/FS Work Plan (WCC, 1992a; Montgomery Watson, 1993):

SWMU 2A, Sewage Treatment Plant;

SWMU 13, Construction Material Landfill;

SWMU 17, Active Wells;
-------
• SWMU 18, Inactive Wells, properly abandoned;

SWMU 19, Aboveground Waste Tank;

• SWMU 26, Storage Area for Contaminated Waste;

SWMU 28, Phostoxin Waste Storage Area; and

SWMU 32, Pesticide Sinks.

2.2.6.5 Past practices and preliminary screening indicated that these sites were not sources of
contamination (see Table 2-2).

2.2.7 Selection of Sites for Feasibility Study

After the RI was completed, sites were selected to proceed to the FS if concentrations detected
at the site indicated the presence of COCs. A COG was identified on the basis of one of the
following criteria:

• Actual or potential threats to beneficial uses of groundwater or background water
guality;

• Increased lifetime cancer risks (ILCR) greater than 1 x 10 -6 to installation
employees, construction workers, or children on the installation;

• Noncancer health risks (or hazard indices) greater than 1.0 to employees,
construction workers, or children on the installation; or

• Potential risks to ecological receptors.

2.2.8 Sites Studied for Feasibility of Remedial Action

The sites recommended for the FS are divided into three groups: A, B, and C. The rationale for
the grouping was:

• Group A: VOCs in the soil and soil gas at these sites pose threats to groundwater;

• Group B: Multiple COCs at these sites pose threats to groundwater or risks to human
or ecological receptors;

• Group C: These sites received or conveyed industrial wastewater and have been
evaluated for a non-time-critical removal action through an engineering
evaluation/cost analysis (EE/CA).

2.2.9 Sites Recommended for No Further Action

2.2.9.1 Fifteen sites were recommended to proceed to the FS based on a site-specific data
evaluation and a baseline risk assessment. If the evaluation of the nature and extent, fate and
transport, and risk assessment indicated that a COG at a site exceeded certain criteria, the
site was evaluated in the FS. Sites without COCs meeting these criteria were recommended for no
further action (Table 2-2). Each of the following criteria were used to identify the no further

• No COCs pose actual or potential threats to groundwater beneficial uses or exceed
background concentrations;

• No COCs pose an excess cancer risk greater than 1 x 10 -6 to depot workers,
construction workers, or children on the installation;

• No COCs have a noncancer hazard index greater than 1.0 for depot workers,
construction workers, or children on the installation; and

• There is no ecological risk.
-------
2.2.9.2 The sites where no water quality site assessment was performed are discussed in Section
6.7. SWMU 10A was identified as a No Further Action site, although vadose zone modeling
indicated a potential threat to groundwater quality (see Table 7-15).

2.2.10 Day Care Center

2.2.10.1 The day care center (DCC), located in the northwest portion of DDJC-Tracy, adjacent to
the main entrance on Chrisman Road, consists of the DCC building and a fenced play yard
approximately 200 feet by 300 feet. The temporary children's play area (TCPA) , an outside play
area, is located north of Building 100, approximately a quarter mile north of the DCC.

2.2.10.2 After site investigations by Montgomery Watson from 1992 to 1995 and Radian in 1996, it
was determined that contaminant levels detected in the soil at the DCC posed a minimal health
risk. Specifically, they posed a potential cancer risk of 2x10-5 (primarily from dieldrin) and a
hazard index of 0.3 for children attending the DCC. The compounds detected at the DCC included
polycyclic aromatic hydrocarbon (PAH) compounds (at less than 10 parts per billion [ppb]) and
pesticides (above background threshold levels). At one location, lead was detected at a
concentration of 20.3 parts per million (ppm) , which is above the background threshold level of
14.8 ppm. Because the pesticides at these levels had the long-term potential to impact children,
DDJC-Tracy executed a time-critical removal action and replaced the soil and playground pea
gravel at the DCC with new clean fill, sod, and pea gravel. The public was notified concerning
the removal and an action memorandum was prepared that documents the removal decision. No action
was performed at the TCPA because the pesticide levels detected there were all below the
background threshold levels (Radian, 1996b).

2.2.11 Proposed Plan

A Final Proposed Plan was prepared to provide information to the public about planned actions at
the sites listed above and to seek public input prior to making final decisions. The proposed
plan for DDJC-Tracy presents remedial alternatives and the preferred alternative for each site
with rationale for the selection (Montgomery Watson, 1997a). The Remedial Design/Remedial Action
schedule to implement the selected alternatives must be submitted within 21 days after this ROD
is signed.

2.3 Non-CERCLA Investigations

Thirty-one of the 32 UST sites were included in the comprehensive RI. All of these 31 UST sites
are inactive. The only UST site that was not investigated in the RI was UST 16, which was
active. Twenty-eight sites were transferred out of the RI to the Tri-Regional Guideline program
managed by the RWQCB. Three UST sites (8, 21, and 31) were maintained within the RI as SWMUs 64,
6, and 24, respectively, because nonfuel hydrocarbon compounds were identified in the soil or
groundwater near the three USTs. These sites are all adjacent to SWMUs. The remainder of the
USTs are not subject to CERCLA. Fifteen sites have been closed. Nine other sites will be further
characterized. The other four will be remediated. Table 2-3 shows the current status of the UST
sites. Figure 2-3 shows the locations of the UST sites.
-------
SWMU I/Area 2
Table 2-1. Background of Solid Waste Management Units and Soil Areas

Old Sewage Lagoon and Former Drum Storage Area-This area was used as a drum storage
area from 1957 through 1984. Chemicals in drums possibly leaked or were discharged
accidentally.
SWMUs 2/3
Sewage (SWMU 2) and Former Industrial Waste Lagoons (SWMU 3)-The wastewater
treatment plant has a permitted discharge to the sewage lagoons. SWMU 3 formerly
received discharge from the industrial waste pipeline (SWMU 33). The lagoons have been in
operation since 1942. Sometime between 1971 and 1979, industrial wastes from SWMU 3
overflowed into SWMU 2.
SWMU 4
SWMU 5
Storm Pond Lagoon-Storm water has been discharged to the lagoon since 1971. The storm
drain lagoon reportedly received rinse water from paint-stripping, degreasing, and steam
cleaning operations. The area was used for open storage before 1952. Manganese ore was
stockpiled northeast of the lagoon area from 1957 to 1968.

Old Industrial Lagoon, Building 255-The site was constructed by 1952. The lagoon
received rinse water from the paint-spraying and paint-stripping operations in Building 255.
The lagoon was enlarged in 1963 and existed until at least 1971.
SWMU 6
Building 28 Sump-The sump operated from 1968 to 1977. A portion of Building 28 was
used for repackaging. Wastes from the repackaging operations collected in the sump. The
sump was initially abandoned in place and then removed in 1988. Former UST Site 21 was
also in this area.
SWMU 7
Burn Pit No. 1-Site of seven former burn pits (Pits A-G) that were used between 1942 and
1954 to dispose of medical supplies, narcotics, Pharmaceuticals, radiological supplies, and
electron tubes. The pits are partially or completely covered by Buildings 15, 19, and 21.
SWMU
SWMU 9
Burn Pit No. 2-A single large burn pit was operated between 1942 and 1971. Various
containers, crates, wooden pallets, trash, unknown liguids and solids, and narcotics were
burned in the pit. Explosions attributed to intermixing liguid chemicals or burning
pressurized containers were reported.

Subsistence Waste Pit-Subsistence waste, primarily food, was buried in the pit beginning
in 1947. Packaging materials were also buried.
SWMU 10
Medical Waste Burial Pit-Former medical waste and burial pit. Outdated medical supplies,
narcotics, mercury compounds, and phosphate compounds were buried. The pit operated
from approximately 1949 until 1965. Since 1967, this area has been used for the storage of
truck trailers.
SWMU 10A
Possible Medical Waste Burial Pit-A former pit was reportedly used to bury medical
wastes. Possible trenches are visible in aerial photographs from 1945 to 1967.
-------
Table 2-1. (Continued)
SWMU 11
SWMU 12
Burial of Lime/Foot Bath-Site was reportedly used to dispose of lime materials associated
with lime foot baths. Area is currently covered with asphalt.

Embalming Fluid Dump-An unknown, but substantial quantity of embalming fluid
containing formaldehyde was buried just east of Building 30.
SWMU 14
Lube Oil Dump-Reported site of a former lube oil dump. Reportedly 150 drums of new
lube oil were emptied into a trench in 1976. The trench was backfilled in 1976. Oil seepage
was visible in aerial photographs. A black viscous surface was reported by construction
workers in 1992.
SWMU 15
SWMU 16
SWMU 20/23
SWMU 21
SWMU 22
SWMU 24
SWMU 25
Pesticide Waste Trench-Former pesticide waste trench from 1977 or 1978 until 1979.
Rodenticide, crushed cans that formerly contained pesticides, phosgene (or phostoxin)
slurry, and empty DDT containers may have been buried. Between 1979 and 1980, the
trench was excavated and the contents were disposed off site.

Possible Waste Disposal Area-Possible waste disposal area from 1952 till 1967. Possible
wastes include asbestos, mercury, fluorescent bulbs, and medical supplies.

Aboveground Solvent Tank and Building 26 Recoup Operations-A 500-gallon
aboveground TCE degreasing unit was located inside Building 10. Building 10 was
constructed in 1950. According to warehouse plans, several cleaning facilities were used
between 1950 and 1974. A spray paint booth and cleaning operations were reportedly
connected to the Manhole W-l of the industrial wastewater pipeline (SWMU 33). A 2,000
gallon tank of No. 2 fuel oil was previously located at former UST Site 13. Building 26 was
used to repackage petroleum products. A wash rack was also present at this site.

Battery Acid Dump-Neutralized solution from the battery shop was discharged to the
ground and a sump behind Building 201.

Previous Hazardous Materials Storage Area-Former storage area from 1979 until 1985.
Leaking containers of hazardous materials (i.e., ammonium thiosulfate) were stored here
prior to repackaging or off-site disposal. The holding area was lined with bentonite clay.

Petroleum Waste Oil Tank-A 500-gallon tank stored petroleum wastes from the materials
testing in Building 247. The tank was used from 1961 until it was removed in 1988.

Boundary Roads-Waste motor oil may have been used as a dust suppressant in the 1940s
and 1050s. Most of the roads are presently paved.
SWMU 27
Building 206 Roundhouse Sump, Building 206-Fluids used to clean locomotives were
reportedly drained into the sump. Pesticides were reportedly stored in Building 206. A
service pit in Building 206 may have been used to transfer fuel oil from UST Site 7 to the
boiler room.
-------
SWMU 29

SWMU 30
Table 2-1. (Continued)

Used Motor Oil Pit-Former motor disposal pit. Period of operation is uncertain.

Salvage Area-Former salvage area. No information regarding the types or volumes of
wastes is available.
SWMU 31
SWMU 33
SWMU 64
Wood Preservation Area-Site was used for wood preservation operations from the mid-
1950s until 1960. Wood products were dipped into vats of phenolic compounds and carbolic
acid to prevent the wood from rotting. The vats were covered with canvas tarps. Spills from
the vats were reported.

Industrial Waste Pipeline (IWPL)-The IWPL was constructed in 1972. Discharges to the
IWPL included paint spray wastewater, phosphoric acid and sodium hydroxide from
strippers and rinse tanks, pesticide wastewaters, cleaning tank washwaters, steam cleaner
washwater, and acid washwater.

Waste Oil Pit-A 1,000-gallon metal tank that contained waste oils from the automotive
maintenance shop was located at this location. The tank was installed in 1975 and removed
in 1988.
Area 1 Building 236

Area 1 Building 237
Solvent Storage Area.

Former Solvent Storage Area-Now used for cleaning asphalt application tools and
equipment.
Area 3
Drum Storage Area-Former drum storage area. Some drums may have leaked or spills may
have occurred.
Building 15
Drum Storage Area-Petroleum hydrocarbons and metals wastes were previously stored at
this site. The site includes a concrete slab where materials are stored.
Building 22

Building 23

Building 30
Drum Storage Area-Site includes a paved area where materials are stored. Drums of
solvents may have been stored here in the past.

Area is adjacent to several open storage areas. Previously called Containment Area 5.

Drum Storage Area-Petroleum hydrocarbons and metals wastes were previously stored at
this site. Solvents may have been stored here. The site is partially covered by the
Consolidated Subsistence Facility (constructed in 1992).
-------
Table 2-1. (Continued)

Surface and Near This nonvegetated area of bare soil in the northern depot was used as a storage area for the
Surface Soils National Stockpile of Strategic Metals. From 1980 to 1986, lead ballast was stored here.
From shortly after World War II until the 1980s, ferrous chromium was stored in Quadrants
VII and VIII. Manganese ore was also stored here from shortly after World War II until the
1970s.

Day Care Center A 1,200-gallon UST containing No. 2 fuel oil was previously located at this site from 1956
until 1988. Pesticide contamination was also found in soil samples.

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Table 2-3. Status of the UST Sites, DDJC-Tracy, Comprehensive RI/FS and UST Site Investigations

Findings Recommendations
Number
Number of
RI/FS
Phase 1
Soil
Regulated
Under Tri
Regional
Groundwater Tank Location Guidelines/
Site of Tanks Removal Borings Contaminants Contaminants NotFound
CERCLA
Additional Removal
Characterization a Action/Remediation b
No
Further
Action c Current Status
UST 1
UST 2
UST 3
UST 4
UST 5
UST 6
UST 7
UST
UST 9
UST 10
UST 11
UST 12
1988
1988
1973
1988
1988
1988
1988
1988
1989
1988
1988
NA
ND ND

ND ND

TPH-G, BTEX, TPH-G, BTEX,
EDB TPH-MO

TPH-D, TPH-D BTEX
TPH-MO
NA NA

ND TPH-D X

TPH-D, BTEX TPH-D, BTEX

ND ND

Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional x
Guidelines

Tri-Regional
Guidelines
CERCLA

Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
Tri-Regional
Guidelines
x Site Closed g

x Site Closed g

x Additional
Investigation
Planned
Characterization
Complete h
Identified and
Investigated as
SWMU 64
Characterization
Complete h
Characterization
Complete h
x Site Closed g

x Site Closed g

-------
Table 2-3. (Continued)
Findings
Recommendations
Regulated
Site
UST 13
UST 14
UST 15
UST 16
UST 17
UST 18
UST 19
UST 20
UST 21
UST 22
UST 23
Number of Under Tri
RI/FS Regional
Number Phase 1 Soil Groundwater Tank Location Guidelines/
of Tanks Removal Borings Contaminants Contaminants NotFound CERCLA
1 1988 3 TCE, Pest TCA, TCE, Pest Tri-Regional
Guidelines

1 1988 3 TPH-G, BTEX ND Tri-Regional
Guidelines
1 1988 2 ND ND Tri-Regional
Guidelines
1 NA NA NA NA Tri-Regional
Guidelines
1 1988 3 1 TPH-D ND Tri-Regional
Guidelines
1 1988 3 TPH-D ND Tri-Regional
TPH-MO, Guidelines
BTEX
1 1988 3 TPH-D, BTEX ND Tri-Regional
Guidelines
1 1988 3 TPH-D TPH-D X Tri-Regional
Guidelines
1 1988 NA NA NA CERCLA

1 1988 2 Toluene ND Tri-Regional
Guidelines
2 1988 6 Toluene, Xylene ND Tri-Regional
Guidelines

No
Additional Removal Further
Characterization a Action/Remediation b Action c Current Status
X d Continued
Investigation as
SWMU 20
X XX Additional
Investigation
X Site Closed g

Active and
permitted UST
X Site Closed g

X X Additional
Investigation

X X Additional
Investigation
Characterization
Complete 1
Identified and
investigated as
SWMU 6
X Site Closed g

X Site Closed g

-------
Table 2-3. (Continued)

Findings
Recommendations
Number
Site of Tanks Removal
UST 24
UST 25
UST 26
UST 27
UST 28
UST 29
UST 30 1
UST 31
UST 32 1
1988
1988
1988
1988
1988
1988
1988
1988
1988
Number of
RI/FS
Phase 1
NA

Soil Groundwater Tank Location
Contaminants Contaminants NotFound
TPH-D TPH-D

TPH,BTEX TPH-D,
Benzene
ND ND

TPH-D, Xylene, Xylene
TPH-MO
ND ND

ND ND

NA NA

TPH-D, Toluene
Ethylbenzene
Regulated
Under Tri
Regional No
Guidelines/ Additional Removal Further
CERCLA Characterization Action/Remediation b Action c
Tri-Regional X X
Guidelines
Tri-Regional X X
Guidelines
Tri-Regional X
Guidelines
Tri-Regional X X
Guidelines
Tri-Regional X
Guidelines
Tri-Regional X
Guidelines
Tri-Regional X
Guidelines
CERCLA

Tri-Regional X
Guidelines

Current Status
Additional
Investigation
Additional
Investigation
Site closed g

Additional
Investigation
Site Closed g

Site Closed g

Identified and
investigated as
SWMU 24
Additional
Investigation
-------
Table 2-3. (Continued)

a Continue with characterization under the Tri-Regional Guidelines program.
b Removal action performed by Sacramento District USAGE under Pre-placed Remedial Action Contracts (PRAC). Sites requiring no further action under Tri-Regional Guidelines will be
coordinated with RWQCB for closure.
c No further action necessary under the Tri Regional Guidelines program.
d UST 13 Closure Report submitted due to no evidence of fuel-related contamination. However, non-fuel-related constituents will continue to be investigated as SWMU 20, located
adjacent to the former UST 13 site. Additional sampling will be conducted along the 1WPL to confirm that nearby diesel hits along the pipeline are not related to this UST.
e UST 3 was abandoned in place in 1972.
f Additional investigations were performed in 1995 and 1996. A detailed description of the results is provided in the final UST Site Investigation Field Work Report (Radian. 1996c)
potential remedial alternatives are currently being assessed.
g Approved for closures by RWQCB (Letter from Karen Bessette dated 15 Aug 1996)
h Natural attenuation is recommended at this site.
i Bieventing combined with natural attenuation is recommended at this site.

BTEX = benzene, toluene, ethylbenzene, and xylenes
CERCLA = Comprehensive Environmental Response, Compensation and Liability Act
EDB = ethylene dibromide:
IWPL = Industrial Wastewater Pipeline
NA = not applicable
ND = not detected
Pest = pesticides
RWQCB = Regional Water Quality Control Board
SWMU = Solid Waste Management Unit
TCA = trichloroethane
TCE = trichlortoethene
TPH-D = total petroleum hydrocarbons as diesel
TPH-G = total petroleum hydrocarbons as gasoline
TPH-MO = total petroleum hydrocarbons as motor oil
USAGE = U.S. Army Corps of Engineers

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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

3.1 A Proposed Plan summarizing the alternatives considered in the DDJC-Tracy Comprehensive
Remedial Investigation/Feasibility Study (RI/FS) was released in November 1996 and was made
available to the public in the Administrative Record located at DDJC-Tracy's Environmental
Protection Division, Building S-108 Sharpe Facility, Lathrop, California, and in the Information
Repository maintained at the same address. The Proposed Plan was also mailed to the
installation's 1,200-address mailing list on 31 January 1997. The 30-day public comment period
on the Proposed Plan ran from 5 February to 6 March 1997. A Public Notice appeared on 4, 14, and
18 February 1997 in the Tracy Press, and on 4, 16, and 18 February in the Stockton Record to
announce the Proposed Plan's public comment period and to invite the community to attend a
public meeting held on 19 February 1997, at the City of Tracy Community Center, Tracy,
California. Comment responses are provided in the Responsiveness Summary.

3.2 The 19 February public meeting was held to answer the community's guestions about the
Proposed Plan and to solicit public input on the selected remedial alternatives presented in the
Proposed Plan. Meeting attendees are listed in Table 3-1.

3.3 The document was made available to the public in the Administrative Record located at
DDJC-Tracy's Environmental Protection Division, Building S-108 Sharpe Facility, Lathrop,
California, and in the Information Repository maintained at the same address.

3.4 The DDJC-Tracy ROD and the related Proposed Plan are based on the site's Administrative
Record and were developed in accordance with applicable federal and state laws, regulations and
codes, including the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and, to the
extent practicable, the National Contingency Plan (NCP).
-------
Table 3-1. DDJC-Tracy Public Meeting a Attendees
Name
Art Dohrman
Bruce Whisenant
John Crow
Mike Eisenzimmer
Steve Glover
Steve Light
Capt. Casey
Col. Melton
Doug Imberi
Fred Green
John S. Green
Roxanne Yonn
John Guzman
Peter Kalush
Victoria Shankel
Wes Harris
Bruce McCarty
Jim Pinasco
Karen Bessette
Michael Work
Deborah Hirsch
Jeff Herrin
Graham Sharpe
Rob Owens
Rose Newman
John Lamb
Bert Heffner
Donald Springer
Glenn Robertson
Jeff Stewart
Marjorie Hannon
Phil Martin
Robert Raspo
Stephen Reid
Affiliation
U.S. Army Corps of Engineers (CEHNC-ED-CS-G)
U.S. Army Corps of Engineers (CEHNC-ED-CS-P)
U.S. Army Corps of Engineers (CEHNC-ED-ME-H)
U.S. Army Corps of Engineers (CEHNC-ED-ME-E)
U.S. Army Corps of Engineers (CEHNC-ED-CS-P)
U.S. Army Corps of Engineers (CEHNC-PM-ED)
DDJC
DDJC
DDJC
DDJC
DDJC
DDJC
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Environmental Office (ASCW-BE)
DDJC Office of Counsel
CAL EPA (DTSC)
CAL EPA (RWQCB)
US EPA, Region IX
Radian International
Radian International
Radian International
CAL EPA (DTSC)
Lawrence Livermore National Laboratory
Remedial Resources/Prime Environmental
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
Citizen
a Meeting held on 19 February 1997
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4.0 SCOPE AND ROIiE OF THE RESPONSE ACTION

4.1 As with many Superfund sites, the environmental issues at Defense Depot San Joaquin
(DDJC)-Tracy are complex. As a result, DDJC-Tracy organized the environmental response program
into two phases. Operable Unit (OU) 1 was defined in the first phase as the contaminated
groundwater within the Upper Tulare Formation, both on- and off-depot, that is emanating from
DDJC-Tracy. The OU 1 contamination was addressed first because the concerns associated with OU 1
were considered the most urgent. Remedies have already been selected for OU 1 (see Section 2) ,
and the Record of Decision (ROD) (WCC, 1993) for this operable unit was signed in August 1993. A
pump-and-treat system has been installed to treat groundwater. The expanded OU 1 treatment
system will begin operation in the first quarter of 1998.

4.2 This ROD is the second phase of the DDJC-Tracy environmental response program and addresses
all of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
issues. This ROD will serve as the Final Remedial Action Plan for DDJC-Tracy.

4.3 All contaminated media at the depot are addressed in this ROD. The objectives of this
comprehensive ROD are as follows:

• Reaffirm or modify as appropriate the selected remedy from the OU 1 ROD. The OU 1
ROD specifically indicated that all groundwater chemicals of concern and pathways
would be reevaluated in the Comprehensive RI/FS (OU 1 ROD, Section 4.2.2) and that
the feasibility of a more stringent aquifer cleanup standard would be evaluated (OU
1 ROD, Section 4.2.4) .

• Address the sites of soil/vadose zone contamination identified in the comprehensive
remedial investigation program (see Table 2-1).

• Document the selected remedial actions and document that they are protective of
human health and the environment.

4.4 The sites addressed in this ROD are identified in Table 2-1. Each of the Solid Waste
Management Units (SWMUs) and soil areas was investigated for potential surface and near-surface
soil contamination. Impacts to groundwater from these sites were identified and evaluated
through monitoring and modeling. A risk assessment was also performed to identify threats to
human health and ecological receptors. This ROD identifies the sites selected for no further
action (NFA) and selects remedies for the remainder of the sites. By addressing all contaminated
media, this ROD completes the identification of appropriate remedies for DDJC-Tracy.

5.0 SUMMARY OF SITE CHARACTERISTICS

5.1 Background

5.1.1 Several phases of Remedial Investigation/Feasibility Study (RI/FS) have been conducted at
DDJC-Tracy. The results of these RI/FSS have been reported in the following:

Operable Unit 1 Field Sampling Report DDRW-Tracy, California (Woodward-Clyde
Consultants, 1992)

DDRW-Tracy, California, Final Comprehensive Site Wide RI/FS: Phase I Site
Characterization Report (Montgomery Watson, 1994b).

• DDRW-Tracy Draft Comprehensive RI/FS. Phase II Technical Memorandum (Montgomery
Watson, 1995a) .

• DDRW-Tracy, California: Final Comprehensive Remedial Investigation/Feasibility
Study, Vols. I and II (Montgomery Watson, 1996a).

5.1.2 The goals of the Comprehensive RI/FS were to identify and investigate potential sources of
contamination at DDJC-Tracy and to collect data to support the evaluation and selection of
remedial alternatives, the baseline risk assessment (BRA), the ecological risk assessment (ERA),
and the design of the selected remedies (Montgomery Watson, 1996a). The RI/FSs were
comprehensive in that these goals were met. A summary of the human health risks may be found in
-------
Sections 6.1 through 6.5, and a summary of the ecological risks may be found in Section 6.6.

5.1.3 The remainder of this section presents summaries of the sites investigated at DDJC-Tracy.
Section 5.2 presents a site characterization summary of the contaminants in the Operable Unit
(OU) 1 groundwater at DDJC-Tracy. Section 5.3 introduces the site characterization summaries of
the contaminants in the soil at DDJC-Tracy. Sections 5.4, 5.5, 5.6, and 5.7 present brief
summaries of the Group A sites, the Group B sites, the Group C sites, and the No Further Action
site, respectively Section 5.8 presents the Time Critical Removal Action Site.

5.1.4 Soil, groundwater, sediment, and surface water are present at DDJC-Tracy. Soils at the
depot consist of shale-pebble conglomerates of the Tulare Formation and the overlying
Quaternary alluvium. The Tulare Formation, which composes most of the geologic column at
DDJC-Tracy, has been divided into the Above Upper, the Upper, the Middle, and the Lower
Horizons.

5.1.5 The Above Upper Horizon is the uppermost 25 to 35 feet of clays, silts, silty sand, and
clayey sand. This interval is saturated only from the northern portion of the depot to the
central portion of the annex. The Upper Horizon is a coarse-grained interval (predominantly sand
and gravel, with lenses of silt, silty sand and clay) ranging between the depths of
approximately 25 to 60 feet below ground surface (bgs). The Middle Horizon is another
coarse-grained interval (silty sand, sand, and gravel) separated from the Upper Horizon by the
Upper/Middle Aguitard. The Middle Horizon occurs in the depth interval between approximately 55
to 85 feet bgs. The top of the Lower Horizon occurs at a depth of approximately 110 feet bgs and
consists primarily of sand and gravel. Fine-gained materials are present at a depth of
approximately 170 feet bgs. Surface water and sediment occur locally at DDJC-Tracy only as part
of the storm drain lagoon (SWMU 4) and the sewage and former industrial waste lagoons (SWMUs
2/3) .

5.1.6 Each of the media present at DDJC-Tracy (soil, groundwater, sediment, and surface water)
has been impacted by contaminants originating from past practices at the depot. The
contaminants of concern (COCs) were identified using the following criteria:

• The concentration of the COG in the groundwater exceeds the criteria for beneficial
uses of groundwater or background groundwater guality;

• The concentration of the COG in the surface water, sediment, or soil has the
potential to exceed the criteria for beneficial uses of groundwater or background
groundwater guality as indicated by the fate and transport (F&T) modeling conducted
as part of a water guality site assessment (WQSA); or

• The COG exceeds the risk criteria for either human or ecological receptors.

5.2 Groundwater

5.2.1 The groundwater at DDJC-Tracy has been impacted by a variety of contaminants. The primary
classes of groundwater COCs are volatile organic compounds (VOCs), pesticides, and herbicides.
Contaminated groundwater is present in plumes, several of which are migrating off site to the
north. Operable Unit 1 was designated in 1992 as a separate entity from the soil and shallower
contaminants so that the OU 1 groundwater contamination could be addressed before soil problems.
The final OU 1 Record of Decision (ROD) (WCC, 1993) was signed in August 1993.

5.2.2 Operable Unit 1 is defined as the contaminated groundwater plume, on and off depot, that
is emanating from DDJC-Tracy. This plume is primarily characterized by tetrachloroethene (PCE)
and trichloroethane (TCE). The distribution of these two contaminants is shown in Figures 5-1
and 5-2. The identified sources of VOCs to the groundwater are:

SWMU I/Area 2;

SWMU 6;

SWMU 8 (possible);

SWMU 20 and Area 1 Building 10;
-------
SWMU 33;

Area 1 Building 237; and

Area 3.

5.2.3 The selected remedy for OU 1 is groundwater extraction and treatment. Groundwater is being
extracted from the Upper, Middle, and Lower Horizons. Extracted groundwater is being treated by
air stripping. The groundwater from two wells is also being treated using liquid-phase granular
activated carbon (GAG to remove pesticides. Treated groundwater is being reinjected into the
Upper Tulare Formation using infiltration galleries. A small portion of the plume is being
allowed to attenuate naturally as described in the Memorandum of Significant Differences, dated
20 December 1995.

5.2.4 The OU 1 ROD established cleanup levels of maximum contaminant levels (MCLs) for TCE, PCE,
and 1,1-DCE. Other VOCs detected in groundwater, including bromoform, carbon disulfide,
cis-l,2-DCE, trans-1,2-DCE, methylene chloride, benzene, toluene, and xylenes, have been
detected only sporadically and at low concentrations, so cleanup levels were not established for
them.

5.2.5 Chloroform has also been detected sporadically in groundwater in a group of installation
monitoring wells (LM003A, LM030AU, LM101A, and LM094AU) and two off-depot wells (LM055B and
LM056C. The maximum detected concentration of chloroform is 16 Ig/L. The probable source of
chloroform is the transformation of chlorine from the wastewater treatment plant or potable
water leaked from water mains at the facility. The locations of the wells where chloroform was
detected are too far to the west and across gradient to be attributed to off-site sources.
However, these sporadic detections do not constitute a plume that requires additional cleanup
limits in the OU 1 remedy. The concentrations of chloroform will continue to be monitored as
part of the ongoing Groundwater Monitoring Program at DDJC-Tracy.

5.2.6 The occurrence of chloroform, bromodichloromethane, and dibromochloromethane
concentrations in LM003AA and the "disappearance" of consistently detected TCE and PCE in the
fourth quarter 1996 sample suggest that treated water was the "source" of contamination at that
location. All of the chloroform occurrences have been downgradient from SWMU 2 and SWMU 3, which
have received chlorinated effluent from the waste-water treatment plant for a number of years.

5.2.7 A separate discussion of a remedy for chloroform is not necessary in this document
because:

• There is no defined chloroform plume associated with depot activities;

• Chloroform concentrations are less than 10% of the California Action Level for
trihalomethanes in drinking water supplies; and

• All chloroform concentrations have been reported within the outer boundaries of
Upper, Middle, or Lower Horizon TCE plumes.

5.2.8 Pesticides and herbicides have been detected in OU 1 groundwater. Detected contaminants
include dieldrin, chlordane, ODD, DDE, DDT, monuron, and diuron. These contaminants have
primarily been identified in the northwestern portion of the depot. The primary sources of these
contaminants to the groundwater are the sewage and industrial waste lagoons, burn pit No. 2
(SWAU 8), and the industrial waste pipeline (SWMU 33). Figure 5-3 shows the distribution of
dieldrin in groundwater. A dieldrin plume can be observed to emanate from the sewage and
industrial waste lagoons (SWMUs 2 and 3). The other pesticides and herbicides do not display a
geographic distribution that can be characterized as a plume.

5.3 Soil

5.3.1 The soil at many of the sites at DDJC-Tracy has been contaminated by past activities at
the installation. The primary classes of contaminants in the soil include VOCs (also identified
in soil gas), semivolatile organic compounds (SVOCs), and pesticides. Metals and SVOCs are minor
contaminants in the soil. For the most part, COCs in the soil are those with the potential to
exceed the criteria for beneficial uses of groundwater or background groundwater
-------
quality-primarily VOCs, and pesticides but also occasional SVOCs.

5.3.2 Sections 5.4 through 5.7 present brief site characterization summaries (SCSs) of the
results of the RIs at each of the sites at DDJC-Tracy. These sections summarize the Final
Comprehensive Remedial Investigation Feasibility Study Vols. I and II (Montgomery Watson,
1996a). The SCSs present information that was relevant to the decision about whether or not to
include a site in the FS. The SCSs present the following data:

• A brief summary of the past activities at a site that may have caused contaminants
to be released to the environment;

• A brief summary of RI/FS activities conducted at a site;

• A tabulation of those contaminants that were identified as COCs based on the
criteria presented in Section 5.2. The tabulation includes a presentation of the
criteria exceeded (e.g., risk to human health, threat to beneficial uses of
groundwater);

• The identification of the criteria exceeded; and

• The calculated volume of contaminated soil and the mass of the contaminants in the
soil at that site.

5.3.3 Soil volume and contaminant mass data were generated by averaging the concentrations of
contaminants in each affected area and multiplying the average concentration by the soil volumes
provided in the RI/FS. These calculations are presented in a table in each SCS in Section 5.4,
5.5, and 5.6.

5.3.4 Section 5.4 comprises the SCSs for the Group A sites, the sites where a potential threat
to groundwater exists because of the presence of VOC contamination in the soil. Section 5.5
comprises the SCSs for the Group B sites and other sites with soil contamination. Section 5.6
comprises the SCSs for the Group C sites, the sites associated with past and present DDJC-Tracy
industrial waste systems that were evaluated in an Engineering Evaluation/Cost Analysis. Section
5.7 comprises the SCSs for the sites recommended for No Further Action.

5.4 Group A

5.4.1 ST/JMU I/Area 2-Old Sewage Lagoon/Drum Storage Area (Group A)

5.4.1.1 Volatile organic compounds and PCBs have contaminated soil as the result of past site
activities. SWMU 1 and Area 2 were a source of TCE and PCE to groundwater. SWMU 1 and Area 2
were evaluated together because of their geographic proximity. Table 5-1 summarizes those
contaminants that pose a risk to either the groundwater or human/ecological receptors. Table 5-2
summarizes the volume and mass of the contaminants in the soil at this site. Figures B-l, B-2,
B-3, and B-4 show sampling locations and analytical results from SWMU I/Area 2. This combined
site was evaluated in the FS because groundwater was impacted. This site also poses a potential
future threat to beneficial uses of groundwater and background groundwater guality because the
contaminants have the potential to migrate to groundwater. In addition, the soil poses a
potential risk to depot workers.

Site Characteristics

Past Site Activities

SWMU 1 - Old Sewage Lagoon

• Sanitary sewage effluent was discharged to the lagoon until 1942.

• Lagoons were abandoned and backfilled in 1944.

• Site is the reported location of old sewage lagoons.
-------
• Site is the reported location of a former Area 2 Drum Storage Area.

• Chemicals stored in drums possibly leaked or were discharged accidentally.

Area 2 was used from 1957 until 1984.

RI/FS Activities

• Site investigation activities at SWMU I/Area 2 included soil gas surveys, soil
sampling, well installation, and groundwater monitoring.

• A WQSA, a fate and transport (F&T) analysis, and a BRA were performed for SWMU
I/Area 2. Summaries of the WQSA and the BRA are presented in Section 6.0.

Conclusions

• SWMU I/Area 2 was a source of PCE to the OU 1 groundwater plume.

• Contaminant F&T modeling indicated that PCE in the soil is a potential ongoing
threat to beneficial uses of groundwater and to background groundwater. F&T modeling
also indicated that TCE in the soil gas is a potential future threat to beneficial
uses of groundwater and to background groundwater guality.

• F&T modeling indicated that Aroclor 1260 may be a potential future threat to
beneficial uses of groundwater; however, Aroclor 1260 was detected in only one soil
sample.

Table 5-1. Summary of Fate and Transport and Risk Data for SWMU I/Area 2

Threat to Threat to
Impacted Beneficial Uses of Background Cancer Hazard Ecological
Medium Groundwater Groundwater Quality Risk Index Risks

Soil VOCs (TCE, PCE), VOCs (TCE, PCE) 1x10 -5 depot <1 construction None
potentially PCBs worker worker
(Aroclor 1260)

Table 5-2. Estimated Volume and Mass of COCs in Soil for SWMU I/Area 2
Volume of Impacted Soil (yd 3) Mass of COCs (pounds)

39,000 PCE: 3.2

5.4.2 Area 1 Building 237 (Group A)

5.4.2.1 Tetrachloroethene (PCE) has contaminated soil as the result of past site activities.
Area 1 Building 237 was a source of PCE to groundwater. Table 5-3 summarizes the risk of PCE to
groundwater and human and ecological receptors. Table 5-4 summarizes the volume and mass of the
contaminants in the soil at the site. Figure B-5 shows sampling locations and analytical
results from Area 1 Building 237. This site was evaluated in the FS because groundwater was
impacted by past site activities. This site also poses a potential future threat to groundwater.

Site Characteristics

Past Site Activities

Area is north of Building 237. Site is also close to UST 12 and SWMU 33.

• Site is used for cleaning asphalt tools and eguipment.
-------
• Solvents were formerly used and stored in this area.

• Site is covered with gravel and asphalt.

RI/FS Activities

• Site investigation activities at Area 1 Building 237 included soil gas surveys, soil
sampling, and groundwater monitoring.

• A WQSA, an F&T analysis, and a BRA were performed for Area 1 Building 237. Summaries
of the WQSA and the BRA are presented in Section 6.0.
Conclusions
Area 1 Building 237 is a source of PCE to the OU 1 groundwater plume.

Contaminant F&T modeling indicated that PCE in the soil is a potential ongoing
threat to beneficial uses of groundwater and to background groundwater guality.

Compounds other than PCE were detected in soil, soil gas, and groundwater. However,
none exceeded risk criteria or represented a potential or actual threat to
beneficial uses of groundwater or background groundwater guality. Thus, these
compounds are not considered COCs.

Table 5-3. Summary of Fate and Transport and Risk Data for Area 1 Building 237
Threat to Beneficial
Uses of Groundwater

VOCs (PCE)
Threat to Background
Groundwater Quality

VOCS (PCE)
Cancer Risk

1x10 -6 a construction
worker
Ecological
Hazard Index Risks

<1 construction None
worker
Table 5-4. Estimated Volume and Mass of COCs in Soil for Area 1 Building 237
Volume of Impacted Soil (yd 3) Mass of COCs (pounds)
8,300
PCE: 6.3

5.4.3 Area 3-Drum Storage Area (Group A)

5.4.3.1 Trichoroethene (TCE) and PCE have contaminated soil as the result of past site
activities. Area 3 is potentially a continuing source of these contaminants to groundwater.
Table 5-5 summarizes those contaminants that pose a risk to either the groundwater or to
human/ecological receptors. Table 5-6 summarizes the volume and mass of the contaminants in the
soil at this site. Figures B-6 and B-7 show sampling locations and analytical results from Area
3. This site was evaluated in the FS because groundwater was impacted. This site also poses a
potential future threat to groundwater guality.

Site Characteristics

Past Site Activities

• Site was used as a drum storage area.

• Stored drums may have leaked or accidentally spilled.

• Site is covered with asphalt.

• No other sites are near Area 3.

RI/FS Activities
-------
Conclusions
Site investigation activities at Area 3 included soil-gas surveys, soil sampling,
and groundwater monitoring.

An F&T analysis and a BRA were performed for Area 3. A summary of the BRA is
presented in Section 6.0.
Area 3 is a source of PCE and TCE to the OU 1 groundwater plume.

Contaminant F&T modeling indicated that PCE and TCE in the soil represent a
potential ongoing threat to beneficial uses of groundwater and to background
groundwater quality.
Table 5-5. Summary of Fate and Transport and Risk Data for Area 3
Impacted
Medium

Soil
Threat to
Beneficial Uses
of Groundwater

VOCs (PCE, TCE)
Threat to Background
Groundwater Quality Cancer Risk
VOCs (PCE, TCE)
worker

5.5.1.1 Semivolatile compounds, pesticides, herbicides, and metals have contaminated surface
sediment as the result of past site activities. Pesticides (simazine, diuron, monuron, and
dieldrin) may have contaminated groundwater (see analysis in Appendix Q. Surface water and
sediment pose a potential threat to ecological receptors. Table 5-7 summarizes those
contaminants that pose a risk to either the groundwater or human/ecological receptors.
Monitoring data suggest that the model has overestimated the threat to groundwater quality from
this site. Table 5-8 summarizes the volume and mass of the contaminants in the soil at this
site. Figures B-8, B-9, and B-10 show sampling locations and analytical results from SWMU 4.
Soil/sediment and surface water pose a potential risk to ecological receptors.

Site Characteristics

Past Site Activities

• Storm water from DDJC-Tracy has accumulated in the storm drain lagoon since 1971.

• The storm drain lagoon is unlined and bounded by soil berms that are approximately 6
feet high.

• The storm drain lagoon contains water nearly year-round, and waterfowl inhabit the
area.

• The storm drain lagoon reportedly received rinse water from paint-stripping,
degreasing, and steam-cleaning operations.

• This area was used for open storage before 1952.
A stockpile of manganese ore was located northeast of the lagoon area from 1957 to
1968.
-------
RI/FS Activities
Conclusions
Site investigation activities at SWMU 4 included a soil-gas survey, surface water
and sediment sampling, soil sampling, and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were conducted for SWMU 4. A summary of the WQSA
and BRA are presented in Section 6.0.
Dichlorodifluoromethane, chloromethane, and toluene in groundwater are part of the
OU 1 groundwater plume; SWMU 4 is not a source of these compounds.

The pesticides and herbicides simazine, diuron, monuron, and dieldrin cannot be
clearly attributed to SWMU 4.

Contaminant F&T modeling indicated that the pesticides and herbicides carbaryl,
carbofaran, chlordane, 2,4-D, and dieldrin in soil or sediment pose a potential
future threat to groundwater. Monitoring data (see Appendix C) indicate that an
impact is unlikely.

F&T modeling indicated that the SVOCs bis(2-ethylhexyl)phthalate, fluoranthene,
phenanthrene, and pyrene in soil or sediment pose a potential future threat to
groundwater. Monitoring data (see Appendix C) indicate that an impact is unlikely.

The compounds DDD, DDE, and DDT in soil, sediment, or surface water pose a potential
risk to ecological receptors. The estimated risk for the metals zinc and selenium in
soil or sediment are above the benchmark level for ecological receptors; however,
these risks are considered conservative because of the biases in the analytical
data.

Compounds other than those listed above were detected in soil, sediment, surface
water, or groundwater; however, none exceeded the risk criteria or represented a
potential or actual threat to beneficial uses of groundwater or background
groundwater quality. Thus, these compounds are not considered COCs.

Impacted
Medium
Soil
Table 5-7. Summary of
Threat to
Beneficial Uses
Groundwater
None a
Fate and Transport and Risk Data
of Threat to Background
Groundwater Quality
None a
for SWMU 4
Cancer
Risk

-------
5.5.2.1 As the result of past site activities, pesticides and herbicides have contaminated soil.
Lindane (a pesticide) has been released to groundwater, and SWMU 6 is probably a former source
of TCE and PCE to groundwater. Table 5-9 summarizes those contaminants that pose a potential
threat to the groundwater at SWMU 6. Table 5-10 summarizes the volume and mass of the
contaminants in the soil at this site. Figure B-ll shows sampling locations and analytical
results for SWMU 6. This site was evaluated in the FS because groundwater was impacted and
because contaminants in the soil pose a potential future threat to groundwater.

Site Characteristics

Past Site Activities

• This site is the former location of UST 21 and a 250-gallon concrete sump.

• A portion of Building 28 was used for repackaging.

• Wastes from repackaging were collected in the sump.

• The sump operated from approximately 1968 to 1977.

• The sump was initially abandoned in place; it was removed in 1988.

RI/FS Activities

• Site investigation activities at SWMU 6 included soil sampling, a soil gas survey,
and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 6. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Conclusions

• SWMU 6 was a source of PCE and TCE to the OU 1 groundwater plume.

• The pesticide lindane has impacted groundwater at SWMU 6.

• Contaminant F&T modeling indicated that the pesticides and herbicides dicamba,
dieldrin, endrin, heptachlor, lindane, and 2,4,5-T in the soil pose a potential
future threat to groundwater.

Table 5-9. Summary of Fate and Transport and Risk Data for SWMU 6

Impacted Threat to Beneficial Threat to Background Cancer Hazard Ecological
Medium Uses of Groundwater a Groundwater Quality Risk Index Risks

Soil Pesticides and herbicides Pesticides and herbicides
-------
5.5.3.1 As the result of past site activities, VOCs, SVOCs, pesticides, herbicides,
dioxins/furans, and petroleum hydrocarbons have contaminated soil. Dioxins/furans were found to
be extremely immobile in the analytical leaching model and have not been detected in groundwater
to date. SVOCs (bis[2-ethylhexyl]phthalate) and pesticides (octachlorocioxin) may have been
released to groundwater. Table 5-11 summarizes those contaminants that pose a threat to
groundwater at SWMU 7. Table 5-12 summarizes the volume and mass of the contaminants in the soil
at this site. Figures B-12 and B-13 show sampling locations and analytical results for SWMU 7.
This site was evaluated in the FS because groundwater was impacted and because the contaminants
in the soil pose a potential future threat to groundwater.

Site Characteristics

Past Site Activities

• SWMU 7 is the site of seven pits (Pits A-G) now partially or completely beneath
Buildings 15, 19, and 21.

• The pits may have been up to 16 feet deep.

• The pits were reportedly used between 1942 and 1954 for disposing of medical
supplies containing mercury and phosphate compounds, narcotics, Pharmaceuticals,
radiological supplies, and electron tubes.

• Solids and liguids stored or used at the depot may have been buried or burned in the
pits.

RI/FS Activities

• Site investigation activities at SWMU 7 included a geophysical survey, soil gas
surveys, radionuclide, screening, soil sampling, trenching, monitoring well
installation, and groundwater monitoring.

• A WQSA, an F&T analysis, and a BRA were performed for this site. Summaries of the
WQSA and the BRA are presented in Section 6.0.

Conclusions

• Groundwater has been impacted by bis(2-ethylhexyl)phthalate and octachlorocioxin.

• Contaminant F&T modeling indicated that contaminants in the soil pose a potential
future threat to groundwater. These contaminants are:
- Pit F: VOCs (1,2-DCE, TCE)
- Pit C: SVOCs(bis[2 ethylhexyl]phthalate)
- Pesticides and herbicides (dieldrin, linuron)
- Pit D: Pesticides and herbicides (2,4-D, dieldrin, linuron, simazine)
- Petroleum hydrocarbons (TPH-diesel)
-------
Table 5-11. Summary of Fate and Transport and Risk Data for ST/JMU 7
Impacted
Medium

Soil
Threat to
Beneficial Uses of
Groundwater

Pit F: VOCs (1,2-DCE,
TCE)
Pit C: Pesticides and
herbicides (dieldrin,
linuron)

Pit D: Pesticides and
herbicides (dieldrin,
linuron, simazine),
petroleum
hydrocarbons (TPH as
diesel)
Threat to
Background Cancer
Groundwater Quality Risk
Hazard
Index
Pit F: VOCs (1,2-DCE,
TCE)

5.5.4.1 Semivolatile organic compounds (SVOCs), pesticides and herbicides, dioxins/furans, and
petroleum hydrocarbons have contaminated soils as the result of past site practices.
Dioxins/furans are present in soil just above groundwater, but the toxicity eguivalent value in
groundwater was extremely low (about 10 -7 Ig/L) and two orders of magnitude below the federal
MCL for 2,3,7,8-tetrachlorodibenzo-p-dioxin. Pesticides (chlordane, ODD, DDE, and DDT) have been
released to groundwater, and SWMU 8 is probably a former source of VOCs (PCE and TCE) to
groundwater. Table 5-13 summarizes those contaminants that pose a potential threat to the
groundwater and a potential risk to construction workers at SWMU 8. Table 5-14 summarizes the
volume and mass of the contaminants in the soil at the site. Figures B-14, B-15, and B-16 show
sampling locations and analytical results for SWMU 8. This site was evaluated in the FS because
groundwater was impacted, because contaminants in the soil pose a potential future threat to
groundwater, and because contaminants in the soil pose a potential risk to construction workers.

Site Characteristics

Past Site Activities

• SWMU 8 is a single large burn pit that reportedly operated between 1942 and 1971.

• Various containers, crates, wooden pallets, trash, unknown solids and liguids, and
narcotics were burned in the pit.

• Explosions, attributed to intermixing liguid chemicals or burning pressurized
containers, were reported (in interviews) as common in the burn pit.
RI/FS Activities
-------
• Site investigation activities at SWMU 8 included geophysical surveys, soil-gas
surveys, soil sampling, radionuclide screening, trenching, monitoring well
installation, and groundwater monitoring.

• A WQSA, an F&T analysis, and a BRA were performed for this site. Summaries of the
WQSA and the BRA are provided in Section 6.0.

Conclusions

SWMU 8 is a possible source of PCE and TCE to the OU 1 groundwater plume.

• Groundwater at SWMU 8 has also been adversely impacted by the pesticides chlordane,
DDD, DDE, and DDT.

• Contaminant F&T modeling indicated that the contaminants bis(2-ethylhexyl)phthalate,
diethylphthalate, 2,4-dinitrotoluene, naphthalene, chlordane, 2,4-D, DDD, DDE, DDT,
dieldrin, lindane, linuron, MCPA, simazine, TPH as gasoline, TPH as diesel, and TPH
as motor oil in the soil pose a potential future threat to groundwater.

• The contaminants dieldrin, DDD, and DDE also pose a potential risk to construction
workers at the site.
Table 5-13. Summary of Fate and Transport and Risk Data for SWMU 8

Impacted Threat to Beneficial
Medium Uses of Groundwater
SVOCs

5.5.5.1 Volatile organic compounds (VOCs), SVOCs, pesticides and herbicides, and petroleum
hydrocarbons have contaminated soil as the result of past site activities. PCE, TCE, and various
pesticides and herbicides (monuron, diuron, alpha-BHC, methiocarb, and 2,4-D) may have
contaminated groundwater. Table 5-15 summarizes those contaminants that pose a threat to
groundwater at SWMU 20. Table 5-16 summarizes the volume and mass of the contaminants in the
-------
soil at this site. Figures B-17 and B-18 show sampling locations and analytical results for SWMU
20. This site was evaluated in the FS because groundwater was impacted and because contaminants
in the soil pose a potential future threat to groundwater.

Site Characteristics

Past Site Activities

SWMU 20 - Aboveground Solvent Tank

• SWMU 20 included a 500-gallon aboveground solvent (TCE) degreasing unit located
inside Building 10.

• Building 10 was constructed in 1950. According to warehouse plans, several cleaning
facilities were used at various times from 1950 to 1974.

• A spray paint booth and cleaning operations were reportedly connected to a sump
(Manhole W-l of the IWPL [SWMU 33]).

UST Site 13 is close to SWMU 20. This site reportedly contained a 2,000-gallon No. 2
fuel oil tank, which was removed in 1987.

RI/FS Activities

• Site investigation activities at SWMU 20 included soil-gas surveys, soil sampling,
sump sampling, pipeline inspection, monitoring well installation, and groundwater
monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 20. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Conclusions

SWMU 20 was a source of TCE and PCE to the OU 1 groundwater plume.

• Groundwater has also been impacted by monuron, diuron, alpha-BHC, methiocarb, and
2,4-D.

• Contaminant fate and transport modeling indicated that TCE, ethylbenzene, xylenes,
diethylphthalate, 2,4-dinitrophenol, pentachlorophenol, 2,4,6-trichlorophenol,
dieldrin, methiocarb, MCPA, linuron, and TPH-diesel in soil pose a potential future
threat to groundwater.

Table 5-15. Summary of Fate and Transport and Risk Data for SWMU 20

Impacted Threat to Beneficial Threat to Background Hazard Ecological
Medium Uses of Groundwater Groundwater Quality Cancer Risk Index Risks

<1 a depot
worker

SVOCs (2,4-dinitrophenol, SVOCs (diethylphthalate,
2,4,6-trichlorophenol) 2,4-dinitrophenol,
pentachlorophenol, 2,4,6-
trichlorophenol)

Pesticides and herbicides
(dieldrin, methiocarb,
MCPA, linuron)

Petroleum hydrocarbons Petroleum hydrocarbons
(TPH as diesel) (TPH as diesel)
-------
Table 5-16. Estimated Volume and Mass of COCs in Soil for SWMU 20
VOCs: 0.1

TPH: 68.0

Pesticides/PCBs: 0.1

Herbicides: 0.01
5.5.6 SWMU 24-Petroleum Waste Oil Tank (Group B)

5.5.6.1 Volatile organic compounds (VOCs), SVOCs, pesticides, PCBs, and petroleum hydrocarbons
have contaminated soil as the result of past site activities. TPH as gasoline may have been
released to the groundwater at SWMU 24. Table 5-17 summarizes those contaminants that pose a
threat to groundwater or a risk to human receptors. Table 5-18 summarizes the volume and mass of
the contaminants in the soil at this site. Figure B-19 shows sampling locations and analytical
results for SWMU 24. This site was evaluated in the FS because contaminants in the soil pose a
potential future threat to groundwater and because there is a potential risk to future depot
workers.

Site Characteristics

Past Site Activities

• A 500-gallon underground steel tank stored petroleum wastes from materials testing
in Building 247.

• The tank was used from 1961 until it was removed in 1988.

• A visual inspection conducted during tank removal revealed pin holes in the base of
the tank.

RI/FS Activities

• Site investigation activities at SWMU 24 included soil sampling, monitoring well
installation, groundwater monitoring, and air monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 24. Summaries of the WQSA
and the BRA are presented in Section 6.0.
Conclusions
SWMU 24 is located within the OU 1 groundwater plume; however, it is not a source of
contaminants to OU 1.

TPH as gasoline may have been released to groundwater; however, its extent is
extremely limited.

The contaminants acetone, 2-butanone, ethylbenzene, 2-hexanone,
4-methyl-2-pentanone, toluene, xylenes, 2,4-dimethylphenol, fluoranthene,
2-methylnaphthatene, 4-methylphenol, naphthalene, phananthrene, phenol, pyrene,
TPH-gasoline, TPH-diesel, PCBs (Aroclor - 1260), carbofuran, lindane, phorate, and
ronnel in the soil pose a potential future threat to groundwater.

There is a potential risk to future depot workers from manganese.
-------
Table 5-17. Summary of Fate and Transport and Risk Data for SfflMU 24

Threat to
Impacted Beneficial uses of Threat to Background Hazard
Medium Groundwater Groundwater Quality Cancer Risk Index

Soil VOCs (Acetone, 2- VOCs (Acetone, 2-butanone,

5.5.7.1 Volatile organic compounds (VOCs), SVOCs, herbicides, PCBs, and petroleum hydrocarbons
have contaminated soil as the result of past site activities. Groundwater has not been impacted.
VOCs, herbicides, and petroleum hydrocarbons pose a potential threat to the beneficial uses of
groundwater and the background groundwater guality. Table 5-19 summarizes those contaminants
that pose a potential threat to the groundwater at SWMU 27 or a potential risk to human
receptors. Table 5-20 summarizes the volume and mass of the contaminants in the soil at this
site. Figures B-20, B-21, and B-22 show sampling locations and analytical results for SWMU 27.
This site was evaluated in the FS because contaminants in the soil pose a potential threat to
groundwater and because there is a potential risk to depot workers.

Site Characteristics

Past Site Activities

• SWMU 27 includes the waste oil sump for the Area 1 Building 206 railroad roundhouse.

• Aerial photographs indicate that Building 206 existed in 1945.

• Fluids from cleaning the exteriors of locomotives reportedly drained into the sump.

• Pesticides were reportedly applied inside Building 206.
-------
A service pit in Building 206 may have been used to transfer fuel oil from UST Site
7 to the boiler room located in Building 206.
RI/FS Activities
• Site investigation activities at SWMU 27 included soil sampling, sludge sampling,
monitoring well installation, and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 27. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Conclusions

• Contaminant F&T modeling indicated that the compounds TCE, benzo(a)pyrene, total
PAHs, 2,4-D, MCPA, PCBs (Aroclor 1260), 2,4,5-T, and TPH as motor oil in the soil
pose a potential future threat to groundwater.

• The compounds benzo(a)pyrene and PCBs (Aroclor 1260) pose a potential risk to depot
workers.

Table 5-19. Summary of Fate and Transport and Risk Data for
SWMU 27 and Area 1 Building 206

Impacted Threat to Beneficial Threat to
Medium Uses of Background Cancer Ecological
Groundwater Groundwater Quality Risk Hazard Index Risks

VOCs (TCE) 3x10 -4 depot >1 depot
worker worker
(benzo[a],
pyrene, total
PAHs, and
PCBs)
Herbicides (MCPA) Herbicides (2,4-D,
MCPA, 2,4,5-T)

Petroleum Petroleum hydrocarbons
hydrocarbons (TPH as (TPH as motor oil)
motor oil)

Table 5-20. Estimated Volume and Mass of COCs in Soil for
SWMU 27 and Area 1 Building 206

Mass of COCs (pounds)

SVOCs: 10.5

TPH: 1,512

Herbicides: 0.6
5.5.8 Building 30 Drum Storage Area (Group B)

5.5.8.1 Semivolatile organic compounds (SVOCs) have contaminated soil as the result of past
site activities. These compounds pose a potential threat to the beneficial uses of groundwater
and the background groundwater guality; however, groundwater is not currently impacted. Table
5-21 summarizes those contaminants in soil that pose a potential threat to Area groundwater at
the Building 30 Drum Storage Area. Table 5-22 summarizes the volume and mass of the
contaminants in the soil at this site. Figure B-23 shows sampling locations and analytical
results for Building 30 Drum Storage Area. This site was evaluated in the FS because
contaminants in the soil pose a potential threat to groundwater.
-------
Site Characteristics
Past Site Activities
The site is partially covered by the Consolidated Subsistence Facility (which was
constructed in 1992) and is located in the southern portion of DDJC-Tracy.

Solvents were reportedly stored in drum storage areas at DDJC-Tracy.

The site history indicates that petroleum hydrocarbons or metal-containing wastes
were stored at Building 30.
RI/FS Activities
Site investigation activities at the Building 30 Drum Storage Area included soil
sampling. No groundwater samples were collected at this site.

An F&T analysis and a BRA were performed for this site. A summary of the results of
the BRA is presented in Section 6.0.
Conclusions
• Contaminant F&T modeling indicated that the compounds benzyl alcohol,
bis(2-ethylhexyl) phthalate, diethylphthalate, and di-n-butylphthalate in the soil
pose a potential future threat to groundwater.

Table 5-21. Summary of Fate and Transport and Risk Data for
Building 30 Drum Storage Area

Impacted Threat to Beneficial Threat to Background Cancer Hazard
Ecological
Medium Uses of Groundwater Groundwater Quality Risk Index Risks

Soil SVOCs (bis[2-ethylhexyl] SVOCs (benzyl alcohol,

5.5.9.1 Pesticides and metals have contaminated soils as the result of past site activities.
Table 5-23 summarizes those contaminants that pose a potential threat to human receptors. Table
5-24 summarizes the volume and mass of the contaminants at this site. Figures B-24 and B-25 show
sampling locations and analytical results for the Northern Depot soils. This site was evaluated
in the FS because of the potential risk to human receptors.

Site Characteristics

Past Site Activities

• The northern depot is a nonvegetated area of bare soil.
-------
The site was reportedly used as a storage area for the National Stockpile of
Strategic Metals.

From 1980 to 1986, lead ballast was stored in this area.

From shortly after World War II until the 1980s, ferrous chromium ore was stored in
Quadrants VII and VII.

From shortly after World War II until the 1970s, manganese ore was also stored in
this area.
RI/FS Activities
Site investigation activities in the Northern Depot Area included soil sampling
(surface and near surface) and respirable dust level measurements.

An F&T analysis and a BRA were conducted for this site. A summary of the BRA is
presented in Section 6.0.
Conclusions
• Contaminant F&T modeling indicated that none of the contaminants in the soil poses a
potential threat to groundwater.

• The metals arsenic and manganese pose a potential risk to a grader operator.

• The pesticides and herbicides DDD, DDE, DDT, chlordane, dieldrin, endrin, and
lindane were detected in the soil at concentrations that exceeded established
background threshold levels; however, none of the concentrations exceeded the risk
criteria or posed a potential future risk to groundwater.

Table 5-23. Summary of Fate and Transport and Risk Data for Northern Depot Soils

Threat to Threat to
Impacted Beneficial Uses Background Ecological
Medium of Groundwater Groundwater Quality Cancer Risk Hazard Index Risks

Soil None None < 1x10 -6 grader > 1 grader None
operator operator (arsenic
and manganese)
Table 5-24. Estimated Volume and Mass of COCs In Soil for Northern Depot Area

Volume of Impacted Soil (yd 3) Mass of COCs (pounds)

60,820 Metals: 62,827

5.6 Group C

5.6.1 SWMU 2-Sewage Lagoons and SWMU 3-Industrial Waste Lagoons

5.6.1.1 SWMU 2 and SWMU 3 were investigated concurrently. SVOCs, pesticides and herbicides, and
metals have contaminated soil as the result of past site activities. Pesticides and herbicides
are also present in surface water. In addition, pesticides and herbicides (dieldrin, monuron,
diuron, aldrin, chlordane, 2,4-D, DDD, DDE, DDT, delta-BHC, endosulfan, sulfate, endrin,
heptachlor epoxide, linuron, and simazene) have been released to groundwater; VOCs in
groundwater are part of the OU 1 plume. Both soil and surface water pose a threat to ecological
receptors. Table 5-25 summarizes those contaminants that pose a risk either to the groundwater
or to human/ecological receptors at SWMU 2. Table 5-26 summarizes those contaminants that pose a
-------
risk to either the groundwater or human/ecological receptors at SWMU 3. Table 5-27 summarizes
the volume and mass of the contaminants in the soil at SWMU 2 and SWMU 3. Figures B-26, B-27,
and B-28 show sampling locations and analytical results from SWMU 2 and SWMU 3. These sites were
evaluated in the FS because groundwater was impacted, because these sites pose a future
potential threat to groundwater, there is also a potential risk to ecological receptors from
soil, sediment, and surface water.

Site Characteristics of SWMU 2

Past Site Activities

• The site consists of two active sewage lagoons that have been in operation since
1942.

• The lagoons are unlined and bounded by earthen berms.

• The northern lagoon supports abundant vegetation and animal life; this lagoon is
cleared annually, sometimes by burning. The southern lagoon contains grassy
vegetation and reeds.

• The lagoons currently receive treated effluent discharged from the sewage treatment
plant.

• The lagoons previously received effluent from the motor pool wash rack.

• Sometime between 1971 and 1979 industrial wastes from SWMU 3 (Industrial Waste
Lagoons) overflowed into the southern lagoon of SWMU 2.

RI/FS Activities

• Site investigation activities at SWMU 2 included soil/sediment sampling, surface
water sampling, evaluation of hexavalent chromium in soils, well installation, and
groundwater monitoring.

• A WQSA, an F&T analysis, and a BRA were performed for SWMUs 2 and 3. Summaries of
the WQSA and the BRA are presented in Section 6.0.
Conclusions
PCE and TCE detected in groundwater are part of the OU 1 groundwater plume; SWMUs 2
and 3 are not a source of these compounds.

The pesticides and herbicides dieldrin, monuron, diuron, aldrin, chlordane, 2,4-D,
DDD, DDE, DDT, delta-BHC, endosulfan, sulfate, endrin, heptachlor epoxide, linuron,
and simazine have impacted groundwater at SWMUs 2 and 3; dieldrin, monuron, and
diuron are the most prevalent.
-------
Table 5-25. Summary of Fate and Transport and Risk Data for SWMU 2
Impacted
Medium

Soil
Threat to Beneficial
Uses of Groundwater

SVOCs (bis[2-ethylhexyl]
phthalate, 4-methylphenol) ,
pesticides and herbicides
(aldrin, dieldrin, diuron,
lindane, monuron,
heptachlor)
Threat to Background Cancer Hazard
Groundwater Quality Risk Index
< 1x10 -6 >1 depot
depot worker
worker (chlordane,
DDK)
Surface
Water
Pesticides and herbicides
(DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
SVOCs (bis[2-ethylhexyl]
phthalate, 2, 4-dimethyl-
phenol, di-n-butylphthalate,
4-methylphenol)

Pesticides and herbicides
(aldrin, total chlordane,
DDD, DDE, DDT, dieldrin,
diuron, endrin, lindane,
monuron, 2,4-D, heptachlor)
Pesticides and herbicides NC NC
(DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
Ecological
Risks

Pesticides
(DDD, DDE,
DDT) ,
metals
(selenium,
lead)
Pesticides
(DDD, DDE,
DDT)
5.6.2 SWMU 3-Industrial Waste Lagoons

Site Characteristics of SWMU 3
Past Site Activities
The site consists of two lined industrial waste lagoons that are situated within a
larger sanitary sewage lagoon (SWMU 2).

The smaller lagoon was installed in 1972 and was unlined during its first year of
use.

The larger lagoon was installed between 1975 and 1979 and was lined at time of
construction.

Historically, the lagoons received wastewater from the IWPL that included effluent
from the recoup operations from Building 26 (wastewater from repackaging of
petroleum products) and effluent from Building 10 (wastewater from paint-stripping,
degreasing, and steam-cleaning operations).

Phostoxin (an insecticide and rodenticide) was released into the lagoon several
times between 1975 and 1979.

Currently, no effluent is entering the lagoons.
Conclusions
Contaminant F&T modeling indicated that the pesticides and herbicides aldrin,
chlordane, DDD, DDE, DDT, dieldrin, diuron, endrin, lindane, monuron, 2,4-D, and
heptachlor epoxide in the soil, sediment, and surface water pose a potential future
risk to groundwater.

The pesticides and herbicides listed in the previous bullet point also pose a
potential risk to ecological receptors in the surface water and soil. In addition,
the estimated risk for selenium in soil, sediment, or surface water is above the
benchmark level for ecological receptors; however, this risk is considered
conservative because of the biases in the analytical data.
-------
Compounds besides those listed above were detected in soil, sediment, and
groundwater; however, none exceeded the risk criteria or represented a potential or
actual threat to beneficial uses of groundwater or background groundwater quality.
Thus, these compounds are not considered COCs.

Contaminant F&T modeling indicated that the SVOCs bis(2-ethylhexyl)phthalate, 2,4-
dimethylphenol, di-n-butylphthalate, and 4-methylphenol in the soil or sediment pose
a potential future risk to groundwater.
Table 5-26. Summary of Fate and Transport and Risk Data for SWMU 3
Impacted
Medium

Soil
Threat to Beneficial
Uses of Groundwater

SVOCs (bis[2-ethylhexyl]
phthalate, 4-methylphenol)

Pesticides and herbicides
(aldrin, dieldrin, diuron,
lindane, monuron,
heptachlor), metals
(mercury)
Surface
Water
Pesticides and herbicides
(DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
Threat to Background Cancer
Groundwater Quality Risk

SVOCs (bis[2-ethylhexyl] 3x10 -6
phthalate, depot
2,4-dimethylphenol, worker
di-n-butylphthalate, 4- (chlordane,
methylphenol) DDK)

Pesticides and herbicides
(aldrin, total chlordane,
DDD, DDE, DDT, DDK,
dieldrin, diuron, endrin,
lindane, monuron, 2,4-D,
heptachlor)

Pesticides and herbicides NC
(DDD, DDE, DDT, 2,4-D,
dieldrin, diuron, linuron,
oxamyl, simazine, stirofos)
Hazard
Index

<1 depot
worker
Ecological
Risks

Pesticides
NC
Pesticides

(DDD,DDE,
DDT)
NC = not calculated
Table 5-27. Estimated Volume and Mass of COCs in Soil for SWMU 2 and 3
Volume of Impacted Soil (yd 3)

10,000
Mass of COCs (pounds)

Pesticides and herbicides: 102
5.6.3 SWMU 33-Industrial Waste Pipeline (Group C)

5.6.3.1 Volatile organic compounds (VOCs), SVOCs, pesticides, herbicides, and petroleum
hydrocarbons have contaminated soil as the result of past site activities. SWMU 33 was also a
source of VOCs (xylenes, TCE, PCE< 1,1-DCE, 1,1-TCA, 1.1-DCA, and 1,2-DCE) and pesticides (DDD,
DDE, DDT, monuron, diuron, alpha-BHC, and dieldrin) to groundwater. Ethylbenzene has also been
detected in soil at this site. Table 5-28 summarizes those contaminants that pose a risk to
either the groundwater or human/ecological receptors at SWMU 33. Table 5-28 summarizes the
volume and mass of the contaminants in the soil at SWMU 33. Figure B-29 shows sampling locations
and analytical results from SWMU 33. This site was evaluated in the FS because groundwater was
impacted and because there is a potential future threat to groundwater from contaminants in the
soil.

Site Characteristics

Past Site Activities
Historically, waste streams from various shops performing unit operations have been
routed to the industrial waste lagoons (SWMU 3) via the industrial waste pipeline
(IWPL) .
-------
The IWPL was constructed in 1972.

The IWPL is buried approximately 2 to 4 feet below ground surface.

The IWPL is constructed of various materials, including transite, vitrified clay
pipe, and polyvinyl chloride (PVC).

There are two major lines from the IWPL. Both the south IWPL and its branches and
the east IWPL and its branches are approximately 1,200 feet in length.
RI/FS Activities
Conclusions
Site investigation activities at SWMU 33 included soil-gas surveys, soil sampling,
well installation groundwater monitoring, surface water and sediment sampling, a
pipeline assessment, video inspection, air and smoke testing and sump sampling. A
removal action is proposed for this site.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 33. A summary of the WQSA
and the BRA are presented in Section 6.0.
SWMU 33 was a probable source of TCE, PCE, chloroform, 1,1-DCA, and 1,2-DCE in the
OU 1 groundwater plume.

SWMU 33 was also a source of DDD, DDE, DDT, monuron, diuron, alpha-BHC, and dieldrin
to groundwater.

Contaminant F&T modeling indicated that xylenes, diethylphthalate,
di-n-butylphthalate, naphthalene, aldrin, carbaryl, dieldrin, methiocarb, and TPH as
diesel in the soil are potential threats to groundwater.
Compounds besides those listed above were detected in soil, soil gas, and
groundwater; however, none exceeded the risk criteria or represented a potential or
actual threat to beneficial uses of groundwater or background groundwater guality.
Thus, these compounds are not considered COCs.

Table 5-28.
Summary of Fate and Transport
and Risk Data for
SWMU 33

Threat to Beneficial Threat to
Impacted
Medium
Soil

Uses of
Groundwater

SVOCs (naphthalene)

Background
Groundwater Quality
Vocs (xylenes) a
SVOCs
(diethylphthalate,
di-n-ibutylphthalate,
naphthalene)
Cancer
Risk

<1X10 -6
construction
worker

Hazard
Index

<1
construction
worker

Ecological
Risks

None

Pesticides (carbaryl,
methiocarb)
Pesticides (aldrin,
carbaryl, dieldrin,
methiocarb)
Petroleum
hydrocarbons (TPH as
diesel)
Petroleum hydrocarbons
(TPH as diesel)
a Suspected former source of VOCs to groundwater.
-------
Table 5-29. Estimated Volume and Mass of COCs in Soil for SWMU 33

Volume of Impacted Soil (yd 3) Mass of COCs (pounds)
33 SVOCs: 1.2

TPH: 750

Pesticides/PCBs: 0.04

5.7 No Further Action Sites

5.7.1 SWMU 5-Old Industrial Lagoon, Building 255 (No Further Action)

5.7.1.1 Soil and groundwater have not been adversely impacted; therefore, this site is
recommended for no further action. Groundwater beneath this site is within the area of OU 1
groundwater contamination; however, the source of TCE in groundwater was not SWMU 5. Table 5-30
summarizes the F&T and risk data for SWMU 5. Figure B-30 shows sampling locations and analytical
results from SWMU 5.

Site Characteristics

Past Site Activities

• The site is located north of Building 255 and south of the railroad tracks.

• The site was constructed by 1952 based on aerial photographs.

• The lagoon received rinse water from paint-spraying and paint-stripping operations
in Building 255.

• The lagoon was enlarged in 1963 and existed until at least 1971.

• In 1972 or 1973, the unlined lagoon was cleaned and backfilled.

• The area is not paved and contains slight topographic depressions where water ponds
during the rainy season.

RI/FS Activities

• Site investigation activities included a geophysical survey, a soil-gas survey, soil
sampling, and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 5. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-30. Summary of Fate and Transport and Risk Data for SWMU 5

Threat to
Background
Threat to Beneficial Groundwater
Uses of Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None
-------
Site Characteristics
Past Site Activities
• The site is located in the eastern portion of DDJC-Tracy.

• Subsistence waste, primarily food, was reported to have been buried in the pit
beginning in 1947. Packaging materials were also buried.

RI/FS Activities

• Site investigation activities included a geophysical survey, soil sampling, well
installation, and groundwater monitoring.

WSQA, an F&T analysis, and a BRA were performed for SWMU 9. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-31. Summary of Fate and Transport and Risk Data for SWMU 9

Threat to Threat to
Beneficial Uses Background
of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 < 1 construction None
construction worker worker

5.7.3 SWMU 10-Medical Waste Burial Pit(No Further Action)

5.7.3.1 Soil and groundwater have not been adversely impacted by past practices at SWMU 10:
therefore, the site is recommended for no further action. Table 5-32 summarizes the F&T and risk
data for SWMU 10. Figure B-32 shows sampling locations and analytical results from SWMU 10.

Site Characteristics

Past Site Activities

• The site is located in the open area south of Buildings 21 and 22 along the
southeastern margin of DDJC-Tracy.

• The site is a former medical waste burial pit.

• Outdated medical supplies, including narcotics, mercury, and phosphate compounds,
were buried at this site.

• Aerial photographs show that the pit operated from approximately 1949 until 1965.

• Since 1967, this area has been used for storing truck trailers.

RI/FS Activities

• Site investigation activities included a geophysical survey, soil-gas surveys trench
excavations, soil sampling, and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 10. Summaries of the WQSA
and the BRA are presented in Section 6.0.
-------
Table 5-32. Summary of Fate and Transport and Risk Data for SWMU 10
Threat to
Beneficial Uses
of Groundwater

None
Threat to
Background
Groundwater Quality

None
Cancer Risk

< 1x10 -6 depot
worker
Hazard Index

< 1 depot worker
Ecological Risks

None
5.7.4 SWMU 10A-Possible Medical Waste Burial Pit (No Further Action)

5.7.4.1 Although soil has been contaminated with SVOCs and metals, the groundwater has not been
adversely affected by this contamination. Therefore, the site is recommended for no further
action. Table 5-33 summarizes the F&T and risk data for SWMU 10A. Figure B-33 shows sampling
locations and analytical results from SWMU 10A.

5.7.4.2 Appendix T.3 of the RI/FS (Montgomery Watson, 1996a) evaluated the feasibility of
remediating diethylphthalate and di-n-butylphthalate at this site. Excavation of the
contaminated soil was estimated to cost $2,047,000. Because these phthalates were suspected lab
contaminants, the expenditure to remediate this site was not considered justified.

Site Characteristics

Past Site Activities

• The site is located in an open area south of Buildings 13 and 14 in the southern
portion of DDJC-Tracy.

• The pit was reportedly used to bury medical supplies.

• A 1945 aerial photograph shows three large strips of disturbed ground, possibly
trench scars. These scars are evident in photographs through 1967.

• The 1969 photographs show undisturbed surface and a parking lot on the north side of
the area. The area in the immediate vicinity is slightly vegetated.

RI/FS Activities
Site investigation activities included a geophysical survey, a trench investigation,
soil-gas surveys, soil sampling, and groundwater monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 10A. Summaries of the
WQSA and the BRA are presented in Section 6.0.

Table 5-33. Summary of Fate and Transport and Risk Data for SWMU 10
Impacted
Medium

Soil
Threat to
Beneficial Uses
of Groundwater
Threat to
Background
Groundwater
Quality
Cancer Risk
SVOCs SVOCs
-------
5.7.5 SWMU 11-Burial of Lime/Foot Bath (No Further Action)

5.7.5.1 No evidence of disposal activities has been identified; therefore, the site is
recommended for no further action. Table 5-34 summarizes the F&T and risk data for SWMU 11.
Figure B-34 shows sampling locations and analytical results from SWMU 11.

Site Characteristics

Past Site Activities

• The site is located along the west side of Building 13 in the southern portion of
DDJC-Tracy.

• The site was reportedly a burial site for disposing of lime materials associated
with lime/foot baths.

• The area is currently covered with asphalt.

• No evidence of disposal activities was identified based on Phase I RI activities.

RI/FS Activities

• Site investigation activities included a soil-gas survey and a geophysical survey.
Because no anomalies were detected during the geophysical survey, soil sampling and
groundwater sampling were not conducted.

• A WQSA was not conducted at SWMU 11. It is likely that the materials reportedly
disposed of at SWMU 11 were actually disposed of at SWMU 10A. Thus, SWMU 11 may have
been misidentified. A BRA was performed for SWMU 11. A summary of the BRA is
presented in Section 6.0.

Table 5-34. Summary of Fate and Transport and Risk Data for SWMU 10

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 depot < 1 depot worker None
worker

5.7.6 SWMU 12-Embalming Fluid Dump (No Further Action)

5.7.6.1 Soil and groundwater have not been adversely impacted by past practices at SWMU 12;
therefore, the site is recommended for no further action. Table 5-35 summarizes the F&T and risk
data for SWMU 12. Figure B-35 shows sampling locations and analytical results from SWMU 12.

Site Characteristics

Past Site Activities

• The site is located on the southern portion of DDJC-Tracy, just east of Building 30,
Consolidated Subsistence Facility.

• The site operated between 1945 and 1946.

• An unknown but substantial guantity of embalming fluid containing formaldehyde was
buried just east of Building 30, Consolidated Subsistence Facility.

• Surface drainage is to a topographic low west of the site.

• The area is not paved.
-------

RI/FS Activities

• Site investigation activities included a geophysical survey, a soil-gas survey, soil
sampling, and groundwater sampling from a HydroPunch sample (HP28), and groundwater
monitoring.

A WQSA, an F&T analysis, and a BRA were performed for SWMU 12. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-34. Summary of Fate and Transport and Risk Data for SWMU 10

Threat to
Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 depot < 1 depot worker None
worker

5.71 SWMU 14-Lube Oil Dump (No Further Action)

5.7.7.1 Semivolatile organic compounds (SVOCs), pesticides, TPH, and metals have been released
to the soil, but do not pose a threat to groundwater. Groundwater has not been adversely
impacted by past activities at SWMU 14; therefore, the site is recommended for no further
action. Table 5-36 summarizes the F&T and risk data for SWMU 14. Figuire B-36 shows sampling
locations and analytical results from SWMU 14.

Site Characteristics

Past Site Activities

• The site is located on the southern end of DDJC-Tracy, just east of Building 30,
Consolidated Subsistence Facility.

• The site was reportedly a former lube oil dump.

• Reportedly, 150 drums of new lube oil were emptied into a trench in 1976. The trench
was backfilled with soil.

• A 1980 aerial photograph shows oil seepage visible on the surface.

• During the installation of a water line across the site in 1992, workers reported a
black, viscous substance in the west wall of the trench.

• The area is unpaved.

RI/FS Activities

• Site investigation activities included geophysical surveys, soil-gas surveys, soil
sampling, trenching investigations, well installations, and groundwater monitoring,

An F&T analysis, a WQSA and a BRA were performed for SWMU 14. Summaries of the WQSA
and the BRA are presented in Section 6.0.
-------
Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 14

Threat to Beneficial
Uses of Threat to Background
Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 < 1 construction None
construction worker worker

5.7.8 SWMU 15-Pesticide Waste Trench (No Further Action)

5.7.8.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 15;
therefore, the site is recommended for no further action. Table 5-37 summarizes the F&T and risk
data for SWMU 15. Figure B-37 shows sampling locations and analytical results from SWMU 15.

Site Characteristics

Past Site Activities

• The site is located on the southern end of DDJC-Tracy, just east of Building 30.
Consolidated Subsistence Facility.

• The site was a pesticide waste trench from approximately 1977 until late 1978 or
early 1979.

• Rodent bait, crushed cans that previously contained pesticides, or phosgene
(phostoxin) slurry may have been buried in the trench.

• Empty DDT containers may have been disposed of in this trench.

• Between 1979 and 1980 the trench was excavated and its contents were disposed of
off-site.

• Two underground water lines run through the middle of the former trench.

• The area is currently unpaved.

RI/FS Activities

• Site investigation activities included a geophysical survey, soil-gas surveys, soil
sampling, well installation, and groundwater monitoring.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 15. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-37. Summary of Fate and Transport and Risk Data for SWMU 15

Threat to Beneficial
Uses of Threat to Background
Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 depot < 1 depot worker None
worker

5.7.9 SWMU 16-Possible Waste Disposal Area (No Further Action)

5.7.9.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 16;
therefore, the site is recommended for no further action. Groundwater SWMU 16 beneath this site
is located in the vicinity of known OU 1 groundwater contamination. However, SWMU 16 is
-------
not the source of this contamination. Table 5-38 summarizes the F&T and risk data for SWMU 16.
Figure B-38 shows sampling locations and analytical results from SWMU 16.

Site Characteristics

Past Site Activities

• The site is located on the northern portion of DDJC-Tracy, just south of Building
26.

• The site was possibly a waste disposal area that operated between 1952 and 1967.

• Reportedly, the following items may have been buried at this site: asbestos;
mercury; fluorescent bulbs; and medical supplies containing narcotics, mercury, and
phosphate compounds.

• The area is currently unpaved and unused.

RI/FS Activities

• Site investigation activities include a geophysical survey, soil-gas surveys, soil
sampling, well installation, and groundwater monitoring.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 16. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 16

Threat to Threat to
Impacted Beneficial Uses of Background
Medium Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

Soil None None < 1x10 -6 < 1 None
construction construction
worker worker

5.7.10 SWMU 21-Battery Acid Dump (No Further Action)

5.7.10.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 21;
therefore, the 1 site is recommended for no further action, Groundwater beneath this site is
within the vicinity of OU 1 groundwater contamination: however, the source of this contamination
in the groundwater is not SWMU 21. Table 5-39 summarizes the F&T and risk data for
SWMU 21. Figure B-39 shows sampling locations and analytical results from SWMU 21.

Site Characteristics

Past Site Activities

• The site is located on the northern portion of DDJC-Tracy, just west of Building
201.

• The site was a battery acid dump area.

• The neutralized solution from the battery shop waste was discharged onto the ground
and later into a sump behind Building 201 and allowed to evaporate or seep into the
ground.

• The area surrounding SVWU 21 is paved with asphalt.

RI/FS Activities
-------
• Site investigation activities included a soil-gas survey, soil sampling, groundwater
sampling from a HydroPunch device (HP29), and groundwater monitoring.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 21. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 21

Threat to Threat to
Impacted Beneficial Uses Background Hazard Ecological
Medium Groundwater Groundwater Quality Cancer Risk Index Risks

Soil None None

5.7.11 SWMU 22-Previous Hazardous Materials Storage Area (No Further Action)

5.7.11.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 22.
therefore, the site is recommended for no further action. Table 5-40 summarizes the F&T and risk
data for SWMU 22. Figure B-40 shows sampling locations and analytical results from SWMU 22.

Site Characteristics

Past Site Activities

• The site is located east of Building 22 in the eastern portion of DDJC-Tracy.

• The site was the previous location for hazardous materials storage for DDJC-Tracy
from 1979 until 1985.

• The site was used for storing leaking containers of hazardous materials prior to
off-site disposal or repackaging in Building 28.

• The holding area was lined with bentonite (clay).

• Aerial photographs show drums in the areas that were labeled as ammonium
thiosulfate.

• The area is unpaved.

RI/FS Activities

• Site investigation activities included a geophysical survey, soil-gas surveys, soil
sampling, well installation, and groundwater monitoring.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 22. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 22

Threat to
Threat to Background
Beneficial Uses of Groundwater
Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None < 1x10 -6 construction < 1 construction None
worker worker
-------
5.7.12 SWMU 23-Building 26 Recoup Operations (No Further Action)

5.7.12.1 Volatile organic compound (PCE, TCE) formerly impacted groundwater at SWMU 23. No
continuing threats to groundwater, human health, or ecological receptors were identified at the
site. Table 5-41 summarizes the fate and transport and risk data for SWMU 23.

Site Characteristics

Past Site Activities

• SWMU 23 includes Building 26 and was used for repackaging petroleum products,
including oils, solvents, and ethylene glycol.

• The site was originally a wash rack constructed in 1950.

• A small floor drain in Building 126 was reportedly connected to the industrial
wastewater system via SWMU 33.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 23

Threat to Beneficial
Uses of Threat to Background
Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.13 SWMU 25-Boundary Roads (No Further Action)

5.7.13.1 Soil has not been adversely impacted by past activities at SWMU 25; therefore, the site
is recommended for no further action. Table 5-42 summarizes the F&T and risk data for SWMU 25.
Figure B-41 shows sampling locations and analytical results for SWMU 25.

Site Characteristics

Past Site Activities

• This site includes the boundary roads of DDJC-Tracy.

• Waste motor oil may have been used as a dust suppressant on the boundary roads in
the 1940s and 1950s.

• Most of the roads are currently paved. The unpaved portions located along the
southern depot boundary were investigated during the Phase I RI. The unpaved
portions are coated with a bituminous (oil and gravel) surface.

RI/FS Activities

• Site investigation activities included soil sampling.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 25. Summaries of the WQSA
and the BRA are presented in Section 6.0.
-------
Table 5-36. Summary of Fate and Transport and Risk Data for ST/JMU 25

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological
Risks

None None

5.7.14 SWMU 29-Used Motor Oil Pit (No Further Action)

5.7.14.1 No evidence of disposal activities has been identified; therefore, the site is
recommended for no further action. Table 5-43 summarizes the F&T risk data for SWMU 29. Figure
B-42 shows sampling locations and analytical results from SWMU 29.

Site Characteristics

Past Site Activities

• The site is located north of Building 225 and west of SWMU 2 in the northern portion
of DDJC-Tracy. The actual location is uncertain.

• The site is a former used motor oil disposal pit.

• The period of operation is uncertain.

• The area in the immediate vicinity of the site has been extensively excavated for
underground utilities and is currently covered with asphalt.

RI/FS Activities

• Site investigation activities included a geophysical survey and soil-gas surveys.

• Because there was no evidence of disposal activities at SWMU 29, no F&T analysis,
WQSA, or BRA was conducted.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 29

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.15 SWMU 30-Salvage Area (No Further Action)

5.7.15.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 30;
therefore, the site is recommended for no further action. SWMU 30 is located within the area of
the known OU 1 plume; however, the source of contamination is not SWMU 30. Table 5-44 summarizes
the F&T and risk data for SWMU 30. Figures B-43 and B-44 show sampling locations and analytical
results from SWMU 30.

Site Characteristics

Past Site Activities

• The site is located south of Building 22 in the eastern portion of DDJC-Tracy.
-------
• The site is a former salvage area.

• No information is available on the history or type of waste disposal practices in
this area.

• The area in the immediate vicinity of the site is unpaved.

RI/FS Activities

• Site investigation activities included soil-gas sampling, soil sampling, and
groundwater monitoring from various wells.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 30. Summaries of the WQSA
and the BRA are presented in Section 6.0.

Table 5-36. Summary of Fate and Transport and Risk Data for SWMU 30

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological
Risks

None None

5.7.16 SWMU 31-Wood Preservation Area (No Further Action)

5.7.16.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 31;
therefore, the site is recommended for no further action. SWMU 31 is located within the area of
the known OU 1 groundwater contamination, but is not considered a potential source area. Table
5-45 summarizes the F&T and risk data for SWMU 31. Figure B-45 shows the sampling locations
and analytical results from SWMU 31.

Site Characteristics

Past Site Activities

The site is located east of Building 247.

• The site was used for wood preservation operations from the mid- 1950s until 1960.

• Wood products, primarily pallets, were reportedly dipped into large vats containing
phenolic compounds and carbolic acid to prevent the wood from rotting.

• The vats sat in the open and were covered with canvas tarps. Liguid was reportedly
spilled from the vats during operation.

• The area in the immediate vicinity is paved.

RI/FS Activities

• Site investigation activities included soil sampling and groundwater monitoring.

An F&T analysis, a WQSA, and a BRA were performed for SWMU 31. Summaries of the WQSA
and the BRA are presented in Section 6.0.
-------
Table 5-36. Summary of Fate and Transport and Risk Data for ST/JMU 31

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.17 STCMU 64-Waste Oil Pit (No Further Action)

5.7.17.1 Soil and groundwater have not been adversely impacted by past activities at SWMU 64;
therefore, the site is recommended for no further action. SWMU 64 is located on the upgadient
edge of the known area of OU 1 groundwater contamination, but is not considered a potential
source. Table 5-46 summarizes the F&T and risk data for SWMU 64. Figure B-46 shows the
sampling locations and analytical results from SWMU 64.

Site Characteristics

Past Site Activities

• The site is located on the northern side of Building 201.

• This site included a 1,000-gallon metal tank that contained waste oils generated by
the automotive maintenance shop in Building 201.

• Waste oils were stored in the tank temporarily, pending off-site disposal.

• The tank was installed in 1975 and removed in 1988.

• The excavated area is covered with asphalt, and the area in the immediate vicinity
of SWMU 64 is covered with concrete.

RI/FS Activities

• Site investigation activities included soil sampling, well installation, and
groundwater monitoring.

• An F&T analysis and a BRA were performed for SWMU 64. A WQSA was not performed for
SWMU 64 because only a few samples (metals) exceeded background concentrations and
then only marginally. A summary of the BRA is presented in Section 6.0.

Table 5-46. Summary of Fate and Transport and Risk Data for ST/\MU 64

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological
Risks
None None

5.7.18 Area 1 Building 236 (No Further Action)

5.7.18.1 Soil has not been adversely impacted by the past activities at this site; therefore,
the site is recommended for no further action. Area 1 Building 236 is located within the known
area of OU 1 groundwater contamination, but is not considered a potential source of the
contamination. Table 5-47 summarizes the F&T and risk data for Area 1 Building 236. Figure B-47
shows the sampling locations and analytical results from Area 1 Building 236.

Site Characteristics
-------
Past Site Activities

• The site is located in the northern portion of DDJC-Tracy in the central shops and
maintenance area directly east of Building 236.

• Solvents have historically been used or stored in this area.

• The area is covered with asphalt.

RI/FS Activities

• Site investigation activities included soil sampling.

• A BRA was performed for Area 1 Building 236. A WQSA was not performed because the
methylene chloride detected in the soil was determined to probably be the result of
laboratory contamination. A summary of the BRA is presented in Section 6.0.

Table 5-47. Summary of Fate and Transport and Risk Data for Area 1 Building 236

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.19 Building 15 Drum Storage Area (No Further Action)

5.7.19.1 Soil has not been adversely impacted by past activities at the Building 15 Drum Storage
Area; therefore, the site is recommended for no further action. Table 5-48 summarizes the F&T
and risk data for the Building 15 Drum Storage Area. Figure B-48 shows the sampling locations
and analytical results from the Building 15 Drum Storage Area.

Site Characteristics

Past Site Activities

• The site is located in the central portion of DDJC-Tracy between A and B Streets.

• The site includes a concrete slab on which various materials are currently stored.

• Solvents were stored at drum storage areas at DDJC-Tracy.

• Site history indicates that petroleum hydrocarbons or wastes containing metals were
stored at this site.

• Infiltration galleries for the OU 1 IRM system were recently constructed at the
site.

• The site is not near other RI sites.

RI/FS Activities

• Site investigation activities included soil sampling.

• Because no contaminants of potential concern were identified, the F&T analysis, the
WQSA, and the BRA were not conducted for the Building 15 Drum Storage Area.
-------
Table 5-48. Summary of Fate and Transport and Risk Data for Building 15 Drum Storage Area

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.20 Building 22 Drum Storage Area (No Further Action)

5.7.20.1 Soil and groundwater have not been adversely impacted by past activities at the
Building 22 Drum Storage Area; therefore, the site is recommended for no further action. Table
5-49 summarizes the F&T and risk data for the Building 22 Drum Storage Area. Figure B-49 shows
the sampling locations and analytical results from the Building 22 Drum Storage Area.

Site Characteristics

Past Site Activities

• The site is located on the eastern edge of DDJC-Tracy at the easternmost end of B
Street.

• The site includes a paved area on which pallets of materials are currently stored.

• Solvents were stored at drum storage areas at DDJC-Tracy.

• The area is paved with asphalt.

RI/FS Activities

• Site investigation activities included soil sampling and groundwater monitoring.

• An F&T analysis and a BRA were performed for the Building 22 Drum Storage Area. A
WQSA was not performed because the Phase I RI activities indicated that there has
not been a release of contaminants from the Building 22 Drum Storage Area. A summary
of the BRA is presented in Section 6.0.

Table 5-49. Summary of Fate and Transport and Risk Data for Building 22 Drum Storage Area

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks

None None

5.7.21 Building 23 (No Further Action)

5.7.21.1 Soil has not been adversely impacted by past activities at this site; therefore, the
site is recommended for no further action. Table 5-50 summarizes the F&T and risk data for
Building 23. Figure B-50 shows the sampling locations and analytical results from Building 23.

Site Characteristics

Past Site Activities

• The site is located in the central portion of DDJC-Tracy, between B and C Streets.
The site is to the east of Building 23 and adjacent to a number of open storage
areas.
-------
• This site is within a larger area identified in previous investigations as being an
area containing potential soil contamination.

• The area in the immediate vicinity of Building 23 is covered with asphalt.

RI/FS Activities

• Site investigation activities included soil-gas surveys and soil sampling.

• Neither an F&T analysis nor a WQSA was conducted for Building 23 because no
chemicals of potential concern were identified. A BRA was performed. A summary of
the BRA is presented in Section 6.0.

Table 5-50. Summary of Fate and Transport and Risk Data for Building 23

Threat to Beneficial Threat to Background
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Ecological Risks
None None

5.8 Day Care Center (Excavation and Disposal-Time Critical Removal Action)

5.8.1 Soil contaminated with SVOCs (PAHs), pesticides, and metals was removed in October 1995.
No threat to groundwater or risks to children remain. Table 5-51 summarizes the F&T and risk
data for the Day Care Center. Figure B-51 shows the sampling locations and analytical results
from the Day Care Center.

Site Characteristics

Past Site Activities

• The site is located on the west side of the depot, north of and adjacent to the main
depot entrance on Chrisman Road.

• A 1,200-gallon metal UST containing No. 2 fuel oil was located at this site.

The UST was installed prior to 1956 and removed in 1988.

• All soil in the lawn area was removed to a depth of 1 foot and replaced with 3
inches of clean soil over 9 inches of clean fill.

RI/FS Activities

• Site investigation activities included soil sampling and groundwater sampling from a
HydroPunch (PH002).

• An F&T analysis and a BRA were performed for the Day Care Center. A WQSA was not
performed because metals and pesticide concentrations at the Day Care Center only
slightly exceeded background levels. A summary of the BRA is presented in Section
6.0.
-------
Table 5-51. Summary of Fate and Transport and Risk Data for Day Care Center

Threat to Beneficial Threat to Background Ecological
Uses of Groundwater Groundwater Quality Cancer Risk Hazard Index Risks

None None 1x10 -6
and hazard index was > 1.0 for children. The increased incremental cancer risk following the action at the
Day Care Center is zero.

6.0 SUMMARY OF SITE RISKS

A baseline risk assessment (BRA) was conducted at Defense Depot San Joaguin (DDJC)-Tracy
(Montgomery Watson, 1996f). The BRA was conducted to determine if remedial action is reguired
given the potential risks to humans, plants, and animals at DDJC-Tracy. Risks that could exist
if no action is taken at DDJC-Tracy were estimated in the BRA. In addition to identifying
potential risks to human health and ecological receptors, the Comprehensive RT/FS (Montgomery
Watson, 1996a) also identified threats to background groundwater guality and beneficial uses
(these threats do not necessarily pose unacceptable risk to human health). The protection of
water guality, the protection of human health, and the protection of ecological receptors were
the major criteria for determining contaminants of concern and whether sites reguired
remediation.

6.1 BRA Methodology

6.1.1 Because DDJC-Tracy is a Superfund site, the BRA was conducted using methods from the
United States Environmental Protection Agency (U.S. EPA) Risk Assessment Guidance for Superfund
(U.S. EPA, 1989a and b; U.S. EPA, 1991a and b). Other applicable supplements were used,
including relevant regional U.S. EPA (Region IX) and state risk assessment guidance (Department
of Toxic Substances Control [DTSC], 1992). The BRA used a conservative and protective approach
that included the following five components:

1. Identification of chemicals of potential concern (COPCs) (also known as hazard
identification);

2. Exposure assessment, including identifying and characterizing the exposure pathways, and
estimating chemical intakes;

3. Toxicity assessment of the COPCs;

4. Risk characterization; and

5. Development of cleanup criteria

6.1.2 The BRA grouped the solid waste management units (SWMUs), the underground storage tanks
(USTs), and soil contamination areas at DDJC-Tracy into 15 exposure units (EUs) based on
location and similarities in contaminants and pathways. The Tracy Annex, OU 1, and property
north of the depot were evaluated as three separate EUs to evaluate groundwater impacts. It is
reasonable to evaluate risks for groups of source areas (Eus) rather than for individual sources
because the sources are close together and receptors may be exposed to contaminants from
multiple sources. The potential for risks from separate EUs to combine and create a larger risk
than the sum of the risks of the individual EUs was considered in an analysis of site-wide risk.
A list of the Eus and associated sites is presented in Table 6-1.

6.2 Identification of COPCs for Humans

The chemicals that were present at a site at levels above background threshold concentrations
but not considered essential nutrients (i.e., the metals sodium, potassium, magnesium, calcium,
-------
and iron) were identified as COPCs. If a chemical was present above the relevant background
threshold in at least one sample within an EU, that compound was evaluated as a COPC for that
EU. The COPCs were evaluated in the toxicity assessment (see Section 6.4) to identify the
chemicals of concern (COCs) that require remediation to protect human health (see Section 6.5).

6.2.1 Current and Future Land Use

Current and future land use at DDJC-Tracy was examined as part of the risk evaluation.
DDJC-Tracy is primarily a storage and distribution facility for various supplies in common use
by the U.S. military services in the western U.S. and throughout the Pacific. In addition, the
depot has residential buildings and a day care center, all of which add potential receptors to
the exposure assessment. The site is also used to train grader operators. The land use
surrounding DDJC-Tracy and the Tracy Annex is primarily agricultural, consisting of irrigated
row crops and orchards. Numerous rural residential developments exist within a 3-mile radius,
including small areas of commercial and industrial land use. The land use at DDJC-Tracy and in
the region surrounding the site is expected to remain the same for the foreseeable future;
however, construction may occur on site or in nearby areas. No known Defense Logistics Agency
plan exists to sell or change the current use of the DDJC-Tracy operations area.

6.2.2 COPCs and Media of Concern

The COPCs, at DDJC-Tracy include volatile organic compounds (VOCs), semivolatile organic
compounds, herbicides, PCBs, petroleum hydrocarbons, metals, and pesticides. These COPCs exist
in surface soil/sediment (0 to 9 inches depth), near-surface soil/sediment (0 to 10 feet depth),
surface water, and groundwater.

6.3 Human Exposure Assessment

The exposure assessment included identifying the following:

• The populations or subpopulations (e.g., children) that may be exposed to COPCs;

• The exposure pathways (i.e., how the COPCs could reach sensitive populations); and

• The magnitude of exposure for these populations (i.e., the amount of a COPC a
population could be exposed to).

• An exposure pathway is complete only if all four of the following elements are
present:

• A COPC must be present in the environment;

• The COPC must have a way to be transported through the environment (i.e., through
soil, water, or air);

• Humans must be exposed to the COPC; and

• A potential human exposure route (e.g., inhalation and ingestion) must exist at the
point of exposure.

6.3.1 Human Receptors and Exposure Pathways

Human receptors evaluated in the BRA include depot workers, visitors, children attending the
on-depot day care center, local residents, agricultural workers, potential future on-depot
residents, construction workers, and grader operators who train at DDJC-Tracy. ("On-depot"
refers to the activities occurring within the operating portion of DDJC-Tracy.) The
environmental transport media that act as pathways for exposure include groundwater, soil,
sediment, and surface water. Table 6-2 summarizes the existing pathways for exposure and Table
6-3 summarizes potential future pathways for exposure.

6.3.2 Exposure Concentrations

Evaluating exposure requires the assessment of an exposure point concentration, or the COPC
-------
concentration that someone may contact. For this assessment, the exposure point concentration
was either the 95% Upper Confidence Limit (UCL) of the mean, or the maximum concentration
detected, whichever was highest. All analytical data from the sampling effort were used in
calculating exposure point concentrations. A concentration equal to one-half the detection limit
was used when chemicals were not detected.

6.3.3 Assumptions Used to Calculate Chemical Exposure

Exposure was estimated in units of milligrams of chemical per kilogram of body weight per day
(mg/kg-day). For example, the milligrams of a chemical entering the body could be calculated as
a water ingestion rate multiplied by the chemical concentration in the water, or an air
inhalation rate multiplied by the chemical concentration in the air. The exposure doses were
estimated using values for input parameters that were consentative and likely to overestimate
exposure.

6.4 Human Toxicity Assessment Associated with COPCs

6.4.1 The toxicity assessment describes the potential harmful effects associated with exposure
to COPCs. Three different methods were used to quantify the toxicity of the COPCs.

6.4.2 Noncarcinogenic effects are characterized by a reference dose (RfD) which is a threshold
below which no effects occur. The U.S. EPA establishes reference doses for ingestion and
inhalation routes (dermal toxicity is based on the oral RfD) with a margin of safety for
sensitive individuals. Reference doses are derived from human epidemiological studies or chronic
animal studies from which extrapolations are made to humans using uncertainty factors. The
uncertainty factor helps to ensure that the extrapolation of experimental data does not
underestimate the potential for noncarcinogenic effects to occur.

6.4.3 Carcinogens are classified into groups A through E by U.S. EPA based on what the weight of
evidence says about the chemical causing human cancer. Carcinogenicity is quantified with a
slope factor (SF), or the cancer risk per unit daily intake of the chemical, expressed in units
of mg/kg-day. The SF represents the upper 95% confidence interval of the slope of the
dose-response curve. The SF times the exposure dose equals the upper-bound estimate of the risk
of developing cancer from exposure to the compound of interest. "Upper-bound" refers to a
conservative estimate of the risks that is calculated from the cancer SF to ensure that actual
cancer risks are not under-estimated. As in the reference dose, uncertainty factors allow for
the extrapolation of chronic animal studies to humans. For this risk assessment, the risks from
multiple COPCs were assumed to be additive; neither synergistic nor antagonistic effects were
considered.

6.4.4 The potential concentration of lead in blood was used to characterize the health risks
caused by exposure to lead. The Cal-EPA Lead Toxicity Model (Leadspread) was used to estimate
the blood-lead levels associated with lead concentrations in soil. A blood-lead level (from
intakes of all sources) of as low as 10 micrograms per deciliter (Ig/dl) has been shown to
decrease attention spans and reduce intelligence quotients in children. According to the model,
blood lead concentrations remained below 10 Ig/L when lead concentrations in the soil were below
130 mg/kg (based on the 95% UCL). Therefore, lead concentrations in the soil of less than 130
mg/kg were eliminated from evaluation by the model and assumed to be harmless.

6.4.5 A summary of the toxicological properties, potential health effects, and the toxicity
criteria values of the COPCs is included in the risk assessment (Montgomery Watson, 1996d).

6.5 Human Risk Characterization

6.5.1 Risk characterization integrates and summarizes the toxicity and exposure assessment
information. The results of risk characterization are carcinogenic and noncarcinogenic
quantitative risk estimates for each medium for each pathway.

6.5.2 Risks for noncancer effects were quantified as a hazard index (HI), the ratio of the
exposure dose to the reference dose. If the sum of the His for all noncarcinogens is less than
1.0, then no chronic health effects are expected. If the HI is greater than 1.0, adverse health
effects are possible. There is some latitude in these conclusions depending on the potential for
underestimating or overestimating the exposure dose.
-------
6.5.3 For carcinogens, risk estimates are the incremental probability that an individual will
develop cancer over a lifetime as a result of exposure to a particular carcinogen or set of
carcinogens, that is, the excess lifetime cancer risks (U.S. EPA, 1989a). According to the
revised National Contingency Plan (NCP) (U.S. EPA, 1990b), carcinogenic risks from exposures at
a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site are in a
potentially acceptable range if they are between 1x10 -4 and 1x10 -6. It is generally accepted
that risks above this range reguire attention, and risks below this range do not reguire
attention.

6.5.4 There is little potential for the depot to become a residential development in the
foreseeable future. Potential future residents were evaluated solely to provide benchmarks for
evaluating receptors with lower potential risk and to fully inform the depot about suitable uses
for different parcels of land.

6.5.5 Summaries of the results of the baseline human health risk assessment are shown in Table
6-4 (for current receptors) and Table 6-5 (for potential future receptors). Risks to potential
future residents on the depot and annex are summarized in the tables, but were not considered in
determining whether remediation is reguired. Under existing conditions, these are not considered
to be potentially completed pathways. If the use of the depot unexpectedly changes, it will be
necessary to reevaluate the selected remedies for any area designated for residential use.

6.5.6 EUs 8, 10, and 11 consist of multiple sites and, therefore, reguired additional analysis
to identify risks on a site-by-site basis. For EU 11, the HI for depot and construction workers
was less than 1 and the cancer risk was less than 1x10 -6; therefore, no remediation was
reguired for this EU (Montgomery Watson, 1997b).

6.5.7 At EU 8, the cancer risk to the depot worker from ingestion, inhalation, and dermal
contact with surface soils was estimated at 3x10 -4. SWMU 27/Area 1 was the only site within EU
8 where surface soil samples were collected and analyzed (no concerns at other sites were
identified in the work plan) so the cancer risk to the current depot worker is attributed to
this site (Montgomery Watson, 1997b). The surface and near-surface soil exposure scenario for
the depot worker and the risk to a future construction worker are summarized in Table 6-6. The
exceedances are associated with SWMU 27/Area 1 Building 206 and with Area 1 - Building 237. Area
1 - Building 237 is not recommended for remediation because the cancer risk (1.3x10 -6) is
associated with arsenic, which is present in concentrations that are considered typical in the
western United States (Shacklette and Boerngen, 1984).

6.5.8 At EU 10, the risks to a construction worker from carcinogenic polycyclic aromatic
hydrocarbons (PAHs), chlordane, dieldrin, DDD, DDE, DDT, polychlorinated biphenyls (PCBs),
dioxins/furans, aluminum, antimony, barium, beryllium, and manganese account for 99% of the
total cancer risk and 99.2% of the hazard index (Montgomery Watson, 1997b). The risk for each of
these chemicals was evaluated at each of the sites and is summarized in Table 6-7. Exceedances
of the benchmark level were calculated at SWMUs 7, 8, and 30. At SWMUs 7 and 24, the hazard
index was estimated at 9 and is associated with manganese. The concentrations of manganese are
typical of those throughout the western United States (Shacklette and Boerngen, 1984). Manganese
concentrations in the west range from <300 to 5,000 mg/kg. At SWMU 30, the cancer risk of
1.3x10 -6 was associated with beryllium. The concentrations of beryllium were within the normal
range for beryllium in the western United States (Shacklette and Boerngen, 1984), and SWMU 30 is
not considered to reguire remediation. Beryllium concentrations in the west range from <1 to 15
mg/kg.

6.5.9 Seven of the sites were identified as reguiring remediation to reduce the increased
lifetime cancer risk (ILCR) to no greater than 1x10 -6 and the hazard index to less than 1.0 for
current and likely potential future receptors (off-depot residents, grader operators, day care
center children, depot workers, and construction workers). These sites include:

• EU 1 (the on-depot groundwater portion of OU 1) has dieldrin and VOCs in concentra-
tions that could present a potential, but unlikely risk to depot workers if a well
were installed into the contaminant plume;

• EU 3 (the off-depot groundwater portion of OU 1) has trichloroethene (TCE) that
presents risks to potential future annex residents, who could be exposed through
ingestion or inhalation;
-------
• SWMU 24 at EU 9 presents potential future risks if a building with poor ventilation
is located on top of the area with the highest concentrations of COPCs;

• SWMU 8 at EU 10 presents potential future risks to construction workers who may be
exposed to organochlorine pesticides in the soils;

• SWMUs 2 and 3 (EUs 4 and 5) present potential risks to depot workers who may be
exposed to pesticides;

• Near surface soils in the northern corner of the depot (EU 8) present potential
future risks to grader operators; and

• SWMU 27 in EU 8 presents potential risks to depot workers if the foundation of
Building 206 is removed. PAHs and PCBs are present in the soils underneath this
foundation.

6.5.10 The cancer risk for a depot worker exposed to constituents (primarily polyaromatic
hydrocarbons, or PAHs) in surface soil at SWMU I/Area 2 was estimated to egual 1x10 -5. This
risk, while above the point of departure of 1x10 -6, is within the potentially acceptable range
of 1x10 -6 to 1x10 -4. Therefore, additional factors need to be examined to determine whether
remediation of PAHs is appropriate for this site.

6.5.11 One of the factors is the potential for exposure to occur. There is a degraded asphalt
pavement/compacted layer at the surface of this area, and the risk assessment considered all
samples above 3.5 feet bgs as surface samples when calculating worker risks. The shallowest
depth at which PAHs were detected was 2.0 feet bgs (PAHs were the chemicals responsible for most
of the risk). However, workers typically only come in contact with the top few inches of soil.
Conseguently, unless the workers excavate down two feet, there will not be a complete pathway
between the workers and the PAHs at this site. The potential for workers to be exposed to PAHs
at this site is considered low.

6.5.12 It should also be noted that the concentrations of carcinogenic PAHs at SWMU I/Area 2 are
typical of what people are exposed to in their everyday lives. The average total concentration
of carcinogenic PAHs from surface soil samples at SWMU I/Area 2 was 0.3 mg/kg. This compares
favorably with the median concentration of 1.1 mg/kg found by Menzie, Potocki, and Santodonato
(1992) in urban background soils, and is in the range of 0.01 to 1.01 mg/kg that was found in
rural soils. Thus, even if exposure pathways are completed at this site, workers will not be
exposed to greater concentrations of PAHs than what people are exposed to on a daily basis in
the United States.

6.5.13 In summary, the risks to workers are in an acceptable range; the exposure pathways for
which the risks were calculated are unlikely to be completed, and the calculated risks are based
on PAH concentrations that are typically encountered in the United States. Conseguently, no
action is an appropriate risk management decision for PAHs at SWMU I/Area 2.

6.5.14 The estimated cancer risk for a worker at SWMU 4 was 1x10 -6. This risk represents a de
minimis risk. It should also be noted that the greatest risk associated with any individual
chemical is only 5x10 -7 . No action is an appropriate risk management decision with respect to
human health risks at this site.

6.5.15 Cancer risks at the Day Care Center were previously estimated at 1x10 -5 . The
contaminated soil was removed from this site as a time-critical removal action. The fill
material brought in to the Day Care Center had no detectable concentrations of volatile
organics, semivolatile organics, pesticides, PCBs, or petroleum hydrocarbons. All metals
detected were either below the EPA Region IX preliminary remediation goal (PRG) for residential
soil or well below the background threshold level for the site. The incremental risk associated
with soils remaining at the Day Care Center was reduced to zero. No other areas within
DDJC-Tracy, as analyzed individually or as part of the site-wide risk, reguired remediation to
protect human health. Table 6-8 identifies the CoCs that reguire remediation and the
concentrations that are protective of human health.

6.6 Ecological Risk Assessment
-------
6.6.1 Background

6.6.1.1 The ecological risk assessment (ERA) evaluated the actual or potential effects of a site
on plants and animals. The objective of the ERA was to estimate the chemical risks to wildlife
on a site for those areas where wildlife habitat currently exists and contamination has been
documented. DDJC-Tracy contains very few areas suitable for wildlife habitat because of the
industrial/commercial land use at the facility. Approximately 75% of the depot is covered with
buildings, roadways, and paved parking areas. No known rare or endangered species of wildlife
have been documented at the depot. The depot is within the historic range of the San Joaguin kit
fox (endangered), the giant garter snake (threatened), Swainsons hawk (threatened), the western
yellow-billed cuckoo (threatened), and the valley elderberry longhorn beetle (threatened).
However, none of these species has been sited during site visits. No critical habitats or
habitats of endangered species have been identified. There are no sensitive habitats, such as
natural high guality wetlands, or aguatic or terrestrial natural areas that provide habitat for
wildlife species on site. However, three on-site areas, though they are man-made, can provide
habitat to wildlife. The three areas are:

• Depot-wide surface soil;

• Surface water and sediment in the SWMU 2 sewage lagoons, referred to as EU 4 in the
BRA (Montgomery Watson, 1996d); and

• Surface water and sediment in the SWMU 4 storm drain lagoon, referred to as EU 6 in
the human health risk assessment.

6.6.1.2 The approach used for the ERA involves identifying chemicals of potential ecological
concern and conducting an exposure assessment, a toxicity assessment, and a risk
characterization.

6.6.2 Identification of COPECs

Chemicals of potential ecological concern (COPECs) are compounds that might have been released
to the environment through site activities that have the potential to pose a health risk to
plants and animals. COPECs are analogous to the COPCs that were identified for their potential
impacts to human health. The following criteria were used to screen the list of COPECs:

• The concentration of the COPEC was compared with background levels;

• The toxicity of the COPEC to plants and animals was assessed;

• The freguency of detection of the COPEC in the samples was determined;

• The COPEC was compared with toxicity benchmarks (e.g., Ambient Water Quality
Criteria [AWQC]); and

• Professional judgment was used.

6.6.3 Exposure Assessment

6.6.3.1 The exposure assessment for ecological receptors was in many ways similar to the
identification of pathways and receptors for human exposures. The assessment included:

• Defining those species or groups of species that exist in each area that could be
exposed to the chemically affected media;

• Selecting the receptors of concern for which to assess risks within each area;

• Determining the complete exposure pathways for the selected receptors of concern;

• Selecting the assessment and measurement endpoints for each area; and

• Estimating the level of chemical exposure based on the type of measurement endpoint
selected for each receptor of concern for each complete exposure pathway.
-------
6.6.3.2 Assessment endpoints are formal expressions of environmental values to be protected and
refer to the characteristics of populations and ecosystems defined over large scales (e.g.,
maintenance of diverse population). The assessment endpoint for the depot-wide surface soil is
to protect the terrestrial habitat at DDJC-Tracy. The assessment endpoint for the industrial and
sewage lagoons (SWMUs 2 and 3) and storm drain lagoon (SWMU 4) is to protect avian species that
use these habitats regardless of how the lagoons are managed.

6.6.4 Toxicity Assessment

Toxicity values, such as lowest observable effects levels, no observable effects levels, and no
observable adverse effects levels were used for the COPECs to define "acceptable" levels of
exposure for the receptors of concern.

6.6.5 Risk Characterization

6.6.5.1 The risk characterization integrates the exposure into a guantitative characterization
of risk posed by the COPEC to each ecological receptor. Only noncarcinogenic health effects
were assessed in the ERA because in the environment the incidence of chemically induced cancer
is insignificant.

6.6.5.2 The only chemical risks to ecological receptors at DDJC-Tracy are the adverse effects
of the industrial and sewage lagoons (SWMUs 2 and 3) and storm drain lagoon (SWMU 4) on bird
species, such as the spotted sandpiper and the great blue heron (storm drain lagoon only). The
primary COPECs of concern in the lagoons are ODD, DDT, and DDE (referred to collectively as
DDTR) and selenium. The DDTR concentrations may reflect background pesticide use in the area of
the depot, rather than use by the depot.

6.6.5.3 Additional monitoring will be performed at SWMUs 2 and 3 to obtain site-specific data
that will be used to refine the risk assessment and cleanup standards. The following preliminary
concentrations (see Appendix D for calculations) are considered protective of ecological
receptors at SWMUs 2 and 3.

Concentration Protective of
Chemical Ecological Receptors (Ig/kg)

Total DDK 241
Lead 28,300
Selenium 616

DDK = DDT + DDE + ODD

6.6.5.4 At SWMU 4, zinc has a hazard index of 70, but this appears to be anomalously high as it
is derived from a sediment concentration of 350 mg/kg. This result implies a hazard at a
concentration as low as 5 mg/kg, whereas the geometric mean soil concentration in the western
United States has been estimated at 55 mg/kg (Shacklette and Boerngen, 1984). Additional
monitoring will be performed at SWMU 4 to obtain site-specific data that will be used to refine
the risk assessment and cleanup standards. The following concentrations (see Appendix D for
calculations) are considered protective of ecological receptors at SWMU 4 (the lead
concentration is lower because bioaccumulation has a greater impact on herons).

Concentration Protective of
Chemical Ecological Receptors (pg/kg)

Total DDK 241
Lead 5,130
Selenium 616

DDK = DDT + DDE + ODD

6.6.5.5 Concentrations of ecological receptors were conservatively estimated using literature
intake benchmarks. The total DDK concentrations are based on values from Heath et al. 1969 and
Anderson et al. 1975. Concentrations of selenium that are protective of ecological receptors
based on intake values reported by Heir et al. 1989 and lead concentrations are based on Edens
-------
et al. 1976 and Edens and Garlich 1983.

6.7 Evaluation of Threats to Groundwater Quality

6.7.1 If any of the following criteria were met for a constituent, it was suspected of posing a
potential threat to groundwater and was included in the initial list of COPCs:

• The constituent was associated with historical practices at the site and was
present at the site above the background soil concentration; and

• The constituent has been detected in groundwater;

6.7.2 To evaluate the fate and transport of these COPCs, a phased approach was used to determine
the potential future impacts of site contaminants on groundwater. The phased approach consisted
of:

1. Screening-level analytical modeling to assess the potential for migration of contaminants in
the vadose zone.

2. A water guality site assessment (WQSA) for metals and pesticides to evaluate the potential
threat to beneficial uses and background groundwater guality.

3. Eguilibrium partitioning of vadose zone contaminants to determine the maximum theoretical
concentration in soil water.

4. Approximate one-dimensional modeling in the vadose zone to determine the likely site-specific
concentration in soil water.

5. Three-dimensional groundwater flow and contaminant transport modeling to assess the impact of
contaminants reaching groundwater at soil-water concentrations in excess of beneficial use
limits.

6.7.3 This analysis was applied to all sites with the exception of the following:

• SWMU 11: Wastes previously believed to have been associated with SWMU 11 were
instead disposed of at SWMU 10A.

• SWMU 64: Only a few samples marginally exceeded background concentrations for some
metals.

• Area 1 Building 236: Methylene chloride was detected at this site, but was
determined to be a laboratory contaminant. No other COPCs were identified at the
site.

• Day Care Center: Metals and pesticide concentrations only marginally exceeded
background concentrations.

6.7.4 The potential for contaminants to migrate through the vadose zone to groundwater was first
assessed using an analytical leachate model (ALM). The model was applied to each site to
determine which COPCs might migrate downward through the soil to groundwater within a period of
100 years. The constituents that would not reach groundwater within 100 years were determined
not to pose a threat to the beneficial uses of groundwater or background groundwater guality and
were eliminated from further consideration as COPCs.

6.7.5 A WQSA was also performed on the metals and pesticides at each of the sites to determine
the potential for groundwater contamination. Site-specific data, generic factors, and background
reference values were used to calculate the relative attenuation reguired to protect
groundwater. Either the Waste Extraction Test was run on the samples with the highest
concentrations of pesticides and metals or the extract concentration was back-calculated
assuming the reaction of soils extract to total metals concentration was consistent. The extract
concentrations were used to determine the attenuation reguired to protect beneficial uses and
background groundwater.
-------
6.7.6 All organic COPCs were further evaluated by equilibrium partitioning analysis (this
approach is less effective than the WQSA for metals). The equilibrium partitioning calculations
used site-specific maximum concentrations of COPCs in the soil to determine the distribution of
contaminants in the soil, the soil water, and the soil gas. The resulting equilibrium-based
concentrations were then compared with beneficial-use limits, background threshold values, and
practical quantitation limits to determine if the theoretical concentrations were in excess of
these values. COPCs with soil-water concentrations less than the applicable background levels
were determined not to pose a threat to groundwater and were eliminated from further
consideration.

6.7.7 One-dimensional modeling further evaluated the potential impacts of compounds that were
detected frequently or had already impacted groundwater. The more exact results of the numerical
vadose zone modeling effort replaced the preliminary screening analytical modeling results.
Numerical models were also used to evaluate the fate and transport of contaminants in
groundwater and the response of the simulated contaminant plumes to the various design
alternatives.

6.7.8 The results of the background threshold evaluation, the ALM, the WQSA, the equilibrium
partitioning assessment, numerical vadose zone modeling, and three-dimensional groundwater
modeling were combined to quantitatively evaluate the overall threat to groundwater quality at
each site. Fate and transport modeling was performed at sites identified as having data gaps in
the remedial investigation to characterize the lateral and vertical extent of contamination. The
results of this assessment for each site are noted in the site characterization summaries in
Section 5 and are summarized in Table 6-9 for all COCs.

6.8 Conclusion

Actual or threatened released of hazardous substances from this site, if not addressed by
implementing the response actions selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
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Table 6-1. Exposure Units, DDJC-Tracy

Exposure Units SWMUs
EU
EU
EU
EU
EU
EU
EU
EU

EU
EU

EU
EU
EU
EU
EU
1
2
3
4
5
6
7
8

9
10

11
12
13
14
15

2
3
4
1
5,20,21,23,27,29,
31,64
24
6,7,8,9,10,16,
22,30
10A, 11, 12,14,15

25
33

USTs
2,3,4,5,6,7,9,10,12,13,14,

15,18,19,22,24,25,26,27,29

28,30,32

1,11,20,23
17
17
Other Areas of Concern

On-depot groundwater (OU 1)
Tracy Annex groundwater (OU 1)
Off-depot groundwater (OU 1)
Area 2
Soil Contamination Area 1 - Bldg. 10, Bldg.
206, Bldg. 236, Bldg.
237; Bldg. 15 Drum Storage Area

Soil Contamination Area 3, Bldg. 22 Drum Storage Area

Bldg. 30 Drum Storage Area
Bldg. 23
Bldg. 23

Day Care Center
EU = Exposure Unit
OU = Operable Unit
SWMU = Solid Waste Management Unit
UST = Underground Storage Tank

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Table 6-4. Summary of Human Health Risks to Current Receptors, DDJC-Tracy
Cancer Risk
Between
1x10 -6 and 1
Off-Depot Groundwater (Exposure Unit 3)
Off-Depot Resident

SWMU 2 - Sewage Lagoons (Exposure Unit 4)
Depot Worker

SWMU 3 - Industrial Waste Lagoons (Exposure
Unit 5)
Depot Worker

SWMU 4 - Storm Drain Lagoon (Exposure Unit 6)
Depot Worker

SWMU I/Area 2 - Old Sewage Lagoon/Drum Storage
Area (Exposure Unit 7)
Depot Worker

Sites in Northern Portion of the Depot (Exposure
Unit 8)
Depot Worker

SWMU 24 - Building 247 Petroleum Laboratory
(Exposure Unit 9)
Depot Worker - Indoor Air
Depot Worker - Outdoor Air

Sites in the Eastern Portion of the Depot (Exposure to
Unit 10)
1x10 -5
2x10 -7
3x10 -6
1x10 -6
1x10 -5a,b
3x10 -4c
NA
NA

3x10 -7
0.9
0.003
0.07
0.01
0.07
0.9
0.7 a
0.06

0.005
Sites in the Southern Portion of the Depot (Exposure
Unit 11)
1x10 -E
0.00001
SWMU 33 - Industrial Waste Pipeline (Exposure
Unit 14)

Day Care Center (Exposure Unit 15)
Day Care Center Children

Depot-Wide Surface/Near-Surface Soil
Grader Operator - Eastern
Grader Operator - Southern
1x10 -8
1x10 -5d
2x10 -7
4x10 -8
0.0007
0.3 d
0.6
0.3
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Table 6-4. (Continued)

a Risk estimates are for soil contamination that has since been remediated. There is also a hazard index potentially greater than one
or a cancer risk potentially greater than 1x10 -6 from indoor air if a building is constructed directly over the area of greatest
contamination.
b The cancer risk is likely between 1x10 -4 and 1x10 -6 if polycyclic aromatic hydrocarbons are substantially more carcinogenic via
dermal than via oral exposure.
c The cancer risk likely exceeds 1x10 -4 if polycyclic aromatic hydrocarbons are substantially more carcinogenic via dermal than via
oral exposure.
d Risk estimates are for soil contamination that has since been remediated.

NA = Not applicable; no exposure to carcinogens by this receptor.
SWMU = Solid Waste Management Unit
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Table 6-5. Summary of Potential Human Health Risks to Future Receptors, DDJC-Tracy, California

Cancer Risk Hazard Index
Between
1x10 -6 and
1
On-Depot Groundwater (Exposure Unit 1)
Depot Worker

Exposure Unit 2 (Annex Groundwater)
Annex Resident c
1x10 -4

2x10 -2

1x10 -4
SWMU 2-Sewage Lagoons (Exposure Unit 4)
On-Depot Residents c

SWMU 3-Industrial Lagoons (Exposure Unit 5)
On-Depot Residents c

SWMU 4-Storm Drain Lagoon (Exposure Unit 6)
On-Depot Residents c
Teenage Swimmer c

SWMU I/Area 2-Old Sewage Lagoon/Drum
Storage Area (Exposure Unit 7)
Construction Worker
On-Depot Residents c

Sites in Northern Portion of the Depot (Exposure
unit 8)
Construction Worker
On-Depot Residents c

SWMU 24-Building 247 Petroleum Laboratory
(Exposure Unit 9)
Construction Worker
On-Depot Residents c

Sites in Eastern Portion of the Depot (Exposure
unit 10)
Construction Worker
On-Depot Residents c

Sites in Southern Portion of the Depot (Exposure
Unit 11)
Construction Worker
On-Depot Residents c

Building 23 and UST 17 (Exposure Unit 12)
Construction Worker
On-Depot Residents c
5x10 -5
9x10 -7
1x10 -9
5x10 -8
9x10 -5
1x10 -6
1x10 -6
5x10 -5
5x10 -6
1x10 -6
6x10 -5
2x10 -6
6x10 -5
2x10 -5
4x10 -4
2x10 -4a
0.05
0.3
1
0.3
0.8
0.0003
0.001
10
10
10
6
-------
Table 6-5. (Continued)
SWMU 33-Industrial Waste Pipeline (Exposure
Unit 14)
Construction Worker 9x10 -9
On-Depot Residents c 4x10 -7

Day Care Center (Exposure Unit 15)
On-Depot Residents 3x10 -5b

Depot-Wide Surface/Near-Surface Soil
Construction Worker (Grader Operator) - Northern 9x10 -7
On-Depot Residents - Northern
On-Depot Residents - Eastern 9x10 -5
On-Depot Residents - Southern 2x10 -5
3x10 -4
0.2
0.4
0.5 b
0.9
30
20
2
a The potential cancer risk would likely exceed 1x10 -4 if polyaromatic hydrocarbons are substantially more carcinogenic via
dermal than via oral exposure.
b Risk estimates are for soil contamination that has since been remediated.
c Not considered a potentially completed pathway or used as a basis for remediation.
SWMU = Solid Waste Management Unit
UST = Underground Storage Tank
-------
Table 6-6. Summary of Cancer Risks at EU 8
Construction Worker

SWMU 5
SWMU 20/23
SWMU 21
SWMU 27/Area 1 Bldg. 206
SWMU 29
SWMU 31
SWMU 64
Area 1 Bldg. 236
Area 1 Bldg. 237
Building 15
UST 2
UST 3
UST 4
UST 5
UST 6
UST 7
UST 9
UST 10
UST 12
UST 13
UST 14
UST 15
UST 18
UST 19
UST 22
UST 24
UST 25
UST 26
UST 27
UST 29
Depot Worker
Surface Soil
N/A
N/A
N/A
3x10-4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Depot Worker
Near-Surface Soil
0
2.2x10 -7
0
1.7x10 -8
0
0
0
0
9.6x10 -7
0
0
0
0
0
0
0
0
0
0
0
1.8x10 -4
0
0
0
0
0
5.6x10 -6
0
0
0
Surface and N
Surface £
1.5x10
0
0
2.1x10
0
1.5x10
0
0
1.3x10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3oi
-7

-5

-7

-6

-------
Table 6-7. Summary of Risks at EU 10
Construction Worker
Cancer Risk
Hazard Index
SWMU 6
SWMU 7
SWMU 8
SWMU 9
SWMU 10
SWMU 16
SWMU 22
SWMU 30
Area 3
Bldg. 22 DSA
UST 28
UST 30
UST 32
8.8x10 -8
4.2x10 -7
2.7x10 -5
6.0x10 -7
0
8.7x10 -7
8.7x10 -7
1.3x10 -6
0
0
0
0
0
2.7x10 -2
9.2
17
1.0x10 -1
1.0x10 -1
5.0x10 -3
1.7x10 -3
2.5x10 -3
0
0
0
0
0
-------
Table 6-8. COCs That Require Remediation for the Protection of Human Health
Site/COC
Media
Concentration Protective
of Human Receptors
Basis
Pathway
OU 1 Groundwater a
Trichloroethene Groundwater
1,1-Dichloroethene Groundwater
Tetrachloroethene Groundwater
Dieldrin Groundwater
SWMU 24
Toluene Soil
SWMU 8
Total DDK Soil
Dieldrin Soil
Near-Surface Soils in Northern
Corner of Depot
Arsenic Soil
Manganese Soil
SWMU 27
Benzo(a)pyrene Soil
Total PAHs e Soil
PCBs (Arochlor - 1260) Soil
5.0 Ig/L
6.0 Ig/L a
5.0 Ig/L
0.05 Ig/L

16,000 Ig/L

30,000 Ig/kg
600 Ig/kg
48 Ig/kg
1,000 Ig/kg

1,000 Ig/kg
15,000 Ig/kg
1,000 Ig/kg
Federal MCL
California MCL
Federal MCL
California Action Level

Risk-based Concentration

Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Risk-based Concentration

Risk-based Concentration
Risk-based Concentration
Risk-based Concentration
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure
Inhalation, Ingestion, Dermal Exposure

Inhalation

Dermal
Ingestion
Inhalation, Ingestion
Inhalation, Ingestion

Dermal, Ingestion
Dermal, Ingestion
Dermal, Ingestion
a The estimated ILCR for on-depot workers exposed to MCL concentrations of CoCs is approximately 4x10 -4. Chloroform and 1,1-dichloroethene contribute
approximately 75 percent and 18 percent, respectively, to the total risk at MCL concentrations.
DDK = Sum of ODD, DDE, and DDT concentrations
MCL = maximum contaminant level
-------
Table 6-9. Summary of Fate and Transport and Water Quality Site Assessment Results
Site/COC
Threat to
Beneficial
Uses in
Groundwater
Threat to
Background
Groundwater
Quality
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses a
Equilibrium
Partitioning Limit
Protective of
Background Water
Quality b
Model Level c
SWMU I/Area 2
VOCs (Ig/kg)
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Yes
Yes
Yes
Yes
2.4
1.3
0.2
0.3
14
NE
Area 1 Building 237
VOCs (Ig/kg)
Tetrachloroethene
(PCE)
Yes
Yes
2.4
0.2
15
Area 3
VOCs (Ig/kg)
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Yes
Yes
Yes
Yes
2.4
1.3
0.2
0.3
22
32
SWMU 4
SVOCs (Ig/kg)
bis(2-Ethylhexyl)phthalate
Fluoranthene
Phenanthrene
Pyrene
Pesticides (Ig/kg)
Carbaryl
Carbofuran
Chlordane, total
2,4-D
Dieldrin
Yes
No
Yes
No

Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
244
8,023
14
5, 610
24
4
10
11
0.1
122
27
14
27

0.2
0.2
10
0.02
0.01
NR
NR
NR
NR

NR
NR
NR
NR
NR
SWMU 6
Pesticides and Herbicides (Ig/kg)
Dicamba Yes
Dieldrin Yes
Endrin No
Heptachlor Yes
Lindane Yes
2,4,5-T No
Yes
Yes
Yes
Yes
Yes
Yes
1.3
0.1
21
0.1
0.2
14
0.01
0.01
0.1
0.04
<0.01
0.02
NE
3d
NE
NE
5
NE
-------
SWMU 7
VOCs (Ig/kg) - Pit F only
1,2-DCE Yes
Trichloroethene (TCE) Yes
SVOCs (Ig/kg) - Pit C only
bis(2-Ethylhexyl)phthalate No
Pesticides (Ig/kg) - Pit C only
Dieldrin Yes
Linuron Yes
Pesticides and Herbicides (Ig/kg) -
Pit D only
2,4-D No
Dieldrin Yes
Linuron Yes
Simazine Yes
Petroleum Hydrocarbons (mg/kg) -
Pit D only
TPH as diesel Yes
Yes
Yes

Yes
1.2
1.3

244
Yes
Yes
Yes
Yes
Yes
Yes
0.1
1
11
0.1
1
1
Yes
NE
0.2
0.3

122

0.01
0.1
0.01
0.01
0.01
0.1
NE
NE
NE

3
NE
NE
3
3
NE
NE
-------
Table 6-9. (Continued)
Constituent
Threat to
Beneficial
Uses in
Groundwater
Threat to
Background
Groundwater
Quality
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses a
Equilibrium
Partitioning Limit
Protective of
Background Water
Quality b
Model Level c
SWMU 8
SVOCs (Ig/kg)
bis(2-Ethylhexyl)phthalate
Diethylphthalate
2,4-Dinitrotoluene
Naphthalene
Pesticides and Herbicides (Ig/kg)
Chlordane, total
2,4-D
DDD
DDE
DDT
DDK, total
Dieldrin
Lindane
Linuron
MCPA
Simazine
Petroleum Hydrocarbons (mg/kg)
TPH as gasoline
TPH as diesel
TPH as motor oil
No
No
Yes
Yes
Yes
Yes
Yes
No
No
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
244
1,222
9
21
10
11
81
NA
7
NA
0.1
0.2
1
1
1
NE
NE
NE
122
0.2
0.4
21

10
0.02
3
15
1
NA
0.01
0.004
0.1
0.1
0.1

NE
NE
NE
NR
NE
NE
NE

NE
NE
NR
NR
NR
NE
2
NE
NE
NE
NE

NE
NE
NE
SWMU 20 and Area 1
VOCs (Ig/kg)
Trichloroethene (TCE) Yes
Ethylbenzene No
Xylenes No
SVOCs (Ig/kg)
Diethylphthalate No
2,4-Dinitrophenol Yes
Pentachlorophenol No
2,4,6-Trichlorophenol Yes
Pesticides and Herbicides (Ig/kg)
Dieldrin No
Methiocarb Yes
MCPA Yes
Linuron Yes
Yes
Yes
Yes

Yes
Yes
Yes
Yes

Yes
Yes
Yes
Yes
1.3
653
582

1,222
11
227
10

0.1
1
1
1
0.3
1
0.3

0.2
5
7
7

0.01
1
0.1
0.1
36
NE
NE

NE
NE
NE
NE

27
NE
NE
NE
-------
Petroleum Hydrocarbons (mg/kg)
TPH as diesel
Yes
Yes
NE
NE
NE
SWMU 24
VOCs (Ig/kg)
Acetone
2-Butanone (MEK)
Ethylbenzene
2-Hexanone
4-Methyl-l-pentanone
(MIBK)
Toluene
Xylenes
SVOCs (Ig/kg)
2,4-Dimethylphenol
Fluoranthene
2-Methylnaphthalene
4-Methylphenol
Naphthalene
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
89
30
653
0.3
436
56
582
34
8,023
6
17
21
1
1
1
1
1

0.4
0.3

1
3
6
1
21
NR
NR
NR
NR
NR

NR
NR

NR
NR
NR
NR
NR
-------
Constituent
Threat to
Beneficial
Uses in
Groundwater
Table 6-9. (Continued)

Threat to
Background
Groundwater
Quality
Equilibrium
Partitioning
Limit Protective
of Beneficial
Uses a
Equilibrium
Partitioning Limit
Protective of
Background Water
Quality b
Model Level c
SWMU 24 (cont.)
SVOCs (Ig/kg)
Phenanthrene
Phenol
Pyrene
Petroleum Hydrocarbons (mg/kg)
TPH as gasoline
TPH as diesel
Pesticides and PCBs (Ig/kg)
PCBs (Aroclor 1260)
Carbofuran
Lindane
Phorate
Ronnel
Yes
Yes
Yes
Yes

Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes

Yes
Yes
Yes
Yes
Yes
14
1
5,610
NE

182
4
0.2
17
1,038
14
0.3
27
NE

45
0.2
0.004
2
1
NR
NR
NR
NR

NR
NR
NR
NR
NR
SWMU 27
VOCs (Ig/kg)
Trichloroethene (TCE) No
SVOCs (Ig/kg)
Benzo(a)pyrene No
Total PAHs No
Pesticides, Herbicides, and PCBs (Ig/kg)
2,4-D No
MCPA Yes
PCBs (Aroclor 1260) No
2,4,5-T No
Petroleum Hydrocarbons (mg/kg)
TPH as motor oil Yes
Yes
1.3
No
No
Yes
Yes
No
Yes
NA
NA
11
1
NA
14
Yes
NE
0.3

NA
NA

0.02
0.1
NA
0.02

NE
36 c

NE
NE

NE
NE
NE
NE

NE
Building 30 Drum Storage Area
SVOCs (Ig/kg)
Benzyl alcohol
bis(2-Ethylhexyl)phthalate
Diethylphthalate
di-n-Butylphthalate
No
Yes
No
Yes
Yes
Yes
Yes
Yes
1,618
244
1,222
83,401
0.3
122
0.2
119
NE
NE
NE
NE
-------
Surface and Near-Surface Soils Northern Depot Area
Metals (Ig/kg)
Arsenic No
Manganese No
SWMU 2 and SWMU 3
SVOCs (Ig/kg)
bis(2-Ethylhexyl)phthalate
2,4-Dimethylphenol
di-n-Butylphthalate
4-Methylphenol
Pesticides (Ig/kg)
Aldrin
Chlordane, total
DDD
DDE
DDT
DDK, total
Dieldrin
Diuron
Endrin
No
No
NA
NA
Yes
No
No
Yes
Yes
No
No
No
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
244
34
83,401
17
3
10
81
484
7
NA
0.1
4
21
NA
NA
NE
NE
122
1
119
1
0.3
10
3
15
1
NA
0.01
0.1
0.1
NE
NE
NE
NE
NE
NR
NR
NR
NR
NR
0.1 (11) f
NE
120 (120)
-------
Constituent

SWMU 2 and SWMU 3 (cont.)
SVOCs (Ig/kg)
Lindane (Gamma-BHC)
Monuron
2,4-D
Heptachlor epoxide

SWMU 33
VOCs (Ig/kg)
Xylenes
SVOCs (Ig/kg)
Diethylphthalate
di-n-Butylphthalate
Naphthalene
Pesticides (Ig/kg)
Aldrin
Carbaryl
Dieldrin
Methiocarb
Petroleum Hydrocarbons (mg/kg)
TPH as diesel
Threat to
Beneficial
Uses in
Groundwater
Yes
Yes
No
Yes
No

No
No
Yes

No
Yes
No
Yes

Yes
Table 6-9. (Continued)

Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
Yes

Yes
Yes
Yes

Yes
Yes
Yes
Yes

Yes
Eguilibrium
Partitioning
Limit Protective
of Beneficial
Uses a
0.2
0.04
11
0.004
582

1,222
83,401
21

3
24
0.1
1

NE
Eguilibrium
Partitioning Limit
Protective of
Background Water
Quality b
0.004
0.01
0.2
0.002
0.3

0.2
119
21

0.3
0.2
0.01
1

NE
Model Level c
NE
NE
NE
NE
NE

NE
NE
NE

NE
NE
27
NE

NE
a Eguilibrium partitioning limit based on comparison of MCLs to soil-water concentrations.
b Eguilibrium partitioning limit based on comparison of detection limit to soil-water concentrations.
c Model level derived using vadose zone and groundwater modeling, and based on predicted achievement of MCL in groundwater at the
source area.
d Model levels derived using vadose zone and groundwater modeling, and based on predicted achievement of achievement of numerical beneficial use
limit in groundwater at the source area.
e Model level extrapolated from Area 1 Bldg. 10, which has similar concentrations and distribution of TCE.
f The value in parentheses represents the dieldrin cleanup level if the soil management cell is constructed at SWMU 3.

NE = not evaluated
NR = not reguired
NA = not applicable
-------
7.0 DESCRIPTION OF ALTERNATIVES

7.1 General Overview

7.1.1 Applicable or relevant and appropriate requirements (ARARs) and remedial action objectives
(RAOs) were developed for each site that requires remedial action at Defense Depot San Joaquin
(DDJC)-Tracy. In most cases, the RAOs were location-specific. Cleanup standards, if not already
dictated by requlatory requirements, were defined to meet the ARARs and RAOs for each site.
Several remedial alternatives were developed and evaluated for each site. ARARs, RAOs, cleanup
standards, and remedial alternatives are discussed in the followinq sections.

7.2 Applicable or Relevant and Appropriate Requirements

7.2.1 Background

7.2.1.1 ARARs are federal and state environmental and facility sitinq requirements that remedial
actions at Superfund sites must comply with. The Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthotization Act (SARA) of 1986 (collectively, CERCLA), and the National Oil and Hazardous
Substances Pollution Continqency Plan (NCP) require compliance with ARARs. Only those state
requirements that are more strinqent than federal ARARs and are legally enforceable and
consistently enforced statewide may be ARARs.

7.2.1.2 Pursuant to Section 121 (d) of CERCLA, the on-site portion of a remedial action selected
for a Superfund site must comply with all ARARs. In addition to ARARs, guidance documents and
other nonpromulqated criteria can be considered in evaluatinq remedial alternatives. These
nonpromulqated quidance or criteria are referred to as criteria or quidelines to be considered
(TBCs). For selected remedies, appropriate TBCs are identified as Performance Standards in
Section 10.0.

7.2.2 Definition of ARARs and Other Criteria or Guidelines to be Considered

7.2.2.1 An ARAR is an "applicable" or "relevant and appropriate" requirement. Accordinq to the
NCP (40 CFR Part 300), "applicable requirements," "relevant and appropriate requirements," and
"criteria or quidelines TBC" are defined as follows:

7.2.2.2 Applicable Requirements are those cleanup standards, standards of control, or other
substantive environmental protection requirements, criteria, or limitations promulqated under
federal or state environmental or facility sitinq laws that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance found at a
CERCLA site. Only those state standards that are identified in a timely manner and that are
more strinqent than federal requirements may be applicable.

7.2.2.3 Relevant and Appropriate Requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements, criteria, or limitations
promulqated under federal or state environmental or facility sitinq laws that, while not
"applicable" to a hazardous substance, pollutant, contaminant, remedial action, location, or
other circumstance at a CERCLA site, address problems or situations sufficiently similar to
those encountered at the CERCLA site that their use is well suited to the particular site. Only
those state standards that are identified in a timely manner and that are more strinqent than
federal requirements may be relevant and appropriate.

7.2.2.4 Advisories, Criteria, Guidance, or Proposed Standards TBCs consist of nonpromulqated
advisories, criteria, or quidance documents that were developed by the U.S. EPA, other federal
aqencies, or states that may be useful in developinq CERCLA remedies. The TBC criteria and
quidelines may be used as the aqencies deem appropriate.

7.2.3 Identification of ARARs

7.2.3.1 Neither CERCLA nor the NCP provides across-the-board standards for determininq whether a
particular remedy effects an adequate cleanup at a particular site. Rather, the process
recoqnizes that each site has unique characteristics that must be evaluated and considered
aqainst the requirements that apply under the qiven circumstances. Therefore, the identification
-------
of ARARs is done on a site-specific basis.

7.2.3.2 The ARARs are identified and considered at the following points in the remedial process:

• As part of the RI/FS scoping;

• During the site characterization phase of the RI;

• During the development of remedial alternatives;

• During the detailed analysis of the remedial alternatives;

• When an alternative is selected (see Section 10 of this document); and

• During the remedial design.

7.2.3.3 CERCLA actions may have to comply with three different types of ARARs: chemical
specific, location specific, and action specific. A detailed analysis of ARARs for the selected
remedies is provided in Section 10. The following discussion of ARARs identifies the ARARs used
in the development and evaluation of alternatives.

7.2.4 Chemical-Specific ARARs

7.2.4.1 Chemical-specific ARARs are health-or risk-based concentration limits or limits
specified by treatment methodologies for various environmental media (i.e., groundwater, surface
water, air, soil, and sediment) that are established for a specific chemical that may be present
in a specific medium at the site or that may be discharged to the site during remedial
activities. The following discussion summarizes the ARARs for each environmental medium of
concern at the sites.

7.2.4.2 Soil. California has promulgated standards for the disposal of waste soil under Division
4.5 of Title 22 of the California Code of Regulations (CCR) (22 CCR). Under Title 22, a waste is
hazardous if it contains any metals at concentrations exceeding the total threshold limit
concentrations (TTLCs). A waste is also hazardous if it contains extractable concentrations
exceeding soluble threshold limit concentrations (STLCs). The extractable concentrations are
determined by performing the Waste Extraction Test (WET) on samples of the waste soil. The WET
is used to determine whether a waste soil is hazardous. If the concentration (in milligrams per
liter) of any of the listed metals is greater than the STLC value the waste is hazardous. It is
also hazardous if the concentration eguals or exceeds the TTLC value. These chemical-specific
reguirements are ARARs for remedial activities involving the disposal of waste soil. Thus, these
ARARs are also action specific.

7.2.4.3 Sediment. No federal or California chemical-specific ARARs have been established for
sediment. MCs and STLCs promulgated under Title 22 are action-specific ARARs for the disposal of
sediment.

7.2.4.4 Surface Water. The federal Clean Water Act (CWA) reguires the establishment of
guidelines and standards to control the direct or indirect discharge of pollutants to waters of
the United States. Section 303 of the CWA reguires each state to develop water guality standards
based on federal water guality criteria to protect existing and attainable uses of the receiving
waters (U.S. EPA, 1988b). In California, water guality standards are a combination of the
designated beneficial uses of water and water guality objectives (numerical or narrative limits)
to protect those uses. In California, water guality standards are promulgated by the State and
Regional Water Boards in Water Quality Control Plans or "Basin Plans." DDJC-Tracy is included in
the Basin Plan for the Central Valley Region-Sacramento River and San Joaguin River Basins
(CVRWQCB, 1994).

7.2.4.5 According to California State Water Resources Control Board (SWRCB) Resolution No.
88-63, all surface waters in California are considered to be suitable, or potentially suitable,
for municipal or domestic water supply unless exempted. Surface water systems designed or
modified to collect or treat storm-water runoff are exempt; thus, municipal and domestic water
supplies are not considered beneficial uses for the storm drain lagoon at SWMU 4. The
percolation area at SWMU 2 is part of the wastewater treatment system and is also exempt. The
-------
lined ponds (SWMU 3) have been removed and incorporated into the percolation area.

7.2.4.6 Groundwater. Drinking water standards (California and Federal) Maximum Contaminant
Levels (MCLs) are chemical-specific ARARs for contaminants in groundwater at DDJC-Tracy. Cleanup
standards were developed consistent with the MCLs. According to SWRCB Resolution No. 88-63, all
groundwater in California is considered suitable, or potentially suitable, for municipal or
domestic water supply.

7.2.5 Location-Specific ARARs

7.2.5.1 Federal, state, and regional location-specific ARARs are restrictions placed on the
constituent concentration or the activities to be conducted at a site based on the location of
the site. Examples of special locations with potential ARARs include flood plains, fault zones,
wetlands, historic places, and sensitive ecosystems or habitats. DDJC-Tracy is not located
within any floodplains or wetlands; therefore, ARARs specific to these types of locations are
not discussed further.

7.2.5.2 National Historic Preservation Act. No buildings or locations at DDJC-Tracy have been or
are being considered for the National Registry of Historic Sites (WCC, 1992a). Hence, the
National Historic Preservation Act is not a location-specific ARAR for DDJC-Tracy.

7.2.5.3 Federal and California Endangered Species Act. These acts requires that all federal
agencies carry out programs for the conservation of listed endangered or threatened wildlife
species by ensuring that actions authorized, funded, or carried out by federal agencies are not
likely to jeopardize the endangered or threatened species. No known rare or endangered species
of wildlife have been documented within the depot. However, the depot is located within the
historic range of five sensitive species (see Section 6.6.1). Both statutes require consultation
with the Department of the Interior and the California Department of Fish and Game. The
Endangered Species Act is a location-specific ARAR for DDJC-Tracy.

7.2.5.4 Aquatic Habitats. The California Fish and Game Code (Division 6, Part 1, Chapter 6)
prohibits the deposition of any substance deleterious to fish, plant, or bird life. This code
applies to the storm drain lagoon (SWMU 4) located in the northern portion of DDJC-Tracy.
Therefore, this code is a location-specific ARAR for DDJC-Tracy.

7.2.6 Action-Specific ARARs

7.2.6.1 Action-specific ARARs are technology- or activity-based requirements or limitations for
actions conducted at a site during remediation. Tables 10-2 and 10-3 provide a complete listing
of action-specific ARARs. The following subsections summarize the key action-specific ARARs used
in the screening of alternatives.

7.2.6.2 Hazardous Waste Management. The Resource Conservation and Recovery Act (RCRA), as
codified in 40 CFR 262, 263, and 264, outlines the requirements for the transportation, storage,
and disposal of hazardous wastes. The State of California has its own hazardous waste
regulations, which are presented in Division 4.5 of Title 22 of the CCR, entitled "Environmental
Health Standards for the Management of Hazardous Wastes." Hazardous wastes generated in
California must comply with both the California and the federal hazardous waste programs,
although the California program is generally more stringent and expansive than the federal
program. Some of the wastes that may be handled during remedial activities conducted for
DDJC-Tracy may be considered hazardous wastes. The specific requirements that may be ARARs will
depend on the types of wastes handled and the specific remedial activities performed at
DDJC-Tracy.

7.2.6.3 Title 23, Division 3, Chapter 15 of the CCR and Title 27, Division 2, Subdivision 1 of
the CCR outlines ARARs that must be satisfied for investigating, monitoring, and selecting all
remedial alternatives for landfills and all other source contaminant sites involving a discharge
to land, Activities included in this program are the issuance of waste discharge requirements
(WDRs) by the Regional Water Quality Control Board (RWQCB) for the discharge of hazardous,
designated, and nonhazardous solid wastes to land and the oversight of corrective actions at
leaking waste management units. Articles 2 and 3 cover waste management unit classification,
management, and siting. Article 5 covers water quality monitoring and response programs and
Articles 8 and 9 cover closure and compliance procedures.
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7.2.6.4 Landfarming. RCRA and CCR Title 22 regulations regarding landfarming are applicable to
on-site bioremediation for DDJC-Tracy. These regulations reguire owners of landfarming
operations to ensure that no migration of hazardous constituents occurs. Title 27, Division 2,
Subdivision 1 of the CCR, which prescribes standards for discharges of wastes to land,
stipulates design reguirements for landfarming treatment pads. In addition, the San Joaguin
County Air Pollution Control District limits the organic content of soils treated with
landfarming to below 5,000 mg/kg.

7.2.6.5 Discharge to Surface Water. The CWA regulates the discharge of pollutants into surface
water. The National Pollutant Discharge Elimination System (NPDES) provides the permit
reguirements for a point-discharge into marine or surface waters. The NPDES reguirements
implemented by the State Water Resources Control Board Order No. 92-08 DWQ (specifically,
general permit 5B39SO 13143) are applicable to storm water discharges to the West Side
Irrigation District Canal which discharges to Sugar Cut at the Old River. The narrative toxicity
water guality objective for inland surface waters, as set forth in the Basin Plan for the
Central Valley Region (Cal-EPA CVRWQCB, 1994), apply as an ARAR for SWMU 4.

7.2.6.6 Discharge to Publicly Owned Treatment Works. The general pretreatment regulations for
existing and new sources of pollution (40 CFR 403) establish standards for the control of
pollutants passing through and interfering with treatment processes in publicly owned treatment
works (POTWs). These regulations are not applicable because remedial actions at DDJC-Tracy will
not involve the discharge of process water to a POTW.

7.2.6.7 The Clean Air Act. The Clean Air Act (CAA) regulates air emissions; certain titles of
the CAA and its amendments are ARARs for CERCLA response actions or technologies. Under Section
110 of the CAA (Title 1), each state has primary responsibility for ensuring air guality within
its geographic area. Through the state implementation plan (SIP), the state establishes a
program for regulating stationary and mobile sources that maintains and achieves the national
ambient air guality standards (NAAQS). SIPs include emission standards, monitoring, record
keeping enforcement, and other measures (e.g., economic incentives). The emission standards and
monitoring reguirements are substantive reguirements and are relevant and appropriate for
DDJC-Tracy for activities such as dust control, air stripping, and carbon adsorption treatment.
The record keeping, enforcement, and other measures are administrative reguirements and
therefore are not ARARs.

7.2.6.8 New Source Performance Standards. Under Section 111 of the CAA, new source performance
standards (NSPS) are defined, as are nationally uniform emission standards for major new
stationary sources, particularly for industrial source categories. At present, the NSPS source
categories coincide with only a few of the air pollutant emission sources typically found at
CERCLA sites. Thus, the NSPS are not usually considered "applicable" to CERCLA activities.
However, they may be "relevant and appropriate" to the CERCLA action if the pollutant emitted
and the technology employed during the cleanup action are sufficiently similar to the pollutant
and source category regulated by an NSPS. For CERCLA municipal landfill remediations (i.e.,
bioremediation), these reguirements would be ARARs after the rule's promulgation. Until these
reguirements are promulgated, they are TBCs.

7.2.6.9 National Emission Standards for Hazardous Air Pollutant. Section 112 of the CAA and
Section 301 (Title III) of the 1990 CAA amendments reguired the U.S. EPA to set uniform national
emission standards for hazardous air pollutants. These standards address new and existing
sources, and are oriented toward particular hazardous pollutants at their point of emission from
specific sources. The U.S. EPA has established a list of the major area source categories that
emit or may emit any of the 189 listed hazardous air pollutants. Treatment standards will be
ARARs and they could apply to emissions from tanks and containers, municipal landfills, or
surface impoundments.

7.2.6.10 Operating Permits. The 1990 CAA amendments (Title V, Sections 501 and 502) reguire
every major source (and certain other sources) regulated under the CAA to obtain an operating
permit. CERCLA on-site actions are not subject to the administrative procedures and permit
reguirements. However, these actions must comply with any substantive standards associated with
the permit programs that are determined to be ARARs. At DDJC-Tracy, the standards could apply to
some of the waste management units, or to the soil containment or removal technology, or the
leachate and groundwater control technology.
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7.2.6.11 RCRA Standards. Regulations under RCRA address air pollutant emissions from several
activities that may occur at CERCLA sites (e.g., incineration, or air stripping). These RCRA
regulations are ARARs.

7.2.6.12 California Air Regulations. California has generally adopted more stringent air
standards and regulations than the CAA. DDJC-Tracy is under the supervision of the San Joaguin
County Unified Air Pollution Control District. The District does not have any prohibitory rules
that would apply to remedial activities at DDJC-Tracy; however, the District reguires that a
minimum of 95 percent of the contaminants released to the air during any remedial action be
controlled the best available technology has been used. The CAA and any rules promulgated by the
local air guality management district may be ARARs for some of the activities and emissions at
DDJC-Tracy.

7.2.6.13 Groundwater Extraction, Treatment, and Discharge. California's SWRCB Resolution No.
68-16 (the state's Antidegradation Policy) reguires that high-guality waters be maintained to
the maximum extent possible. This resolution applies most often at CERCLA cleanups that involve
extracting, treating, and discharging treated groundwater. Any activities that result in
discharges (including injection) to high-guality water are reguired to use the best practicable
treatment or method of control of the discharge necessary to avoid a pollution or nuisance and
to maintain water guality. Best practicable treatment takes into account technical and economic
feasibility. Also, hydraulic control of the contaminant plume will be maintained during
extraction and injection.

7.2.6.14 The Basin Plan for the Central Valley Region, Sacramento River and San Joaguin River
Basins, has designated groundwater at DDJC-Tracy with the following beneficial uses: municipal
and domestic supply, agricultural supply, industrial service supply, and industrial process
supply. These beneficial uses apply to all groundwater.

7.2.6.15 California SWRCB Resolution 92-49 establishes policies and procedures for the oversight
of investigations and cleanup and abatement activities resulting from discharges (including
injection) that affect or threaten water guality. SWRCB Resolution 92-49 reguires actions for
cleanup and abatement to conform to SWRCB Resolution 68-16 and state and regional water board
basin plans and policies. Cleanup levels are not reguired to be more stringent than background
levels. Cleanup levels and effluent discharge limitations need not be identical for the same
site.

7.2.6.16 Part C of the Federal Safe Drinking Water Act (SDWA) set up Underground Injection
Control (UIC) program reguirements that are specified in 40 CFR Part 144. These regulations
define a classification system, discharge prohibitions, and a permitting system for wells that
inject fluids into groundwater. Any water that is injected into the groundwater at DDJC-Tracy
must meet these UIC program reguirements and potentially reguire UIC permitting.

7.2.7 Identification of Other Guidance and Criteria to be Considered

7.2.7.1 Other TBCs in evaluating remedial alternatives are federal, state, or local advisories
or guidance documents that have not been promulgated. Since TBCs are not promulgated, they are
not legally binding. If there are no specific federal, state, or regional ARARs for a particular
chemical or remedial action, or if existing ARARs are not considered sufficiently protective,
then guidance or advisory criteria should be identified and used to ensure public health and
environmental protection. TBCs may provide health effect information with a high degree of
credibility, technical information on performing or evaluating site investigations or remedial
actions, and useful policies for dealing with hazardous substances.

7.2.7.2 Soil. In general, there are no promulgated cleanup levels available for soil. No
numerical chemical-specific ARARs were identified for contamination in soil; to protect human
health and the environment, chemical-specific TBCs were developed from Water Quality Goals
(CVRWQCB, 1994) (see Section 6.7). There are also some guidelines for the allowable levels of
total petroleum hydrocarbons (TPH) in soil that are based on recommendations from the
Tri-Regional Board (California RWQCB, 1996). These guidelines do not constitute final cleanup
goals, but rather target levels that should prevent existing TPH soil contamination from
becoming a source of constituents to underlying groundwater.

7.2.7.3 Aguatic Habitat and Sediment. According to the Basin Plan, freshwater habitat is
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potentially a beneficial use for surface water at SWMU 4. Thus, federal ambient water quality
criteria (AWQC) are chemical-specific TBCs for surface water at SWMU 4. Of the constituents
detected in surface water at SWMU 4 (primarily pesticides), only DDT and dieldrin have AWQC for
the protection of aquatic life (U.S. EPA, 1988b). The freshwater chronic AWQC for DDT is 1.0x10
-3 Iq/L. The freshwater chronic AWQC for dieldrin is 1.9x10 -3 Iq/L. There are no established
California or federal sediment quality criteria (SQC) for the protection of aquatic life,
however interim SQC have been proposed by the U.S. EPA for 17 nonpolar hydrophobic orqanic
contaminants, includinq six polycyclic aromatic hydrocarbons (PAHs), seven pesticides, aniline,
and polychlorinated biphenyls (PCB s) (Aroclor 1254). The current approach to developinq
sediment criteria involves partitioninq the constituent to the water phase and evaluatinq
bioavailability. Because there is still discussion reqardinq the choice of partition
coefficients and the methods for determininq uncertainty in the interim SQC values, the final
values will differ from these interim values, thouqh not substantially (U.S. EPA, 1989b). A
number of other predictive models and methods are beinq investiqated for constituents, but no
one approach has been accepted to develop sediment-based criteria (Shea, 1988; Chapman, 1989;
NOAA, 1990; Di Toro et al., 1991; Burton, 1991; U.S. EPA, 1989b).

7.2.7.4 National Oceanic and Atmospheric Administration (NOAA) effects-based sediment quality
values are available for evaluatinq the potential for constituents in sediment to cause adverse
bioloqical effects. These values are not standards or criteria. NOAA effects ranqe low (ER-L)
values are concentrations equivalent to the lower 10 percentile of available data screened by
NOAA. These values indicate the low end of the ranqe of concentrations in specific sediments at
which adverse bioloqical effects were observed or predicted in sensitive species and/or
sensitive life staqes.

7.2.7.5 The effects ranqe-median (ER-M) values are concentrations based on the median values of
the NOAA-screened data at which adverse bioloqical effects were observed or predicted. The ER-L
and ER-M values are used by U.S. EPA as sediment screeninq values to indicate the potential for
adverse ecoloqical effects. The ER-L and ER-M values do not allow observed toxicity
concentrations to be readily extrapolated from one sediment location to another. Sediment
characteristics qreatly influence the contaminant toxicity; thus, the ER (L and ER-M values
cannot be used as direct indicators of adverse effects to aquatic orqanisms. U.S. EPA qenerally
recommends further ecoloqical testinq and evaluation (when these values are exceeded) to
determine the site-specific risks. The ER-L and ER-M values for constituents detected in
sediment at SWMU 4 are considered chemical-specific TBCs for sediment at SWMU 4.

7.2.7.6 Groundwater. The non-promulqated water quality criteria were identified as TBCs for
dieldrin in qroundwater. Water quality criteria were also developed for monuron and diuron.

7.3 Operable Unit 1 Groundwater

7.3.1 Background

7.3.1.1 Operable Unit (OU) 1 is defined as the contaminated qroundwater plume, on and off depot.
The plume is characterized by PCE and TCE. The OU 1 ROD (WCC, 1993) established aquifer cleanup
standards for TCE, PCE, and 1,1 -DCE. As described in the OU 1 ROD, the selected remedy for VOCs
in OU 1 qroundwater is qroundwater extraction and treatment.

7.3.1.2 The OU 1 ROD documents the development and evaluation of four alternatives to address
VOCs in qroundwater at DDJC-Tracy. Alternative 1 considered no action to address TCE, PCE, and
1,1 -DCE. Alternative 2, institutional controls, included restrictions on drinkinq water wells
and future residential development, an Interaqency Manaqement Aqreement to manaqe future
qroundwater use at the depot, continued qroundwater monitorinq, and the supplyinq of drinkinq
water to affected families. Alternative 3 included a system of approximately 40 extraction
wells, the treatment of 1,000 qallons of qroundwater per minute by air strippinq, vapor-phase
carbon adsorption, the injection of treated water, and continued monitorinq. Alternative 4
consisted of approximately 40 extraction wells, the treatment of 1,000 qallons of qroundwater
per minute by air strippinq, vapor-phase carbon adsorption, in situ bioloqical treatment, the
injection of treated water, and continued monitorinq.

7.3.1.3 Alternative 3 was the selected alternative. Alternatives 1 and 2 were not preferred
because they did not remediate the contaminated aquifer, did not protect human health and the
environment, did not meet the ARARs, and would not be accepted by the community or the state.
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Alternative 4 was not preferred because it is untried at full scale and would therefore require
significant advance testing and experimentation. As a result it would be significantly more
costly than Alternative 3. Acceptance of Alternative 4 by the agencies and the public was
expected, but not certain.

7.3.1.4 The selected remedy for TCE, PCE, and 1,1 -DCE is presently under construction. The
conceptual design (i.e., flow rate and number of wells) of the alternative presented in the ROD
has been refined in the design process (see Section 9.5). In addition to the alternatives
described above, reductive dechlorination was considered as a possible remedy during the design
phase. However, given the size of the contaminant plume, the cost of installing a subsurface
reductive dechlorination system was prohibitive. Alternative 3 remains the preferred alternative
to address VOCs in groundwater at DDJC-Tracy, and the selection of Alternative 3 is reaffirmed
in this ROD.

7.3.1.5 An Explanation of Significant Differences (BSD) (Montgomery Watson, 1996g) was approved
that allows a small portion of the plume to be remediated by natural attenuation.

7.3.1.6 Studies to assess the technical and economic feasibility of achieving "background"
(i.e., detection limits) for TCE, PCE, and 1,1-DCE were performed and are reported in the 3-D
Groundwater Model Technical Evaluation (Montgomery Watson, 1995). It was estimated that
remediation to detection limits would require approximately 50 percent more time than the time
needed to attain MCLs. This would significantly increase the cost per unit removal of
contaminants from the aquifer. Furthermore, strict adherence to a detection-limit remediation
goal would require installation of more extensive extraction and infiltration facilities both on
and off depot. Additional property acquisition and easements would be necessary. Remediation to
MCLs enables the extraction and infiltration systems to be limited to government property and
avoids the high incremental cost of treatment to detection limits. Therefore, this ROD reaffirms
the selected remedy of extraction and treatment to MCLs with the natural attenuation of a small
portion of the plume.

7.3.1.7 Other VOCs (see Table 7-1) detected in samples from various monitoring wells at
DDJC-Tracy during the groundwater monitoring program include bromoform, carbon disulfide,
chloroform, 1,1-DCE, cis- 1,2-DCE, trans- 1,2-DCE, methylene chloride, benzene, toluene, and
xylenes. However, the concentrations of these VOCs were an order of magnitude less than the
concentrations of TCE and PCE and were detected intermittently in only a few wells. The nature
and extent of chloroform is discussed in Sections 5.2.2 and 5.2.7.

7.3.1.8 The Lower Tulare Aquifer was sampled when wells AG-1 and AG-3 were abandoned. No VOCs
were reported. No sample could be collected from AG-2 because the well had collapsed above the
Lower Tulare contaminants may have migrated through the Corcoran Clay prior to the well collapse
at 375 feet bgs. However, the date of the collapse is unknown and may have occurred before the
OU 1 plume migrated to this area. Concentrations of TCE and PCE within the Lower Horizon and
below the Lower Horizon are relatively low. Attenuation and dilution effects are also expected
to additionally reduce concentrations of TCE and PCE, if present, as groundwater transport
processes continued across the Corcoran Clay and Lower Tulare Aquifer. Because over 200 feet of
find-grained silty and clayey sediments (including the Corcoran Clay) are present below the
permeable zone at 180 feet bgs, significant vertical migration TCE and PCE to the Lower Tulare
Aquifer in locations other than connecting production wells is considered unlikely.

7.3.1.9 Based on the contamination observed below the Lower Horizon in well LM57D and the
concentrations of TCE and PCE detected in the deep CPT samples collected in the vicinity of
AG-2, OU 1 contaminants have migrated vertically to the water-bearing zone at 180 feet bgs.
Because this zone is adjacent to the bottom of the perforated intervals observed in well AG-2,
it is not known whether contaminants have migrated any deeper. However, the absence of TCE or
PCE in the sample collected from AG-1, which is located directly downgradient of AG-2 in the
Lower Tulare Aquifer, provides a reasonable level of certainty that the Lower Tulare Aquifer has
not been contaminated.

7.3.1.10 Additional investigation of the Lower Tulare Aquifer would require drilling into and
possibly through the Corcoran Clay, which may open new conduits from contaminated zones in the
Upper Tulare Aquifer to uncontaminated zones. Additional groundwater sampling in the Corcoran
Clay and Lower Aquifer is therefore not recommended. Based on all available data, the risk of
contributing to deep aquifer contamination as a result of drilling and installing well materials
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through the Corcoran Clay and overlying contaminated aguifer is not warranted to obtain
additional data to support this assessment.

7.3.1.11 Several pesticides and herbicides (primarily dieldrin, chlordane, DDD, DDE, DDT,
monuron, and diuron) have also been detected in groundwater at DDJC-Tracy (see Table 7-1).
Pesticides have been predominantly detected in wells in the northwestern portion of the depot.
On the basis of analytical modeling results (Montgomery Watson, 1996a), the primary source areas
for pesticides and herbicides are SWMUs 2 and 3. In particular, the dieldrin plume appears to
emanate from the lagoons and extends into the Tracy Annex. Monuron and diuron occur in a similar
distribution. There is insufficient groundwater data to confirm the shape of the monuron and
diuron plume; however, the occurrence of monuron and diuron in groundwater at DDJC-Tracy has
been interpreted as the result of the source areas at SWMUs 2 and 3. The occurrence of all other
pesticides and herbicides in groundwater is intermittent. In addition, the concentrations of
other pesticides are generally below numerical beneficial use limits.

7.3.1.12 Dieldrin has historically been detected at low concentrations in groundwater from 26
monitoring wells (Montgomery Watson, 1996a). Monuron and diuron have been detected in 24 and 14
wells, respectively. The majority of consistent monuron, diuron, and dieldrin detections are in
the Above Upper or Upper Horizon wells downgradient from SWMU 2. Isolated detections of dieldrin
have also occurred in the Above Upper Horizon Wells downgradient from the Storm Drain Lagoon
(SWMU 4), Burn Pit No. 2 (SWMU 8), and the IWPL (SWMU 33). The background threshold values for
dieldrin, monuron, and diuron are 0.005 Ig/L, 0.163 Ig/L, and 0.144 Ig/L, respectively. These
background levels were based upon detection limits derived from use of a modified method as part
of an initial background study These detection limits were not reproducible. The numerical
beneficial use limit (Cal/EPA and USEPA Cancer Potency Factor) for dieldrin is 0.002 Ig/L. No
federal or California MCLs have been established for dieldrin, monuron, or diuron. The
California Action Level for dieldrin is 0.05 Ig/L (RWQCB, 1995). The numerical beneficial use
limit (SNARL) for monuron and diuron is 10 Ig/L.

7.3.1.13 Total concentrations of arsenic (see Table 7-1) have consistently been detected at
values slightly greater than background in two Above Upper and Upper horizon wells with
elevated turbidity. Arsenic has also been detected intermittently in nine other Above Upper and
Upper Horizon wells in the northwest corner of the depot and downgradient from SWMUs 2 and 3.
The maximum detected value of total arsenic is 7.4 Ig/L compared to the MCL of 50 Ig/L and the
background threshold value of 3 Ig/L. Manganese has been consistently detected above the
background threshold value in LM27AA. The maximum concentration of manganese was 1,640 Ig/L,
compared to a background threshold value of 338 Ig/L. The source of manganese in this location
is the former manganese ore stockpiles that were previously located along the northern fenceline
at DDJC-Tracy. Contaminant transport occurred as rainwater leached through the stockpiles and
became acidic because of sulfides in the ore. The ore may also have been a source for arsenic.
The source for manganese in groundwater is no longer present. Manganese and barium have also
been detected downgradient from SWMUs 2, 3, 4, and 33. The detected concentrations of barium are
only slightly greater than background and have never exceeded the MCL. No dissolved
concentrations of any other metal were detected consistently above background in samples
collected from wells at DDJC-Tracy.

7.3.1.14 Based on a review of historical groundwater monitoring data, dieldrin contamination in
groundwater warrants remediation. The analysis of all groundwater COPCs is summarized in Table
7-1. The general response actions developed for dieldrin are discussed below.

7.3.2 Remedial Action Objectives

As explained in Section 7.3.1, the selected remedy for VOC contamination in groundwater was
reevaluated and determined to be the most viable remedy. As a result, RAOs are presented for
dieldrin, the only remaining chemical of concern (COG) in groundwater. The RAOs for the dieldrin
in groundwater in OU 1 are:

• Remediate hot spots (i.e., areas with the highest levels of dieldrin contamination
in groundwater);

• Minimize contaminant transport off-depot; and
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• Minimize dieldrin migration and remediate to the aquifer cleanup level of 0.05
micrograms per liter (Ig/L) based on a California Action Level.

7.3.3 Remedial Alternatives

Remedial alternatives for VOCs are discussed in Section 7.3.1. Four modifications of the
selected remedial alternative for VOCs were evaluated to address dieldrin in OU 1 groundwater.
Currently, three areas of groundwater are contaminated with dieldrin levels above the
California Action Level of 0.05 Ig/L. One area is located near SWMUs 2 and 3, one is near SWMU
8, and one is within the Tracy Annex. These areas all lie within the OU 1 VOC plume. The
full-scale OU 1 groundwater remediation system includes two extraction wells with liquid-phase
carbon to treat dieldrin at the wellhead. Table 7-2 describes the four alternatives that would
modify the OU 1 groundwater remedy:

• No Further Action;

• Institutional Controls (land use restrictions and groundwater monitoring);

• Groundwater Extractions and Treatment- Option 1 (wellhead pretreatment with GAG at
nine extraction wells and air stripping to remove VOCs); and

• Groundwater Extraction and Treatment - Option 2 (wellhead pretreatment with
granular activated carbon (GAQ at three extraction wells and air stripping to remove
VOCS).

7.4 Group A Sites

7.4.1 Remedial Action Objectives

Prevent the migration of the following VOCs in soil that could cause groundwater contamination:

SWMU I/Area 2 - PCE and TCE;

Area 1 Building 237 - PCE; and

Area 3 - PCE and TCE.

To reach this RAO, site-specific soil cleanup levels were developed that are protective of the
background groundwater quality.

7.4.2 Remedial Alternatives

Four remedial alternatives were evaluated at the Group A sites (SWMU I/Area 2, Area 1 Building
237, and Area 3). These sites are characterized mainly by soil contaminated with VOCs and are
considered potential sources to OU 1 groundwater contamination. PCE and TCE are present at SWMU
I/Area 2 and Area 3. PCE is present at Area 1 Building 237. Table 7-3 describes the four
remedial actions considered for these sites:

• No Further Action;

• Groundwater Extraction and Treatment - Option 1 (wellhead pretreatment with GAG

• Institutional Controls;

• Soil Vapor Extraction (SVE); and

• Excavation and Disposal.

7.5 Group B Sites

There are nine Group B sites (SWMUs 4, 6, 7, 8, 20/23, 24, 27, the Building 30 Drum Storage Area
and the surface and near-surface soils in the North Depot Area). Specific RAOs and alternatives
were developed for each site and are discussed separately. To reach these RAOs, site-specific
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soil cleanup standards were developed for each chemical of concern. The cleanup standards will
leave a residual cancer risk that is no greater than 1x10 -6, a residual hazard index that is no
greater than 1.0, and will be protective of the background groundwater quality.

7.5.1 ST/JMU 4 - Storm Drain Lagoon

7.5.1.1 Remedial Action Objectives. The RAOs for SWMU 4 are:

• Prevent release of COCs (DDT and dieldrin) from sediments that would cause surface
water concentrations that exceed federal AWQC for protection of aquatic life;

• Prevent ecological receptors from being exposed to COCs (DDT, lead, and PCBs) in
surface water above aquatic standards; and

• Prevent ecological receptors from being exposed to COCs in sediment.

7.5.1.2 Remedial Alternatives. Three remedial alternatives were evaluated for SWMU 4, a storm
drain lagoon that collects all storm water runoff from DDJC-Tracy. Table 7-4 describes the three
remedial actions considered for this site:

• Prevent the migration of pesticides (dicamba, dieldrin, endrin, heptachlor, lindane,
and 2,4,5-T) in the soil that could cause groundwater contamination.

7.5.2.2 Remedial Alternatives. Four remedial alternatives were evaluated for SWMU 6, which is
located on the west side of Building 28 in the eastern portion of DDJC-Tracy. Table 7-5
describes the four remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);

• In Situ Stabilization (immobilize contaminated materials); and

• Excavation and Disposal (excavate contaminated soil and transport it to a Class I or
II disposal facility) .

7.5.3 SWMU 7 - Burn Pit No. 1

7.5.3.1 Remedial Action Objectives. The RAO for SWMU 7 is:

Prevent the migration of the following COCs in the soil that could cause groundwater
contamination:

• Pesticides and herbicides (2,4-D, linuron, dieldrin, and simazine);

SVOCs (bis(2-ethylhexyl]phthalate);

VOCs (1,2-dichloroethene [1,2-DCE] and TCE); and

• Petroleum hydrocarbons (diesel).

7.5.3.2 Remedial Alternatives. Four remedial alternatives were evaluated for SWMU 7, which
consists of seven pits that operated before warehouse buildings 15, 19, and 21 were constructed.
These pits were used for disposing of medical supplies containing mercury and phosphate
compounds, narcotics, radiological supplies, etc. In addition, other materials (both solid and
liquid) that were stored or used at DDJC-Tracy may have been burned and/or buried at SWMU 7. The
ashes were removed and transported to off-site landfills during the later years of operation.
Table 7-6 describes the four remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);
-------
• In Situ Stabilization with Institutional Controls (immobilize the contaminated
materials); and

• Excavation and Disposal with Institutional Controls (excavate the contaminated soils
and transport to a Class I disposal facility).

7.5.4 SWMU 8 - Burn Pit No. 2

7.5.4.1 Remedial Action Objectives. The RAOs for SWMU 8 are:

• Prevent future construction workers from being exposed to the following COCs in the
soil that would cause an excess cancer risk greater than 10 -6 or a hazard index
greater than 1.0:

- Pesticides (total DDK and dieldrin);

• Prevent the migration of the following COCs in the soil that could cause groundwater
contamination;

- SVOCs (diethylphthalate, bis[2-ethylhexyllphthalate, 2,4-dinitrotoluene,
and naphthalene);

- Pesticides and herbicides (chlordane, 2,4-D, DDT, ODD, dieldrin, lindane,
linuron, MCPA, and simazine); and

- Petroleum hydrocarbons (diesel, motor oil, and gasoline).

7.5.4.2 Remedial Alternatives. Four remedial alternatives were evaluated for SWMU 8, a single
large burn pit approximately 16 feet deep, 250 feet long, and 30 feet wide. Petroleum
hydrocarbons were detected in deep soils extending to the water table (21 feet below ground
surface at maximum concentrations of 2,600 mg/kg (TPH as diesel), 70 mg/kg (TPH as gasoline),
and 5,600 mg/kg (TPH as motor oil). Table 7-7 describes the four remedial actions considered for
this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);

• Bioventing (enhance biodegradation in the subsurface by installing a blower and
three air-injection well clusters); and

• Excavation and Disposal (excavate the contaminated soil and transport it to a Class
I or other disposal facility in compliance with state and federal laws and
regulations).

7.5.5 SWMU 20 - Aboveground Solvent Tank Building 26 Recoup Operations and Area 1 Building 10

7.5.5.1 Remedial Action Objectives. The RAO for SWMU 20:

• Prevent the migration of the following COCs in the soil that could cause
groundwater contamination that exceeds appropriate regulatory standards and health-
based concentrations:

VOCs (TCE, ethylbenzene, and xylenes);

SVOCs (diethylphthalate, 2,4-dinitrophenol, pentachlorophenol [PCP], and
2,4,6-trichlorophenol);

Pesticides and herbicides (dieldrin, methiocarb, MCPA, and linuron); and

Petroleum hydrocarbons (diesel).
-------
7.5.5.2 Remedial Alternatives. Four remedial alternatives were evaluated for SWMU 20, an
aboveground solvent tank located in Area 1 Building 10. Table 7-8 describes the four remedial
actions considered for this site:

• No Action;

• Institutional Controls;

• SVE, Excavation and Disposal, and Natural Attenuation (excavate the contaminated
soil from SWMU 20 and SWMU 26 and transport it to a Class I disposal facility;
install an SVE system near soil boring [SB] 108 [Area 1 Building 6] and SB431
[SWMU 23]); and

• Excavation and Disposal (excavate the contaminated soil and transport it to a
Class I disposal facility).

7.5.6 SWMU 24 - Petroleum Waste Oil Tank

7.5.6.1 Remedial Action Objectives. The RAOs for SWMU 24 are:

• Prevent future depot workers from being exposed to toluene in the soil that would
cause a hazard index greater than 1.0.

• Prevent the migration of the following COCs in the soil that could cause
groundwater contamination that exceeds appropriate regulatory standards and health-
based concentrations.

- VOCs (acetone, 2-butanone [MEK], ethylbenzene, 2-hexanone, 4-methyl-2-pentanone,
toluene, and xylenes);

- SVOCs (2,4-dimethylphenol, fluoranthene, 2-methylnaphthalene, 4-methylphenol,
naphthalene, phenenthrene, phenol, and pyrene); PCBs (Aroclor 1260)

- Pesticides (carbofuran, lindane, phorate, and ronnel); and

- Petroleum hydrocarbons (diesel and gasoline).

7.5.6.2 Remedial Alternatives. Five remedial alternatives were evaluated for SWMU 24, a
500-gallon underground storage tank (UST) that was used to store petroleum wastes between 1961
and 1988. The average biodegradable hydrocarbon concentration detected at SWMU 24 is 3,000
mg/kg. Table 7-9 describes the five remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);

• Boiventing (install air-injection well blower);

• Excavation and Disposal (excavate the contaminated soil and transport it to a
Class I disposal facility); and

• Excavation and Onsite Bioremediation (excavate the soil exceeding the cleanup
standards and treat above ground with on-site bioremediation method such as
landfarming or a slurry-phase reactor).

7.5.7 SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206
-------
7.5.7.1 Remedial Action Objective. The RAOs for SWMU 27 are:

• Prevent future depot workers from being exposed to the following COCs in the soil
that would cause an excess cancer risk greater than 1x10 -6:

- PAHs (benzo[a]pyrene,
benzo[a]anthracene,
benzo[b]fluoranthene,
benzo[k]fluoranthene, and indeno[1,2,3-
cd]pyrene); and

- PCBs (Aroclor 1260).

• Prevent the migration of the following COCs in the soil that could cause
groundwater contamination that exceeds appropriate regulatory standards and health-
based concentrations:

- VOCs (TCE);

- Herbicides (2,4-D, MCPA, and 2,4,5-T); and

- Petroleum hydrocarbons (motor oil).

7.5.7.2 Remedial Alternatives. Three remedial alternatives were evaluated for SWMU 27, which
consists of the waste oil sump, the service pit, the locomotive pit, and the area around the
floor drain in Building 206. Table 7-10 describes the three remedial actions considered for this
site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring) ;
and

• Excavation and Disposal (excavate the contaminated soil and transport it to a Class
I disposal facility).

7.5.8 Building 30 Drum Storage Area

7.5.8.1. Remedial Action Objectives. The RAO for the Building drum 30 Storage Area is:

• Prevent the migration of benzyl alcohol, bis(2-ethylhexyl)phthalate,
diethylphthalate, and di-n-butylphthalate in the soil that could cause groundwater
contamination that exceeds appropriate regulatory standards and health-based
concentrations.

7.5.8.2. Remedial Alternatives. Three remedial alternatives were evaluated for the Building 30
Drum Storage Area which is located in the southern portion of the depot, on the south side of D
Street. Table 7-11 describes the three remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);
and

• Excavation and Disposal (excavate contaminated soil and transport to Class I or
II disposal facility).

7.5.9 Surface and Near-Surface Soils - Northern Depot Area
-------
7.5.9.1 Remedial Action Objectives. The RAO for the Northern Depot Area is:

• Prevent future depot workers from being exposed to arsenic and manganese in the
surface and near-surface soils that would cause a hazard index greater than 1.0.

7.5.9.2 Remedial Alternatives. Four remedial alternatives were evaluated for the remediation of
metals in shallow soils. The data from the surface and near-surface soils indicate that arsenic
and manganese in the soil pose a threat to human health in the northern area of the depot. Table
7-12 describes the four remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);

• Asphalt Cover (install an asphalt cover over the soil with elevated levels of
arsenic and manganese) ; and

• Excavation and Disposal (excavate the contaminated soil and transport it to a Class
II or III disposal facility).

7.6 Group C Sites

There are two Group C sites: SWMUs 2 and 3, and SWMU 33. Specific RAOs and alternatives were
developed for each site and are discussed separately. To develop these RAOs, site-specific soil
cleanup standards were developed for each constituent of concern.

7.6.1 SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons

7.6.1.1 Remedial Action Objectives. The RAO for SWMUs 2 and 3 is:

Prevent the migration of dieldrin, DDT, ODD, DDE, di-n-butylphthalate, and bis (2-
ethylhexyl)phthalate in post-removal-action soil that could cause groundwater
contamination that exceeds appropriate regulatory standards and health-based
concentrations.

7.6.1.2 Remedial Alternatives. Three remedial alternatives were evaluated for SWMUs 2 and 3,
which are located in the north part of the depot west of and adjacent to the sewage treatment
plant. Table 7-13 describes the three additional remedial actions considered for this site:

• No Action;

• Institutional Controls (implement land use restrictions and groundwater monitoring);
and

• Excavation and Disposal (a geofabric filter and backfill will be used to isolate
ecological receptors from contaminants left in place).

7.6.2 SWMU 33 - Industrial Waste Pipeline

7.6.2.1 Remedial Action Objective. The RAO for SWMU 33 is:

• Prevent the migration of aldrin, dieldrin, diethylphthalate, and di-n-butylphthalate
in the postremoval-action soil that could cause groundwater contamination that
exceeds appropriate regulatory standards and health-based concentrations.

7.6.2.2 Remedial Alternatives. Three remedial alternatives were evaluated for SWMU 33, a 4-inch-
to 7-inch-diameter industrial waste pipeline buried 2 feet below grade. These remedial
alternatives were developed assuming that the removal actions recommended in the January 1996
EE/CA would be completed. Table 7-14 describes the three additional remedial actions considered
for this site:

• No Action;
-------
• Institutional Controls (implement land use restrictions and groundwater monitoring);

• Limited Excavation and Disposal (excavate the contaminated soil and transport it to
a Class I disposal facility), grouting, and institutional controls (groundwater
monitoring); and

• Excavation and Disposal (excavate contaminated soil and transport it to a Class I
disposal facility).

7.7 No Further Action Sites

7.7.1 Twenty-one sites have been identified as "No Further Action (NFA)" sites based on site
specific data developed in the RI/FS. These sites are categorized as NFA sites because they meet
the following criteria:

• No COCs pose actual or potential threats to groundwater beneficial uses or exceed
background concentrations;

• No COCs pose an excess cancer risk greater than 1x10 -6 to depot workers,
construction workers, or children on the installation;

• No COCs have a non-cancer hazard index greater than 1.0 for depot workers,
construction workers, or children on the installation; and

• There is no ecological risk.

7.7.2 One NFA site, SWMU 10A, does not fully meet the above criteria. Soil contamination at SWMU
10A does pose a potential threat to background groundwater guality. Remediation was not
recommended because of the cost, the limited number of detections, and guestions regarding the
reliability of the data (Montgomery Watson, 1996a). Therefore, the site has been designated as
an NFA site.

7.7.3 ARARs would not be violated by not taking action on these NFA sites. No chemical
specific ARARs or TBCs for soil would be exceeded. All concentration of contaminants in soil are
below such ARARs as the Designated Level Methodology (DLM) values for sediments, surface soils,
and subsurface soils specified by the RWQCB, State and federal hazardous waste criteria (22 CCR
66261 and 40 CFR 261), and the USEPA Toxic Substance Control Act (TSCA) .

7.7.4 Similarly, no groundwater ARARs or TBCs would be violated by not taking action at these
sites. No National or State MCLs (40 CFR 141) would be exceeded and beneficial uses of
groundwater specified in the RWQCB Basin Plan would not be affected. No reguirements of the
Porter-Cologne Water Quality Act or SWRCB Resolution 68-16 would be violated by not taking
action at these sites.

7.7.5 These sites are identified in Table 7-15, along with the rationale for their NFA
designation.
-------
Table 7-1. Groundwater Chemicals of Concern: Detection Frequency, Remedial Decision Rationale, and Risk Characterization, DDJC-Tracy
Chemical of
Concern

Volatile Organic
Compounds
Maximum
Detected
Concentration a
(Ig/L)

560
Background
Threshold
Values b
(Ig/L)

NC
Beneficial Use
Numerical
Limits c
(Ig/L)
Freguency
Detected
Versus
Freguency
Analyzed a

770/1465
Remedial
Decision

Aguifer cleanup level
established
Remedial Decision
Rationale

Prevalent depot-related chemical
of concern
Excess
Cancer Risk
(x-4)

0.37
Hazard
Quotient d

NC
Trichloroethene
(TCE)
Effluent treatment
standard established
Contributes significantly to
human health risk
Tetrachloroethene
(PCE)
457
NC
0.7
661/1465 Aguifer cleanup level
established
Risk based on maximum
concentration in 1994 (130 Ig/L)

Prevalent depot-related chemical
of concern
0.50
NC
Effluent treatment
standard established
Contributes significantly to
human health risk
1,1-Dichloroethene
(DCE)
37
NC
55/1465 Aguifer cleanup level
established
Risk based on maximum
concentration in 1994 (120 Ig/L)

Depot-related chemical of
concern
3.71
NC
Effluent treatment
standard established
Contributes significantly to
human health risk
Carbon
Tetrachloride
NC
1/1465
NFA; effluent
treatment standard
established
Detected levels may not be
depot-related
0.10
0.62
Chloroform
NC
1.0
78/1465 NFA; effluent
treatment standard
established
Constituent detected infreguently

Depot-related chloroform
concentrations are an order of
magnitude below the MCL
0.14
NC
-------
Table 7-1. (Continued)
Chemical of
Concern
Maximum
Detected
Concentration a
(Ig/L)
Background
Threshold
Values b
(Ig/L)
Benzene 10
cis-1,2- 39
Dichloroetheric
NC
NC
Beneficial Use
Numerical
Limits c
(Ig/L)
Frequency
Detected
Versus
Frequency
Analyzed a

9/1276
10/905
Remedial
Decision

NFA
NFA
Remedial Decision
Rationale

Constituent detected
infrequently (less than 1%
frequency)

Constituent detected
infrequently (1% frequency of
detections)
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
Constituent detected below
beneficial use limit (MCL)
trans-1,2- 10
Dichloroethene
Toluene 19
NC
NC
10
42
6/1341
56/1276
NFA
NFA
Constituent detected
infrequently (less than 1%
frequency)

Constituent detected
infrequently (less than 5%
frequency)
NA
0.002 8
Constituent detected well
below beneficial use limit
(MCL)
1,1,1-
Trichloroethane
16
NC
200
21/1465
NFA
Constituent detected
infrequently (less than 2%
frequency)
Constituent detected well
below beneficial use limit
(MCL)
-------
Table 7-1. (Continued)
Chemical of
Concern

Xylenes (m,p + o)
Maximum
Detected
Concentration a
(Ig/L)

10
Pesticides and Herbicides

2,4-D 2.78
Background
Threshold
Values b
(Ig/L)

NC
0.101 f
Beneficial Use
Numerical
Limits c
(Ig/L)

17
Frequency
Detected
Versus
Frequency
Analyzed a

11/909
Remedial
Decision

NFA
70
18/284
NFA
Remedial Decision
Rationale

Constituent detected
infrequently (less than 2%
frequency)

Constituent detected well
below beneficial use limit
(MCL)
Constituent detected
infrequently (less than 30%
frequency)

Constituent detected well
below beneficial use limit
(MCL) and only slightly above
background threshold value.
Excess
Cancer Risk
(x-4)

NA
Hazard
Quotient d

0.00007 8
2,4-DB
0.209
Aldrin
0.02
0.101 f
0.005 f
290
2/294
NFA
0.002
4/574
NFA
Source areas will be removed
(SWMU 2)

Constituent detected
infrequently (only once in 2
wells)

Constituent detected well
below beneficial use limit
(PRG) and only slightly above
background threshold value

Constituent detected
infrequently (only once in 4
wells)

Constituent detected well
below the beneficial use limit
(CA action level)
-------
Table 7-1. (Continued)
Chemical of
Concern

Alpha-BHC
Maximum
Detected
Concentration a
(Ig/L)

0.008
Background
Threshold
Values b
(Ig/L)

0.005 f
Beneficial Use
Numerical
Limits c
(Ig/L)

0.15
Frequency
Detected
Versus
Frequency
Analyzed a

1/573
Remedial
Decision

NFA
Carbaryl (Sevin) 2.75
0.382 f
60
1/185
NFA
Remedial Decision
Rationale

Constituent detected
infrequently (detected once in
one well)

Constituent detected below
beneficial use limit
(Proposition 65 regulatory
level)

Constituent detected
infrequently (only once in one
well)

Constituent detected below
beneficial use limit (CA action
level)
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
NA
0.0002 8
Chlordane
0.7
0.104 f
0.03
25/574
NFA; effluent
treatment standard
established
Delta-BHC
0.282
0.005 f
500
6/573
NFA
Constituent detected
intermittently (less than 50%
frequency) in 11 wells.

The source areas will be
removed (SWMUs 2,3, and 8)

Constituent generally detected
below beneficial use limit
(MCL)

Constituent detected
infrequently (only once in 6
wells)
0.06 h
NC
-------
Chemical of
Concern
Maximum
Detected
Concentration a
(Ig/L)
Table 7-1. (Continued)

Background Beneficial Use
Threshold Numerical
Values b Limits c
(Ig/L) (Ig/L)
Freguency
Detected
Versus
Freguency
Analyzed a
Remedial
Decision
Remedial Decision
Rationale
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
ODD
0.052
0.005 f
DDE
0.116
0.005 f
DDT
0.262
0.005 f
Diazinon
0.347
1.00 f
0.15
16/574
NFA; effluent
treatment standard
established
0.1
25/574
NFA; effluent
treatment standard
established
0.1
23/574
NFA; effluent
treatment standard
established
0.6
1/236
NFA
Constituent detected
infreguently in 9 wells (less
than 25% freguency). The
source areas will be removed
(SWMUs 2,8, and 33)

Constituent detected below
beneficial use limit (CA/EPA
cancer potency factor)

Constituent detected
infreguently in 9 wells (less
than 25% freguency). The
source areas will be removed
(SWMUs 2, 3, 8, and 33)

Constituent detected below
beneficial use limit (CA/EPA)
cancer potency factor)

Constituent detected
intermittently in 7 wells (less
than 25% freguency). The
source areas will be removed
(SWMUs 2, 3, and 33)

Constituent generally detected
below beneficial use limit
(NAS drinking water standard)

Constituent detected
infreguently (less than 25%
freguency in only one well)

Constituent detected below
beneficial use limit (SNARL)
-------
Table 7-1. (Continued)
Chemical of
Concern

Dicamba (Banvel)
Maximum
Detected
Concentration a
(Ig/L)

0.024
Background
Threshold
Values b
(Ig/L)

0.091 f
Beneficial Use
Numerical
Limits c
(Ig/L)

210
Frequency
Detected
Versus
Frequency
Analyzed a

1/284
Remedial
Decision

NFA
Remedial Decision
Rationale

Constituent detected
infrequently (less than 25%
frequency; detected only once
in one well)
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
Dichlorvos (DDVP) 0.325
1.00 t
1.00
1/236
NFA
Constituent detected well
below beneficial use limit
(EPA-SNARL)

Constituent detected
infrequently (less than 20%
frequency; detected only once
in one well).
Constituent detected below
background threshold value
Dieldrin
0.569
0.005 f
0.002
114/574
Diuron
3.31
0.144 f
14
26/185
Aquifer cleanup level
established
Effluent treatment
standard established
NFA; effluent
treatment standard
established
Constituent detected in 26
wells (20% to 100%
frequency)

The source areas will be
removed (SWMUs 2, 3, 6, 8,
20, and 33)

Constituent detected in 14
wells. Plume has been
identified downgradient of
SWMU 2/3 with OU 1 capture
zone and will be treated by
dieldrin treatment system.

Constituent detected below
beneficial use limit (EPA-
SNARL)
0.62
NC
NA
0.005
-------
Table 7-1. (Continued)
Chemical of
Concern

Endosulfan A
Maximum
Detected
Concentration a
(Yg/L)

0.166
Background
Threshold
Values b
(Yg/L)

0.005 f
Beneficial Use
Numerical
Limits c
(Yg/L)

0.93/2.0
Freguency
Detected
Versus
Freguency
Analyzed a

4/573
Remedial
Decision

NFA
Remedial Decision
Rationale
Excess
Cancer Risk d
(x-4)
Constituent detected
infreguently (less than 25%
freguency; detected only once
in 4 wells)
Hazard
Quotient d
Endosulfan B
0.007
0.005 f
0.93/2.0
2/573
NFA
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)

Constituent detected well
below water guality criterion

Constituent detected
infreguently (less than 25%
freguency; detected only once
in 2 wells)
Endosulfan Sulfate
0.295
0.005 f
0.93/2.0
5/574
NFA
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)

Constituent detected well
below water guality criterion

Constituent detected
infreguently (less than 25%
freguency; detected only once
in 5 wells)
Constituent not detected in site
soils. Originates from off-site
source area (agricultural non-
point sources)

Constituent detected well
below water guality criterion
-------
Table 7-1. (Continued)
Chemical of
Concern
Endrin
Maximum
Detected
Concentration a
(Yg/L)

0.066
Background
Threshold
Values b
(Yg/L)

0.005 f
Beneficial Use
Numerical
Limits c
(Yg/L)

2
Freguency
Detected
Versus
Freguency
Analyzed a

13/573
Remedial
Decision

NFA
Heptachlor
0.025
0.005 f
0.006
3/574
NFA
Remedial Decision
Rationale
Excess
Cancer Risk d
(x-4)
Constituent detected
intermittently (less than 50%
freguency; detected only in 4
wells)

The sources areas will be
removed (SWMU 2/3)

Constituent detected well
below water guality criterion

Constituent detected
infreguently (less than 25%
freguency; detected only once
in 3 wells) and data validation
indicates that the presence of
this compound is unconfirmed

Constituent not detected in site
soils.
NA
Hazard
Quotient d

0.0008
Heptachlor Epoxide
0.029
0.005 f
0.003
9/574
Originates from off-site source
area (agricultural non-point
sources)

Constituent detected at or
below beneficial use limit
(MCL)

NFA Constituent detected
infreguently (less than 25%
freguency; detected only once
in 9 wells) and data validation
indicates that the presence of
this compound is unconfirmed

The source area will be
removed (SWMU 6)
-------
Table 7-1. (Continued)
Chemical of
Concern

Lindane (Gamma-
Maximum
Detected
Concentration a
(Yg/L)

0.046
Background
Threshold
Values b
(Yg/L)

0.005 f
Beneficial Use
Numerical
Limits c
(Yg/L)

0.03
Freguency
Detected
Versus
Freguency
Analyzed a

4/573
Remedial
Decision

NFA
Linuron
23.i
0.157 f
1.4
6/185
NFA
Remedial Decision
Rationale
Excess
Cancer Risk d
(x-4)
Constituent detected
infreguently (less than 25%
freguency; detected only once
in 5 wells)

The sources area will be
removed (SWMU 6)

Constituent detected at or
below beneficial use limit
(MCL)

Constituent detected
infreguently (less than 25%
freguency; detected only once
in 5 wells)
Hazard
Quotient d
NA
0.09
Methiocarb
4.57
1.36 f
1.36
3/185
NFA
Constituent originates from
off-site source area
(agricultural non-point sources)

Constituent generally detected
below beneficial use limit
(EPA RFD)

Constituent detected NR
intermittently (detected once in
only 3 wells)

Constituent originates from
off-site source area
(agricultural non-point sources)
NR
-------
Table 7-1. (Continued)
Chemical of
Concern

Methoxychlor
Maximum
Detected
Concentration a
(Yg/L)

0.004
Background
Threshold
Values b
(Yg/L)

0.005 f
Beneficial Use
Numerical
Limits c
(Yg/L)

40
Freguency
Detected
Versus
Freguency
Analyzed a

1/569
Remedial
Decision

NFA
Monuron
3.14
0.163 f
10
40/185
NFA; effluent
treatment standard
established
Remedial Decision
Rationale

Constituent detected
infreguently (less than 25%
freguency; detected only once
in one well)

Constituent detected below
beneficial use limit (MCL)

Constituent detected
inconsistently in 24 wells

Plume has been identified
downgradient of SWMU 2/3
within OU 1 capture zone and
will be treated by dieldrin
treatment system.
Excess
Cancer Risk d
(x-4)
Hazard
Quotient d
NA
0.007
Simazine
2.07
0.492 f
7/236
NFA
Constituent detected below
beneficial use limit (SNARL)

Constituent detected
intermittently in only 4 wells

The source areas will be
removed (SWMUs 2, 3, and 4)

Constituent detected below
beneficial use limit (MCL)
0.02
NC
-------
Table 7-1. (Continued)
Chemical of
Concern

Dioxins/Furans
Maximum
Detected
Concentration a
(Yg/L)

2.7x10 -7
Background
Threshold
Values b
(Yg/L)

1x10 -6
Beneficial Use
Numerical
Limits c
(Yg/L)

2.7x10 -7
Freguency
Detected
Versus
Freguency
Analyzed a

2/17
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected below
beneficial use limit.
Excess
Cancer Risk
(x-4)

I
Hazard
Quotient d
Metals

Arsenic (total) 7.4
50
40/804
NFA
Arsenic (dissolved)
7.5
50
15/594
NFA
Only the least toxic congener
(OCDD) was detected at
concentrations well below the
background threshold value

Technical economic evaluation
indicates that it is economically
infeasible to remediate
dioxins/furan in groundwater
Constitutent detected
intermittently in 10 wells;
freguency of detections may be
due to elevated turbidity

The source areas will be
removed (SWMUs 2/3)

Constituent detected well
below beneficial use limit
(MCL) and only slightly above
background threshold value

Constituent detected
intermittently in only 4 wells

Constituent detected well
below beneficial use limit
(MCL) and slightly above
background threshold value
0.4
NC
0.4 g
-------
Table 7-1. (Continued)
Chemical of
Concern

Antimony (total)
Antimony
(dissolved)
Maximum
Detected
Concentration a
(Yg/L)

250
3.9
Background
Threshold
Values b
(Yg/L)
Beneficial Use
Numerical
Limits c
(Yg/L)
Freguency
Detected
Versus
Freguency
Remedial
Analyzed a Decision

7/803 NFA
3.9
3/498
NFA
Remedial Decision
Rationale

Constituent detected
intermittently in 5 wells
than 25% freguency)
Excess
Cancer Risk
(x-4)

NA
Hazard
Quotient d
(less
Constitutent detected
intermittently in 3 wells
(other detections are due to
filter contamination)
NA
Constituent detected below
beneficial use limit (MCL)
slightly above background
threshold value
and
Barium (total)
572
145
1,000
63/791
NFA
Constituent detected in 12
wells; other detections are due
to elevated turbidity

Constituent detected well
bellow beneficial use limit
(MCL) and slightly above
background threshold value

The pattern of detections is not
suggestive of site
contamination. Most
detections ranged from 50-150
Yg/L
NA
-------
Table 7-1. (Continued)
Chemical of
Concern

Barium (dissolved)
Maximum
Detected
Concentration a
(Yg/L)

763
Background
Threshold
Values b
(Yg/L)
Beneficial Use
Numerical
Limits c
(Yg/L)

1,000
Freguency
Detected
Versus
Freguency
Analyzed a

60/473
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected in 14
wells
Excess
Cancer Risk
(x-4)

NA
Hazard
Quotient d
Constituent detected below
beneficial use limit (secondary
MCL)
Beryllium (total)
0.1
0.1
2/804
NFA
The pattern of detections is not
suggestive of site
contamination. Most
detections ranged from 50-
150 Yg/L

Constitutent detected
intermittently in 2 wells
(less than 20% freguency);
dissolved beryllium not
detected above background
threshold value
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Boron (total)
7,090
2,590
600
18/643
NFA
Boron (dissolved)
3,380
2360
600
5/315
NFA
Constituent detected NA
intermittently in 14 wells (less
than 50% freguency)

Detections may be due to
elevated turbidity

Constituent originates from
off-site source area
(agricultural non-point sources)

Constituent detected NA
intermittently in only 4 wells
(less than 25% freguency)
-------
Table 7-1. (Continued)
Chemical of
Concern

Cadmium (total)
Maximum
Detected
Concentration a
(Yg/L)

40
Background
Threshold
Values b
(Yg/L)

4.4
Beneficial Use
Numerical
Limits c
(Yg/L)
Freguency
Detected
Versus
Freguency
Analyzed a

6/804
Remedial
Decision

NFA
Remedial Decision
Rationale

Constituent detected
intermittently in 6 wells
(less than 20% freguency);
dissolved cadmium not
detected above background
threshold value
Excess
Cancer Risk d
(x-4)

NA
Hazard
Quotient d
Constituent generally detected
below beneficial use limit
(MCL)
Chromium (total)
44.7
35.7
50
23/810
NFA; effluent
treatment standard
established
Constitutent detected
intermittently in 17 wells (less
than 25% freguency)

Detections may be due to
elevated turbidity

Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Chromium
(dissolved)
43
30
50
14/595
NFA
Copper (total)
90
12.9
1,000
17/814
NFA
Constituent detected
intermittently in 8 wells (less
than 50% freguency)

Constituent detected
beneficial use limit (MCL)

Constituent detected
intermittently in 14 wells (less
than 25% freguency); other
detections are due to elevated
turbidity

Constituent detected below
beneficial use limit (secondary
MCL)
NA
-------
Table 7-1. (Continued)
Chemical of
Concern

Copper (dissolved)
Maximum
Detected
Concentration a
(Ig/L)

70
Background
Threshold
Values b
(Ig/L)

20.2
Beneficial Use
Numerical
Limits c
(Ig/L)

1,000
Freguency
Detected
Versus
Freguency
Analyzed a

9/595
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected
intermittently in 8 wells
than 30% freguency)
Excess
Cancer Risk
(x-4)

NA
Hazard
Quotient d
(less
Constituent detected below
beneficial use limit (secondary
MCL)
Lead (total)
20.4
21.2
15
14/875
NFA Most detections are due to
elevated turbidity; exceeds
back-ground threshold value in
5 wells intermittently. Not
related to site contamination.
Dissolved lead not detected
NA
Manganese (total)
1,640
338
50
13/723
NFA Constituent detected
consistently in only one well
(less than 25% freguency)

Most detections are due to
elevated turbidity

Technical and economic
evaluation indicates that it is
economically infeasible to
remediate manganese in
groundwater
NA
-------
Table 7-1. (Continued)
Chemical of
Concern

Manganese
(dissolved)
Maximum
Detected
Concentration a
(Ig/L)
Background
Threshold
Values b
(Ig/L)

17.5
Beneficial Use
Numerical
Limits c
(Ig/L)

50
Freguency
Detected
Versus
Freguency
Analyzed a

41/407
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected
intermittently in 13 wells
(consistently detected in 3
wells)
Excess
Cancer Risk
(x-4)

NA
Hazard
Quotient d
Trend of decreasing
concentrations observed

Constituent detected above
beneficial use limit (secondary
MCL)
Mercury (total)
6.62
0.2
6/799
NFA
Technical and economic
evaluation indicates that it is
economically infeasible to
remediate manganese in
groundwater

Constituent detected
intermittently in 5 wells (less
than 25% freguency). Other
detections may be due to
elevated turbidity
NA
Constituent generally detected
below beneficial use limit
(MCL)
Mercury,
(dissolved)
1.95
0.2
3/407
NFA Constituent detected
intermittently in 5 wells
NA
Constituent detected above
beneficial use limit (MCL)
-------
Table 7-1. (Continued)
Chemical of
Concern

Nickel (total)
Maximum
Detected
Concentration a
(Ig/L)

25.8
Background
Threshold
Values b
(Ig/L)

21.2
Beneficial Use
Numerical
Limits c
(Ig/L)

100
Freguency
Detected
Versus
Freguency
Analyzed a

2/804
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected
intermittently in 2 wells
than 20% freguency);
dissolved nickel not detected
above background threshold
value
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
NA
(less
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Nitrate, as N
26.3
25.1
45
4/232
NFA Constituent generally detected
below beneficial use limit
(state MCL) and background
threshold value
NA
Selenium (total)
Selenium
(dissolved)
7.87
9.1
12.1
6.0
50
50
6/804
4/594
NFA
NFA
Constituent detected
infreguently in 5 wells
than 25% freguency)
(less
Constituent detected
intermittently in 3 wells
than 35% freguency)
NA
NA
(less
Constituent detected below
beneficial use limit (MCL) and
only slightly above background
threshold value
Vanadium (total)
43.1
30.2
50
17/785
NFA Constituent detected
intermittently in 17 wells (less
than 25% freguency). Other
detections may be due to
elevated turbidity.

Constituent detected below
beneficial use limit (MCL)
NA
-------
Table 7-1. (Continued)
Chemical of
Concern
Vanadium
(dissolved)
Maximum
Detected
Concentration a
(Ig/L)

20
Background
Threshold
Values b
(Ig/L)

16.2
Beneficial Use
Numerical
Limits c
(Ig/L)

50
Freguency
Detected
Versus
Freguency
Analyzed a

10/467
Remedial Remedial Decision
Decision Rationale

NFA Constituent detected
intermittently in 8 wells
than 30% freguency)

Constituent detected below
beneficial use limit (MCL)
Excess
Cancer Risk
(x-4)
Hazard
Quotient d
NA
(less
a Database includes guarterly monitoring results from January 1987 to June 1995; results obtained in earlier sampling events were not used in the statistics provided for metals
because the guality of these data is lower than the guality of data collected after 1991. Samples with elevated turbidity were not counted in the statistics provided for metals.
Additionally, unconfirmed outliers were eliminated from the statistical data provided on this table.
b Background threshold values are presented for the "A" horizon.
c Beneficial use numerical limits and the types of water guality goals that these values represent are presented in Appendix P, Table P-10 of the RI/FS (Montgomery Watson,
1996a). Numerical limits were updated based on input from the CVRWQCB.
d Risk numbers are based on maximum concentrations reported in the monitoring well database unless otherwise noted.
e Chemical not reported as a contaminant in the Phase I RI/RA (WCC, 1992b), the OU 1 ROD, or in wells located on the Annex or off-depot; therefore, risks were not calculated.
f No monuron or diuron has been detected in the background wells. The value cited is the lowest detection limit from a modified method that was previously used. These detection
limits have not been reproducible.

NA = not applicable; chemical is not an oral carcinogen.
NC = not calculated; applies to either the risk assessment (Section 5.2.15 of Appendix R of the RI/FS [Montgomery Watson, 1996a]) or background threshold values.
NFA = No Further Action
-------
Table 7-2. Remedial Alternatives for OU 1 Groundwater
Description of
Details
No Further Action
Institutional Controls
Alternatives
Groundwater Extraction and
Treatment-Option 1
Groundwater Extraction
and Treatment-Option 2
Treatment Process
Description
Containment or
Storage
Components
No treatment in addition
to tile full-scale OU 1
groundwater remediation
system.
None.
No treatment in addition to
the full scale OU 1
groundwater remediation
system.
Impose land use restrictions
for areas where elevated
concentrations of dieldrin in
the groundwater have been
detected.
Use wellhead pretreatment
(GAG) at the nine extraction
wells to remove dieldrin.
Treat water at OU 1
treatment plant (air stripping)
to remove VOCs.

None.
Use wellhead pretreatment
(GAG) at three wells to
remove dieldrin.
Treat water at OU 1
treatment plant (air
stripping) to remove VOCs.

None.
Groundwater
Components
Groundwater monitoring
is included in Well
Monitoring Program.
Extraction wells for the
OU 1 groundwater
remediation system are
located in the vicinity of
the greatest dieldrin
concentrations detected in
groundwater.
Per CERCLA guidance,
five-year reviews
involving further
groundwater sampling
will be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Extraction wells for the OU 1
groundwater remediation
system are located in the
vicinity of the greatest
dieldrin concentrations
detected in groundwater.
Per CERCLA guidance, five-
year reviews involving
further groundwater sampling
will be conducted.
Additional groundwater *
extraction wells are installed
in the Above Upper Horizon
in the following locations:
SWMUs 2 and 3 (three
wells), SWMU 8 (two
wells), and the Tracy Annex
(four wells). Estimated flow *
rate at each extraction well is
5 gallons per minute (gpm). *
Treated groundwater (no
VOC contamination) is
reinjected from SWMU 8
using injection facilities.
Groundwater monitoring is
included in Well Monitoring
Program.
Three additional ground-
water extraction wells are
installed in the Above
Upper Horizon near
SWMUs 2 and 3. Estimated
flow rate at each extraction
well is 5 gpm.
Treated water is discharged
to infiltration gallery.
Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-2.
(Continued)
Alternatives
Description of
Details

Implementability
No Further Action

No action is required to
implement provided an
annual groundwater
monitoring program is
implemented as planned.
Institutional Controls

Cooperation is required J
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
The land use restriction
affects groundwater use, but *
allows the annex and off-base
areas to remain in productive
agricultural use.
Groundwater Extraction and
Treatment-Option 1

* It is feasible to install
groundwater extraction wells
with pad-mounted liquid-
phase GAG systems and
conveyance piping for each
well.
Coordination with regulatory
agencies is required for
installation of any wells and
operation of the groundwater
treatment system.
Groundwater Extraction
and Treatment-Option 2

* It is feasible to install
groundwater extraction
wells with pad-mounted
liquid-phase GAG
systems and conveyance
piping for each well.
k Coordination with
regulatory agencies is
required for installation of
any wells and operation of
the groundwater treatment
system.
Risk Reduction
This alternative does not
reduce the risk of human
or environmental
exposure.
This alternative reduces the *
risk of human exposure to
dieldrin. However, it does
not actively reduce the risk to
the environment.
This alternative is protective
of both human health and the
environment because
groundwater is extracted and
treated at all three areas of
contamination.
Groundwater modeling
predicts that in 50 years
dieldrin concentration may be
reduced below the aquifer
cleanup standard (California
Action Level) of 0.05 Ig/L at
SWMUs 2 and 3 and SWMU
8. At the Tracy Annex, the
cleanup standard will not be
met in 50 years.
This alternative is
protective of both human
health and the
environment at the area
where groundwater is
extracted and treated.
Groundwater modeling
predicts that in 50 years
the dieldrin concentration
can possibly be reduced
below the aquifer cleanup
standard (California
Action Level) of 0.05
Ig/L at SWMUs 2 and 3.
The dieldrin concentration
will not be actively
reduced at the DDJC-
Tracy Annex or
SWMU 8.
-------
Table 7-2.
(Continued)
Alternatives
Description of
Details

Major ARARs and
TBCs
No Further Action

Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Estimated Cost
(Present Worth)
$9,561,600 ($49,000 for
additional reviews)
Institutional Controls

Chemical-specific TBCs
were developed from Water
Quality Goals (CVRWQCB,
1993).
$9,601,000 ($99,000 for
additional monitoring)
Groundwater Extraction and
Treatment-Option 1

* No chemical-specific or
location-specific ARARs are
identified. Chemical-specific
TBCs were developed from
Water Quality Goals
(CVRWQCB, 1993).
* Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
* Spent GAG can only be
stored on-site for 90 days.
$12,040,000 ($2,528,000 to
address dieldrin)
Groundwater Extraction
and Treatment-Option 2

k No chemical-specific or
location-specific ARARs
are identified. Chemical-
specific TBCs were
developed from Water
Quality Goals
(CVRWQCB, 1993).
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
k Spent GAG can only be
stored on-site for 90 days.

k $10,909,000 ($1,396,000
to address dieldrin)
ARARS = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response Compensation, and Liability Act
GAG = Granular Activated Carbon
OU = Operable Unit
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
Ig/L = microgram per Liter
VOC = volatile organic compound
-------
Description of
Details

Treatment Process
Description
Containment or
Storage
Components
No Action

* None.
Table 7-3. Remedial Alternatives for SWMU I/Area 2, Area 1 Building 237, and Area 3
Alternatives
Institutional Controls Soil Vapor Extraction
None.
None.
Impose land use restrictions
for areas where elevated
concentrations of TCE and
PCE in the soil have been
detected.
In situ SVE system installed in
the area of highest
contamination at each site.
Each SVE well has an
approximately 40-foot range
of influence.
Wells are screened from
approximately 5 feet bgs to
approximately 3 feet above the
water table,
Extracted air treated by vapor
phase GAG.
Treated air discharged to
atmosphere.

None.
Excavation and Disposal

* Soil contaminated with Vocs
excavated from each site:
- 30,100 yd 3 at SWMU I/
Area 2,
- 8,500 yd 3 at Area 1 Bldg.
237,
- 25,200 yd 3 at Area 3.
* Soil transported to a Class I
off-depot disposal facility.
* Clean soil imported from off-
depot to backfill the excavated
areas.
None.
Groundwater
Components
* Groundwater monitoring is
included in Well
Monitoring Program.
* Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling will
be conducted.
* Groundwater monitoring is
included in Well Monitoring
Program.
* Per CERCLA guidance,
five-year reviews involving
minimal groundwater
sampling will be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-3. (Continued)
Description of
Details
No Action
Alternatives
Institutional Controls
Soil Vapor Extraction
Excavation and Disposal
Implementability
No action is required to
implement provided annual
groundwater monitoring
program is implemented as
planned.
Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
It is feasible to install and
maintain the SVE system.
It is feasible to excavate and
landfill the contaminated soil.
Risk Reduction
This alternative does not
reduce the risk of human or
environmental exposure to
PCE and TCE.
This alternative reduces the
risk of human exposure to
TCE and PCE. However, it
does not actively reduce the
risk to the environment
(groundwater).
This alternative is protective of
human health and the
environment.
It is expected that continuous
operation of the SVE system
for 6 months will remove the
threat of VOC migration to
groundwater.
This alternative is protective
of human health and the
environment.
The threat of VOC migration
to groundwater is removed
immediately on completion of
excavation.
Major ARARs and
TBCs
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Chemical-specific TBCs
were developed from Water
Quality Goals
(CVRWQCB, 1993).
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management, California
requirements for groundwater
protection, and air quality
management district
requirements for air emissions
from GAG.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements fur
groundwater protection.
Estimated Cost
(Present Worth)
$15,000 (for each site)
$65,000 (for each site)
$266,000 (SWMUl/Area 2)
$140,000 (Area 1 Bldg. 237)
$242,000 (Area 3)
$19,785,000 (SWMU I/Area
2)
$5,607,000 (Area 1 Bldg. 237)
$16,662,000 (Area 3)
-------
Table 7-3. (Continued)

ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
GAG = Granular Activated Carbon
PCE = tetrachloroethene
SVE = Soil Vapor Extraction
SWMU = Solid Waste Management Unit
TBC = to be considered
TCE = trichloroethene
U.S. EPA = United States Environmental Protection Agency
VOCs = volatile organic compounds
yd 3 = cubic yards
-------
Description of
Details

Treatment Process
Description
Table 7-4. Remedial Alternatives for ST/JMU 4 - Storm Drain Lagoon

Alternatives

No Action Upstream Source Control

None. * Remove sediment periodically (2,300
yd 3 every five years) from storm water
conduits upstream of the storm drain
lagoon.
* Dewater and transport the sediment to
an off-site Class I disposal facility.
Limited Excavation and Disposal of
Sediments

* Excavate sediment contaminated with metals
and pesticides.
* Dewater and transport the sediment to a
Class III (municipal) facility for disposal.
Containment or
Storage
Components

Groundwater
Components
Implementability
due
Risk Reduction
None.
Groundwater monitoring is included
in Well Monitoring Program.
Per CERCLA guidance, five-year
reviews involving minimal sediment,
surface water, and groundwater
sampling will be conducted.

No action is reguired to implement

provided annual groundwater moni-
toring program is implemented as
planned.

There is no potential risk of human
exposure at SWMU 4. However, this
alternative does not actively reduce
the potential risk posed to ecological
receptors or groundwater.
None.
Groundwater monitoring is included in
Well Monitoring Program.
This alternative is easy to implement.
There is no potential risk of human
exposure at SWMU 4. However, this
alternative does not directly, imme-
diately reduce the potential risk posed
to ecological receptors.
This alternative prevents the potential
threat to groundwater and surface water
from increasing.
Temporarily stockpile excavated material on-
site.
* Groundwater monitoring is included in Well
Monitoring Program.
* It is difficult to implement this alternative

to the logistics reguired to drain the lagoon
prior to sediment removal.
This alternative is protective of human health
and the environment. However, the
excavation of contaminated sediment could
have a much larger negative impact on the
lagoon ecosystem and the aguatic biota than
the ecological risks posed by the
contaminants.
-------
Table 7-4. (Continued)

Alternatives
Description of
Details

Risk Reduction
(Continued)
No Action
Upstream Source Control
Limited Excavation and Disposal of
Sediments

The threat posed to ecological receptors is
removed by isolating the receptors from
contaminants in subsurface soils.
Major ARARs and
TBCs
Estimated Cost
(Present Worth)
Federal ambient water guality criteria
for protection of aguatic life is a
chemical-specific ARAR for surface
water.
Chemical-specific TBCs for
groundwater protection were
developed from Water Quality Goals
(CVRWQCB, 1993).
California Fish and Game Code is a
location-specific ARAR.
No action-specific ARARs are
identified.
$ 25,000
Federal ambient water guality criteria
for protection of aguatic life is a
chemical-specific TBC for surface
water.
Chemical-specific TBCs for
groundwater protection were developed
from Water Quality Goals
(CVRWQCB, 1993) .
California Fish and Game Code is a
location-specific ARAR.
Action-specific ARARs include
California and federal reguirements for
hazardous waste management and
California reguirements for groundwater
protection.

$ 1,158,000
ARARs = Applicable or Relevant and Appropriate Reguirements
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVOC = semivolatile organic compound
SWMU = Solid Waste Management Unit
TBC = to be considered
yd 3 = cubic yards
Federal ambient water guality criteria for
protection of aguatic life is a chemical-
specific TBC for surface water.
Chemical-specific TBCs for groundwater
protection were developed from Water
Quality Goals (CVRWQCB, 1993).
California Fish and Game Code is a
location-specific ARAR.
Action-specific ARARs include California
and federal reguirements for hazardous
waste management and California
reguirements for groundwater protection.
$ 552,000
-------
Table 7-5. Remedial Alternatives for SWMU 6 - Building 28 Sump
Description of
Details
No Action
Alternatives
Institutional Controls In situ Stabilization
Excavation and Disposal
Treatment Process
Description
None.
None.
Mix contaminated soils
with pozzolanic materials
using an auger and well
head system to physically
and chemically
immobilize pesticide
contamination.
Excavate soil contaminated with
pesticides (100 yd 3) from SWMU 6.
Transport 60 yd 3 of soil to a Class I or
Class II off-site disposal facility
depending on the level of
contamination.
Import clean soil from off site to
backfill the excavated areas.
Containment or
Storage
Components
None.
Impose land use
restrictions for area
where elevated
concentrations of
pesticides have been
detected.
Capture vapors or dust
produced during the
stabilization process.
Temporarily stockpile excavated
material on-site.
Groundwater
Components
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling will
be conducted.
Groundwater monitoring
is included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling
will be conducted.
Groundwater monitoring
is included in Well
Monitoring Program.
Groundwater monitoring is included
in Well Monitoring Program.
Implementability
No action is reguired to
implement provided annual
groundwater monitoring
program is implemented as
planned.
Cooperation is reguired
among the Army, the
U.S. EPA, San Joaguin
County, and Cal-EPA to
enact the land use
restrictions.
This alternative is
technically feasible and
commercially available.
It is feasible to excavate, transport,
and landfill the contaminated soil.
-------
Table 7-5. (Continued)
Description of
Details

Risk Reduction
No Action
Alternatives
Institutional Controls In situ Stabilization
* There is no potential risk to * There is no potential risk
human exposure at SWMU
6, This alternative does
not reduce the risk of
environmental exposure to
pesticides.
to human exposure at
SWMU 6. This
alternative does not
actively reduce the risk
of environmental
exposure to pesticides.
This alternative is
protective of human
health and the
environment.
The potential threat to
groundwater is
significantly reduced.
Excavation and Disposal

This alternative is protective of human
health and the environment.
The threat of contamination migrating
to groundwater is removed
immediately on completion of
excavation.
Major ARARs and
TBCS
Chemical-specific TBCs
were developed front
Water Quality Goals
(CVRWQCB, 1993)
chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993)
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993)
Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993)
Estimated Cost
(Present Worth)
$ 15,000
$ 65,000
$ 169,000
$ 65,000 for Class I disposal or
$ 45,000 for Class II disposal
ARARs = Applicable or Relevant and Appropriate Reguirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd 3 = cubic yards
-------
Table 7-6. Remedial Alternatives for SWMU 7 - Burn Pit No. 1
Alternatives
Description of
Details

Treatment
Process
Description
No Action

* None.
Institutional Controls

* None.
In Situ Stabilization with
Institutional Controls

* Mix contaminated soils with
pozzolanic materials using an
auger system for mixing and
an injector head system to
apply stabilization agents.
Excavation and Disposal with
Institutional Controls

Excavate 3,600 yd 3 (4,700 tons)
of contaminated soil and debris.
Transport the contaminated soil
to a Class I off-site disposal
facility.
Import clean soil from off-site
to backfill the excavated areas.
Containment or
Storage
Components
None.
Impose land use restrictions
for areas where elevated
concentrations of VOCs,
SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons in the soil have
been detected.
Capture vapors or dust
produced during the
stabilization process.
None.
Groundwater
Components
Groundwater
monitoring is included
in Well Monitoring
Program.
per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling
will be conducted.
Install two additional
monitoring wells
downgradient of the site.
Monitor the two wells for OP
pesticides, OC pesticides,
chlorinated herbicides,
carbon/urea pesticides, and
dioxins/furans semiannually
for one year.
Monitor one well for SVOCs
annually for four years.
Groundwater monitoring is
included in Well Monitoring
Program.
Groundwater monitoring is
included in Well Monitoring
Program.
Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-6. (Continued)

Alternatives
Description of
Details
No Action
Institutional Controls
In Situ Stabilization with
Institutional Controls
Excavation and Disposal with
Institutional Controls
Implementability
* No action is required to
implement provided
annual groundwater
monitoring program is
implemented as planned.
* Cooperation is required among
the Army, the U.S. EPA, San
Joaquin County, and Cal-EPA
to enact the land use
restrictions.
* This is a technically feasible
and commercially available
technology. Materials
required for implementing this
alternative are readily
available.
It is feasible to excavate,
transport, and landfill the
contaminated soil.
Risk Reduction
Major ARARs
and TBCs
This alternative does
not reduce the risk of
human or
environmental exposure
to VOCs, SVOCs,
pesticides and
herbicides, petroleum
hydrocarbons.

Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993).
This alternative reduces the
risk of human exposure to
VOCs, SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons. However, it
does not actively reduce the
risk to the environment or
groundwater.

Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993) .
This alternative is protective
of human health and the
environment.
This alternative significantly
reduces the threat posed to the
groundwater.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
This alternative is protective of
human health and the
environment.
The potential threat of SVOC,
pesticide and herbicide, and
petroleum hydrocarbon
migration to groundwater
would be eliminated.

No chemical-specific or
location-specific ARARs are
identified.
Action-specific ARARs include
California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
Estimated Cost
$ 15,000
$ 208,000
$ 822,000
$ 2,605,000
-------
Table 7-6. (Continued)
ARARs
= Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
OP = organophosphorus
OC = organochlorine
SVOCs = semivolatile organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
VOCS
= volatile organic compounds
-------
Table 7-7. Remedial Alternatives for SWMU 8 - Burn Pit No. 2
Description of
Details

Treatment
Process
Description
No Action

* None.
Alternatives
Institutional Controls
* None.
Bioventing

Install three air-injection well
clusters to oxygenate the
subsurface.
Install a pad-mounted blower
adjacent to the air-injection
well to supply air necessary to
enhance biodegradation in the
subsurface.
Excavation and Disposal

* Excavate 4,500 yd 3 (5,800
tons) of contaminated soil and
debris.
* Transport 3,400 tons of
contaminated soil to a Class I
off-site disposal facility.
* Transport 2,400 tons of debris
to a Class III off-site disposal
facility.
* Import clean soil from off-site
to backfill the excavated areas.
Containment or
Storage
Components
None.
Impose land use restrictions for
areas where elevated
concentrations of SVOCs,
pesticides and herbicides, and
petroleum hydrocarbons in the
soil have been detected.
None.
* Temporarily stockpile
excavated materials on-site.
Groundwater
Components
* Install a new monitoring
well between the two
existing monitoring
wells.
* Monitor the new well
and the two existing
wells for OC pesticides
over four guarters for
one year.
* Groundwater monitoring
is included in Well
Monitoring Program.
* Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling
will be conducted.
* Install a new monitoring well
between the two existing
monitoring wells.
* Monitor the new well and the
two existing wells for OC
pesticides over four guarters for
one year.
* Groundwater monitoring is
included in Well Monitoring
Program.
* Per CERCLA guidance, five-
year reviews involving
minimal groundwater sampling
will be conducted.
* Groundwater monitoring is
included in Well Monitoring
Program.
Install one new monitoring
well between the two existing
monitoring wells.
Monitor the new well and the
two existing wells for OC
pesticides over four guarters
for one year.
Groundwater monitoring is
included in Well Monitoring
Program.
* Install one new monitoring
well between the two existing
monitoring wells.
* Monitor the new well and the
two existing wells for OC
pesticides over four guarters
for one year.
* Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-7. (Continued)
Description of
Details

Implementability
No Action

No action is required to
implement provided
annual groundwater
monitoring program is
implemented as planned.
New monitoring wells
can be easily installed.
Alternatives
Institutional Controls

Cooperation is required among
the Army, the U.S. EPA, San
Joaquin County, and Cal-EPA
to enact the land use
restrictions.
Bioventing

It is feasible to install and
maintain the bioventing
system. However, air-
injection wells may be
difficult to install and operate
due to construction debris.
Excavation and Disposal

Excavate may be difficult at
SWMU 8 due to construction
debris. The debris must be
separated from the
contaminated soil before
disposal.
Risk Reduction
* This alternative does not
reduce the risk of human
or environmental
exposure to SVOCS,
pesticides and
herbicides, or petroleum
hydrocarbons.
* Additional monitoring
will help clarify actual
exposure potential and
risk to groundwater.
* This alternative reduces the
risk of human exposure to
SVOCs, pesticides and
herbicides, and petroleum
hydrocarbons. However, it
does not actively reduce the
risk to the environment.
* Additional monitoring will help
clarify actual exposure potential
and risk to groundwater.
This alternative is protective
of human health and the
environment.
The petroleum hydrocarbons
and SVOCs should be reduced
below the cleanup standard in
two years.
This alternative does not
reduce the threat posed to the
groundwater by pesticides in
the soil.
* This alternative is protective
of human health and the
environment.
* The potential threat of SVOC,
pesticide and herbicide, and
petroleum hydrocarbon
migration to groundwater
would be eliminated.
Major ARARs
and TBCs
Estimated Cost
(Present Worth)
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
$ 15,000
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
$65,000
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
$246,000
* Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
* Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
* $2,823,000
ARARs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
OC = organochlorine
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
SVOCS = semivolatile organic compounds
yd 3 = cubic yards
-------
Description of
Details

Treatment Process
Description
Containment or
Storage
Components
Table 7-8. Remedial Alternatives for SWMU 20 - Aboveground Solvent Tank/Building 26
Recoup Operations and Area 1 Building 10
No Action
None.
Alternatives
Institutional Controls
None.
None.
Impose land use restrictions
for areas where elevated
concentrations of
contaminants in the soil have
been detected.
SVE, Excavation and Disposal,
and Natural Attenuation

* Excavate the contaminated soil
(250 yd 3) from SWMU 20,
* Transport soil to a Class I off-site
disposal facility.
* Import clean soil from off-site to
backfill the excavated areas.
* Install in situ SVE system in the
vicinity of SB 108 at Area 1
Building 10 and SB431 to reduce
TCE concentrations below
cleanup standard.
* Soil contaminated with 2,4,6-
trichlorophenol is expected to
naturally attenuate before it
reaches groundwater.

* None.
Excavation and Disposal

* Excavate soil (500 yd 3)
contaminated with VOCs,
SVOCs, pesticides, and
petroleum hydrocarbons from
SWMU 20 and Area 1
Building 10.
* Transport soil to a Class I off-
site disposal facility.
* Import clean soil from off-site
to backfill the excavated
areas.
Temporarily stockpile
excavated materials on-site.
Groundwater
Components
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal
groundwater sampling will
be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving
minimal groundwater
sampling will be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-8. (Continued)
Description of
Details

Implementability
Risk Reduction
Major ARARs and
TBCs
No Action

No action is required to
implement provided
annual groundwater
monitoring program is
implemented as planned.
This alternative does not
reduce the risk of human
or environmental exposure
to VOCs, SVOCs, and
pesticides and herbicides.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993) .
Alternatives

Institutional Controls

* Cooperation is required
among the Army, the U.S.
EPA, San Joaquin County,
and Cal-EPA to enact the
land use restrictions.
* This alternative reduces the
risk of human exposure to
VOCs, SVOCs, and
pesticides and herbicides.
However, it does not reduce
the risk to the environment.
Chemical-specific TBCs
were developed from Water
Quality Goals (CVRWQCB,
1993).
Estimated Cost
(Present Worth)
$ 15,000
$65,000
SVE, Excavation and Disposal,
and Natural Attenuation

* It is feasible to install and
maintain the SVE system.
* It is feasible to excavate,
transport, and dispose of the
contaminated soil.
* This alternative is protective of
human health and the
environment.
* The threat of contaminant
migration to groundwater would
be eliminated.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993) .
Action-specific ARARs include
California and federal
requirements for hazardous waste
management, California
requirements for groundwater
protection, and AQMD
requirements for air discharges
from the SVE system.
$ 293,000
Excavation and Disposal

It is feasible to excavate,
transport, and dispose of the
contaminated soil.
This alternative is protective
of human health and the
environment.
The threat of contaminant
migration to groundwater
would be removed
immediately on completion of
excavation.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs
include California and federal
requirements for hazardous
waste management and
California requirements for
groundwater protection.
$355,000
ARARS = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVE = Soil Vapor Extraction
SVOCS = semivolatile organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
TCE = trichloroethene
U.S. EPA = United States Environmental Protection Agency
VOCS = volatile organic compounds
-------
Table 7-9. Remedial Alternatives for SWMU 24 - Building 247 Petroleum Laboratory Waste Oil Tank
Description of
Details

Treatment Process
Description
No Action

* None.
Institutional Controls

t None.
Alternatives

Bioventing

Install an air-injection
well and a pad-
mounted blower
system.
The well should be
screened from 6 feet
bgs to 16 feet bgs.
Excavation and
Disposal

Excavate 240 cubic
yards (320 tons) of
contaminated soil
and debris.
Transport the
contaminated soil to
a Class I off-site
disposal facility.
Import clean soil
from off site to
backfill the
excavated areas.
Excavation and On-Site
Bioremediation

* Excavate the soil with
contaminant levels above
cleanup standards.
* Treat the soil
aboveground using on-
site bioremediation, such
as landfarming, slurry-
phase reactors,
composting, or biopiles.
The actual remediation
process chosen to
remediate this site will be
determined during the
remedial design phase.
* The treated soil will be
backfilled at the site.
Containment or
Storage
Components
None.
Impose land use
restrictions for areas
where elevated
concentrations of
contaminants in the soil
have been detected.
None.
None.
None.
-------
Table 7-9. (Continued)

Alternatives
Description of
Details
No Action
Institutional Controls
Bieventing
Excavation and
Disposal
Excavation and On-Site
Bioremediation
Groundwater
Components
Monitor well
LM118AA for TPH as
gasoline and TPH as
diesel guarterly for
three guarters.
Groundwater
monitoring is included
in Well Monitoring
Program.
Per CERCLA
guidance, five-year
reviews involving
minimal groundwater
sampling will be
conducted. Analytical
data will be reviewed
to assess the potential
threat to groundwater
contamination.
Monitor well
LM118AA for TPH as
gasoline and TPH as
diesel guarterly for
basis for three guarters.
Groundwater
monitoring is included
in Well Monitoring
Program.
Per CERCLA
guidance, five-year
reviews involving
minimal groundwater
sample will be
conducted. Analytical
data will be reviewed to
assess the potential
threat to groundwater
contamination.
Monitor well
LM118AA for TPH as
gasoline and TPH as
diesel guarterly for three
guarters.
Groundwater
monitoring is included
in Well Monitoring
Program.
Monitor well
LM118AA for TPH
as gasoline and TPH
as diesel on a
guarterly basis for
three guarters.
Groundwater
monitoring is
included in Well
Monitoring
Program.
Monitor well
LM118AA for TPH
as gasoline and TPH
as diesel guarterly for
three guarters.
Groundwater
monitoring is
included in Well
Monitoring Program.
Implementability
There are no
implementation issues.
Cooperation is reguired
among the Army, U.S.
EPA, San Joaguin
County, and Cal-EPA
to enact the land use
restrictions.
It is feasible to install
and maintain the
bioventing system.
Excavation of soil
beneath Building
247 may be difficult
due to excavation
depth of 17 feet.
Excavation of soil
beneath Building 247
may be difficult due
to excavation depth of
17 feet.
-------
Table 7-9. (Continued)

Alternatives
Description of
Details
No Action
Institutional Controls
Bieventing
Excavation and
Disposal
Excavation and On-Site
Bioremediation
Risk Reduction
This alternative does
not reduce the risk of
human or
environmental
exposure to
contaminants.
This alternative reduces
the risk of human
exposure to
contaminants, but does
not reduce the risk to
groundwater.
This alternative is
protective of human
health and the
environment.
The VOCs, SVOCs, and
petroleum hydrocarbons
are reduced below the
cleanup standard in two
years.
This alternative
permanently reduces the
threat posed to the
groundwater by
biodegrading the
primary soil
contaminants (VOCs,
SVOCs, and petroleum
hydrocarbons).
Although PCBs and
pesticides are present in
the soil at SWMU 24,
posed by these
compounds is
considered low.
This alternative is
protective of human
health and the
environment.
The potential threat
of contaminant
migration to
groundwater would
be eliminated.
This alternative is
protective of human
health and the
environment.
The potential threat of
contaminant
migration to
groundwater would
be eliminated.
-------
Table 7-9. (Continued)

Alternatives
Description of
Details
No Action
Institutional Controls
Bieventing
Excavation and
Disposal
Excavation and On-Site
Bioremediation
Major ARARs
and TBCs
Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993).
Estimated Cost
(Present Worth)
$ 15,000
Chemical-specific TBCs
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993) .
$ 65,000
ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
PCB = polychlorinated biphenyl
SVOCs = semivolatile organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
TPH-D = total petroleum hydrocarbons as diesel
TPH-G = total petroleum hydrocarbons as gasoline
U.S. EPA = United States Environmental Protection Agency
VOCs = volatile organic compounds
Chemical-specific
were developed from
Water Quality Goals
(CVRWQCB, 1993) .
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
$ 166,000
Chemical-specific
TBCs were
developed from
Water Quality Goals
(CVRWQCB,
1993).
Action-specific
ARARs include
California and
federal requirements
for hazardous waster
management and
California
requirements for
groundwater
protection.

$ 214,000
Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993).
Action-specific
ARARs include
California and federal
requirements for
hazardous waster
management and
California
requirements for
groundwater
protection.
$263,000
-------
Table 7-10. Remedial Alternatives for SWMU 27 - Building 206 Roundhouse Sump/Area 1 Building 206
Description of
Details

Treatment Process
Description
No Action
None.
Alternatives
Institutional Controls
None.
Excavation and Disposal

Excavate soil contaminated to 16 feet bgs
around the sump and to 5 feet bgs in the
other areas based on the nature and extent of
contamination.
Transport 130 yd 3 (170 tons) of contaminated
soil and concrete to a Class I off-site disposal
facility.
Import clean soil from off-depot to backfill
the excavate areas.
Containment or
Storage
Components
None.
Impose land use restrictions for area
where elevated concentrations of VOCs,
SVOCs, and PCBs in the soil have been
detected.
None.
Groundwater
Components
Groundwater monitoring is included
in Annual Well Monitoring Program.
Per CERCLA guidance, five-year
reviews involving minimal
groundwater sampling will be
conducted.
Groundwater monitoring is included in
Annual Well Monitoring Program.
Per CERCLA guidance, five-year reviews
involving minimal groundwater sampling
will be conducted.
Groundwater monitoring is included in
Annual Well Monitoring Program.
Implementability
Risk Reduction
No action is required to implement
provided annual groundwater
monitoring program is implemented
as planned.
This alternative does not reduce the
risk of human or environmental
exposure to VOCs, SVOCs, and
PCBs.
Cooperation is required among the Army,
the U.S. EPA, San Joaquin County, and
Cal-EPA to enact the land use
restrictions.
This alternative reduces the risk of human
exposure to VOCs, SVOCs, and PCBs.
However, it does not actively reduce the
risk to environment.
It is feasible to excavate, transport, and
dispose of the contaminated soil.
This alternative is protective of human health
and the environment.
The threat of contaminant migration to
groundwater is removed immediately on
completion of the excavation.
-------
Table 7-10. (Continued)
Description of
Details

Major ARARs
and TBCs
Estimated Cost
(Present Worth)
No Action

Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993).
$ 15,000
Alternatives
Institutional Controls

Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
$ 65,000
ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
PCBs = polychlorinated biphenyls
SVOCs = semivolatile organic compounds
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
VOCs = volatile organic compounds
yd 3 = cubic yards
Excavation and Disposal

Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
Action-specific ARARs include California
and federal requirements for hazardous waste
management and California requirements for
groundwater protection.

$ 112,000
-------
Table 7-11. Remedial Alternatives for Building 30 Drum Storage Area
Description of
Details

Treatment Process
Description
No Action

None.
Alternatives
Institutional Controls
* None.
Excavation and Disposal

Excavate contaminated soil to 18 feet bgs.
Transport 2,800 yd 3 (3,600 tons) of
contaminated soil to a Class I or Class II
off-site disposal facility based on the level
of contamination.
Import clean soil from off-depot to backfill
the excavated areas.
Containment or
Storage
Components
None.
Impose land use restrictions for area
where elevated concentrations of benzyl
alcohol and phthalates in the soil have
been detected.
None.
Groundwater
Components
Groundwater monitoring is included
in Well Monitoring Program.
Per CERCLA guidance, five-year
reviews involving minimal
groundwater sampling will be
conducted.
Install a monitoring well downgradient of
the Building 30 Drum Storage Area.
Monitoring guarterly for one year for
SVOCs.
Groundwater monitoring is included in
Well Monitoring Program.
Per CERCLA guidance, five-year reviews
involving minimal groundwater sampling
will be conducted.
Groundwater monitoring is included in Well
Monitoring Program.
Implementability
Site reviews are very easy to
implement.
Cooperation is reguired among the Army
the U.S. EPA, San Joaguin County, and
Cal-EPA to enact the land use
restrictions.
It is feasible to excavate, transport, and
dispose of the contaminated soil.
Risk Reduction
This alternative does not reduce the
risk of human or environmental
exposure to benzyl alcohol and
phthalates.
This alternative reduces the risk of human
exposure to benzyl alcohol and
phthalates. However, it does not actively
reduce the risk to the environment.
This alternative is protective of human
health and the environment.
The threat of contaminant migration to
groundwater is removed immediately on
completion of the excavation.
-------
Table 7-11. (Continued)
Description of
Details

Major ARARs
and TBCs
Estimated Cost
(Present Worth)
No Action

Chemical-specific TBCs were
developed from Water Quality Goals
(CVRWQCB, 1993).
$ 10,000
Alternatives
Institutional Controls

Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
$ 87,000
ARARs = Applicable or Relevant and Appropriate Requirements
bgs = below ground surface
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
SVOCs = semivolatile organic compounds
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd 3 = cubic yards
Excavation and Disposal

* Chemical-specific TBCs were developed
from Water Quality Goals (CVRWQCB,
1993).
* Action-specific ARARs include California
and federal requirements for hazardous
waste management and California
requirements for groundwater protection.

* $ 907,000 (Class II disposal), or
$ 1,860,000 (Class I disposal)
-------
Table 7-12. Remedial Alternatives for Surface and Near-Surface Soil - Northern Depot Area
Description of
Details

Treatment
Process
Description
No Action

* None.
Institutional Controls

* None.
Alternatives
Asphalt Cover

* None.
Excavation and Disposal

k Excavate 3,000 yd 3 (4,000
tons)of soil containing
elevated levels of arsenic
and manganese.
k Transport the contaminated
soil to a Class II or Class III
off-site disposal facility
depending on the level of
contamination.
Containment or
Storage
Components
None.
Impose land use restrictions
for areas where elevated
concentrations of
contaminants in the soil have
been detected.
Install an asphalt cover
over the soils with
elevated levels of arsenic
and manganese.
None.
Groundwater
Components
Per CERCLA guidance,
five-year reviews will be
conducted.
Per CERCLA guidance, five-
year reviews will be
conducted.
Per CERCLA guidance
five-year reviews will be
conducted.
Per CERCLA guidance five-
year reviews will be
conducted.
Implementability
Site reviews are very easy to
implement.
No action is reguired to
implement provided annual
groundwater monitoring
program is implemented as
planned.
Cooperation is reguired
among the Army, the U.S.
EPA, San Joaguin County,
and Cal-EPA to enact the
land use restrictions.
It is easy to implement
this alternative.
Excavation, transportation,
and disposal of soil are
easily implementable.
-------
Description of
Details

Risk Reduction
Major ARARs
and TBCs
No Action

This alternative does not
reduce the risk of human
or environmental
exposure to contaminants.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
Estimated Cost
(Present Worth)
* $15,000
Table 7-12. (Continued)
Alternatives
Institutional Controls Asphalt Cover
This alternative reduces the
risk of human exposure to
arsenic and manganese.
However, it does not
actively reduce the risk to
the environment.
This alternative is
protective of human health
under current and future
land use conditions.
Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
$ 17,000
ARARs = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
Yd 3 = cubic yards
* An asphalt cover provides
a reliable barrier and
reduces the exposure to
soil contaminants via
dermal contact, ingestion,
and/or inhalation.
* The risk to the
environment will not be
actively reduced; however
the asphalt cap may
reduce potential transport
of contaminants to the
groundwater.

* Chemical-specific TBCs
were developed from
Water Quality Goals
(CVRWQCB, 1993).
* Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.

* $504,000
Excavation and Disposal

This alternative is protective of
human health and the
environment.
The threat of contaminant
migration to groundwater is
removed immediately on
completion of the excavation.
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs include
California and federal
requirements for hazardous waste
management and California
requirements for groundwater
protection.
$995,000 (Class II disposal), or
$769,000 (Class III disposal)
-------
Table 7-13. Remedial Alternatives for SWMUs 2 and 3
Description of
Details

Treatment Process
Description
No Action
Containment or
Storage
Components

Groundwater
Components
None.
None.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving minimal
soil and groundwater sampling
will be conducted.
Alternatives
Institutional Controls

None.
Impose land use restrictions for
areas around the lagoons.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving minimal
soil and groundwater sampling
will be conducted.
Excavation and Disposal

Excavate soil above cleanup standards identified to
protect groundwater guality.
- 10,000 yd 3 estimated to be removed.
Transport soil to a Class III off-depot disposal
facility.
Import clean soil from off-depot to backfill the
excavated areas.
Install geofabric filter and apply additional clean
backfill to protect ecological receptors.
None.
Groundwater monitoring is included in Well
Monitoring Program.
Implementability
Site reviews are very easy to
implement.
No action is reguired to
implement provided annual
groundwater monitoring
program is implemented as
planned
Cooperation is reguired among
the Army, the U.S. EPA, San
Joaguin County, and Cal-EPA
to enact the land use
restrictions.
Difficult to implement because of the large volume of
soil/sediment to be excavated.
Excavation will disrupt DDJC-Tracy operations as
the lagoons would not be available for discharge of
effluent from the nearby sewage treatment plant.
-------
Table 7-13. (Continued)
Description of
Details

Risk Reduction
No Action

This alternative does not reduce
the risk of human or
environmental exposure to
dieldrin, ODD, DDE, DDT, di-
n-butylphthalate, and bis(2-
ethylbexyl)phthalate.
Alternatives
Institutional Controls

This alternative reduces the risk
of human exposure to dieldrin,
ODD, DDE, DDT, di-n-
butylphthalate, and bis(2-
ethylhexyl)phthaiate. However,
it does not actively reduce the
risk to the environment.
Excavation and Disposal

This alternative is protective of human health and the
environment.
The threat of contamination migrating to groundwater
is removed immediately on completion of excavation.
Risks to ecological receptors are mitigated by
isolating receptors from exposure to contaminants.
Major ARARs and
TBCs
Estimated Cost
(Present Worth)
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
$15,000
Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
$65,000
ARARs = Applicable or Relevant and Appropriate Reguirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
EE/CA = Engineering Evaluation/Cost Analysis
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd 3 = cubic yards
Chemical-specific TBCs were developed from Water
Quality Goals (CVRWQCB, 1993).
Action-specific ARARs include California and federal
reguirements for hazardous waste management and
California reguirements for groundwater protection.
$2,100,000
-------
Table 7-14. Remedial Alternatives for SWMU 33
Description of
Details
No Action
Alternatives
Institutional Controls Excavation, Grouting,
Institutional Controls
Excavation
Treatment Process
Description
None.
* None.
* Excavate approximately
200 yd 3 of soil at
SB464,SB462, and
SB204
Excavate the entire IWPL and
surrounding soil where aldrin,
dieldrin, diethylphthalate, and di-n-
butylphthalate concentrations are
above the revised soil cleanup
standards.
- 6,700 yd 3 estimated to be
removed.
- Depth of excavation 15 feet bgs
and 3 feet on each side of the
pipeline along the entire IWPL.
Transport soil to a Class I off-
depot disposal facility.
Import clean soil from off-depot to
backfill the excavated areas.
Containment or
Storage
Components
None.
Impose land use restrictions
for areas where elevated
concentration of aldrin,
dieldrin, diethylphthalate,
and di-n-butylphthalate have
been detected.
Pressure grout
manholes and laterals to
eliminate discharges.
None.
Groundwater
Components
Groundwater monitoring is
included in Well
Monitoring Program.
Per CERCLA guidance,
five-year reviews
involving minimal soil and
groundwater sampling will
be conducted.
Groundwater monitoring is
included in Well Monitoring
Program.
Per CERCLA guidance, five-
year reviews involving
minimal soil and
groundwater sampling will be
conducted.
Groundwater
monitoring is included
in Well Monitoring
Program.
Groundwater monitoring is
included in Well Monitoring
Program.
-------
Table 7-14. (Continued)
Description of
Details
No Action
Alternatives
Institutional Controls Excavation, Grouting,
Institutional Controls
Excavation
Implementability
Site reviews are very easy to
implement.
Risk Reduction
Major ARARs and
TBCs
Estimated Cost
(Present Worth)
This alternative does not
reduce the risk of
environmental exposure to
aldrin, dieldrin,
diethylphthalate, and di-n-
butylphthalate.
Chemical-specific TBCs
were developed from Water
Quality Goals
(CVRWQCB, 1993).
$ 15,000
Cooperation is required
among the Army, the U.S.
EPA, San Joaguin County,
and Cal-EPA to enact the
land use restrictions.
This alternative reduces the '
risk of environmental
exposure to aldrin, dieldrin,
diethylphthalate, and di-n-
butylphthalate. However, it
does not actively reduce the
risk to the environment.
Chemical-specific TBCs
were developed from Water
Quality Goals (CVRWQCB,
1993).
$ 65,000
ARARS = Applicable or Relevant and Appropriate Requirements
Cal-EPA = California Environmental Protection Agency
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
FS = Feasibility Study
IWPL = Industrial Waste Pipeline
SWMU = Solid Waste Management Unit
TBC = to be considered
U.S. EPA = United States Environmental Protection Agency
yd 3 = cubic yards
Excavation and
grouting are
implementable.
Contaminants would be
removed or contained.
Groundwater
monitoring required to
ensure any future
impacts are addressed.
Chemical-specific
TBCs were developed
from Water Quality
Goals (CVRWQCB,
1993) .
Action-specific ARARs
include California and
federal requirements for
hazardous waste
management and
California requirements
for groundwater
protection.
$ 242,600
Difficult to implement excavation
because of utilities and building in
the area and the required
excavation depth at same location.
Excavation will disrupt DDJC-
Tracy operations.

Chemical-specific TBCs were
developed from Water Quality
Goals (CVRWQCB, 1993).
Action-specific ARARs include
California and federal
requirements for hazardous waste
management and California
requirements for groundwater
protection.
$ 4,708,000
-------
Table 7-15. No Further Action Sites
SWMU Number/Site

SWMU 5
Description

Old Industrial Lagoon
SWMU 9
Subsistence Waste Pit
SWMU 10
Medical Waste Burial Pit
SWMU 10A
SWMU 11
SWMU 12
Possible Medical Waste Burial Pit
Lime/Foot Bath Burial
Embalming Fluid Dump
Comments

VOCs, SVOCs, pesticides, petroleum hydrocarbons and metals have not been released to
the soil from disposal activities. Additionally, the Phase I WQSA showed that
concentrations of metals in site soils do not pose a possible threat to background water
guality or beneficial uses of groundwater at SWMU 5. Low concentrations of TCE are
present in groundwater downgradient of SWMU 5, but the concentrations of TCE are
consistent with concentration detected in this area of the OU 1 groundwater plume.

No evidence of any buried disposal pit has been found. Metals were detected in site
soils at concentrations that slightly exceeded background thresholds. However, the
Phase I WQSA showed that concentrations of methals in site soils do not pose a possible
threat to background water guality or beneficial uses of groundwater. Samples from
monitoring wells adjacent to SWMU 9 do not indicate any groundwater contamination
associated with the site.

Very little information is available concerning disposal activities at SWMU 9, and it is
possible that the suspected subsistence waste pit reported at this site may instead be the
disposal area identified at SWMU 8.

There has not been a release of contaminants associated with SWMU 10 to soil or
groundwater. No evidence of any subsurface disposal feature was found. No evidence
of disposal or backfilling was observed during trenching and soil boring activities. The
Phase I and Phase II WQSA showed that concentrations of metals in site soils do not
pose a possible threat to background water guality or beneficial uses of groundwater.

SWMU 10A is recommended for no further action because there is no adverse human
health risk posed by COPCs in site soils and the COPCs that have been released to site
soils (bis[2-ethylhexyl]phthalate, dieldrin, and metals) were seldom detected in soil
samples and have not been detected in groundwater above background levels.

No disposal activities have been identified at SWMU 11. Additionally, no potential
source of soil or groundwater contamination has been identified at this site.

No contaminants have been released to the soil or groundwater from the disposal
activities associated with SWMU 12. None of the soil and groundwater samples had
detectable concentrations of formaldehyde or methanol. The Phase I WQSA showed
that concentrations of metals in site soils do not pose a possible threat to background
water guality or beneficial uses of groundwater at SWMU 12. COPCs at SWMU 12
pose a cancer risk below 1x10 -6 and a hazard index of less than 1 for the construction
worker.
-------
Table 7-15. (Continued)
SWMU Number/Site

SWMU 14
Description

Lube Oil Dump
Comments

SVOCs, pesticides, petroleum hydrocarbons, and metals have been released to vadose
zone soils at SWMU 14. Groundwater has not been impacted by activities at
SWMU 14. COPCs at SWMU 14 do not pose a threat to background groundwater
guality based on the WQSA and analytical modeling. COPCs at SWMU 14 result in a
cancer risk that is below 1x10 -6 and a hazard index of less than 1 for the construction
worker.
SWMU 15
Pesticide Waste Trench
SWMU 16
Possible Hazardous Waste Storage
There has not been a release of contaminants from the former pesticide waste trench to
the soil and groundwater. During drilling activities, no subsurface evidence of a
disposal area was identified. The presence of DDT in one soil sample at a low
concentration is most likely related to a minor isolated spill or chronic use of these
chemicals in the vicinity of DDJC-Tracy, and is not interpreted as indicative of a single
identifiable contaminant source. The isolated occurrence of metals detected above
background is not indicative of an identifiable contamination source. The presence of
two metals in one sample at concentrations only slightly exceeding background may be
related to the inherent natural variability in the environment. The results of the Phase I
WQSA showed that concentrations of metals in site soils do not pose a possible threat to
background water guality or beneficial uses of groundwater. Based on the results of the
analytical modeling, the constituents detected in site soils at SWMU 15 do not pose a
threat to groundwater.

There was no evidence of a disposal area at SWMU 16 based on the results of the Phase
I RI sampling and field observations made during drilling. Metals were detected at
concentrations only slightly greater than DDJC-Tracy background levels in deep soil
samples collected at SWMU 16. Beryllium was the only metal detected in deep soil
samples at a concentration greater than two times its background threshold value. The
low levels of metals exceeding DDJC-Tracy background levels may be related to the
inherent natural variability in the environment, specifically, the presence of expansive
clays at depth beneath the site. All detected concentrations are less than the range of
background values compiled for California and the San Joaguin Valley. The low levels
of OC pesticides, dioxins, and radionuclides are limited in occurrence and are also
interpreted to represent natural conditions at DDJC-Tracy. The WQSA and analytical
modeling performed for SWMU 16 indicate that constituents detected in site soils do not
pose a threat to groundwater. COPCs at SWMU 16 most likely result in a cancer risk
that is below 1x10 -6 and a hazard index of less than 1 for the construction worker.
-------
Table 7-15. (Continued)
SWMU Number/Site

SWMU 21
Description

Battery Acid Dump
SWMU 22
Previous Hazardous Material
Storage Area
SWMU 23
Building 26 Recoup Operations
SWMU 25
Boundary Roads
SWMU 29
Used Motor Oil Disposal Pit
Comments

No contaminants have been released to the soil and groundwater from the battery shop
activities at SWMU 21. The isolated detection of beryllium in soil at a concentration
only slightly above the background reference levels is attributed to the natural
variability in the environment. Although total barium and iron were detected at concentrations
slightly above background in groundwater, these metals were not detected in site soils
above background levels. It was determined that beryllium does not have the potential
to reach the groundwater within 100 years.

There has been no release of contaminants to the soil from disposal activities associated
with SWMU 22. There are no historical data to suggest that metal-containing wastes
were stored at this site, and the low concentrations of COPCs (beryllium, chromium, and
molybdenum) detected are not distributed in any identifiable spatial pattern that would
be indicative of an anthropogenic source. Additionally, these three metals have not been
detected above background in four guarters of groundwater monitoring from
downgradient monitoring wells. Low levels of TCE and metals (copper and manganese)
have been inconsistently detected in groundwater samples collected at SWMU 22;
however, these constituents may be attributed to another source (SWMU 8), because
these compounds were not detected in soil above the background threshold at SWMU 22.

low levels of contaminants were detected in sludge from SL001. None of the
contaminants were present above concentrations that would impact human health,
ecological receptors, or groundwater guality. The sludge has been removed. Tile floor
drain connects into the industrial wastewater pipeline (IWPL) and contamination in tile
IWPL is being addressed under SWMU 20 and SWMU 33.

There has not been a release of contaminants associated with SWMU 25 dust control CD
activities to site soils. OC pesticides were not detected above background threshold
levels and petroleum hydrocarbons in the form of TPHD and TPHG were not detected.
In addition, the results of the Phase I WQSA showed that concentrations of metals in site
soils do not pose a possible threat to background water guality or beneficial uses of
groundwater at SWMU 25.

No potential source of soil and groundwater contamination was identified at SWMU 29
No other evidence indicates the presence or location of the used motor oil pit. Because
no evidence of any disposal area or contamination was found within SWMU 29, there
are no known risks associated directly with the site.
-------
Table 7-15. (Continued)
SWMU Number/Site

SWMU 30
Description

Salvage Area
SWMU 31
Wood Preservation Area
SWMU 64
Waste Oil Pit
Area 1 Building 236
Past Solvent Storage and Use
Comments

Low levels of VOCs were detected in soil-gas samples, however, no spatial pattern of
distribution was observed, and the presence of VOCs was not confirmed by soil samples
collected at SWMU 30. Isolated low concentration of PAHs and phenols were detected
in soil samples. Based on all analytical data collected at the site, no release of
contamination has occurred at SWMU 30. The results of the Phase I WQSA showed
that concentrations of metals in site soils do not pose a threat to background water
guality or beneficial uses of ground water at SWMU 30. Phenols and benzene pose a
potential threat to groundwater at SWMU 30 based on the results of the analytical
model. However these constituents are not considered a threat to groundwater because
detections of phenols are not considered representative of current site conditions and
benzene was not detected in site soil samples. COPCs at SWMU 30 do not contribute to
the human health risk calculated for the exposure unit associated with this site.

No contaminants have been released to the soil and groundwater from the wood
preservation activities at SWMU 31. The occurrence of isolated concentrations of
nickel, manganese, and barium at levels only slightly above the background reference
levels in two of four samples from one soil boring location are attributed to the natural
variability in the environment or minor spills. The results of the Phase I WQSA showed
that concentrations of metals in site soils do not pose a possible threat to background
water guality or beneficial uses of groundwater at SWMU 31.

The isolated occurrence of metals detected above background is not indicative of a
identifiable contaminant source. The presence of metals at concentrations only slightly
exceeding background may be related to the inherent variability of background
concentrations expected under naturally occurring conditions. Metals were not
consistently detected in the six guarters of groundwater samples. Based on tile results of
the Phase I RI activities, no contaminants have been released to the soil and groundwater
from the former storage tank at SWMU 64.

There has not been a release of contaminants associated with solvent storage activities at
Area I Building 236. Although methylene chloride was detected in site soils during
previous investigations, the results of the Phase I investigation did not confirm the
presence of methylene chloride contamination in the soil at Building 236. In addition,
23 soil borings were drilled during investigations near Building 236 and methylene
chloride contamination in soil was not found. There has not been a release of
contaminants to the subsurface in association with drum storage in this area.
-------
Table 7-15. (Continued)
SWMU Number/Site

Drum Storage Area
Building 15
Drum Storage Area
Building 22
Description

Drum Storage Area

Drum Storage Area
Building 23
Storage Areas
Comments

No VOC or SVOC constituents were detected in any of the soil samples collected in the
vicinity of Building 15. Because no chemicals were detected in soil samples from the
Drum Storage Area Building 15, there are no known risks associated with this site.

There has not been a release of contaminants associated with drum storage at Building
22. VOCs were not detected above the reporting limits in soil samples. Phthalate
compounds were detected sporadically, and were attributed to field or laboratory related
contamination. VOC contamination in nearby wells is believed to be related to disposal
activities at other sites. The results of the analytical modeling indicated that bis (2-
ethylhexyl) phthalate posed a threat to groundwater; however, recharge at the site was
not sufficient to mobilize di-n-butyl phthalate to groundwater. Numerical modeling
results from other sites which had similar site conditions and concentrations of
phthalates were applied to Drum Storage Area Building 22, to further evaluate
contaminant fate and transport. Based on this final assessment, bis (2-
ethylhexyl)phthalate does not pose a threat to groundwater at Drum Storage Area
Building 22.

There has not been a release of contaminants at Building 23. VOCs were not detected ill
soil samples above the reporting limit. A phthalate compound was detected in one
sample, but was attributed to laboratory-related contamination. COPCs at Building 23
result in a cancer risk that is below 1 X 10 -6 and a hazard index of less than 1 for the
construction worker.
Day Care Center
PAHs, pesticides, and lead were present in site soils as a result of nearby operations or
vehicular emissions in the vicinity of the Day Care Center. COPCs at the Day Care
Center posed a cancer risk that was greater than 1 x 10 -6 and a hazard index that was less
than 1 for children. Additional soil sampling was performed by Radian on August 31,
1995 in support of the corrective action proposed for the Day Care Center. The results
of this investigation confirmed the results of the Phase 11 investigation conducted by
Montgomery Watson in 1994. The corrective action was performed by Davy
International in September and October 1995. All soil within the lawn areas was
excavated to a depth of 1 foot. Approximately 9 inches of clean fill were placed and
compacted, and then a 3-inch soil cover was laid down. The corrective action resulted in
a reduction of the incremental cancer risks associated with the Day Care Center to zero
by removing the highest concentrations of pesticides, PAHs, and metals and eliminating
the potential for contact with contaminated surface soil.
SWMU=Solid Waste Management Unit
-------
8.0 COMPARATIVE ANALYSIS OF ALTERNATIVES

8.1 Background

8.1.1 The nine National Contingency Plan (NCP) evaluation criteria were developed to provide
decision makers with sufficient information to adequately compare the remedial alternatives for
a site and to select an appropriate remedy. These criteria fall into three groups: threshold
criteria, primary balancing criteria, and modifying criteria. The threshold criteria must be met
for an alterative to be eligible for selection. The balancing criteria are used to compare the
relative strengths and weaknesses of the different alternatives. The modifying criteria are
taken into account after public and regulatory comments are received. The NCP evaluation
criteria are summarized in Table 8-1.

8.1.2 In the Feasibility Study (FS), the remedial alternatives presented for each site, or
group of sites, were evaluated using the following seven NCP criteria:

• Overall protection of human health and the environment;

• Compliance with Applicable or Relevant and Appropriate Requirements (ARARs);

• Long-term effectiveness and permanence;

• Reduction of toxicity, mobility, and volume through treatment;

• Short-term effectiveness;

• Implementability; and

Cost.

8.1.3 Two additional NCP criteria, state acceptance and community acceptance, are addressed
based on comments received on the final RI/FS report and the Proposed Plan. State acceptance has
also been addressed by incorporating state comments on the draft ROD into the final ROD. During
the public comment period for the Proposed Plan, only one written public comment was received
(see Responsiveness Summary).

8.1.4 In this section, the remedial alternatives presented for each site (or group of sites) are
compared with each other in regard to all nine criteria to highlight their relative strengths
and weaknesses (see Table 8-2). For all sites, the No Action (or No Further Action) alternative
is evaluated to provide a baseline for comparison with the other remedial alternatives.
Five-year reviews are typically part of the No Action alternative, as contaminants will remain
on site. Institutional Controls, which include land use restrictions, restrictive covenants,
and/or fencing, are also part of each comparative evaluation.

8.1.5 Per Section 6.5, the potential future resident scenario was not considered in the
evaluation of the protection of human health because this scenario is highly unlikely.

8.2 Analysis of Remedial Alternatives for OU 1 Groundwater

8.2.1 Remedial Alternatives

8.2.1.1 This ROD modifies the selected remedy for Operable Unit (OU) 1 groundwater (WCC, 1993)
to address dieldrin. The selection of the remedy for OU 1 groundwater is discussed in Section
7.3. As noted in Section 7.3 and Table 7-1, no additional contaminants of concern other than
dieldrin were identified for OU 1 groundwater. The remedy selected in the OU 1 ROD addressed
TCE, PCE, and 1,1-DCE. The remedy included groundwater extraction, treatment, and injection. The
location and number of extraction wells has been optimized in the design process and new wells
are included in the alternatives to address dieldrin. Treatment by air stripping remains
appropriate for VOCs (no non-aqueous phase contamination has been encountered and no VOC
concentrations have been encountered that exceed the design capabilities of the air stripping
systems), but is not adequate to address pesticides in groundwater. Therefore, the selected
remedy was reevaluated and modified in the OU 1 BSD (Montgomery Watson, 1996g) to include well-
head treatment to remove pesticides. No metals or other contaminants have been identified in the
-------
RI/FS (see Table 7-1) or operation of the interim groundwater treatment system that require
treatment to meet discharge requirements. Injection remains the preferred method of discharge,
although infiltration galleries have proven more effective than injection wells. The capture of
the VOC plume was also reevaluated in the OU 1 BSD (Montgomery Watson, 1996g) and the selected
remedy was modified to include dispersion of TCE and PCE east of Banta Road. Four modifications
of the selected remedial alternative were developed for dieldrin in OU 1 groundwater. They are:

Alternative 1 - No Further Action
Alternative 2 - Institutional Controls
Alternative 3 - Groundwater Extraction and Treatment
Alternative 4 - Groundwater Extraction and Treatment Option 2

8.2.1.2 Alternative 1 provides a baseline for comparison with other alternatives. It includes
existing extraction, treatment, and injection to address VOCs in groundwater; five-year site
reviews; and long-term groundwater monitoring. Alternative 2 includes the components of
Alternative 1 as well as land use restrictions in the areas where elevated levels of dieldrin in
groundwater have been detected.

8.2.1.3 Future water rights restrictions would be written into the land property deed as
necessary if ownership of the depot were transferred to private or non-DoD entities. Alternative
3 consists of groundwater "extraction and treatment with liquid-phase granular activated carbon
(GAG in all three areas of dieldrin-contaminated groundwater (near solid waste management units
[SWMUs] 2, 3, and 8). Alternative 4 consists of groundwater extraction and treatment with GAG in
the vicinity of SWMUs 2 and 3. The contaminated ground-water near SWMU 8 would not be treated
under this alternative.

8.2.2 Overall Protection of Human Health and the Environment

The off-depot groundwater risk to residents is estimated at 1x10 -5 and the hazard index is
estimated at 0.9. These risks are associated with exposure to VOCs. Future risks to depot
workers were estimated at 2x10 -2 in the unlikely event that a drinking water well is installed
in the contaminant plume. Alternative 1 (No Further Action) does not address the human health
risks associated with dieldrin for the future depot worker. Institutional Controls provided in
Alternative 2, reduce the potential for direct contact with contaminated groundwater for both
current and future land use conditions. Alternative 3 (Groundwater Extraction and Treatment
Option 1) provides greater overall protection of human health and the environment than
Alternative 2 because groundwater is extracted and treated in all three areas of dieldrin
contamination. Alternative 4 (Groundwater Extraction and Treatment Option 2) provides more
overall protection than Alternative 2 but less than Alternative 3 because groundwater near SWMU
8 would not be treated.

8.2.3 Compliance with ARARs

There is a California Action Level of 0.05 micrograms per liter (Ig/L) for dieldrin in
groundwater, which is a chemical-specific TBC (to be considered). This TBC would be met by
Alternative 3 (Groundwater Extraction and Treatment Option 1) only. The ARARs concerning
groundwater protection (27 CCR Division 2, Subdivision 1 et seq., SWRCB Resolution No. 68-16,
and SWRCB Resolution No. 92-49) apply to all alternatives but are only be met by Alternative 3
(Groundwater Extraction and Treatment Option 1). The action-specific ARARs for hazardous waste
management (22 CCR, Division 4, Chapter 30, Section 66001 et seq., and 40 CFR 262, 263, and 264)
only apply to Alternatives 3 and 4 (Groundwater Extraction and Treatment Option 2). All
hazardous wastes generated are managed in compliance with these ARARs.

8.2.4 Long-Term Effectiveness

Alternatives 1 (No Further Action) and 2 (Institutional Controls) are not protective of human
health and the environment, as dieldrin contamination in groundwater remains. Alternative 3
(Groundwater Extraction and Treatment Option 1) provides long-term effectiveness and permanence
by using ground-water extraction and treatment to reduce dieldrin concentrations to below the
California Action Level of 0.05 Ig/L. However, treatment would take approximately 50 years to
achieve this level. Alternative 4 (Groundwater Extraction and Treatment Option 2) is similar to
Alternative 3 for the areas near SWMUs 2 and 3; however, the groundwater near SWMU 8 would not
be treated so the action level may not be met in that area.
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8.2.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Further Action) and 2 (Institutional Controls) do not actively reduce the
toxicity, mobility, or volume of dieldrin in groundwater at OU 1. Alternatives 3 (Groundwater
Extraction and Treatment Option 1) and 4 (Groundwater Extraction and Treatment Option 2) remove
dieldrin from the groundwater and treat it, thereby reducing the toxicity, mobility, and volume
of this constituent. Alternative 4 results in less reduction than Alternative 3, as the
contaminated groundwater near SWMU 8 will not be treated in Alternative 4.

8.2.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Further Action) and 2 (Institutional Controls) does not
pose any new risks to the community or any new environmental impacts. Under Alternatives 3
(Groundwater Extraction and Treatment Option 1) and 4 (Groundwater Extraction and Treatment
Option 2), remedial workers could be exposed to contaminated soils during drilling to install
extraction wells and/or during the operation of the groundwater treatment systems. However, dust
control and protective measures could be taken to minimize these risks. Remedial activities
would continue for approximately 50 years.

8.2.7 Implementability

There is no action associated with Alternative 1 (No Further Action). The land use restrictions
in Alternative 2 (Institutional Controls) are easily implementable. Alternatives 3 (Groundwater
Extraction and Treatment Option 1) and 4 (Groundwater Extraction and Treatment Option 2) are
also readily implementable. Conventional drilling eguipment can be used to install extraction
wells because the wells would be less than 50 feet deep. Few difficulties are expected during
construction and operation of the groundwater extraction and treatment systems. GAG treatment of
groundwater that contains pesticides/VOCs containing groundwater is well understood and has been
implemented at other sites.

8.2.8 Cost

The estimated present worth for Alternative 1 (No Further Action, $9,561,000), Alternative 2
(Institutional Controls, $9,611,000), and Alternative 3 (Groundwater Extraction and Treatment
Option 1, $12,040,000) increases successively due to the subseguent addition of component
technologies. The present worth of Alternative 4 (Groundwater Extraction and Treatment Option 2,
$10,909,000) is lower than for Alternative 3 because less dieldrin-contaminated groundwater is
remediated in Alternative 4.

8.2.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Further Action), 2 (Institutional
Controls) or 4 (Groundwater Extraction and Treatment Option 2) because of the potential health
threats associated with dieldrin to potential future residents of the annex. Alternative 3
(Groundwater Extraction and Treatment Option 1) is protective of human health and the
environment because pesticides are removed from the groundwater and the treated groundwater is
returned to the aguifer for future use. Therefore, state and community acceptance of Alternative
3 is anticipated. One written public comment addressing the capacity of the reinjection wells
and the cost of the groundwater treatment was received (see Responsiveness Summary).

8.3 Analysis of Remedial Alternatives for the Group A Sites

8.3.1 Remedial Alternatives

8.3.1.1 The Group A sites (SWMU I/Area 2, Area 1 Building 237, and Area 3) are characterized by
tetrachloroethene (PCE) and trichloroethene (TCE) contamination in soil. The remedial
alternatives developed for the Group A sites are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Soil Vapor Extraction
Alternative 4 - Excavation and Disposal
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8.3.1.2 Alternative 1 includes five-year site reviews and long-term monitoring. Alternative 2
includes the components of Alternative 1, plus land use restrictions around areas where
elevated concentrations of volatile organic compounds (VOCs) have been detected at the Group A
sites. Restrictive land use covenants can be written into the property deed if ownership of the
installation were transferred to private or non-federal agencies in the future. Alternative 3
treats VOC-contaminated soil in situ by installing a soil vapor extraction (SVE) system in the
area of highest contamination at each Group A site. Alternative 4 involves excavating
approximately 63,800 cubic yards of VOC contaminated soil at the Group A sites and disposing of
the soil off site.

8.3.2 Overall Protection of Human Health and the Environment

If polycyclic aromatic hydrocarbons are substantially more carcinogenic via dermal than via oral
exposure, the cancer risk for the current depot worker is estimated at 1x10 -5, the cancer risk
for the future construction worker is estimated at 1x10 -6, and the hazard index is 0.07.
However, as noted in Tables 6-4 and 6-5, the actual risk is likely to be one category lower due
to bias in the risk estimate (see Paragraph 6.5.10 for discussion). Therefore, all alternatives
are considered protective of human health. Alternative 2 reduces the potential for direct
contact with contaminated soils and is therefore protective of the current depot worker.
Neither Alternative 1 (No Action) nor Alternative 2 (Institutional Controls) addresses the
migration of VOCs to groundwater. Alternatives 3 (SVE) and 4 (Excavation) remove the VOC
contamination and eliminate the potential threat to groundwater and are therefore protective of
human health and the environment.

8.3.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for PCE and TCE in soil at the Group A sites. Since
Alternatives 1 (No Action) and 2 (Institutional Controls) do not involve any treatment or
removal actions, they do not comply with these chemical-specific TBCs. Alternatives 3 (SVE) and
4 (Excavation) meet these TBCs through treatment (Alternative 3) or by excavating and disposing
of the contaminated soils off site (Alternative 4). The action-specific ARARs for hazardous
waste management (22 CCR, Division 4, Chapter 30, Section 66001 et seg., and 40 CFR 262, 263,
and 264) that apply to Alternatives 3 and 4 are met, as are the air emission controls (best
available technology) that apply to Alternative 3.

8.3.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of VOCs
in soil to groundwater because VOC-contaminated soils remain on site. Alternative 3 (SVE) and
Alternative 4 (Excavation) provide long-term effectiveness and permanence by reducing VOC
concentrations in soil or removing VOC-contaminated soils from the site, respectively.

8.3.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of TCE or PCE in soils at the Group A sites through
treatment. The toxicity, mobility, and volume of these contaminants in soil is reduced through
treatment in Alternative 3(SVE).

8.3.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Remedial workers could be
exposed to contaminated soils during drilling (Alternative 3 - SVE) or excavation and disposal
(Alternative 4). However, dust control and protective measures could be taken to minimize
these risks. The heavy truck traffic associated with transporting excavated soils off site in
Alternative 4 (Excavation) may impact the surrounding community. Following construction of the
SVE system in Alternative 3, remedial workers could be exposed to extracted vapors during
operation and maintenance. Remediation under Alternative 3 is estimated to take approximately
six months. Alternative 4 would take approximately three months to implement.

8.3.7 Implementability
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There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are easily implementable. Alternative 3 (SVE) is also
readily implementable. Conventional drilling equipment can be used to install SVE wells, as the
wells are relatively shallow (i.e., less than 20 feet deep). SVE is a commercially available
technology, and SVE systems are generally easy to install and maintain. For Alternative 4
(Excavation), conventional equipment can be used to excavate the soil. However, due to the
depths of soil contamination, shoring is required during excavation.

8.3.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000 for each Group A site.
Alternative 2 (Institutional Controls) is expected to cost $65,000 per site. These costs assume
that five-year site reviews will be discontinued after ten years because soil contamination is
expected to be reduced below levels of concern within that time frame. The costs to implement
SVE at the Group A sites in Alternative 3 are estimated at $266,000 for SWMU I/Area 2, $140,000
for Area 1 Building 237, and $242,000 for Area 3. The costs of Alternative 4 (Excavation)
include excavation and off-site disposal at a Class I facility. These costs are estimated at
$19,785,000 for SWMU I/Area 2, $5,607,000 for Area 1 Building 237, and $16,662,000 for Area 3.

8.3.9 State and Community Acceptance

The state is not expected to accept Alternative 1 (No Action) or Alternative 2 (Institutional
Controls) because they are not protective of the environment. Alternatives 3 (SVE) and 4
(Excavation) are protective of human health and the environment because contaminants are
permanently removed from the soils at the Group A sites. Therefore, state and community
acceptance is anticipated. One written public comment expressing concern over the potential
exposure and high cost of excavation was received (see Responsiveness Summary).

8.4 Analysis of Remedial Alternatives for SWMU 4— Storm Drain Lagoon

8.4.1 Remedial Alternatives

8.4.1.1 SWMU 4 is a storm drain lagoon. Lagoon sediments have shown elevated concentrations of
pesticides and metals that pose a possible threat to ecological receptors. In addition, surface
water concentrations of dieldrin and DDT exceed federal ambient water quality criteria (AWQC)
for protection of aquatic wildlife. The remedial alternatives developed for SWMU 4 are:

Alternative 1 - No Action
Alternative 2 - Upstream Source Control
Alternative 3 - Excavation and Disposal of Sediments, Evaluate Discharge Concentrations

8.4.1.2 Five-year reviews and long-term sediment, surface water, and groundwater monitoring
are included in Alternative 1. Alternative 2 consists of periodically (every five years)
removing sediment from storm water conduits upstream of the lagoon, and dewatering and
transporting those sediments to an off-site disposal facility. Alternative 3 consists of
excavation of the sediment in the storm drain lagoon that is contaminated with metals and
pesticides. The excavated sediments would be dewatered and transported to an off-site disposal
facility.

8.4.2 Overall Protection of Human Health and the Environment

The cancer risk estimated for the current depot worker is 1x10 -6 ; however, as noted in Table
6-4, the actual risk is likely to be one category lower due to bias in the risk estimate. The
hazard index was estimated at 0.01. Therefore, all alternatives are considered protective of
human health. The threat to ecological receptors is not addressed by Alternative 1 (No Action).
By removing contaminated sediments upstream, Alternative 2 (Source Control) reduces the
potential future threats to ecological receptors. Alternative 3 (Excavation) would remove the
soil with contaminants. It is uncertain if the concentrations of dieldrin and DDT in the storm
water discharged to the canal exceed the AWQC. Alternative 3 requires monitoring of the storm
water discharge to determine if the AWQC are complied with.

8.4.3 Compliance with ARARs
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Federal ambient water quality criteria for the protection of aquatic wildlife are considered
chemical-specific ARARs for surface water discharqed to the local irriqation canal. The
action-specific ARARs for hazardous waste manaqement (22 CCR, Division 4, Chapter 30, Section
66001 et seq., and 40 CFR 262, 263, and 264) that apply to Alternatives 2 and 3 are met. For all
alternatives, the California Fish and Game Code is a location-specific ARAR.

8.4.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Source Control) do not prevent the exposure of ecoloqical
receptors to constituents in the sediment. Alternative 3 relies on excavation to address the
threat to ecoloqical receptors. With proper storm water pollution prevention measures, the
lonq-term effectiveness is considered hiqh. The lonq-term effectiveness will be assessed in the
5-year review to ensure there is no continuinq source. Sediment excavation could have a much
larqer neqative impact on the laqoon ecosystem and aquatic biota than the ecoloqical risks posed
by the contaminants detected in the sediment.

8.4.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action) and 2 (Source Control) do not actively reduce the toxicity, mobility,
and volume of SVOCs and pesticides in laqoon sediments throuqh treatment. However, Alternative 2
reduces further deposition of contaminated sediments into the laqoon. Alternative 3 (Excavation)
removes contaminated sediment from the storm drain laqoon, but does not provide treatment.

8.4.6 Short-Term Effectiveness

The implementation of Alternative 1 (No Action) does not pose any new risks to the community or
any new environmental impacts. Under Alternatives 2 (Source Control) and 3 (Excavation),
remedial workers could be exposed to contaminated sediments durinq excavation. However,
protective measures could be taken to minimize these risks. Sediment excavation activities in
Alternative 3 could potentially impact the sensitive nestinq and breedinq habitats of various
waterfowl by disturbinq the shoreline and shallow water.

8.4.7 Implementability

There is no action associated with Alternative 1 (No Action). With Alternative 2 (Source
Control), conventional soil excavation equipment can be used to remove contaminated sediment
from the open storm drain ditches. Alternative 3 (Limited Excavation) may be difficult to
implement qiven the previous problems with draininq the laqoon (due to cloqqinq) and a hiqh
water table.

8.4.8 Cost

The present worth of Alternative 1 (No Action) is $25,000. This cost assumes that five-year site
reviews will be conducted for a 30-year period. The present worth cost for Alternative 2 (Source
Control), which includes sediment excavation, dewaterinq, and off-site disposal, is $1,158,000.
The present worth for Alternative 3 (Excavation), which includes excavation of laqoon sediment
with dewaterinq and off-site disposal, is $552,600.

8.4.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) or 2 (Source Control) because
they are not protective of ecoloqical receptors. Alternative 3 (Limited Excavation) is
protective of both human health and the environment because most of the contaminants in the
sediment will be permanently removed from the laqoon. The remainder of the contaminants will be
covered with clean fill to isolate them from ecoloqical receptors. Therefore, state and
community acceptance of Alternative 3 is anticipated. One written public comment expressinq
concern over the potential exposure and hiqh cost of excavation was received (see Responsiveness
Summary).

8.5 Analysis of Remedial Alternatives for ST/JMU 6-- Building 28 Sump

8.5.1 Remedial Alternatives
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8.5.1.1 SWMU 6 is the former location of a 250-gallon concrete sump that was removed in 1988.
Pesticide and herbicide contamination in soil has been detected immediately adjacent to the sump
excavation at depths from below the sump excavation to directly above the water table. The
pesticides dicamba, dieldrin, heptachlor, 2,4,5-T, and lindane detected at the site could
potentially pose a threat to background groundwater quality. The remedial alternatives developed
for SWMU 6 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - In Situ Stabilization
Alternative 4 - Excavation and Disposal

8.5.1.2 Alternative 1 includes five-year site reviews and long-term monitoring. Alternative 2
includes the components of Alternative 1 plus land use restrictions around areas where elevated
levels of contaminants have been detected at the site. Alternative 3 consists of using in situ
stabilization to physically and chemically immobilize the pesticides detected in the soil.
Alternative 4 consists of excavating approximately 60 cubic yards of pesticide-contaminated soil
and disposing of it off site at either a Class I or a Class II disposal facility, depending on
the level of contamination.

8.5.2 Overall Protection of Human Health and the Environment

The cancer risk to future construction workers at SWMU 6 was estimated at 8.8x10 -8 and the
hazard index was 2.7x10 -2. All alternatives are protective of human health. In Alternatives 1
(No Action) and 2 (Institutional Controls), pesticides in the soil could potentially pose a
threat to groundwater. With Alternative 3 (Stabilization), pesticides are immobilized in situ,
significantly reducing their threat to groundwater. In Alternative 4 (Excavation), the threat to
groundwater is eliminated because pesticide-contaminated soils are permanently removed from the
site.

8.5.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for the pesticides detected in the soil at SWMU 6.
Alternatives 1 (No Action) and 2 (Institutional Controls) do not comply with these
chemical-specific TBCs, as pesticide-contaminated soil remains at the site. Alternatives 3
(Stabilization) and 4 (Excavation) meet these TBCs by either immobilizing or permanently
removing the contaminated soil. The action-specific ARARs for hazardous waste management (22
CCR, Division 4, Chapter 30, Section 66001 et seg., and 40 CFR 262, 263, and 264) that apply to
Alternatives 3 and 4 are also will met.

8.5.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of
constituents in soil to groundwater because the pesticides remain on site. Alternative 3
(Stabilization) significantly reduces the threat to groundwater because the pesticides are
immobilized through the stabilization process. Alternative 4 (Excavation) provides long-term
effectiveness and permanence through excavation and off-site disposal of pesticide-contaminated
soils.

8.5.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of contaminants at the site through treatment.
Alternative 3 (Stabilization) reduces the mobility of contaminants in the soil through
stabilization, but does not reduce their toxicity or volume.

8.5.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternatives 3
(Stabilization) and 4 (Excavation), remedial workers could be exposed to contaminated soil
during stabilization and excavation. Also, under Alternative 3 remedial workers could be exposed
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to the chemicals used for stabilization. Dust control and protective measures could be taken to
minimize these risks. Alternative 4 (Excavation) can be completed in approximately three months.

8.5.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. The in situ stabilization in
Alternative 3 is a technically feasible, commercially available technology. The materials
required for implementing this alternative are readily available. In Alternative 4, conventional
earthmoving equipment can be used to excavate the soil. Transporting soils for off-site disposal
is also easily implementable.

8.5.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume that five-year site reviews will be discontinued after ten years because contamination is
expected to be reduced below levels of concern within that time frame. The present worth cost
for the in situ stabilization process in Alternative 3 is $169,000. In Alternative 4, excavation
with off-site disposal to a Class II landfill has a present worth cost of $45,000. If disposal
at a Class I facility is required, the cost would increase to $65,000.

8.5.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) or 2 (Institutional Controls)
because they are not protective of the groundwater beneath the site. Alternatives 3
(Stabilization) and 4 (Excavation) are protective of both human health and the environment
because contaminants in soil will be permanently immobilized or removed from the site.
Therefore, state and community acceptance of Alternatives 3 and 4 is anticipated. One written
public comment was received that expressed concern over the potential exposure and high cost of
excavation. It also expressed interest in the encapsulation (stabilization) process (see
Responsiveness Summary).

8.6 Analysis of Remedial Alternatives for ST/JMU 7--Burn Pit No. 1

8.6.1 Remedial Alternatives

8.6.1.1 SWMU 7 (Burn Pit No. 1) comprises seven former burn pits that were used between 1942
and 1954 for disposing of medical supplies containing mercury and phosphate compounds,
narcotics, general Pharmaceuticals, radiological supplies, and electron tubes. Remedial Investi-
gation (RI) results indicate that pesticides in soils at three of the pits (Pits C, D, and F)
may pose a threat to groundwater quality. The remedial alternatives developed for SWMU 7 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - In Situ Stabilization with Institutional Controls
Alternative 4 - Excavation and Disposal with Institutional Controls

8.6.1.2 Alternative 1 consists of five-year site reviews and long-term groundwater monitoring.
Alternative 2 includes these components and adds land use restrictions around the disposal pits
where elevated levels of contaminants have been detected. If ownership of the depot is
transferred to private or non-federal entities, restrictive covenants could be written into the
property deed. Alternative 3 consists of using in situ stabilization to physically and
chemically immobilize the contaminants detected in the soil at Pits C, D, and F. Alternative 4
involves excavating approximately 3,600 cubic yards of contaminated soils from these three pits
and disposing of them off site at a Class I disposal facility. Both Alternatives 3
(Stabilization) and 4 (Excavation) also include institutional controls because portions of the
pits are covered by buildings.

8.6.2 Overall Protection of Human Health and the Environment

The cancer risk to future construction workers at SWMU 7 was estimated at 4.2x10 -7 and the
hazard index was estimated at 9.2. However, the hazard index was elevated because of manganese
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concentrations that are typical of those throughout the western United States. All alternatives
are protective of human health under the scenarios considered. However, Alternatives 1 (No
Action) and 2 (Institutional Controls) do not mitigate the threat to groundwater posed by
contaminants in the soil. Alternative 3 (Stabilization) immobilizes pesticides in situ,
significantly reducing the potential threat to groundwater. Alternative 4 (Excavation) provides
the greatest protection to human health and the environment because contaminated soils are
permanently removed from the site.

8.6.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for the constituents of concern in the soil at SWMU 7.
The potential threats to background water guality have not yet been confirmed through
monitoring. Alternative 1 (No Action) does not comply with the chemical-specific TBCs. If
long-term monitoring in Alternative 2 (Institutional Controls) identifies a concern, the
implementation of Alternative 2 would be modified to ensure the protection of the groundwater.
Therefore, Alternative 2 is considered to comply with these chemical-specific TBCs. Alternatives
3 (Stabilization) and 4 (Excavation) also meet these TBCs by either immobilizing or permanently
removing the contaminated soil. The action-specific ARARs for hazardous waste management (22
CCR, Division 4, Chapter 30, Section 66001 et seg., and 40 CFR 262, 263, and 264) that apply to
Alternatives 3 and 4 are also met.

8.6.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the potential migration
of soil constituents to groundwater because the pesticides remain on site. Alternative 2 does
include long-term monitoring to evaluate the long term effectiveness. Alternative 3 (Stabiliza-
tion) significantly reduces the threat to groundwater because the pesticides are immobilized
through the stabilization process. Alternative 4 (Excavation) provides long-term effectiveness
and permanence through excavation and off-site disposal of pesticide-contaminated soils.

8.6.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of contaminants at the site through treatment.
Alternative 3 (Stabilization) reduces the mobility of pesticides and other contaminants in the
soil through stabilization, but does not reduce their toxicity or volume.

8.6.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternatives 3
(Stabilization) and 4 (Excavation), remedial workers could be exposed to contaminated soil
during stabilization and excavation. Under Alternative 3, remedial workers could be exposed to
stabilization chemicals. However, dust control and protective measures could be taken to
minimize these risks. Alternative 4 can be completed in approximately three months.

8.6.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. The in situ stabilization in
Alternative 3 (Stabilization) is a technically feasible, commercially available technology.
The materials reguired for implementing this alternative are readily available. In Alternative 4
(Excavation), conventional earthmoving eguipment can be used to excavate the soil.
Transporting soils for off-site disposal is also easily implementable.

8.6.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $208,000. These costs
assume two five-year site reviews. The present worth cost for the in situ stabilization process
and institutional controls in Alternative 3 (Stabilization) is $822,000. The present worth cost
for Alternative 4 (Excavation), which combines excavation with off-site disposal and
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institutional controls, is $2,605,000.

8.6.9 State and Community Acceptance

The state is not expected to accept Alternative 1 (No Action) because it may not be protective
of future land use conditions or groundwater beneath the site. The land use restrictions in
Alternative 2 (Institutional Controls) and the long-term groundwater monitoring ensure
protection of groundwater. (There is a potential threat to groundwater guality that has not been
confirmed through historical monitoring.) Therefore Alternative 2 is expected to be acceptable
to both the state and the public. Alternatives 3 (Stabilization) and 4 (Excavation) are
protective of both human health and the environment because contaminants in the soil are
permanently immobilized or removed from the site. Therefore, state and community acceptance is
anticipated for Alternatives 3 and 4 as well. One written public comment was received that
expressed concern over the potential exposure and high cost of excavation. It also expressed
interest in the encapsulation (stabilization) process (see Responsiveness Summary).

8.7 Analysis of Remedial Alternatives for ST/JMU 8--Burn Pit No. 2

8.7.1 Remedial Alternatives

8.7.1.1 SWMU 8 is a single large burn pit. Polynuclear aromatic hydrocarbons (PAHs),
phthalates, pesticides, dioxins/furans, metals, and petroleum hydrocarbons were detected in
soils in the pit. The site contaminants potentially pose a threat to groundwater. The remedial
alternatives developed for SWMU 8 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Bioventing
Alternative 4 - Excavation and Disposal

8.7.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the disposal pits. If ownership of the depot is transferred to private or non-federal
agencies in the future, restrictive covenants could be written into the property deed.
Alternative 3 consists of injecting air into the subsurface to enhance natural aerobic
degradation processes in the vadose zone. Three air injection well clusters are needed, and a
pad-mounted blower would be installed adjacent to the injection wells. Alternative 4 involves
excavating contaminated soil (approximately 2,600 cubic yards) and debris (approximately 1,900
cubic yards) and transporting them off site to Class I and Class III disposal facilities,
respectively.

8.7.2 Overall Protection of Human Health and the Environment

All alternatives are protective of human health under the current depot worker exposure
scenario. Alternative 1 (No Action) is not protective of the future construction worker. The
estimated cancer risk associated with organochlorine pesticides is between 1x10 -4 and 1x10 -6 ,
and the hazard index is greater than 1 for this scenario. The land use restrictions in
Alternative 2 (Institutional Controls) provide some protection for the future construction
worker. However, neither Alternative 1 nor Alternative 2 mitigate the threat to groundwater
posed by contaminants in the soil. Alternative 3 (Bioventing) involves the biodegrading
petroleum hydrocarbons and some SVOCs in situ; however, pesticides, PCBs, and dioxin/furans are
not readily biodegraded and the potential threat to groundwater from pesticides, PCBs, and
dioxin/furans would remain. Alternative 4 (Excavation) provides the greatest protection to human
health and the environment because contaminated soils are permanently removed from the site.

8.7.3 Compliance with ARARs

8.7.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of
constituents in the soil to groundwater because contaminants remain on site. Alternative 3
(Bioventing) eliminates the threat to groundwater from petroleum hydrocarbons and SVOCs, but it
does not reduce the potential threat to groundwater from pesticides because these constituents
are not amenable to biodegradation. Alternative 4 (Excavation) provides long-term effectiveness
and permanence through the excavation and off-site disposal of pesticide-contaminated soils.

8.7.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls), and 4 (Excavation) do not actively
reduce the toxicity, mobility, or volume of contaminants at the site through treatment.
Alternative 3 (Bioventing) reduces the toxicity, mobility, and volume of petroleum hydrocarbons
and SVOCs at SWMU 8, but does not reduce the toxicity, mobility, or volume of pesticides, PCBs,
or dioxin/furans at the site.

8.7.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternatives 3
(Bioventing) and 4 (Excavation), remedial workers could be exposed to contaminated soil during
drilling and excavation. However, various dust control and protective measures could be taken to
minimize these risks. Following the installation of the bioventing system, it will take
approximately two years to biodegrade petroleum hydrocarbons in the soil. Alternative 4
(Excavation) can be completed in approximately three months or less.

8.7.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. With Alternative 3
(Bioventing), conventional drilling equipment can be used to install bioventing wells because
they will are relatively shallow; however, installing the wells may be difficult because of the
construction debris buried in the former burn pit. The system might also short-circuit because
of the debris. In Alternative 4 (Excavation), conventional earthmoving equipment can be used to
excavate the soil. Transporting soils for off-site disposal is also easily implementable.

8.7.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume two five-year site reviews. The present worth cost of the bioventing system in
Alternative 3 is $246,000. The cost for Alternative 4, which includes excavation and off-site
disposal, is $2,823,000.

8.7.9 State and Community Acceptance

The state is not expected to accept Alternative 1 (No Action) because it is not protective of
human health for the future construction worker or protective of groundwater beneath the site.
State acceptance is also not expected with Alternatives 2 (Institutional Controls) and 3
(Bioventing) because of the potential future threat to groundwater. Alternative 4 (Excavation)
is protective of both human health and the environment because contaminants in the soil are
permanently removed from the site. Therefore, state and community acceptance is anticipated for
this alternative. One written public comment was received that expressed concern over the
potential exposure and high cost of excavation (see Responsiveness Summary).

8.8 Analysis of Remedial Alternatives for SWMU 20-- Aboveground Solvent Tank/Building 26
Recoup Operations and Area 1 Building 10
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8.8.1 Remedial Alternatives

8.8.1.1 SWMU 20 consists of two sumps associated with an aboveground solvent tank located at
Building 10 and contaminated soils at Area 1 Building 10. Modeling results indicate that TCE,
SVOCs, pesticides, and herbicides detected in the soil at these sites pose a potential threat to
beneficial uses of groundwater. The remedial alternatives developed for SWMU 20 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - SVE with Excavation and Disposal and Natural Attenuation
Alternative 4 - Excavation and Disposal and Natural Attenuation

8.8.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the areas of contamination. If ownership of the depot is transferred to private or
non-federal agencies in the future, restrictive covenants could be written into the property
deed. Alternative 3 involves excavating the SWMU 20 sumps and the floor drain at Building 26.
The excavated material would be transported and disposed of off site. SVE would be performed in
Area 1 Building 10 to reduce the TCE concentrations to below the cleanup level. Soil
contaminated with 2,4-dinitrophenol and 2,4,6-trichlorophenol at 15 feet bgs would be allowed to
attenuate naturally. Alternative 4 is the same as Alternative 3, except that the
TCE-contaminated soils are excavated and transported off site rather than treated by SVE.

8.8.2 Overall Protection of Human Health and the Environment

The risk to depot workers at SWMU 20 was estimated at 2.2x10 -7 and the hazard index at 0.3. All
alternatives are protective of human health. However, Alternatives 1 (No Action) and 2
(Institutional Controls) do not mitigate the threat to groundwater posed by VOCs and phthalates
in the soils. Alternatives 3 (SVE/Excavation/Natural Attenuation) and 4 (Excavation/Natural
Attenuation) permanently remove contaminated soils and sludges associated with the sumps and the
floor drain, thereby eliminating the potential threat to groundwater at those locations. TCE at
Area 1 Building 10 is removed through SVE in Alternative 3 and excavation and off-site disposal
in Alternative 4. The removal TCE eliminates the threat to groundwater at that location.

8.8.3 Compliance with ARARs

8.8.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of
constituents in the soil to groundwater because the contaminants remain on site. Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4 (Excavation/Natural Attenuation) provide long-term
effectiveness and permanence because contaminated soils are excavated and disposed of off site
or treated via SVE.

8.8.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls) and 4 (Excavation/Natural Attenuation) do
not actively reduce the toxicity, mobility, or volume of contaminants at the site through
treatment. Alternative 3 (SVE/Excavation/Natural Attenuation) reduces the toxicity, mobility,
and volume of TCE at Area 1 Building 10 through SVE.

8.8.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
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any new risks to the community or any new environmental impacts. Under Alternatives 3
(SVE/Excavation/Natural Attenuation) and 4 (Excavation/Natural Attenuation), remedial workers
could be exposed to contaminated soil during drilling and excavation activities. However, dust
control and protective measures could be taken to minimize these risks. Alternatives 3 and 4
could each be completed in less than three months.

8.8.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. With Alternative 3 (SVE/
Excavation/Natural Attenuation), conventional eguipment can be used to install and maintain the
SVE system. Conventional earthmoving eguipment can be used to excavate and transport soils in
Alternatives 3 and 4 (Excavation/Natural Attenuation).

8.8.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume two five-year site reviews. The present worth cost for the SVE system and the excavation
and off-site disposal in Alternative 3 (SVE/Excavation/Natural Attenuation) is $293,000. The
present worth cost for excavation and off-site disposal in Alternative 4 (Excavation/Natural
Attenuation) is $355,000.

8.8.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) or 2 (Institutional Controls)
because they are not protective of groundwater beneath the site. Alternatives 3 (SVE/Excavation/
Natural Attenuation) and 4 (Excavation/Natural Attenuation) are protective of both human health
and the environment because contaminants in the soil are permanently removed from the site
either by treatment or by excavation. Therefore, state and community acceptance is anticipated
for these alternatives. One written public comment was received that expressed concern over the
potential exposure and high cost of excavation (see Responsiveness Summary).

8. 9 Analysis of Remedial Alternatives for SWMU 24-Petroleum Waste Oil Tank

8.9.1 Remedial Alternatives

8.9.1.1 SWMU 24 was a 500-gallon underground storage tank (UST) that was used to store
petroleum wastes derived from materials testing in Building 247. During UST removal, visibly
contaminated soil from the excavation was disposed of off site. The remaining soil contamination
is limited to soils within and immediately surrounding the tank excavation. The VOCs, SVOCs,
petroleum hydrocarbons, PCBs, and pesticides remaining in the soil at the site may pose a threat
to background groundwater guality. The remedial alternatives developed for SWMU 24 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Bioventing
Alternative 4 - Excavation and Disposal
Alternative 5 - Excavation and On-Site Bioremediation

8.9.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the area of contamination. If ownership of the depot is transferred to private or non-
federal agencies in the future, restrictive covenants could be written into the property
deed. Alternative 3 consists of injecting air into the subsurface to enhance natural aerobic
degradation processes in the vadose zone. Due to the limited aerial extent of the VOC
contamination, only one air injection well is needed. Alternative 4 involves excavating
approximately 240 cubic yards of contaminated soil and transporting it off site to a Class I
disposal facility. Alternative 5 involves excavating the contaminated soil and treating it
aboveground using on-site bioremediation. This treatment involves spreading and tilling soil on
a treatment pad to enhance the natural biodegradation of hydrocarbon compounds.

8.9.2 Overall Protection of Human Health and the Environment
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The cancer risk estimated far the future construction worker at this site is 1x10 -6 , and the
hazard index was estimated, to be 10. The risk is associated with exposure to PAHs and manganese
(see Section 6.5). Remediation of these compounds was not deemed necessary. The risk associated
with exposure to VOCs in indoor air was estimated at 0.7. Alternatives 1 (No Action) and 2
(Institutional Controls) do not mitigate the threat to groundwater posed by the contaminants in
the soil. Alternatives 3 (Bioventing) and 5 (Excavation/Bioremediation) involve biodegrading
VOCs, SVOCs, and petroleum hydrocarbons in situ but pesticides and PCBs do not biodegrade.
However, the potential threat to groundwater from these pesticides and PCBs is considered low
relative to the threat posed by other contaminants of concern. Alternative 4
(Excavation/Disposal) provides the greatest protection to human health and the environment
because contaminated soils are permanently removed from the site.

8.9.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for the constituents of concern in the soil at SWMU 24.
Alternatives 1 (No Action) and 2 (Institutional Controls) do not comply with these
chemical-specific TBCs, as the constituents of concern remain in the soil at the site.
Alternatives 3 (Bioventing), 4 (Excavation/Disposal), and 5 (Excavation/Bioremediation) meet
these TBCs by treating the contaminated soil through bioventing (Alternative 3), bioremediation
(Alternative 5), or excavation and off-site disposal (Alternative 4). Although bioventing and
bioremediation do not address the PCB or pesticide soil contamination at SWMU 24, the
groundwater threat posed by these compounds is considered low. Pesticide detections were
infreguent and none of the pesticides or PCBs in soil have been detected in groundwater near the
site. PCBs were only detected in one boring (SB-192) and the concentrations of both PCBs and
pesticides decreased with increasing depth. Removing these compounds from underneath existing
buildings was not considered justified at this time. The action-specific ARARs for hazardous
waste management (22 CCR, Division 4, Chapter 30, Section 66001 et seg., and 40 CFR 262, 263,
and 264) that apply to Alternatives 3 through 5 are also met.

8.9.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of soil
constituents to groundwater because contaminants remain on site. Alternatives 3 (Bioventing) and
5 (Excavation/Bioremediation) eliminate the threat to groundwater from VOCs, SVOCs, and
petroleum hydrocarbons; however, they do not reduce the potential threat to groundwater from
pesticides and PCBs because these constituents are not amenable to biodegradation. Alternative 4
(Excavation/Disposal) provides long-term effectiveness and permanence through excavation and
off-site disposal of contaminated soils.

8.9.5 Reduction of Toxicity, Mobility, and Volume through Treatment

Alternatives 1 (No Action), 2 (Institutional Controls), and 4 (Excavation/Disposal) do not
actively reduce the toxicity, mobility, or volume of contaminants at the site through treatment.
Alternatives 3 (Bioventing) and 5 (Excavation/Bioremediation) reduce the toxicity, mobility, and
volume of VOCs, SVOCs, and petroleum hydrocarbons at SWMU 24, but do not treat the PCBs and
pesticides at the site.

8.9.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternatives 3
(Bioventing), 4 (Excavation/Disposal), and 5 (Excavation/Bioremediation), remedial workers
could be exposed to contaminated soil during drilling, excavation, and operation of the
aboveground bioremediation cell. However, dust control and protective measures could be taken to
minimize these risks. Following the construction of the bioventing system in Alternative 3, it
will take approximately two years to biodegrade the constituents of concern in the soil.
Alternative 4 (Excavation) can be completed in approximately three months.

8.9.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. With Alternative 3
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(Bioventing), conventional drilling eguipment can be used to install the bioventing well, as it
is relatively shallow. Alternatives 4 (Excavation/Disposal) and 5 (Excavation/Bioremediation)
may be difficult to implement because they reguire the excavation of soil beneath Building 247.
In addition, some shoring is reguired because soils need to be excavated to a depth of 17 feet
bgs. The transportation and off-site disposal of soil in Alternative 4 (Excavation/Disposal) are
readily implementable. The chemicals and eguipment needed for biotreatment in Alternative 5 are
also readily available. The treatment pad could be easily constructed on land available in the
southern portion of the base.

8.9.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume two five-year site reviews. The present worth cost for the bioventing system in
Alternative 3 (Bioremediation) is $166,000. The present worth cost for Alternative 4
(Excavation/Disposal), which includes excavation and off-site disposal, is $214,000. The present
worth cost of Alternative 5 (Excavation/Bioremediation), excavation with on-site bioremediation,
is estimated at $263,000.

8.9.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) or 2 (Institutional Controls)
because they do not mitigate the threat to the groundwater beneath the site. Alternatives 3
(Bioremediation), 4 (Excavation/Disposal), and 5 (Excavation/Bioremediation) reduce the threat
to groundwater from VOCs, SVOCs, and petroleum hydrocarbons and are protective of human health.
Therefore, state and community acceptance is anticipated for these alternatives. One written
public comment was received that expressed concern over the potential exposure and high cost of
excavation (see Responsiveness Summary).

8.10 Remedial Alternatives for SWMU 27-Building 206 Roundhouse Sump/Area 1 Building 206

8.10.1 Remedial Alternatives

8.10.1.1 SWMU 27 consists of the waste oil sump, the service pit, the locomotive pit, and the
area around the floor drain in the demolished Building 206. Elevated levels of PAHs and PCBs
were detected at shallow depths at this site. Exposure to these constituents in soil could
cause a cancer risk greater than 10 -6 to potential future depot workers. Also, VOCs,
herbicides, and petroleum hydrocarbons in the soil pose a potential threat to groundwater
guality. The remedial alternatives developed for SWMU 27 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal

8.10.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the area of contamination. If ownership of the depot is transferred to private or non-
federal agencies in the future, restrictive covenants could be written into the property
deed. Alternative 3 involves excavating the waste oil sump that has been filled with sand, the
contaminated soil beneath the railroad tracks, and the contaminated soil at SB469. The
excavated material, approximately 130 cubic yards, is transported off site to a Class I disposal
facility.

8.10.2 Overall Protection of Human Health and the Environment

The cancer risk estimated for the future construction worker at this site is 5x10 -6.
Alternative 1 (No Action) is not protective of human health for the current depot worker. The
estimated cancer risk is 3x10 -4 for this scenario. By reducing the potential for direct contact
of contaminated soils through land use restrictions, Alternative 2 (Institutional Controls) is
protective of the current depot worker. Because contaminants remain on site, neither Alternative
1 nor Alternative 2 mitigates the threat to groundwater posed by contaminants in the soil.
Alternative 3 (Excavation) permanently removes contaminated soil from the site, thereby
eliminating the potential threat to future depot workers and the potential threat to groundwater
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quality at this location.

8.10.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific ARARs that are
protective of groundwater were developed for the constituents of concern in the soil at SWMU 27.
Alternatives 1 (No Action) and 2 (Institutional Controls) do not comply with these
chemical-specific TBCs, as the constituents of concern remain in the soil at the site.
Alternative 3 (Excavation) meets these TBCs by permanently removing the contaminated soils from
the site. The action-specific ARARs for hazardous waste management (22 CCR, Division 4, Chapter
30, Section 66001 et seg., and 40 CFR 262, 263, and 264) that apply to Alternative 3(Excavation)
are also met.

8.10.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of
constituents in the soil to groundwater because contaminants remain on site. In addition,
Alternative 1 does not prevent adverse human exposure under a future construction worker
exposure scenario. Alternative 3 (Excavation) provides long-term effectiveness and permanence
because contaminated soils are permanently removed from the site.

8.10.5 Reduction of Toxicity, Mobility, and Volume through Treatment

None of the alternatives actively reduces the toxicity, mobility, or volume of contaminants at
the site through treatment.

8.10.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternative 3
(Excavation), remedial workers could be exposed to contaminated soil during excavation
activities. However, dust control and protective measures could be taken to minimize these
risks. Alternative 3 could probably be implemented in less than three months.

8.10.7 Implementability

8.10.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume two five-year site reviews. The present worth cost for the excavation and off-site
disposal described in Alternative 3 (Excavation)is $112,000.

8.10.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) and 2 (Institutional Controls)
because they do not mitigate the potential threat to groundwater beneath the site, and
Alternative 1 is not protective of human health for the current depot worker. Alternative 3
(Excavation) eliminates the threat to groundwater and is protective of human health. Therefore,
state and community acceptance is anticipated for Alternative 3. One written public comment was
received that expressed concern over the potential exposure and high cost of excavation (see
Responsiveness Summary).

8.11 Analysis of Remedial Alternatives for Building 30 Drum Storage Area

8.11.1 Remedial Alternatives

8.11.1.1 The Building 30 Drum Storage Area is located near the Consolidated Subsistence
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facility. Buried drums (removed in 1991) were discovered during construction of the Consolidated
Subsistence facility. Phthalate compounds and benzyl alcohol were detected in the soil at
concentrations that could pose a threat to background groundwater guality. The remedial
alternatives developed for the Building 30 Drum Storage Area are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal

8.11.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions around
the area of contamination. If ownership of the depot is transferred to private or non-federal
agencies in the future, restrictive covenants could be written into the property deed.
Alternative 3 involves excavating approximately 2,800 cubic yards of contaminated soil at the
site. Depending on the level of contamination, soils will be disposed of off site at either a
Class I or a Class II disposal facility.

8.11.2 Overall Protection of Human Health and the Environment

The cancer risk to future construction workers at the Building 30 Drum Storage Area was
estimated at 9x10 -7 and the hazard index as 0.3. All alternatives are protective of human
health. However, since contaminants remain on site, neither Alternative 1 (No Action) nor
Alternative 2 (Institutional Controls) mitigates the threat to groundwater posed by contaminants
in the soil. Alternative 3 (Excavation) permanently removes contaminated soil from the site,
thereby eliminating the potential threat to groundwater guality at this location.

8.11.3 Compliance with ARARs

8.11.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the potential migration
of soil constituents to groundwater because contaminants remain on site. Alternative 2 does
include groundwater monitoring to evaluate the long-term effectiveness. By removing contaminated
soils from the site, Alternative 3 (Excavation) eliminates any threat to groundwater and
provides long-term effectiveness and permanence.

8.11.5 Reduction of Toxicity, Mobility, and Volume through Treatment

None of the alternatives actively reduces the toxicity, mobility, or volume of contaminants at
the site through treatment.

8.11.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternative 3
(Excavation), remedial workers could be exposed to contaminated soil during excavation
activities. However, dust control and protective measures could be implemented to minimize
these risks. Alternative 3 could probably be implemented in less than three months.

8.11.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. With Alternative 3, conven-
tional earthmoving eguipment can be used to excavate and transport soils to an off-site disposal
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facility. However, excavation may be difficult to implement because soil excavation could
disrupt robotics operations in Building 30.

8.11.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $87,000. These costs
assume two five-year site reviews and installation of a downgradient monitoring well in
Alternative 2. The present worth cost for excavation and off-site disposal to a Class II
disposal facility in Alternative 3 is $907,000. If disposal at a Class I facility is reguired,
the cost increases to $1,860,000.

8.11.9 State and Community Acceptance

The state is not expected to accept Alternative 1 (No Action) because it does not mitigate the
potential threat to groundwater beneath the site. State acceptance of Alternative 2
(Institutional Controls) is anticipated because of the proposed monitoring program to identify
and respond to any groundwater impacts. Alternative 3 (Excavation) eliminates the threat to
groundwater and is protective of human health; therefore, state and community acceptance is
anticipated. One written public comment was received that expressed concern over the potential
exposure and high cost of excavation (see Responsiveness Summary).

8.12 Analysis of Remedial Alternatives for Surface and Near-Surface Soil-Northern Depot Area

8.12.1 Remedial Alternatives

8.12.1.1 Pesticides and metals are present in shallow soils at locations not associated with
any particular point source at the depot. Based on sampling results, a hazard index of 30 from
arsenic and manganese was calculated in the northern area of the depot. This result concerns a
potential exposure scenario for a depot worker being trained as a grader operator. The remedial
alternatives developed for surface soils and near-surface soils in the Northern Depot Area are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Asphalt Cover
Alternative 4 - Excavation and Disposal

8.12.1.2 Alternative 1 includes five-year site reviews and long-term groundwater monitoring.
Alternative 2 includes restricting access (posting signs) to the areas where elevated
concentrations of arsenic and manganese have been detected and two five-year site reviews.
Alternative 3 consists of installing an asphalt cover over the soils with elevated levels of
arsenic and manganese. The area reguiring an asphalt covering is estimated at 140,000 sguare
feet. Alternative 4 involves excavating approximately 3,000 cubic yards of soils with elevated
arsenic and manganese concentrations and transporting them off site to a Class II or Class III
disposal facility, depending on the level of contamination.

8.12.2 Overall Protection of Human Health and the Environment

The northern depot area soils pose a cancer risk Of 9 x 10 -7 to future grader operators and the
estimated hazard index is 30. Soil contaminants in the surface and near-surface soils are not
considered to pose a potential threat to groundwater in any of the alternatives. Alternative
1(No Action) may not be protective of human health for the future grader operators, as the
hazard index for this scenario exceeds 30. Alternative 2 (Institutional Controls) provides some
protection to human health by reducing the potential for grader operators to be exposed to
contaminated soils. Alternative 3 (Asphalt Cover) significantly reduces exposure by covering the
soils with asphalt. Alternative 4 (Excavation) provides the greatest protection to human health
and the environment because contaminated soils are permanently removed from the site.

8.12.3 Compliance with ARARs

No chemical-specific ARARs are identified for the constituents of concern in the surface and
near-surface soils in the Northern Depot Area. The chemicals of concern in surface and near
surface soils in the Northern Depot Area are not considered to pose a threat to groundwater,
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therefore, chemical-specific TBCs do not need to be developed in accordance with Water Quality
Goals. Also, location-specific ARARs are identified for this site. The action-specific ARARs for
hazardous waste management (22 CCR, Division 4, Chapter 30, Section 66001 et seq., and 40 CFR
262, 263, and 264) that apply to Alternatives 3 (Asphalt Cover) and 4 (Excavation) are met.

8.12.4 Long-Term Effectiveness

Alternative 1 (No Action) does not control exposure to contaminated soil, nor does it provide a
long-term management measure. Alternative 2 (Institutional Controls) provides control measures
to reduce the potential for contact by depot workers at the site. Alternative 3 (Asphalt Cover)
provides a reliable barrier to human contact and thus prevents depot workers from being exposed
to arsenic and manganese in the soil. However, since contaminants remain on site, some long-term
potential for exposure continues to exist. Alternative 4 (Excavation) provides long-term
effectiveness and permanence through excavation and off-site disposal of contaminated soils.

8.12.5 Reduction of Toxicity, Mobility, and Volume through Treatment

None of the alternatives actively reduces the toxicity, mobility, or volume of contaminants at
the site through treatment.

8.12.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternatives 3 (Asphalt
Cover) and 4 (Excavation), remedial workers could be exposed to contaminated soil during capping
and soil excavation. However, dust control and protective measures could be taken to minimize
these risks. Alternative 4 (Excavation) can be completed in approximately three months.

8.12.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. The asphalt cover in
Alternative 3 is relatively easy to install. Standard techniques, equipment, and materials for
the asphalt cover could be employed. In Alternative 4 (Excavation), conventional earthmoving
equipment can be used to excavate the soil. The transportation of soils and off-site disposal
are also easily implementable.

8.12.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $17,000. These costs assume
two five-year site reviews. The present worth cost for the asphalt cover in Alternative 3 is
$504,000. The present worth cost for Alternative 4, which includes excavation with off-site
disposal, is $769,000 for disposal at a Class III facility. The cost would increase to $995,000
if disposal at a Class II facility is required.

8.12.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) and 2 (Institutional Controls)
because they do not mitigate the potential threat to the future construction worker.
Alternatives 3 (Asphalt Cover) and 4 (Excavation) eliminate the threat to human health and are
protective of the environment; therefore, state and community acceptance is anticipated. One
written public comment was received that expressed concern over the potential exposure and high
cost of excavation. It also expressed interest in the asphalt-capping alternative (see
Responsiveness Summary).

8.13 Remedial Alternatives for SWMUs 2 and 3-the Sewage and Industrial Waste Lagoons

8.13.1 Remedial Alternatives

8.13.1.1 SWMUs 2 and 3 are located in the northern part of the depot, adjacent to the Sewage
Treatment Plant. According to the Engineering Evaluation/Cost Analysis (EE/CA that was prepared
for SWMUs 2, 3, and 33, the recommended alternative for the lagoons is excavation with off-site
-------
disposal. The remedial alternatives developed for SWMUs 2 and 3 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Excavation and Disposal

8.13.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the lagoons. Alternative 3 (selected in the EE/CA) involves excavating approximately
10,000 cubic yards of soil with contaminant concentrations above soil cleanup standards. It is
assumed that these soils can be disposed of at a nearby Class III (municipal) facility.

8.13.2 Overall Protection of Human Health and the Environment

The maximum cancer risk estimated for the current depot worker at these sites is 3x10 -6 . The
risk hazard index was estimated at 0.07. Neither Alternative 1 (No Action) nor Alternative 2
(Institutional Controls) mitigates the threat to groundwater posed by contaminants in the soil.
Alternative 3 (Excavation) permanently removes contaminated soil from the site, thereby
eliminating the potential threat to groundwater guality at this location. Threats to ecological
receptors will be addressed by installation of a geofabric filter and bringing in clean fill to
isolate receptors from contaminants.

8.13.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for the constituents of concern in soil at SWMUs 2 and
3. Alternatives 1 (No Action) and 2 (Institutional Controls) are not expected to comply with
these chemical-specific ARARs, as the constituents of concern remain at the site. Alternative 3
(Excavation) meets these ARARs by permanently removing the contamination through excavation and
off-site disposal. The action-specific ARARs for hazardous waste management (22 CCR, Division 4,
Chapter 30, Section 66001 et seg., and 40 CFR 262, 263, and 264) that apply to Alternative 3
(Excavation) are also met.

8.13.4 Long-Term Effectiveness

Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of
constituents in the soil to groundwater because contaminants remain on site. By removing
contaminated soils from the site, Alternative 3 (Excavation) eliminates any threat to
groundwater and provides long-term effectiveness and permanence.

8.13.5 Reduction of Toxicity, Mobility, and Volume through Treatment

None of the alternatives actively reduces the toxicity, mobility, or volume of contaminants at
the site through treatment.

8.13.6 Short-Term Effectiveness

The implementation of Alternatives 1 (No Action) and 2 (Institutional Controls) does not pose
any new risks to the community or any new environmental impacts. Under Alternative 3
(Excavation), remedial workers could be exposed to contaminated soil during excavation. However,
dust control and protective measures could be taken to minimize these risks. Alternative 3
(Excavation)could probably be implemented in less than three months.

8.13.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. With Alternative 3
(Excavation), conventional earthmoving eguipment can be used to excavate and transport soils to
an off-site disposal facility. However, it may not be possible for the municipal landfills in
the vicinity of DDJC-Tracy to accept the large guantity of soil that would need to be excavated.

8.13.8 Cost
-------
The estimated ten-year present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs assume
that five-year site reviews are completed for 30 years. The present worth cost for excavation
and off-site disposal to a Class III disposal facility (Alternative 3) is $2.1 million.

8.13.9 State and Community Acceptance

The state is not expected to accept Alternatives 1 (No Action) and 2 (Institutional Controls)
because they do not mitigate the potential threat to groundwater posed by contaminants in the
soil. Alternative 3 (Excavation) eliminates the threat to groundwater and is protective of human
health; therefore, state and community acceptance is anticipated. One written public comment was
received that expressed concern over the potential exposure, and high cost of excavation (see
Responsiveness Summary).

8.14 Analysis of Remedial Alternatives for SWMU 33- Industrial Waste Pipeline

8.14.1 Remedial Alternatives

8.14.1.1 SWMU 33 is an industrial waste pipeline (IWPL) buried 2 feet bgs. The IWPL is no longer
used. According to the EE/CA for SWMUs 2, 3, and 33 (Radian, 1996) the removal action for the
IWPL involves pressure-grouting the laterals and sumps and excavating the most contaminated
soils. Following this removal action, all soil cleanup levels will be attained except those for
aldrin, dieldrin, diethylphthalate, and di-n-butylphthalate. SWMU 33 is considered a source area
for VOCs and pesticides. The remedial alternatives developed for SWMU 33 are:

Alternative 1 - No Action
Alternative 2 - Institutional Controls
Alternative 3 - Grouting, Limited Excavation, and Disposal (removal action)
Alternative 4 - Excavation and Disposal

8.14.1.2 Alternative 1 includes five-year reviews and long-term groundwater monitoring.
Alternative 2 includes five-year reviews, long-term monitoring, and land use restrictions
around the areas of contamination. Alternative 3 involves grouting inlets to the entire IWPL,
limited excavation, and institutional controls including monitoring potential impacts to water
guality. It is assumed that the excavated soils need to be disposed of at a Class I disposal
facility. The entire IWPL and all associated soil contamination would be excavated under
Alternative 4.

8.14.2 Overall Protection of Human Health and the Environment

Current cancer risks associated with SWMU 33 are estimated at 1x10 -8 and the hazard index at
0.0007. All alternatives are protective of human health. Alternatives 1 (No Action) and 2 do not
address any of the contamination that could potentially impact groundwater. Alternative 3
(Grouting, Limited Excavation, Institutional Controls) includes excavation of portions of the
IWPL, but a potential, though unconfirmed, threat to groundwater guality would remain at this
location. Monitoring would be used to identify any impacts to groundwater guality. Alternative 4
would remove confirmed and unconfirmed threats to the environment.

8.14.3 Compliance with ARARs

In compliance with Water Quality Goals (CVRWQCB, 1993), chemical-specific TBCs that are
protective of groundwater were developed for the constituents of concern in soil at SWMU 33.
Alternatives 1 (No Action) and 2 (Institutional Controls) do not comply with these
chemical-specific TBCs, as the constituents of concern remain at the site. Contaminants also
remain in place in concentrations above cleanup standards for Alternative 3 (Grouting, Limited
Excavation/Institutional Controls). Alternative 3 removes a portion of the contamination and
reduces the potential for the migration of these contaminants. The action-specific ARARs for
hazardous waste management (22 CCR, Division 4, Chapter 30, Section 66001 et seg., and 40 CFR
262, 263, and 264) that apply to Alternatives 2 and 3 are also met. Alternative 4 satisfies all
ARARs.

8.14.4 Long-Term Effectiveness
-------
Alternatives 1 (No Action) and 2 (Institutional Controls) do not prevent the migration of soil
contaminants to groundwater because contaminants remain on site. Alternative 3 (Grouting,
Limited Excavation/Institutional Controls) removes a portion of the contaminants, reduces the
mobility of the contaminants, and relies on groundwater monitoring to indicate potential threats
to groundwater from the contaminants left in place. Alternative 4 has the highest long-term
effectiveness because all contaminants would be removed.

8.14.5 Reduction of Toxicity, Mobility, and Volume through Treatment

None of the alternatives actively reduces the toxicity, mobility, or volume of contaminants at
the site through treatment.

8.14.6 Short-Term Effectiveness

The implementation of Alternatives 1 and 2 (No Action) do not pose any new risks to the
community or any new environmental impacts. Under Alternatives 2, 3 (Grouting, Limited
Excavation, Institutional Controls), and 4 (Excavation and Disposal), remedial workers could be
exposed to contaminated soil during excavation. However, dust control and protective measures
could be taken to minimize these risks.

8.14.7 Implementability

There is no action associated with Alternative 1 (No Action). The land use restrictions in
Alternative 2 (Institutional Controls) are readily implementable. Alternative 3 (Grouting,
Limited Excavation, Institutional Controls) would use conventional earthmoving eguipment to
excavate and transport soils to an off-site disposal facility. Alternative 4 (Excavation and
Disposal) would be difficult to implement because of the number of subsurface utilities and
would impact the mission of DDJC-Tracy by interrupting traffic.

8.14.8 Cost

The estimated present worth for Alternative 1 (No Action) is $15,000. Alternative 2
(Institutional Controls) is expected to have a present worth cost of $65,000. These costs
assume that five-year site reviews will be completed for 30 years. In Alternative 3 (Grouting,
Limited Excavation, Institutional Controls) the present worth cost for excavation and off-site
disposal to a Class I disposal facility is $242,600. Alternative 4 (Excavation and Disposal) has
a present worth cost of $4,708,000.

8.14.9 State and Community Acceptance

The state is not expected to accept Alternative 1 (No Action) because it does not mitigate the
threats to groundwater at the site. Alternative 2 (Institutional Controls) is not expected to be
acceptable because it doesn't address potential threats to groundwater guality. Alternative 3
(Grouting, Limited Excavation, and Institutional Controls) is expected to be acceptable if the
groundwater monitoring program has adeguate provisions to address potential threats to
background groundwater guality from contaminants left in place. Alternative 4 (Excavation and
Disposal) is expected to be acceptable to the state. One written public comment was received
that expressed concern over the potential exposure and high cost of excavation (see
Responsiveness Summary).
-------
Table 8-1. National Contingency Plan (NCP) Evaluation Criteria
Category
Evaluation Criterion
Criterion Definition
Threshold Overall Protection of Human Health
Criteria and the Environment
Addresses whether a cleanup alternative provides
adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or
controlled.
Compliance with ARARs
Addresses whether a remedy will meet all federal and
state environmental laws and/or provide grounds for a
waiver.
Balancing Long-Term Effectiveness and
Criteria Permanence
Refers to the ability of a remedy to provide reliable
protection of human health and the environment over
time.
Reduction of Toxicity, Mobility, or
Volume through Treatment
Refers to the preference for a remedy that reduces health
hazards, the movement of contaminants, or the quantity of
contaminants at the site through treatment of the
contaminated media.
Short-Term Effectiveness
Addresses the period of time needed to complete the
remedy, and any adverse effects to human health and the
environment that may be caused during the construction
and implementation of the remedy.
Implementability
Refers to the technical and administrative feasibility of a
remedy. This includes the availability of materials and
services needed to carry out a remedy. It also includes
federal, state, and local governments working together to
clean up the site.
Cost
Evaluates capital, operation, and maintenance costs of
each alternative in comparison to other equally protective
alternatives.
Modifying
Criteria
State Acceptance
Indicates whether the state agrees with, opposes, or has no
comment on the preferred alternatives.
Community Acceptance
Includes determining which components of the
alternatives interested persons in the community support,
have reservations about, or oppose. This assessment may
not be completed until public comments on the Proposed
Plan are received.
-------
Table 8-2. Comparative Analysis of Alternatives by Site
Site: Dieldrin In Operable Unit 1 Groundwater
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
Alternative 2
Alternative 3
Groundwater
Extraction and
Alternative 4
Groundwater
Extraction and

No Action
Low
Low
Low
Low
High
High
$49,000
Low
Low
Institutional
Controls
Medium
Low
Medium
Low
High
High
$99,000
Low
Medium
Treatment
Option 1
High
High
High
High
Medium
High
$2,528,000
High
Medium
Treatment
Option 2
Medium
Medium
Medium
Medium
Medium
High
$1,396,000
Medium
Medium
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Site: Group A Sites

Alternative 1 Alternative 2
Alternative 3
Alternative 4
Excavation and

No Action
Low
Low
Low
Low
High
High
$45,000
Low
Low
Institutional
Controls
Medium
Low
Medium
Low
High
High
$195,000
Low
Medium
Soil Vapor
Extraction
High
High
High
High
Medium
High
$649,000
High
Medium
Off-site
Disposal
High
High
High
Low
Medium
Medium
$42,054,000
Medium
Medium
-------
Table 8-2. (Continued)
Site: SWMU 4 - Storm Drain Lagoon
Alternative 1

No Action

Medium
Low
Low
Criteria
Overall Protection of Human Health
and the Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity, Mobility, and
Volume through Treatment Low
Short-Term Effectiveness Low
Implementability High
Cost $25,000
Stale Acceptance Low
Community Acceptance Low
Alternative 2
Upstream Source
Control

Medium
Low
Medium

Low
Medium
Medium
$1,158,000
Low
Medium
Alternative 3
Excavation and
Sediment Disposal

Medium
Medium
Medium

Low
High
High
$552,000
Medium
High
Site: SWMU 6 - Building 28 Sump

Alternative 1 Alternative 2 Alternative 3
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
No Action
Medium
Low
Low
Low
High
High
$15,000
Low
Low
Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
In Situ
Stabilization
High
High
High
High
Medium
High
$169,000
High
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
High
$45,000 -$65,000
High
Medium
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Table 8-2. (Continued)
Site: STCMU 7 - Burn Pit No. 1
Alternative 1
Alternative 2
Alternative 3
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 4
Excavation and

No Action
Medium
Low
Low
Low
High
High
$15,000
Low
Low
Institutional
Controls
Medium
High
Medium
Low
High
High
$208,000
High
Medium
In Situ
Stabilization
High
High
High
High
Medium
High
$822,000
High
Medium
Off-site
Disposal
High
High
High
Low
Medium
High
$2, 605,000
High
Medium
Site: SWMU 8 - Burn Pit No. 2
Alternative 1 Alternative 2
Alternative 3
Alternative 4
Excavation and
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance

No Action
Low
Low
Low
Low
High
High
$15,000
Low
Low
Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium

Bi eventing
Medium
Medium
Medium
Medium
Medium
Medium
$246,000
Low
Medium
Off-site
Disposal
High
High
High
Low
Medium
High
$2,823,000
High
Medium
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Table 8-2. (Continued)
Site: SWMU 20 - Area 1, Building 10/Building 26
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
No Action
Medium
Low
Low
Low
High
High
$15,000
Low
Low
Alternative 2

Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
Alternative 3
SVE with
Excavation and
Disposal
High
High
High
High
Medium
High
$293,000
High
Medium
Alternative 4
Excavation and
Off-site
Disposal
High
High
High
Low
Medium
High
$355,000
High
Medium
Site: SWMU 24 - Petroleum Waste Oil Tank
Criteria
Alternative 1
No Action
Overall Protection of
Human Health and
the Environment Medium
Compliance with
ARARs Low
Long-Term
Effectiveness Low
Reduction of
Toxicity, Mobility,
and Volume
through Treatment Low
Short-Term
Effectiveness High
Implementability High
Cost $15,000
State Acceptance Low
Community
Acceptance Low
Alternative 2

Institutional
Controls
Medium

Low

Medium

Low

High
High
$65,000
Low

Medium
Alternative 3
Excavation
and Off-site
Bioventing
Medium

High

Medium

Medium
High
$166,000
High

Medium
Alternative 4

Excavation and
Disposal
High

High

Low

Medium
Medium
$214,000
High

Medium
Alternative 5

Bioremediation

Medium

High

Medium

Medium
Medium
$263,000
High

Medium
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Table 8-2. (Continued)
Site: STCMU 27 - Building 206
Alternative 1
Alternative 2
Alternative 3
Criteria
No Action
Institutional Controls
Excavation and Off-
site Disposal
Overall protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Low Medium
Low Low
Low Medium
Low Low
High High
High High
$15,000 $65,000
Low Low
Low Medium

Site: Drum Storage Area - Building 30
High
High
High
Low
Medium
High
$112,000
High
Medium
Alternative 1
Alternative 2
Alternative 3
Criteria
No Action
Institutional Controls
Excavation and Off-
site Disposal
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Medium
Low
Medium
Low
High
High
$15,000
Low
Low
Medium
Low
Medium
Low
High
High
$87,000
High
Medium
High
High
High
Low
Medium
Medium
$907,000
High
Medium
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Table 8-2. (Continued)
Site: Surface and Near Surface Soil
Alternative 1
Alternative 2
Alternative 3
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability

Cost
State Acceptance
Community Acceptance
Alternative 4
Excavation and

No Action
Low
High
Low
Low
High
High

$15,000
Low
Low
Institutional
Controls
Medium
High
Medium
Low
High
High

$17,000
Low
Medium

Asphalt Cover
High
High
Medium
Low
Medium
High

$504,000
High
Medium
Off-site
Disposal
High
High
High
Low
Medium
High
$769,000-
$995,000
High
Medium
Site: SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons

Alternative 1 Alternative 2 Alternative 3
Criteria
No Action
Institutional Controls
Excavation and Off-
site Disposal
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Medium
Low
Medium
Low
High
High
$15,000
Low
Low
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
High
High
High
Low
Medium
Medium
$2,100,000
High
Medium
-------
Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Reduction of Toxicity,
Mobility, and Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Table 8-2. (Continued)
Site: SWMU 33 - Industrial Waste Pipeline
Alternative 1
Alternative 2
Alternative 3
Alternative 4

No Action
Medium
Low
Medium
Low
High
High
$15,000
Low
Low
Institutional
Controls
Medium
Low
Medium
Low
High
High
$65,000
Low
Medium
Limited
Excavation
High
High
High
Low
Medium
Medium
$242,600
High
Medium
Excavation and
Off-Site Disposal
High
High
High
Low
Medium
Low
$4,708,000
High
Medium
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9.0 SEIiECTED REMEDIES

Defense Depot San Joaquin (DDJC)-Tracy, the United States Environmental Protection Agency
(U.S. EPA), the Department of Toxic Substances Control (DTSC), and the Central Valley Regional
Water Quality Control Board (RWQCB) have selected remedies for each site at DDJC-Tracy. These
remedies were selected based on the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), information in the Comprehensive Remedial
Investigation/Feasibility Study (RI/FS) (Montgomery Watson, 1996a), a detailed analysis of
alternatives, and public comments. Twenty-two sites are recommended for no further action
(addressed in Section 9.2). Remedial actions will be taken at the other sites. Designs will be
implemented after DDJC-Tracy, U.S. EPA, DTSC, and the RWQCB sign this Record of Decision (ROD).
The selected remedies for all sites are summarized in Table 9-1.

9.1 Monitoring Program

9.1.1 There are 104 monitoring wells, 11 extraction wells, and 6 potable water supply wells that
are presently being sampled for analysis on a quarterly to annual basis at DDJC-Tracy.
Twenty-four extraction wells have been designed and employed for the Operable Unit (OU) 1
groundwater remediation effort and seven new wells are identified in this ROD as part of the
selected remedy. The success of the selected remedies identified in this ROD will be, in part,
evaluated through the Well Monitoring Program.

9.1.2 The monitoring wells that will initially be used to monitor the performance of the
selected remedies are summarized in Table 9-2. The Well Monitoring Program will undergo annual
review to ensure that the well locations, monitoring frequency, water level measurements, and
analytes are optimized for the long term (see Appendix E for monitoring well locations and the
decision logic that will be used to modify the program in response to the monitoring results).
Each of the sites (not necessarily every well at each site) recommended for further action in
this ROD (see Table 9-1) will be monitored for the analytes identified in this section of the
ROD (see specific subsections for each individual site) for no less than three years after soil
and groundwater cleanup standards have been attained (per 27 CCR, Section 20410). Furthermore,
if wastes remain in place (e.g., under institutional controls), the site will be monitored until
cleanup standards are met or until it can be demonstrated that no further threat to water
quality remains (27 CCR, Section 20400) .

9.1.3 Wastes will remain in place at SWMU I/Area 2, SWMU 7, SWMU 24, SWMU 33, and Drum Storage
Area/Building 30 that could impact groundwater quality at some future date. Monitoring will
continue at these sites until an acceptable rationale (e.g., based on additional DI-WET
analysis, data from the well monitoring program, or revised vadose zone modeling) demonstrates
to the satisfaction of the signatory parties that there is no further threat to groundwater
quality.

9.1.4 The Well Monitoring Program will be modified to incorporate all of the site-specific
monitoring requirements identified in this section. The following discussions of the selected
remedies identify specific monitoring requirements that are part of the selected remedies. The
monitoring requirements specified in this ROD are summarized in Table 9-2. The Annual Well
Monitoring Report is a primary document. This report will identify and include a qualitative
evaluation of all groundwater results and trends that exceed background concentrations (see
Table 7-1). This evaluation may include recommendations for additional sampling, additional
monitoring wells, or reevaluation of the selected remedy. Each selected remedy of this ROD
identifies water quality objectives to protect the beneficial uses of groundwater. If any of
these water quality objectives are exceeded, the appropriateness of the selected remedy will be
evaluated in the Annual Well Monitoring Report. Groundwater concentrations requiring evaluation
are not intended to serve as aquifer cleanup standards. Per the Federal Facilities Agreement
(FFA) , any party to the agreement may submit a written proposal for additional work or
modification of the selected remedy on the basis of the Annual Well Monitoring Report results.
DDJC-Tracy and the agencies will jointly determine if any additional remedial action is
warranted.

9.2 No Further Action Sites

9.2.1 Twenty-two sites are recommended for no further action (Table 9-1). The Comprehensive
RI/FS (Montgomery Watson, 1996a) documented all sites recommended for no further action along
-------
with the rationale supporting that decision (see Table 7-15). All sites were carried through to
the feasibility study process if the baseline risk assessment results indicated that chemicals
of concern (COCs) posed a significant potential risk to humans, plants, or animals. A site was
also carried through if it was determined that COCs posed a threat to background groundwater
guality or beneficial uses. If neither of these conditions was met, the site was determined to
pose no threat to human health and the environment and recommended for no further action. No
further action sites were not typically considered in the development of the Well Monitoring
Program.

9.2.2 Three sites with COCs were also recommended for no further action. Low levels of COCs were
identified at Solid Waste Management Unit (SWMU) 10A, SWMU 14, and SWMU 23 at DDJC-Tracy.
Groundwater has not been impacted to date by activities at SWMU 10A. The fate and transport
evaluation conducted for SWMU 10A showed that the diethylphthalate and di-n-butylphthalate
present in site soils pose a potential threat to background groundwater guality. Both compounds
were detected in deep soils, but were suspected laboratory contaminants (Montgomery Watson,
1996a). The cost to excavate possible phthalate contamination was estimated at $2 million to
$4.3 million (depending on type of disposal reguired). Although technically feasible,
remediation was not recommended because of the cost, the limited number of detections, and
guestions regarding the reliability of the data. This site will be assessed through the Well
Monitoring Program to determine if groundwater has been impacted by COCs at this site.

9.2.3 The fate and transport evaluations for SWMU 14 and SWMU 23 showed that constituents in
soils do not pose a threat to water guality. The baseline risk assessment (Montgomery Watson,
1996e) showed that COCs at SWMU 10A, SWMU 14, and SWMU 23 do not pose unacceptable risk to human
health or ecological receptors.

9.3 Day Care Center

The time-critical removal action at the Day Care Center eliminated the incremental cancer risk
above background concentrations for surface soils. No further threat to human health, ecological
receptors, or background groundwater guality remains at this site. No additional actions are
anticipated at the Day Care Center.

9.4 Cleanup Standards

Cleanup standards were established to protect human health, ecological receptors, background
groundwater guality, and beneficial uses. Cleanup standards protective of human health are
risk-based standards to reduce the incremental risk at a site to 1 x 10 -6. Cleanup standards to
protect ecological receptors were developed with input from the U.S. EPA. Cleanup standards for
groundwater are based on beneficial use limits (e.g., Maximum Contaminant Levels [MCLs]).
Cleanup standards to protect background water guality were developed through vadose zone
modeling and eguilibrium partitioning limits developed in the RI/FS (Montgomery Watson, 1996a).
This water guality assessment is summarized in Table 6-9. Appendix F documents the review of
analytical laboratories to identify the lowest concentrations that can be reproducibly detected
as verified by the use of a low-level standard. Where appropriate these concentrations were
adopted as cleanup standards.

9.5 OU 1 Groundwater

9.5.1 The selected remedy for OU 1 includes extraction wells, air stripping to remove VOCs,
wellhead carbon treatment to remove dieldrin, and reinjection. The primary disposal method is to
discharge extracted and treated groundwater to shallow aguifers utilizing injection wells and
infiltration galleries located on the main base property. DDJC-Tracy will construct additional
subsurface disposal facilities in these areas or on the northern Annex property, as necessary,
to optimize the capacity of the groundwater recharge disposal method. DDJC-Tracy will also
install a blind flange in the discharge piping so that continued discharge to the storm water
detention pond is no longer possible. As a back-up disposal method after optimization of all
available subsurface disposal systems, treated groundwater may be discharged to the on-site
wastewater evaporation/percolation ponds in cases of emergency. An "emergency" is defined as
conditions such as failure of piping or capacity problems such that discharge to groundwater is
not possible, as jointly determined by DDJC-Tracy and the regulatory agencies. The remedy
addresses groundwater contaminated with TCE, PCE, 1,1-DCE, and dieldrin.
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9.5.2 OU 1 is defined as the contaminated groundwater plume, on and off the depot, that is
emanating from DDJC-Tracy. This plume of contamination is primarily identified by
concentrations of PCE and TCE. In August 1993, the final OU 1 ROD (WCC, 1993b) was signed to
implement the remedial alternatives presented in the OU 1 RI/FS (WCC, 1992b). The OU 1 ROD
established aguifer cleanup standards for PCE, TCE, and 1,1-DCE. Groundwater from the OU 1 plume
is currently being extracted and treated by the Interim Remedial Measure (IRM) system (Figure
9-1). The present worth cost to construct and operate the IRM system to address volatile organic
compounds (VOCs) is estimated at $9.5 million.

9.5.3 As part of the OU 1 full-scale design, the feasibility of decreasing the OU 1 cleanup
standards to detection limits was analyzed. This analysis was reguired by the OU 1 ROD (WCC,
1993). Modeling results showed that it is technically and economically infeasible to reduce OU 1
cleanup standards from aguifer cleanup standards to detection limits. This conclusion was
documented in the Explanation of Significant Differences (BSD) to the OU 1 ROD, which was
approved by parties to the FFA on 29 January 1996 (Montgomery Watson, 1996g). The BSD modified
the selected remedy for OU 1 from extraction, treatment, and reinjection to a combination of
extraction, treatment, reinjection, and dispersion (dispersion is limited to the TCE and PCE
plume east of Banta Road).

9.5.4 The OU 1 ROD deferred remedial decisions for other constituents detected in groundwater to
the Comprehensive RI/FS. Table 7-1 lists minimum and maximum concentrations detected, the
freguency of detection, the remedial decision, the remedial decision rationale, and the
potential risks for each constituent detected in groundwater at DDJC-Tracy. Table 7-1 shows that
except for TCE, PCE, 1,1-DCE, and dieldrin, groundwater contaminants do not warrant remedial
action because they were detected infreguently and/or below beneficial use limits (e.g., MCLs)
or background levels. Dieldrin concentrations above the California Action Level of 0.05 Ig/L
were detected near SWMUs 2, 3, and 8, and within the Tracy Annex. Concentrations of monuron and
diuron in OU 1 groundwater are well below the numerical beneficial use limit (Table 7-1) of 10
Ig/L. Removal actions have been performed to excavate contaminated soils from the primary source
area for monuron and diuron (SWMUs 2 and 3). Neither compound was detected in confirmation soil
samples.

9.5.5 A thorough analysis of the Applicable or Relevant and Appropriate Reguirements (ARARs) is
presented in Section 10.3. All chemical-specific ARARs were reviewed and the most stringent were
adopted as cleanup standards for the aguifer. The cleanup standard for dieldrin is based on the
California Action Level (a chemical-specific performance standard). Attainment of background
levels is not technically or economically feasible. Aguifer cleanup standards for groundwater at
DDJC-Tracy are provided in the in-text table, below.

Aguifer
Cleanup
Standards
Analytes (Ig/L) Basis
1,1-Dichloroethene 6.0 California MCL
Tetrachloroethene 5.0 Federal MCL
Trichloroethene 5.0 Federal MCL
Dieldrin 0.05 California Action Level
9.5.6 The OU 1 BSD revised and expanded the ROD-specified effluent treatment standards to
include total chromium, ODD, DDE, DDT, chlordane, monuron and diuron. The effluent treatment
standards for monuron and diuron were based on limited data from the initial background study.
No monuron or diuron has been detected in the background wells at DDJC-Tracy. The prior monthly
median values of 0.17 Ig/L for monuron and 0.15 Ig/L for diuron were derived from the detection
limits for the A Horizon during the background study. This study employed a modified method and
the detection limits for the A and B Horizons varied (Radian, 1997) because the detection limits
were not reproducible. Therefore, this ROD proposes raising the effluent treatment standard for
these compounds to the minimum concentration that can be reproducibly detected, as verified by
the use of a low-level standard (see Appendix F). Modified effluent treatment standards are
provided in the in-text table, below.

9.5.7 The existing OU 1 groundwater treatment system includes 11 extraction wells, an air
stripper, and an infiltration gallery. The system operates at a capacity of 350 to 470 gallons
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per minute (gpm) . The system is presently being expanded to add 24 new extraction wells, a
larger treatment plant (air stripper), and nine new infiltration galleries. The operating
capacity of the expanded system is estimated to be 1,250 gpm (Montgomery Watson, 1996f). To
address pesticide contamination, the current OU 1 design includes wellhead treatment at
extraction wells EW-02 and EW-05 with liguid-phase carbon.

Treated Treated
Effluent Effluent
Monthly Daily
Median Maximum
Analytes (Ig/L) (Ig/L)
Carbon Tetrachloride 0.5 0.5
Chloroform 0.5 5.0
Chromium (total) 50 50
1,1-Dichloroethene 0.5 5.0
Tetrachloroethene 0.5 5.0
Trichloroethene 0.5 5.0
Dieldrin 0.05 0.1
4,4-DDD 0.15 1.0
4,4-DDE 0.1 1.0
4,4-DDT 0.1 1.0
Chlordane 0.104 0.25
Monuron 1.0 1.0
Diuron 1.0 1.0
Total Volatile Organic 1.0 5.0
Compounds (VOCs)

9.5.8 Alternative 3 (groundwater extraction and treatment) is the selected remedy for dieldrin
in groundwater in OU 1. The components of the selected remedy for dieldrin will be added to the
remedy of the OU 1 ROD to address all COCs in groundwater. The area recommended for
remediation contains dieldrin concentrations near SWMUs 2, 3, and 8, and within the DDJC-Tracy
Annex north of SWMUs 2 and 3. The selected aquifer cleanup standard for dieldrin is consistent
with the effluent treatment standard for dieldrin selected for the full-scale OU 1 groundwater
treatment system.

9.5.9 Groundwater modeling was performed to prepare the conceptual design. The groundwater model
assumed that the removal actions will be completed at SWMUs 2 and 3, and a remedial action
(Section 9.6.4) will be completed at SWMU 8. The groundwater modeling indicates that it is not
technically feasible to meet the aguifer cleanup standard for dieldrin within 30 years. The
modeling predicts that the aguifer cleanup standard can possibly be attained at SWMUs 2 and 3
within 50 years, and at SWMU 8 in 30 to 50 years. However, the groundwater modeling predicts
that aguifer cleanup standards cannot be attained at the Annex within 50 years. The use of
additional extraction wells is not expected to reduce the time required to reach the aquifer
cleanup standard because dieldrin is relatively immobile and the capture of concentrations above
the proposed cleanup standard is difficult to achieve. Although the cleanup standard of 0.05
Ig/L cannot be achieved within a 30 year time frame (in accordance with interim Final Guidance
for conducting Feasibility Studies Under CERCLA [U.S. EPA, 1988]), DDJC-Tracy will take action.

9.5.10 The selected remedy for dieldrin consists of installing groundwater extraction wells in
the following areas: SWMUs 2 and 3 (one well), SWMU 8 (two wells), and the Annex (at least four
wells). Two existing extraction wells at SWMUs 2 and 3 (EW02 and EW05) will also be used to
remediate dieldrin. Figure 9-2 shows proposed extraction well locations and the area of
groundwater to be remediated. Each extraction well will be completed in the Above Upper Horizon
and is expected to produce approximately 5 gpm. Extracted water will be treated with liquid
phase granular activated carbon (GAG) to remove dieldrin, VOCs, and semivolatile organic
compounds (SVOCs)/pesticides in the extracted groundwater.

9.5.11 Given the relatively low groundwater extraction rates expected from the additional
extraction wells, it is anticipated that the infiltration galleries included in the OU 1 full-
scale design will be sufficient to handle the additional groundwater flows from SWMUs 2 and 3
and within the Tracy Annex. Because SWMU 8 is located approximately 1,500 feet from the nearest
OU 1 infiltration gallery, it is proposed that treated groundwater at this site be injected.
Although fouling of injection wells has previously occurred, properly designed injection
-------
systems (i.e., galleries), combined with operation and maintenance (O&M)(including regularly
scheduled re-development), are proposed as an appropriate and cost-effective means for managing
treated water.

9.5.12 A five-year policy site review will be reguired for the OU 1 groundwater treatment system
because it will take more than five years to attain the aguifer cleanup standard for dieldrin.
However, the five-year policy review for the OU 1 treatment system will be postponed to
correspond with the review of all other sites at DDJC-Tracy. This postponement will put all
decision-making on a single five-year cycle. Five-year reviews will evaluate the performance of
the selected remedy and be continued for as long as cleanup standards are exceeded. Groundwater
sampling within the plume areas will be conducted as part of the Well Monitoring Program (see
Table 9-2).

9.5.13 The selected remedy is protective of human health and the environment because dieldrin,
other pesticides, and VOCs are removed from the groundwater, and because the treated groundwater
is returned to the aguifer for use. Future risk to off-depot residents and depot workers is
addressed by the selected remedy. The risk to off-depot residents is from carbon tetrachloride
(71 %) and TCE (29%). Carbon tetrachloride has been detected infreguently in on-depot wells.
Most of the carbon tetrachloride in groundwater was not related to depot activities (Montgomery
Watson, 1996a). TCE will be removed by the selected remedy. On depot, the remedy will address
dieldrin, which is responsible for 55 percent of the cancer risk. The remedy also addresses
1,1-dichloroethene (38% of the cancer risk ) and chloroform (7% of the cancer risk). The
potential incremental cancer risk above background to future depot workers will be reduced to
3.83x10 -4 (this is eguivalent to the risk associated with the COCs at their corresponding
MCLs). The estimated present worth of the selected remedy for dieldrin is $2,528,000. The basis
for this cost estimate is included in Table 9-3. The total cost to address all COCs in
groundwater (VOCs and dieldrin) has a 30-year present worth cost of approximately $12 million.

9.6 Group A Sites

9.6.1 The selected remedy (Alternative 3 - SVE) for the Group A sites addresses VOCs (TCE and
PCE) in soils. The remedy focuses on VOCs at the following sites:

SWMU I/Area 2;

Area 1 Building 237; and

Area 3.

In addition to these sites, the northern portion of the Industrial Waste Pipeline (IWPL)(SWMU
33) in the immediate vicinity of Area 1 Building 237 (between manhole W-5 and SB463) will be
further evaluated for VOCs in the predesign soil-gas sampling effort as part of the remedial
design/remedial action effort. The soil-gas investigation will be extended from the specified
locations as needed to identify the lateral and vertical extent of contamination above the
numerical cleanup standards. The selected remedy will be implemented concurrently with the SVE
system for SWMU 20, which addresses VOCs at SWMU 20, Area 1 Building 10, and the portion of the
IWPL near Building 10.

9.6.2 The Group A sites do not pose potential risks to human health under the depot or
construction worker exposure scenarios. No risks to ecological receptors have been identified.
Vadose zone modeling (Montgomery Watson, 1996b) and groundwater data suggest that SWMU I/Area 2,
Area 1 Building 237, and Area 3 are continuing sources of VOCs to groundwater that would reguire
the OU 1 treatment system to operate beyond 30 years.

9.6.3 A thorough analysis of ARARs for the selected remedy is provided in Section 10.4. The
cleanup standards for the Group A sites are as follows:

Group A Site Soil-Gas
Analytes Cleanup Standards (Ig/L)
Tetrachloroethene 5.4 (780 ppbv)
Trichloroethene 1.9 (350 ppbv)

Although TCE has not been detected in soils at Area 1 Building 237, groundwater results suggest
-------
that this area could be a potential source area. Therefore, a cleanup standard for TCE was
retained at this site. The SVE systems will address VOC concentrations above the cleanup
standards.

9.6.4 PCBs (Aroclor 1260) were detected at a concentration of 140 mg/kg at 14.5 feet bgs in
SB145 at SWMU I/Area 2. Aroclor 1260 was not detected in any other soil samples collected at the
site. Fate and transport modeling results show that the PCBs in soil at SB145 pose a threat to
beneficial uses of groundwater. A hypothetical cost estimate was prepared assuming that the area
of soil around boring SB145 where the PCBs were detected is to be remediated by excavation and
disposal (Montgomery Watson, 1996a). The excavation would be approximately 15 feet by 15 feet by
15 feet for a total soil volume of 125 cy (165 tons). The total present worth cost for a removal
action with Class 1 disposal of soil is $108,000. Although excavation and disposal is
technically feasible, the cost expenditure reguired to remediate the small area of PCB-
contaminated soil at SWMU I/Area 2 is not considered justified given the relatively low level of
contamination and the fact that PCBs were detected in only one soil sample.

9.6.5 The vadose zone cleanup will be achieved when:

1. The concentrations of PCE and TCE present in soil gas are egual to or less than the
cleanup standard;

2. It is demonstrated that the remaining TCE and PCE can no longer cause leachate
concentrations to exceed the aguifer cleanup standards; and

3. TCE and PCE have been removed to the extent technically and economically feasible.
This evaluation will include, at a minimum, the following factors:

a) The total cost and duration of continued operation of the SVE
system until aguifer cleanup standards are met.

b) The total cost and duration of continued groundwater treatment to
meet aguifer cleanup standards without continued SVE operation.

c) The incremental cost (cost benefit) of continued operation of the SVE
system on the basis of a cost per pound of contaminant removal if the
underlying groundwater has not attained aguifer cleanup standards.

9.6.6 The signatory parties to the ROD will jointly decide when the cleanup of volatile organic
COCs in the vadose zone has been achieved and when the SVE system will be shut off permanently.
The evaluation of technical and economic feasibility that will serve as the basis for this
decision will be a primary document.

9.6.7 The signatory parties to the FFA agree that DDJC-Tracy may cycle the SVE system on and off
to optimize the SVE operation and/or evaluate all feasibility analysis factors.

9.6.8 The selected alternative reguires an SVE system to be installed in the area of
contamination at each Group A site. Conceptual site layouts of the SVE systems for SWMU I/Area
2, Area 1 Building 237, and Area 3 are shown in Figures 9-3, 9-4, and 9-5, respectively.
Predesign soil-gas sampling will be performed at the areas designated for SVE remediation. This
investigation will be expanded as needed to define the lateral and vertical extent of
contamination above the soil-gas cleanup standard. The SVE systems will remove VOCs from the
vadose zone. Depending on the extent of VOC contamination at each Group A site, an array of
extraction wells will be installed and screened in the vadose zone. Approximately ten extraction
wells will be reguired for SWMU I/Area 2, five for Area 1 Building 237, and eight for Area 3
(Montgomery Watson 1996a). The radius of influence of the SVE wells is estimated to be 40 feet
based on the soil lithology. The number of SVE wells will be modified as necessary to address
the extent of contamination associated with the northern portion of the IWPL (centered between
manhole W-5 and SB-463), SWMU 1 /Area 2, Area 1 Building 237, and Area 3. Additional SVE wells
or optimization technigues will be used to address all soil-gas concentrations above the
cleanup standard.

9.6.9 An SVE system, including a treatment pad and piping to connect the wells to a mobile
blower system, will be installed at each Group A site. Air extracted from the SVE wells will be
-------
treated with vapor-phase GAG before discharge to the atmosphere. Techniques other than cycling
the system will be evaluated as needed to achieve the cleanup standard. It is assumed that each
SVE system will operate continuously for only six months because of the low mass of VOC
contamination.

9.6.10 The selected remedy includes continued groundwater monitoring to evaluate the performance
of the selected remedy (see Section 9.1 and Table 9-2).

9.6.11 Conventional drilling equipment can be used to install the SVE wells. Treatability
studies may be required before full-scale implementation to increase the accuracy of the design
parameters (e.g., SVE well radius of influence and blower specifications).

9.6.12 The estimated costs to implement SVE and to achieve soil-gas cleanup levels at each
Group A site include installing air extraction vents, renting mobile SVE systems (including
vapor-phase GAG treatment units), piping, and soil-gas confirmation sampling (less expensive
and more accurate than soil sampling). The present worth of the treatment systems for the Group
A sites is $266,000 (SWMU I/Area 2), $140,000 (Area 1 Building 237), and $242,000 (Area 3). The
total cost for all Group A sites is $648,000. The basis for these cost estimates is included in
Tables 9-4, 9-5, and 9-6, respectively.

9.7 Group B Sites

9.7.1 SWMU 4 - Storm Drain Lagoon

9.7.1.1 Alternative 3 (Limited Excavation and Disposal) is the selected remedy for SWMU 4.
SWMU 4 is a storm water detention pond that collects all storm water runoff from DDJC-Tracy
through a network of underground storm drains and open surface drainage ditches. SVOCs (PAHs),
pesticides, and metals have been detected in the lagoon sediment and subsurface soil (see
Appendix C). Selenium, lead, and OC pesticides pose a threat to ecological receptors. Human
health is not threatened under the depot worker or construction worker scenario.

9.7.1.2 Because the concentrations of contaminants in the sediment and the soil beneath the
storm water pond do not indicate a current threat to groundwater quality, no further action to
protect groundwater quality is warranted at SWMU 4. Four points support this conclusion.

9.7.1.3 First, the October 1996 subsurface sampling results (not included in the RI/FS) show
that migration from the surface sediment to the subsurface soil is minimal. The analysis of
these results modifies the conclusions of the RI/FS (Montgomery Watson, 1996a). The
concentrations and numbers of analytes that exceed background or cleanup concentrations are much
lower in the soil samples collected at 1 to 1.5 feet below the bottom of the pond than in the
sediment samples collected from 0 to 6 inches below the bottom of the pond. The compounds that
are present in the soil at concentrations greater than background levels (DDD and the PCB
Arochlor 1260) have not been detected in groundwater samples from downgradient monitoring wells
(LM004AU and LM027AUA). Dieldrin was detected above the practical quantitation limit (3 Ig/kg)
in only one soil sample collected from deeper than 6 inches.

9.7.1.4 The data from fourteen surface sediment samples (0 to 6 inches below the bottom of the
pond) collected during the remedial investigation (Montgomery Watson, 1996) and 18 subsurface
soil samples collected above the water table (1 to 1.5 feet below the bottom of the
pond)(Radian, 1996e) indicate that the number of compounds and their concentrations decrease
with depth beneath the storm water pond (see Appendix C. The surface sediment samples had one to
five SVOCs reported; however, no SVOCs were reported in the subsurface soil samples. One PCB
(Arochlor 1260) was detected in eight surface sediment samples at concentrations of 41 to 459
Ig/kg; however, this contaminant was only detected in 1 of the 18 subsurface soil samples (at a
concentration of 160 Ig/kg).

9.7.1.5 No urea-carbonate pesticides or chlorinated herbicides were reported in the subsurface
soil samples. The pesticide DDD was detected in all the surface sediment samples at
concentrations of 31 to 2,310 Ig/kg. Although this compound was detected in 14 of the 18
subsurface soil samples from 1 to 1.5 feet below the bottom of the pond, the concentrations
ranged from 1.5 to 380 Ig/kg, and only four samples had concentrations above background soil
concentrations (28.1 Ig/kg). The concentrations of DDT, which were detected in four subsurface
soil samples, and DDE, detected in ten subsurface soil samples, were all less than the
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background soil concentrations of 2,565 Ig/kg and 1,284 Ig/kg, respectively. Dieldrin was
reported in four surface sediment samples and four subsurface soil samples; however, the highest
reported concentration in the subsurface soil (6.5 Ig/kg) was lower than the lowest
concentration in the surface sediment samples.

9.7.1.6 Second, the de-ionized water waste extraction test (DI-WET) results for subsurface soils
do not indicate any confirmed impacts to water guality. One subsurface soil sample that had
measurable concentrations of DDE (73 Ig/kg), ODD (380 Ig/kg), DDT (1.1 Ig/kg), and dieldrin (2.7
Ig/kg) was subjected to the DI-WET to determine what fraction of the compounds may be leachable.
Analyses of the leachate from the sample only showed reportable concentrations of DDE (0.13
Ig/L) and ODD (1.1 Ig/L. DDT and dieldrin concentrations were below reporting limits in the
leachate. Although the leachate results suggest that there is potential for the freguently
reported ODD and DDE to affect groundwater adversely, neither ODD nor DDE has been reported in
any groundwater samples collected from LM004AU and LM027AUA, the downgradient monitoring wells.

9.7.1.7 Third, only dieldrin has been detected in both surface sediment and subsurface soil
samples and in downgradient monitoring wells. Only dieldrin (one of six samples from LM004AU and
one of 11 samples from LM027AUA), monuron (two of four samples from LM027AUA, and none from
LM004AU), diuron (one of two samples from LM004A, and three of four from LM027AA), simazine (one
of one from LM027AUA), and manganese (one of one from LM027AUA) detections have indicated any
adverse impact on groundwater. However, dieldrin is the only one of these compounds reported in
the groundwater samples that was also reported above background levels in the surface sediment
or subsurface soil samples from the pond.

9.7.1.8 Finally, dieldrin has not been measured in downgradient monitoring wells since 1994.
Dieldrin has been detected in one of six LM004AU groundwater samples and one of 11 LM027AUA
samples. In July 1993, a dieldrin concentration of 0.011 Ig/L was measured at LM004AU. In 1995
and 1996, all dieldrin results were below the reporting limit of 0.10 Ig/L. Between 1987 and
1993, dieldrin concentrations at LM027AUA ranged from less than 0.005 Ig/L (detection limit) to
0.11 Ig/L. All dieldrin results were less than the reporting limit (0.1 Ig/L) in 1995 and 1996.

9.7.1.9 In conclusion, the surface sediment, subsurface soil, soil leachate, and groundwater
results suggest that SWMU 4 is not now, and is unlikely to be in the future, a source of
groundwater contamination. Although there has been an almost constant downward driving force of
standing storm water in the pond, contaminants have not been leached into the groundwater at
levels that would cause groundwater concentrations to exceed background levels during the 25
years that the pond has been used. The groundwater analyses do not indicate conclusively that
the dieldrin, monuron, and diuron detected in the groundwater samples can be attributed to the
storm water pond. There is no clear evidence that the remediation of the soil at this site would
have any effect on groundwater guality. This analysis modifies the conclusions of the RI/FS.

9.7.1.10 The cost of excavating all surface sediment and subsurface soils with analyte
concentrations that could potentially impact background groundwater guality (based on
eguilibrium partitioning limits) is estimated as $700,000. The above analysis shows that the
benefits associated with excavation to protect groundwater guality at SWMU 4 are doubtful, and
funding excavation to address unlikely groundwater impacts is not warranted at this site.
Therefore, the selected remedy is based on cleanup standards to protect ecological receptors.

9.7.1.11 A thorough analysis of ARARs is provided in Section 10.5.2. Sediment cleanup standards
for SWMU 4 were developed from ecological assessment results (see Appendix D). The cleanup
standards are:

SWMU 4 Cleanup
Analytes Standards (Ig/kg)
Total DDK 241
Lead 5,130
Selenium 616
Preliminary standards: see discussion below.

9.7.1.12 Cleanup standards for total DDK, lead, and selenium are risk-based concentrations
(see Section 6.6.5). These standards were estimated using literature values rather than site-
specific bioaccumulation factors. Additional data will be collected to obtain site-specific
bioaccumulation factors, and to evaluate the effects of the sediment on surface water. These
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cleanup standards and the extent of excavation will be evaluated and revised as jointly
determined by DDJC-Tracy and the agencies. Any modification of the cleanup standards will be
made through an explanation of significant differences to this ROD.

9.7.1.13 In addition to the cleanup standards identified for sediments, any discharge from SWMU
4 to the local irrigation canal must meet the freshwater chronic ambient water guality criteria
(AWQC) for protection of aguatic life (U.S. EPA, 1988). Samples collected in early October 1994
exceeded the freshwater chronic AWQC for DDT (1.0 x 10 -3 Ig/L) and dieldrin (1.9 x 10 -3 Ig/L).
The following standards for storm water discharge will be applied.

Storm Water
Discharge
Analytes Standards
DDT 0.1*
Dieldrin 0.05*
* For these compounds, results above the estimated detection limit (see Table 9-7)
will be reported as trace amounts and will be evaluated. Cases where the actual
detection limit differs significantly from the estimated detection limit because
of matrix or other effects will be flagged.

9.7.1.14 The storm water pond will only receive storm water. It is uncertain if the storm water
discharge will exceed the AWQC; however, the concentrations will be confirmed by sampling (under
the storm water pollution prevention program) at least two discharge events per year (the first
event of the year and one other) for the next five years and evaluated in the first five-year
review. The potential carryover of sediment from the pond will also be evaluated. If
contaminants (filtered and unfiltered water samples) exceeding the discharge standard or
contaminated sediment are found in the discharge, DDJC will evaluate and identify an appropriate
modification of the selected remedy (e.g., additional excavation, sediment traps, etc.) to
achieve the discharge reguirements.

9.7.1.15 The selected remedy includes dewatering the storm drain lagoon, construction of a
sediment trap at the northern inlet and an overflow weir for discharge to surface water at the
outlet, excavating sediment contaminated with pesticides and selenium (Figure 9-6), and
transporting the sediment to a disposal facility (Class II municipal facility is anticipated)
for disposal. The need for additional sediment controls on the southern inlet will be evaluated.
Sediment samples will be collected for analysis during the remedial action to ensure that
sediment remaining across the bottom of the lagoon does not exceed the risk-based concentrations
for ODD, DDE, DDT, and selenium that are protective of ecological receptors or cause any
discharge from SWMU 4 to exceed the AWQC for the protection of aguatic life. The excavated
sediment should not be considered a listed hazardous waste under RCRA.

9.7.1.16 Groundwater sampling for SVOCs and pesticides/herbicides will be performed as part of
the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected
remedy. Lead and selenium are potential threats to ecological receptors only and do not post a
threat to groundwater guality. As stated in Section 9.1, concentrations of COCs exceeding the
following concentrations will be evaluated in the Annual Well Monitoring Reports.
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Groundwater
Concentrations
Requiring
Analytes Evaluation (Ig/L)
Bis(2-ethylhexyl)phthalate 10*
Carbaryl 60
Carbofuran 18
Chlordane 0.1*
2,4-D 70
Dieldrin 0.05*
Fluoranthene 280
Phenanthrene 10
Pyrene 210
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.1.17 At a date to be agreed upon, far enough in advance of the 5-year CERCLA review
meeting so that relevant information can be presented, DDJC Tracy will collect and analyze
sediment samples from SWMU 4 for the pesticides of concern. If pesticide levels are not found to
be protective of the ecological receptors, DDJC Tracy will take action to restore the ecological
protectiveness level in the sediment. This action, depending on the consensus of the group,
could be performed under CERCLA or some other program, such as the Storm Water Protection
Program. In either case DDJC would agree to install sediment traps on the inlet to the storm
water detention pond to prevent any future buildup of sediments if the selected remedy does not
demonstrate adequate permanence.

9.7.1 .18 The selected remedy reduces the toxicity and volume of sediment and surface water COCs
at the site because it removes the contaminated sediment from the storm drain lagoon. The
selected remedy is protective of human health and the environment. Because the storm drain
lagoon will remain in service as part of the DDJC-Tracy storm water system, the appropriate best
management practices, as identified in the DDJC-Tracy Storm Water Pollution Prevention Plan,
will be used to ensure that future storm water pollution is minimized. The present worth cost of
this alternative is estimated at $855,520. The basis for this cost estimate is included in Table
9-8.

9.7.1 SWMU 6 - Building 28 Sunp

9.7.2.1 Alternative 4 (Excavation and Disposal) is the selected remedial alternative for SWMU 6.
SWMU 6 consisted of a 250-gallon concrete sump located on the west side of Building 28; this
building was used to repackage materials from damaged containers. Wastes from this recoup
operation were collected in the concrete sump, pumped into 55-gallon drums, and then removed to
a Class I or other disposal site. The sump was removed in 1977; an asphalt patch at the site
marks the location of the excavation. RI results indicate that pesticide and herbicide
contamination in the soil is limited to the area immediately adjacent to the sump excavation and
from depths below the sump excavation to directly above the water table. The Baseline Risk
Assessment (BRA) results show no potential human health or ecological risks at SWMU 6. Vadose
zone modeling results indicate that pesticides (dicamba, dieldrin, endrin, heptachlor, 2,4,5-T,
and lindane) pose a potential threat to background groundwater quality. Thus, the recommended
alternative will permanently remove the potential threat posed to groundwater by pesticides in
the soil.

9.7.2.2 A thorough evaluation of ARARs is provided in Section 10.6.2. Cleanup standards for SWMU
6 were developed from vadose zone modeling (Montgomery Watson, 1996a), which identified
potential threats to background groundwater quality at this site. The cleanup standards were
developed to protect background groundwater quality to levels consistent with Water Quality
Goals (CVRWQCB, 1993). The proposed cleanup standards are:
-------
SWMU 6
Cleanup standards
Analytes (Ig/kg)
Dicamba 10
Dieldrin 3
Endrin 3
Heptachlor 1.5
Lindane 1.7
2,4,5-T 5

9.7.2.3 The equilibrium partitioning limits developed in the RI/FS (see Table 6-9 for summary)
provided very conservative estimates of the soil concentrations required to protect background
groundwater quality. These limits correspond to the maximum concentration expected in soil pore
water and do not account for an expected decrease in concentration resulting from migration
through less contaminated or clean soils to groundwater (see Figure B-ll). Furthermore, only
lindane has impacted groundwater at SWMU 6 to date. Because of these factors, it was considered
appropriate to use a laboratory reporting limit corresponding to the lowest concentration that
can be reproducibly detected as verified by the use of a low-level standard (Appendix F). This
analysis modifies the cleanup standards presented in the RI/FS (Montgomery Watson, 1996a).

9.7.2.4 The selected remedy includes excavating approximately 100 cy of soil contaminated with
pesticides from SWMU 6 (Figure 9-7). Confirmation samples will be collected to ensure that
cleanup standards will be achieved. A natural gas line at the site must be taken out of service
during the excavation. Approximately 60 cy of soil will be transported to a Class I or Class II
off-site disposal facility, depending on the level of contamination. Clean soil imported from
off-site will be used to backfill the excavated areas.

9.7.2.5 Groundwater sampling for SVOCs and pesticides/herbicides will be performed as part of
the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected
remedy. As discussed in Section 9.1. concentrations of CCCs exceeding the following levels will
be evaluated in the Annual Well Monitoring Reports.

Groundwater
Concentrations
Requiring Evaluation
Analytes (Ig/L)
Dieldrin 0.05*
Dicamba 210
Endrin 2
Heptachlor 0.01*
Lindane 0.03
2,4,5-T 70
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.2.6 This alternative is protective of human health and the environment. It removes the
threat to groundwater posed by the contaminated soil. The present worth of this alternative is
$45,000 for Class II disposal or $65,000 for Class I disposal. The basis for these cost
estimates is included in Tables 9-9 and 9-10.

9.7.3 SWMU 7 - Burn Pit No. 1

9.7.3.1 Alternative 2 (Institutional Controls) is the selected remedy for SWMU 7. SWMU 7
consists of a total of seven reported pits that were operated before the construction of the
warehouse and buildings at the site. The pits were used for the disposal of medical supplies,
narcotics, general Pharmaceuticals, radiological supplies, and electron tubes. The pits may have
been up to 16 feet deep; ashes were removed and transported to off-site landfills during the
later years of operation (WCC, 1992a). BRA results show no potential risks to human or
ecological receptors. Vadose zone modeling results indicate that total petroleum hydrocarbons as
diesel (TPHD) in Pit D, VOCs in Pit F, SVOCs in Pit C, and pesticides and herbicides (2,4-D,
linuron, dieldrin, and simazine) detected in SWMU 7 soils may pose a threat to background
-------
groundwater quality uses at two of the pits; however, this threat has not been confirmed by the
results of groundwater monitoring conducted to date. Because portions of the seven pits are
covered by buildings and groundwater contamination is not present at the site, institutional
controls appear warranted as the recommended alternative. By covering portions of the pits, the
building foundations prevent adverse exposure to receptors and mitigate groundwater threats by
reducing rainwater infiltration.

9.7.3.2 A thorough evaluation of ARARs is provided in Section 10.7.2. Cleanup standards for SWMU
7 were developed from vadose zone modeling (Montgomery Watson, 1996a), which identified
potential threats to background groundwater quality at this site. The cleanup standards were
developed to protect background groundwater quality to levels consistent with Water Quality
Goals (CVRWQCB, 1993). The proposed cleanup standards are:

SWMU 7
Cleanup
standards
Analytes (Ig/kg)
1,2-Dichloroethene (Pit F) 10
Trichloroethene (Pit F) 5
Bis(2-ethylhexyl)phthalate (Pit C) 330
2,4-D 25
Dieldrin (Pit C and D) 3
Linuron (Pit C and D) 200
Simazine (Pit D) 10
TPH as diesel (Pit D) 100,000

9.7.3.3 The TPHD cleanup standard was developed from the Tri-Regional Guidelines. The
equilibrium partitioning limits developed in the RI/FS (see Table 6-9 for summary) provided
very conservative estimates of the soil concentrations required to protect background
groundwater quality. These limits correspond to the maximum concentration expected in soil
water and do not account for an expected decrease in concentration resulting from migration
through less contaminated or clean soils to groundwater (Figures B-12 and B-13). Furthermore, of
the COCs, only bis(2-ethylhexyl)phthalate has been detected in groundwater at SWMU 7 to date.
Because of these factors, it was considered appropriate to use a laboratory reporting limit
corresponding to the lowest concentration that can be reproducibly detected as verified by the
use of a low-level standard (Appendix F). This analysis modifies the cleanup standards presented
in the RI/FS (Montgomery Watson, 1996a).

9.7.3.4 The selected remedy includes the following components:

• The real property records for Buildings 19 and 21 will be modified such that the
signatory parties to the ROD must be contacted at least one month before any
demolition or construction activities that could expose contaminated soil. The DDJC-
Tracy Master Plan designates this area for industrial use only.

• Two additional monitoring wells will be installed downgradient from SWMU 7 (see
Figure E-2).

• Groundwater will be monitored for as long as contaminants remain in place with
concentrations that could threaten groundwater quality or until it can be
demonstrated that no further threat to groundwater quality exists.

9.7.3.5 The selected remedy includes land use restrictions around the disposal pits (at
Buildings 19 and 21) where concentrations of pesticides and other COCs have been detected. If
ownership of the installation is transferred to private or nonfederal entities in the future,
restrictive covenants, written into the land property deed, could be established that would
prevent schools, playgrounds, hospitals, and housing from being built at the sites until COCs
are below levels of concern. Cooperation among the U.S. Army, San Joaquin County, and Cal-EPA
will be required to enact the restrictions on access and land use.

9.7.3.6 Two new wells will be installed as part of the selected remedy (Figure E-2). One of the
additional wells will be monitored for SVOCs and both wells will be monitored for
Organophosphorus (OP) pesticides, OC pesticides, chlorinated herbicides, and carbamate/urea
-------
pesticides annually. In addition, both new wells will be monitored for dioxins/furans
(unconfirmed chemicals of potential concern) semiannually for one year. Monitoring for
dioxins/furans in the two new wells was incorporated into the selected remedy in lieu of
performing additional investigation activities at SWMU 7. The new wells will be sufficient to
assess any groundwater contamination emanating from the burn pits without performing additional
monitoring of LM43A. Monitoring of LM095AU will be continued as part of the selected remedy.

9.7.3.7 Groundwater sampling for SVOCs and pesticides/herbicides will be performed as part of
the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected
remedy. As discussed in Section 9.1, concentrations of COCs exceeding the following levels will
be evaluated in the Annual Well Monitoring Reports.

Groundwater
Concentrations
Reguiring
Evaluation
Analytes (Ig/L)
1,2-Dichloroethene (Pit F) 6
Trichloroethene (Pit F) 2.3
Bis(2-ethylhexyl) phthalate (Pit C) 10*
Linuron 2*
2,4-D 70
Simazine 4
Dieldrin (Pit C and D) 0.05*
TPH as diesel 100
Total dioxins/furans 0.01*
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.3.8 At least two additional consecutive rounds of groundwater monitoring for dioxins/furans
are reguired as part of the selected remedy. This monitoring and interpretation was agreed upon
as a substitute for extending the remedial investigation. The potential threat to groundwater
from dioxins/furans will be reevaluated in the first five-year CERCLA review.

9.7.3.9 Five-year site reviews are reguired by the CERCLA guidance because contaminants will be
left in place.

9.7.3.10 Institutional controls do not reduce the toxicity, mobility, or volume of the COCs in
the soils. The selected remedy is protective of human health under current land use conditions,
and because it implements land use restrictions, it is also protective of human health under
future land use conditions. The present worth of this alternative is $208,000. The basis for
this cost estimate is included in Table 9-11.

9.7.4 SWMU 8 - Burn Pit No. 2

9.7.4.1 Alternative 4 (Excavation and Disposal) is the selected remedy for SWMU 8. SWMU 8 is a
single large burn pit that is approximately 16 feet deep, 250 feet long, and 30 feet wide.
Phthalates, PAHs, pesticides, petroleum hydrocarbons, dioxin/furans, and metals have been
released to the soil from disposal activities associated with SWMU 8. In general, the elevated
concentrations of these constituents are limited to the middle fill horizon (starting at
approximately 4 feet below ground surface [bgs]) and the lower fill horizon (down to
groundwater) of the central and northern portion of the pit. The BRA results indicate that OC
pesticides (chlordane, DDD, DDE, DDT, and dieldrin) detected in soil at SWMU 8 could pose
potentially significant risks to future construction workers. The selected remedy would remove
the contaminated soils that contribute to a risk in excess of 1x10 -6. The hazard index at this
site would be approximately 8 following remediation, but this level reflects that the presence
of manganese (upper confidence limit [UCL] is 630 mg/kg) is below the background threshold
concentration (805 mg/kg). The selected remedy is therefore considered protective of human
health under current and future land use conditions.

9.7.4.2 The vadose zone modeling results for SWMU 8 indicate that SVOCs, pesticides/herbicides,
-------
and petroleum hydrocarbons detected in deep soils could migrate to groundwater and potentially
threaten background groundwater guality. SWMU 8 is considered a primary source area of dieldrin
contamination in groundwater. In addition, the levels of total petroleum hydrocarbons as
gasoline (TPHG), TPHD and total petroleum hydrocarbons as motor oil (TPH-MO) in soil at SWMU 8
are above the State Water Resources Control Board (SWRCB) Tri-Regional Guidelines of 1,000
Ig/kg, 10,000 Ig/kg, and 10,000 Ig/kg, respectively, for TPH within five feet of groundwater.

9.7.4.3 A thorough evaluation of ARARs is provided in Section 10.8.2. Cleanup standards for SWMU
8 were developed using risk-based concentrations and vadose zone modeling (Montgomery Watson,
1996a), which identified potential threats to background groundwater guality at this site. The
cleanup standards developed to protect background groundwater guality are consistent with Water
Quality Goals (CVRWQCB, 1993) and SWRCB Tri-Regional Guidelines. The proposed cleanup standards
SWMU 8 Cleanup
Analytes Standards (Ig/kg)
Total chlordane 10
2,4-D 25
DDD 81
DDT 7
Total DDK 30,000
Dieldrin 2
Lindane 1.7
Linuron 200
MCPA 5,000
Simazine 10
bis(2-ethylhexyl)phthalate 330
Diethylphthalate 330
2,4-Dinitrotoluene 330
Naphthalene 330
TPH as gasoline 1,000
TPH as diesel 10,000
TPH as motor oil 10,000

9.7.4.4 The basis for the soil cleanup standards for DDD and DDT is the calculated eguilibrium
partitioning limit developed in the RI/FS (see Table 6-9 for summary) that is protective of
beneficial uses. The cleanup standard for total DDK is a risk-based concentration
corresponding to increased lifetime cancer risk of 1X10 -6. The soil cleanup standards for TPHG,
TPHD, and TPH-MO were determined using the scoring criteria of the Tri-Regional guidance.

The basis for the soil cleanup standards for 2,4-D, bis(2-ethylhexyl)phthalate, naphthalene,
total chlordane, dieldrin, lindane, linuron, MCPA, simazine, diethylphthalate, and 2,4-dini-
trotoluene is the analytical method reporting limit. The eguilibrium partitioning limits
provided very conservative estimates of the soil concentrations reguired to protect background
groundwater guality. These limits correspond to the maximum concentration expected in soil water
and do not account for an expected decrease in concentration resulting from migration through
less contaminated or clean soils to groundwater (Figures B-14 through B-16). Chlordane, DDD,
DDE, and DDT have been detected in groundwater at SWMU 8 to date. The disposal area for these
compounds is well defined, and soil will be excavated to the water table so all COCs will be
addressed. Therefore, it was considered appropriate to use a laboratory reporting limit
corresponding to the lowest concentration that can be reproducibly detected as verified by the
use of a low-level standard (Appendix F). This analysis modifies the cleanup standards presented
in the RI/FS (Montgomery Watson, 1996a).

9.7.4.5 The selected alternative includes excavating approximately 8,000 cy (10,400 tons) of
contaminated soil and debris from the burn pit at SWMU 8 (Figure 9-8). The soil and debris will
be excavated to approximately 14 feet bgs (the limits of the disposal area are well defined).
Soil will be removed to the approximate depth of the water table. From the COCs detected in
SWMU 8 soils, it is assumed that 3,400 tons of contaminated soil will be disposed of at a Class
I or other disposal facility in compliance with state and federal laws and regulations.
Approximately 2,400 tons of debris (concrete, wood, etc.) will be disposed of at a Class III
facility. Clean soil imported from off-site will be used to backfill the excavated areas.
Excavation and disposal will permanently remove all known soil with contaminant concentrations
-------
above cleanup standards. Therefore, the selected alternative permanently prevents migration of
any known soil constituents to groundwater (confirmation sampling is included in the remedy for
VOCs to address remaining data gaps). Given the relatively high levels of contaminants in the
former burn pit, construction workers should take necessary precautions to ensure worker health
protection during soil excavation activities. In addition, the presence of buried debris in the
former burn pit can make the excavation of the contaminated material difficult.

9.7.4.6 Confirmation sampling for the COCs and VOCs (soil gas) will be performed during site
remediation. Sampling for VOCs has been agreed to by the signatory parties as a substitute for
extending the remedial investigation at this site. The results of the confirmation sampling for
VOCs will be included in the construction report. Further actions at SWMU 8 will depend on the
magnitude of any VOCs reported. If VOC concentrations in soil-gas exceed the soil-gas cleanup
standard, an explanation of significant differences will be reguired to evaluate remedial
options.

9.7.4.7 Also included in the selected remedy for SWMU 8 is the installation of one new
monitoring well (see Table 9-2). This well and the two existing wells (LM97A and LM119A) near
the site will be monitored for OC pesticides over four guarters. This monitoring is included in
the selected remedy because the dieldrin plume predicted to be in groundwater downgradient of
the site by groundwater modeling has not been confirmed by historical groundwater monitoring
results. It is assumed that the new monitoring well will be installed in the zone of highest
concentrations of dieldrin at SWMU 8, approximately halfway between monitoring wells LM97A and
LM119A. The new monitoring well will also be monitored for dioxins/furans semiannually for one
year. If the dioxin/furan levels are above the water guality objectives, the Annual Well
Monitoring Report will be used to develop a strategy for continued monitoring or further action,
as needed.

9.7.4.8 Groundwater sampling for SVOCs and pesticides/herbicides will be performed as part of
the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected
remedy. As stated in Section 9.1, concentrations of COCs exceeding the following levels will be
evaluated in the Annual Well Monitoring Reports.

Groundwater
Concentrations
Reguiring
Analytes Evaluation (Ig/L)
Bis(2-ethylhexyl) phthalate 10*
Diethylphthalate 5,600
2,4-Dinitrotoluene 10*
Naphthalene 20
Chlordane 0.1*
2,4-D 70
DDD 0.15
DDE 0.1
DDT 0.1
Dieldrin 0.05*
Lindane 0.03
Linuron 2*
MCPA 380*
Simazine 4
Total dioxins/furans 0.01*
TPH as gasoline 50*
TPH as diesel 100
TPH as motor oil 100
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.4.9 The selected alternative reduces the toxicity and volume of all COCs in the soil at the
site and is therefore protective of human health and the environment. The alternative also
removes the threat posed to groundwater by the COCs in the soil. The present worth of this
alternative is $2,823,000. The basis for this cost estimate is included in Table 9-12.
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9.7.5 ST/JMU 20 - Aboveground Solvent Tank/Building 26 Recoup Operations and Area 1 Building 10

9.7.5.1 Alternative 3 (SVE, Excavation and Disposal, Natural Attenuation) is the selected remedy
for SWMU 20 and Area 1 Building 10. SWMU 20 was an aboveground solvent tank located in Building
10. SWMU 20 also contains a 4-foot-by-5-foot sump (at Manhole W-l) located outside the
northwestern corner of Building 10 and a 2-foot-by-3-foot sump (at Manhole W-3) located outside
the northeastern corner of Building 10. VOCs and SVOCs were detected in sludges collected from
the two sumps, the floor drain, and soil samples collected beneath these features. Area 1 of
Building 10 is also located near the northeast corner of Building 10. Due to the proximity of
Area 1 Building 10 to SWMU 20 and the similarity of the COCs at both locations, these sites were
evaluated together in the RI/FS. The selected remedy also addresses potential VOCs associated
with the southern portion of the IWPL in the immediate vicinity of SWMU 20 (between manholes W-l
and W-3 and the area between SB430 and SB432). The SVE portion of the remedy will be coordinated
with the remedy for the Group A sites.

9.7.5.2 BRA results indicate that SWMU 20 and Area 1 Building 10 do not pose potential risks to
human health under either the current depot worker or the future construction worker exposure
scenarios. In addition, there are no ecological receptors at SWMU 20 and Area 1 Building 10.
Thus, Alternative 3 is protective of human health under current and future land use conditions.
Vadose modeling results show that VOCs, SVOCs, TPHD, and pesticides/herbicides could pose a
threat to groundwater at the site.

9.7.5.3 The recommended alternative includes the excavation and disposal of the two sumps (at
manholes W-l and W-3) in the vicinity of Building 10 and the floor drain at Building 26 (Figure
9-9). Confirmation samples will be collected to ensure that cleanup standards are achieved. The
soil beneath the sumps and the floor drain will also be excavated and disposed of. The excavated
soil will be transported to a Class I or other off-site disposal facility. Clean soil imported
from off-site will be used to backfill the excavated areas. Geotechnical concerns should be
considered when excavating soils adjacent to Building 10. In addition, this alternative may
disrupt underground utilities.

9.7.5.4 A thorough evaluation of ARARs is provided in Section 10.9.2. Cleanup standards for SWMU
20 were developed using vadose zone modeling (Montgomery Watson, 1996a), which identified
potential threats to background groundwater quality at this site. The cleanup standards
developed to protect background groundwater quality are consistent with Water Quality Goals
(CVRWQCB, 1993) and the SWRCB Tri-Regional Guidelines. The proposed soil cleanup standards are:

SWMU 20 Cleanup
Analytes Standards (Ig/kg)
Trichloroethene 5
Ethylbenzene 5
Xylenes 5
Diethylphthalate 330
2,4-Dinitrophenol 830
Pentachlorophenol 830
2,4,6-trichlorophenol 330
Dieldrin 2
Methiocarb 500
Linuron 200
MCPA 5,000
TPH as diesel 10,000

9.7.5.5 The soil cleanup standard for TPHD was developed using the Tri-Regional Guidelines. The
equilibrium partitioning limits developed in the RI/FS (see Table 6-9 for summary) provided very
conservative estimates of the soil concentrations required to protect background groundwater
quality. These limits correspond to the maximum concentration expected in soil water and do not
account for an expected decrease in concentration resulting from migration through less
contaminated or clean soils to groundwater (Figures B-17 and B-18). Monuron, diuron, alpha-BHC,
methiocarb, and 2,4-D have also impacted groundwater quality. These pesticides/herbicides were
detected in sludges, but were not encountered at depth (Figure B-18). Significant dilution is
therefore anticipated. Because of these factors, it was considered appropriate to use a
laboratory reporting limit corresponding to the lowest concentration that can be reproducibly
detected as verified by the use of a low-level standard (Appendix F). This analysis modifies the
-------
cleanup standards presented in the RI/FS (Montgomery Watson, 1996a).

9.7.5.6 Groundwater sampling for VOCs, SVOCs, and pesticides/herbicides will be performed as
part of the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the
selected remedy. As stated in Section 9.1, concentrations of COCs exceeding the following levels
will be evaluated in the Annual Well Monitoring Reports.

9.7.5.7 SVE will be performed to remediate the TCE-contaminated soil detected at Area 1 Building
10 (near SB 108) and near SB431. SVE is expected to be effective in reducing TCE concentrations
at these locations. Predesign soil-gas sampling will be conducted at the areas designated for
SVE remediation at SWMU 20, the adjacent portion of the IWPL, and Area 1 Building 10. The
investigation will be expanded from the identified areas as needed to define the lateral and
vertical extent of contamination above the specified soil-gas cleanup standard. Additional SVE
wells will be added as needed to address soil-gas concentrations in excess of the soil-gas
cleanup standard.

9.7.5.8 The cleanup standard for TCE in soil gas is:

SWMU 20
Soil Gas Cleanup
Analyte Standard (Ig/L)
Trichloroethene 1.9 (350 ppbv)

9.7.5.9 This concentration will also be used to determine if it is necessary to evaluate further
action to address the TCE associated with the IWPL between manholes W-l and W-3 and between
SB430 and SB432 (this area will be expanded as reguired to attain the soil-gas cleanup
standard). The SVE systems will address VOC concentrations above the cleanup standards.

9.7.5.10 The vadose zone cleanup will be achieved when:

1. The concentrations of TCE present in soil gas are egual to or less than the
cleanup standard;

2. It is demonstrated that the remaining TCE can no longer cause leachate
concentrations to exceed the aguifer cleanup standards; and

3. TCE has been removed to the extent technically and economically feasible.
This evaluation will include, at a minimum, the following factors:

a) The total cost and duration of continued operation of the SVE
system until aguifer cleanup standard are met.

b) The total cost and duration of continued groundwater treatment to
meet aguifer cleanup standards.

9.7.5.11 The signatory parties to the ROD will jointly decide when the cleanup of VOCs in the
vadose zone has been achieved and when the SVE system be shut off permanently. The evaluation of
technical and economic feasibility that will serve as the basis for this decision will be a
primary document.

9.7.5.12 The signatory parties to the FFA agree that DDJC-Tracy may cycle the SVE system on and
off to optimize the SVE operation and/or evaluate all feasibility analysis factors.

9.7.5.13 Phenols detected in the soil (SB432/432b) are anticipated to attenuate as they migrate
to groundwater. The maximum concentration of phenols measured in the RI/FS (Montgomery Watson,
1996a) is less than five times the eguilibrium partitioning limit. This limit does not account
for any dilution of the soil water as a result of migration through less contaminated or clean
soil. To date, phenols have not been detected in groundwater, although they are very mobile in
sandy soils. They are known to form extremely stable complexes with clay particles, and these
-------
complexes could retard their mobility.

9.7.5.14 This alternative reduces the toxicity and volume of all COCs in the soil at the site.
The threat of COG migration to groundwater will be removed immediately on completion of the
excavation. The present worth of this alternative is $293,000. The basis for this cost estimate
is included in Table 9-13.

Groundwater
Concentrations
Reguiring Evaluation
Analytes (Ig/L)
Ethylbenzene 29
Xylenes 17
Trichloroethene 2.3
Tetrachloroethene 2*
Diethylphthalate 5,600
2,4-Dinitrophenol 50*
Pentachlorophenol 50*
2,4,6-Trichlorophenol 10*
Dieldrin 0.05*
Methiocarb 5
MCPA 380
Linuron 2*
TPH as diesel 100
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.6 SWMU 24 - Petroleum Waste Oil Tank

9.7.6.1 The selected remedy for SWMU 24 is Alternative 3 (Bioventing). SWMU 24 was a 500-gallon
Underground Storage Tank (UST) that was used to store petroleum wastes from materials testing in
Building 247 from 1961 to 1988. The UST was removed in 1988, and visibly contaminated soil from
the excavation was disposed of off-site. During the Phase I and II investigations, xylenes,
2-butanone, MIBK, petroleum hydrocarbons, and other organic compounds were detected in soils in
the vicinity of the tank excavation.

9.7.6.2 BRA results indicate that there is a potential health threat to future depot workers
exposed to toluene at SWMU 24. The hazard index associated with indoor air is presently
estimated at 0.7; however, if a building with poor ventilation were constructed over the
contamination, the hazard index could potentially exceed 1.0. Bioventing will reduce toluene
levels in soil and therefore is protective of human health under current and future land use
conditions. Vadose zone modeling results for SWMU 24 show that VOCs, SVOCs, petroleum
hydrocarbons, PCBs, and pesticides pose a threat to background water guality. Also, TPHG and
TPHD levels in the soil are above the SWRCB Tri-Regional Guidelines of 1 mg/kg and 10 mg/kg,
respectively, for TPH within five feet of groundwater.

9.7.6.3 A thorough evaluation of ARARs is provided in Section 10.10.2. Cleanup standards for
SWMU 24 were developed using vadose zone modeling (Montgomery Watson, 1996a), which identified
potential threats to background groundwater guality at this site. The cleanup standards
developed to protect background groundwater guality are consistent with Water Quality Goals
(CVRWQCB, 1993) and the SWRCB Tri-Regional Guidelines. The cleanup standards are:
-------
SWMU 24 Cleanup
Analytes Standards (Ig/kg)
Acetone 10
2-butanone 10
Ethylbenzene 10
2-hexanone 10
4-methyl-2-pentanone 10
Toluene 5
Xylenes 5
2,4-dimethylphenol 330
Fluoranthene 330
2-methylnaphthalene 330
4-methylphenol 330
Naphthalene 330
Phenanthrene 330
Phenol 330
Pyrene 330
Carbofuran 500
Lindane 1.7
Phorate 20
Ronnel 35
Aroclor 1260 30
TPH as gasoline 1,000
TPH as diesel 10,000

9.7.6.4 Soil cleanup standards for TPHG and TPHD were developed using the scoring criteria of
the Tri-Regional guidance. The eguilibrium partitioning limits developed in the RI/FS (see
Table 6-9 for summary) provided very conservative estimates of the soil concentrations reguired
to protect background groundwater guality. These limits correspond to the maximum concentrations
expected in soil water and do not account for an expected decrease in concentrations resulting
from migration through less contaminated or clean soils to groundwater (Figure B-19). Soil
sampling data indicate that the concentrations and numbers of analytes detected generally
decrease with increasing sampling depth. Significant dilution is therefore anticipated. Because
of these factors, it was considered appropriate to use a laboratory reporting limit
corresponding to the lowest concentration that can be reproducibly detected as verified by the
use of a low-level standard (Appendix F) as a basis for all other cleanup standards. This
analysis modifies the cleanup standards presented in the RI/FS (Montgomery Watson, 1996a).

9.7.6.5 Bioventing (Figure 9-10) is expected to biodegrade the COCs that pose the greatest
threat to groundwater. Therefore, the recommended alternative reduces the potential for
migration of soil constituents to the groundwater and is protective of beneficial uses. PCBs and
pesticides are not fully remediated during bioventing treatment because these compounds are not
amenable to aerobic biodegradation. However, the threat to groundwater posed by PCBs and
pesticides is considered low relative to the threat posed by the other COCs. Pesticide
detections were infreguent, and none of the pesticides or PCBs detected in soil has been
detected in groundwater near the site. PCBs were only detected in one boring (SB-192), and the
concentrations of both PCBs and pesticides decreased with depth. Removing these compounds
through excavation beside and under Building 247 would be expensive (approximately $263,000),
and the threat to groundwater is guestionable at this site. Therefore, groundwater monitoring
for PCBs and pesticides is considered adeguate to address the remaining threat to groundwater.
Groundwater will be monitored as long as contaminants remain in place or until it can be
demonstrated that no further threat to groundwater exists.

9.7.6.6 The extent of soil contamination is very limited at SWMU 24; thus, only a bioventing
system consisting of one air injection well is necessary. The conceptual site layout for the
bioventing system is shown in Figure 9-9. The selected alternative includes installing one air
injection well and a pad-mounted blower system at SWMU 24. The well would be screened from 6
feet bgs to 16 feet bgs. An air injection rate of 0.5 pore volumes per day (Dupont, 1993) was
assumed for the conceptual design. With this air injection rate, the total operating flow rate
for the bioventing system will be approximately 4 standard cubic feet per minute (scfm). The
bioventing system will be operated until the cleanup standards provided above have been
achieved. Predesign soil-gas sampling will be conducted; pending the results of the soil-gas
sampling, bioventing may be preceded by SVE (if VOCs resistant to biodegradation are measured).
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The immediate implementation of SVE will be evaluated before bioventing if the following cleanup
standards are exceeded.

SWMU 24 Soil
Gas Action
Analytes Levels (Ig/L)
Tetrachloroethene 5.4 (780 ppbv)
Trichloroethene 1.9 (350 ppbv)

9.7.6.7 Groundwater sampling for VOCs, SVOCs, and pesticides/herbicides will be performed as
part of the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the
selected remedy. As stated in Section 9.1, concentrations of COCs exceeding the following levels
will be evaluated in the Annual Well Monitoring Reports.

9.7.6.8 The selected remedy for SWMU 24 also includes the guarterly monitoring of well LM118A
for TPHG and TPHD for at least three guarters (Table 9-2). The purpose of this monitoring is to
assess the natural attenuation of petroleum hydrocarbons in the groundwater.

Groundwater
Concentrations
Reguiring Evaluation
Analytes (Ig/L)
Acetone 700
2-Butanone 4,200
Ethylbenzene 29
2-Hexanone 10
4-Methyl-2-Pentanone 40
Toluene 42
Xylenes 17
Trichloroethene 2.3
Tetrachloroethene 2*
TPH as gasoline 50*
TPH as diesel 100
Fluoranthene 280
2-Methylnaphthalene 10
4-Methylphenol 10
2,4-Dimethylphenol 140
Naphthalene 20
Phenol 4,200
Pyrene 210
PCBs (Arochlor 1260) 0.5
Carbofuran 18
Lindane 0.03
Phorate 0.5
Ronnel 0.5
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.6.9 The selected remedy reduces the toxicity, mobility, and volume of COCs in the soil at
the site. This remedy is protective of human health and the environment. The threat posed by the
migration of VOCs, SVOCs, and petroleum hydrocarbons to groundwater will be removed through the
biodegradation of these constituents. The present worth of this alternative is $166,000. The
basis for this cost estimate is included in Table 9-14.

9.7.7 SWMU 27 - Building 206 Roundhouse Sump and Area 1 Building 206

9.7.7.1 Alternative 3 (Excavation and Disposal) is the selected remedy for SWMU 27 and Area 1
Building 206. SVOCs, herbicides, PCBs, petroleum hydrocarbons, and metals have been released to
soils as a result of activities associated with SWMU 27. The distribution of these constituents
is primarily confined to the area within Building 206, mainly around the former service pit, the
former waste oil sump, and the former floor drain located within Building 206. Building 206,
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which is part of SWMU 27, is no longer in use and was demolished in April 1995. The floor slab
remains and the locomotive pit, service pit, and sump were filled with concrete.

9.7.7.2 BRA results indicate that there is a potential cancer risk greater than 1x10 -6 under
the depot and construction worker exposure scenarios. The potential cancer risk is based on
exposure to PAHs and PCBs. The selected remedy would reduce these risks to 1x10 -6 by
excavating contaminated soils to the specified cleanup standards for total PAHs and Arochlor
1260. No ecological receptors were identified at SWMU 27. TCE, 2,4-D, MCPA, 2,4,5-T, and TPH-MO
are potential threats to groundwater guality.

9.7.7.3 A thorough evaluation of ARARs is provided in Section 10.10.2. Cleanup standards for
SWMU 27 were developed using risk-based concentrations and vadose zone modeling (Montgomery
Watson, 1996a), which identified potential threats to background groundwater guality at this
site. The cleanup standards developed to protect background groundwater guality are consistent
with Water Quality Goals (CVRWQCB, 1993) and the Tri-Regional Guidelines. The cleanup standards
are:

SAMU 27 Cleanup
Analytes Standards (Ig/kg)
Benzo[a]pyrene 1,000
Total PAHs 15,000
Arochlor 1260 1,000
TCE 5
2,4-D 25
MCPA 5,000
2,4,5-T 5
TPH as motor oil 10,000

9.7.7.4 The basis for the sail cleanup standards for benzo(a)pyrene, total PAHs, and Arochlor
1260 is the Risk Based Concentration (RBC) where the cancer endpoint is 1x10 -6 . The cleanup
standard for TPH-MO was determined from the Tri-Regional Guidelines. Cleanup standards for
other COCs are based on laboratory reporting limits. The eguilibrium partitioning limits
developed in the RI/FS (see Table 6-9 for summary) provided very conservative estimates of the
soil concentrations reguired to protect background groundwater guality. These limits correspond
to the maximum concentrations expected in soil water and do not account for an expected decrease
in concentrations resulting from migration through less contaminated or clean soils to
groundwater (Figures B-20 and B-21). Soil sampling data indicate that the concentrations and
numbers of analytes detected generally decrease with increasing sampling depth (none of the COCs
was detected at a depth of greater than 10 feet). Significant dilution is therefore anticipated.
Because of these factors, it was considered appropriate to use laboratory reporting limits
corresponding to the lowest concentrations that can be reproducibly detected as verified by the
use of low-level standards (Appendix F) as a basis for all other cleanup standards. This
analysis modifies the cleanup standards presented in the RI/FS (Montgomery Watson, 1996a).

9.7.7.5 The recommended alternative (Figure 9-11) involves excavating the former waste oil sump,
which is presently filled with sand and capped with concrete; excavating soil contaminated with
PAHs, PCBs, petroleum hydrocarbons, and herbicides (2,4-D, MCPA, and 2,4,5-T) from beneath the
railroad tracks (between SB471 and SB470); and excavating soil contaminated with MCPA (a
herbicide) at SB469 (the area of a suspected herbicide spill). Soils will be excavated to 16
feet bgs around the former waste oil sump and to 5 feet bgs in the vicinity of SB469, SB470, and
SB471. A total of approximately 130 cy (170 tons) of soil and concrete will be excavated and
transported to an off-depot disposal facility. The level of soil contamination at SWMU 27
indicates that the excavated material will be disposed of at a Class I or other disposal
facility. Confirmation samples will be collected to ensure that the cleanup standards are
attained. Clean soil, imported from off-depot, will be backfilled to replace the excavated
material. The former service pit is not recommended for excavation and disposal because
contaminated sludge was previously removed from the pit, and the pit was filled with concrete.

9.7.7.6 Groundwater sampling for VOCs, SVOCs, and herbicides will be performed as part of the
Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected remedy.
Compounds with risk-based cleanup standards to protect human health do not threaten groundwater
guality and are not included in the monitoring program. As stated in Section 9.1, concentrations
of COCs exceeding the following levels will be evaluated in the Annual Well Monitoring Reports.
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Groundwater
Concentrations Requiring
Evaluation
Analytes (Ig/L)
Trichloroethene 2.3
2,4-D 70
MCPA 380*
2,4,5-T 70
TPH motor oil 100
* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.

9.7.7.7 This alternative reduces the toxicity and volume of all COCs in the soil at the site.
This alternative is protective of human health and the environment. The threat of COG migration
to groundwater will be removed by excavation. The present worth of this alternative is $112,000.
The basis for this cost estimate is included in Table 9-15.

9.7.8 Drum Storage Area - Building 30

9.7.8.1 Alternative 3, institutional controls, is the selected remedy for the Drum Storage Area
Building 30. The Drum Storage Area Building 30 is located in the southern portion of the depot,
near the Consolidated Subsistence Facility. The original area of the site was much larger, but
is now partially covered by the Consolidated Subsistence Facility, which was constructed in
1992. During construction of the facility, buried drums were discovered in the vicinity of the
Drum Storage Area Building 30. The site now encompasses a relatively small area between a
forklift ramp and the central office on the north side of the Consolidated Subsistence Facility.
Bis(2-ethylhexyl)phthalate, and di-n-butylphthalate were detected several times in soil samples
collected at the site. Benzyl alcohol and diethylphthalate were detected in only one sample.
Although phthalates are commonly introduced into environmental samples as part of laboratory
analytical procedures, the distribution and magnitude of the concentrations indicate that these
detected concentrations may be representative of site conditions.

9.7.8.2 A thorough evaluation of ARARs is provided in Section 10.12.2. Cleanup standards were
developed from vadose zone modeling (Montgomery Watson, 1996a) of potential threats to
background groundwater quality at this site. Groundwater data were not available for use as a
basis for selecting the remedy. The cleanup standards developed to protect background
groundwater quality are consistent with Water Quality Goals (CVRWQCB, 1993). The proposed soil
cleanup standards are:

Building 30
Cleanup
Standards
Analytes (Ig/kg)
Benzyl Alcohol 330
Bis(2-ethylhexyl) phthalate 330
Diethylphthalate 330
di-n-Butylphthalate 330

9.7.8.3 All cleanup standards correspond to the laboratory reporting limit (Radian, 1997). The
equilibrium partitioning limits developed in the RI/FS (see Table 6-9 for summary) provided
very conservative estimates of the soil concentrations required to protect background
groundwater quality. These limits correspond to the maximum concentration expected in soil
water and do not account for an expected decrease in concentrations resulting from migration
through less contaminated or clean soils to groundwater (Figure B-23). Benzyl alcohol and
diethylphthalate were only detected in one sample. Because of these factors, it was considered
appropriate to use laboratory reporting limits corresponding to the lowest concentrations that
can be reproducibly detected as verified by the use of low-level standards (Appendix F) as a
basis for all other cleanup standards. This analysis modifies the cleanup standards presented in
the RI/FS (Montgomery Watson, 1996a).

9.7.8.4 The selected remedy includes the installation of one monitoring well downgradient of the
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site. This well will be monitored for SVOCs to confirm that benzyl alcohol,
bis(2-ethylhexyl)phthalate, (diethylphthalate, and di-n-butylphthalate do not pose a threat to
background groundwater guality. Four rounds of monitoring for pesticides was agreed upon as a
substitute for extending the remedial investigation. The selected remedy will be reevaluated if
groundwater concentrations exceed the concentrations of VOCs or SVOCs indicated below or if
increasing concentration trends are observed, as discussed in Section 9.1. Four rounds of
groundwater sampling for pesticides/herbicides will be performed (see Table 9-2).

Groundwater
Concentrations
Reguiring Evaluation
Analytes (Ig/L)
Benzyl Alcoho 10
Bis(2-ethylhexyl)phthalate 10*
Diethylphthalate 5,600
Di-n-butyl phthalate 700
Trichloroethene 2.3
Tetrachloroethene 2*

9.7.8.5 Five-year site policy reviews are included in the selected remedy. The reviews are
reguired because contaminants will be left in place.

9.7.8.6 This alternative does not actively reduce the toxicity, mobility, or volume of the COCs
in the soil. The selected remedy is protective of human health and the environment. The present
worth of this alternative is $87,000. The basis for this cost estimate is included in Table
9-16.

9.7.9 Surface and Near-Surface Soil - Northern Depot Area

9.7.9.1 Alternative 3, an asphalt cover, is the selected remedy for the surface and near-surface
soils in the Northern Depot Area. Several nonvegetated areas of bare soil are present on the
depot. These areas are located at the southern end, the northern end, and near the northwestern
corner of the depot. These areas are periodically graded to bare dirt.

9.7.9.2 The results of surface and near-surface soil sampling in the Northern Depot Area
indicate that arsenic and manganese are present at levels that pose potential noncarcinogenic
risks to grader operators and construction workers. The elevated arsenic and manganese levels
are related to ore stockpiles previously located in the Northern Depot Area. The selected remedy
consists of installing an asphalt cover over the soils that have elevated levels of arsenic and
manganese (approximately 138,000 sguare feet of soil). The cover will provide a barrier to
prevent grader operators or construction workers from coming in contact with surface soils
containing elevated levels of arsenic and manganese. The depot reguires the use of this area as
an active storage area. Therefore, institutional controls were not considered an acceptable
remedy for this site.

9.7.9.3 A thorough evaluation of ARARs is provided in Section 10.13.2. Cleanup standards
correspond to risk-based concentrations that would reduce the hazard index to 1.0. These
standards will be used as a benchmark to reassess the need for continued controls in the
first five-year site review. The proposed soil cleanup standards are:

Northern Depot Area
Cleanup Standards
Analytes (Ig/kg)
Arsenic 48
Manganese 1,000

9.7.9.4 The asphalt cover will be maintained for as long as soil concentrations exceed the
established cleanup standard. The selected remedy will have to be reevaluated before
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initiating any construction that would impact the asphalt cap.

9.7.9.5 Five-year site reviews are included in the selected remedy. The reviews are required for
both statutory and policy reasons. The containment provided by the asphalt cap must be
periodically reviewed and wastes will be left in place for more than five years.

9.7.9.6 This alternative does not reduce the toxicity or volume of arsenic or manganese, but it
reduces their mobility in the surface and near-surface soils. The selected remedy is protective
of human health and the environment because direct contact with soils containing elevated
arsenic and manganese levels is significantly reduced by covering the soil with asphalt. The
present worth of this alternative is $504,000. The basis for this cost estimate is included in
Table 9-17.

9.8 Group C Sites

9.8.1 SWMUs 2 and 3 - Sewage and Industrial Waste Lagoons

9.8.1.1 Alternative 3 (Excavation and Disposal) is the selected remedy for SWMUs 2 and 3. SWMU 2
(Sewage Lagoons) and SWMU 3 (Industrial Lagoons) are located in the northern part of the depot,
west of and adjacent to the Sewage Treatment Plant. The industrial lagoons are lined and are no
longer in use. The DDJC-Tracy wastewater treatment plant discharges treated water to the sewage
lagoons. In January 1996, an EE/CA was prepared to evaluate alternatives and select a
non-time-critical removal action for SWMUs 2 and 3 (Radian, 1996a). The recommended removal
action is the selected remedy for is SWMUs 2 and 3.

9.8.1.2 A thorough evaluation of ARARs is provided in Section 10.13.2. Cleanup standards were
developed from vadose zone modeling (Montgomery Watson, 1996a), which identified potential
threats to background groundwater quality at this site. The cleanup standards were developed to
protect human health and ecological receptors. The cleanup standard to protect background
groundwater quality are consistent with Water Quality Goals (CVRWQCB, 1993). The proposed
cleanup standards are:

SWMUs 2 and 3
Cleanup
Analytes Standard (Ig/kg)

Selenium 616 b
Lead 28,000 b
Dieldrin 370
DDD 1,600
DDE 1,800
DDT 1,700
Total DDK 241 b
Aldrin 3
Chlordane 10
Diuron 260
Endrin 3
Lindane (Gamma-BHC) 1.7
Monuron 260
2,4-D 47
Heptachlor epoxide 1.5
2,4-Dimethylphenol 330
4-Methylphenol 330
Bis(2-ethylhexyl)phthalate a 330
di-n-butylphthalate a 330

SWMU 2 only.
b Preliminary standard.

9.8.1.3 The cleanup standards for total DDK, lead, and selenium are risk-based standards to
protect ecological receptors (see Section 6.6.5). These standards are considered preliminary
because they were estimated using literature values rather than site-specific bioaccumulation
factors. Additional data will be collected to obtain site-specific bioaccumulation factors, and
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the cleanup standards and extent of excavation will be revised accordingly through an
explanation of significant differences to this ROD.

9.8.1.4 The cleanup standards for DDD, DDE, DDT, dieldrin, and 2,4-D were revised on the basis
of DI-WET results obtained during the excavation of SWMUs 2 and 3. These results demonstrated
that these pesticides would attenuate in the vadose zone at higher concentrations than were
estimated in the RI/FS (Montgomery Watson, 1996a). All other cleanup standards are consistent
with laboratory reporting limits. The eguilibrium partitioning limits developed in the RI/FS
(see Table 6-9 for summary) provided very conservative estimates of the soil concentrations
reguired to protect background groundwater guality. These limits correspond to the maximum
concentrations expected in soil water and do not account for an expected decrease in
concentration resulting from migration through less contaminated or clean soils to groundwater
(Figures B-24 through B-27). The numbers and concentrations of analytes in soil generally
decreases with increasing depth. Because of these factors, it was considered appropriate to use
laboratory reporting limits corresponding to the lowest concentration that can be reproducibly
detected as verified by the use of low-level standards (Appendix F) as a basis for all other
cleanup standards. This analysis modifies the cleanup standards presented in the RI/FS
(Montgomery Watson, 1996a).

9.8.1.5 The existing industrial waste lagoon liners and partitions are presently being excavated
(Figure 9-12). The entire footprint of the lagoons has been excavated to a depth of 1 foot.
Pockets of additional pesticide contamination will be excavated until cleanup standards are
attained. Confirmation sampling will be performed to ensure that the cleanup standards are met.
The total volume of material to be excavated will be approximately 10,000 cy (15,000 tons). The
nonhazardous excavated soil will be stockpiled and transported to a Class I or other disposal
facility in compliance with state and federal laws and regulations. The initial excavation
activities attempted to provide clean closure. The cleanup standards were modified to protect
water guality and are expected to achieve clean closure. Clean closure is expected to be
verified through groundwater monitoring.

9.8.1.6 Groundwater sampling for SVOCs and pesticides/herbicides will be performed as part of
the Well Monitoring Program (see Table 9-2) to evaluate the effectiveness of the selected
remedy. Lead and selenium do not threaten groundwater guality and are not included in the
monitoring program. As stated in Section 9.1, concentrations of COCs exceeding the following
levels will be evaluated in the Annual Well Monitoring Reports.

Groundwater
Concentrations
Reguiring
Analytes Evaluation (Ig/L)
Bis(2-ethylhexyl)phthalate 10*
2,4-Dimethylphenol 140
Di-n-butylphthalate 700
4-Methylphenol 10
Aldrin 0.05*
Chlordane 0.1*
DDD 0.15*
DDE 0.1
DDT 0.1
Dieldrin 0.05*
Endrin 2
Lindane (Gamnma-BHC) 0.03
Diuron 14
Monuron 1. 0
2,4-D 70
Heptachlor epoxide 0.01*

* For these compounds, results above the estimated detection limit (see Table 9-7) will be
reported as trace amounts and will be evaluated. Cases where the actual detection limit
differs significantly from the estimated detection limit because of matrix or other
effects will be flagged.
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9.8.1.7 Contaminants will be permanently removed from the site through excavation. The selected
remedy is protective of human health at the site under current and future land use conditions.
The present worth of this alternative is approximately $2,200,000. The basis of the cost
estimate is included in Table 9-18.

9.8.2 SWMU 33 - Industrial Waste Pipeline (IWPL)

9.8.2.1 Alternative 3 (Grouting, Limited Excavation, and Institutional Controls) is the
preferred alternative for SWMU 33. In 1972, an existing pipeline and a storm drain line were
interconnected to form the IWPL at SWMU 33. The IWPL is constructed of 4-inch to 7-inch diameter
pipe of varying composition (transite, vitrified clay, polyvinyl chloride) and is buried to a
depth of approximately two to four feet below grade. Eight manholes are located along the
pipeline. The pipeline consists of two major segments referred to as the south industrial waste
pipeline (SIWPL) and the east industrial waste pipeline (EIWPL). The total length of the SIWPL
and its branches is approximately 1,200 lineal feet. The total length of the EIWPL and its
branches is also approximately 1,200 lineal feet. Use of the IWPL has been discontinued.

9.8.2.2 A thorough evaluation of ARARs is provided in Section 10.14.2. Cleanup standards were
developed from vadose zone modeling (Montgomery Watson, 1996a), which identified potential
threats to background groundwater guality at this site. The cleanup standards developed are
consistent with Water Quality Goals (CVRWQCB, 1993) and the Tri-Regional Guidelines. The
proposed cleanup standards are:

SWMU 33
Cleanup
Analytes Standard (Ig/kg)

Xylenes 5
Diethylphthalate 330
Di-n-butylphthalate 330
Naphthalene 330
Aldrin 1.7
Carbaryl 400
Dieldrin 2
Methiocarb 500
TPH as diesel 100,000

9.8.2.3 The soil cleanup standard for TPHD was developed using the Tri-Regional Guidelines. The
eguilibrium partitioning limits developed in the RI/FS (see Table 6-9 for summary) provided very
conservative estimates of the soil concentrations required to protect background groundwater
guality. These limits correspond to the maximum concentration expected in soil water and do not
account for an expected decrease in concentration resulting from migration through less
contaminated or clean soils to groundwater (Figure B-29). Excavation will be performed at SB461,
SB204, and SB462. At other locations the concentrations of COCs in soil decrease with increasing
depth. Because of these factors, it was considered appropriate to use a laboratory reporting
limit corresponding to the lowest concentration that can be reproducibly detected as verified by
the use of a low-level standard (Appendix F) as a basis for all other cleanup standards. This
analysis modifies the cleanup standards presented in the RI/FS (Montgomery Watson, 1996a).

9.8.2.4 An engineering evaluation/cost analysis (EE/CA) (Radian, 1996) has been prepared to
expedite the action for SWMU 33 (Radian, 1996). According to the EE/CA, the recommended removal
action alternative for SWM 33 involves pressure grouting the laterals and sumps in the IWPL and
excavating the most contaminated soils (approximately 10 cy). It should be noted that the sumps
at manholes W-l and W-3 are interpreted as being part of SWMUs 20. As discussed in Section
9.5.5, excavation and disposal are recommended for the sumps and surrounding soils at manholes
W-l and W-3. In addition, SVE is recommended for VOC contamination at SB108 (Area 1 Building 10)
and SB431 (SWMUs 20/23) .

9.8.2.5 These excavations will not address all areas of the IWPL where contaminants are present
above cleanup standards. Aldrin, dieldrin, diethylphthalate, and di-n-butylphthalate will be
present above the cleanup standards and pose a potential threat to background groundwater
guality. However, the contaminants are generally below buildings or other paved areas, so the
threat of migration to groundwater is considered low. Therefore, the selected remedy supplements
-------
the grouting and excavation with groundwater monitoring and institutional controls. Groundwater
sampling for VOCs, SVOCs, and pesticides/herbicides will be performed as part of the Well
Monitoring Program (see Table 9-2). As stated in Section 9.1, concentrations of COCs exceeding
the following concentrations will be evaluated in the Annual Well Monitoring Reports.

Groundwater
Concentrations
Reguiring Evaluation
Analytes (Ig/L)
Xylenes 17
Diethylphthalate 5,600
Di-n-butylphthalate 700
Naphthalene 20
TPH as diesel 100
Aldrin 0.05*
Carbaryl 60
Dieldrin 0.05*
Methiocarb 5

9.8.2.6 The selected remedy also includes land use restrictions around the IWPL. Buildings and
pavement greatly reduce the effects of percolation along the pipeline. Any construction,
excavation, or demolition along the IWPL will reguire an evaluation of potential impacts to the
selected remedy. This evaluation will be provided to the signatory parties of the ROD for
approval before construction activities. Land use restrictions are currently documented at DDJC-
Tracy in a Master Plan. In this Master Plan, SWMU 33 is presently designated for industrial use
only. This restriction is reguired as part of the selected remedy. If ownership of the
installation is transferred to private or non-federal entities in the future, restrictive
covenants will be written into the land property deed to prevent schools, playgrounds,
hospitals, and housing from being built at the site until COCs are below levels of concern.
Cooperation among the U.S. Army, San Joaguin County, and Cal-EPA will be reguired to enact the
access and land use restrictions.

9.8.2.7 Five-year site reviews are included in the selected remedy as specified in the CERCLA
guidance. Statutory and policy reviews are reguired because wastes will be left in place and the
use of the site will be limited by institutional controls. Site reviews may include literature
searches, site walks, interviews, and minimal sampling. Groundwater sampling at these sites
will be conducted as part of the Well Monitoring Program.

9.8.2.8 Some of the contaminants will be permanently removed from the site through excavation.
The grouting of the pipe will further reduce the mobility of the contaminants by preventing
water from entering or leaking from cracks in the IWPL. The selected remedy is protective of
human health and the environment. The present worth of this alternative is $242,600. The basis
of this cost estimate is included in Table 9-19.

9.9 Five-Year Review Process

9.9.1 Every five years, the success of the selected remedies will be evaluated using the most
current knowledge and site information. The five-year reviews provide an opportunity to
reexamine past decisions. Statutory reviews are reguired for sites that will not allow for
unlimited use and unrestricted exposure on attainment of ROD cleanup levels. Policy reviews are
reguired for sites that reguire more than five years to attain ROD cleanup levels. Policy
reviews must be completed within five years of the initiation of the remedial action. The
five-year reviews will evaluate the performance of the selected remedy and be continued for as
long as cleanup standards are exceeded or soil contaminants remain in place. DDJC-Tracy will
document the review as a secondary document. As specified in the FFA, any party to the agreement
may submit a written proposal for additional work or modification of the selected remedy.

9.9.2 The results of the DDJC-Tracy Well Monitoring Program will provide key information for
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evaluating the sites in the review process. Groundwater monitoring will be conducted in
accordance with Title 27 of the California Code of Regulations. Specifically, Section 20430
reguires monitoring to determine the effectiveness of corrective actions.

Sections 20410, 20950, 22207 (a), 22212(a), and 22222 identify monitoring reguirements for the
closure, post-closure, and compliance periods. Pursuant to Title 27, Section 20410(c),
monitoring is reguired for three consecutive years following the date that ROD cleanup standards
are achieved. Pursuant to Title 27, Section 20950(a), the post-closure maintenance period lasts
as long as water guality is threatened by the COCs.

9.10 Post-ROD Documents

9.10.1 DDJC-Tracy will submit a schedule for all post-ROD primary documents within 30 calendar
days of the issuance of the Site-Wide Comprehensive Record of Decision. The following post-ROD
documents will be submitted as primary documents:

• Remedial Design Work Plan (to include sampling and analysis plan);

• Remedial Design (to include institutional controls);

• Remedial Action Work Plan (to include sampling and analysis plan);

• Construction Quality Assurance Plan;

• Construction Quality Control Plan;

• Construction Completion Report; and

• Project Closure Plan.

9.10.2 Separate design packages are planned for the SVE sites (Group A sites and SWMU 20) and
the remaining soil sites. For each of these sites, the Construction Quality Assurance and
Construction Quality Control Plans will be combined into a single document. All documents
except for the Project Closure Plan will be modified primary documents that have a 30-day
review period.

9.10.3 Technical and economic evaluations of the SVE sites will be prepared before treatment
is discontinued. These evaluations will be primary documents.
-------
SWMU
Number/Site

OU1 Groundwater
Table 9-1. Selected Remedies

Description

Extraction, Treatment (Air Stripping, Carbon),
Injection
Comments
SWMU I/Area 2
SWMUs 2/3
SWMU 4
Soil Vapor Extraction
Excavation with Off-Site Disposal
Excavation and Off-Site Disposal of
Sediments
SWMU 5
No, Further Action
No contamination identified at this
site.
SWMU 6

SWMU 7
Excavation with Off-Site Disposal

Institutional Controls (modify property records
of Buildings 19 and 21, two additional
monitoring wells, and groundwater
monitoring)
SWMU 8

SWMU 9
Excavation with Off-Site Disposal

No Further Action
No contamination identified at this
site.
SWMU 10
No Further Action
No contamination identified at this
site.
SWMU 10A
No Further Action
No adverse human health risk.
Remediation to address potential
threat to groundwater would reguire
$2 million to $4 million.
SWMU 11
No Further Action
No contamination identified at this
site.
SWMU 12
No Further Action
No contamination identified at this
site.
SWMU 14
No Further Action
No threat to groundwater and no
adverse human health risk from
chemicals of potential concern in
soils.
-------
SWMU
Number/Site
Table 9-1. (Continued)

Description
Comments
SWMU 15

SWMU 16

SWMU 20

SWMU 21

SWMU 22

SWMU 23

SWMU 24

SWMU 25

SWMU 27/Area 1

SWMU 29

SWMU 30

SWMU 31

SWMU 33
No Further Action
No Further Action
Soil Vapor Extraction, Limited Excavation
with Off-Site Disposal, and Natural
Attenuation

No Further Action
No Further Action

No Further Action

Bioventing

No Further Action

Excavation with Off-Site Disposal

No Further Action

Pipe Grouting, Limited Excavation, and
Institutional Controls (land use restrictions
along IWPL and groundwater monitoring)
No contamination identified at this
site.

No contamination identified at this
site.
No contamination identified at this
site.

No contamination identified at this
site.

No threat to groundwater and no
adverse human health risk from
chemicals of potential concern in
soils.
No contamination identified at this site.
No contamination identified at this site.
No contamination identified at this site.
No contamination identified at this site.
SWMU 64 No Further Action

Area 1 Building 236 No Further Action
No contamination identified at this site.

No contamination identified at this site.
-------
Table 9-1. (Continued)

Description

Area 1 Building 237 Soil Vapor Extraction
SWMU
Number/Site
Area 3

Building 15 Drum
Storage Area
Building 22 Drum
Storage Area
Building 23

Building 30 Drum
Depot Wide Surface
and Near-Surface
Soils, Northern Depot
Area

Day Care Center
Soil Vapor Extraction

No Further Action

Institutional Controls (groundwater
Storage Area monitoring)

Asphalt Cover
Excavation and Disposal (Corrective Action
Completed)
Comments
No contamination identified at this site.

No contamination identified at this site.

No contamination identified at this site.
SWMU = Solid Waste Management Unit
-------
Well ID

Existing Monitoring

LM025AUA

LM055B

LM056C

LM058AU

LM063A

LM064B

LM065C

LM066A

LM067B

LM070C

LM076A

LM077A

LM081C

LM083A

LM084B
Table 9-2. Performance Monitoring Network

Rationale

Wells-OU 1

Monitor VOC cleanup performance of extraction well EW-37AU

Monitor VOC cleanup performance of extraction well EW-27B

Monitor VOC cleanup performance of extraction well EW-31C

Monitor VOC cleanup performance of extraction well EW-34AU

Monitor groundwater guality in the Upper Horizon north of the northern infiltration
galleries and confirm that the Upper Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity

Monitor groundwater guality in the Middle Horizon north of the northern infiltration
galleries and confirm that the Middle Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity

Monitor groundwater guality in the Lower Horizon north of the northern infiltration
galleries and confirm that the Lower Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity

Monitor VOC cleanup performance of extraction well EW-21A

Monitor VOC cleanup performance of extraction well EW-26B

Monitor VOC cleanup performance of extraction well EW-13C

Monitor VOC cleanup performance in the Upper Horizon directly south of the Banta
Road, Extraction Wellfield (OU 1 Remedial Design)

Monitor VOC concentrations directly east of the northern galleries

Monitor VOC cleanup performance of extraction well EW-30C

Monitor groundwater guality in the Upper Horizon northwest of the northern infiltration
galleries and confirm that the Upper Horizon VOC plum has not migrated downgradient.
of the OU 1 Remedial Design in this vicinity

Monitor groundwater guality in the Middle Horizon northwest of the northern infiltration
galleries and confirm that the Middle Horizon VOC plum has not migrated downgradient
of the OU 1 Remedial Design in this vicinity
-------
Table 9-2. (Continue)

Well ID Rationale

LM089C Monitor groundwater quality in Lower Horizon cross-gradient of extraction well (EW-31C).

LM093AU Monitor VOC cleanup performance of extraction well EW-36AU

LM143AU Monitor VOC cleanup performance of extraction well EW-22

LM145AU Evaluate if off-site chloroform plume is migrating toward DDJC-Tracy as a result of the
reinjection of treated groundwater into the Upper Horizon from the southern infiltration galleries.

LM146A Monitor VOC cleanup performance of extraction well EW-15A

LM148C Monitor groundwater quality downgradient of extraction wells EW-13C, EW-31C, and EW-30C.

LM053A Monitor for dieldrin to evaluate the effectiveness of the extraction system

LM028A Monitor for dieldrin to evaluate the effectiveness of the extraction system

LM101A Monitor for dieldrin to evaluate the effectiveness of the extraction system

LM094AU Monitor for dieldrin to evaluate the effectiveness of the extraction system

Proposed New Monitoring Wells-OU 1

PMW001A\LM150A Monitor the VOC and off-site chloroform plumes located south and southeast of the
proposed Banta Road Extraction Wellfield (OU 1 Remedial Design), respectively.

PMW002A\LM151A Monitor the VOC and off-site chloroform plumes located south and southeast of the
proposed Banta Road Extraction Wellfield (OU 1 Remedial Design), respectively.

PMW003A\LM152A Monitor the off-site chloroform plume located southeast of the proposed Banta Road
Extraction Wellfield (OU 1 Remedial Design).

PMW004A\LM153A Monitor VOC cleanup performance of extraction wells EW-19A and EW-20A

PMW005B\LM154A Monitor VOC cleanup performance of extraction wells EW-24B and EW-25B

PMW006A\LM155A Monitor cleanup of the VOC plume east of the Banta Road Extraction Wellfield (OU 1
Remedial Design)

PMW007A\LM156A Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume east of the Banta Road Extraction Wellfield (OU 1 Remedial Design)
-------
Table 9-2. (Continue)

Well ID Rationale

PMW008A\LM157A Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume east and northeast of the Banta Road Extraction Wellfield (OU 1 Remedial
Design)

PMW009A\LM158A Monitor cleanup and dispersion of the VOC plume and movement of the chloroform
plume northeast of the Banta Road Extraction Wellfield (OU 1 Remedial Design)

PMW010A\LM159A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)

PMW011A\LM160A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)

PMW012A\LM161A Monitor cleanup and dispersion of the VOC plume northeast of the Banta Road
Extraction Wellfield (OU 1 Remedial Design)

PMW013A\LM162A Monitor VOC concentrations north of the OU 1 Remedial Design Extraction Wellfield
constructed near former Agricultural Well #2

PMW014B\LM163A Monitor potential migration of off-site chloroform plume east of Banta Road Extraction
well field

PMW015B\LM164A Monitor potential migration of off-site chloroform plume southeast of Banta Road
Extraction well field

PMW016A\LM165A Monitor potential migration of off-site chloroform plume northeast of Banta Road
Extraction well Field

Existing Monitoring Wells-SWMU I/Area 2

LM030AUA Monitor TCE and PCE migrating from source area to EW008A

LM040B Closest Middle Horizon well to VOC source area. Monitor for VOCs.

LM041B Monitor for VOCs to evaluate effectiveness of SVE system in preventing groundwater
contamination

LM094AU Monitor VOCs from SWMUl/Area 2 to evaluate the performance of the SVE system.

Existing Monitoring Well Area 3

LM032AU Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater
impacts
-------
Table 9-2. (Continue)

Well ID Rationale

Existing Monitoring Wells-Area 1 Building 237

LM137A Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater

LM061AU Monitor for VOCs to assess effectiveness of SVE system in preventing groundwater
impacts

Existing Monitoring Wells-SWMUs 2/3
LM003AA Monitor performance of removal action at SWMUs 2/3. Closest downgradient well.
Monitor for SVOCs, OC and C/U pesticides.

LM015AA Monitor performance of removal action at SWMUs 2/3. Closest downgradient well.
Monitor for SVOCs, OC and C/U pesticides.

Existing Monitoring Wells-SWMU 4
LM004AU Monitor for SVOCs, VOCs, OC and C/U pesticides, and simazine to assess potential
groundwater impacts at SWMU 4

LM027AUA Monitor for SVOCs, VOCs, OC and C/U pesticides, and simazine to potential
groundwater impacts at SWMU 4 nearest downgradient well

Existing Monitoring Wells-SWMU6
LM017A Monitor for VOCs, OC and C/U pesticides, and chlorinated herbicides to evaluate the
performance of the excavation at SWMU 6

LM092C Upgradient from potential source at SWMU 6. Monitor for VOCs.

Existing Monitoring Wells-SWMU 7
LM095AU Downgradient from south area pits. Monitor for VOCs, OP, OC, and C/U pesticides,
chlorinated herbicides, SVOCs, and dioxins/furans.

New Monitoring Wells-SWMU 7
LM166AU Monitor for VOCs, TPHD, OP, OC, and C/U pesticides, chlorinated herbicides, and
SVOCs to evaluate potential groundwater impacts from contaminants left in place.

LM167AU Monitor for VOCs, TPHD, dioxins/furans, SVOCs, OP, OC, and C/U pesticides
dioxins/furans, and chlorinated herbicides. Nearest downgradient well from Pits D and F.

Existing Monitoring Wells-SWMU 8

LM019A Monitor for VOCs, SVOCs, OC and C/U pesticides, and simazine to evaluate the
performance of the remedial action.
-------
Table 9-2. (Continue)

Well ID Rationale

LM097AU Nearest well to potential source of OC pesticides, simazine, VOCs, and dioxin/furan compounds.

LM119A Monitor for VOCs, SVOCs, chlorinated herbicides, and OC pesticides, nearest
downgradient well to potential source area.

New Monitoring Wells-SWMU 8
LM168A Nearest downgradient well from potential source at SWMU 8. Monitor for VOCs,
SVOCs, chlorinated herbicides, dioxins/furans, and OC pesticides.

Existing Monitoring Wells-SWMU 10A
LM014A Monitor for SVOCs to ensure No Further Action determination for SWMU 10A was appropriate.

Existing Monitoring Wells-SWMU 20
LM085B Monitor vertical migration downgradient from SWMUs 20/23 and Area I/Building 10.
Monitor for VOCs, SVOCs, OC and C/U pesticides, chlorinated herbicides, and TPHD.

LM093AU Monitor VOCs, SVOCs, OC, OP, and C/U pesticides from SWMUs 20/23 to evaluate the
performance of the remedial action.

LM115AU Monitor VOCs, SVOCs, OC, OP, and C/U pesticides, and chlorinated herbicides to
evaluate migration from source area.

Existing Monitoring Wells—SWMU 24
LM116A Monitor for VOCs, SVOCs, PCBs, TPHG, TPHD, OC, and C/U pesticides to evaluate
migration from source area.

LM118AU Nearest downgradient well to potential source of TPH, VOCs, SVOCs, OC and C/U
pesticides, and PCBs at SWMU 24.

Existing Monitoring Wells—SWMU 27
LM117A Monitor migration of VOCs, herbicides, and TPH-MO from potential source at SWMU
27.

Existing Monitoring Wells--SWMU 33
LM002A Monitor for VOCs, SVOCs, OC and C/U pesticides associated with SWMU 33.
Monitoring will assess effectiveness of removal action and identify impacts from
contaminants left in place.

LM129A Monitor source area for VOCs, SVOCs, TPH, and chlorinated herbicides.

Existing Monitoring Wells-Drum Storage Area 30-1
LM169A Nearest downgradient well. Monitor for VOCs, SVOCs, and pesticides/herbicides.
-------
Table 9-2. (Continue)
C/U = carbamate/urea
OC = organochlorine
OP = organophosphorus
OU = Operable Unit
SVE = soil vapor extraction
SVOC = semivolatile organic compound
TPHD = total petroleum hydrocarbons as diesel
TPHG = total petroleum hydrocarbons as gasoline
TPH-MO = total petroleum hydrocarbons as motor oil
VOC = volatile organic compound
-------
Table 9-3. OU 1 Groundwater
Alternative 3 - Groundwater Extraction and Treatment
Quantity
2,000
1
18
11
9
1
1
2,000
1
Item Description

DIRECT CAPITAL COSTS (Dieldrin)

EQUIPMENT COSTS (EC)
Conveyance Piping and Fittings
Wellhead Eguipment (Pumps & Controls)
Granular Activated Carbon (GAG) Units
CONSTRUCTION COSTS
Extraction and Injection Wells a
Eguipment Pads
Permitting
Pumping Test
Trenching
System Startup
Mechanical
Instrumentation
Electrical
TOTAL DIRECT CAPITAL COST (DCC)

INDIRECT CAPITAL COSTS (Dieldrin)

Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
Unit Cost
Unit ($)
Linear foot $5
Lump sum $10,000
each $3,500
Subtotal EC
each $10,000
each $2,500
lump sum $10,000
lump sum $15,000
linear foot $13
lump sum $15,000
40% of EC
10% of EC
20% of EC
Subtotal

6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
Total Cost
($)
$10,000
$10,000
$63,000
$83,000
$110,000
$22,500
$10,000
$15,000
$26,000
$15,000
$33,200
$8,300
$16, 600
$256, 600
$339, 600
$20,400
$13, 600
$6,800
$34,000
$101,900
$57,800
$68,000
TOTAL INDIRECT CAPITAL COST
$302,500
-------
Table 9-3. (Continued)
TOTAL CAPITAL REQUIREMENT
ANNUAL OPERATION AND MAINTENANCE COSTS (Dieldrin)
Influent/Effluent Monitoring b
Spent GAG Changeout Costs c
Labor
Maintenance Materials
Groundwater Monitoring d
Injection Well Redevelopment e
$642,100
216
27
0.25
1
1
1
each
each
man-year
lump sum
lump sum
lump sum
$200
$1,900
$75,000
$2,000
$10,000
$16,800
$43,200
$51,300
$18,750
$2,000
$10,000
$16,800
PRESENT WORTH (Dieldrin)
TOTAL O&M COSTS
Interest Rate
Years
7%
30
$142,050
DIELDRIN UPGRADE PRESENT WORTH
CAPITAL COSTS (VOCs)
TOTAL PRESENT WORTH
$2,528,000
$3,324,400
$12,037,500
a Based on nine extraction wells and two injection wells
b Based on one influent sample and one effluent sample collected monthly and analyzed for dieldrin.
c Based on three changeouts per year for each well. Includes disposal of spent GAG and replacement with fresh GAG.
d Based on monitoring 10 wells for dieldrin.
e The two injection wells will be re-developed every two months to prevent fouling.
-------
Table 9-4. SWMU I/Area 2 - Aboveground Solvent Tank/Building 26 Recoup Operations
Alternative 3 - Soil Vapor Extraction
Unit Cost Total Cost
Item Description Quantity Unit ($) ($)
DIRECT CAPITAL COSTS
SOIL VAPOR EXTRACTION
Mobilization/Demobilization a
Air Extraction Vents
Collection Piping
Rental of Mobile Blower System b
Labor (O&M)
Air Effluent Testing
Confirmation Sampling (Soil Gas)

CLOSURE REPORT c
1
1
2,000
12
0.25
1
1
lump sum
lump sum
linear foot
months
man-year
lump sum
lump sum
$1,000
$47,000
$20
$2,000
$75,000
$5,000
$2,000
$1,000
$47,000
$40,000
$24,000
$18,750
$5,000
$2,000
40
hour
$70
$2,800
TOTAL DIRECT CAPITAL COST (DCC)
$140,550
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
$8,500
$5,700
$2,900
$14,100
$42,200
$23,900
$28,200
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$125,500

$266,100
PRESENT WORTH
Interest Rate
Years
7%
1
TOTAL PRESENT WORTH
$266,600
Assumptions:
a Mobilization/demobilization of SVE system will be conducted concurrently with same for systems at other sites.
b Includes vapor-phase carbon treatment; assumes that two systems will be needed, each operated for 6 months.
c 25-page report to be included in depot-wide closure report.
-------
Table 9-5. Area 1 Building 237
Alternative 3 - Soil Vapor Extraction
Item Description

DIRECT CAPITAL COSTS
Quantity
Unit
Unit Cost
($)
Total Cost
($)
SOIL VAPOR EXTRACTION
Mobilization/Demobilization a
Air Extraction Vents
Collection Piping
Rental of Mobile Blower System b
Labor (O&M)
Air Effluent Testing
Confirmation Sampling (Soil Gas)

CLOSURE REPORT c
1
1
500
6
0.25
1
1
lump sum
lump sum
linear foot
months
man- year
lump sum
lump sum
$1,000
$22,000
$20
$2,000
$75,000
$5,000
$2,000
$1,000
$22,000
$10,000
$12,000
$18,750
$5,000
$2,000
40
hour
$70
$2,800
TOTAL DIRECT CAPITAL COST (DCC)
$73,550
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
$4,500
$3,000
$1,500
$7,400
$22,100
$12,600
$14,800
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$65,900

$139,500
PRESENT WORTH
Interest Rate
Years
7%
1
TOTAL PRESENT WORTH
$140,000
Assumptions:
a Mobilization/demobilization of SVE system will be conducted concurrently with same for systems at other sites.
b Includes vapor-phase carbon treatment.
c 25-page report to be included in depot-wide closure report.
-------
Table 9-6. Area 3
Alternative 3 - Soil Vapor Extraction
Item Description

CLOSURE REPORT c
1
1
2000
6
0.25
1
1
lump sum
lump sum
linear foot
months
man- year
lump sum
lump sum
$1,000
$46,000
$20
$2,000
$75,000
$5,000
$2,000
$1,000
$46,000
$40,000
$12,000
$18,750
$5,000
$2,000
40
hour
$70
$2,800
TOTAL DIRECT CAPITAL COST (DCC)
$127,550
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
$7,700
$5,200
$2,600
$12,800
$38,300
$21,700
$25,600
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$113,900

$241,500
PRESENT WORTH
Interest Rate
Years
7%
1
TOTAL PRESENT WORTH
$242,000
Assumptions:
a Mobilization/demobilization of SVE system will be conducted concurrently with same for systems at other sites.
b Includes vapor-phase carbon treatment.
c 25-page report to be included in depot-wide closure report.
-------
Table 9-7. Groundwater Monitoring Requirements (Ig/L) for DDJC-Tracy
Analyte
Soil Cleanup Standards (Ig/kg)
Acetone
Aldrin
Benzyl alcohol
bis (2-Ethylhcxyl)phthalate
2-Butanone
Carbaryl
Carbofuran
Chlordane
2,4-D
DDD
DDE
DDT
Dicamba
1, 2-Dichloroethene
Beneficial
Method Use Limit
SW8260B 700
SW8081A 0.002
SW8270C NA
SW8270C 4.2
SW8260B 4,200
E632 60
E632 18
SW8081A 0.03
SW8151A 70
SW8081A 0.15
SW8081A 0.1
SW8081A 0.1
SW8151A 210
SW8260B 6
Groundwater
Concentration
Background Quantitation Estimated Reguiring
Concentration Limit Detection Limit a Evaluation
NE 10 - 700
0.005 b 0.05 0.01 0.05(0.01)
NE 10 - 10
NE 10 2 10(2)
NE 20 - 4,200
0.382 b 5 - 60
NE 5 - 18
0.104 b 0.1 (0.05) 0.1(0.05)
0.101 b 10 - 70
0.005 b 0.1 - 0.15
0.005 b 0.1 - 0.1
0.005 b 0.1 - 0.1
0.091 b 10 - 210
NE 0.5 - 6
Rationale

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to guantitation limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Corresponds to beneficial use limit.
-------
Table 9-7. (Continued)
Analyte

Soil Cleanup Standards (Ig/kg)(Continued)

Dieldrin
Diethylphthalate

2,4-Dimethylphenol

Di-n-butyl phthalate

2,4-Dinitrophenol
2,4-Dinitrotoluene
Dioxins/Furans
Diuron

Endrin

Ethylbenzene

Fluoranthene
Beneficial Background
Method Use Limit Concentration
mtinued)
SW8081A 0.002 0.005 b
SW8270C 5,600 NE
SW8270C 140 NE
SW8270C 700 NE
SW8270C 14 NE
SW8270C 0.11 NE
SW8280 0.0000002 0.000001
7
E632 14 0.144 b
SW8081A 2 0.005 b
SW8260B 29 NE
SW8270C 280 NE
Quantitat
Limit
0.05
10
10
10
50
10
0.01

1
0.1
2.0
10
Estimated
Detection Limit a
0.01
10
0.01
Groundwater
Concentration
Reguiring
Evaluation
0.05 (0.01)
5, 600

140

700

50(10)
10(2)
0.01 (0.01)
14

280
Rationale
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated9
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Corresponds to beneficial use limit.
-------
Table 9-7. (Continued)
Beneficial
Analyte Method Use Limit

Soil Cleanup Standards (Ig/kg) (Continued)

Heptachlor SW8081A 0.006
Background
Concentration
0.005 b
Quantitation
Limit
0.01
Heptachlor Epoxide
SW8081A
0.003
0.005 b
0.01
MCPA
SW8151
3.5
NE
380
Methiocarb

4-Methyl-2-pentanone

2-Methylnaphthalene

4-Methylphenol

Monuron

Naphthalene

PCB (Aroclor 1260)
E632
SW8260B
SW8270C
SW8270C
E632
SW8270C
SW8082
NA
40
NA
NA
NA
20
NA
1.36 b
NE
NE
NE
0.163 b
NE
NE
5
10
10
10
1
10
0.5
Estimated
Detection Limit a
0.01
0.01
100
Groundwater
Concentration
Reguiring
Evaluation
0.01 (0.01)
0.01 (0.01)
2-Hexanone
Lindane
Linuron
SW8260B
SW8081A
E632
NA
0.03
1.4
NE
0.005 b
0.157 b
10
0.03
2 1.0
10
0.03
2(1.0)
380(100)
5

1.0

0.5
Rationale
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Corresponds to guantitation limit.
-------
Table 9-7. (Continued)
Analyte
Soil Cleanup Standards
Pentachlorophenol
Phenanthrene
Phenol
Phorate
Pyrene
Ronnel
Simazine
2,4,5-T
Tetrachloroethene
Method
Beneficial
Use Limit
Background
Concentration
Quantitation
Limit
(Ig/kg) (Continued)
SW8270C
SW8270C
SW8270C
SW8141A
SW8270C
SW8141A
E507
SW8151A
SW8260C
1.9
NA
4,200
NA
210
NA
4
70
0.7
NE
NE
NE
NE
NE
NE
0.492 b
NE
NE
50
10
10
0.5
10
0.5
0.2
10
2
Toluene

TPH-Diesel

TPH-Gasoline
TPH-Motor Oil

Trichloroethene
SW8260C

SW8015Mod

SW8015Mod
42

100

5
SW8015Mod

SW8260B
100

2.3
NE

NE
NE

NE
1

100

50
100

1
Estimated
Detection Limit a
10
0.5
40
Groundwater
Concentration
Reguiring
Evaluation
50 (10)
10

4,200

0.5

210

0.5

2(0.5)
42

100

50 (40)
100

2.3
Rationale
Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Corresponds to guantitation limit.

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Corresponds to beneficial use limit.

Corresponds to beneficial use limit.
-------
Table 9-7. (Continued)
Groundwater
Concentration
Beneficial Background Quantitation Estimated Requiring
Analyte Method Use Limit Concentration Limit Detection Limit a Evaluation Rationale

Soil Cleanup Standards (Ig/kg) (Continued)

2,4,6-Trichlorophenol SW8270C 0.5 NE 10 2 10(2) Quantitative results will be
provided at the concentration listed.
Trace concentrations will be
reported down to the estimated
detection limits (in parenthesis).

Xylenes SW8260B 17 NE 2 - 17 Corresponds to beneficial use limit.

a Estimated method detection limits (MDLs) which should be achievable for project laboratories by performing the MDL study following 40 CFR 136, Appendix B issued July 1, 1997.
The reported MDLs will be laboratory specific and shall be at or below estimated detection limit. Groundwater monitoring results will include reporting of all concentrations between
the laboratory MDL and guantitation limit as trace or "DNQ." In cases where a change in matrix or other effects caused the MDL or guantitation limit to differ significantly from the

laboratory-derived MDL/RL values, the results shall be flagged accordingly, along with the estimates of the detection limit and guantitation limit actually received.
b These compounds have not been detected in background wells. The value cited is the lowest detection limit used to analyze groundwater during the remedial investigation.

() = estimated detection limit
NA = not available
NE = not evaluated
Ig/kg = micrograms per kilogram
Ig/L = micrograms per Liter
-------
Table 9-8 SWMU 4 - Storm Drain Lagoon
Alternative 3 - Excavation and Disposal of Sediments
Item Description

DIRECT CAPITAL COSTS
SEDIMENT EXCAVATION/DEWATERING
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Excavation b
Sediment Dewatering
Clean Backfill
Site Restoration
Sediment Trap or Cyclones

POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c
Surface Water Analyses

CLASS III DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e
CLOSURE REPORT f
INDIRECT CAPITAL COSTS
Quantity
60
1
1
3,010
3,010
560
1
1
40
1
31
10
1

3,010

40
TOTAL DIRECT CAPITAL COST (DCC)
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
Unit
hour
lump sum
lump sum
ton
cubic yards
cubic yards
unit
unit
hour
lump sum
sample
sample
lump sum

ton

hour
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
Unit Cost
($)
$130
$10,000
$1,000
$30
$5
$10
$59,400
$150,000
$60
$500
$500
$125
$300
$30
$70

Total Cost
($)
$7,800
$10,000
$1,000
$90,300
$15,000
$5, 600
$59,400
$150,000
$2,400
$1,000
$15,500
$1,250
$300
$90,300
$2,800
$452, 650
$27,160
$18,110
$9,050
$45,270
$135,800
$76,950
$90,530
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$402,870

$855,520
-------
PRESENT WORTH
Interest Rate 7%
Years 1
TOTAL PRESENT WORTH $855,520

Assumptions:
a Two-person crew (one senior and one professional), 6 days, 10-hour days
b Sediment volume to be excavated is approximately 2,315 cubic yards (3,010 tons). Assumed moisture content of sediment is
50%.
c Assumes 1 sample collected per 100 cubic yards.
d Disposal of dewatered sediment at nearby municipal (Subtitle D) landfill.
e Cost includes transportation and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------
Table 9-9. SWMU 6 - Building 28 Sunp
Alternative 4a- Excavation and Class II Disposal
Item Description

DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation b
Imported Fill
Backfilling and Compaction

POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c

CLASS II DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e
CLOSURE REPORT f
INDIRECT CAPITAL COSTS
Quantity
20
1
1
100
130
78
130
12
1
5
1

40
TOTAL DIRECT CAPITAL COST (DCC)
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
Unit
hour
lump sum
lump sum
linear foot
ton
ton
ton
hour
lump sum
sample
lump sum

ton

hour
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
Unit Cost
($)
$130
$15,000
$500
$3
$30
$6
$30
$60
$500
$200
$300
$60
$70

Total Cost
($)
$2,600
$1,500
$500
$300
$3,900
$468
$3,900
$720
$500
$1,000
$300
$4, 680
$2,800
$23,168
$4,400
$1,000
$500
$2,400
$7,000
$4,000
$4,700
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$21,000

$44,168
-------
PRESENT WORTH
Interest Rate 7%
Years 1

TOTAL PRESENT WORTH $45,000

Assumptions:
a Two-person crew (one senior and one professional), 2 days, 10-hour days
b The total volume of soil to be excavated is 100 cy (130 tons).
c Assumes 1 sample collected per 20 cubic yards.
d Disposal of 78 tons of contaminated soil at McKittrick's Class II Disposal Facility.
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------
Table 9-10. SWMU 6 - Building 28 Sunp
Alternative 4b - Excavation and Class I Disposal
Item Description

DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation b
Imported Fill
Backfilling and Compaction

POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c

CLASS II DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e
CLOSURE REPORT f
INDIRECT CAPITAL COSTS
Quantity
20
1
1
100
130
78
130
12
1
5
1

40
TOTAL DIRECT CAPITAL COST (DCC)
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
Unit
hour
lump sum
lump sum
linear foot
ton
ton
ton
hour
lump sum
sample
lump sum

ton

hour
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
Unit Cost
($)
$130
$15,000
$500
$3
$30
$6
$30
$60
$500
$210
$300
$200
$70

Total Cost
($)
$2,600
$1,500
$500
$300
$3,900
$468
$3,900
$720
$500
$1,050
$300
$15, 600
$2,800
$34,138
$2,100
$1,400
$700
$3,500
$10,300
$5,900
$6,900
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$30,800

$64,938
-------
PRESENT WORTH
Interest Rate 7%
Years 1

TOTAL PRESENT WORTH $65,000

Assumptions:
a Two-person crew (one senior and one professional), 2 days, 10-hour days
b The total volume of soil to be excavated is 100 cy (130 tons).
c Assumes 1 sample collected per 20 cubic yards.
d Disposal of 78 tons of contaminated soil at Chemical Management's Kettleman Hills Class I Disposal Facility.
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------
Table 9-11. SWIVIU 7 - Burn Pit No. 1
Alternative 2 - Institutional Controls
Item Description

DIRECT CAPITAL COSTS
Installation of Two New Monitoring Wells

INDIRECT CAPITAL COSTS

Land Use Restrictions
ANNUAL GROUNDWATER MONITORING COSTS a

Chemical Analyses (Year 1)
Chemical Analyses (Years 2-4)
Fieldwork
Reporting
Quantity Unit

1 lump sum

TOTAL CAPITAL REQUIREMENT
Unit Cost
($)
$17,000
$50,000
FIVE-YEAR SITE REVIEW

Site Review Report
Site Review Assessment and Report
Contingency
PRESENT WORTH
1 lump sum
20% O&M

TOTAL 5-YEAR SITE REVIEW
Interest Rate
Years
TOTAL PRESENT WORTH
$10,000
7%
10
Total Cost
($)
$17,000

$50,000

$67,000
1 lump sum
1 lump sum
1 lump sum
1 lump sum
'ORING COSTS (YEAR 1)
', COSTS (YEARS 2-4)
$12,000
$9,000
$10,000
$15,000

$12,000
$9,000
$10,000
$15,000
$37,000
$34,000
$10,000
$2,000

$12,000
$208,000
a Groundwater monitoring of the two new wells will be conducted.
-------
Table 9-12. STCMU 8 - Burn Pit No. 2
Alternative 4 - Excavation and Class I Disposal
Item Description

DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Temporary Fence
Excavation b
Imported Fill
Backfilling and Compaction

POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c

CLASS I DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e

CLASS III DISPOSAL FACILITY f
Pre-Disposal Lab Analytical Testingt
Waste Profile
Disposal g

CLOSURE REPORT h
Quantity
100
1
1
800
10,400
5,800
10,400
Unit
hour
lump sum
lump sum
linear foot
ton
ton
ton
Unit Cost
($)
$130
$3,000
$1,000
$3
$30
$6
$30
$60
$500
$210
Total Cost
($)
$13,000
$3,000
$1,000
$2,400
$312,000
$34,800
$312,000
$2,400
$500
$16,800
4 0 hour
1 lump sum
80 sample
1 lump sum
3,400 ton
1 lump sum
2,400 ton
4 0 hour
$60
$500
$210
$300
$200
$300
$30
$70
$2,400
$500
$16,800
$300
$680,000
$300
$72,000
$2,800
GROUNDWATER MONITORING I
Installation of Two New Monitoring Wells j
Chemical Analyses
Fieldwork
Reporting
1
1
1
1
lump sum
lump sum
lump sum
lump sum
$20,000
$3,000
$10,000
$7,000
$20,000
$3,000
$10,000
$7,000
TOTAL DIRECT CAPITAL COST (DCC)
$1,493,300
-------
Table 9-12. (Continued)

INDIRECT CAPITAL COSTS

Engineering Design Services 6% of DCC $89,600
Office Engineering During Construction 4% of DCC $59,800
Non-Design Engineering 2% of DCC $29,900
Construction Management 10% of DCC $149,400
Contingency 30% of DCC $448,000
Contract Administration 17% of DCC $253,900
Contractor's Overhead and Profit 20% of DCC $298,700

TOTAL INDIRECT CAPITAL COST $1,329,300

TOTAL CAPITAL REQUIREMENT $2,822,600

PRESENT WORTH
Interest Rate 7%
Years 1

TOTAL PRESENT WORTH $2,823,000

Assumptions:
a Two-person crew (one senior and one professional), 10 days, 10-hour days
b Soil/debris volume to be excavated is approximately 8,000 cubic yards (10,400 tons). Approximately 5,800 tons is clean soil
that can be backfilled; 3,400 tons is contaminated soil; 2,400 tons is uncontaminated debris.
c Assumes 1 sample collected per 100 cy.
d Disposal of 3,400 tons of contaminated soil at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f Disposal of 2,400 tons of uncontaminated debris (e.g., concrete, wood, etc.) at nearby municipal (Subtitle D) landfill.
g Cost includes transportation and 10% county tax.
h 25-page report to be included in depot-wide closure report.
i Groundwater monitoring will be conducted.
j One new well will be installed to replace LM97A which will be removed during excavation of the former burn pit. The second
new well will be used to characterize the dieldrin plume downgradient of the site.
-------
40
1
1
320
320
320
hour
lump sum
lump sum
ton
ton
ton
$130
$1,000
$500
$30
$6
$30
$5,200
$1,000
$500
$9,600
$1,920
$9, 600
Table 9-13. SWMU 20 - Aboveground Solvent Tank/Building 26 Recoup
Operations and Areal Building 10
Alternative 3 - SVE, Excavation and Class I Disposal
Unit Cost
Item Description Quantity Unit ($)
DIRECT CAPITAL COSTS
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Excavation b
Imported Fill
Backfilling and Compaction

POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c

CLASS I DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e

CLOSURE REPORT f
SOIL VAPOR EXTRACTION
Construction Trailer (rental)
Mobilization/Demobilization
Air Extraction Vents
Collection Piping
Blower System Rental
Labor
Air Effluent Testing
Confirmation Sampling (Soil Gas)
Total Cost
($)
20
1
3
1
320
40

1
1
1
50
6
0.25
1
1

iST (DCC)
hour
lump sum
sample
lump sum
ton
hour

month
lump sum
lump sum
linear foot
months
man- year
lump sum
lump sum

$60
$500
$210
$300
$200
$70
Subtotal
$500
$3,000
$18,000
$20
$2,000
$75,000
$2,000
$2,000
Subtotal

$1,200
$500
$630
$300
$64,000
$2,800
$97,250
$500
$3,000
$18,000
$1,000
$12,000
$18,750
$2,000
$2,000
$57,250
$154,500
-------
Item Description

INDIRECT CAPITAL COSTS
Table 9-13. (Continued)
Quantity
Unit
Unit Cost
($)
Total Cost
($)
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC

TOTAL INDIRECT CAPITAL COST

TOTAL CAPITAL REQUIREMENT
$9,300
$6,200
$3,100
$15,500
$46,400
$26,300
$30,900

$137,700

$292,200
PRESENT WORTH
Interest Rate
Years
7%
1
TOTAL PRESENT WORTH
$293,000
Assumptions:
a Two-person crew (one senior and one professional), 4 days, 10-hour days
b The floor drain located within Building 26, and the sumps at Manholes W-l and W-3 will be excavated which represents
approximately 320 tons of soil concrete.
c Assumes 3 sample collected
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------
Table 9-14. SWMU 24 - Building 247 Petroleum Laboratory Waste Oil
Alternative 3 - Bioventing
Unit Cost
Item Description Quantity Unit ($)
Total Cost
($)
DIRECT CAPITAL COSTS
BIOVENTING
Construction Trailer (rental)
Mobilization/Demobilization
Air Injection Vent
Collection Piping
Blowers
Gauges, Valves, etc.
Eguipment Pads
Treatability Study

GROUNDWATER MONITORING a
Chemical Analyses
Fieldwork
Reporting

CLOSURE REPORT b
TOTAL DIRECT CAPITAL COST
1
1
1
20
1
1
1
1
1
1
1
40
:c)
month
lump sum
lump sum
linear foot
each
lump sum
each
lump sum
lump sum
lump sum
lump sum
hour

$500
$3,000
$14,000
$20
$2,000
$500
2,500
$10,000
$1,000
$5,000
$5,000
$70

$500
$3,000
$14,000
$400
$2,000
$500
$2,500
$10,000
$1,000
$5,000
$5,000
$2,800
$46,700
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
$2,900
$1,900
$1,000
$4,700
$14,100
$8,000
$9,400
TOTAL INDIRECT CAPITAL COST
$42,000
TOTAL CAPITAL REQUIREMENT
$88,700
-------
ANNUAL OPERATION AND MAINTENANCE COSTS
Energy
Labor
Maintenance Materials
3,500
0.5
1
kw-hr
man-year
lump sum
$0.10
$75,000
$2,000
$350
$37,500
$2,000
PRESENT WORTH
TOTAL O&M COSTS

Interest Rate
Years
7%
2
$39,850
TOTAL PRESENT WORTH
$166,000
Assumptions:
a Groundwater monitoring of LM118A will be conducted.
b 25-page report to be included in depot-wide report.
-------
Table 9-15. SWMU 27 - Building 206 Roundhouse Sunp/Area 1 Building 206
Alternative 3 - Excavation and Class I Disposal
Unit Cost
Item Description Quantity Unit ($)
Total Cost
($)
DIRECT CAPITAL COSTS
Construction Costs
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Excavation b
Imported Fill
Backfilling and Compaction
20
1
1
170
170
170
hour
lump sum
lump sum
ton
ton
ton
$130
$3,000
$1,000
$30
$6
$30
$2,600
$3,000
$1,000
$5,100
$1,020
$5,100
POST-EXCAVATION SAMPLING
Sampling
Personnel
Sampling Material
Analyses c

CLASS I DISPOSAL FACILITY d
Field Sampling
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e
CLOSURE REPORT f
TOTAL DIRECT CAPITAL COST (DCC)
16
1
8
10
1
170
40
ST (DCC)
hour
lump sum
sample
hour
lump sum
ton
hour

$60
$500
$210
$60
$300
$200
$70

$960
$500
$1, 680
$600
$300
$34,000
$2,800
$58, 660
INDIRECT CAPITAL COSTS
Engineering Design Services
Office Engineering During Construction
Non-Design Engineering
Construction Management
Contingency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
30% of DCC
17% of DCC
20% of DCC
$3,600
$2,400
$1,200
$5,900
$17,600
$10,000
$11,800
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$52,500

$111,160
-------
PRESENT WORTH
Interest Rate 7%
Years 1

TOTAL PRESENT WORTH $112,000

Assumptions:
a Two-person crew (one senior and one professional), 2 days, 10-hour days
b Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately
130 cubic yards (170 tons).
c Assumes 8 sample collected.
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------
Table 9-16. Drum Storage Area - Building 30
Alternative 2 - Institutional Controls
Item Description

DIRECT CAPITAL COSTS
Installation of One New Monitoring Well

INDIRECT CAPITAL COSTS

Land Use Restrictions

ANNUAL GROUNDWATER MONITORING COSTS a

Chemical Analyses
Fieldwork
Reporting
Quantity
Unit
lump sum
Unit Cost
($)
$10,000
TOTAL ANNUAL MONITORING COSTS
FIVE-YEAR SITE REVIEW

Site Review Report
Site Review Assessment and Report
Contingency
PRESENT WORTH
1 lump sum
20% of DCC

TOTAL 5-YEAR SITE REVIEW
Interest Rate
Years

TOTAL PRESENT WORTH

Assumptions:
a The new well will be monitored for SVOCs on a guarterly basis for one year.
$10,000
7%
10
Total Cost
($)
$10,000
1
TOTAL CAPITAL
1
1
1
lump
sum
$50,
000
REQUIREMENT
lump
lump
lump
sum
sum
sum
$2,
$5,
$5,
000
000
000
$50,
$60,
$2,
$5,
$5,
000
000
000
000
000
$12,000
$10,000
$2,000

$12,000
$87,000
-------
Table 9-17. Surface and Near-Surface Soils - Northern Depot Area
Alternative 3 - Asphalt Cover
DDJC-Tracy, Comprehensive RVFS
Item Description Quantity Unit

DIRECT CAPITAL COSTS
ASPHALT COVER-SURFACE AND NEAR-SURFACE SOILS
Asphalt a,b 138,000 square foot

ASPHALT PAVEMENT FOR ROADWAY
Asphalt a,b 9,700 square foot

CLOSURE REPORT c 40 hour

INDIRECT CAPITAL COSTS
Unit Cost
($)
$2.00

$2.00

$70
Total Cost
($)
$276,000

$19,400

$2,800
Enqineerinq Desiqn Services
Office Enqineerinq Durinq Construction
Non-Desiqn Enqineerinq
Construction Manaqement
Continqency
Contract Administration
Contractor's Overhead and Profit
6% of DCC
4% of DCC
2% of DCC
10% of DCC
10% of DCC
17% of DCC
20% of DCC
$17,900
$12,000
$6,000
$29,900
$29,900
$50,700
$59,700
TOTAL INDIRECT CAPITAL COST
TOTAL CAPITAL REQUIREMENT
$206,100

$504,300
PRESENT WORTH
Interest Rate
Years
7%
1
TOTAL PRESENT WORTH
$504,000
Assumptions:
a Asphalt unit cost based on quote from Capital Asphalt Construction, Inc., Stockton, CA, for 4 inches of asphalt and 4 inches
of aqqreqate base; unit cost includes qradinq and compaction.
b It is assumed that drainaqe controls are not needed.
c 25-paqe report to be included in depot-wide closure report.
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Table 9-18. SWMU 2/3 - Sewage and Industrial Waste Lagoons
Alternative 3 - Excavation and Class I Disposal
Item Description

DIRECT CAPITAL COSTS

Construction Costs
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Site Preparation
Excavation b

POST-EXCAVATION SAMPLING
Sampling
Analyses

CLASS I DISPOSAL FACILITY d
Pre-Disposal Lab Analytical Testing/
Waste Profile
Disposal e

CLOSURE REPORT f
INDIRECT CAPITAL COSTS

Engineering Design Services 6% of DCC

TOTAL INDIRECT CAPITAL COST

TOTAL CAPITAL REQUIREMENT
Unit Cost
uantity Unit ($)
1 hour $77,200
1 lump sum $15,000
1 lump sum $12,941
15067 ton $9.23
1 lump sum $355,400
1 lump sum $240,300
15,067 ton $75.50
40 hour $70
OST (DCC)
Total Cost
($)
$77,
$15,
$12,
$139,
$355
$240
200
000
941
000
,400
,300
$1,137,800
$2,
800
$1,980,500
$11,880

$11,880

$1,992,380
-------
PRESENT WORTH
Interest Rate 7%
Years 1

TOTAL PRESENT WORTH $2,132,000

Assumptions:
a Two-person crew (one senior and one professional), 2 days, 10-hour days
b Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately
130 cubic yards (170 tons).
c Assumes 8 sample collected.
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
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Table 9-19. SWMU 33 - Industrial Waste Pipeline
Alternative 3 - Excavation, Grouting, and Institutional Controls
Unit Cost
Item Description Quantity Unit ($)
DIRECT CAPITAL COSTS

Construction Costs
SOIL EXCAVATION
Engineering Oversight a
Mobilization & Demobilization
Grouting
Excavation b
Site Restoration
Pier Drilling
Hydroflush IWPL

POST-EXCAVATION SAMPLING
Sampling & Analyses c

CLASS I DISPOSAL FACILITY d
Waste Profile
Disposal e

CLOSURE REPORT f
40
Lump sum
Lump sum
hour
TOTAL DIRECT CAPITAL COST (DCC)

ANNUAL MONITORING (5 years) 1 Lump sum

TOTAL CAPITAL REQUIREMENT
$23,700

$
$27,200

$70

$65,000
Total Cost
($)
20
1
1
170
1
1
1
Hour
Lump sum
Lump sum
Ton
Lump sum
Lump sum
Lump sum
$130
$15,000
$37,300
$31
$1,000
$78,500
$7,500
$2,600
$15,000
$1,000
$5,200
$1,000
$78,500
$7,500
$23,700

$27,200

$2,800

$164,500

$65,000

$229,500
PRESENT WORTH
Interest Rate
Years

TOTAL PRESENT WORTH
7%
1
$245,600
Assumptions:
a Two-person crew (one senior and one professional), 2 days, 10-hour days
b Area to be excavated includes one sump, one hot spot of soil contamination, and one area of railroad tracks; approximately
130 cubic yards (170 tons).
c Assumes 8 sample collected.
d Disposal at Chemical Waste Management's Kettleman Hills Class I Disposal Facility
e Cost includes transportation, treatment (stabilization), and 10% county tax.
f 25-page report to be included in depot-wide closure report.
-------

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10.0 STATUTORY DETERMINATIONS

10.1 Sites Recommended for No Further Action

Twenty-one sites at Defense Depot San Joaquin (DDJC)-Tracy were recommended in the
comprehensive Remedial Investigation/Feasibility Study (RI/FS) for no further action due to the
absence of contamination (see Table 9-1). Two additional sites, solid waste management units
(SWMUs) 10A and 14, and 23 were recommended for no further action because there is not an
unacceptable risk to human health or the environment and the cost of a remedial alternative is
prohibitive (see Table 7-15). Because no remedial actions are required for these sites, no
discussion of statutory requirements is needed.

10.2 Statutory Requirements

Section 9.0 identifies the selected remedy for each site recommended for remedial action. This
section discusses how each selected remedy meets the statutory requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121.
Specifically, a remedy should:

• Protect human health and the environment;

• Comply with Applicable or Relevant and Appropriate Requirements (ARARs) (or
justify an ARAR waiver);

• Be cost-effective;

• Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable (also includes agency and
community acceptance); and

• Satisfy the preference for treatment to reduce toxicity, mobility, or volume as a
principal element (or explain why this preference is not valid).

10.3 Operable Unit (OU)1 Groundwater

The selected remedy (Alternative 3) modifies the OU 1 groundwater treatment system by installing
groundwater extraction wells in the three areas of dieldrin contamination (near SWMUs 2 and 3,
SWMU 8, and within the Tracy Annex). Granular activated carbon (GAG) will be used to remove the
pesticides.

10.3.1 Protection of Human Health and the Environment

The selected remedy extracts and treats groundwater from each of the three identified areas of
dieldrin contamination. Modeling results predict that the cleanup standard of 0.05 micrograms
per liter (Ig/L) for dieldrin will be met in approximately 50 years at SWMUs 2/3 and 8. However,
more than 50 years will be required to reduce the concentrations in the Tracy Annex below the
cleanup standard. Because dieldrin has low mobility and is, therefore, difficult to extract, a
more aggressive pumping strategy will not significantly affect the cleanup time. The selected
remedy will contain the dieldrin until the cleanup standard is met and is, therefore,
protective of human health and the environment.

10.3.2 Compliance With ARARs

The selected remedy complies with all federal and state ARARs. The cleanup standards specified
in the OU1 ROD (WCC, 1993) are consistent with chemical-specific ARARs as follows:

Aquifer Cleanup
Chemical Standard Basis

DCE 6.0 I/L California MCL
PCE 5.0 I/L Federal MCL
TCE 5.0 I/L Federal MCL
-------
No ARAR waivers are necessary. No chemical-specific ARARs (i.e., Maximum Contaminant Levels
[MCLs]) have been identified for dieldrin. The California Action Level of 0.05 Ig/L for dieldrin
is a performance standard. The location-specific ARARs identified for this site are listed in
Table 10-1. Action-specific ARARs for groundwater extraction and treatment are listed in Table
10-2.

10.3.3 Cost-effectiveness

Groundwater extraction with GAG is the only treatment alternative considered effective at OU 1.
Air stripping would remove the volatile organic compounds (VOCs) but would not remove the
dieldrin in the groundwater. GAG would remove both dieldrin and VOCs. The incremental cost of
adding treatment for dieldrin is small compared to the total treatment system cost. Alternative
3, the selected remedy, is the only alternative that addresses all three areas of dieldrin
contamination. It provides the best overall effectiveness proportional to the cost ($2,528,000)
and is therefore considered cost-effective. Reinjecting groundwater at this site also is
proposed as a cost-effective means for disposal of treated water.

10.3.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.3.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected remedy provides greater
long-term effectiveness and permanence than the other alternatives. The mobility of the
contaminants will be controlled through extraction, and treatment will be used to remove the
dieldrin from the aguifer permanently. The remedy provides short-term effectiveness, is readily
implementable, and is considered the most cost-effective (although the most costly) of the
alternatives. No cost effective treatment technologies with proven effectiveness were
identified. No resource recovery technigues were appropriate for dilute VOCs and pesticides.

10.3.4.2 The state and the United States Environmental Protection Agency (U.S. EPA) have
accepted the feasibility study and concur with the implementation of Alternative 3 as
recommended in this Record of Decision (ROD).

10.3.4.3 One public comment was received guestioning the capacity of the reinjection wells and
the cost of groundwater treatment (refer to Responsiveness Summary for discussion).

10.3.5 Preference for Treatment as a Principal Element

The use of groundwater extraction, followed by treatment by carbon (and air stripping if VOCs
are present) satisfies the statutory preference for the use of remedies that include treatment
as a principal element.

10.4 Group A Sites

The Group A Sites (SWMU I/Area 2, Area 1 Building 237, and Area 3) are considered potential
sources of VOCs to OU 1 groundwater. The selected remedy for the Group A sites is soil vapor
extraction (SVE)(Alternative 3).

10.4.1 Protection of Human Health and the Environment

The selected remedy is one of the two alternatives considered the most protective of human
health and the environment. In the selected remedy, VOCs are extracted from the soil and
treatment is provided at the surface to control air emissions.

10.4.2 Compliance With ARARs

10.4.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for the Group A sites are listed in Table 10-1. Action-
specific ARARs for SVE are listed in Table 10-3.

10.4.2.2 Background threshold concentrations and beneficial use numerical limits for the Group A
sites are listed in Table 7-1. Tables 10-4, 10-5, and 10-6 provide, for SWMU I/ Area 2, Area 1
Building 237, and Area 3, respectively, an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
-------
the basis for the cleanup standards developed. These standards were developed meet ARARs and to
protect background groundwater guality and beneficial uses in a way consistent with the
performance standards of the Water Quality Goals established in Basin Plan for the Central
Valley Region - Sacramento River and San Joaquin River Basins (Cal-EPA CVRWQCB, 1994).

10.4.3 Cost-effectiveness

Only Alternatives 3 and 4 are protective of human health and the environment; however,
Alternative 3 is much less costly to implement than Alternative 4. Alternative 3 is estimated to
cost $648,000, whereas Alternative 4 is estimated at $42,054,000. Because Alternative 3 provides
comparable effectiveness to Alternative 4 at a much lower cost, Alternative 3 is considered
cost-effective. Also, the VOCs in the soils at the Group A sites may be a continuing source of
VOCs in groundwater at OU 1. Therefore, remediating the Group A sites may significantly reduce
the cost of groundwater remediation at OU 1 by decreasing aguifer cleanup times.

10.4.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.4.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. Alternatives 3 (SVE) and 4
(excavation) both satisfy the threshold criteria. Alternative 3 was selected over Alternative 4
because it utilizes treatment to remove the contaminants and is much more cost-effective. The
selected alternative provides long-term effectiveness and permanence; reduces the toxicity,
mobility, and volume of the contaminants; provides short-term effectiveness; is readily
implementable; and is considered the most cost-effective of the alternatives. Alternative
treatment methods were not considered because SVE has been identified as the presumptive method
for treating VOCs in vadose zone soils. No economical method of recovering the VOCs was
identified.

10.4.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3.

10.4.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.4.5 Preference for Treatment as a Principal Element

The use of SVE, followed by emissions treatment, satisfies the statutory preference for the use
of remedies that include treatment as a principal element.

10.5 SWMU 4-Storm Drain Lagoon

The selected remedy is excavation with off-site disposal of the sediments (Alternative 3). All
sediment excavated from the bottom of the storm drain lagoon will be disposed of off-site.

10.5.1 Protection of Human Health and the Environment

The selected remedy is the only alternative that removes chemicals of concern (COCs) (metals
and pesticides) from the lagoon. Confirmation samples will be collected to ensure that the
excavation is protective of the environment. By combining the action proposed in this ROD with
the appropriate best management practices for stormwater pollution prevention, long-term
protection can be achieved. The lagoon will remain in use as part of the DDJC-Tracy stormwater
system.

10.5.2 Compliance With ARARs

10.5.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in Table 10-3.

10.5.2.2 Background threshold concentrations and beneficial use numerical limits for SWMU 4 are
listed in Table 7-1. Table 10-7 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
-------
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994). Table 10-8 identifies chemical-specific disposal reguirements.

10.5.2.3 The remedy includes the construction of a sediment trap and overflow weir to comply
with the narrative toxicity water guality objective for inland surface waters (Cal-EPA CVRWQCB,
1994). National Ambient Water Quality Criteria to protect freshwater life will be used as
performance standards to evaluate the success of the selected remedy.

10.5.3 Cost-effectiveness

Alternative 3 is the only alternative protective of human health and the environment. Therefore,
this alternative provides the most overall effectiveness relative to its cost of $552,700.

10.5.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.5.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence that is better or comparable to the other alternatives
(because they do not remove the existing contamination). Potential risks to ecological receptors
from pesticides and metals in surface soil are reduced to a hazard index of 10 (see Table 10-7) .
Excavation is used to remove the sediment from the lagoon permanently. The five-year review
process will be used to assess the possibility of a continuing low-level source. The remedy
provides short-term effectiveness, is readily implementable, and is considered cost-effective.
When combined with the appropriate best management practices as part of the DDJC-Tracy
stormwater program, this alternative best satisfies the five balancing criteria. No
cost-effective alternative technologies or recovery technigues for treating low concentrations
of pesticides were identified.

10.5.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the imple-
mentation of Alternative 3 as recommended in this ROD.

10.5.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.5.5 Preference for Treatment as a Principal Element

The selected remedy relies on excavation with off-site disposal rather than treatment. No
appropriate in situ methods were identified for treating the SVOCs and pesticides in the
sediment at the bottom of the lagoon. Treating the excavated soil (on or off site) is not cost-
effective due to the relatively small guantity of soil excavated, the cost for tests to identify
an appropriate treatment process, and the cost of treatment.

10.6 SWMU 6-Building 28 Sump

The selected remedy is excavating the contaminated soils and disposing of them at an off-site
disposal facility (Alternative 4).

10.6.1 Protection of Human Health and the Environment

The selected remedy removes the potential threats that pesticides pose to the beneficial uses of
groundwater and background groundwater guality. The selected remedy is considered the most
effective of the alternatives for protecting human health and the environment.

10.6.2 Compliance With ARARs

10.6.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for excavation and disposal are listed in Table 10-3.

10.6.2.2 Background threshold concentrations and beneficial use numerical limits for SWMU 6 are
listed in Table 7-1. Table 10-9 provides an identification of the ARARs, other factors that are
-------
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to meet ARARs and protect background groundwater quality and beneficial uses in a way
consistent with the chemical-specific performance standards of the Water Quality Goals
established in Basin Plan for the Central Valley Region - Sacramento River and San Joaguin River
Basins (Cal-EPA CVRWQCB, 1994).

10.6.3 Cost-effectiveness

Only Alternatives 3 and 4 are protective of human health and the environment; however,
Alternative 4 is much less costly to implement than Alternative 3. Alternative 4 is estimated to
cost between $45,000 and $65,000, whereas Alternative 3 is estimated at $169,000. Because the
selected excavation and off-site disposal action of Alternative 4 provides comparable or better
effectiveness than Alternative 3 at lower cost, Alternative 4 is considered a cost-effective
remedy. In addition, excavation probably costs less than maintaining the long-term institutional
controls of Alternative 2.

10.6.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.6.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, reduces the volume of the contaminants, provides
short-term effectiveness, is readily implementable, and is considered cost-effective. No
cost-effective alternative treatment technologies or resource recovery techniques were
identified for low levels of pesticide contamination.

10.6.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the imple-
mentation of Alternative 4 as recommended in this ROD.

10.6.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.6.5 Preference for Treatment as a Principal Element

The selected remedy relies on excavation with off-site disposal rather than treatment. No
appropriate in situ methods were identified for treating the pesticides in the soil. Treating
the excavated soil (on or off site) would not be cost-effective due to the relatively small
quantity of soil excavated, the cost for tests to identify an appropriate treatment process, and
the cost of treatment. In situ stabilization is considered in Alternative 3 as a treatment
option, but there are uncertainties regarding its long-term effectiveness and it is less
cost-effective.

10.7 SWMU 7-Burn Pit No. 1

The selected remedy for SWMU 7 is institutional controls (Alternative 2). The planned
institutional controls include land use restrictions around the disposal pits. The restrictions
would designate the land for industrial use and prevent its use for schools, hospitals, play-
grounds, or housing until COCs are below levels of concern. The institutional controls also
restrict construction in and the demolition of Buildings 19 and 21. In addition, the remedy
includes the use of monitoring to evaluate the effectiveness of these controls in protecting the
beneficial uses of groundwater.

10.7.1 Protection of Human Health and the Environment

The selected remedy is protective of human health for both current and future exposure
scenarios. Groundwater monitoring is used to identify potential impacts to groundwater that were
identified in the water quality site assessment. The analyte concentrations that would require
analysis in the Well Monitoring Program are specified in Section 9.5.3. Institutional controls
for Buildings 19 and 21 and groundwater monitoring are continued at least until the first
five-year review and the need for continued controls will be reevaluated at that time.

10.7.2 Compliance With ARARs
-------
10.7.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for institutional controls are listed in Table 10-3.

10.7.2.2 Background threshold concentrations and beneficial use numerical limits for SWMU 7 are
listed in Table 7-1. Table 10-10 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect groundwater guality and beneficial uses, consistent with the
chemical-specific in performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.7.3 Cost-effectiveness

Alternatives 2 through 4 are considered protective of human health and the environment.
Long-term threats to groundwater have not been confirmed and the long-term monitoring of the
selected remedy (Alternative 2) would identify any potential concerns and reguire discussing in
the Well Monitoring Program if a concern is identified. The selected remedy costs $208,000 to
implement; Alternatives 3 and 4 cost significantly more at $822,000 and $2,605,000 respectively.
Therefore, the selected remedy provides the most cost-effective remedy at SWMU 7.

10.7.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.7.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. Given that groundwater contamination
has not been detected and much of the soil is underneath Buildings 15, 18, 19 and 21, the cost
of a more aggressive alternative does not appear warranted. The long-term effectiveness is
assessed through monitoring. The toxicity, mobility, and volume of contaminants will not be
reduced; however, much of the soil is already covered by pavement or buildings, so contaminant
migration is limited. The selected remedy provides short-term effectiveness, is readily
implementable, and is considered cost-effective. No cost-effective alternative treatment
technologies or resource recovery technigues were identified for low levels of pesticide
contamination.

10.7.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the imple-
mentation of Alternative 2 as recommended in this ROD.

10.7.4.3 One public comment expressed concern over the cost of excavation (Alternative 4) and
potential exposure to excavated soils. The comment also expressed interest in encapsulation
(Alternative 3) (refer to Responsiveness Summary for discussion).

10.7.5 Preference for Treatment as a Principal Element

The selected remedy relies on institutional controls rather than treatment. The potential threat
to the beneficial uses; of groundwater has not been confirmed through historical monitoring.
Also, portions of the SWMU 7 burial pits are covered by buildings. Treatment would be expensive
and very difficult to implement at this site.

10.8 SWMU 8-Burn Pit No. 2

The selected remedy is excavating the contaminated soils from the former burn pit and disposing
of them at a Class I disposal facility (Alternative 4).

10.8.1 Protection of Human Health and the Environment

The selected remedy provides the greatest protection of human health and the environment.
Contaminated soils (containing SVOCs, pesticides, herbicides, and petroleum hydrocarbons) are
permanently removed from the site and disposed of at a Class I disposal facility.

10.8.2 Compliance With ARARs

10.8.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
-------
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific
ARARs for excavation and disposal are listed in Table 10-3.

10.8.2.2 Background threshold values and beneficial use numerical limits for SWMU 8 are listed
in Table 7-1. Table 10-11 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.8.3 Cost-effectiveness

Only Alternative 4 is protective of human health and the environment. The estimated cost for
Alternative 4 is $2,823,000. SWMU 8 is a major potential source area for dieldrin contamination
in groundwater at OU 1. As explained in Section 10.4.3, it is considered more cost-effective to
address source areas than to extend operation of the OU 1 groundwater treatment system.
Therefore, the selected excavation and off-site disposal action of Alternative 4 is considered a
cost-effective remedy.

10.8.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.8.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, reduces the volume of the contaminants, provides
short-term effectiveness, is readily implementable, and is considered cost-effective. None of
the other alternatives satisfied the threshold criteria as well as the selected remedy. There is
a trade-off between cost and satisfying the other four balancing criteria. The additional cost
is considered justified, and the alternative is considered cost-effective. No cost-effective
alternative treatment technologies or recovery technigues were identified for low levels of
pesticide contamination.

10.8.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the imple-
mentation of Alternative 4 as recommended in this ROD.

10.8.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.8.5 Preference for Treatment as a Principal Element

The selected remedy relies on excavation with off-site disposal rather than treatment. No
appropriate in situ methods were identified for treating the pesticides in the soil. Bioventing
was evaluated, but was not as effective as the selected remedy in addressing pesticide
contamination at the site (dieldrin is of particular concern).

10.9 SWMU 20 Aboveground Solvent Tank
Building 26 Recoup Operations and Area 1
Building 10

The selected remedy includes soil vapor extraction, excavation with disposal at a Class I
disposal facility, and natural attenuation (Alternative 3).

10.9.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. A portion of the
contaminated soils (containing SVOCs, pesticides, and petroleum hydrocarbons) is permanently
removed from the site and disposed of at a Class I disposal facility. The remaining soils are
treated by SVE and natural attenuation. The selected remedy addresses all existing site risks
and potential impacts to groundwater.

10.9.2 Compliance With ARARs
-------
10.9.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for SVE and excavation and disposal are listed in Table 10-3.

10.9.2.2 Background threshold values and beneficial use numerical limits for SWMU 20 are listed
in Table 7-1. Table 10-12 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.9.3 Cost-effectiveness

Only Alternatives 3 and 4 are protective of human health and the environment. Alternative 3,
soil vapor extraction with excavation, provides comparable effectiveness to the larger
excavation remedy of Alternative 4; however, Alternative 3 is less costly to implement.
Alternative 3 is estimated to cost $293,000, whereas Alternative 4 is estimated at $355,000.
Therefore, Alternative 3 is considered the most cost-effective alternative.

10.9.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.9.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, reduces the volume of the contaminants, provides
short-term effectiveness, is readily implementable, and is considered cost-effective. A larger
excavation (Alternative 4) could be marginally more effective, but is also more difficult to
implement and more expensive. No cost-effective alternative treatment technologies or recovery
technigues were identified for low levels of pesticide contamination.

10.9.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3 as recommended in this ROD.

10.9.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.9.5 Preference for Treatment as a Principal Element

The selected remedy relies on a combination of treatment (SVE), excavation with off-site
disposal, and natural attenuation. The excavation is limited and addresses the soil beneath the
sumps and floor drains associated with Buildings 10 and 26. The phenols are expected to
attenuate naturally. Per the reguest of the Regional Water Quality Control Board (RWQCB),
predesign soil-gas sampling will be performed in areas designated for SVE remediation and the
results may expand the size of the area targeted for SVE treatment.

10.10 SWMU 24-Petroleum Waste Oil Tank

The selected remedy for SWMU 24 is bioventing (Alternative 3). However, predesign soil gas
sampling will be conducted to determine if SVE also needs to be implemented.

10.10.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. Potential threats
to background groundwater guality and beneficial uses from VOCs, SVOCs, and petroleum
hydrocarbons are permanently eliminated. Although bioventing does not enhance the biodegradation
of polychlorinated biphenyls (PCBs), the threat posed to groundwater by PCBs is low relative to
the threat posed by other COCs. The remedy includes three guarters of monitoring data to assess
the natural attenuation of petroleum hydrocarbons in groundwater. Potential risks to future
depot workers are eliminated by this remedy.

10.10.2 Compliance With ARARs
-------
10.10.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for bioventing are listed in Table 10-3.

10.10.2.2 Background threshold values and beneficial use numerical limits for SWMU 24 are listed
in Table 7-1. Table 10-13 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.10.3 Cost-effectiveness

Alternative 4 is considered cost-effective because pesticides and PCBs are permanently removed
from the site. Alternatives 3 and 5 are also considered cost-effective because long-term threats
to groundwater from pesticides and PCBs are considered relatively low at SWMU 24. Alternative 3
is the least costly of these alternatives to implement ($166,000 as compared to $214,000 for
Alternative 4 and $263,000 for Alternative 5). Therefore, Alternative 3 provides the most
cost-effective remedy for the site.

10.10.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.10.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, reduces the toxicity and volume of the contaminants,
provides short-term effectiveness, is readily implementable, and is considered cost-effective.
Excavation (Alternatives 4 and 5) is only marginally more effective, more difficult to implement
(since excavation under Building 247 would be reguired), and more costly. No cost-effective
alternative treatment technologies or recovery technigues were identified for low levels of
pesticide contamination.

10.10.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3 as recommended in this ROD.

10.10.4.3 One public comment expressing concern over the high cost of excavation (Alternatives 4
and 5) and potential exposure to excavated soil was received (refer to Responsiveness Summary
for discussion).

10.10.5 Preference for Treatment as a Principal Element

The use of bioventing satisfies the statutory preference for the use of remedies that include
treatment as a principal element.

10.11 SMU 27-Building 206
Roundhouse Sump/Area 1
Building 206

The selected remedy is excavating contaminated soil and disposing of it at a Class I disposal
facility (Alternative 3).

10.11.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. Potential threats
to background groundwater guality and beneficial uses from VOCs, pesticides, and herbicides are
permanently eliminated. Potential risks to future depot workers and the environment are also
eliminated.

10.11.2 Compliance With ARARs

10.11.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific
-------
ARARs for excavation and disposal are listed in Table 10-3.

10.11.2.2 Background threshold limits and beneficial use numerical limits for SWMU 27 are listed
in Table 7-1. Table 10-14 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.11.3 Cost-effectiveness

Alternative 3 is the only alternative protective of human health and the environment and
therefore provides the most overall effectiveness relative to its cost of $112,000. Depending on
the level of contamination in the excavated soil, Alternative 3 may be less expensive than the
long-term costs of implementing institutional controls.

10.11.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.11.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, reduces the volume of the contaminants, provides
short-term effectiveness, is readily implementable, and is considered cost-effective. No
cost-effective alternative treatment technologies or recovery technigues were identified for low
levels of pesticide contamination.

10.11.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3 as recommended in this ROD.

10.11.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.11.5 Preference for Treatment as a Principal Element

10.12 Building 30 Drum Storage Area

The selected remedy for the Building 30 Drum Storage Area is institutioned controls with
groundwater monitoring (Alternative 2).

10.12.1 Protection of Human Health and the Environment

Baseline risk assessment results do not indicate potential adverse risks to depot workers or
future construction workers. A potential threat to background groundwater guality was
identified; however, the COCs have not been detected in the groundwater at this site. Modeling
suggests a future threat to groundwater is possible. The selected remedy protects human health
and the environment by reguiring monitoring and discussion in the Well Monitoring Program if a
concern is identified. The analyte concentrations that would reguire analysis in the Well
Monitoring Program are identified in Section 9.5.8.

10.12.2 Compliance With ARARs

10.12.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for institutional controls are listed in Table 10-3.

10.12.2.2 Background threshold concentrations and beneficial use numerical limits for the
-------
Building 30 Drum Storage Area are listed in Table 7-1. Table 10-15 provides an identification of
the ARARs, other factors that are involved in developing cleanup standards, and the cleanup
standards themselves. The ARARs are the basis for the cleanup standards identified. These
standards rely on the best practicable technology to protect background groundwater quality and
beneficial uses, consistent with the chemical-specific performance standards of the Water
Quality Goals established in Basin Plan for the Central Valley Region - Sacramento River and San
Joaguin River Basins (Cal-EPA CVRWQCB, 1994) .

10.12.3 Cost-effectiveness

Alternatives 2 and 3 are considered protective of human health and the environment. Long-term
threats to groundwater from the drum storage area have not been confirmed and the long-term
monitoring of Alternative 2 would identify any future concerns. Alternative 2, institutional
controls, costs $87,000 to implement. Alternative 3, excavation and off-site disposal, costs
significantly more at $1,860,000. Excavation is considered cost-prohibitive because of the
difficulty of excavating beneath a building where sensitive robotics activities are conducted.
Therefore, Alternative 2 provides the most cost-effective remedy for the site.

10.12.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.12.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence, provides short-term effectiveness as groundwater
monitoring will identify any short-term impacts, is readily implementable, and is considered
cost-effective. To ensure that the threshold criteria are met, the institutional controls
include installing a monitoring well and quarterly monitoring for SVOCs for one year to confirm
that there is no threat to background groundwater quality. No cost-effective alternative
treatment technologies or recovery techniques were identified for low levels of phthalate
contamination.

10.12.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 2 as recommended in this ROD.

10.12.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.12.5 Preference for Treatment as a Principal Element

The selected remedy relies on institutional controls rather than treatment. The potential
threat to the beneficial uses of groundwater has not been confirmed through historical
monitoring. Further groundwater monitoring will be performed to assess the success of
institutional controls.

10.13 Surface and Near-Surface Soils-Northern Depot Area

The selected remedy for the surface and near-surface soils in the Northern Depot Area is
installing an asphalt cover (Alternative 3).

10.13.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. No impacts to
background groundwater quality or beneficial uses were identified at this site. The installation
of an asphalt cap, to be maintained by DDJC-Tracy, will prevent depot workers (grader operators)
from being exposed to arsenic and manganese in the surface and near-surface soils in the area.
The lifetime of the cap is estimated at 20 years as long as annual or semiannual sealing is
provided.

10.13.2 Compliance With ARARs

The selected remedy complies with all federal and state ARARs. No ARAR waivers are necessary.
Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs for
asphalt cover installation are listed in Table 10-3. No COCs were identified as impacting
groundwater quality at this site. The cleanup standards (Section 9.5.9.3) correspond to a hazard
-------
index of 1.0 for grader operators.

10.13.3 Cost-effectiveness

Alternatives 3 and 4 are the only alternatives that provide long-term effectiveness for the
surface and near-surface soils in the Northern Depot Area. Alternative 3, asphalt paving, costs
significantly less than the excavation and off-site disposal proposed in Alternative 4.
Alternative 3 is estimated at $504,000, whereas Alternative 4 is estimated to cost between
$769,000 and $995,000, depending on the level of contamination in the soil. Because Alternative
3 provides comparable worker protection to Alternative 4, Alternative 3 is considered highly
effective relative to its cost.

10.13.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.13.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected alternative provides
long-term effectiveness and permanence (the asphalt cover will need to be maintained by
DDJC-Tracy), reduces the mobility of the contaminants, provides short-term effectiveness, is
readily implementable, and is considered cost-effective. No alternative treatment technologies
or recovery technigues were identified for low levels of disperse metals.

10.13.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3 as recommended in this ROD.

10.13.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.13.5 Preference for Treatment as a Principal Element

The selected remedy relies on containment rather than treatment. The asphalt cover will protect
workers from exposure to arsenic and manganese in the soils. The size of the Northern Depot Area
and nature of the contamination preclude a cost-effective approach for treatment.

10.14 SWMUs 2 and 3-Sewage and Industrial Waste Lagoons

The selected remedy is excavation with off-site disposal (Alternative 3).

10.14.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. Risks to human
health and threats to beneficial uses and background groundwater guality are addressed by
excavation. Impacts to ecological receptors will be addressed by installing a geofabric filter
and clean backfill to isolate contaminants from receptors.

10.14.2 Compliance With ARARs

10.14.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action-specific ARARs
for institutional controls are listed in Table 10-3.

10.14.2.2 Background threshold values and beneficial use numerical limits for SWMUs 2/3 are
listed in Table 7-1. Table 10-16 provides an identification of the ARARs, other factors that
are involved in developing cleanup standards, and the cleanup standards themselves. The ARARs
are the basis for the cleanup standards identified. These standards rely on the best
practicable technology to protect background groundwater guality and beneficial uses in a way
consistent with the chemical-specific performance standards of the Water Quality Goals
established in Basin Plan for the Central Valley Region - Sacramento River and San Joaguin River
Basins (Cal-EPA CVRWQCB, 1994).

10.14.3 Cost-effectiveness

The selected remedy is the only alternative that is protective of human health and the environ-
ment. The estimated cost is approximately $2,100,000. It is considered more cost-effective to
-------
address the soil source area than to extend the operation of the OU 1 groundwater treatment
system. Therefore, excavation and off-site disposal is considered a cost-effective remedy.

10.14.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery

10.14.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected remedy provides short- and
long-term effectiveness and permanence, reduces the volume of the contaminants, is readily
implementable, and is considered cost-effective. No cost-effective alternative treatment
technologies or recovery technigues were identified for low levels of pesticide contamination.

10.14.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 3 as recommended in this ROD.

10.14.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.14.5 Preference for Treatment as a Principal Element

The selected remedy relies on excavation rather than treatment. No appropriate in situ methods
were identified for permanently treating the pesticides in the soils.

10.15 SWMU 33-Industrial Waste Pipeline (IWPL)

The selected remedy for the IWPL is grouting, limited excavation, and institutional controls
(Alternative 3). The institutional controls include groundwater monitoring to identify potential
impacts to background groundwater guality from the aldrin, dieldrin, diethylphthalate, and
di-n-butylphthalate that will remain after the excavation is completed. Section 9.6.2 identifies
the beneficial use limits that cannot be exceeded in the groundwater samples without reguiring
discussion in the Well Monitoring Program.

10.15.1 Protection of Human Health and the Environment

The selected remedy provides protection of human health and the environment. No risks to human
health or ecological receptors were identified for SWMU 33. A portion of the contaminants will
be removed in the excavation. Groundwater monitoring is specified to assess any impact of the
residual soils on groundwater guality.

10.15.2 Compliance With ARARs

10.15.2.1 The selected remedy complies with all federal and state ARARs. No ARAR waivers are
necessary. Location-specific ARARs for this site are listed in Table 10-1. Action specific ARARs
for excavation and institutional controls are listed in Table 10-3. Table 10-8 lists waste soil
and sediment hazardous waste levels for both the total and leachable portion of constituents
from 22 CCR Division 4.5, Section 66261.

10.15.2.2 Background threshold values and beneficial use numerical limits for the SWMU 33 are
listed in Table 7-1. Table 10-17 provides an identification of the ARARs, other factors that are
involved in developing cleanup standards, and the cleanup standards themselves. The ARARs are
the basis for the cleanup standards identified. These standards rely on the best practicable
technology to protect background groundwater guality and beneficial uses in a way consistent
with the chemical-specific performance standards of the Water Quality Goals established in Basin
Plan for the Central Valley Region - Sacramento River and San Joaguin River Basins (Cal-EPA
CVRWQCB, 1994).

10.15.3 Cost-effectiveness

Alternative 3 is considered cost-effective because contamination along the IWPL does not appear
to be impacting groundwater at this time. The limited excavation, grouting, and institutional
controls in Alternative 3 are estimated to cost $242,600 and will be effective in detecting any
future groundwater concerns.

10.15.4 Utilization of Permanent Solutions, Alternative Treatment, and Resource Recovery
-------
10.15.4.1 The selected remedy uses permanent solutions and alternative technologies or resource
recovery technologies to the maximum extent practicable. The selected remedy may not prevent
soil contaminants from migrating to groundwater; however, the removal action addresses the most
contaminated areas, and most of the area in question is paved. In addition, the selected remedy
represents implementation of the best practicable technology, consistent with SWRCB Resolution
No. 68-16. The groundwater monitoring program specifies beneficial use limits that cannot be
exceeded without discussion in the Well Monitoring Program. The mobility, toxicity, and volume
of the contaminants will be reduced through limited excavation. The selected remedy provides
short-term effectiveness and is implementable. It is considered the most cost-effective of the
alternatives. The cost-benefit analysis indicates that it is more cost-effective to rely on the
OU 1 groundwater treatment system to address pesticides flushed from the vadose zone than to
further excavate the contaminated soils. No cost-effective alternative treatment technologies or
recovery techniques were identified for low levels of pesticide contamination.

10.15.4.2 The state and U.S. EPA have accepted the feasibility study and concur with the
implementation of Alternative 2 as recommended in this ROD.

10.15.4.3 One public comment expressing concern over the high cost of excavation and potential
exposure to excavated soil was received (refer to Responsiveness Summary for discussion).

10.15.5 Preference for Treatment as a Principal Element

The selected remedy relies on limited excavation, grouting, and institutional controls rather
than treatment. Further treatment beyond that proposed in the selected remedy is not considered
cost-effective. Further groundwater monitoring will be performed to assess the success of the
selected remedy.
-------
Table 10-1. Compliance With Location-Specific ARARS
No.

2.
3.
Source

Nat'l Historic
Preservation Act
(16 U.S.C. °461-
467)

Endangered
Species Act
Standard,
Requirement,
Criterion, or Limitation

NA
50 CFR 17
Executive Order
11988,
Protection of
Flood Plains
40 CFR 6, Section 6.302(b)
Description

No building or location at DDJC-Tracy
has been considered for the National
Registry of Historic Sites.
Several species on both the federal and
state endangered or threatened species
lists are found in the vicinity of DDJC-
Tracy. Any remedial action taken at
the site must not jeopardize these
species.

Relates to actions that will occur in a
flood plain, i.e., lowlands and relatively
flat areas adjoining inland and coastal
waters and other flood-prone areas.
Actions must be taken to avoid adverse
effects, minimize potential harm,
restore and preserve natural and
beneficial values.
ARARs, or
Performance Standard
(for NPL Sites)

Not applicable.
Applicable.

Applies to remedial actions
taken at all DDJC-Tracy
sites.
Not applicable.

DDJC-Tracy does not lie
within a floodplain area.
Compliance

NA
No known rare or endangered
species have been observed at the
depot. There is no reason to
believe that planned remedial
actions will jeopardize any
endangered or threatened species.

NA
4. California Fish
and Game Code
Division 6, Part 1,
Chapter 6
This statute prohibits the deposition of
any substance deleterious to fish, plant,
or bird life where the substance can
pass into the waters of the state. This
code may apply to the Storm Drain
Lagoon (SWMU 4).
Applicable.

May apply to the Storm
Drain Lagoon (SWMU 4).
No deleterious substances will
deposited in the Storm Drain
Lagoon.
be
-------
Table 10-2. Compliance With Action-Specific ARARs for OU 1 Groundwater Remediation
No. Source

1 Porter-Cologne
Water Quality
Control Act
(California Water
Code Section 13000
et seq.).

2 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240,13241,
13242,13243).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000,13304,
13240,13241,
13242,13243).
Standard,
Requirement,
Criterion, or Limitation

California Water Code
Section 13243.
the discharge of waste, or certain
Water Quality Control Plan
(Basin Plan) for the
RWQCB, Central Valley
Region.
Description
ARAR or Performance
Standard Applicability
RWQCB, Central Valley
Region Basin Plan, "Policy
for Investigation and
Cleanup of Contaminated
Sites."
The RWQCB may specify Applicable. Applies to
certain conditions or areas where groundwater remedial actions.

types of waste, is not permitted.
Establishes water quality
objectives, including narrative
and numerical standards, that
protect the beneficial uses and
water quality objectives of
surface and ground waters in the
region. Describes implementa-
tion plans and other control
measures designed to ensure
compliance with statewide plans
and policies and provide
comprehensive water quality
planning.
Establishes and describes policy
for investigating and remediating
contaminated sites. Also
includes implementation actions
for setting groundwater and soil
cleanup standards.
Applicable. Specific
applicable portions of the
Basin Plan include beneficial
uses of affected water bodies
and water quality objectives to
protect those uses. Any
activity, including but not
limited to the discharge of
contaminated soils or waters
or in situ treatment or
containment of contaminated
soils or waters, must not result
in actual water quality
exceeding water quality
objectives.
Applicable. Cleanup
standards for OU 1
groundwater should be equal
to background concentrations
unless such standards are
technically and economically
infeasible to achieve. In such
cases, cleanup standards
should not exceed applicable
water quality objectives.
Compliance

The location of the treated
water discharge and waste
discharge standards will be
approved by the RWQCB
before the discharge occurs.
Beneficial uses were
considered in establishing
cleanup standards for
groundwater contaminants.
The most stringent federal or
state objective was selected
as the appropriate cleanup
standard. The waste
discharge standards
developed for treated
groundwater are protective of
groundwater quality.
Cleanup standards do not
exceed the applicable water
quality objectives. It has been
demonstrated in the RI/FS
that it is not economically
feasible to reduce
contaminant concentrations
to background levels.
-------
Table 10-2. (Continued)
No. Source

4 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240,13241,
13242,13243).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240,13241,
13242,13243).
Standard,
Reguirement,
Criterion, or Limitation

RWQCB, Central Valley
Region Basin Plan, "Policy
for Application of Water
Quality Objectives."
RWQCB, Central Valley
Region Basin Plan,
"Wastewater Reuse
Policy."
Description

This policy defines water guality
objectives and explains how the
Regional Water Board applies
the numerical and narrative
water guality objectives to
ensure the reasonable protection
of beneficial uses of water and
how the Regional Water Board
applies Resolution No. 68-16 to
promote the maintenance of
existing high-guality waters.

Reguires applicants for waste
discharge reguirements and
discharge permits to evaluate
land disposal as an alternative to
discharge to surface waters.
ARAR or Performance
Standard Applicability

Applicable. Applies to OU 1
groundwater remedial actions.
Applicable. Applies to
groundwater extracted by the
OU 1 groundwater treatment
system.
Compliance

Water guality objectives were
defined and are consistent
with the referenced sections.
Reinjection of treated
groundwater will be pursued
as the primary disposal
method. Treated groundwater
that cannot be reinjected will
be disposed to the percolation
ponds.
-------
Table 10-2. (Continued)
No. Source

6 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13263,13304).
Standard,
Requirement,
Criterion, or Limitation

State Water Resources
Control Board Resolution
No. 68-16 ("Anti-
degradation Policy").
Description

Requires that high-quality
surface and ground waters be
maintained to the maximum
extent possible. Degradation of
waters is allowed (or allowed to
remain) only if it is consistent
with the maximum benefit to the
people of the state, does not
unreasonably affect present and
anticipated beneficial uses, and
does not result in water quality
less than that prescribed in
RWQCB and SWRCB policies.
If degradation is allowed, the
discharge must meet best
practicable treatment or control,
which must prevent pollution or
nuisance and result in the highest
water quality consistent with
maximum benefit to the people
of the state.
ARAR or Performance
Standard Applicability

Applicable. Applies to
discharges of waste to waters,
including discharges to soil
that may affect surface or
ground waters. In situ cleanup
standards for contaminated
groundwater must be set at
background level, unless
allowing continued
degradation is consistent with
the maximum benefit to the
people of the state. If
degradation of waters is
allowed or allowed to remain,
the discharge must meet best
practicable treatment or
control standards, and result in
the highest water quality
possible that is consistent with
the maximum benefit to the
people of the state. In no case
may water quality objectives
be exceeded.
Compliance

DDJC-Tracy will apply best
practicable treatment or
control method for ground
water remediation. Water
quality objectives will not be
exceeded.
-------
Table 10-2. (Continued)
No. Source

7 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000,13140, 13240,
13260,13263,
13267,13300,
13304,13307).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000,13140,
13240) .
Standard,
Reguirement,
Criterion, or Limitation

State Water Resources
Control Board Resolution
No. 92-49 (as amended
21 April 1994).
State Water Resources
Control Board Resolution
No. 88-63 ("Sources of
Drinking Water Policy")
(as contained in the
RWQCB's Water Quality
Control Plan).
Description

Establishes reguirements for
investigation, cleanup, and
abatement of discharges.
Among other reguirements,
dischargers must clean up and
abate the effects of discharges in
a manner that promotes the
attainment of either background
water guality, or the best water
guality that is reasonable if
background water guality cannot
be restored. Reguires the
application of Title 23, CCR,
Section 2550.4 reguirements to
cleanups.

Specifies that, with certain
exceptions, all groundwaters and
surface waters must have the
beneficial use of municipal or
domestic water supply.
ARAR or Performance
Standard Applicability

Applicable. Applies to
groundwater remedial actions.
Applicable. Applies in
determining beneficial uses for
waters that may be affected by
discharges of waste.
Compliance

The groundwater cleanup
system will be operated in
such a way that the best
water guality reasonable is
restored. The reguirements of
Chapter 15 will be met.
Water use as municipal or
domestic water supply used
as a basis for determining
beneficial use limits.
-------
Table 10-2. (Continued)
No. Source

9 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267,13304).
10 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172,13260,13263,
13267,13304).
Standard,
Reguirement,
Criterion, or Limitation

Title 27, CCR, Division 2,
Subdivision 1 (Section
20080 et seg.)
Title 23, CCR, Division 3,
Chapter 15 (Section 2510
et seg.
Title 27,CCR, Section
20090(d),
Title 23, CCR, Section
2511 (d).
from immediate place of release
and discharged to land must be
managed in accordance with the
classification (Title 27,CCR,
,Section 20200 /Title 23, CCR,
section 2520) and siting
reguirements of Title 27 or Title
23 and wastes contained or left
in place must comply with Title
27 or Title 23 to the extent
feasible.
Description

Establishes waste and siting
classification systems and
minimum waste management
standards for discharges of waste
to land for treatment, storage,
and disposal. Engineered
alternatives that are Consistent
with the Title 27/Title 23
performance goals may be
considered. Establishes
corrective action reguirements
for responding to discharges to
land, including spills, leaks, and
other unauthorized discharges.
Actions taken by public agencies
to cleanup unauthorized releases
are exempt from Title 27/Title
23 accept that wastes removed
ARAR or Performance
Standard Applicability

The application of specific
sections of Title 27/Title 23 is
discussed below. Provisions
of Title 23 apply to hazardous
waste and provisions of Title
27 apply to designated and
nonhazardous waste.
Compliance

See specific reguirements
discussed below under
Porter-Cologne Water
Quality Control Act.
Applicable. Applies to
remediation and monitoring of
sites.
Ground water will be
remediated and monitored
according to Title 27/Title 23
regulations.
-------
Table 10-2. (Continued)
No.
Source
11 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267,13304).
Standard,
Requirement,
Criterion, or Limitation

Title 27, CCR, Section
20400,
Title 23, CCR, Section
2550.4.
12 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267, 13304).
Title 27, CCR, Section
20410,
Title 23, CCR, Section
2550.6
Description

Cleanup standards must be set at
background concentration levels,
or, if background levels are not
technologically and
economically feasible, then at
the lowest levels that are
economically and
technologically achievable.
Specific factors must be
considered in setting cleanup
standards above background
levels.
Requires monitoring for
compliance with remedial action
objectives for three years from
the date of achieving cleanup
standards.
ARAR or Performance
Standard Applicability

Relevant and Appropriate, a
Applies in setting groundwater
cleanup standards for all
discharges of waste to land.
Relevant and Appropriate, a
Applies to OU 1 groundwater
remedial actions.
Compliance

Attainment of background
levels for dieldrin is not
technologically or
economically feasible.
Cleanup standards above
background levels will be
evaluated every five years. If
the actual concentration of a
constituent is lower than its
associated cleanup standard,
the cleanup standard shall be
lowered to reflect existing
water quality.

Post-cleanup monitoring will
be conducted in accordance
with these provisions.
-------
Table 10-2. (Continued)
No.
Source
13 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267,13304).
Standard,
Requirement,
Criterion, or Limitation

Title 27, CCR, Section
20415,
Title 23, CCR, Section
2550.7.
Description

Requires general soil, surface
water, and groundwater
monitoring.
ARAR or Performance
Standard Applicability

Relevant and Appropriate, a
Applies to all areas at which
waste has been discharged to
land.
Compliance

Monitoring will be
conducted, accordance with
the requirements of Title 27
Article 5/Title 23 Article 5
for all ground water at the
facility subject to
remediation. The agencies
will be provided with
quarterly and annual
monitoring reports as part of
the site-wide ground water
Well Monitoring Program
which covers assessment of
ground water at the facility
during the implementation of
soil and ground water
remedial actions.
14 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267,13304).
Title 27, CCR, Section
20425,
Title 23, CCR, Section
2550.9.
Requires an assessment of the
nature and extent of the release,
including a determination of the
spatial distribution and
concentration of each
constituent.
Relevant and Appropriate, a
Applies to areas at which
monitoring results show
statistically significant
evidence of a release.
Further assessment of the
nature and extent of releases
to ground water is ongoing as
part of implementing the
ground water remedial
actions .
-------
Table 10-2. (Continued)
No.
Source
15 Poeter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147, 13172,
13260,13263,
13267,13304).
16 California Safe
Drinking Water Act
(California Health &
Safety Code Section
4010 et seq.).
Standard,
Requirement,
Criterion, or Limitation

Title 27, CCR, Section
20430,
Title 23, CCR, Section
2550.10
Title 22, CCR, Section
64400 et seq.
17 Staff Report of the
RWQCB, Central
Valley Region.
"A Compilation of Water
Quality Goals."
Description

Requires implementation of
corrective action measures that
ensure that cleanup standards are
achieved throughout the zone
affected by the release by
removing the waste constituents
or treating them in place. Source
control may be required. Also
requires monitoring to determine
the effectiveness of the
corrective actions.
Requirements for public water
systems; includes Maximum
Contaminant Levels (MCLs) and
Secondary Maximum
Contaminant Levels (SMCLs).
SDWA standards for this
cleanup action are 6 Ig/L for
DCE. Standards for TCE and
PCE are established by the
Federal Safe Drinking Water
Act.
Provides guidance on selecting
numerical values to implement
narrative water quality
objectives contained in the Basin
Plan.
ARAR or Performance
Standard Applicability

Relevant and Appropriate, a
Applies to groundwater
remedial actions.
Compliance

Corrective action measures
will be implemented and the
actions will be monitored to
assess effectiveness.
Relevant and appropriate. The
act is legally applicable for an
aquifer and associated
distribution and pre-treatment
system that is currently
defined as a "public water
system." If it is only a
potential "public water
system," then the act is
relevant and appropriate.

Performance Standard. To be
considered in selecting
appropriate numerical values
to implement the Basin Plan
for setting cleanup standards
and discharge limits. The
numerical values contained in
the staff report may be
ARARs or Performance
Standards, depending on the
source of the values.
See Section 10-3 for a list of
cleanup goals for the OU 1
remedial action.
Concentrations protective of
beneficial uses have been
established that are consistent
with the referenced action
levels.
Cleanup standards were
developed consistent with the
specified methodology.
-------
Table 10-2. (Continued)
No. Source

18 Solid Waste Disposal
Act as amended by
the Resource
Conservation and
Recovery Act
(RCRA) 42 USC
6901 et seq.
Standard,
Requirement,
Criterion, or Limitation

22CCR 66264
Description

RCRA outlines the requirements
for the transportation, storaqe,
and disposal of defined
hazardous wastes. Some of the
wastes handled durinq any
remedial action at DDJC-Tracy
may be hazardous wastes.
ARAR or Performance
Standard Applicability

Applicable. Applies to
hazardous waste manaqement.
The specific requirements that
may be applicable depend on
the wastes handled and the
technoloqies identified in the
RI/FS process.
Compliance

All wastes (i.e., spent GAG)
qenerated by the OU 1
qroundwater treatment
system will be handled in
accordance with the
substantive requirements of
RCRA.
California Hazardous
Waste Control Act
(HWCA) California
Health and Safety
Code 25100 et seq.

19 Health and Safety
Standards for
Manaqement of
Hazardous Waste
20 Health and Safety
Standards for
Manaqement of
Hazardous Waste
CCR, Title 22, Division
4.5, Chapter 14, Article 16,
Sections 66264.600-
66264.603
CCR, Title 22, Division
4.5, Chapter 14, Article 9,
Sections 66264.170 -
66264.178.
Applies to owners and operators
of facilities that treat, store, or
dispose of RCRA hazardous
waste in miscellaneous units.
Covers environmental
performance standard,
monitorinq, inspections, and
post-closure care.

Applies to owners and operators
who store hazardous waste more
than 90 days in containers.
Covers use and manaqement of
containers, containment,
inspections, and closure.
Relevant and Appropriate.
Relevant and Appropriate
The selected remedy will
utilize air stripper units
which are considered
miscellaneous units.

CA Requlatory Aqency:
DTSC
The spent qranular activated
carbon units are the only
anticipated hazardous waste
to be qenerated by the
selected remedy. These units
are considered to be
containers. Because these
units may be stored for more
than 90 days, this requlation
applies.

CA Requlatory Aqency:
DTSC
-------
Table 10-2. (Continued)
No.
21
Source

Hazardous Waste
Control Act
(California Health
and Safety Code
25100 et seq.).
22
Air Resources Act H
&S Code, Div. 26,
Sec. 39000.
Standard,
Requirement,
Criterion, or Limitation

27 CCR, Division 2,
Subdivision 1.
CCR, Title 17, Part III,
Chapter 1, Sec. 60000 and
San Joaquin Valley
Unified Air Pollution
Control District Rules and
Requlations, Rules 4651
and 2201.
Description

Title 27 establishes waste and
sitinq classification systems and
minimum waste manaqement
standards for discharqes of waste
to land for treatment, storaqe,
and disposal. Title 27 also
contains corrective action
provisions for respondinq to
leaks and other unauthorized
discharqes.

Requlates nonvehicular sources
of air contaminants in California.
The local Air Pollution Control
District (APCD) sets allowable
emissions limits. Requlations for
the release of orqanic solvents
from an air stripper are specified
in Rule 4651, Volatile Orqanic
Compound (VOC) Emissions
from Decontamination Of Soil,
and Rule 2201, New and
Modified Stationary Source
Rule. San Joaquin Valley
Unified APCD performs a
screeninq health risk assessment
for soil or qroundwater cleanup
projects based on the CAPCOA
Risk Assessment Guideline as a
matter of policy. Maximum
allowable cancer risk is 10 in 1
million. Public notification is
required if the site is within
1,000 feet of a K-12 school.
ARAR or Performance
Standard Applicability

Applicable. Applies to
discharqes of waste to land for
treatment storaqe and disposal.
Compliance

Spent GAG and other wastes
will be classified and handled
in accordance with Title 27
requirements.
Applicable. Applies to soil
decontamination processes
and could reasonably apply to
this qroundwater remediation
system and associated air
emissions. BACT is required
if the emissions exceed two
pounds per day of a requlated
air contaminant. For this type
of process, a control
effectiveness of 95% is
considered BACT.
Air emissions standards for
the air stripper system will be
specified by SJVUAPCD.
-------
Table 10-2. (Continued)
No. Source

23 San Joaquin Valley
Unified Air Pollution
Control District
(SJVUAPCD) Rules
and Regulations,
Regulation VIII
Standard,
Requirement,
Criterion, or Limitation

SJVUAPCD Regulation
VIII, Rules 8010, 8020,
and 8060.
Description

Prohibitory rules regulate
fugitive dust and PM10
emissions that occur during
demolition, construction, and
vehicle travel on paved and
unpaved roads. Requires the use
of dust suppression measures
during all site preparation and
vehicle travel.
ARAR or Performance
Standard Applicability

Applicable. Applies to
construction and site
preparation activities as well
as the PM 10 emissions due to
ground disturbances during the
installation of the groundwater
remediation system.
Compliance

Construction and site
preparation activities will
include dust suppression and
PM10 emission control
measures. At a minimum,
water will be used to
minimize the emission of fine
particulate dust to less than
the visible dust emission
requirement specified in Rule
8010.
24
25
San Joaquin Valley
Unified Air Pollution
Control District
(SJVUAPCD) Rules
and Regulations,
Regulation IV
42 USC Section 300
el Seq.
SJVUAPCD Regulation
IV, Rule 4102.
40 CFR 144 et seq.
ment of fluids through an
injection well. There are five
classes of wells regulated.
Prohibits the emission of any
regulated air pollutants in such
quantities that tile source causes
injury, detriment, or nuisance to
the public.
Regulates subsurface emplace-
groundwater infiltration
galleries, which are classed as
Type V wells.
Applicable. Applies to the
operation of the groundwater
remediation system emissions
which could feasibly create a
nuisance due to TCE/PCE
odors and PM10 emissions
from ground disturbances
during the installation of the
groundwater remediation
system.

Applicable. Applies to
groundwater infiltration
these regulatory provisions.
The groundwater remediation
system will be operated in a
manner that eliminates or
substantially reduces the
potential to create a nuisance.
Infiltration galleries will be
operated in accordance with
-------
Table 10-2. (Continued)
No. Source

26 Resource
Conservation and
Recovery Act
Subpart AA (22 CCR
66265.1030 et seq.)
Standard,
Requirement,
Criterion, or Limitation

Article 27 Air Emission
Standards for Process
Vents (22 CCR
66265.1030 - 66265.1035).
27 National Emission
Standards for
Hazardous Air
Pollutants (40 CFR
63.920 er seq.).
Subpart PP-National
Emission Standards for
Containers (40 CFR 63.922
et seq.).
Description

Applies to treatment, storaqe,
and disposal facilities with
process vents associated with
solvent extraction or air or steam
strippinq operations manaqinq
RCRA hazardous wastes with
orqanic concentrations of at least
10 ppmw. These operations
must reduce total orqanic
emissions below specified
concentrations or use a control
device to reduce total orqanic
emissions by 95 percent by
weiqht.

Applies to owners and operators
of containers who are subject to
40 CFR parts 60, 61, or 63.
Containers must, amonq other
thinqs, be equipped with a cover
and closure devices that form a
continuous barrier over container
openinqs. Any open-top
containers must ensure that no
materials are exposed to the
atmosphere.
ARAR or Performance
Standard Applicability

Relevant and appropriate.
Requirements are not
applicable because
contaminant concentrations do
not exceed RCRA hazardous
waste levels. However, the
requirements are relevant and
appropriate for qroundwater
extraction and air-strippinq
operations.
Relevant and appropriate.
Containers storinq hazardous
materials and wastes will be in
place to support all remedial
options.
Compliance

The remedial action will be
manaqed to ensure that total
orqanic emissions are
controlled below specified
emission levels.
All containers will be
manaqed so as to avoid the
release of volatile hazardous
air pollutants. Containers
will be properly equipped
and will only be open durinq
loadinq and unloadinq
events.
-------
Table 10-2. Compliance With Action-Specific ARARs for OU 1 Groundwater Remediation

EPA's legal position is that Title 23 CCR, division 3, chapter 15 and Title 27 CCR, division 2, subdivision 1 are ARARs only as invoked by 23 CCR 2511(d) and 27 CCR 20090(d)
respectively. The RWQCB disagrees with this and reserves the legal position that these reguirements are applicable.

APCD = Air Pollution Control District
ARAR = Applicable or Relevant and Appropriate Reguirement
CAA = Clean Air Act
CCR = California Code of Regulations
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
DCE = dichloroethene
GAG = Granular Activated Carbon
HWCA = Hazardous Waste Control Act
MCL = maximum contaminant level
NA = not applicable
NAAQS = National Ambient Air Quality Standards
NESHAP = National Emission Standards for Hazardous Air Pollutants
NSPS = New Source Performance Standards
OU = Operable Unit
PCE = tetrachloroethene
POTW = Publicly Owned Treatment Works
RCRA = Resource Conservation and Recovery Act
RI/FS = Remedial Investigation/Feasibility Study
RWQCB = Regional Water Quality Control Board
SJVUAPCD = San Joaguin Valley Unified Air Pollution Control District
SMCL = Secondary Maximum Contaminant Level
SWMU = Solid Waste Management Unit
SWRCB = State Water Resources Control Board
TCE = trichloroethene
VOC = volatile organic compound
-------
Table 10-3. Compliance With Action-Specific ARARs for Soil Remediation
No. Source

1 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13304,
13240, 13241,
13242, 13243) .
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243) .
Standard,
Reguirement,
Criterion, or
Limitation

RWQCB, Central
Valley Region,
Water Quality
Control Plan
(Basin Plan),
"Policy for
Investigation and
Cleanup of
Contaminated
Sites."
RWQCB, Central
Valley Region
Basin Plan,
"Policy for
Application of
Water Quality
Objectives"
Description

Establishes and describes the
policy for the investigation and
remediation of contaminated
sites. Also includes
implementation actions for
setting groundwater and soil
cleanup levels.
This policy defines water
guality objectives and explains
how the Regional Water Board
applies numerical and narrative
water guality objectives to
ensure the reasonable protection
of beneficial uses of water and
how the Regional Water Board
applies Resolution No. 68-16 to
promote the maintenance of
existing high-guality waters.
ARAR or Performance
Standard (Applicability)

Applicable. Cleanup levels
for soils should be egual to
levels that would achieve
background concentrations
in ground water unless such
levels are technically and
economically infeasible to
achieve. In such cases, soil
cleanup levels are such that
groundwater will not exceed
applicable groundwater
guality objectives.

Applicable. Applies to all
cleanups of discharges that
may affect water guality.
Actions and Sites
Affected

All sites.
Compliance

Soil cleanup standards
were established to
comply with this
reguirement
All sites.
Soil cleanup standards
were established to
comply with this
reguirement
-------
Table 10-3. (Continued)
No. Source

3 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13240, 13241,
13242, 13243) .
Standard,
Requirement,
Criterion, or
Limitation

RWQCB, Central
Valley Region
Basin Plan.
Description

Establishes water quality
objectives, including narrative
and numerical standards, that
protect the beneficial uses of
surface and groundwaters in the
region. Describes
implementation plans and other
control measures designed to
ensure compliance with
statewide plans and policies and
provide comprehensive water
quality planning. Also includes
implementation actions for
setting soil cleanup levels for
soils that threaten water quality.
ARAR or Performance
Standard (Applicability)

Applicable. Specific
applicable portions of the
Basin Plan include
beneficial uses of affected
water bodies and water
quality objectives to protect
those uses. Any activity,
including for example a
new discharge of
contaminated soils or in situ
treatment or containment of
contaminated soils, that
may affect water quality
must not result in water
quality exceeding water
quality objectives.
Implementation plans and
other policies and
requirements may also
apply.
Actions and Sites
Affected

All sites.
Compliance

Soil cleanup standards
were established to
comply with this
requirement
-------
Table 10-3. (Continued)
No. Source

4 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13263, 13304) .
Standard,
Requirement,
Criterion, or
Limitation

State Water
Resources Control
Board Resolution
No. 68-16,
"Antidegradation
Policy".
Description

Requires that high-quality
surface and groundwaters be
maintained to the maximum
extent possible. Degradation of
waters will be allowed (or
allowed to remain) only if it is
consistent with the maximum
benefit to the people of the
state, will not unreasonably
affect present and anticipated
beneficial uses, and will not
result in water quality less than
that prescribed in RWQCB and
SWRCB policies. If
degradation is allowed, the
discharge must meet best
practicable treatment or control,
which must prevent pollution or
nuisance and result in the
highest water quality consistent
with maximum benefit to the
people of the state.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
discharges of waste to
waters, including discharges
to soil that may affect
surface or groundwaters. In
situ cleanup levels for
contaminated soils must be
set so that ground waters are
not degraded, unless
degradation is consistent
with the maximum benefit
of the people of the state. If
degradation is allowed, the
discharge must meet best
practicable treatment or
control and result in the
highest water quality
possible that is consistent
with tile maximum benefit
to the people of the state. In
no case may water quality
objectives be exceeded.
Actions and Sites
Affected

All sites.
Compliance

Soil cleanup standards
were established to
comply with this
requirement
-------
Table 10-3. (Continued)
No. Source

5 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13000, 13140,
13240, 13260,
13263, 13267,
13300, 13304,
13307).
Porter-Cologne
Water Quality
Standard,
Requirement,
Criterion, or
Limitation

State Water
Resources Control
Board Resolution
No. 92-49 (as
amended 21 April
1994).
State Water
Resources Control
Description

Establishes requirements for the
investigation, cleanup, and
abatement of discharges.
Among other requirements,
dischargers must clean up and
abate the effects of discharges
in a manner that promotes the
attainment of either background
water quality or the best water
quality that is reasonable if
background water quality
cannot be restored. Requires
the application of Title 23,
CCR, Division 3, Chapter 15
requirements to cleanups.

Specifics that, with certain
exceptions, all ground and
ARAR or Performance
Standard (Applicability)

Applicable. Applies to all
cleanups of discharges that
may affect water quality.
Actions and Sites
Affected
All sites.
Applicable. Applies in
determining beneficial uses
All sites.
Compliance

Soil cleanup standards
were established to
comply with this
requirement
Cleanup standards to
maintain beneficial
Control Act

(California Water
Code Sections
13000, 13140,
13240) .
Board Resolution

No. 88-63
("Sources of
Drinking Water
Policy") (as
contained in the
RWQCB's Basin
Plan).
surface waters have the

beneficial use of municipal or
domestic water supply.
for waters that may be

affected by dischargers of
waste.
uses were developed in

a way consistent with
the requirements for
municipal or domestic
water supply. Conse-
quently, California
state primary MCLs are
relevant and
appropriate; however,
the most stringent
federal or state standard
was used to determine
the beneficial use limit.
California standards
may be found in 22
CCR 66439 et seq.
-------
No.
Source
Standard,
Requirement,
Criterion, or
Limitation
Table 10-3. (Continued)
Description
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
Staff Report of the
RWQCB, Central
Valley Region.
Staff Report of the
RWQCB, Central
Valley Region.
The Designated
Level
Methodology for
Waste
Classification and
Cleanup Level
Determination.
"A Compilation of
Water Quality
Goals."
Provides guidance on how to
classify wastes according to
Title 27, CCR, Division 2,
Subdivision I/Title 23, CCR,
Division 3, Chapter 15, Article
10.
Provides guidance on selecting
numerical values to implement
the narrative water quality
objectives contained in the
Basin Plan.
Performance Standard. To
be considered in
determining the
classification of wastes
contaminated soils.
Excavation - SWMUs
2,3,4,6,8,20,27,33
and
Performance Standard. To
be considered in selecting
appropriate numerical
values to implement the
Basin Plan for setting
cleanup levels and
discharge limits. The
numerical values contained
in the staff report may be
applicable, relevant, and
appropriate or to be
considered, depending on
the source of the values.
All sites.
This methodology will
be used when
classifying excavation
wastes. Designated
wastes will only be
discharged to an off-
site Class I or Class II
facility.

This guidance was
considered as one of
the criteria for setting
beneficial uses and,
consequently, setting
soil cleanup levels.
-------
Table 10-3. (Continued)
No. Source

9 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13304).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Division 2,
Subdivision 1
(Section 20080 et
seq.),
Title 23, CCR,
Division 3,
Chapter 15
(Section 2510 et
Description

Establishes waste and sitinq
classification systems and
minimum waste manaqement
standards for discharqes of
waste to land for treatment,
storaqe, and disposal.
Enqineered alternatives that are
consistent with the Title
27/Title 23 performance qoals
may be considered. Establishes
corrective action requirements
for respondinq to leaks and
other unauthorized discharqes.
ARAR or Performance
Standard (Applicability)

The application of specific
sections of Title 27/Title 23
to different situations is
discussed below. Provisions
of Title 23 apply to
hazardous waste and
provisions of Title 27 apply
to desiqnated and
nonhazardous solid waste.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Excavated soil will be
classified appropriately
and deposited in a
disposal facility that
maintains compliance
with this provision.
Waste manaqement
procedures consistent
with Title 27/Title 23
will be utilized in soil
handlinq and manaqinq
stockpiled soils.
10 Porter-Coloqne
Water Quality
Control Act
(California Water
Code Sections

13140-13147,
13172,13260,1326
3,13267,13304).
Title 27,CCR,
Section 20090(d),
Title 23, CCR,
Section 2511(d).

Title 27/Title 23
seq. )
Actions taken by public
aqencies to cleanup
unauthorized releases are
exempt from Title 27/Title 23
accept that wastes removed
from immediate place of release
and discharqed to land must be
manaqed in accordance with the
classification (Title 27,CCR
,Section 20200/Title 23,CCR,
Section 2520) and sitinq
requirements of Title 27 or Title
23 and wastes contained or left
in place must comply with Title
27 or Title 23 to the extent
feasible.
Applicable, Applies to
remediation and monitorinq
of sites.
Applies to all sites subject
to remediation.
Ground water will be
monitored and soil sites
will be remediated and
closed accordinq to
requlations.
-------
Table 10-3. (Continued)
No. Source

11 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
1330-4).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Section 20080(d)

Title 23, CCR,
Section 2510(d).
Description

Requires closure of existing
waste management units in
accordance with the
requirements of Title 27 Article
8/Title 23 Article 8.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
"existing" waste
management units (i.e.,
areas where waste was
discharged to land on or
before 27 November 1984,
but that were not closed,
abandoned, or inactive prior
to that date).
Actions and Sites
Affected

Applies to all sites subject
to remediation.
Compliance

The OU 1 groundwater
and the SWMUs that
are suspected sources
of contamination will
be closed in accordance
with the requirements
of Title 27 Article
8/Title 23 Article 8.
These requirements
include closure in
accordance with an
12 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13304).
Title 27,CCR,
Section 20080(g),

Title 23,CCR,
Section 25
Requires monitoring. If water
quality is threatened, corrective
action consistent with Title 27,
Article 5/Title 23 is required
Relevant and Appropriate, a
Applies to areas of land
where discharges have
ceased as of 27 November
1984 (the effective date in
the revised Title 27/Title 23
regulations).
Applies to all sites where
water quality is
threatened. (All sites
except for the North
Depot surface soils.)
approved closure and
post-closure
maintenance plan that
provides for continued
compliance with the
applicable Title 27
standards for waste
containment,
precipitation and
drainage control, and
monitoring.

The monitoring
program at these sites
will be implemented in
accordance with Title
27/Title 23.
-------
Table 10-3. (Continued)
No.

13
14
Source

Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Section 20400,
Title 23, CCR,
Section 2550.4.
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172,13260,
13263,13267,
13269).
Title 27, CCR,
Section 20410,
Title 23, CCR
Section 2250.6
Description

Cleanup levels must be set at
background concentration levels
or, if background levels are not
technologically and
economically feasible, at the
lowest levels that are
economically and
technologically feasible.
Specific factors must be
considered in setting cleanup
levels above background levels.
Cleanup levels above
background levels shall be
evaluated every five years. If
the actual concentration of a
constituent is lower than its
associated cleanup level, the
cleanup level shall be lowered
to reflect existing water quality.

Requires monitoring for
compliance with remedial
action objectives for three years
from the date of achieving
cleanup levels.
ARAR or Performance
Standard (Applicability)

Relevant and Appropriate. ,
If water quality is
threatened, this section
applies in setting soil
cleanup levels for all
cleanups of discharges of
waste to land.
Actions and Sites
Affected

All sites.
Relevant and Appropriate, a
Applies to all soil cleanup
activities.
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33

Institutional Controls
SWMUs 7,11,33

Bioventing - SWMU 24
Compliance

Sites where wastes will
be left in place will be
managed and
monitored in
accordance with the
requirements of Title
27/Title 23.
Sites will be monitored
for at least three years
after cleanup standards
have been achieved.
-------
Table 10-3. (Continued)
No. Source

15 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263,
13267, 13269).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Section 20415,
Title 23, CCR,
Section 2550.7.
Description

Requires general soil, surface
water, and groundwater
monitoring.
ARAR or Performance
Standard (Applicability)

Relevant and Appropriate, a
Applies to all areas in which
waste has been discharged
to land.
Actions and Sites
Affected

SVE - Group A Sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33

Institutional Controls
SWMUs 7,11,33
Bieventing - SWMU 24

Natural Attenuation -
SWMU 20
Asphalt Cover -
N.Depot surf, soils
Compliance

Monitoring will be
conducted in
accordance with the
requirements of Title
27 Article 5/Title 23
Article 5 for all ground
water at the facility
subject to remediation.
The agencies will be
provided with quarterly
and annual monitoring
reports as part of the
site-wide ground water
Well Monitoring
Program which covers
assessment of ground
water at the facility
during the
implementation of soil
and ground water
remedial actions.
-------
Table 10-3. (Continued)
No.

16
17
Source

Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13267,
13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263,
13267, 13269).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Section 20425,
Title 23, CCR,
Section 2550.9.
Title 27, CCR,
Section 20430,

Title 23, CCR,
Section 2550.10
Description

Requires an assessment of the
nature and extent of the release,
including a determination of the
spatial distribution and
concentration of each
constituent.
ARAR or Performance
Standard (Applicability)

Relevant and Appropriate, a
Applies to sites at which
monitoring results show
statistically significant
evidence of a release
Requires the implementation of
corrective action measures that
ensure that cleanup levels are
achieved throughout the zone
affected by the release by either
removing the waste constituents
or treating them in place.
Source control may be required.
Also requires monitoring to
determine the effectiveness of
the corrective actions.
Relevant and Appropriate, a
If water quality is
threatened, this section
applies to all soil cleanup
activities.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33

Institutional Controls -
SWMUs 7,11,33
Bioventing - SWMU 24
Natural Attenuation -
SWMU 20
Asphalt Cover -
N. Depot surf, soils

SVE - Group A sites,
SWMU 20

Excavation - SWMUs
2,3,4,6,8,20,27,33
Institutional Controls -
SWMUs 7,11,33

Bioventing - SWMU 24

Natural Attenuation -
SWMU 20
Asphalt Cover -
N. Depot surf, soils
Compliance

Further assessment of
the nature and extent of
releases will continue
during implementation
of the RD/RA.
Corrective action
measures and
monitoring will be
undertaken as
prescribed. To
demonstrate cleanup,
the concentration of
each COG in
groundwater must be
equal to or less than the
cleanup standard for at
least one year
following the corrective
action; otherwise, the
remedy will be
reevaluated.
-------
Table 10-3. (Continued)
No. Source

18 Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263,
13267, 13269).
Standard,
Requirement,
Criterion, or
Limitation

Title 27, CCR,
Section 20950;
22207(a);
22212 (a), and
22222,
Title 23, CCR
Sections
2550.0(b); 2580;
2580(f);
Description

General closure requirements,
including continued
maintenance of waste
containment, drainage controls,
and groundwater monitoring
throughout the closure and post-
closure maintenance periods.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
partial or final closure of
waste management units.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20
Excavation - SWMUS
2,3,4,6,8,20,27,33

Institutional Controls -
SWMUs 7,11,33
Bioventing - SWMU 24
Natural Attenuation -
SWMU 20
Compliance

Monitoring and
maintenance of waste
management units will
be conducted during
closure and post-
closure periods for as
long as wastes pose a
threat to water quality.
19
20
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172, 13260,
13263, 13269).
Title 27, CCR,
Section 21400,
Title 23, CCR,
Section 2582.
Title 27, CCR,
Section 20080(d)

Title 23, CCR,
Section 2510(d)
Requires surface impoundments
to be closed by removing and
treating all free liquid and either
removing all remaining
contamination or closing the
surface impoundment as a
landfill.
Requires closure of existing
waste management units
according to Title 27, Article
8/Title 23 Article 8.
Applicable. If water
quality is threatened, this
section is relevant and
appropriate for natural
topographic depressions,
excavations, and diked
areas where wastes
containing free liquids were
discharged.
Applicable. Applies to all
areas where waste has been
discharged to land.
Excavation - SWMUs
2,3,4
All sites.
Clean closure will be
attempted. Cleanup
standards identified in
this ROD are expected
to protect water
and attain clean
closure. Clean closure
will be verified with
ground water
monitoring.

All SWMUs and soil
contamination areas
will be closed
according to Title 27
closure requirements.
-------
Table 10-3. (Continued)
No.

21
22
Source

Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172,13260,
13263,13269).
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172,13260,
13263,13269).
Standard,
Reguirement,
Criterion, or
Limitation

Title 23, CCR,
Section),2520
2521,
Title 27, CCR,
Section
20200(c),20210.
Description

Reguires that hazardous waste
be discharged to Class I waste
management units that meet
certain design and monitoring
standards.
Reguires that designated waste
be discharged to Class I or
Class II waste management
units.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
discharges of hazardous
waste to land for treatment,
storage, or disposal.
Applicable. Applies to
discharges of designated
waste (nonhazardous waste
that could cause degradation
of surface or groundwaters)
to land for treatment,
storage, or disposal.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20, 27,33
Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes will
be discharged to Class I
waste management
units. Excavated
hazardous wastes will
be properly manifested
and disposed of off site
at a permitted Class I
hazardous waste
treatment storage or
disposal facility.

Designated wastes will
be discharged off site to
permitted Class I or
Class II waste
management units.
23
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13140-13147,
13172,13260,
13263,13269).
Title 27, CCR,
Section
20200(c),20220.
Reguires that nonhazardous
solid waste be discharged to a
classified waste management
unit.
Applicable. Applies to
discharges of nonhazardous
solid waste to land for
treatment, storage, or
disposal.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Nonhazardous solid
wastes will be
discharged to classified
waste management
units.
-------
Table 10-3. (Continued)
No.

24
25
Source

CWA, Section 402,
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13260,13263,

133703.5,13372,
13373,13374,
13375,13376,
13377,13383).
CWA, Section 402,
Porter-Cologne
Water Quality
Control Act
(California Water
Code Sections
13260,13263,

13370.5,13372,
13373,13374
13375,13376
13377,13383).
Standard,
Reguirement,
Criterion, or
Limitation

40 CFR Parts
122,123,124,
National Pollution
Discharge
Elimination
System,
implemented by
State Water
Resources Control
Board Order No.
92-08 DWQ
40 CFR Parts
122,123,124,
National Pollution
Discharge
Elimination
System,
implemented by
California General
Stormwater Permit
for Industrial
Activities, State
Water Resources
Control Board
Order #97-03-
DWQ.
Description

Regulates pollutants in
discharge of storm water
associated with construction
activity (clearing, grading, or
excavation) involving the
disturbance of 5 acres or more.
Reguirements to ensure storm
water discharges do not
contribute to a violation of
surface water guality standards
Regulates pollutants in
discharge of storm water
associated with hazardous waste
treatment, storage, and disposal
facilities, wastewater treatment
plants, landfills, land
application sites, and open
dumps. Reguirements to ensure
storm water discharges do not
contribute to a violation of
surface water guality standards.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
construction areas over 5
acres in size. Includes
measures to minimize
and/or eliminate pollutants
in storm water discharges
and monitoring to
demonstrate compliance.
Applicable. Applies to
storm water discharges from
industrial areas. Includes
measures to minimize
and/or eliminate pollutants
in storm water discharges
and monitoring to
demonstrate compliance.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4
SVE - Group A Sites,
SWMU 20

Bioventing - SWMU 24
Compliance

Storm water best
management practices
(BMPs) will be used to
prevent adverse effects
to surface water.
Excavations will be
conducted during dry
season. A Storm Water
Pollution Prevention
Plan will be submitted
to the RWQCB under
the storm water
compliance program.

All treatment activities
will comply with the
substantive portions of
the permit, including
implementation of best
management practices.
A Storm Water
Pollution Prevention
Plan will be submitted
to the RWQCB under
the storm water
compliance program.
-------
Table 10-3. (Continued)
No. Source

26 California
Hazardous Waste
Control Law
Standard,
Requirement,
Criterion, or
Limitation

Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
12 (Standards
Applicable to
Generators of
Hazardous Waste),
Article 1
(Applicability) 22
CCR 66262.11
Description

Establishes standards for
generators of hazardous waste.
Applicable for determining if
the wastes from excavated sites
or treatment processes are
classified as hazardous or non-
RCRA hazardous waste, and the
remedial action constitutes
treatment, storage, or disposal
of hazardous waste.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
hazardous waste
management. The specific
requirements that may be
applicable will depend on
the wastes handled and the
technologies identified in
the RI/FS process.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No. Source

27 California
Hazardous Waste
Control Law
Standard,
Requirement,
Criterion, or
Limitation

Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
9 (Use and
Management of
Containers) 22
CCR 66264.171 -
66264.178
Description

The chemicals recovered from
the sediments, surface soils,
subsurface soils, or groundwater
may need to be managed as
either a RCRA or non-RCRA
hazardous waste. The treatment,
storage, and disposal
requirements for these wastes
are either applicable or relevant
and appropriate (depending
upon the classification of the
waste material) and they
include; using containers to
store the recovered product that
are compatible with this
material (22 CCR 66264.172);
using containers that are in
good condition (22 CCR
66264.171); segregating (the
waste from incompatible wastes
(12 CCR 66264.177); inspect
the containers (22 CCR
66264.174); isolating the waste
from sources of ignition (if the
material is ignitable) and (22
CCR 66264.176); providing
adequate secondary
containment for the waste
stored (22 CCR 66264.175);
containers must be closed
during transfer (22 CCR
66264,173); and all hazardous
material must be removed at
closure (22 CCR 66264.178).
ARAR or Performance
Standard (Applicability)

Applicable if during
excavation, treatment
processes, or cleanup
activities hazardous waste is
identified through the
proper characterization
process, the hazardous
waste will be managed in
accordance with the
standards stated in these
sections of the regulation.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No. Source

28 California
Hazardous Waste
Control Law
Standard,
Requirement,
Criterion, or
Limitation

Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
12 (Waste Piles)
22 CCR
66264.251,
66264.254,
66264.256-
66264.259
Description

Delineates requirements for the
management of waste piles for
hazardous wastes. This
regulation is applicable to sites
where excavated materials are
classified as hazardous wastes
and managed in waste piles.
The titles of the regulations are
Section 66264.251. Design and
Operating Requirements;
Section 66264.254. Monitoring
and Inspection; Section
66264.256. Special
Requirements for Ignitable or
Reactive Waste; Section
66264.257. Special
Requirements for Incompatible
Wastes; Section 66264.258.
Closure and Post-Closure Care;
and Section 66264.259. Special
Requirements for Hazardous
Wastes P020, P021, P022,
P023, P026, and P027.
ARAR or Performance
Standard (Applicability)

If during excavation,
treatment processes, or
cleanup activities,
hazardous waste is
identified through the
proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
No. Source

29 California
Hazardous Waste
Control Law
Standard,
Requirement,
Criterion, or
Limitation

Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
14 (Standards for
Owners and
Operators of
Hazardous Waste
Transfer,
Treatment,
Storage, and
Disposal
Facilities), Article
19 (Corrective
Action for Waste
Management
Units) 22 CCR
6624.552,
66264.553
Table 10-3. (Continued)
Description

CAMU: Placement,
consolidation, and treatment of
soils and wastes being
generated as part of a corrective
action under RCRA will not be
considered a new disposal to
land as long as the materials are
handled in designated CAMUs.
Land disposal restrictions (22
CCR 66268) are not invoked
when remediation wastes are
managed in a CAMU. A
CAMU can only be used for the
management of remediation
wastes pursuant to
implementing corrective actions
at the facility.

USEPA intended that the
federal CAMU rule be
considered for the management
of wastes generated at
CERCLA sites. Excavation of
wastes from the discharge and
disposal sites might be managed
at a CAMU for on-base
disposal, or ex situ
bioremediation.
ARAR or Performance
Standard (Applicability)

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No. Source

29 (Continued)
Standard,
Requirement,
Criterion, or
Limitation
Description

A CAMU is an area within a
facility for the purpose of
implementing corrective
actions. Uncontaminated areas
are allowed to be designated as
part of a CAMU when they are
necessary to achieve the overall
goals for the facility and will
enhance the protectiveness of
the remedial action. The CAMU
rule allows consolidation and
treatment of wastes in a single
unit, from other areas of the
facility, without triggering
minimum technology
requirements and LDR found in
other provisions of RCRA and
HWCL; that is, placement of
wastes into a CAMU is not
considered land disposal and
redeposition of treated wastes
into the CAMU does not trigger
the LDRs. Groundwater must
be monitored at the CAMU in
order to detect and characterize
a release.
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
-------
Table 10-3. (Continued)
No.
Source
30 California
Hazardous Waste
Control Law
Standard,
Requirement,
Criterion, or
Limitation

Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article I (General)
22 CCR 66268.3,
66268.7(a) & (b),
66268.9
Description

Provides (the purpose, scope,
and applicability of LDRs. The
title of the sections of the
regulations are; Section
66268.3, Dilution Prohibited As
a Substitute for Treatment;
Section 66268.7, Waste
Analysis and Record Keeping;
and Section 66268.9, Special
Rules Regarding Wastes That
Exhibit a Characteristic.
ARAR or Performance
Standard (Applicability)

If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Only applicable if
hazardous wastes are
disposed of or treated in an
area not designated as a
CAMU or disposed of or
treated beyond the area of
contamination.
Actions and Sites
Affected

Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
31 California
Hazardous Waste
Control Law
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 3
(Prohibitions on
Land Disposal) 22
CCR 66268.30-
66268.35
These standards are applicable
to sites where excavated
material is classified as
hazardous waste and is disposed
of or treated in an area not
designated as a CAMU.
Provides waste-specific LDRs
for Section 66268.30, Waste
Specific Prohibitions-Solvent
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No.

31
Source

(Continued)
Standard,
Requirement,
Criterion, or
Limitation
Description

Wastes; Section 66268.31,
Waste Specific Prohibitions-
Dioxin-Containing Wastes;
Section 66268.32, Waste
Specific Prohibitions-California
List Wastes; Section 66268.33,
Waste Specific Prohibitions-
First Third Wastes; Section
66268.34. Waste Specific
Prohibitions-Second Third
Waste; and Section 66268.35,
Waste Specific Prohibitions-
Third Third Waste.
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
32
California
Hazardous Waste
Control Law
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 4 66268.41.
(Treatment
Standards) 22
CCR 66268.41 -
66268.43
These standards are applicable
to sites where excavated
materials are classified as
hazardous waste and are
disposed of or treated in an area
not designated as a CAMU.
Provides treatment standards
expressed in contaminant
concentrations in Section
Treatment Standards
Expressed As Concentrations in
Waste
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
No. Source

32 (Continued)
Standard,
Requirement,
Criterion, or
Limitation
Table 10-3. (Continued)
Description

Extract; Section 66268.42.
Treatment Standards Expressed
As Specified Technologies; and
Section 66268.43. Treatment
Standards Expressed As Waste
Concentrations.
ARAR or Performance
Standard (Applicability)
Actions and Sites
Affected
Compliance
These standards provide waste
specific LDRs for solvent
wastes, dioxin-containing
wastes, and California Listed
Wastes.
33 California
Hazardous Waste
Control Law
Title 22, Division
4.5
(Environmental
Health Standards
for Management
of Hazardous
Waste), Chapter
18 (Land Disposal
Restrictions),
Article 5
(Prohibitions on
Storage) 22 CCR
66268.50
This standard is applicable to
sites where excavated material
is classified as hazardous waste.
The standard provides
prohibitions on storage of
restricted wastes.
If during excavation,
treatment processes, or
cleanup activities hazardous
waste is identified through
the proper characterization
process, and will be
managed in waste piles, the
hazardous waste will be
managed in accordance with
the standards stated in these
sections of the regulation.
Excavation - SWMUs
2,3,4,6,8,20,27,33
Hazardous wastes will
be stored, transported,
and disposed in
accordance with
HWCA requirements.
-------
Table 10-3. (Continued)
No.

34
35
Source

San Joaquin Valley
Unified Air
Pollution Control
District
(SJVUAPCD)
Rules and
Regulations,
Regulation VIII.
San Joaguin Valley
Unified Air
Pollution Control
District
(SJVUAPCD)
Rules and
Regulations,
Regulation IV.
Standard,
Reguirement,
Criterion, or
Limitation

SJVUAPCD
Regulation VIII
Rules 8010, 8020,
and 8060.
SJVUAPCD
Regulation IV
Rule 4102.
Description

Prohibitory rules regulate
fugitive dust and PM 10
emissions that occur during
demolition, construction, and
vehicle travel on paved and
unpaved roads. Reguires the use
of dust suppression measures
during all site preparation and
Vehicle travel.
Prohibits the emission of any
regulated air pollutants in such
guantities that the source causes
injury, detriment, or nuisance to
the public.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to
construction and site
preparation activities as
well as the PM10 emissions
due to ground disturbances
during the installation of the
SVE, bioventing, and
excavation activities.
Applicable. Applies to the
use and operation of the
remediation systems and the
associated emissions that
could feasibly create a
nuisance due to odors.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33

Bioventing - SWMU 24
Compliance

The SVE and
bioventing systems will
be operated in a manner
that eliminates or
substantially reduces
the potential to create a
nuisance.
-------
Table 10-3. (Continued)
No. Source

36 Air Resources Act
H&S Code, Div.
26, Sec. 39000.
Standard,
Requirement,
Criterion, or
Limitation

CCR, Title 17,
Part III, Chapter 1,
Sec. 60000 and
San Joaquin
Valley Unified Air
Pollution Control
District Rules and
Requlations, Rules
4651.
Description

Regulates nonvehicular sources
of air contaminants in
California. The local Air
Pollution Control District sets
allowable emissions limits.
Regulations for release of
organic solvents from an air
stripper are specified in Rule
4651 Volatile Organic
Compound (VOC) Emissions
from Decontamination of Soil.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to soil
decontamination processes
and remediation systems
and their associated air
emissions. BACT is
required if the emissions
exceed 2 pounds per day of
a regulated air contaminant.
For this type of process, a
control effectiveness of
95% is considered BACT.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
Compliance

SVE, excavation, and
bioventing systems will
be operated in a manner
that complies with the
requirements in
SJVUAPCD Rule
4651.
37 Air Resources Act
H&S Code, Div.
26, Sec.39000.
CCR, Title 17,
Part III, Chapter 1,
Sec. 60000 and
San Joaquin
Valley Unified Air
Pollution Control
District Rules and
Regulations, Rules
2201.
New and Modified Stationary
Source Rule. SJVUAPCD
performs a screening health risk
assessment for soil or
groundwater cleanup projects
based on the CAPCOA Risk
Assessment Guideline as a
matter of policy. Maximum
allowable cancer risk is 10 in 1
million. Public notification is
required if site is within 1,000
feet of a K - 12 school.
Applicable. Applies to soil
decontamination processes
and remediation systems
and their associated air
emissions. BACT is
required if the emissions
exceed 2 pounds per day of
a regulated air contaminant.
For this type of process, a
control effectiveness of
95% is considered BACT.
SVE - Group A sites,
SWMU 20
Excavation - SWMUs
2,3,4,6,8,20,27,33
Bioventing - SWMU 24
SVE, excavation, and
bioventing systems will
be operated in a manner
that complies with the
requirements in
SJVUAPCD Rule
4651.
-------
Table 10-3. (Continued)
No. Source

38 Clean Air Act
(CAA) (42 USC
°7401-7642).
Standard,
Requirement,
Criterion, or
Limitation

National Emission
Standards for
Hazardous Air
Pollutants (40
CFR Part 61),
Subparts A, E, F,
J, V, and FF, and
SMAQMD Rule
4002.
Description

Section 112 of the CAA
establishes national emission
standards for hazardous air
pollutants (NESHAPs). The
standards address new and
existing sources, and are
oriented toward particular
hazardous pollutants at their
point of emission from specific
sources.
ARAR or Performance
Standard (Applicability)

Applicable. Applies to air
emissions at DDJC-Tracy
associated with soil
remediation technologies.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20

Excavation - SWMUs
2,3,4,6,8,20, 27,33

Bioventing - SWMU 24
Compliance

Hazardous air pollutant
standards will be met at
the points of emission.
39 National Emission
Standards for
Hazardous Air
Pollutants (40 CFR
63.920 et seg.).
Subpart PP—
National Emission
Standards for
Containers (40
CFR 63.922 et
seg.).
Applies to owners and operators
of containers who are subject to
40 CFR parts 60, 61, or 63.
Containers must, among other
things, be eguipped with a cover
and closure devices that form a
continuous barrier over
container openings. Any open-
top containers must ensure that
no materials are exposed to the
Relevant and appropriate.
Containers storing
hazardous materials and
wastes will be in place to
support all remedial
options.
SVE - Group A sites,
SWMU 20

Excavation - SWMUs
2,3,4,6,8, 20,27,33
All containers will be
managed so as to avoid
the release of volatile
hazardous air
pollutants. Containers
will be properly
eguipped and will only
be open during loading
and unloading events.
-------
Table 10-3. (Continued)
No. Source

40 National Emission
Standards for
Hazardous Air
Pollutants (40 CFR
63.680 et seq.).
Standard,
Requirement,
Criterion, or
Limitation

Subpart DD-
National Emission
Standards from
Off-site Waste and
Recovery
Operations (40
CFR 63.680 et
seq.).
Description

Applies to owners and operators
of off-site treatment, storaqe,
and disposal facilities,
wastewater treatment
operations, or hazardous waste
recyclinq facilities that are
major sources of hazardous air
pollutants. Requires any of the
followinq: (1) the installation
of air emission controls; (2) the
pretreatment of the hazardous
air pollutant before enterinq
manaqement units; or (3)
ensurinq that volatile hazardous
air pollutant concentrations
remain below 500 ppmw.
ARAR or Performance
Standard (Applicability)

Relevant and appropriate.
Actions and Sites
Affected

SVE - Group A sites,
SWMU 20

Bioventinq - SWMU 24
Excavation - SWMUs
2,3,4,6,8,20,27,33
Compliance

The volumes and
concentrations of
volatile hazardous air
pollutants are expected
to fall below specified
action levels. In the
event hiqher
concentrations are
observed, appropriate
control devices will be
installed.
-------
Table 10-3. (Continued)

a EPA's legal position is that Title 23 CCR, division 3, chapter 15 and Title 27 CCR, division 2, subdivision 1 are ARARs only as invoked by 23 CCR 2511(d) and 27 CCR 20090(d)
respectively. The RWQCB disagrees with this and reserves the legal position that these reguirements are applicable.

APCD = Air Pollution Control District
ARAR = Applicable or Relevant and Appropriate Reguirement
BMPS = Best Management Practices
CAA = Clean Air Act
CAMU = Corrective Action Management Unit
CAPCOA = California Air Pollution Control Officer Association
CCR = California Code of Regulations
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFA = Code of Federal Regulations
DCE = dichloroethene
GAG = Granular Activated Carbon
HWCA = Hazardous Waste Control Act
LDR = Land Disposal Restriction
MCL = maximum contaminant level
NA = not applicable
NAAQS = National Ambient Air Quality Standards
NESHAP = National Emission Standards for Hazardous Air Pollutants
NPL = National Priority List
NSPS = New Source Performance Standards
OU = Operable Unit
PCE = tetrachloroethene
POTW = Publicly Owned Treatment Works
RCRA = Resource Conservation and Recovery Act
RI/FS = Remedial Investigation/Feasibility Study
RWQCB = Regional Water Quality Control Board
SDWA = Safe Drinking Water Act
SJVUAPCD = San Joaguin Valley Unified Air Pollution Control District
SMAQMD = Sacramento Metropolitan Air Quality Management District
SMCL = Secondary Maximum Contaminant Level
SVE = soil vapor extraction
SWMU = Solid Waste Management Unit
SWRCB = State Water Resources Control Board
TCE = trichloroethene
UST = underground storage tank
VOC = volatile organic compound
-------
Table 10-4. Determination of Soil Cleanup Standards for SWMU I/Area 2, DDJC-Tracy
Constituent

VOCs (Ig/kg)
Maximum
Background Concentration
Threshold a Detected
Threat to
Beneficial
Uses in
Groundwater
Threat to
Background
Groundwater
Quality

RBC RBC
E-06 HI = 1

Region
RL IX PRG b
Tetrachloroethene (PCE) NE
Trichloroethene (TCE) NE
400
220 Ig/L g
Yes
Yes
Yes
Yes
NA
NA
NA
NA
10 17,000
10 7,000
Eguilibrium
Partitioning Limit
Protective of MCL c
2.4
1.3
Eguilibrium
Partitioning
Limit Protective
of Background Model
Water Quality d Level
0.2 14
0.3 NE
Soil Gas
Cleanup
standards
780 ppbv f
350 ppbv g,h
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996) .
c Eguilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
d Eguilibrium partitioning limit based upon comparison of detection limit to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of MCL in groundwater at the source area.
f Soil cleanup standard for PCE corresponds to a target soil gas cleanup standard of 5.4 Ig/L (780 ppbv).
g TCE was detected only in soil gas at SWMU I/Area 2.
h Soil cleanup standard for TCE corresponds to a target soil gas cleanup standard of 1.9 Ig/L (350 ppbv).

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not reguired
PRG = Preliminary Remedial Goal
RBC = risk-based concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-5. Determination of Soil Cleanup Standards for Area 1 Building 237
Equilibrium
Threat to Threat to Partitioning
Maximum Beneficial Background Equilibrium Limit Protective Soil Gas
Background Concentration Uses In Groundwater RBC RBC Region Partitioning Limit of Background Model Cleanup
Constituent Threshold a Detected Groundwater Quality E-06 HI = 1 RL IX PRG b Protective of MCL c Water Quality d Level e Standards

VOCS (Ig/kg)
Tetrachloroethene (PCE) NE 1,120 Yes Yes NA NA 10 17,000 2.4 0.2 15 780 ppbv f
Trichloroethene (TCE) NE ND NA NA NA NA 10 7,000 1.3 0.3 NE 350 ppbv g

a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Equilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
d Equilibrium partitioning limit based upon comparison of detection limit to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of MCL in groundwater at the source area.
f Soil cleanup standard for PCE corresponds to a target soil gas cleanup standard of 5.4 Ig/L (780 ppbv).
g Soil cleanup standard for TCE corresponds to a target soil gas cleanup standard of 1.9 Ig/L (350 ppbv).

HI = Hazard index
NA = not applicable
NE = not evaluated
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-6. Determination of Soil Cleanup Standards for Area 3
Constituent

VOCS (Ig/kg)
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Background
Threshold a
NE
NE
Maximum
Concentration
Detected
227
440
Threat to
Beneficial
Uses In
Groundwater
Yes
NA
Threat to
Background
Groundwater
Quality
Yes
NA
RBC
E-06
NA
NA
RBC
HI = 1
Region
Eguilibrium
Partitioning Limit
Eguilibrium
Partitioning
Limit Protective
of Background
Model
Soil Gas
Cleanup
NA
NA
RL
10
10
IX PRG b Protective of MCL c Water Quality d Level e Standards
17,000
7,000
2.4
1.3
0.2
0.3
22
32
780 ppbv f
350 ppbv g
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996) .
c Eguilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
d Eguilibrium partitioning limit based upon comparison of detection limit to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of MCL in groundwater at the source area.
f Soil cleanup standard for PCE corresponds to a target soil gas cleanup standard of 5.4 Ig/L (780 ppbv).
g TCE was detected only in soil gas at SWMU I/Area 2.

Pesticides (Ig/kg)

Total DDK

Metals (Ig/kg)

Lead

Selenium
Background
Threshold a
3,877

NE
Maximum
Concentration
Detected
NE

25,000
Threat to
Beneficial
Uses In
Groundwater
Yes

No
Threat to
Background
Groundwater
Quality
Yes

No
RBC
E-06

NA
Ecological
RBC

241

5,130

616
RL
NE

NE
Region IX
PRG b

5,600

NE
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
NE

NE
Eguilibrium
Partitioning
Limit Protective
of Background d
NE

NE
Cleanup
Standards
241

5,130

616
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon comparison of MCLs to soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values in groundwater (A Horizon) or detection limits to soil-water concentrations.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = Not Reguired
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-8. Chemical-Specific Requirements for Disposal of Soil/Sediment, DDJC-Tracy
Substances
STLC TTLC Wet Weight
(mg/L) (mg/kg)
Inorganic Substances
Antimony and/or antimony compounds 15
Arsenic and/or arsenic compounds 5.0
Barium and/or barium compounds (excluding barite) 100
Beryllium and/or beryllium compounds 0.75
Cadmium and/or cadmium compounds 1.0
Chromium (VI) compounds 5
Chromium and/or chromium (III) compounds 5 b
Cobalt and/or cobalt compounds 80
Copper and/or copper compounds 25
Fluoride salts 180
Lead and/or lead compounds 5 . 0
Mercury and/or mercury compounds 0.2
Molybdenum and/or molybdenum compounds 350
Nickel and/or nickel compounds 20
Selenium and/or selenium compounds 1.0
Silver and/or silver compounds 5
Thallium and/or thallium compounds 7.0
Zinc and/or zinc compounds 250
500
500
10,000
75
100
500
2,500
8,000
2,500
18,000
1,300
20
3,500
2,000
100
500
700
5,000
Organic Substances
Aldrin
Chlordane
DDT, DDE, ODD
Dieldrin
Dioxin (2,3,7,8-TCDD)
Endrin
Heptachlor
Lead compounds, organic
Lindane
Methoxychlor
Pentachlorophenol
Polychlorinated biphenyls (PCBs)
Trichloroethene
0.14
0.25
0.1
0.8
0.001
0.02
0.47

0.4
10
1.7
5.0
204
1.4
2.5
1.0
8.0
0.01
0.2
4.7
13
4.0
100
17
50
2,040
a Excluding barium sulfate.
b If the soluble chromium as determined by the TCLP set forth in Appendix I of Chapter 18 of
this division, is less than 5 mg/L, and the soluble chromium, as determined by the procedures
set forth in Appendix I of Chapter 11, eguals or exceeds 560 mg/L and the waste is not
otherwise identified as a RCRA hazardous waste.
c Excluding molybdenum disulfide.

STLC = Soluble Threshold Limit Concentration
TTLC = Total Threshold Limit Concentration
Source: Title 22, California Code of Regulations, Division 4.5, Section 66261.
-------
Table 10-9. Determination of Soil Cleanup Standards for SWMU 6
Constituent

Pesticides and Herbicides (Ig/kg)

Dicamba

Dieldrin

Endrin

Heptachlor

Lindane

2,4,5-T

Background
Threshold a
(Ig/kg)
2.82
12.9
1
13.5
1.23
2.97

Maximum
Concentration
Detected

3.84
24.9
66.7
23
56
74.8
Threat to
Beneficial
Uses In
Groundwater

Yes
Yes
No
Yes
Yes
No
Threat to
Background
Groundwater
Quality

Yes
Yes
Yes
Yes
Yes
Yes

RBC
E-06

NA
NA
NA
NA
NA
NA

RBC
HI = 1

NA
NA
NA
NA
NA
NA

Region IX
RL PRG b

10 20,000,000
2 120
3 200,000
1.5 420
1.7 1,500
5 6,800,000
Equilib
Partitioni:
Protect!"
Beneficial

1.3
0.1
21
0.1
0.2
14
Eguilibrium
Partitioning Limit
Protective of
Background d
0.01

0.01

0.1

0.04

<0.01

0.02
Model
Level e
NE
3 f
NE
NE
5
NE
Cleanup
Standards
10
3
3
1.5
1.7
5
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of numerical beneficial use limits to soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values in groundwater (A Horizon) to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of numerical beneficial use limit in groundwater at the source area.
f Model level extrapolated from SWMU 7, which has similar concentrations and distribution of dieldrin.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not reguired
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-10. Determination of Soil Cleanup Standards for SWMU 7
Constituent

VOCs (Ig/kg) - Pit F Only

1,2-Dichloroethene
Trichloroethene (TCE)

SVOCs (Ig/kg) - Pit C Only

bis (2-
Ethylhexyl)phthalate
Background
Threshold a
NE
NE
NE
Maximum
Concentration
Detected
7.1
22
5,700
Threat to
Beneficial
Uses In
Groundwater
Yes
Yes
No
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
RBC
E-06
NA
NA
NA
RBC
HI = 1
NA
NA
NA
RL
10
5
330
Pesticides and Herbicides (Ig/kg) - Pit C Only
Dieldrin
Linuron
12.9
96
69.5
360
Pesticides and Herbicides (Ig/kg) - Pit D Only
2,4-D
Dieldrin
Linuron
Simazine
3.06
12.9
96
84
23.4
7.49
270
79.4
Petroleum Hydrocarbons (Ig/kg - Pit D Only

TPH as Diesel NE 320
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
3
200
NA
NA
10
Region IX
PRG b
120,000
7,000
140,000
120
1,400,000
Equilibrium
Partitioning Limit
Protective of
Beneficial Uses c
1.2
1.3
224
Equilibrium
Partitioning
Limit Protective
of Background d
0.2
0.3
122
Model Cleanup
Level e Standards g
NE
NE
NR
10
5
330
NA
NA
NA
NA
NA
NA
NA
NA
25
3
200
10
6,800,000
120
1,400,000
16,000
NE
0.1
1
11
0.1
1
1
NE
0.01
0.1
0.01
0.01
0.1
0.1
NE
3
NE
NE
3
NE
NE
NE
3
200
25
3
200
10
100,000 f
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Equilibrium partitioning limit based upon equivalency of numerical beneficial use limits to soil-water concentrations.
d Equilibrium partitioning limit based upon equivalency of background threshold values in groundwater (A Horizon) to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, and based upon predicted achievement of numerical beneficial use limit in groundwater at the source area.
f Limits for TPH were determined using the scoring criteria in the Tri-Regional guidance.
g Cleanup standards serve as criteria for evaluating the continued need for institutional contents.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = Not Required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-11. Determination of Soil Cleanup Standards for SWMU 8

Constituent
SVOCs (Ig/kg)
bis (2-Ethylhexyl)phthalate
Diethylphthalate
2, 4-Dinitrotoluene
Naphthalene
Pesticides and Herbicides
Chlordane, total
2,4-D
DDD
DDE
DDT
DDK, Total
Dieldrin
Lindane
Linuron
MCPA
Simazine

Background
Threshold a

NE
NE
NE
NE
(Ig/kg)
585
3.06
28.1
1,284
2,565
3,877
12.9
1.23
96
66.2
84
Maximum
Concentration
Detected

4,000
120
220
2,100

2,130
47.2
51,400
15,200
2,640
69,240
2,640
34.3
280
82.5
300
Threat to
Beneficial
Uses In
Groundwater

No
No
Yes
Yes

Yes
Yes
Yes
No
No
NA
Yes
Yes
Yes
Yes
Yes
Threat to
Background

Groundwater RBC
Quality

Yes
Yes
Yes
Yes

Yes
Yes
Yes
No
Yes
NA
Yes
Yes
Yes
Yes
Yes
E-06

NA
NA
NA
NA

NA
NA
NA
NA
NA
30,000 f
600 f
NA
NA
NA
NA

RBC
HI = 1

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

330
330
330
330

5
25
3
3
3
3
2
1.7
200
5,000
10

Region IX
PRG b

140,000
10,000,000
1,400,000
2,400,000

1,500
6,800
7,900
5, 600
5,600
NE
120
1,500
1,400,000
6,800,000
16,000
Petroleum Hydrocarbons (Ig/kg)
TPH as Gasoline
TPH as Diesel
TPH as Motor Oil
NE
NE
NE
11
2, 600
14,000
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NE
NE
NE
NE
NE
NE
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
224
1,222
9
21
10
11
81
NA
7
NA
0.1
0.2
1
1
1
NE
NE
NE
Eguilibrium
Partitioning
Limit Protective
of Background
Water Quality d
122
0.2
0.4
21
10
0.02
3
15
1
NA
0.01
0.004
0.1
0.1
0.1
NE
NE
NE
Model
Level e
NR
NE
NE
NE
NE
NE
NR
NR
NR
NE
2
NE
NE
NE
NE
NE
NE
NE
Cleanup
Standards
330
330
330
330
10
25
81
NE
7
30,000
2
1.7
200
5,000
10
1,000 g
10,000 g
10,000 g
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of numerical beneficial use limits to soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values in groundwater (A Horizon) or detection limits to soil-water concentration.
e Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of MCL in groundwater.
f Risk-based cleanup standard based on mitigating exposure to future construction workers.
g Limits for TPH were determined using the scoring criteria in the Tri-Regional guidance.
= hazard index
= not applicable
= not evaluated
= not reguired
HI
NA
NE
NR
PRG = Preliminary Remedial Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Constituent

VOCs (Ig/kg)
Table 10-12. Determination of Soil Cleanup Standards for SWMU 20 and Area 1 Building 10
Maximum
Background Concentration Uses In Groundwater RBC RBC Region IX
Threshold a Detected Groundwater Quality E-06 HI = 1 RL PRG b
Trichloroethene (TCE)
Ethylbenzene
Xylenes

SVOCs (Ig/kg)

Diethylphihalate
2,4-Dinitrophenol
Pentachlorophenol
2,4,6-Trichlorophenol
NE
NE
NE
NE
NE
NE
NE
Pesticides and Herbicides (Ig/kg)
Dieldrin
Methiocarb
MCPA
Linuron
12.9
820
66.2
96
Petroleum Hydrocarbons (Ig/kg)

PH as Diesel NE
630
6.1
35
490
3,210
2,380
1,420
5.3
900
79.3
240
500
Threat to
Beneficial
Uses In
Groundwater
Yes
No
No
No
Yes
No
Yes
No
Yes
Yes
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

RBC
E-06
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

RBC
HI = 1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10 7,000
5 230,000
5 320,000
330 10,000,000
1,300 1,400,000
830 7,900
330 170,000
2 120
500 NE
5,000 6,800,000
200 1,400,000
Yes
Yes
NA
NA
NE
NE
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
1.3
653
582
1,222
11
227
10
0.1
1
1
1
NE
Eguilibrium
Partitioning
Limit Protective
of Background
Water Quality d
0.3
1
0.3
0.2
5
7
7
0.01
1
0.1
0.1
NE
Model
Level e
36
NE
NE
NE
NE
NE
NE
27
NE
NE
NE
Cleanup
Standards
5(350 ppb f)
5
5
330
1,300
830
330
2
500
5,000
200
NE
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of the numerical beneficial use limits to the soil-water concentration.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values or PQLs to the soil-water concentration.
e Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of MCLs in groundwater at the source area.
f Soil cleanup standard for TCE for treatment with SVE corresponds to a target soil-gas cleanup standard of 1.9 Ig/L (350 ppbv).
g Standards for TPH were determined using scoring criteria from Tri-Regional Guidelines.

VOCs (Ig/kg)

Acetone
2-Butanone (MEK)
Ethylbenzene
2-Hexanone
4-Methyl-2-pentanone (MIUK)
Toluene
Xylenes

SVOCs (Ig/kg)

2,4-Dimethylphenol
Fluoranthene
2-Methylnaphthalene
4-Methylphenol
Naphthalene
Phenanthrene
Phenol
Pyrene

Petroleum Hydrocarbons (Ig/kg)

TPH as Gasoline
TPH as Diesel

Pesticides and PCBs (Ig/kg)

PCBs (Aroclor- 1260)
Carbofuran
Lindane
Phorate
Ronnel

Background
Threshold a
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
r\
f)
NE
NE
NE
490
1.23
38.8
40.8
Maximum
Threat to
Beneficial
Concentration Uses in
Detected
860,000
500
37,000
66,000
80
160,000
200,000
260
23,000
30,000
880
20,000
24,000
350
16,000
5,160
1,390
450
620
30
439
353
Groundwater
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

RBC
E-06
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

RBC
HI = 1
NA
NA
NA
NA
NA
16,000 e
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

RL
10
10
10
10
10
5
5
330
330
330
330
330
330
330
330
1
10
30
500
1.7
20
35

Region IX
PRG b
8,800,000
27,000,000
230,000
NE
2,800,000
880,000
320,000
14,000,000
27,000,000
NE
3,400,000
240,000
NE
100,000,000
100,000
NE
NE
340
34,000,000
1,500
140,000
34,000,000
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
89
30
653
0.3
436
56
582
34
8,023
6
17
21
14
1
5,610
NE
NE
182
4
0.2
17
1,038
Eguilibrium
Partitioning Limit
Protective of
Background d
1
1
1
1
1
0.4
0.3
1
3
6
1
21
14
0.3
27
NE
NE
45
0.2
0.004
2
1
Cleanup
Standards
10
10
10
10
10
5
5
330
330
330
330
330
330
330
330
1,000 f
10,000 f
30
500
1.7
20
35
-------
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of numerical beneficial use limits to soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values in groundwater (A Horizon) or detection limits to soil-water concentrations.
e Risk-based cleanup standard based on mitigating exposure to future depot workers to toluene in indoor air and arbitrary assumption that toluene concentration must be reduced by a
factor of 10.
f Units for TPH were determined using the scoring criteria in the Tri-Regional Guidelines.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not reguired
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-14. Determination of Soil Cleanup Standards for SWMU 27
Maximum
Background Concentration
Constituent

VOCs (Ig/kg)

Trichloroethene (TCE)

SVOCS (Ig/kg)

Benzo(a)pyrene
Total PAHs
Threshold a
NE
NE
NE
Detected
5.9
6,100
22,900 JII
Pesticides, Herbicides, and PCBs (Ig/kg)
2,4-D
MCPA
PCBs (Aroclor-1260)
2,4,5-T
3.06
66.2
NE
2.97
4.36
142
1,800 J14
5.69
Threat to
Beneficial
Uses in
Groundwater
No
No
No
No
Yes
No
No
Threat to
Background
Groundwater
Quality
Yes
No
No
RBC
E-06
NA
1,000
RBC
HI = 1
NA
NA
15,000 h NA
Region IX
RL PRG b
7,000
330
460
260
33,800
Yes
Yes
No
Yes
NA
NA
1,000
NA
NA
NA
NA
NA
25
5,000
30
5
6,800,000
680,000
340
680,000
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
1.3
NA
NA
11
1
NA
14
Eguilibrium
Partitioning Limit
Protective of Model
Background d Level e
0.3
NA
NA
0.02
0.1
NA
0.02
36 f
NE
NE
NE
NE
NE
NE
Cleanup
Standards
5 R
1,000
15,000
25
5,000
1,000
5
Petroleum Hydrocarbons (Ig/kg)
TPH as Motor Oil
NE
12,000
Yes
Yes
NA
NA
10
NE
NE
NE
NE
10,000 L
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of the numerical beneficial use limits to the soil-water concentration.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values in groundwater (A Horizon) or detection limits to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of MCLs in groundwater.
f Model level extrapolated from Area 1 Building 10, which has similar concentrations and distribution of TCE.
g Soil cleanup standard for TCE corresponds to a soil gas cleanup standard of 1.9 Ig/L (350 ppbv).
h Sum of benzo(a)anthracene, benzo(b)fluornanthene, benzo(k)fluoranthene, and ideno(1,2,3-cd)pyrene.
i Standards for TPH as motor oil were determined using scoring criteria for Tri-Regional guidance.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not reguired
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-16. Determination of Soil Cleanup Standards for SWMU 2 and SWMU 3
Constituent

VOCs (Ig/kg)
Threat to Threat to
Maximum Beneficial Background
Background Concentration Uses in Groundwater
Threshold a Detected Groundwater Quality
RBC RBC Region IX
E-06 HI = 1 RL PRG b
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
Eguilibrium
Partitioning Limit
Protective of Model
Background d Level e
Cleanup
Standards
Table 10-15. Determination of Soil Cleanup Standards for Brum Storage Area Building 30
Constituent

SVOCs (Ig/kg)

Benzyl alcohol
bis (2-Ethylhexyl)phthalate
Diethylphalate
Di-n-butylphthaiate
Background
Threshold a
NE
NE
NE
NE
Maximum
Concentration
Detected
1,300
2,800
230
96,000
Threat to
Beneficial
Uses in
Groundwater
No
Yes
No
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
RBC
E-06
NA
NA
NA
NA
RBC
HI = 1
NA
NA
NA
NA
RL
330
330
330
330
Region IX
PRG b
10,000,000
140,000
10,000,000
68,000,000
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
1, 618
244
1,222
83,401
Eguilibrium
Partitioning Limit
Protective of
Background d
0.3
122
0.2
119
Cleanup
Standards
330
330
330
330
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of numerical beneficial use limits to soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of detection limits to soil-water concentrations.
e Cleanup standards serve as criteria for evaluating the continued need for institutional controls.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not reguired
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
-------
Table 10-16. Determination of Soil Cleanup Standards for SWMU 2 and SWMU 3
Constituent

SVOCs (Ig/kg)

bis (2-Ethylhexyl)phthalate
2,4-Dimethylphenol
Di-n-butylphthaiate
4-Methylphenol

Pesticides (Ig/kg)

Aldrin
Chlordane, total
DDD
DDE
DDT
DDK, total
Dieldrin
Diuron
Endrin

Lindane (Gamma-BHC)
Monuron
2,4-D
Heptachlor epoxide
Metals (Ig/kg)

Lead
Selenium

Background
Threshold a
NE
NE
NE
NE
0.817
585
28.1
1,284
2,565
3,877
12.9
88.2
1
1.23
100
3.06
0.765
NE
514
Maximum
Concentration
Detected
790
450
4,600
400
30.2
32,900
13,100
3,350
8,900
25,350
4,770
145
31.9
40
220
16.9
6,250
NE
13,500
Threat to
Beneficial
Uses in
Groundwater
Yes
No
No
Yes
Yes
No
No
No
No
No
Yes
Yes
No
Yes
Yes
No
Yes
No
No
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No

RBC
E-06
NA
NA
NA
NA
NA
8,000
NA
NA
NA
30,000
600
NA
NA
NA
NA
NA
NA
NE
NA

RBC
HI = 1
NA
NA
NA
NA
NA
NA
NA
NA
NA
241
NA
NA
NA
NA
NA
NA
NA
28,300
616

RL
330
330
330
330
1.7
5
3
3
3
3
2
260
3
1.7
260
25
1.5

Region IX
PRG b
140,000
14,000,000
68,000,000
3,400,000
110
1,500
7,900
5, 600
5,600
5, 600
120
1,400,000
200,000
1,500
NE
6,800,000
210
NE
NE
Equilibrium
Partitioning Limit
Protective of
Beneficial Uses c
244
34
83,401
17
3
10
1,600 f
1,800 f
1,700 f
NA
370 f
4
21

0.2
0.04
47 f
0.004
Equilibrium
Partitioning Limit
Protective of
Background d
Model
Level e
NE
NE
NE
NR
NE
NR
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Equilibrium partitioning limit based upon equivalency of the numerical beneficial use limits to the Soil-Water concentration.
d Equilibrium partitioning limit based upon equivalency of background threshold values (A Horizon) or PQLs to soil-water concentrations.
e Model level derived using vadose zone and groundwater modeling, based upon predicted achievement of beneficial use limits in groundwater at the source area.
f Revised on basis of supplemental DI-WET results obtained during removal action.

HI = Hazard Index
NA = not applicable
NE = not evaluated
NR = not required
PRG = Preliminary Remediation Goal
RBC = Risk-Based Concentration
RL = Laboratory reporting limit corresponding to the lowest concentration that can be reproducibly detected as verified by the use of a low-level standard
Cleanup
Standards
122
1
119
1
NE
NE
NE
NE
330
330
330
330
0.3
10
1,600
15
1
NA
0.01
0.1
0.1

0.004
0.01
0.2
0.002
NE
NR
NR
NR
NR
NR
0.1
NE
120
(120)
NE
NE
NE
NE
3
10
1,600
1,800
1,700
241
370
260
3

1.7
260
47
1.5
28,300
616
-------
Table 10-17. Determination of Soil Cleanup Standards for SWMU 33
Constituent

VOCs (Ig/kg)

Xylenes

SVOCS (Ig/kg)

Diethylphthalate
Di-n-butylphthaiate
Naphthalene

Pesticides (Ig/kg)

Aldrin
Carbaryl
Dieldrin
Methiocarb

Hydrocarbons (Ig/kg)

TPH as Diesel
Threat to
Maximum Beneficial
Background Concentration Uses in
Threshold a Detected Groundwater
NE
NE
NE
NE
32
130
1,900
2,800 J
No
No
No
Yes
Threat to
Background
Groundwater
Quality
Yes
Yes
Yes
Yes
RBC
E-06
NA
NA
NA
NA
RBC
HI = 1
NA
NA
NA
NA
RL
330
330
330
Region IX
PRG b
320,000
10,000,000
68,000,000
800,000
Eguilibrium
Partitioning Limit
Protective of
Beneficial Uses c
582
1,222
83,401
21
0.817
230
12.9
820
1.54
540
22.6
3,200
No
Yes
No
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
NA
NA
1.7
400
2
500
110
68,000,000
120
NE
3
24
0.1
NE
Eguilibrium
Partitioning Limit
Protective of Model
Background d Level e
Cleanup
Standards
NE
15,100
Yes
Yes
NA
NA
10
NE
NE
0.3
0.2
119
21
0.3
0.2
0.01
1
NE
NE
NE
NE
NE
NE
NE
27
NE
NE
330
330
330
1.7
400
2
500
100,000
a Background threshold values were determined for metals in all site soils; background threshold values for pesticides apply only to soils less than 2 feet deep.
b Region IX PRG based on industrial exposure scenario (USEPA, 1996).
c Eguilibrium partitioning limit based upon eguivalency of the numerical beneficial use limits to the soil-water concentrations.
d Eguilibrium partitioning limit based upon eguivalency of background threshold values (A Horizon) or detection limits to soil-water concentrations.
e Model level extrapolated from SWMU 7, which has similar concentrations and distribution of B2EHP.
f Standards for TPH as diesel was determined using the scoring criteria in the Tri-Regional guidance.
-------
Table B-l.
Summary of Data Flags and Figure Abbreviations
Comments Explanation
1 Qualified due to detected concentration in associated method blank sample.
2 Qualified due to detected concentration in associated trip blank sample.
3 Qualified due to integration nonconformances; bias cannot be determined.
4 Qualified due to detected concentration in associated equipment rinsate blank sample.
5 Qualified as positively biased due to surrogate recoveries above the established acceptance limits.
6 Qualified as negatively biased due to surrogate recoveries below the established acceptance limits.
7 Qualified due to surrogate recoveries outside the established acceptance limits; bias cannot be
determined.
8 Qualified as positively biased due to MS/MSD recoveries above the established acceptance limits.
9 Qualified as negatively biased due to MS/MSD recoveries below the established acceptance limits.
10 Qualified due to MS/MSD recoveries outside the established acceptance limits; bias cannot be determined.
11 Qualified as positively biased due to LCS recoveries above the established acceptance limits.
12 Qualified as negatively biased due to LCS recoveries below the established acceptance limits.
13 Qualified due to LCS recoveries outside the established acceptance limits; bias cannot be determined.
14* Qualified as positively biased due to calibration nonconformances.
15* Qualified as negatively biased due to calibration nonconformances.
16 Qualified due to calibration nonconformances; bias cannot be determined.
17 Qualified as negatively biased due to holding time nonconformances.
18 Qualified as negatively biased due to sample receipt nonconformances.
19 Qualified as positively biased due to sample receipt nonconformances.
20 Qualified due to sample receipt nonconformances; bias can not be determined.
21 Qualified as positively biased due to other criteria (used twice, once for selenium and once for
miscalculation).
22 Qualified as negatively biased due to other criteria (Not used).
23 Qualified due to other criteria; bias cannot be determined (Not used).
24 Qualified due to detected concentration in associated source water sample.
25 Reporting limit estimated due to low standard response.
26 Chromatogram did not match the diesel standard fingerprint pattern.
27 Retention time windows shifted during analysis.

DUP = duplicate sample
J = qualified as estimated
mg/kg = milligrams per kilogram
mg/L = milligrams per Liter
NC = No Constituents detected above laboratory reporting limit or above background
R = qualified as rejected
TEQ = toxicity equivalent, expressed as Ig/kg or Ig/L of 2,3,7-8 TCDD for soil and water, respectively.
TPHD = total petroleum hydrocarbons, diesel range
TPHG = total petroleum hydrocarbons, gasoline range
U = qualified as not detected
Ig/kg = micrograms per kilogram
Ig/L = microgram per Liter
* = most commonly used qualifiers
MS/MSD = matrix spike/matrix spike duplicate
LCS = laboratory control samples
-------
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Canonie Environmental Services, 1989. Laboratory Results of Lined Industrial Wastewater Pond
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Cal-EPA CVRWQCB, 1994. Basin Plan for the Central Valley Region - Sacramento River and San
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Cal-EPA DTSC, 1992. Supplemental Guidance for Human Health Multimedia Risk Assessments for
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DDRW-Tracy, 1996. Personal communication between Marshall Cloud of DDRW-Tracy and Nancy Barnes
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Dupont, R.R., 1993. Bioventing/Soil Vapor Extraction Do's and Don'ts. Presented at Montgomery
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Edens, F.W.; Benton, E.; Bursian, S.J.; Morgan, G.W. Toxicology and Applied Pharmacology, Volume
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Edens, F.W. and Garlich, J.D. Poultry Science, Volume 62,1757-63. 1983.

ENSOTECH, 1991. Geologic Well Logs for Interim Groundwater Remediation at Tracy Defense Depot.
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Heath, R.G.; Spann, J.W.; Kreitzer, J.F. Nature (London) 224, 47-8. 1969.

Heintz, G.H.; Hoffman, D.J.; Gold, L.G. Journal of Wildlife Management. 53:418-28. 1989.

Menzie, C.A.; Potocki, B.B; Santodonato, J., 1992. "Exposure to Carcinogenic PAHs in the
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Montgomery Watson, 1993. DDRW-Tracy, California, Amendments to the Comprehensive Remedial
Investigation/Feasibility Study (RI/FS) Work Plan. June.

Montgomery Watson, 1994a. DDRW-Tracy, California, Final Well Abandonment Work Plan. September.

Montgomery Watson, 1994b. DDRW-Tracy, California, Final Comprehensive Site Wide RI/FS - Phase I
Site Characterization Report. October.

Montgomery Watson, 1994c. DDRW-Tracy, California, Final Comprehensive Site Wide RI/FS - Phase II
Work Plan. December.

Montgomery Watson, 1995. DDRW-Tracy Draft Comprehensive RI/FS. Phase II Technical Memorandum.
March.

Montgomery Watson 1996a. DDRW-Tracy California, Final Comprehensive Remedial
Investigation/Feasibility Study. Volumes I and II. November.

Montgomery Watson, 1996b. DDRW-Tracy, California, Remedial Action Work Plan for Operable Unit 1.
January.

Montgomery Watson, 1996c. DDRW-Tracy, California, Final Remedial Design Report and Analysis for
Operable Unit 1, 100 Percent Submittal. April.
-------
Montgomery Watson, 1996d. Final Comprehensive Site-Wide Baseline Risk Assessment, Appendix R to
the DDRW-Tracy Comprehensive RI/FS. November.

Montgomery Watson, 1996e. DDRW-Tracy, California, Final Construction Specifications, OU 1
Remedial Design, 100 Percent Submittal. April.

Montgomery Watson, 1996f. DDRW-Tracy, Final Well Abandonment Engineering Report. November.

Montgomery Watson, 1996g. DDRW-Tracy, California, Final Explanation of Significant Differences.
January.

Montgomery Watson, 1997a. Final Comprehensive Site-Wide Proposed Plan. November 1996.

Montgomery Watson, 1997b. Draft Technical Memorandum Site-Specific Risks for Exposure Units 8,
10, and 11, June.

Radian, 1986. DDRW, Tracy, California, Geohydrological Investigations, Final Engineering Report.

Radian, 1996a. Final EE/CA for the Industrial Waste Pipeline, Sewage Lagoons, and Industrial
Waste Lagoons. January.

Radian, 1996b. Day Care Center Closure Report.

Radian, 1996c. Final Underground Storage Tank Closure Report. May.

Radian, 1996d. Draft Action Memorandum for Removal Actions at the Industrial Waste Pipeline,
Sewage Lagoons, and Industrial Waste Lagoons. February.

Radian, 1996e. Environmental Master Plan, Version 1.0. Final. December.

Radian, 1997. DDRW-Tracy Well Monitoring Program: 1996 Annual Monitoring Report. April.

USATHAMA, 1980. U.S. Army Toxic and Hazardous Materials Agency Installation Assessment of
Defense Depot, Tracy, California, Report No. 181. October.

U.S. Army Environmental Hygiene Agency (USAEHA), 1980. Solid Waste Special Study No.
10-61-0165-81 DDTC. July.

USAEHA, 1985. Geohydrological Study No. 38-26-0488-85, Defense Depot, Tracy. February.

U.S. EPA, 1988, CERCLA Compliance with Other Laws, Draft Guidance, OSWER Directive 9234.1-01,
August 8, 1986.

U.S. EPA, 1989a. Exposure Factors Handbook, EPA/600/8-89/043, 1989.

U.S. EPA, 1989b. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation
Manual (Part A), EPA/540/1 - 89/002, Interim Final. December.

U.S. EPA, 1989c. Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The
Record of Decision, Explanation of Significant Differences, The Record of Decision
Amendment. Interim Final. July.

U.S. EPA, 1990a. RCRA Facility Assessment Defense Depot, Tracy, California. April.

U.S. EPA, 1990b. National Oil and Hazardous Substances Pollution Contingency Plan Final Rule, 40
CFR Part 300, Federal Register Vol. 55, No. 46, March.

U.S. EPA, 1991a. Ecological Assessment of Superfund Sites: An Overview, Publication 9345.0-051.
December 1991.

U.S. EPA, 1991b. Human Health Evaluation Manual Supplemental Guidance: Standard Default Exposure
Factors, Publication 9285.6-03. March.
-------
Woodward-Clyde Consultants (WCC), 1992a. Final Comprehensive RI/FS Work Plan, DDRW-Tracy.
September.

WCC, 1992b. Draft Final Operable Unit No. 1 RI/RA, DDRW-Tracy, California. July.

WCC, 1992c. Operable Unit 1 FS Report DDRW-Tracy, California. December.

WCC, 1992d. Draft Final Operable Unit 1 RI/RA Report DDRW-Tracy, California. July.

WCC, 1993. Final Operable Unit No. 1, Record of Decision, DDRW-Tracy, California. August.
-------
RESPONSIVENESS SUMMARY

A. OVERVIEW

Since 1942, the DDJC-Tracy facility has played an active role in the Tracy community, service as
one of the largest employers in this historically agricultural region. According to the
installation's 1994 Community Relations Plan, the Tracy community is generally well-informed
about environmental concerns at the depot and generally supportive of the installation's efforts
to remediate its contaminated sites.

In February 1997, DDJC-Tracy published and distributed a Proposed Plan for Twenty Sites
(Proposed Plan), which summarized the cleanup alternatives considered in the DDRW-Tracy
Comprehensive Remedial Investigation/Feasibility Study (RI/FS). The RI/FS identified twenty
sites within the original installation boundaries where action is required to reduce the risks
posed by on-site contaminants. Preferred remedial alternatives were identified for each of the
twenty sites. The Proposed Plan was mailed to the installation's 1,200-address community contact
list, and was presented and discussed at a public meeting held at the City of Tracy Community
Center on 19 February 1997.

Although the meeting was well attended, no verbal comments specific to the cleanup alternatives
presented in the Proposed Plan were received from the public. Public comments recorded at the 19
February meeting included guestions about:

• The installation's history of success with the cleanup of large contaminant plumes,
and the usual time frame for accomplishing such cleanups;

• The effectiveness of the installation's existing air stripper and groundwater treatment
system;

• The reuse of treated groundwater for agricultural purposes;

• The reuse of industrial wastewater from other industries in the community;

• How the reinjection of treated groundwater impacts the movement of contaminant plumes;

• Other remediation projects under way at the installation; and

• Whether the installation is currently conducting any activities that would lead to the
future need for remediation.

An adjacent property owner submitted the single written comment received on the Proposed Plan.
In this comment the property owner expressed his overall support for several of the proposed
alternatives, and his concern about the capacity and the cost of the proposed groundwater
treatment system. This comment is addressed in Section C of the Responsiveness Summary,
("Summary of Public Comments Received During Public Comment Period, and Agency Responses").

B. BACKGROUND ON COMMUNITY INVOLVEMENT

Community interest in environmental issues at DDJC-Tracy has been low to moderate throughout the
course of the depot's history. Recurring issues of concern primarily involve the movement of
contaminants in groundwater.

In 1980, DDJC-Tracy (then known as Defense Depot Tracy) began sampling a series of 14
groundwater monitoring wells. In May 1984, the depot advised the California Regional Water
Quality Control Board (RWQCB) that the TCE and PCE levels in three of these wells exceeded the
respective state action levels. The depot's on-post newsletter, the Tracy Triangle, addressed
this situation in several articles beginning in July 1984.

Contamination issues at the DDJC-Tracy depot began to receive widespread coverage in the local
and regional press when, in July 1985, the installation was identified as one of a number of
sites to be studied by a county toxic waste task force. Nearby residents and the principal of
the nearest school were invited to a public meeting at Defense Depot Tracy on 2 April 1986 to
discuss the depot's groundwater monitoring program, the test results, and future plans. Media
-------
attention continued as the installation added monitoring wells both on- and off-site. In July
1986, State Assembly member Patrick Johnston toured the site's groundwater monitoring
facilities. The installation's first Community Relations Plan (CRP) was also prepared that year.

Public participation activities waned until DDJC-Tracy was placed on the National Priorities
List of the U.S. Environmental Protection Agency's on August 30, 1990. Following this listing,
opportunities for community involvement in environmental restoration activities increased.
DDJC-Tracy issued a number of press releases, held public comment periods on new environmental
study documents, and conducted several public meetings.

In May 1991, a series of interviews was conducted with community residents and representatives.
Community attitudes toward the depot and its environmental restoration program were mostly
favorable. Community concerns at that time included the effects that a State of California "red
line" around the depot might have on local real estate, the impacts that the injection well
system might have on local aquifers, the length of the cleanup period, efforts to contain the
contamination, and the desire for more information about the depot's environmental restoration
activities. Interviewees expressed an interest in attending public meetings and in receiving
newsletters and status reports. The CRP was updated to reflect this new input.

The CRP was again updated in 1994. At that time, the principal environmental concerns within the
community involved the ongoing drought and the dropping groundwater table. Related concerns
included groundwater contamination of the Upper Tulare Aguifer due to saltwater intrusion and/or
various chemical and hazardous materials spills.

In September 1995, DDJC-Tracy received a great deal of media attention when the depot announced
it had discovered pesticide residues in the lawn outside the installation's on-site Child
Development Center. DDJC-Tracy acted guickly to excavate and replace the lawn, and to keep
concerned parents and the community informed throughout this process. A public meeting was held
on 13 September 1995, at the Child Development Center site to present the excavation plan and to
answer all guestions regarding the health and safety of the children attending the facility.
Specialists in the fields of toxicology and risk assessment were included on the depot's
presentation panel and informational handouts were made available. The meeting was very well
attended, and DDJC-Tracy received high marks from the community and the press for its proactive
handling of this incident.

In June 1996, DDJC-Tracy initiated a new series of informational fact sheets for distribution to
the installation's community contact list. Fact Sheet #1 summarized the Engineering
Evaluation/Cost Analysis (EE/CA) for three on-post waste sites. A postage-paid environmental
concerns guestionnaire was included with the fact sheet mailing.

A mailing to the community contact list in February 1997 served several purposes. The mailing,
which was introduced with a letter from DDJC's Commander, Captain Michael Casey, transmitted a
copy of the installation's Proposed Plan for Twenty Sites and requested public comments on this
document. The mailing announced a public meeting to be held 19 February 1997 to discuss the
Proposed Plan. Fact sheet #2 also announced DDJC-Tracy's plans to reinstitute a Technical Review
Committee (TRC), and included a TRC membership application form. Per discussions with Cal-EPA's
Department of Toxic Substances Control, it was determined that, due to the generally low level
of interest within the community, it was not necessary to establish a Restoration Advisory Board
at the depot. Instead, the TRC concept would be expanded to allow for more input from community
members.

The first meeting of the installation's new TRC, held at the City of Lathrop Council Chambers on
22 May 1997 was attended by eleven community members of the TRC. Topics of discussion included
TRC formation logistics and the status of the installation's remedial program.

A chronology of community involvement activities and media coverage to date is attached to this
document.

C. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD, AND AGENCY RESPONSES

Part I - Summary and Response to Local Community Concerns

Remedial Alternative Preferences
-------
(1) Asphalt capping and encapsulation appear to be steps in the right direction, as toxics
become more of a hazard when they are extracted or otherwise entrained.

DDJC-Tracy Response: Comment noted.

(2) Alternatives involving excavation increase the potential for exposure to toxics.

DDJC-Tracy Response: Construction crews performing the excavation may be subject to some
additional risk. These crews can use risk reduction technigues, engineering controls, and
personal protective eguipment to control any potential exposure to excavated contaminants. The
soil can be wetted to minimize airborne dust, and the excavated material can be transported in
covered vessels. These measures will minimize short-term exposure to construction crews and the
general public.

Excavation reduces the risk of exposure within the surrounding community. The proposed
excavations are primarily designed to remove threats or potential threats to groundwater
guality. If the contaminants are not excavated from the sites in guestion, they will be more
likely to contact groundwater and migrate beyond the depot boundaries.

Technical Comments

(1) If the injection wells are of insufficient capacity to handle the anticipated volumes of
treated wastewater, and overflow occurs as a result, then site conditions will not have
improved significantly.

DDJC-Tracy Response: The injection system is one of the most difficult design issues to address.
DDJC-Tracy will probably construct injection galleries to discharge the treated water. The
galleries are more expensive than injection wells, but can handle larger volumes of treated
water. Additional injection galleries can be constructed if the need arises.

Cost Issues

(1) Given the limited number of families living in the path of the groundwater contaminant
plume, an alternative less costly than the proposed air stripper and groundwater treatment
system would probably be acceptable.

DDJC-Tracy Response: The groundwater treatment system primarily addresses the portions of the
groundwater plume that exceed federal and state action levels. These federal and state standards
apply to all aguifers regardless of the number of people potentially impacted by a plume.
DDJC-Tracy will fund the design, construction, and operation of a treatment system that will
reduce contaminant concentrations to these action levels. Portions of the plumes with
concentrations below the action levels will be left to attenuate.

Part II - Comprehensive Response to Specific Legal and Technical Questions

(Not applicable.)

D. REMAINING CONCERNS

(Not applicable.)
-------
Attachment A
Chronology of Community Involvement Activities
and Media Coverage

July 1984 - An environmental update of the depot's groundwater testing program appeared in
DDRW-Tracy's monthly newsletter, the Tracy Triangle.

September 1984 - A short article in the Tracy Triangle presented the results from the June
sampling of the 14 groundwater monitoring wells. The tests revealed traces of PCE and TCE above
state action levels in some wells.

December 1984 - A front-page article in the Tracy Triangle indicated plans to add 12 monitoring
wells to track the source, or sources, of the chemicals.

May 1985 - An article in the DLA Dimensions announced that the drinking water at DDRW-Tracy
meets or exceeds all reguirements of both state and federal agencies.

19 July 1985 - An article in the Tracy Press announced that DDRW is one of 61 sites to be looked
at by a county toxic task force.

20 July 1985 - A front-page article in the Manteca Bulletin announced that a task force would
study toxic waste sites in the area, including DDRW.

20 July 1985 - An article in the Stockton Record announced that Assembly member Patrick Johnston
and Supervisor Bill Sousa would be forming a task force to help the state agencies do better
jobs and that the task force recognized DDRW as a toxic waste site.

22 July 1985 - An article in the Tracy Press stated that a task force had been formed to study
toxic waste sites in San Joaguin County, including DDRW.

24 July 1995 - A front-page article in the Manteca News listed DDRW as one of the toxic sites to
be reviewed.

20 September 1985 - An article in the Modesto Bee announced that DDRW was preparing to drill
more test wells to determine whether the solvents contaminating the base's groundwater were
migrating onto surrounding farmland.

26 November 1985 - An article in the Modesto Bee stated that the San Joaguin County Toxic Task
Force wanted the military to adopt special safeguards in the event DDRW was selected as a
regional storage center for hazardous waste.

2 April 1986 - A public meeting was held at DDRW-Tracy to discuss the groundwater monitoring
program, test results, and future plans. Nineteen residents and the principal of the nearest
school were invited. Fourteen residents were in attendance.

8 April 1996 - A press release was issued to announce the results from the additional
monitoring wells and plans to install test wells off-site.

July 1986 - California State Assembly member Patrick Johnston toured the site and was brought up
to date on the groundwater monitoring program.

July 1989 - An article in the Tracy Triangle announced DDRW's placement on the National
Priorities List (NPL) of the U.S. Environmental Protection Agency.

14 July 1989 - An article in the Stockton Record announced that DDRW had been placed on the NPL
by the U.S. EPA.

30 July-30 August 1989 - A Public Notice in the Tracy Press announced a public comment period on
the Draft Negative Declaration for the interim remediation system for groundwater.

9-11 May 1990 - A public notice in the Tracy Press announced a public comment period and a
public meeting at the Tracy Public Library on a Draft Interim Remedial Action Plan for site
cleanup activities.
-------
30 August 1990- The Federal Register announced DDRWs placement on the National Priorities List.

12 July 1991 - Public notices in the Tracy Press and Stockton Record reguested public comment on
the Federal Facility Agreement for DDRW-Tracy.

30 August 1991 - Public Notices in the Tracy Press and Stockton Record reguested public comment
on the Primary Document Delivery Dates for DDRW-Tracy.

15 October 1991 - An article in the Modesto Bee discussed DDRW Tracy's efforts to locate a site
for the depot's information repository.

3 August 1992 - An article in the Stockton Record updated the public on the cleanup processes
being conducted at DDRW-Tracy.

24 December 1992 - Public notices in the Tracy Press and Stockton Record announced a public
comment period and public meeting at the Tracy Public Library on the Feasibility Study/Proposed
Plan for Operable Unit 1.

14 January 1993 - An article in the Modesto Bee announced a public meeting for the Proposed Plan
for DDRW-Tracy.

15 January 1993 - An article in the Stockton Record discussed the public meeting held on 14
January 1993.

23 February 1994 - An article in the Tracy Press discussed the air-stripping process at
DDRW-Tracy.

30 March 1994 - A front-page article in the Stockion Record listed DDRW-Tracy as one of three
Superfund cleanup sites in San Joaguin County.

9 September 1995 - Articles in the Tri-Valley Herald and the Stockton Record reported the
discovery of traces of the long-banned pesticide DDT in the lawn area surrounding the Child
Development Center at DDRW-Tracy and described DDRW-Tracy's response.

13 September 1995 - DDRW-Tracy held a public meeting to discuss actions taken in response to the
discovery of DDT in the lawn area surrounding the on-post Child Development Center. A panel of
experts was available to answer guestions from the community.

22 April 1996 - DDRW environmental and public affairs staff teamed with Radian Corporation to
host an environmental awareness program and open house for local high school students in
conjunction with Earth Day.

23 April 1996 - Articles in the Stockton Record, Manteca Bulletin, Modesto Bee, and Tracy Press
reported on Earth Day activities at DDRW-Tracy and DDRW-Sharpe.

June 1996 - A fact sheet describing the Engineering Evaluation/Cost Analysis at three
DDRW-Tracy waste sites was distributed to the community contact list.

January 1997 - DDRW-Tracy's Proposed Plan for Twenty Sites (Proposed Plan) was mailed to the
community contact list, along with a fact sheet that announced the reintroduction of the
Technical Review Committee and encouraged public participation.

8 February 1997 - An article in the Tracy Press announced the upcoming public meeting on
DDRW-Tracy's Proposed Plan.

8 February 1997 - A front-page article in the Tracy Press reported that a small amount of
corrosion inhibitor had leaked during transport and described DDRW-Tracy's response.

9 February 1997 - An article in the Stockton Record announced upcoming public meetings to
discuss cleanup proposals at the DDRW-Tracy and DDRW-Sharpe depots.

22 May 1997 - A new Technical Review Committee met to learn about the progress of DDRW-Tracy's
Installation Restoration Program.
-------
RESPONSE TO AGENCY COMMENTS

-------
FINAL

DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN (DDJC), TRACY SITE
TRACY, CALIFORNIA

SITE-WIDE COMPREHENSIVE RECORD OF DECISION

VOLUME 2 OF 2
(APPENDICES)

U.S. Army Corps of Engineers
Engineering and Support Center
Huntsville (CEHNC)
4820 University Sguare
Huntsville, Alabama 35816-1822
Attn: CEHNC-PM-ED

Prepared by:

Radian International
10389 Old Placerville Road
Sacramento, California 95827

April 1998
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Decision
APPENDIX A
ADMINISTRATIVE RECORD FIIiE INDEX
Administrative Record File Index - DDJC Tracy
Date
67/07/01
80/07/21
80/10/01
82/06/01
82/10/12
83/08/05
84/05/07
84/05/30
84/06/01
84/06/15
84/06/26
84/07/05
84/07/05
84/07/17
84/07/26
84/08/07
Author
DWR
USEHA
USATHAMA
Jefferson Assoc.,
DDTC-J
DDTC-J
DHS
RWQCB
DDTC-J
DDTC-J
RWQCB
DDTC-J
USAEHA
RWQCB
USAEHA
USAEHA
84/09/05
84/10/05
84/10/10
84/11/02

84/11/13
84/11/21

85/01/10
85/02/01
85/07/12
85/08/01
85/08/02
85/08/15

85/08/28
85/09/13
85/11/13
USAEHA
DDTC-J
DHS
DHS

RWQCB
USAEHA

DHS
USATHAMA
RWQCB
SJLHD
RWQCB
DDTC-J

DDTC-J
DHS
RWQCB
Addressee
DDTC
DDTC
DDTC
Inc. DDTC
DLA-WS
EPA
DDTC-J
DDTC-J
RWQCB
RWQCB
DDTC-J

RWQCB
DDTC-J

DDTC-J
DDTC-J
DDTC-J

DDTC-J
USAEHA
RWQCB
DDTC-D

USAEHA
DLA-WS

DDTC-D
DDTC
DDTC-J
DDTC-J
DDTC-J
RWQCB

SJLHD
Commander, DDTC
Commander, DDTC
Subject
San Joaquin County Groundwater Investigation.
Solid Waste Special Study No. 10-61-0165-81, Defense Depot Tracy, Tracy, California
Installation Assessment of Defense Depot Tracy, California, Report #181
Environmental Assessment, Defense Depot Tracy, Tracy California
Information to DLA regarding the DoD Installation Restoration Program.
Letter forwarding statistical data requested during a telephone conversation on 2 August 1983.
Letter informing DDTC that the industrial pond does not require a permit.
Letter forwarding a report regarding the inspection of DDTC on 2 Apr 84.
RWQCB response to letter of 11 May 84 (Groundwater Monitoring Program).
Transmittal of the plan for sampling, preserving, and analyzing groundwater.
Letter requesting DDTC purge wells by pumping water until pH, electrical conductivity, and
temperatures stabilize, rather than by pumping 3 to 5 volumes as suggested.
Response to RWQCB letter dated 26 June 1984.
Correspondence providing information and guidance concerning actions being taken to correct
monitoring program problems.
Letter regarding the time schedule for submittal of analytical results.
Request for review of the plan for the groundwater investigation at DDTC.
Notification of a groundwater consultation scheduled for DDTC during the period 17-20 September
1984.
Request that installations use only the new containers for the groundwater monitoring program and
return all old
and extra containers to USAEHA.
Minutes of the Groundwater Consultation meeting between USAEHA, RWQCB and DDTC.
DHS review comments on the plan for groundwater quality investigation at DDTC.
Clarification as to what the Toxic Substances Control Division can and will require in regard to the
hazardous waste site investigation.
RWQCB comments on the groundwater investigation.
Groundwater Consultation No. 38-26-0474-85, Strategy for Groundwater Quality Investigation, Defense
Depot Tracy, Tracy, California, 17-20 September 1984.
DHS comments on the Hazardous Waste Site Investigation at DDTC.
Geohydrological Study No. 38-26-0488-85, Defense Depot Tracy, California
Letter regarding the status of the SOW for the groundwater contamination project.
Closure plan for the underground storage tanks at DDTC.
Comments on the draft Statement of Work for the hazardous contamination investigation at DDTC.
DDTC response to letter of 2 Aug 85 (draft Statement of Work for the hazardous contamination
investigation.
Notice of the formulation of a closure plan for underground storage tanks.
Draft Statement of Work for hazardous waste contamination investigation.
RWQCB comments on the draft plans for the geohydrological investigation.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
85/11/14
85/12/13
86/03/01
86/03/04
86/04/07
86/04/11
86/06/11
86/06/12
86/07/14

86/07/17
86/08/05
86/08/15
86/08/27
86/10/20
86/11/07
86/11/12
86/11/13
86/11/26
86/12/01
87/02/01
87/03/06
87/03/16
87/03/19
87/04/01
87/04/09
87/04/13
87/04/17
87/04/17
87/04/17
Author
RC
DDTC-WB
SJLHD
Radian
CoE
DDTC-WB
DDTC-WB
CoE
DHS

DDTC-WB
RWQCB
RWQCB
RC
WCC
WCC
CoE
DDTC-W
DHS
WCC
CoE
WCC
DHS
WCC
WCC
WCC
DDTC-W
CoE
DDTC-W
DDTC-W
Addressee
DDTC
RWQCB
DDTC-WB
Coe, Huntsville
DDTC-J
CoE
RWQCB
DDTC-W
Deputy
Commander, DDT
RWQCB
DDTC-J
RWQCB
DDTC
CoE
CoE, Huntsville
DDTC-WB
DHS
DDTC-J
DDTC
WCC
DDTC
DDTC-J
DDTC
DDTC
DDTC-W
SJCHD
WCC
RWQCB
DHS
87/04/17
DDTC-W
WCC
Subject
Geohydrological Investigations, Final Plans, Defense Depot Tracy, Tracy, California
RWQCB response to letter of 13 Nov 85 (Geohydrological Investigations)
Permanent closure tank removal policy
Geohydrological Investigations Draft Engineering Report, DDRW-Tracy
Recommendation for Phase II, groundwater contamination confirmation and corrective action
investigation at DDTC.
Confirmation that Options 1 and 2 not be exercised under the current contract with Radian
Corporation.
Reguest review/comment for the proposed scope of work for the continuation of the Groundwater
Quality Assessment Study.
Letter forwarding the proposed SOW for the Phase II and III, IRP, Groundwater Contamination
Assessment at DDTC.
Comments on the draft Geohydrological Investigations Report.

Reguest for comments on the Radian Corporation's Draft Final engineering Report.
RWQCB's comments to the Geohydrological Investigation.
Disposal, treatment, and reuse of soils contaminated with petroleum fractions.
Geohydrological Investigations, Final Engineering Report, Defense Depot Tracy, Tracy, California
Minutes for the pre-construction meeting held on 15 October 1986.
Draft Phase II Work Plans RI/FS
Reguest for review comments on the RI/FS Work Plans.
Letter forwarding the Phase II Work Plans, RI/FS.
Reguest for a 30-day extension to comment on the Phase II Work Plan RI/FS.
Phase II Work Plans, Remedial Investigation/Feasibility Study, Defense Depot Tracy
Reguest to change analytical laboratory to perform the USEPA Method 601 and 602
Letter Report Number 1, Defense Depot Tracy, Tracy, California.
DHS comments and recommendations of the Phase II Work Plans for the RI/FS.
Draft Letter Report Task 8, Sampling and Analysis of Private Wells, Defense Depot Tracy.
Work Plans, Remedial Investigation/Feasibility Study, Defense Depot Tracy.
Cost estimate for sampling and analysis of the Raspo Well 3AG.
Letter transmitting the Work Plans for the RI/FS.
Response to WCC letters dated 31 March 1987 and 3 April 1987.
Notification that Well #12 will be tested again to verify the finding of the first test.
Letter transmitting the well log for the irrigation well located approximately 300 feet north of
DDTC's northern boundary.
Letter transmitting the well log for the irrigation well located approximately 300 feet north of
DDTC's northern boundary.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
87/04/17
87/04/19
87/04/22
87/04/22
87/04/23
87/04/30
87/05/13
87/05/20
87/06/13
87/07/10
87/07/13
87/07/20
the RI/FS.
87/07/21
87/07/31
87/08/10
Author
DDTC-W
WCC
DDTC-W
DHS
DHS
CoE
DHS
DDTC-W
WCC
DDTC-G
RWQCB
WCC

WCC
DDTC-W
DDTC-W
Addressee
DHS
CoE
DLA-WS
DDTC-W
DDTC-WB
WCC
DDTC-J
DHS
DDTC
DDTC-D
RWQCB
CoE

CoE
WCC
SJCHD
87/08/19
RWQCB
DDTC-W
87/08/26
87/09/29
87/10/14
87/10/19
87/10/21
87/10/29
87/11/20
88/02/01
88/03/10
88/03/17
88/03/28
88/04/01
88/04/04
88/04/04
88/04/04
RWQCB
WCC
DHS
RWQCB
CoE
WCC
DDTC-W
WCC
WCC
DLA-WS
WCC
EGOS, Inc.
DDTC-W
DDTC-W
DDTC-W
DDTC-W
CoE
DDTC-WB
DDTC-W
DDTC-WB
WCC
RWQCB
DDTC
CoE
DDTC-W
CoE
DDTC
SJLHD
DHS
RWQCB
Subject
Notification that Well #12 shall be tested again to verify the finding of the first test.
Letter submitting Addendum No. 2 to the work plans for Tasks 30 and 32.
Reguest for funds to exercise options and Huntsville Division support for the RI/FS.
Letter confirming staff approval of the placement of 10 groundwater monitoring wells.
Underground storage tank closure plan, notice of deficiencies.
CoE review comments on the RI/FS letter reports and work plans.
Letter approving the reguest for a change in the classification of core material extracted during
the construction of off base groundwater monitoring well.
Addendum to the tank closure plan.
Letter Report Number 2,DDTC
Letter regarding the damages arising from exercise of right-of-way to Mr. Frank J. Raspo's property.
Minutes of 7 July 1987 meeting held at DDTC.
Letter forwarding 4 copies of Draft Work Plans for the Part 2 field work to be performed as part of

Minutes of the Project Review Meeting at DDTC held 7 July 1987.
Letter transmitting DHS' letter regarding material reclassification.
Notification that DDTC will comply with reguest to provide all analytical results, geotechnical data
and site assessment inform.
Minutes for Waste Discharge Reguirements and Groundwater Progress Review Meeting held on 7 July
1987.
RWQCB comments on the work plan for the remedial investigation.
Letter forwarding an addendum to the proposed Part 2 Work Plan.
Notice that the closure plan has adeguately addressed all of the issues needed to ensure the proper
closure of the unit.
RWQCB comments on the groundwater RI/FS.
Reguest for funds to contract for an aguifer pump test in Contaminated Area 2.
Summary of the chemical analysis data from the 48 soil borings identified as SB31 and SB52 that were
drilled and sampled from 17-20 August 1987.
DDRW addressing RWQCB's concerns regarding the groundwater RI/FS.
Letter Report Number 3, DDTC
Minutes from Progress Review Meeting Two on the Defense Depot Tracy RI/FS project.
State of California involvement in interagency agreements for clean up of hazardous waste sites.
Letter advising DDRW the drilling subcontractor for performing soil boring and sampling work within
the Southern Pacific Railroad right of way is Exceltech, Inc.
Tank Closure Report for Buildings 28 and 247, Underground Storage Tanks at DDTC.
Letter forwarding the proposed work plans for additional well sampling and soil borings.
Letter forwarding the proposed work plans for additional well sampling and soil borings.
Letter forwarding the proposed work plans for additional well sampling and soil borings.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
88/04/18
88/04/18
32.
88/04/21
88/04/29
88/05/19
88/05/27
88/05/27
88/06/10
88/06/17

88/06/20
88/06/22
88/06/23
88/07/19
88/08/15
88/08/23
88/08/24
88/09/07
88/09/13
88/09/22
88/09/22
88/10/17
88/10/20
Author
SJLHD
WCC

WCC
WCC
DDTC-W
DDTC-W
RWQCB
DDTC-W
Canonie
Environmental
WCC
WCC
WCC
DDTC-W
RWQCB
WCC
DHS
WCC
WCC
DDTC-WB
DDTC-WB
DHS
RWQCB
Addressee
DDTC-WB
CoE

SPTC
DDTC
CoE
CoE
DDTC-D
CoE
DDTC

CoE
CoE
DDTC
RWQCB
RWQCB
CoE
DDTC-W
DDTC
CoE
EPA
DHS
DDTC-D
DDTC-D
88/11/01

88/11/28
88/11/28

88/11/29
88/11/29
88/12/05
WCC

Kleinfelder
Raymond Vail 6
Assoc.
DDTC-W
DDTC-W
Canonie
Environmental
CoE

DDTC
DDTC

DHS
RWQCB
Professional
Consultants, Inc
Subject
Review comments by SJLHD on Phase II of the rank removal closure plan.
Letter transmitting four copies of the proposed Addendum No. 1 to the work plans for Tasks 30 and

Letter submitting Contractors Right of Entry Forms, Exhibit A, and Certificate of Insurance.
Draft Remedial Investigation Engineering Report, DDTC
DDTC comments on the Remedial Investigation/Feasibility Study.
DDTC comments on the Draft Remedial Investigation Engineering Report.
Letter requesting that DDTC continue with the groundwater investigation immediately.
Letter forwarding RWQCB's comments on the RI/FS groundwater project.
Point Source Sampling Investigation.

WCC recommending that both Options 11 and 12 be exercised at this time, for a total of 22 new wells
to be installed.
Summarization of the status of efforts to obtain approval from the Southern Pacific to drill soil
borings within its right of way adjacent to DDTC.
Letter Report Number 4, DDTC
Letter transmitting a copy of Letter Report Number 4, which summarizes the last laboratory analysis
from 63 monitoring wells associated with the RI of groundwater and soil.
RWQCB review comments for the Groundwater Remedial investigation.
Letter transmitting notes summarizing the discussions and conclusions from Progress Review Meeting
Three on the RI/FS project.
Review comments on the proposed off-site well installation.
Work Plan Section 11.0, Additional Groundwater Monitoring Wells, DDTC
WCC proposed comments to the comments submitted by RWQCB.
Request for comments on the closure plan for the underground storage tanks.
Request for comments on the closure plan for the underground storage tanks.
Contract stipulations for the RI/FS does not allow sufficient flexibility for changing situations.
Letter recommending that the final contract contain provisions for maintaining flexibility in the
RI/FS process.
Comments and discussion in response to RWQCB and DHS letters regarding the remedial investigations
currently underway at DDTC.
Soil Sampling Investigation, DDTC
Preliminary Submittal, Proposed Improvements for Evaporation Ponds, 1, 2, and 3, and Various
Sanitary Conveyance Facilities.
Response to letters from RWQCB and DHS.
Response to letters from RWQCB and DHS.
Detection limits of the samples taken on 5 April 1988.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
88/12/05
88/12/12

88/12/13
88/12/13
88/12/23
89/01/10
89/01/10
89/01/23

89/01/26
89/01/30
89/02/24
89/02/24
89/02/27

89/03/01
89/03/09
89/03/24
89/04/07
89/04/07
89/04/10

89/04/11

89/04/11
89/04/25

89/04/25
89/04/28
89/04/28
89/05/11

89/05/12

89/05/15
Author
WCC
RMS Prof. Consults,
Inc.
DDTC-WB CoE,
WCC
WCC
DDTC-WB
ERG CoE,
DHS
DDTC-WB
ERG CoE,
DDTC-WB
DDTC-WB
CoE
ERG EESC
WCC
ERG CoE,
RWQCB
WCC
DDTC-WB
Addressee
CoE
PVER, Inc.

Huntsville
CoE
DDTC
CoE
Huntsville
DDTC-WB
DHS
Huntsville
DHS
RWQCB
WCC
DDTC
DDTC
Huntsville
RWQCB
DDTC
CoE
RWQCB

RWQCB
CoE

DDTC-WB
ERG EESC
ERG EESC
ERG EESC

DHS

DDTC-WB
DDTC-WB

DDTC-WB
WCC

CoE
DDTC
DDTC
DDTC

DDTC-WB

RWQCB
Subject
Fact sheet delineating the content of each RI/FS report deliverable.
Transmittal of contract prints of the photos of the fuel tank excavation.

Comments on the Statement of Work for the aquifer pump test.
Submission of a revised Fact Sheet which describes DDTC's report deliverables.
Phase I Remedial Investigation Report, DDTC
Review comments for the Draft Phase I Remedial Investigation Report.
Preliminary Draft Work Plan Aguifer Pump Test Defense Depot Tracy
Reguest for additional information to complete closure certification report for underground waste
storage tanks at Building 247 and Warehouse 28.
Additional information necessary to meet State Underground Tank Closure reguirements.
Draft Work Plan Aguifer Pump Test Defense Depot Tracy
Copy of the draft Work Plan for the Aguifer Pump Test.
Copy of the draft Work Plan for the Aguifer Pump Test.
Reguest for WCC to incorporate review comments in the Phase II Remedial Investigation/Feasibility
Study (RI/FS).
Work Plan, Aguifer Pump Test, DDTC
Data Analysis Supporting Task 36 Well Locations for DDTC
Draft Aguifer Pump Test Engineering Report, Defense Depot Tracy
Comments for Phase I Remedial Investigation report.
Technical Submittal of Task 28 - Part 1, Groundwater Sampling and Analysis for DDTC.
Reguest the development of a delivery order contract for the installation, operation, and
maintenance of a remediation system to mitigate groundwater contamination.
RWQCB's comments to the Phase I Remedial Investigation Report and Data Analysis Supporting Task 36
Well Locations.
Draft DHS comments on the geology and well placement.
CoE comments and reguest that Phase I of the RI/FS be revised to include more analysis and
correlation of the field data.
Reguest the development of a delivery order contract for a supplemental study to the existing RI/FS.
Aguifer Pump Test Engineering Report, DDTC
Evaluation of Groundwater Withdrawal and Treatment, DDTC.
Section C, Description/Specification/Work Statement Data Items DD 1423 and DD 1664, Interim Remedial
Measure, Defense Depot Tracy, California
Comments to the Phase I Draft Remedial Investigation report and the Data Analysis Task 36 Well
Locations Report.
Status report on the RI/FS project.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
89/05/16

89/05/16
89/05/16
89/05/26
89/06/06

89/06/26
89/07/03
89/07/05
Author
DDTC-WB

ERG EESC
ERG EESC
CoE
DDTC-WB

RWQCB
WCC
DDTC
89/07/10
89/07/10
89/07/19
89/07/19
89/07/20
DHS

RWQCB
WCC
DDTC-WB
89/07/25 CoE, Huntsville
89/07/28

89/07/28
89/08/09
89/08/18
89/09/05
89/09/05
89/11/20
90/01/15
90/01/15
90/01/23
90/01/24
CoE

CoE
DDTC-W
DHS
DDTC-W
DDTC-W
Ensotech, Inc.
Ensotech, Inc.
Ensotech, Inc.
Ensotech, Inc.
AEPCO
90/01/24 DDTC-WB
90/01/25 Ensotech, Inc.
90/01/25 Ensotech, Inc.

90/02/06 DDTC-WB
90/02/21 Ensotech, Inc.
Addressee Subject
RWQCB Request for comments on the Aquifer Pump Test Report; Evaluation of Groundwater Withdrawal and
Treatment, FS; Environmental Assessment; ROD; and Work Statement for IRM.
DDTC Environmental Assessment, Interim Groundwater Remediation System, Defense Depot Tracy, California
DDTC Record of Decision - Interim qroundwater Remediation System - Defense Depot Tracy, California
DDRW-WB Draft scope of work for the Supplemental Study to the RI/FS.
CoE DDTC-WB's response to telefax of 25 May 1989 (Industrial Process Assessment and Process Alternatives
Evaluation).
DDTC-W RWQCB comments on the RI/FS Enqineerinq Report, Volume I.
DDTC Draft RI/FS Enqineerinq Report DDTC.
Neqative Declaration for Interim Remediation System (Air Stripper) for Groundwater Treatment, US
Defense Loqistics Aqency, Defense Depot Tracy, Tracy, California
DDTC-WB Comments on the proposed Interim Remedial Measure (IRM).
Contract DACA87-89-R-0099, Interim Groundwater Withdrawal, Treatment and Disposal System
DDTC-WB RWQCB's comments on the Statement of Work for the Interim Groundwater System.
DDTC Work Plan, Section 13.0, Additional Groundwater Monitorinq Wells for DDTC
RWQCB Submittal of analysis on the sanitary and industrial seweraqe system.
Solicitation/Modification of Contract for Interim Groundwater Withdrawal Treatment and Disposal
System
WCC Request that the disposition of the comments be in separate correspondence and the incorporation of
the chanqes in the final feasibility study.
WCC CoE's comments on the RI/FS to WCC.
CoE DDTC review comments to the RI/FS contract modification.
DDTC-WB DHS comments on the Interim Groundwater Withdrawal, Treatment, and Disposal System.
EPA Letter proposinq that DDTC be deleted from further consideration as an NPL site.
EPA Letter proposinq that DDTC be deleted from further consideration as an NPL site.
DDTC Permit for Drillinq 18 Wells at DDTC
DDTC Safety, Health, and Emerqency Response Plan (Draft) for DDTC
DDTC Site Specific Safety Plan, Groundwater Remediation (Draft) for DDTC
DDTC Preliminary Draft Groundwater Model Report
CEHND Draft Investiqation Plan Industrial Process System Assessment & Process Alternatives Evaluation at
Defense Depot Tracy
CoE Request for review of the abandoned well sites.
DDTC Permits Status Report for Interim Groundwater Remediation at DDTC
DDTC Equipment Submittal Data (Draft) for Interim Groundwater Remediation at Tracy Defense Depot, San
Joaquin County, California
CoE DDTC's comments on the documents from Ensotech, Inc.
DDTC Rationale for Monitorinq Well Placement at DDTC.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
90/02/22
90/02/22
90/02/28
90/02/28
90/03/02
90/03/08
90/03/22
90/03/24
90/04/01
90/04/04
90/04/05
90/04/06
90/04/18
90/05/04
90/05/04
90/05/10
90/05/17
90/05/25
90/05/25
90/05/31
90/05/31
SSTC-WB
Ensotech, Inc.
CoE
CoE
DDTC-WB
Ensotech, Inc.
Ensotech, Inc.
Ensotech, Inc.
DDRW
DDTC-WB
Ensotech, Inc.
DDTC-WB
DHS
DDTC-WB
DDTC-WB
CoE
Aepco, Inc.
DDTC-WB
DDTC-WB
DDTC-WB
DDTC-WB
CoE
DDTC
AEPCO, Inc.
Ensotech, Inc
CoE
DDTC
DDTC
DDTC

RWQCB
DDTC
CoE
DHS
RWQCB
DHS
AEPCO, Inc.
DDTC
RWQCB
DHS
DHS
DHS
90/06/08

90/06/15
90/06/15
90/06/26
90/07/02

90/07/10
90/07/12
90/07/16
DDTC-WB

Ensotech, Inc.
RWQCB
DDRW-WB
RWQCB

DDRW-DE
Ensotech, Inc.
DDRW-DE
CoE

DDTC
DDTC-WB
EPA
DDTC-WB

RWQCB
DDTC
CoE
Subject

DDTC's comments on the AEPCO, Inc., Draft Investigation Plan.
Addendum to Work Plan
COE comments on the DDTC Process Evaluation
CoE comments on the Groundwater Treatment System.
DDTC comments on the Addendum to Work Plan, interim Groundwater Withdrawal, Treatment, and
Disposal System and Rationale for Monitoring Well Placement Report.
Rev 1 Safety, Health, and Emergency Response Plan for Defense Depot Tracy
Preventative Maintenance Schedule for Interim Groundwater Remediation at DDTC
Preliminary Groundwater Model Report, DDTC
Interim Remedial Action Plan for DDTC
Copy of the Draft Investigation Plan Industrial Process System Assessment and Process
Alternatives Evaluations.
Topographic Site Survey for interim Groundwater Remedation at DDTC
DDTC comments on the Abandoned Water Well Evaluation Project.
Formal agreement between Region 1 Permitting and Site Mitigation for the Site Mitigation
Units (SMU) to oversee characterization and remediation activities.
Reguest for review and approval of the Solid Waste Management Units Investigation Plan.
Reguest for review and approval of the Solid Waste Management Units Investigation Plan.
CoE comments on the Point Source Evaluation Investigation Plan.
Final Investigation Plan (Rev 01) Industrial Process System Assessment and Process
Alternatives Defense Depot Tracy, California
Reguest review of WCC's Work Plan, Task 33, Soil Boring, and Task 37, Groundwater
Monitoring Wells.
Reguest review of WCC's Work Plan, Task 33, Soil Boring, and Task 37, Groundwater
Monitoring Wells.
Copy of the draft Scope of Work for the DDTC Well Monitoring Program.
Reguest review of the Abandoned Water Well Evaluation and Underground Storage Tank
Investigation and Study.
DDTC comments on the Statement of Work for the Abandoned Well Evaluation and Draft
Underground Storage Tank Investigation and Study
Final Safety, Health, and Emergency Response Plan for Defense Depot Tracy
RWQCB comments on the draft Scope of Work for the regular monitoring to tile RI/FS wells.
Letter submitting minutes for the Project Managers Meeting held 4-5 June 1991.
RWQCB comments on the proposed Statement of Work underground tank and abandoned waterwell
investigations.
Reguest review of the Solid Waste Management Unit RI/FS Statement of Work.
Design Calculations for Interim Groundwater Remediation at DDTC
Reguest CoE increase the sampling reguirements on a guarterly basis (Well Monitoring
Program).
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date Author

90/07/18 DDRW-DE
90/07/23 DDRW-DE
90/07/24 Ensotech, Inc.

90/07/24 RWQCB

90/08/01 DDRW-DE
90/08/01 DHS
90/08/01 DHS

90/08/01 Nakata Plan Grp, Inc.
90/08/02 CoE

90/08/07 DDRW-DE
90/08/07 DDRW-DE

90/08/09 DDRW-DE
90/08/14 CoE
90/08/31 RWQCB

90/09/27 CoE
90/09/27 COE

90/09/28 CoE

90/09/28 DDRW-DE
90/09/28 DDRW-DE
90/10/09 CoE
90/10/23 CoE

90/11/01 Golden West Builders
90/11/14 DDRW-DE

90/11/14 DDRW-DE

90/11/26 CoE

90/11/27 CoE
90/12/11 Ensotech, Inc.

90/12/13 DDRW-DE
Addressee

DHS
DHS
DDRW-WB

DDRW-DE

DHS
DDRW-DE
DDRW-DE

DDTC
Ensotech, Inc.

CoE
CoE

CoE
Ensotech, Inc.
DDRW-WB

WCC
Ensotech, Inc.

Ensotech, Inc.

CoE
DHS
DDRW-WB
Ensotech, Inc.

DDRW
RWQCB

DHS

Ensotech, Inc.

AEPCO, Inc.
DDTC

CoE
Subject

DHS comments on WCC's risk assessment portion of the RI/FS.
DHS comments on WCC's RI/FS risk assessment.
Notification that the air stripping tower will be shipped to the depot on 24 July
1990.
Notification that the Statement of Work for the remediation of the underground
storage tank site appeared satisfactory.
Copy of the internal audit on the monitoring well drilling operations.
DHS comments on the risk assessment of the draft RI/FS engineering report.
Acceptance of technical responses and submittal of a schedule for the Interim
Groundwater Treatment System.
Concept Development Report, DDTC
Letter notifying Enotech that the vapor control unit does not meet the terms of the
contract.
Comments from DHS on the RI/FS Study Risk Assessment.
Letter transmitting a copy of tile waste discharge reguirements for the IRM as
proposed by RWQCB.
Documents regarding the late revision for the IRM Waste Discharge Permit.
Notice of failure to comply with contract reguirements.
Letter approving the revised statement of work for the monitoring well sampling
program.
Change in laboratory, revised schedule, and internal audits for RI/FS.
Letter reguesting that the addendum to the "Authority to Construct" permit application
for the IRM be received by 22 August 1990.
CoE comments on the document submittals for the interim groundwater withdrawal,
treatment, and disposal system.
DDRW reguesting a response for a firm start date on the construction of the IRM.
Letter reguesting a response for a firm start date on the construction of the IRM.
CoE responding to DDRW-WB1s letter dated 28 September 1990.
CoE review comments on the permit application for construction of the air stripping
tower and vapor control unit.
DDRW Building 201 Contract/Scope of Work
Reguest review of the Draft Work Plan for Investigation of Solid Waste Management
Units and Work Plans for the Well Monitoring Program.
Reguest review of the Draft Work Plan for Investigation of Solid Waste Management
Units and Work Plans For tile Well
CoE comments on the document submittals for the interim groundwater for the interim
groundwater withdrawal, treatment, and disposal system.(cill,
Reguest disposition of comments and incorporation of changes in the final report.
Application for Authority to Construct and Permit to Operate Air Stripping Tower and
GAG Vapor Control Units to Cleanup TCE and PCE Contaminated Groundwater
Letter reguesting that Mr. Marshall Cloud he replaced as tile contracting officers
representative for the IRM.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
90/12/27
91/01/16
91/01/16
91/01/25
91/01/25
91/01/25
91/01/28
91/01/29
91/01/29
91/01/31
91/01/31
91/02/01
91/02/05
91/02/05
91/02/06
91/02/06
91/02/11
91/02/11
91/02/11
91/02/13
91/02/15
91/02/15
91/02/15
91/02/22
91/02/25
91/02/28
91/03/01
Author
DDRW-DE
CoE
CoE
RWQCB
RWQCB
RWQCB /DTSC
CoE
CoE
EPA
Aepco, Inc.
DHS
WCC
DDRW-WB
EPA
DDRW-DE
WCC
DDRW-WB
DDRW-WB
DDRW-WB
EPA
DDRW-WB
DDRW-WB
DDRW-WB
EPA
Ensotech, Inc.
DDRW-WB
DDRW-WB
Addressee
CoE
DDRW-DE
DDRW-WB
DDRW-DE
RWQCB
RWQCB/DTSC
WCC
DDRW-DE
DDRW-DE
DDRW
DDRW-DE
DDRW
CoE
CoE
DHS
DDRW
DHS
RWQCB
EPA
DDRW-WB
EPA
RWQCB
DHS
DDRW-WB
DDRW
EPA
DHS
Subject

DDRW comment to the Industrial Process System Assessment and Process Alternatives
Evaluation Final Investigation Plan.
Request for a technical report which documents the work completed under the COE
purchase order.
Letter recommending that DDRW request permission to proceed with the well monitoring
and solid waste management unit programs with regulatory comment.
Comments on the Solid Waste Management Unit and Well Monitoring Work Plans
Comments on the work plan for the Well Monitoring Program
Comments on the Work Plan for Well Monitoring Program.
CoE comments on the Preliminary Draft RI/FS Report.
Letter clarifying the relationship between the well monitoring program and monitoring
for the IRM.
EPA comments on the Draft Work Plan for Investigation for solid waste management
units.
Alternatives Evaluation/Implementation Report, Industrial Process System Assessment
and Process Alternatives Evaluation at DDRW, Tracy, California
Comments on the Draft Work Plans for the Solid Waste Management Units.
Final Work Plan for Investigation of Solid Waste Management Units at Defense
Distribution Region West, Tracy, California
CoE comments on the Preliminary Draft RI/FS Report.
EPA comments on the Work Plans for the Well Monitoring Program
Copy of Volume II of the Well Monitoring Plan.
Vol I and II, Work Plan for the Well Monitoring Program at Defense Distribution Region
West, Tracy
Copy of the final Alternatives Evaluation/Implementation Report.
Copy of the final Alternatives Evaluation/Implementation Report.
Copy of the final Alternatives Evaluation/Implementation Report.
EPA comments on the draft scope of work for UST Investigation and Study.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan for
Investigation of Solid Waste Management Units.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan for
Investigation of Solid Waste Management Units.
Copy of the Work Plan for the Well Monitoring Program and Final Work Plan for
Investigation of Solid Waste Management Units.
EPA comments on the draft scope of work for the Abandoned Waterwell Evaluation.
Geologic Well Logs (Draft) for Interim Groundwater Remediation at Tracy Defense Depot,
San Joaquin County, California
Copy of the Installation Assessment of Defense Depot Tracy and Pre-Survey Instructions
for Installation Assessment.
Two copies of the Draft RI/FS Report.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

91/03/01
91/03/01

91/03/11
91/03/12
91/03/15
91/03/18
91/03/25
91/03/29
91/04/01
91/04/02

91/04/05
91/04/01
91/05/06

91/05/17

91/05/22
91/05/23

91/05/27

91/05/29
91/05/29

91/05/29
91/05/31
91/06/04
91/06/10
91/06/19

91/06/21
91/06/24

91/06/27
91/07/05
91/07/09

91/07/11
91/07/18

91/07/18
Author

DDRW-WB
DDRW-WB

DDRW-WB
DDRW-WB
GWESBGC
EPA
DDRW-WB
CoE
DDRW-WB
Ensotech, Inc.

Ensotech, Inc.
DDRW-WB
RWQCB

Ensotech, Inc.

EPA
EPA

Ensotech, Inc.

DDRW-WB
DDRW-WB

DDRW-WB
DHS
Ensotech, Inc.
DDRW-WB
DDRW-WB

DDRW-WB
DDRW-WB

RWQCB
RWQCB
DDRW-WB

CoE
CoE

DDRW-WB
Addressee

EPA
CoE

ATSDR
EPA
DDRW
DDRW-WB
EPA
DTSC
CoE
DDRW

DDTC
CoE
DDRW-WB

DDRW

CoE
DDRW-WB

DDRW

CoE
RWQCB

CoE
DDRW-WB
DDRW
CoE
CoE

CoE
CoE

CoE
DDRW-WB
EPA

RWQCB
Ensotech, Inc.

EPA
Subject

Two copies of the RI/FS Report.
DDRW informing CoE of their difficulties with Ensotech, Inc., tile prime contractor
for the air stripper project.
Two copies of the Draft RI/FS Report.
Information submitted as requested by EPA's letter dated 28 February 1991.
Remediation Status Report, DDRW Building 201 Underground Tank Site Remediation
EPA comments on the Community Relations Plan.
DDRW response to EPA, RQWCB, and DHS comments regarding the Well Monitoring Program,
Solid Waste Management Units, and Abandoned Well Project and Underground Storage
Tanks.
Letter addressing comments received by DTSC, RWQCB, and EPA.
Copy of the signed Building 201 UST Contract.
Installation Data Report for Interim Groundwater Remediation at Tracy Defense Depot,
Tracy, California
Start-Up Schedule for Interim Groundwater Remediation at DDTC
DDRW comments on the Statement of Work for Building 201 soil treatment/disposal.
Letter indicating those wells which should be measured monthly for groundwater
elevations for a period of one year.
Report on Prove-Out of Interim Groundwater Remediation System at Tracy Defense Depot,
Tracy, California
EPA comments concerning the Draft RI/RS Report.
EPA input concerning the selection of monitoring wells to be used to measure monthly
groundwater levels.
Site Specific Quality Management Plan (SSQMP) for Interim Groundwater Treatment System
at Tracy Defense Depot, San Joaguin County, California
DDRW comments on the Installation Data Report for Groundwater Remediation.
Letter informing RWQCB of the intent to begin sampling for the well monitoring
program.
DDRW comments on the Installation Data Report.
DHS comments on the Draft RI/FS Report.
Drill Cuttings Disposal Report for Interim Groundwater Remediation System at DDTC
DDRW comments on the Prove-Out of Interim Groundwater Remediation System Report.
DDRW review comments for the Drill Cuttings disposal report and the Site Specific
Quality Management Plan.
DDRW notifying CoE of deficiencies in the construction of the IRM.
Notification of the existence of a Federal Facilities Agreement between the regulatory
agencies and DDRW.
RWQCB comments on the Statement of Work for the RI/FS Work Plan.
RWQCB comments on the RI/FS Report.
Letter notifying EPA of the intent to issue a press release which details the signing
of the FFA.
Letter presenting a proposed plan for completion of the RI/FS for OU-1.
Letter notifying the contractor of deficiencies in the installation of the interim
groundwater withdrawal and disposal system.
Letter submitting copies of the publication notices soliciting public comment on the
Federal Facility Agreement.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
91/07/19
91/07/22
91/07/24
91/07/29
91/07/30
91/07/31
91/08/02
91/08/09
91/08/09
91/08/09
91/08/13
91/08/15
91/08/19
91/08/19
91/08/20
91/08/21
91/08/21
91/08/21
91/08/23
91/08/23
91/08/23
91/08/24
91/08/26
91/08/26
91/08/26
91/08/26
91/08/29
DDRW-WB
EPA
EPA
CoE
DDRW-WB
RWQCB
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
EPA
DDRW-WB
DDRW-WB
EPA
DDRW-WB
DDRW-WB
EPA
DDRW-WB
DTSC
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
EPA
RWQCB
DDRW-WB
Addressee Subject

CoE DDRW comments for the Installation Data Report and the Prove-Out Report.
DDRW-WB Letter delineating the US EPA's concerns regarding the location of the proposed Subsistence Warehouse.
DDRW-WB EPA's response to DDRWs letters of 18 July 1991 and 22 July 1991.
DDRW-DE Letter proposing deadlines for the Federal Facility Agreement at DDRW.
CoE Reguest that monitoring wells 2F-89-25 and 2F-89-26 not be destroyed because of the location of several old
SWMUs in proximity to the new Subsistence Warehouse.
DDRW-WB Letter reguesting that DDRW investigate options and take actions to discontinue the use of the agricultural
supply wells and to replace the water supply for those well owners.
DDRW-WB RWQCB reguesting a 30-day extension for the review of the Draft Solid Waste Management Unit Engineering
Report.
RWQCB Letter proposing document delivery dates and a press release of the document deadlines.
EPA Letter proposing document delivery dates and a copy of the public notice to be published in the Tracy Press and
Stockton Record regarding
DHS Letter proposing primary document deadlines.
DDRW Draft Quarterly Groundwater Monitoring Program, May 1991, for the Well Monitoring Program at Defense
Distribution Region West, Tracy, California
DDRW-WB EPA's preliminary comments on the investigative effort at DDRW Tracy's Subsistence Warehouse.
EPA Letter informing EPA of the discovery of an old buried pit at the Subsistence Warehouse construction site.
DTSC Letter informing DTSC of the discovery of several old buried 55-gallon drums and numerous old burn pits in the
Subsistence Warehouse construction site.
DDRW-WB EPA comments on the proposed schedule for draft primary documents.
RWQCB Letter reguesting RWQCB's review and comment on the Draft Quarterly Groundwater Monitoring Report.
CoE DDRW review comments on the DDRW-Tracy Subsistence Warehouse Scope of Work (SOW) .
DDRW-WB EPA comments on the Scope of Work for the Subsistence Warehouse removal action.
CoE Correspondence regarding the funding for the replacement of the Raspo agricultural wells.
DDRW-WB DTSC comments of the SOW for the Subsistence Warehouse Construction Site.
DDRW-WB RWQCB comments on the Draft Investigation and Remediation Plan.
EPA DDRW reguesting EPA review the preliminary sampling results from the Subsistence Warehouse construction
site.
EPA DDRW reguesting permission to release stockpiled excavation soils for other construction purposes.
CoE Notification that DDRW is officially releasing the Subsistence Warehouse stockpiled soils from restriction.
DDRW-WB Letter agreeing with DDRW-WB's letter that the stockpiled soils from the Subsistence Warehouse do not

represent an imminent threat to human health and the environment.
DDRW-WB RWQCB comments on the Proposed Plan for the completion of the RI/FS for OU-1.
EPA Letter transmitting the SOW for the rapid characterization and cleanup of the Subsistence Warehouse
construction site.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
91/08/29
91/08/30
91/09/01
91/09/03
91/09/04
91/09/05
91/09/09
91/09/10
91/09/12
91/09/12
91/09/12
91/09/16
91/09/17
91/09/18
91/09/18
91/09/18
91/09/18
91/09/19
91/09/24
91/09/26
91/10/01
91/10/01
91/10/07
91/10/10
91/10/16
91/10/16
91/10/17
91/10/17
91/10/18
91/10/21
91/10/23
RWQCB
DDRW-WB
EPA
DDRW-WB
DDRW-WB
DDRW-WB
EPA
RWQCB
DDRW-WB
DDRW-WB
DTSC
CoE
DDRW-WB
CoE
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
CoE
DDRW
Unknown
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
EPA
DDRW-WB
Addressee

DDRW-WB
RWQCB

DDRW
CoE
DTSC
DLA-WE
DDRW-WB
DDRW-WB
RWQCB
Resident
DDRW-WB
Ensotech, Inc.
RWQCB
WCC
EPA
DTSC
CoE

CoE
DDRW-WB
DDRW-WB

DDRW-Tracy
CoE

CoE
DTSC
CoE
CoE
DTSC

DDRW-WB
DDRW-WB
EPA
Subject

RWQCB comments on the IRM Prove-Out Phase Reports.
Letter requesting the Raspo agricultural wells be made an agenda item for the upcoming project manager's
meeting.
Aerial Photographic Analysis of DDRW Tracy
DDRW review comments on the Quarterly Groundwater Monitoring Report.
DDRW's proposed schedule change for the draft primary documents.
An informational letter regarding the Subsistence Warehouse cleanup.
EPA comments on the Draft SWMU Engineering Report.
RWQCB comments on the Draft Solid Waste Management Unit Engineering Report.
DDRW's response to RWQCB letter dated 31 July 1991.
Response to documents requested during meeting held 5 September 1991.
DTSC comments on the Solid Waste Management Unit Engineering Report.
Approval to proceed with full-scale operation of the groundwater withdrawal, treatment, and disposal system.
Letter concerning the offsite contamination of crops and agricultural supply wells.
CoE comments to the Draft Quarterly Monitoring Report Number 1 for the Well Monitoring Program.
Notification that the public comment period for the FFA expired and DDRW had received no comments.
Letter regarding the public comment period for the Federal Facility Agreement.
Notification that the public comment period for the Federal Facility Agreement has expired and there were no
comments received.
DDRW review comments for Telic Engineering Corporation Draft Subsistence Warehouse Report.
DTSC comments on the prove-out reports for the groundwater treatment plant.
Letter regarding the excavation and testing at the Consolidated Subsistence Facility.
Final Defense Distribution Region West, Environmental Program, Community Relations Plan, 1991
Community Relations Plan
Request that CoE send the RWQCB and DTSC appropriate number of copies of all SOWs and reports for the
Building 201 site characterization.
DDRW notifying CoE off their concerns with the start-up of the air stripper by Ensotech, Inc.
Letter requesting, DTSC provide a list of all ARARs which might affect development of the Operable Unit One

Draft Feasibility Study.
DDRW notifying CoE of the IRM failure on 12 October 1991.
Letter responding to an inquiry regarding the Raspo property easement.
Letter notifying DTSC of all equipment failure which resulted in a spill of TCE/PCE contaminated water at the
IRM.
DTSC comments and recommendations regarding the RI/FS activities at DDRW Tracy
EPA comments on the Draft Quarterly Groundwater Monitoring (May 1991) Report.
Letter transmitting minutes of the Project Manager's Meeting held 10-11 October 1991.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date Author

91/10/24 DRW-WB
91/10/26 Telic Engineering,
Corporation
91/10/29 DDRW-WB

91/10/29 DDRW-WB

91/10/29 DDRW-WB
91/10/29 DTSC
91/10/30 WCC
91/10/31 WCC
91/11/01 DDRW-WB
91/11/01 IT Corp.
91/11/06 DDRW-WB
91/11/11 WCC
91/11/11 WCC
91/11/15 DDRW-WB
91/11/15 EPA
91/11/19 DDRW-WB
91/11/19 EPA

91/11/20 DDRW-WB
91/11/20 DDRW-WB
91/11/20 PHS, SJC

91/11/22 RWQCB

91/11/26 DTSC
91/11/26 EPA
91/11/27 DTSC

91/12/01 WCC
91/12/01 WCC
91/12/02 DTSC
Addressee Subject

CoE Letter transmitting photographs of the IRM during the time of the spill.
DDRW Project Summary Report, DDRW Tracy, subsistence Warehouse

Resident Letter reguesting permission to collect water samples from private wells which might be in the flow path of the
contaminants.
Resident Letter reguesting permission to collect water samples from private wells which might be in the flow path of the
contaminants.
DTSC Letter transmitting the Subsistence Warehouse Removal Action Summary Report for informational purposes.
DDRW-WB DTSC reguiring DDRW to prepare a report for regulatory review regarding the inadeguacies of the air stripper.
CoE Draft Letter Report (Response to Comments and Outline of Remaining Work) for the DDRW Tracy OU#1 RI/FS
CoE WCC's minutes for the Project Manager's Meeting held 10-11 October 1991.
CoE Notification that the air stripper now has all outside telephone line.
DDRW Soil Treatment/Disposal, Building 201, DDRW Tracy
EPA WCC's minutes from the Project Manager's meeting held 10-11 October 1991.
DDRW Quarterly Monitoring Report of May 1991 Sampling Round for Well Monitoring Program at DDRW Tracy
DDRW Quarterly Monitoring Report of August 1991 Sampling Round for Well Monitoring Program at DDRW Tracy
CoE Letter reguesting the IRM startup be rescheduled.
DDRW-WB EPA comments on the Draft Work Plan for Well Evaluation and Abandonment.
RWQCB Letter transmitting the minutes for the Project Manager's Meeting held on 14 November 1991.
DDRW-WB This letter documents EPA' s approval of the revised Federal Facility Agreement schedule submitted on 10
September 1991.
CoE DDRW reguesting that a cure notice be issued to the contractor because of its failure to operate the IRM.
Resident Letter transmitting the laboratory results for the water samples taken from his well on 6 and 14 November 1991.
DDRW-WB Letter expressing concerns relative to the recent confirmation of contamination in off-site domestic drinking
water wells.
DDRW-WB Reguest that DDRW Tracy submit a time schedule for development of a long term alternative water supply for
those domestic wells impacted by groundwater contamination.
DDRW-WR Recommendations regarding groundwater contamination at off-site residences near DDRW.
DDRW-WB EPA comments on the Draft Minutes of the Project Manager Meeting held 10-11 October 1991.
DDRW-WB DTSC recommending that DDRW provide an alternative drinking water supply to any resident impacted and
conduct an offsite well survey for a one-mile distance from DDRW.
DDRW Final Solid Waste Management Unit Engineering Report, DDRW, Tracy
DDRW Comprehensive RI/FS Work Plan, DDRW Tracy
DDRW-BE DTSC approving DDRW's reguest for all extension of the delivery date for the OU-1 Draft Final FS and
Proposed Plan.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
91/12/03
91/12/04
91/12/04
91/12/05
91/12/06
91/12/10
91/12/13
91/12/13
91/12/13
91/12/16
91/12/16
91/12/19
91/12/19
91/12/20
91/12/30
92/01/01
92/01/02
92/01/06
92/01/06
92/01/16
92/01/16
92/01/16
92/01/17
92/01/20
92/01/21
92/01/22
92/01/23
DDRW-WB
CoE
Ensotech, Inc.
CoE
EPA
DDRW-WB
DDRW-WB
DDRW-WB
EPA
DDRW-WB
RWQCB
DTSC
EPA
DDRW-WB
Ensotech, Inc.
IT Corp.
GWESBGC
DDRW-WB
DDRW-WB
CoE
DTSC
DTSC
DDRW-D
Ensotech, Inc.
EPA
EPA
EPA
Resident
DHS
DDRW
Ensotech, Inc
DDRW-WB
CoE
EPA
RWQCB
DDRW-WB
CoE
DDRW-WB
DDRW-WB
DDRW-WB
CoE
CoE
DDRW
DDRW
CoE
EPA
Ensotech, Inc
DDRW-WB
DDRW-WB
CoE
CoE
DDRW-WB
DDRW-WB
DDRW-WB
Subject

Letter transmitting the laboratory test results for the water samples taken from his well on 6 and 4 November 1991
Letter requesting concurrence regarding the use of bioremediation as the method of treatment for the soil from Building 201.
Monthly Operation Report, Interim Groundwater Remediation System, DDRW Tracy
Notice to discontinue work on the interim groundwater treatment system.
EPA review comments on EPA EMSL's aerial photography analyses.
DDRW review comments on the Telic Engineering Company's Project Summary Report for the Subsistence Warehouse construction project.
Notification that DDRW is providing bottled water to two residents near DDRW.
Notification that DDRW is providing bottled water to two residents near DDRW.
EPA comments on RI/FS for OU-1/
Letter requesting 2 copies of the Oracle Database User Instruction Manual and review the possibility of adding
sampling of all IRM wells to the existing contract.
RWQCB comments and concerns with the Draft Work Plan for Well Evaluation and Abandonment.
DTSC comments of the Draft Work Plan for Well Evaluation and Abandonment.
EPA review comments on the Draft Quarterly Monitoring Report of the August 1991 Sampling Round for the Well Monitoring Program.
DDRW comments on the Draft Work Plan for Well Evaluation and Abandonment.
Ensotech's response to CoE's letter dated 18 December 1991.
Remedial Action at Building 201, DDRW Tracy
Remediation Status Report, DDRW Building 201 Underground Tank Site Remediation
Letter directing the CoE, Huntsville Division, to proceed with the termination for default process on the IRM unit.
Letter informing EPA that bioremediation is the selected treatment method for diesel contaminated soils from the Building 201 site.
CoE notifying Ensotech of their failures to perform in accordance with the contract.
DTSC letter expressing concern regarding the expansion of DDRW Tracy's groundwater contamination.
Notification that the groundwater treatment system restoration report submitted was insufficient and requested
that the report be resubmitted.
Letter urging the CoE to default the interim remedial measure unit contractor because of their failure to get the system operational.
Ensotech's response to CoE's letter dated 19 December 1991.
Letter submitting a draft analysis of potential Federal ARARs for the RI/FS for OU-1.
Summary of the meeting of 16 December 1991 regarding chemicals of concern for OU-1 RI/FS.
EPA review comments on the Final May 1991 Quarterly Monitoring Report.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

92/01/24
92/01/24
92/01/30
92/01/30

92/01/30
92/01/31
92/02/01
92/02/01
92/02/05
92/02/05
92/02/06
92/02/10
92/02/13
92/02/19
92/02/20
92/02/24
92/02/28
92/02/28
92/02/28
92/02/28

92/03/01
92/03/05
92/03/05
92/03/06
92/03/09
92/03/11
92/03/11
92/03/12
92/03/12
92/03/12
92/03/12
Author
EPA
Resident
DDRW-WB
DDRW-WB

DDRW-WB
RWQCB
IT Corp.
WCC
DDRW-D
EPA
DDRW-WB
WCC
EPA
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WB
RWQCB
WCC
DDRW-WB
DDRW-D
EPA
Deputy Secretary,
Resources Agency
Ofe of Env Proj Rev
DDRW-WB
DDRW
DDRW
Resident
DDRW-WB
EPA
CoE
DDRW-WB
CoE
CoE
EPA
EPA
DTSC
DDRW-WB
DDRW
IT Corp.
DDRW-WB
DDRW-WB
WCC
WCC
DDRW-WB
USAMC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
Addressee Subject

Letter submitting guidance for the natural resource damage assessment.
Letter requesting status on the contamination located on his property.
Letter requesting EPA determine the necessity of performing a Natural Resources Damage Assessment at DDRW Tracy.
Letter requesting the Resources Agency determine the necessity of performing a Natural Resources Damage
Assessment at DDRW Tracy.
Letter requesting this office determine the necessity of performing a Natural Resources Damage Assessment at DDRW Tracy.
RWQCB comments for the work plan for Remedial Action at Building 201.
Treatment/Disposal Alternatives Report, Soil Treatment/Disposal for Building 201, DDRW Tracy
Final Work Plan for Well Evaluation and Abandonment at DDRW Tracy
Response to Mr. Raspo's letter dated 24 January 1992.
EPA comments on the Risk Assessment and the Overall RI/FS Work Plan.
Letter requesting an extension for submittal of the Draft RI Report for Operable Unit #1.
Letter requesting a 17 day extension of the deadline for the Third Quarterly Monitoring Report.
Letter approving DDRW's request for a 36-day extension on the Draft RI Report.
Request for a schedule extension for the Draft Abandoned Waterwell Evaluation Report.
Notification of the need to resample the five domestic wells sampled in December 1991.
Letter requesting an extension of the submittal date deadline for the Draft Abandoned Waterwell Evaluation Report.
Letter requesting 91 additional days for the Draft Abandoned Waterwell Evaluation Report.
Request for an additional 91 days to review the Draft Abandoned Waterwell Evaluation Report.
Letter transmitting information regarding ARARs for Operable Unit 1.
Quarterly Monitoring Report of the November 1991 Sampling Round for the Well Monitoring Program at
Defense Distribution Region West -
DDRW Technical Work Plan Remedial Action at Building 201, Defense Distribution Region West, Tracy, California
EPA Submittal of the minutes for the Project Manager's Meeting held 26-27 February 1992.
CoE DDRW comments for the Treatment/Disposal Alternatives Report Soil Treatment/Disposal for Building 201.
CoE Letter transmitting a tentative list of the 26 wells recommended for sampling and analysis.
CoE WCC minutes for the Project Manager's Meeting held 26-27 February 1992.
Residents Letter requesting permission to sample his private domestic well.
DLA Letter endorsing the request for the acquisition of agricultural land adjacent to DDRW.
Resident Letter requesting permission to sample his private domestic well.
Resident Letter requesting permission to sample his private domestic well.
Resident Letter requesting permission to sample his private domestic well.
Resident Letter requesting permission to sample his private domestic well.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
92/03/13
92/03/16
92/03/17
92/03/19
92/03/24
92/03/27
92/04/09
92/04/13
92/04/17
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/20
92/04/21
92/04/30
92/04/30
92/04/30
92/04/30
92/04/30
92/01/30
92/04/30
92/05/01
92/05/01
92/05/01
92/05/03
92/05/04
WCC
WCC
WCC
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WIEP
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DTSC
ESE, Inc.
IT Corporation
WCC
DDRW-WB
DDRW-WB
Addressee Subject

CoE Letter transmitting the final list of the 26 wells to be sampled and analyzed.
ETCC Notification of the intent to commence with the collection of groundwater samples from 26 on-site monitoring
wells, water supply wells, and off-site private wells.
ETCC Notification of the resampling of the five domestic wells initially samples on 30 December 1991.
DDRW-WB RWQCB review comments for the Final Work Plan for Well Evaluation and Abandonment.
CoE Letter addressing concerns of the Tracy Well Monitoring Well Delivery Order.
USDOI Letter submitting a copy of Ecological Risk Assessment section of the Draft Operable Unit 1 for information purposes.
EPA Letter transmitting the minutes from the telephone conference call that occurred on 23 March 1992.
EPA Letter transmitting WCC's minutes for the Project Manager's Meeting held 20 March 1992.
DLA-WS Response to AMCEN letter dated 11 March 1992 regarding the acguisition of agricultural land adjacent to DDRW.
Resident Letter requesting permission to collect a sample from their domestic water well.
Resident Letter requesting permission to collect a sample from his agricultural/domestic water wells.
Resident Letter requesting permission to collect a sample from his domestic water well.
Resident Letter requesting permission to collect a sample from his domestic water well.
Resident Letter requesting permission to collect a sample from his domestic water well.
Resident Letter requesting permission to collect a sample from her domestic water well.
Resident Letter requesting permission to collect a sample from his domestic water well.
Resident Letter requesting permission to collect a sample from his domestic water well.
CoE DDRW's review comments for the Site Wide RI/FS Work Plan.
EPA Letter requesting a seven day extension for the Draft Final Site Wide RI/FS Wolk Plan.
EPA Letter requesting an extension for the Draft Abandoned Waterwell Evaluation Report.
RWQCB Letter requesting an extension for the Draft Abandoned Waterwell, Evaluation Report.
DTSC Letter requesting an extension for the Draft Abandoned Waterwell Evaluation Report.
RWQCB Letter requesting a seven day extension of the document delivery date for the Draft Final Site Wide RI/FS Work Plan.
DTSC Letter requesting a seven day extension of the document delivery date for the Draft Final Site Wide RI/FS Work Plan.
DDRW-WB Letter providing concurrence with the Final Well Abandonment Work Plan.
DDRW Comprehensive Quality Assurance Plan
DDRW US Army Corps of Engineers, Contract DACA87-91-D-0010, Draft Site Investigation Report, Building 201,
Defense Distribution Region West
DDRW Draft Final Comprehensive RI/FS Work Plan, Defense Distribution Region West
EPA Submission of the Draft Site Investigation Report for regulatory review and comment.
DTSC Submission of the Draft Site Investigation Report for regulatory review and comment.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

92/05/04
92/05/05
92/05/05
92/05/05
92/05/06
92/05/09
92/05/22
92/06/01
92/06/08
92/06/08
92/06/08
92/06/09
92/06/09
92/06/09
92/06/09
92/06/09
92/06/17
92/06/25
92/06/25
92/06/25
92/06/26
92/06/26
92/06/26
92/06/26
92/06/26

92/06/29
92/06/29
92/06/29
92/06/29
92/06/29
Author

DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
RWQCB
DDRW-WB
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
WCC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB

DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
Addressee Subject

RWQCB Submission of the Draft Site Investigation Report for regulatory review and comment.
DTSC Letter transmitting the meeting minutes from the Project Manager's Meeting held 23-24 May 1992.
RWQCB Letter transmitting the minutes from the Project Manager's Meeting held 23-24 May 1992.
EPA Letter transmitting the minutes from the Project Manager's Meeting held 23-24 May 1992.
DDRW-BE RWQCB comments on the SOW for the IRM and Well Monitoring Program.
CoE DDRW review comments on the Draft Site Investigation 1 Report.
DDRW-WB Quarterly Monitoring Report of the February 1992 Sampling Round for the Well Monitoring Program
DDRW Draft Operable Unit No. 1 FS Report, DDRW-Tracy, California, Vol II
RWQCB DDRW's response to EPA comments on the Draft Final Site Wide RI/FS Work Plan.
EPA DDRW's response to EPA comments on the Draft Final Site Wide RI/FS Work Plan.
DTSC DDRW's response to EPA comments on the Draft Final Site Wide RI/FS Work Plan.
RWQCB Letter requesting an extension for the Site Wide Remedial Investigation/Feasibility Study Work Plan.
EPA Letter requesting an extension for the Site Wide Remedial Investigation/Feasibility Study Work Plan.
DTSC Letter requesting an extension for the Site Wide Remedial Investigation/Feasibility Study Work Plan.
CoE Letter requesting for review and comment of the Draft Operable Unit #1 Proposed Plan for DDRW Tracy.
CoE Defense Distribution Region West - Tracy, Proposed Plan for Contaminated Groundwater, Tracy, California, June 1992
CoE Letter expressing displeasure With the Draft Operable Unit One (OU-1) Proposed Plan prepared by Woodward-Clyde Consultants.
DTSC Letter agreeing with the regulatory agencies that the addendums to the Site Wide RI/FS Work Plan be made primary documents.
EPA Letter agreeing with the regulatory agencies that the addendums to the Site Wide RI/FS Work Plan be made
RWQCB Letter agreeing with the regulatory agencies that the addendums to the Site Wide RI/FS Work Plan be made primary documents.
DTSC Letter requesting that EPA rescind its insistence on PRGs at this time.
RWQCB Letter requesting that EPA rescind its insistence on PRGs at this time.
EPA Letter requesting that EPA rescind its insistence on PRGs at this time.
CoE DDRW directing CoE to withhold any further driller or field work progress payments on this project.
CoE Request that Solid Waste Management Unit (SWMU) #13 data be used in the Draft Final Site Wide RI/FS Work
Plan as agreed to during the Project Managers meeting,
CoE Minutes for the Project Manager's meeting of 15-16 June 1992.
RWQCB Minutes for the Project Manager's meeting of 15-16 June 1992.
DTSC Minutes for the Project Manager's meeting of 15-16 June 1992.
EPA Minutes for the Project Manager's meeting of 15-16 June 1992.
WCC Minutes for the Project Manager's meeting of 15-16 June 1992.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
92/06/30
92/07/01
92/07/07
92/07/07
92/07/07
92/07/07
92/07/07

92/07/31
92/07/31
92/07/31
92/07/31
92/08/06
92/08/24
92/08/24
92/08/27
92/08/27
92/08/27
92/08/28
92/08/31
92/08/31
92/08/31
92/09
92/09/02
92/09/04
DDRW-WB
WCC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB

DDRW-WB
DDRW-WB
DDRW-WB
EPA
EPA
DDRW-WB
PHS, SJC
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
Woodward-Clyde
DTSC
DDRW-WB
EPA
DDRW
BCID
ISWMB
WSID
DFG
City of Tracy,
Public Works Dept
EPA
RWQCB
DTSC
DDRW- BE
DDRW- BE
CoE
DDRW-WB
CoE
EPA
EPA
CoE
RWQCB
EPA
DTSC
CoE, Huntsville
DDRW- BE
RWQCB
92/09/04
DDRW-WB
DTSC
Subject

Letter transmitting the final report on the remediation effort at the Subsistence Warehouse construction site.
Final Analytical Data Submittal for Well Evaluation and Abandonment at Defense Distribution Region West, Tracy, California
Letter soliciting the identification of ARARS for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.
Letter soliciting the identification of ARARs for remediation of groundwater contamination.

Letter notifying the regulatory agencies how they intend to dispose of purge water and drill cuttings.
Letter notifying the regulatory agencies how they intend to dispose of purge water and drill cuttings.
Letter notifying the regulatory agencies how they intend to dispose of purge water and drill cuttings.
Letter confirming the date of the dispute resolution meeting.
Notification of resolution of the dispute invoked by EPA regarding the Draft Final Comprehensive RI/FS Work Plan.
DDRW comments on the Post Treatment/Disposal Report Soil Treatment/Disposal for Defense Distribution
Region West Tracy, California.
Letter regarding the investigation of off-site contamination of domestic wells.
DDRW review comments for the Operable Unit One Feasibility Study.
Resolution of dispute for DDRW Tracy Draft Final Comprehensive RI/FS Work Plan.
Letter transmitting the Treatment/Disposal Report Soil Treatment/Disposal for Defense Distribution Region
West (DDRW) Tracy, California.
Replacement of ruptured gas line during the initial well excavation effort.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance at DDRW Tracy.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance found at DDRW Tracy.
Letter notifying the regulatory agencies of the discovery of a tar-like petroleum based substance at DDRW Tracy.
Final Comprehensive RI/FS Work Plan.
Letter notifying DDRW that DTSC considers the dispute to be resolved and the Draft Final RI/FS Work Plan to be approved.
Letter submitting a location map and laboratory results of the substance found in the new water line trench
adjacent to the Subsistence Warehouse.
Letter submitting a location map and laboratory results of the substance found in the new water line trench
adjacent the Subsistence Warehouse.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

92/09/04

92/09/08

92/09/10
92/09/10
92/09/10
92/09/10
92/09/11
92/09/18
92/09/18
92/09/18
92/09/22
92/10/01
92/10/01
92/10/01
92/10/01
92/10/02
92/10/02
92/10/02
92/10/09
92/10/09
92/10/09
92/10/09
92/10/09
92/10/09
92/10/15
92/10/16

92/10/26
92/10/28
92/10/28
Author

DDRW-WB

Senator Johnston

DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
RWQCB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
DDRW-WB
WCC
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DTSC
DDRW-BE
RWQCB

DDRW-BE EPA
DDRW-BE
DDRW-BE
Addressee Subject

EPA Letter submitting a location map and laboratory results of the substance found in the new water line trench
adjacent to the Subsistence Warehouse.
DDRW-D Letter urging DDRW to survey wells within a mile radius including sampling of identified wells along Banta
Road, and schedule a community awareness forum.
CoE Letter forwarding the minutes for the Project Manager's Meeting held 22-23 July 1992.
RWQCB Letter forwarding the minutes for the Project Manager's Meeting held 22-23 July 1992.
DTSC Letter forwarding the minutes for the Project Manager's Meeting held 22-23 July 1992.
EPA Letter forwarding the minutes for the Project Manager's Meeting held 22-23 July 1992.
DDRW-BE RWQCB comments on the Draft Engineering Report for the Well Monitoring Program.
EPA Letter reguesting an extension of the delivery date for the Site-Wide RI/FS.
DTSC Letter reguesting an extension of the delivery date for the Site-Wide RI/FS.
RWQCB Letter reguesting an extension of the delivery date for the Site-Wide RI/FS.
CoE DDRW comments on the Draft Final OU-1 RI/RA.
EPA Submission of the revised Federal Facilities Agreement schedule for review/approval.
DTSC Submission of the revised Federal Facilities Agreement schedule for review/approval.
RWQCB Submission of the revised Federal Facilities Agreement schedule for review/approval.
DDRW Draft Final Operable Unit No. 1 FS Report, DDRW-Tracy, California
RWQCB Letter transmitting the final minutes for the Project Managers meetings of 15-16 June and 22-23 July 1992.
EPA Letter transmitting the final minutes for the Project Managers meetings of 15-16 June and 22-23 July 1992.
DTSC Letter transmitting the final minutes for the Project Managers meetings of 15-16 June and 22-23 July 1992.
CoE DDRW comments on the Operable Unit #1 and Proposed Plan Draft Final.
DTSC Notification that DDRW is prepared to begin spreading the remaining soil from the Subsistence Warehouse on the DDRW Tracy Facility.
RWQCB Notification that DDRW is prepared to begin spreading the remaining soil from the Subsistence Warehouse on the DDRW Tracy Facility.
EPA Notification that DDRW is prepared to begin spreading the remaining soil from the Subsistence Warehouse on the DDRW Tracy Facility.
CoE Letter reguesting that CoE exercise Option 5 (reclassify the soil stockpile) of the Site Investigation Report.
DDRW-BE DTSC's review of detection limits for the Site Wide RI/FS Work Plan found no reportable anomalies other than those previously identified.
CoE DDRW comments for the Final Analytical Data Report for Well Abandonment.
DDRW-BE Letter reguesting that DDRW Tracy provide a time schedule and work plan for discontinuing well use and
conducting an alternative water supply evaluation.
CoE Letter reguesting that San Joaguin County Public Health Services be added to the document distribution list.
CoE Letter reguesting CoE adds wells LM-112 and LM-113 to the well monitoring/RI/FS work effort.
EPA Minutes for the Project Managers Meetings held 14 Oct. 92.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

92/11/01
92/11/01
92/11/01
92/11/04
92/10/10
92/11/12
92/11/12
92/11/16
92/11/19
92/11/23
92/11/23
92/11/24
92/11/30
92/11/30

92/12/01
92/12/02
92/12/02
92/12/02
92/12/02
92/12/03
92/12/04

92/12/04

92/12/07
92/12/08
92/12/10
92/12/10
Author Addressee Subject

IT Corp. DDRW Post Treatment/Disposal Report Soil Treatment/Disposal for Defense Distribution Region West, Tracy, California
WCC DDRW Final Operable Unit No. 11 RI/RA Report, DDRW-Tracy
WCC DDRW Final Well Evaluation and Abandonment Engineering Report, Defense Distribution Region West, Tracy, California
DDRW-BE EPA Submission of the revised FFA deadlines for the DDRW Tracy Facility IRP documents.
DDRW-BE EPA Letter reguesting a 30 day delivery date extension to the finalization period of the Draft final FS and Proposed Plan for OU-1.
PHS,SJC DDRW-D Public Health Services comments to DDRW Tracy's letter dated 14 September 1992.
RWQCB DDRW-BE RWQCB comments on the Draft Final Feasibility Study Report and Proposed Plan for Operable Unit No. 1.
RWQCB TEPC Letter reguesting premise access to monitoring wells to measure groundwater levels and to collect and analyze water guality samples.
EPA DDRW-BE EPA comments on the Proposed revisions to the FFA schedule.
EPA DDRW-BE EPA comments on minutes of meetings of October 14-15, 1992.
RWQCB DTSC RWQCB comments on DTSC's 22 Oct 92 review of the Draft Final Well Evaluation and Abandonment Engineering Report for DDRW Tracy.
DDRW-BE EPA DDRW reguesting a position statement from EPA regarding the inclusion of PHS/EHD in the CERCLA process.
DDRW-BE RWQCB Letter submitting a time line for the accomplishment of the abandonment of the off-site agricultural wells.
DDRW-BE EPA DDRW Tracy reguesting an additional 10-day delivery date extension of the finalization period of the Draft
Final Proposed Plan and Feasibility Study for OU-1.
DDRW Proposed Plan for Contaminated Groundwater Remedation of Operable Unit No. 1 at Defense Distribution Region West-Tracy
DTSC DDRW-BE DTSC approving DDRW's reguest for an extension of the delivery date for the OU-1 Draft Final FS and Proposed Plan
DTSC DDRW-BE DTSC approving the proposed changes in the FFA schedule.
EPA DDRW-BE EPA comments on the Comprehensive RI/FS Risk Assessment Statement of Work.
RWQCB DDRW-BE Letter submitting the well sample results for turbidity at DDRW Tracy.
EPA DDRW-BE EPA Comments on the ARARs Tables for the Draft Final FS for OU-1
EPA DDRW-BE EPA's position on the reguest of the San Joaguin County Public Health Services/Environmental Health Division
to be included in the CERCLA process at DDRW-Tracy
EPA DDRW-BE EPA concurring with DDRW Tracy's reguest for an extension for revision/review of the Draft Final Feasibility
Study for Operable Unit No. 1.
DDRW-BE EPA DDRW reguesting review of the revised FFA schedule for DDRW Tracy.
DDRW-BE RWQCB Letter submitting the daily stratup/proveout reports for the Tracy IRM for the period of November 5-14, 1992.
DDRW-BE PHS DDRW's response to a letter from Public Health Services dated November 12, 1992.
PSR,Corp DDRW Transcript for DDRW Tracy Facility Community Meeting to Establish the Technical Review Committee (TRC)
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date Author Addressee Subject

92/12/14 DDRW-BE CoE Letter submitting the test results from the RWQCB for the well monitoring program they are conducting at DDRW Tracy.
92/12/16 RWQCB DDRW-BE Letter submitting an inspection report and a memorandum on stockpiled soils from the Subsistence Warehouse.
92/12/17 DDRW-BE EPA Letter transmitting the final minutes for the Project Managers meeting held 14-15 October 1992.
92/12/24 EPA DDRW-BE Letter recommending an extension to the finalization process of the FFA schedule from 30 to 45 days.
93/01/01 JMM DDRW Final Groundwater Pilot Chemical Data Acguisition Plan
93/01/04 JMM EPA Minutes from the telephone conference (17 December 1992) on evaluation of detection limits for the
Comprehensive Phase 1 Remedial Investigation.
WCC DDRW Tracy furnishing WCC with a copy of the Proposal Plan Fact Sheet for the DDRW Tracy Operable Unit #1 Feasibility Study/Proposed Plan.
EPA DDRW providing EPA with a list of the wells and sampling methods to be used for the upcoming sampling round.
RWQCB DDRW reguesting a variance to the Monitoring and Reporting Section of the Waste Discharge Reguirement.
EPA DDRW resubmitting a revised Federal Facilities Agreement Schedule for review and comment.
EPA DDRW providing the regulatory agencies with a copy of the transcript for the public meeting held on 19 December 1992.
DDRW-BE DTSC confirming the agreements reached during a tele-conference held November 19, 1992.
DDRW Transcript for DDRW Tracy Facility Community Meeting for the Operable Unit No. 1 Feasibility Study/Proposed Plan
DDRW-BE Letter reguesting DDRW complete a Report of Waste Discharge for the disposal of the treated groundwater from OU-1 by 15 Mar. 93.
DDRW-BE Letter concurring with the revised Federal Agreement schedule.
SJVUAPCD Letter reguesting approval of its Application for Permit to Construct for the Tracy Facility air stripper.
DDRW-BE EPA comments on the Risk Assessment and the Comprehensive RI/FS Work Plan.
CoE Letter reguesting CoE expedite the removal of the Subsistence Warehouse soil pile from the DDRW Tracy Facility.
DDRW-BE Letter addressing the Proposed Plan for Contaminated Groundwater Remediation of Operable Unit No. 1 at Defense Distribution
Region West - Tracy.
93/01/30 WCC DDRW Final Engineering Report for the Well Monitoring Program at Defense Distribution Region West - Tracy, Tracy, California
93/02/01 JMM DDRW Final Well Monitoring Program Quarterly Monitoring Report - September 1992 Sampling Round
93/02/02 DDRW-BE SJFBF DDRW1 s response to the San Joaguin Farm Bureau Federation's letter dated January 28, 1993.
93/02/02 DDRW-BE EPA Minutes for the Project Manager's meeting held January 13-14, 1993.
93/02/02 RWQCB DDRW-BE Notification that James Taylor will replace Camilla Williams as Project Manager for the DDRW Tracy project.
93/02/04 DDRW-BE EPA Minutes for the Project Manager's meeting held December 10, 19992.
93/02/04 JMM DDRW Groundwater Treatment Pilot Plant Monthly Operations Reports.
93/01/11
92/01/11
93/01/11
93/01/11
93/01/12
93/01/12
93/01/14
93/01/17
93/01/19
93/01/25
93/01/27
93/01/28
93/01/28
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DTSC
PSR,Corp
RWQCB
EPA
DDRW-BE
EPA
DDRW-BE
SJFBF
-------
Administrative Record File Index - DDJC Tracy (Continued)
93/02/08
93/02/11
93/02/22
93/02/23
93/03/03
93/03/08
93/03/12
93/03/17
93/03/26
93/03/29
93/03/29
93/03/29
DDRW-BE
SWRCB
DDRW-BE
DDRW-BE
DDRW-BE
EPA
RWQCB
EPA
RWQCB
DDRW-BE
RWQCB
RWQCB
Date Author Addressee Subject

CoE DDRW Requesting CoE direct Woodward-Clyde Consultants review the ARARs for DDRW Tracy Operable Unit No. 1, for specificity.
DDRW-D Notification that the DDRW Tracy Facility Operable Unit No. 1 Feasibility Study/Proposed Plan is acceptable.
EPA Letter transmitting final minutes for the project Managers' meetings held on December 10, 1992 and January 13-14, 1993.
CoE Letter requesting that CoE contact JMM and ensure that specific changes be made to the well monitoring numbering system.
CoE DDRW requesting CoE direct MW to institute a numbering sequence for all air stripper extraction wells.
DDRW-BE EPA providing DDRW with an updated copy of the Draft Preliminary Remediation Goals Table.
DDRW-BE Letter addressing disposal of stockpiled soil excavated from the foundation of the Subsistence Warehouse.
DDRW-BE Letter submitting contour maps based on MW's September 1992 quarterly monitoring round ay DDRW Tracy.
DDRW-BE RWQCB comments on the list of wells and sampling methods to be used in the spring 1993 quarterly groundwater monitoring round.
CoE Letter transmitting a copy of the waste discharge requirements for H.J. Heinz for information purposes.
DDRW-BE RWQCB clarifying their person on the proposed rehabilitation program for the IRM system at DDRW Tracy.
DDRW-BE Letter requesting DDRW complete a Report of Waste Discharge for the disposal of the treated groundwater from
OU-1 in order to receive Waste Discharge Requirements.
Final Groundwater Treatment Pilot Plan System Start-up and Prove-out Report
Letter transmitting minutes from the Technical Review Committee (TRC) meeting held 23 March 1993.
Letter transmitting a soil survey of San Joaquin County for use in the Comprehensive Site Wide RI/FS.
DTSC recommending that the Final Engineering Report for the Well Monitoring Program be discussed at the April Project Managers' meeting.
Notification of approval of Operable Unit No. 1 Feasibility Study.
DDRW requesting CoE prepare sections 2.1.6 and 2.1.7 for the Report of Waste Discharge.
EPA's comments on the Draft Work Plan Amendments for Phase 1 of the Comprehensive RI/FS.
RWQCB Comments on the Draft Comprehensive RI/FS Work Plan Amendments and evaluation of detection
limits for the Comprehensive Phase 1 Remedial Investigation.
93/04/12 TRC Member DDRW-BE Letter submitting comments on the TRC minutes.
93/04/13 DDRW-BE MW DDRW providing MW with copies of DDRW Tracy Facility's Project Managers' meeting minutes for the period
October 10, 1991 through January 14, 1993.
93/04/14 Enscco DDRW Analytical Services Quality Assurance Project Plan for the Comprehensive RI/FS
93/04/15 TRC Member DDRW-BE Letter responding to the minutes of the TRC meeting for DDRW Tracy.
93/04/19 DDRW-BE EPA Letter transmitting minutes for the Project Managers' meeting held on 23 March 1993.
93/04/26 DDRW-BE TRC Member DDRW responding to comments made on the TRC meeting minutes of 15 April 1993.
93/04/26 RWQCB DDRW-BE RWQCB addressing concerns they have with the Site Wide Remedial Investigation Work Plan.
93/04/29 DDRW-BE CoE DDRW requesting that CoE hydrogeologists review RWQCB well survey test results.
93/04/01
93/04/08
93/04/08
93/04/09
93/04/09
93/04/12
93/04/12
93/04/12
MW
DDRW-BE
DDRW-BE
DTSC
DTSC
DDRW-BE
EPA
RWQCB
DDRW
TRC Members
CoE
DDRW-BE
DDRW-BE
CoE
DDRW-BE
DDRW-BE
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
93/05/01
93/05/01
93/05/12
93/05/14
93/05/14
93/05/15
93/05/18
93/05/18
93/05/26
93/05/27
93/06/01
93/06/01
93/06/01
93/06/02
93/06/03
93/06/04
93/06/07
93/06/08
93/06/08
93/06/10
93/06/11
93/06/11
93/06/15
93/06/16
93/06/21
93/06/24
MW
MW
CoE
DDRW-BE
DDRW-BE
DDRW
DDRW-BE
DDRW-BE
DDRW-BE
DDRW-BE
DTSC
MW
MW
CoE
DDRW-BE
RWQCB
DDRW-BE
DDRW-BE
DDRW-BE
DTSC
DDRW-BE
RWQCB
DDRW-BE
DDRW-BE
EPA
DDRW-BE
Addressee Subject

DDRW Defense Distribution Region West, Tracy, California, Draft Groundwater Treatment Pilot Plant Three Month Evaluation Report
DDRW Defense Distribution Region West, Tracy, California, Final Well Monitoring Program. Quarterly Monitoring
Report, January 1993 Sampling Round
DDRW Defense Distribution Region West, Tracy Facility, Operable Unit No. 1, Groundwater Treatment Remedial Design, Statement of Work
CoE DDRW providing CoE a copy of the DDRW Environmental Program Review performed by the U.S. Environmental Hygiene Agency.
RWQCB DDRW submitting the Tracy Facility's Report of Waste Discharge.
Report of Waste Discharge for Defense Distribution Region West, Tracy Facility, Tracy, CA
RWQCB DDRW notifying RWQCB that water was pumped from its storm water pond to the West Side Irrigation District's distribution system.
CAAE DDRW responding to a letter from Congressman Richard Pombo.
CAAE DDRW forwarding a copy of the Tracy Facility's Report of Waste Discharge.
EPA Reguest for a decision on the CERCLA 15-Month Rule.
DDRW-BE DTSC recommending that DDRW explore long-term remedial alternatives for residents impacted by groundwater contamination.
DDRW Defense Distribution Region West, Tracy, California, Final Amendments to the Comprehensive Remedial Investigations/Feasibility
DDRW Defense Distribution Region West, Tracy, California, Draft Groundwater Treatment Pilot Plant Injection Well
Rehabilitation and Chemical Testing Work Plan
DDRW-BE Response to DDRW-Tracy letter of 29 April 1993, Regional Water Quality Control Board Well Survey Test Results
DTSC Alternatives water supply for the Rose and Raspo properties.
DDRW-BE RWQCB comments on the Draft Record of Decision for Operable Unit No. 1.
CAAE DDRW responding to an inguiry from Congressman Richard Pombo.
EPA Final minutes for the Project Managers' meeting held 23 March 1993.
EPA Letter transmitting draft minutes for the Project Manager's Meeting held 27 - 28 Apr. 93.
DDRW-BE DTSC comments on the Draft Record of Decision for Operable Unit No. 1.
CoE DDRW comments on the Operable Unit No. 1 Groundwater Treatment Remedial Design scope of work.1992.
DDRW-BE RWQCB comments on the Statement of Work for Groundwater for Groundwater Treatment Remedial Design.
CoE DDRW reguesting CoE obtain repair costs from MW for level monitoring wells 48 and 57.
CoE DDRW reguesting WCC provide a legal review/approval of the ARARs section for the Draft Final ROD.
DDRW-BE Minutes of the conference call between EPA and RWQCB held June 18, 1993.
CoE Response to EPA Draft OU-1 Rod comments.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
93/06/29
93/06/30
93/06/30
93/06/30
93/07/02
93/07/02
93/07/07
93/07/15
93/07/15
93/07/15
93/07/22
93/07/22
93/07/28
93/08/01
93/08/01
93/08/01
93/08/03
93/08/04
93/08/04
93/08/11
93/08/11
93/08/12
93/08/17
93/08/20
93/08/26
93/08/26
93/08/30
93/09/01
93/09/01
93/09/03
93/09/13
93/09/19
DDRW- BE
DDRW- BE
DDRW- BE
DDRW- BE
MW
RWQCB
MW
DDRW- BE
DDRW- BE
DDRW- BE
MW
MW
EPA
MW
MW
WCC
MW
MW
MW
RWQCB
RWQCB
DTSC
EPA
RWQCB
DDRW
EPA
DDRW- BE
DDRW- BE
DDRW- BE
DDRW- BE
MW
MW
CoE
CoE
EPA
TRC Member
DDRW
EPA
CoE
EPA
RWQCB
CoE
DDRW- BE
DDRW- BE
DDRW- BE
DDRW
DDRW
DDRW
CoE
DDRW- BE
CoE
DDRW- BE
DDRW- BE
DDRW- BE
DDRW- BE
EPA

DDRW- BE
EPA
CoE
EPA
EPA
CoE
DDRW- BE
Subject

Draft Groundwater Treatment Pilot Plant Injection Well Rehabilitation and Chemical Testing Work Plan review comments.
DDRW requesting established of background levels for metals and pesticides at DDRW.
Submission of minutes for a conference call held on March 1993.
DDRW response to TRC comments.
Groundwater Treatment Pilot Monthly Operations Reports No 2.
RWQCB comments on EPA's letter dated 21 June 1993.
Draft Groundwater Modeling Workplan for Defense Distribution Region West, Tracy, California
Minutes for the Project Managers' meeting held on 25 May 1993.
Letter transmitting the DDRW Tracy Facility Supply Well #4 Abandonment Work Plan.
Letter requesting the repaation of well LM-57.
Minutes for the Project Managers' meeting held on 7 July 1993.
Minutes for the Project Managers' meeting held on 8 July 1993.
EPA comments on the Draft Final ROD for OU-#1.
Final Groundwater Treatment Pilot Plant Three Month Evaluation Report No. 2
Defense Distribution Region West, Final Well Monitoring Program, Quarterly Monitoring Report, April 1993 Sampling Round.
Final Operable Unit No. 1, Record of Decision, DDRW-Tracy, California
Written notification concerning the DDRW-Tracy Pilot Plant system shutdowns occurring on July 19 and July 29, 1993.
Letter transmitting video tapes and log sheets from the industrial waste pipeline investigation.
Written notification of the Tracy Pilot Plant system shutdown occurring on 3 August 1993.
Letter approving the Draft Final OU-1 ROD.
RWQCB approving the Draft Final Record of Decision.
DTSC comments on the Work Plan for Well 4 Abandonment.
EPA responding to DDRW's letter of May 27, 1993.
RWQCB's response to information received from EPA regarding the Draft ROD for OU-1.
Work Plan for Well 4 Abandonment at Defense Distribution Region West, Tracy, California
Letter documenting a telephone conversation with CoE regarding potential modification to the final amendments
to the Comprehensive RI/FS Work Plan.
Letter transmitting minutes for the Project Managers' meeting held on 7 July 1993.
Submission of the amendments to the Well #4 Abandonment Work Plan.
Letter submitting a copy of the OU-1 signature pages for the DDRW Tracy ROD.
Letter transmitting the OU-1 Design Schedule.
Written notification of the DDRW Tracy Pilot Plant shutdown occurring on 8 September 1993.
Final Phase 1 Site-Wide Ecological Assessment Work Plan for the Naval Air Station Moffett Field
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
93/09/20
93/09/22
93/09/27
93/09/30
93/10/01
93/10/01
93/10/05
93/10/05
93/10/06
93/10/07

93/10/12
93/10/15
93/10/21
93/10/22
93/10/25
93/10/27
93/10/27
93/10/27
93/11/01
93/11/01
93/11/17
93/11/30
93/12/01
93/12/01
93/12/01

EPA
RWQCB
EPA
DDRW- BE
DDRW- BE
MW
MW
MW
DDRW- BE
CoE

EPA
RWQCB
MW
DDRW- BE
DDRW- BE
DDRW- BE
DDRW- BE
DDRW- BE
MW
MW
MW
EPA
EPA
MW
MW
93/12/10
DDRW- BE
DDRW- BE
DDRW- BE
CoE
EPA
DDRW
CoE
CoE
CoE
USEHA, HSHB-
ME-SR
DDRW- BE
DDRW- BE
CoE
EPA
RWQCB
DTSC
EPA
RWQCB
DDRW
DDRW
CoE
DDRW-ABE
DDRW-ABE
DDRW
DDRW
DDRW-ABE
Subject

EPA comments on the Draft Remedial Design/Remedial Action Schedule for Operable Unit No. 1.
RWQCB comments on the Draft Groundwater Modeling Work Plan.
EPA comments on the Final Well Monitoring Program Quarterly Monitoring Report, April 1993 Sampling Round (August 1993).
DDRW reguesting COE investigate the possibility and potential cost savings of using dedicated sampling devices at DDRW Tracy monitoring wells.
DDRW Operable Unit #1 revised Design Schedule.
Final Groundwater Modeling Interim Technical Memorandum, Defense Distribution Region West, Tracy, California
Notification that the DDRW Tracy Pilot Plant was shutdown due to a brief power failure.
MW response to USAGE review comments on the July monthly report.
DDRW providing maps of the water and wastewater systems at the DDRW Tracy Facility.
CoE reguesting that HSHB-ME-SR review the DDRW Tracy Risk Assessment work.

EPA comments on the revised RD/RA Schedule for DDRW Tracy OU-1.
RWQCB comments on the Groundwater Treatment Pilot Plan System Start-up, Prove- out and Evaluation Reports.
Notification that file DDRW Tracy Pilot Plant system was shutdown. The shutdown was caused by a high level alarm at the pad drainage sump.
DDRW Operable Unit# 1 revised Design Schedule.
Waste Discharge Reguirements (WDRs) revision for Defense Distribution Region West, Tracy Facility
Federal Facility Agreement personnel change notification.
Federal Facility Agreement personnel change notification.
Federal Facility Agreement personnel change notification.
Defense Distribution Region West, Tracy, California, Well Monitoring Program, Well Redevelopment Report
Draft Pre-Design Technical Summary and Remedial Design Work Plan
Response to review comments on September Monthly Report.
EPA notifying DDRW of receipt of the Draft Risk Assessment SOW for the Site Wide Comprehensive Work Plan.
Notification of a change in EPA's RI/FS oversight support contractor.
Defense Distribution Region West, Tracy, California, Draft Groundwater Treatment Pilot Plant Operation and Maintenance Manual
Final Well Monitoring Program, Quarterly Monitoring Report, July 1993 Sampling Round
CoE DDRW review comments on the Draft Risk Assessment Statement of Work for the Site Wide Comprehensive Work Plan.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
93/12/10
93/12/13
93/12/13
93112/13
93/12/13
93/12/14
93/12/16
93/12/20
93/12/22
93/12/23
93/12/28
93/12/30
93/12/31
94/01/01
94/01/03
94/01/06
94/01/12
94/01/14
94/01/19
94/02/01
94/02/08
94/02/10
94/02/11
94/02/11
94/02/14
94/02/16
94/02/23
94/03/09
94/03/10
DDRW-ABE
DDRW-ABE
DDRW-ABE
EPA
MW
EPA
RWQCB
DDRW-ABE
EPA
DDRW-ABE
DTSC
DDRW-ABE
DTSC
MW
DDRW-ABE
DDRW-ABE
EPA
DDRW-ABE
DDRW-ABE
MW
DDRW-ABE
EPA
CoE
DTSC
EPA
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
EPA
CoE
Resident
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
City of Tracy
DDRW-ABE
DTSC
DDRW-ABE
EPA
DDRW-ABE
DDRW
CoE
CoE
DDRW-ABE
CoE
EPA
DDRW
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DTSC
CoE
DDRW-ABE
CoE
Subject

Comments on EPA's comments of the Final Well Monitoring Program Quarterly Monitoring Report, April 1993 Sampling Round.
Review comments for the Final Groundwater Modeling Interim Technical Memorandum.
DDRW providing sampling results for the January and April 1993 sampling rounds.
Letter transmitting EPA preliminary risk calculations with regard to human health affects associated with groundwater data collected.
Response to review comments on the August Monthly Report and Startup and Prove-out Report.
EPA comments on the Groundwater Modeling Interim Technical Memorandum.
RWQCB responding to DDRW letter dated October 25, 1993.
Placement of information repository for DDRW,
EPA comments on the Well Monitoring Program, Well Development Report.
DDRW providing DTSC information regarding the use of Eureka Laboratory.
Letter concurring with DDRW's Risk Assessment Statement of Work.
Notification of soil contamination at Building 201 (DDRW Tracy Facility).
DTSC and RWQCB comments on the Well Redevelopment Report and Groundwater Modeling Technical Memorandum.
Final Groundwater Treatment Pilot Plan Three Month Evaluation Report No. 3
Building 201 expansion foundation fill material.
DDRW reguesting monitoring well/air stripper repairs.
EPA's comments on the Draft Predesign Technical Summary and Draft Remedial Design/ Remedial Action Work Plan for OU-1.
DDRW comments on the RI/FS Site Characterization Report.
Minutes for the Project Managers' Meeting held December 7-8, 1993.
Defense Distribution Region West, Tracy, California, Groundwater Treatment Pilot Plant Monthly Operation Reports No. 3
DDRW comments on the Groundwater Treatment Pilot Plant Monthly Operations Report No. 3.
EPA comments on the Drift SOW for Well Evaluation and Abandonment and Draft SOW for Comprehensive RI/FS Work Plan Amendment.
Notification of access agreements from landowners whose property adjoins DDRW Tracy.
DTSC reguesting an extension for comments on the Comprehensive Site Wide RI/FS, Phase 1, Analytical Data Report.
EPA comments on the Draft Comprehensive RI/FS, Phase 1, Site Characterization Report.
DDRW response to DTSC letter dated 11 February 1994.
DDRW addressing EPA's comments on the Comprehensive Site Wide RI/FS, Site Characterization Report.
CoE providing information on off-site monitoring well easements.
Air stripper maintenance problems experienced at the DDRW Tracy Facility.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
94/03/10
94/03/11
94/03/15
94/03/23
94/03/30
94/04/01
94/04/01
94/04/01
94/04/05
94/04/07
94/04/08
94/04/11
94/04/11
94/04/13
94/04/13
94/04/13
94/04/14
94/04/14
94/04/14
94/04/18
94/04/18
94/04/19
94/04/20
94/04/22
94/04/27
94/04/29
94/05/01
94/05/01
94/05/02
94/05/06
94/05/09
MW
DDRW-ABE
DTSC
EPA
RWQCB
MW
MW
MW
DDRW-ABE
MW
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
EPA
CoE
MW
DTSC
DDRW-ABE
DDRW-ABE
DTSC
MW
MW
MW
TRC Member
EPA
DDRW-ABE,
RWQCB
CoE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW
CoE Hunt svi lie
EPA

Resident
TRC Members
CoE
DDRW-ABE
Resident
Resident
CoE
PHS
DDRW-ABE
DDRW
CoE
DDRW-ABE
RWQCB
EPA
DDRW-ABE
CoE
DDRW
CoE, Huntsville
DDRW-AB
DDRW-ABE
EPA
Subject

MW proposal to streamline the reporting process of the Quarterly Monitoring Reports under the Well Monitoring Program.
DDRW review comments on the air stripper monthly operations report.
Comments on the Draft Comprehensive RI/FS - Phase 1 - Site Characterization Report/Analytical Data Report,
Defense Distribution Region West, Tracy Site.
EPA's response to streamlining the quarterly monitoring report format.
RWQCB comments on the Groundwater Treatment Pilot Plant Three Month Evaluation Report No. 3.
Defense Distribution Region West, Tracy, California, Characterization of investigation- Derived Waste, Remedial Investigation, Phase 1
Draft Remedial Measure Expansion Design Analysis, DDRW, Tracy,
Draft DDRW - Tracy Facility Operable Unit 1 Remedial Action Plan
Minutes for the Project Managers' Meeting held on 15 and 16 February 1994.
Minutes from the Premobilization meeting for OU-1 CPT investigation held on 7 April 1994.
Private well sample results.
Minutes for the Technical Review Committee meeting held on 15 February 1994.
DDRW comments on the Groundwater Treatment Pilot Plant Monthly Operations Report for March 1994.
Revised Federal Facility Agreement proposed schedule.
Private well sample results.
Private well sample results.
DDRW comments on the Draft Well Abandonment Work Plan.
DDRW submitting a map and legend depicting all the solid waste management units and underground storage
tanks at the DDRW Tracy Facility.
EPA comments on the Draft Well Abandonment Work Plan.
Defense Distribution Region West, Tracy, California, Subsistence Warehouse Stockpiled Soil, Rapid Response, Final Report
Minutes from the Baseline Risk Assessment Work Plan Meeting held on 31 March 1994.
DTSC comments on the Draft Well Abandonment Work Plan.
Request for extension of Waste Discharge Requirements operating permit.
Letter submitting the revised Federal Facility Agreement schedule.
DTSC comments regarding the Draft Well Abandonment Work Plan for DDRW Tracy.
DDRW Tracy Site Witte Background Assessment Technical Memorandum.
Final Well Monitoring Program, Quarterly Monitoring Report, January 1994 Sampling Round
Community Relations Plan, DDRW-Tracy
Comments on the TRC meeting of 15 February 1994.
EPA requesting a written statement which explains the "good cause" for the revised FFA schedules.
DDRW's FFA-A schedule rationale as requested by EPA
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
94/05/11
94/05/12
94/05/12
94/05/12
94/05/13
94/05/18
94/05/19
94/05/20
94/05/23
94/05/24
94/05/24
94/05/25
94/05/26
94/05/26
94/06/01
94/06/01
94/06/01
94/06/01
94/06/06
94/06/06
94/06/06
94/06/10
94/06/13
94/06/15
94/06/20
DDRW-ABE
Dames & Moore
Dames & Moore
MW
DDRW-ABE
DDRW-ABE
EPA
DTSC
EPA
DDRW-ABE
DDRW-ABE
EPA
DDRW-ABE
DTSC
MW
MW
MW
MW
DDRW-ABE
EPA
MW
DTSC
DTSC
DDRW-ABE
DDRW-ABE
CoE
DDRW
DDRW
EPA
TRC Members
TRC Member
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
CoE
DDRW-ABE
CoE
DDRW-ABE
DDRW
DDRW
DDRW
DDRW
CoE
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
CoE
CoE
Subject

DDRW comments on the IRM design.
Draft Chemical Data Acquisition Plan, Well Abandonment
Site Safety and Health Plan for Well Abandonment
MW requesting an informal review of the format for the extended data packages being provided by their subcontract laboratory.
Final minutes for the TRC meeting held on 15 February 1994.
DDRW's responding to letter dated 2 May 1994.
Approval of extensions to DDRW Tracy FFA Schedules for the Comprehensive RI/FS/PP and ROD and OU-1 RD/RA.
DTSC's and RWQCB's concurrence of the Characterization of Investigation Derived Waste, Remedial Investigation, Phase I report.
EPA comments on the characterization of Investigative derived waste report.
DDRW comments oil Groundwater Treatment Pilot Plant Three- Month Evaluation Report No. 4.
DDRW Tracy's comments on Draft Chemical Data Acquisition and Health and Safety Plans for Supply Well #4 Abandonment.
EPA requesting additional information and a written response their letter dated 23 May 1994.
Clarification of DDRW Tracy's position regarding monitoring well sample turbidity.
DTSC approving revisions to the FFA schedule.
Draft IRM Expansion - Installation of Injection/ Extraction Wells and Chimney Drains Work Plan
Defense Distribution Region West, Tracy, CA, Draft Interim Groundwater Treatment Plant Expansion
Defense Distribution Region West, Tracy, CA, Draft Interim Groundwater Treatment Plant Expansion. Volume II - Drawings
Defense Distribution Region West, Tracy, CA, Characterization of Investigation-Derived Waste. Remedial Investigation, Phase I
DDRW requesting CoE contact Montgomery Watson regarding software requirements for the DDRW Tracy IRM.
EPA comments on the Draft Well Monitoring Program, Annual Monitoring Report, October 1993 Sampling Round.
Response to EPA Comments on Draft Investigative Derived Waste Report.
Comments on the Draft Chemical acquisition Plan and Site Safety and Health Plan for the Abandonment of Well No.4 report
DTSC comments on the Draft Chemical Data Acquisition Plan, Well Abandonment, and Draft Site Safety and Health Plan, Well Abandonment.
DDRW comments on the Draft Well Monitoring Program, Annual Monitoring Report.
DDRW comments on the Final Well Monitoring Program, Quarterly Well Monitoring Report, January 1994 Sampling Round.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
94/06/21
94/06/22
94/06/22
94/06/23
94/06/23
94/06/27
94/06/27
94/06/28
94/06/28
94/06/29
94/06/30
94/06/30
94/07/01
94/07/06
94/07/13
94/07/14
94/07/25
94/07/27
94/08/01
94/08/01
94/08/01
94/08/01
94/08/10
94/08/11
94/08/11
94/08/11
94/08/11
94/08/12
94/08/12
94/08/12
94/08/12
DDRW-ABE
DTSC
RWQCB
DDRW-ABE
EPA
DDRW-ABE
DTSC
DDRW-ABE
EPA
EPA
DDRW-ABE
EPA
MW
DDRW-ABE
DTSC
CoE
MW
DTSC
CoE
MW
MW
MW
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DTSC
EPA
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
CoE
DDRW-ABE
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW
CoE
DDRW-ABE
DDRW-ABE
CoE
DDRW-ABE
DDRW
DDRW
DDRW
CoE Huntsville
Resident
Resident
Resident
Resident
Resident
Resident
Resident
DDRW-ABE
DDRW-ABE
Subject

Well 4 abandonment requirements.
Request for extension for comments concerninq the Draft Well Monitorinq Proqram, Annual Monitorinq Report.
Notification of chanqe of Project Manaqer for RWQCB.
DDRW comments on the Draft Interim Remedial Measure Expansion - Installation of Injectional Extraction Well
and Chimney Drains Work Plan.
EPA comments on the example extended data packaqe.
DDRW comments on the Draft Final Well Abandonment Work Plan.
DTSC comments on the Draft Final Well Abandonment Work Plan.
DDRW comments on the Comprehensive Site-Wide Baseline Risk Assessment Work Plan.
Relocation of the information repository/administrative record for DDRW Sharpe and Tracy Facilities.
Commends on the Draft Chemical Data Acquisition Plan - Well Abandonment, May 94
DDRW comments on the Draft Final Site Characterization Report.
EPA comments on the Draft Final Well Abandonment Work Plan.
Final Groundwater Treatment Pilot Plan Three-Month Evaluation Report No. 4
DDRW review comments on the Site Wide RI/FS Analytical Data Report.
Review comments on Draft Final Comprehensive RI/FS Phase I Site Characterization Report and Analytical Data Report.
Use of Missouri River Division Laboratory for DDRW Tracy Facility investiqations.
Minutes for the meetinq at EPA on 19 July 1994.
Review comments on the Draft Well Monitorinq Proqram.
Scope of Work for IRM Expansion
Defense Distribution Reqional West, Tracy, California, Groundwater Treatment Pilot Plant Monthly Operations Reports No. 4.
Defense Distribution Reqion West, Tracy, CA, Final Well Monitorinq Proqram.
DDRW Tracy, California, Draft Groundwater Treatment Pilot Plant Three-Month Evaluation Report No. 6
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Private well results for the January 1994 samplinq round.
Extension for submittal of comments concerninq the Draft Comprehensive Site Wide Baseline Risk Assessment Work Plan.
Comments on the Draft Comprehensive RI/FS, Phase II Work Plan and Draft Comprehensive Risk Assessment Work Plan.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
94/08/15
94/09/24
94/08/31
94/09/01
94/09/01
94/09/01
94/09/01
94/09/08
94/09/19
94/09/21
94/10/01
94/10/01
94/10/01
94/10/24
94/10/25
94/11/01
94/11/01
94/11/01
94/11/01
94/11/01
94/11/04
94/11/11
94/11/28
94/12/01
94/12/01
94/12/01
94/12/01
DTSC
DDRW-ABE
DDRW-ABE
CoE
MW
MW
MW
DDRW-ABE
EPA
EPA
MW
MW
MW
DDRW-ABE
EPA
MW
MW
MW
MW
MW
MW
DTSC
DDRW-ABE
CoE
CoE
CoE
DDRW-ABE
DDRW-ABE
CoE
EPA
DDRW-ABE
DDRW
DDRW
CoE Hunt svi lie
EPA
DDRW-ABE
DDRW-ABE
DDRW
DDRW
DDRW
EPA
DDRW-ABE
DDRW
DDRW
CoE Hunt svi lie
CoE Hunt svi lie
DDRW-Tracy
CoE
DDRW-ABE
RWQCB
DDRW
DDRW
DDRW
EPA
Subject

Review comments on Draft Comprehensive RI/FS, Phase 11 Work Plan.
Comments on the Draft Comprehensive RI/FS Work Plan.
Minutes from the Project Managers' Meeting held on 7-9 June 1994.
Revised FFA schedule for Operable Unit 1.
Defense Distribution Region West, Tracy, California, Final Well Abandonment Work Plan
Defense Distribution Region west, Tracy, CA, Final Groundwater Treatment Pilot Plant Three-Month Evaluation, Report No. 5
DDRW Tracy, California, Final Groundwater Treatment Pilot Plant Three-Month Evaluation Report No.5
Reguest for FFA schedule extension,
EPA concurrence of low-flow groundwater sampling.
Approval of proposed extension to DDRW Tracy FFA schedule lot Operable unit 1 RD/RA.
Draft Final Comprehensive Remedial Investigation/ Feasibility Study - Phase I, Site Characterization Report
Final Well Monitoring Program, Annual Monitoring Report, October 1993 Sampling Round
Defense Distribution Region West, Tracy, CA, Final Comprehensive Remedial Investigation/Feasibility Study - Phase I, Analytical Data Report
Minutes for the Project Managers' Meeting held on 17-18 August 1994.
Comments on Final Phase I Site Characterization Report and Draft Final Phase II Work Plan.
Defense Distribution Region West, Tracy, California, Final Groundwater Treatment Pilot Plant Three-Month Evaluation Report No. 6
Defense Distribution Region West, Tracy, CA, Interim Groundwater Treatment Plant Expansion Start-up and Prove- out Work Plan, Table 2-1
Draft Well Monitoring Program Low-Flow Sampling Study Work Plan for Defense Distribution Region West. Tracy
DDRW Tracy, California, Draft Groundwater Treatment Pilot plant Three-Month Evaluation Report No. 7
Interim Groundwater Treatment land Expansion Construction management Mid-Project Progress Report, Aug 25, 1994 to Oct 19, 1994
Minutes for 11 October 1994 conference call on Draft Baseline Risk Assessment Work Plan.
Comments on Draft Final Phase II Work Plan.
Waste discharge reguirements for DDRW Tracy.
Scope of Work for Engineering Evaluation/Cost Analysis for Industrial Waste Lagoon Removal Action at Defense Distribution Region West, Tracy, CA
Scope of Work for Engineering Evaluation/Cost Analysis for Industrial Waste Pipeline Removal Action at Defense Distribution Region West, Tracy,
Appendix A, Annex B, Investigation, Alternatives Proposal, and Design for Removal Action of Underground Storage Tank Sites at DDRW Tracy, CA
Minutes for the Project Managers' Meeting held on 19 October 1994.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
94/12/01
94/12/01
94/12/01
94/12/01
94/12/01
94/12/01
94/12/07

94/12/07

94/12/08
94/12/12
94/12/14
94/12/14
94/12/14
94/12/14
94/12/15
94/12/15
94/12/15
94/12/19
94/12/19
94/12/28
95/01/01
95/01/01
95/01/05
95/01/11
95/01/13
95/01/18
95/01/20
95/01/23

MW
MW
MW
MW
MW
MW
James J. Oakham, Jr.,
MAI
James J. Oakham, Jr.,
MAI
DDRW-ABE
EPA
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DDRW-ABE
DTSC
DDRW-ABE
DDRW-ABE
MW
MW
MW
RC
EPA
EPA
DTSC
DDRW-ABE
DLA COL R.S.
LaBaron
DDRW
DDRW
DDRW
DDRW
DDRW
DDRW
CoE Sacto
Appraisal Branch
CoE Sacramento,
Appraisal Branch

DDRW-ABE
Resident
Resident
Resident
Resident
Resident
Resident
DDRW-ABE
Resident
CoE
CoE
DDRW
CoE Hunt svi lie
CoE Hunt svi lie
DDRW-ABE
DDRW-ABE
DDRW-ABE
CoE
ASCW-BE Tracy

Defense Distribution
Defense Distribution
Defense Distribution
Defense Distribution
Defense Distribution
Defense Distribution
Real Estate Planning
Subject

Region West, Tracy, CA, Final Bench Test Work Plan
Region West, Tracy, CA, Well Monitoring Program, 1994 Work Monitoring Program
Region West, Tracy, CA, Final Comprehensive Remedial Investigation/Feasibility Study - Phase II Work Plan
Region West, Tracy, CA, Lower Tulare Monitoring Well Technical Memorandum
Region West, Tracy, CA, Start-Up, Prove-Out, and Extended Prove-Out Work Plan
Region west, Tracy, Well Monitoring Program, Quarterly Monitoring Report, August 1994 Sampling Round
Report Part A for Proposed Easement Acguisitions Near The Tracy Facility DDRW
Real Estate Planning Report Part A for Proposed Easement Acguisitions for Contaminant Plume Management
near the Tracy Facility
Minutes for the Technical Review Committee Meeting held on 3 Oct 94
EPA comments on the Draft Final Comprehensive Risk Assessment Work Plan.
Private wells results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
Private well results for the March 1994 sampling round.
DTSC and RWQCB comments on the Draft Final Phase II Work Plan.
Private well results for the March 1994 sampling round.
DDRW comments on the Interim Groundwater Treatment Plant Expansion drawings.
Conference call minutes on the Draft Final Baseline Risk Assessment Work Plan.
Defense Distribution Region West, Tracy, CA, Final Groundwater Treatment Pilot Plant Three-Month Evaluation Report No. 7
DDRW Tracy, California, Groundwater Treatment Pilot Plant Monthly Operations Reports No.4, July - December 1994
DDRW Sharpe/Tracy Integrated Geographic Information System Needs Analysis and Reguirements Document
Comments on statements of work for removal actions for the industrial waste lagoon/industrial waste pipeline
and underground storage tanks.
Comments on the Low-Flow Sampling Work Plan.
DTSC and RWQCB comments on the Draft Well Monitoring Program, Low-Flow Sampling Study Work Plan.
Comments on the Low Flow Sampling Study Work Plan.
8 Feb 95 TRC Meeting @ Ogden, Utah
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
95/01/27
95/01/31
95/02/01

95/02/01
95/02/06
95/02/08
95/02/09
95/02/10
95/02/16
95/02/20

95/02/20

95/02/25
95/03/01
95/03/01
95/03/01
95/03/01
95/03/01
95/03/09
95/03/10
95/03/10
95/03/10
95/03/17
95/03/17
95/03/20
95/03/22
95/03/22
95/03/27
DDRW-ABE
DDRW-ABE
MW Jamie S. Atwood

RC
EPA
DDRW-ABE
DDRW-ABE
MW
ASCW-BE
MW

ASCW-BE
MW
MW
MW
MW
PTASI
EPA
MW
PTASI
RC
ASCW-BE
ASCW-BE
ASCW-BE
Unknown
Unknown
ASCW-BE
RWQCB
EPA
Steve Liqht,
CEHND
CoE Hunt svi lie
DDRW-ABE
EPA
EPA
CoE Hunt svi lie
CoE
Steve Liqht,
CEHND
Steve Liqht,
CEHND
RWQCB
DDRW
DDRW
DDRW
CoE Hunt svi lie
ASCW-BE
ASCW-BE
Marshall Cloud
ASCW-BE
CoE Hunt svi lie
Residents

DDRW - Tracy
Participants
RWQCB
Subject

Comments on the Draft Waste Discharge Requirements Permit.
Request for a 23-day extension for the Operable Unit 1 desiqn/implementation schedule.
Minutes of Project Coordination Meetinq on January 23, 1995

Draft Final DDRW Sharpe/Tracy Inteqrated Geoqraphic Information System (GIS) Needs Analysis and Requirements Document
EPA response to DDRWs letter of 31 January 1995.
DDRW submittinq a table as requested in EPA's letter dated 6 February 1995.
EPA approvinq the FFA schedule extension for OU-1 RD.
January 27, 1995 Conference Call Minutes on Draft Final BRAWP
Comments on the Environmental Baseline Study Statement of Work
Confirmation of Abandonment and Demolition Task at Well AG-3

A-E Weekly Quality Control Report: Well Investiqation and Abandonment of Well AG-3

DDRW requestinq a 15-day extension of the due date for the DDRW Tracy air stripper monitorinq report.
Defense Distribution Reqion West, Tracy, CA, Draft Final Comprehensive Site-Wide Baseline Risk Assessment Work Plan.
Defense Distribution Reqion West, Tracy, CA, Final Well Monitorinq Proqram, Low-Flow Samplinq Study Work Plan
Defense Distribution Reqion West, Tracy, California, Well Monitorinq Proqram, Quarterly Monitorinq Report,
October 1994 Samplinq Round
Defense Distribution West, Tracy, California: Well Monitorinq Proqram; Low-Flow Samplinq Study Work Plan
Monthly Monitorinq Report: March 1993
EPA comments on the Pre-Desiqn Data Report for Operable Unit 1.
Final Well Repairs for Well Abandonment DO (21)
MONTHLY REPORT FOR FEBRUARY 1-28,1995
Final DDRW Sharpe/Tracy Inteqrated Geoqraphic Information System (IGIS) Needs Analysis and Requirements Document
Private wells results for the Auqust 1994 samplinq round.
Minutes for the Technical Review Committee Meetinq held 5 December 1994.
Minutes for the Project Manaqers' Meetinq held 29-30 November 1994.
Minutes of Project Manaqers1 Meetinq held 22-23 March 1995
RPM Minutes March 22, 1995
Request for permission to shut down the Operable Unit 1 air stripper for maintenance.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
95/03/29
95/03/30
95/04/01
95/04/01
95/04/01
RC
EPA
MW
MW
RC
95/04/01 RC

95/04/06 MS Steve Krueger
95/04/06 USEPA, Michael
95/04/10 PTASI
95/04/11 MW Robert P.
Schlicher
95/04/11 RC Scott Kranhold
95/04/13 DTSC Jim Pinasco
95/04/17 CoE Huntsville
95/04/17 MW Andrew Somes
95/04/17 MW Jamie S. Atwood

95/04/24 ASCW-BE, Mcllvoy
95/04/26 MW Nancy Barnes
95/04/26 RC Francis E, Slavich

95/04/27 MW
95/04/27 MW
95/05/01 MW
95/05/01 PTASI
95/05/01 PTASI
95/05/01 RC
95/05/01 The Stockton Record
95/05/04 RC
Addressee

CoE Huntsville
ASCW-BE
CoE Huntsville
CoE Huntsville
CoE Huntsville

CoE Huntsville

Marshall Cloud
ASCW-BE
ASCW-BE
Steve Light,
Huntsville
ASCW-BE
Marshall Cloud
ASCW-BE Tracy
ASCW-BE
Steve Light,
Huntsville
RWQCB
ASCW-BE
ASCW-BE and CoE
Huntsville
Distribution List
Steve Light
CoE Huntsville
ASCW-BE
DDRW - Tracy
ASCW-BE
General Public
CoE Huntsville
Subject

DDRW Sharpe/Tracy Integrated Geographic Information System (IGIS) Database Design Document (Draft Final)
Response to EPA comments on the Draft Final Comprehensive Baseline Risk Assessment Work Plan for DDRW Tracy.
DDRW, Tracy, CA Draft Extended Prove-Out report Expanded Interim Remedial Measure System
DDRW, Tracy, CA, 30 Percent Remedial Design Report & Analysis for Operable Unit 1
Draft Delivery Order 002 Environmental Baseline Study Work Task Proposal for Defense Distribution West
Sharpe/Tracy, California
Draft Delivery Order 002 Environmental Baseline Study Work Task Proposal for Defense Distribution West
Sharpe/Tracy, California
5 Apr 95 Conference Minutes on Discussion of Work Submittal Forwarded to CEHND Prior to Meeting on OU1 Design
Review comments on PWP for Monitoring Well Sampling & Analysis @ DDRW Sharpe & Tracy; Amendments Work for 27 Dec 94
MONTHLY REPORT FOR MARCH 1-31, 1995
Status Update of IRM Expansion Project at Tracy

Copy of BBS Questionnaire for Interviewing Property Owners
Review of the Draft Pre-Design Data Report, DDRW, Tracy
COE Package for Out Lease of Tracy Annex
State of California, Department of Water Resources, Well Completion Reports for Tracy
Comprehensive Summary of Approach Used for Determination of Depot-wide Soil & Deionized Water
Extraction Test Soil Leachate Background Threshold Levels at Tracy
Feb 1995 Monthly Report for Tracy Air Stripper
List of Subcontractors for Site Access & Field Studies at Tracy
Draft Environmental Baseline Study for Tracy

Letter to Steve Light Regarding Phase III Sampling
Technical Memo Review Comments and Phase III Sampling for Phase II Investigation and Report DDRW - Tracy
DDRW, Tracy, CA, Well Monitoring Program 1994 Annual Report
Monthly Monitoring Report: May 1995
Monthly Monitoring Report - May 1995
Administrative Support Center West-Tracy Operable Unit 1 CPT Study Work Plan
Newspaper Article: Project Manager Wins Award for Innovative Way to Clean Up Depots
Draft ASCW Sharpe/Tracy Integrated Geographic System (IGIS) User Guides
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date Author

95/05/04 RC
95/05/04 Tracy Press, Sam
Matthews
95/05/04 USEPA, Michael
Work
95/05/05 PTASI

95/05/10 PTASI
95/05/11 MW Jamie S. Atwood
95/05/11 USEPA, Michael
Work
95/05/16 DDRW-Tracy RIM
95/05/18 USEPA, Michael
Work
95/05/18 USEPA, Michael
Work
95/05/19 MW

95/05/23 MW Nancy Barnes
95/05/26 Patricia L. Rivers,
OUSD
95/05/30 MW Nancy Barnes
95/06/01 MW
95/06/01 MW Susan Tiffany
95/06/01 PTASI
95/06/01 RC
95/06/01 RC
95/06/01 USACOE,
Sacramento District
95/06/05 MW
95/06/05 MW Jamie S. Atwood

95/06/08 Michael Work,
USEPA
95/06/08 Steven L. Glaser, MW
Addressee

CoE Huntsvilie
ASCW-BE

ASCW-BE Tracy

DDRW, Tracy
Facility
DDRW - Tracy
ASCW-BE Tracy
Marshall Cloud

ASCW-BE Tracy
Marshall Cloud

Marshall Cloud

Steve Light, CoE
Huntsville
Steve Light
ASCW-BE, Tracy

Marshall Cloud
CoE Huntsville
ASCW-BE
DDRW - Tracy
ASCW-BE
CoE Huntsville
ASCW-BE

Steve Light
Steve Light and
Marshall Cloud
Mr. Marshall Cloud

CoE Huntsville
Subject

ASCW Sharpe/Tracy Integrated Geographic Information System Implementation Plan (Draft)
City's Plans for Golf Course

EPA's Review of Data Validation Portion of Tracy's Comprehensive RI/FS Phase II Analytical Data Report,
Volumes I, II, III
Quarterly Monitoring Report: First Quarter 1995

Monthly Monitoring Report, April 1995
Video Survey of the Grouting of and Abandonment of Well AG3
Flow Chart For Amending a ROD

IRM Specifications for Eguipment, Well Pumps, Piping, Meters, & Valves for Tracy A/S System
Receipt of DDRW-Tracy's Draft Technical Memorandum: Comprehensive Remedial Investigation/Feasibility
Study - Phase II (Mar 95 (Volumes I & II)
DDRW-Tracy's Draft Technical Memorandum: Comprehensive Remedial Investigation/Feasibility Study -
Phase II, Volumes I & II
DDRW Tracy Background Discussions

Draft Status Report: Abandonment of Well AG-3
Technical Assistance for Public participation in the DERA Program-Federal Register Notice of Reguest for
Comments
Weekly DQCRS from Road Work, Well Abandonment, & Phase III RI
Technical Memorandum Human Health Risk Assessment at Exposure Units 1,2,7
Preliminary Applicable or Relevant and Appropriate Reguirements for ASC-Tracy Feasibility Study
Monthly Monitoring Report, June 1995
Delivery Order 0003: OU Design Support Work Task Proposal
Operable Unit 1 CPT Study Work Plan
Environmental Baseline Study OU 1 Easement Properties

DDRW-Tracy Phase II RI Final Investigation Derived Waste Report
Details Concerning DDRW-Tracy Phase II RI Final Investigation Derived Waste Report

DDRW-Tracy's 30 Per Cent Remedial Design Report and Analysis, Remedial Action Work Plan (Apr 95) for
Operable Unit 1
Risk Assessment Criteria, Committee Meeting Minutes, May 9, 1995
-------
Date Author

95/06/09 Karen Bessett,
RWQCB, Central
Valley
95/06/12 Dennis C. Noble,
Attorney at Law
95/06/12 MW
95/06/14 Francis E. Slavick, RC
95/06/20 Francis E. Slavich, RC
95/06/20 Steven L. Glaser, MW
95/06/21 Nancy Barnes, MW
95/06/26 Jim Pinasco, DTSC
95/06/26 Steven L. Glaser, MW
95/06/30 RC
95/07/01 MW
95/07/01 PTASI
95/07/01 RC
95/07/01 RC
95/07/01 RC
95/07/05 PTASI
95/07/06 Diane Hinson, PHS,
SJC
95/07/06 SWRCB, Central
Region
95/07/07 DoD, Material Mgt
Distributions, IMP,
Virginia Crowson
95/07/11 MW
95/07/17 Nancy Barnes, MW
95/07/18 Francis E. Slavich, RC

95/07/18 Steven M. Newton,
Administrative Record File Index - DDJC Tracy (Continued)

Addressee Subject

Mr. Marshall Cloud, Addendum to Pre-Design Data Report for Operable Unit 1, DDRW Tracy
RRWQCB

Steve Light
Steve Light
Steve Light
Marshall Cloud,
Steve Light
Mr. Marshall Cloud
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
DDRW-Tracy
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
DDRW - Tracy
RWQCB
Irrigation Well Installation 26101 S. Chrisman Road APN 252-040-05 Anthony Traina, et. al.

A-E Weekly Quality Control Report, June 12, 1995, Well Investigation & Abandonment
Delivery Order 0006, Project Management Contract DACA87-95-D-0001, Meeting Minutes, Public Relations
Delivery Order 0003, Groundwater Treatment Remedial Design Support for DDRW Submittal of Work Task Proposal
Baseline Risk Assessment at DDRW - Tracy
Submittal of Well Abandonment Work Plan for AG-3
Review of 30 Per Cent Design Report and Analysis and Draft Remedial Action Work Plan for Operable Unit No. 1, DDRW, Tracy
Corrections and Clarifications to the Meeting Minutes of the May 9, 1995 Baseline Risk Assessment CCM for ASCW - Tracy
DDRW Sharpe/Tracy Integrated geographic Information System Draft Final Database Design Document
DDRW-Tracy Environmental Baseline OU 1 Easement Properties Final Report
Monthly Monitoring Report July 1995
DDRW Sharpe/Tracy Integrated Geographic Information System Implementation Plan, Draft Final
DDRW Sharpe/Tracy Integrated Geographic Information System Draft Final User Guides, Version I
DDRW Sharpe/Tracy Integrated Geographic Information System, Draft final User Guides, Version II
Quarterly Monitoring Report - April - June 1995
Proposed Irrigation Well Installation, APN 252-040-05, 26101 Chrisman Rd, DDRW Tracy

Proposed Irrigation Well installation, APN-252-040-05, 26101 S. Chrisman Road, Tracy
Diane Hinson,
SJCPHS
Mr. Marshall Cloud, Proposed Easement Acguisitions for contaminant Plume Management Near DDRW - Tracy
CoE Huntsvilie
Steve Light
Steve Light

Steve Light
Transmittal of Predraft Proposed Plan
A-E Weekly Quality Control Report, 17 July 95
Delivery order 0003, Contract DACA87-95-D-001, Groundwater Treatment Remedial Design Support for
DDRW OU#1 CPT Study Field Reports
Strawberry Agricultural Well Potential Impact on DDRW-Tracy
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
Subject
95/07/20

95/07/25
95/07/27
95/07/27

95/07/28
95/07/28
95/07/31
95/07/31
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/01
95/08/15
Michael Work,
US EPA
David C. Ennis
RC
RWQCB, Central
Valley
MW
MW
Peter B. LeVon, MW
Randy Marx, RC
MW
MW
MW
MW
MW
MW
PTASI
RC
RC
RC
Joe Schratz, Calcoi
Systems, Inc.
95/08/17 Michael Work,
US EPA
95/08/18 Steven L. Glaser, MW
95/08/22 Unknown

95/08/24 Michael Work,
USEPA
95/08/25 Michael Work,
USEPA
95/08/27 Unknown
95/08/28 Michael Work,
Marshall Cloud DDRW Tracy Technical Memorandum, Human Health Risk Assessment at Exposure Units 1,2, & 7, June 1995

Steve Light Possible Use of Zero Valent Metals for Operable Unit 1, Groundwater Cleanup at DDRW, Tracy
Steve Light Document Submission - Final Environmental Baseline Study
Jim Pinasco, DTSC General Comments on Well Monitoring Program 1994 Annual Monitoring Report for Tracy
Marshall Cloud
CEHND
Steve Light
Steve Light
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
DDRW - Tracy
DDRW - Tracy
DDRW - Tracy
CoE Huntsvilie

CoE
CoE Huntsvilie
Peter Kalush

Marshall Cloud

Steve Light
DDRW Remedial
Project Mgrs
Marshall Cloud

Marshall Cloud

General Public
Marshall Cloud
Well Completion Reports Well Abandonment Program Delivery Order 021
Comprehensive RI/FS - Phase II and Phase III Analytical Data Report, Vol I, II, & III
Response To Comments on DDRW Tracy Well Monitoring Program Draft Low-Flow Sampling Study Work Plan
Submittal of Record of Decision Summary Table
Draft Comprehensive Site-Wide Baseline Risk Assessment
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume 1
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume 2
Draft Comprehensive Remedial Investigation/Feasibility Study, Volume III
Final Groundwater Model Technical Evaluation, Volume 1
Final 3-D Groundwater Model Technical Evaluation, Volume 2
Monthly Monitoring Report, August 1995
Draft Engineering Evaluation Cost Analyses (EE/CA) for the Industrial Waste Pipeline, Sewage Lagoons, &
Industrial Waste Lagoons for DDRW-Tracy
DDRW Tracy & Sharpe, CA Delivery Order 006: Community Relations Task Work Task Proposal
UST Site Investigation Work Plan, Draft
Tracy DDRW Air Stripper- Valve Failure

DDRW Tracy Incomplete RI Submission and EPA's Risk Assessment Comments of July 20, 1995

Submittal of Draft Comprehensive Site-Wide Risk Assessment Section 6 - Ecological Assessment
Presentation of DDRW Draft Comprehensive RI/FS and BRA Findings to Remedial Project Managers

Resolution of Informal Dispute Re DDRW-Tracy Incomplete RI

DDRW-Tracy Draft Explanation of Significant Difference for OU-1 ROD (Aug 95)

Public Notice for Agriculture Lease Meeting on September 7, 1995
Ltr. regarding DDRW Tracy Investigation of AG-2/Lower Tulare
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date Author

95/08/30 Deborah C.Z. Hirsch,
RC
95/08/30 Steven L. Glaser, MW
95/09/01 MW
95/09/01 MW
95/09/01 MW
95/09/01 MW
95/09/01 MW
95/09/01 MW
95/09/01 RC
95/09/08 Nancy Price, Stockton
Record
95/09/09 Scott Howard, The
Valley Newspaper
95/09/09 Stockton Record
95/09/13 RC

95/09/14 MW
95/09/14 Peter B. LeVon, MW
95/09/15 AMCEN-R
(MMDIM), Col Mark
Porter
95/09/15 Deborah C.Z. Hirsch,
RC
95/09/18 MW
95/09/19 Michael Work,
US EPA
95/09/20 Deborah C.Z. Hirsch,
RC
95/09/20 Steven L. Glaser, MW
95/09/22 CPT Will Harmon
95/09/26 CoE
95/09/26 RC
95/09/26 RC
Addressee

Steve Light

Marshall Cloud
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
CoE Huntsvilie
General Public
Subject

Delivery Order 006: Transmittal of Meeting Minutes and Draft Poster Boards

Parental Notification Letter, Day Care Center
DDRW-Tracy Operable Unit 1 CPT Technical Memorandum Final Report
DDRW-Tracy 60 Per Cent Remedial Action Work Plan for Operable Unit 1
DDRW-Tracy 60 Per Cent Construction Specifications for Operable Unit 1, Volume II
Interim Groundwater Treatment Expansion Operations & Maintenance Manual
DDRW-Tracy: 60% Remedial Design Report ana Analysis for Operable Unit 1
DDRW-Tracy 60% Construction Specifications Volume 1
DDRW-Tracy Underground Storage Tank Closure Report Draft
Newspaper Article: Feds Looking for A Few Good Farmers for Leases Near Tracy Depot
General Public Day Care Center Discovers Minute Amount of DDT
General Public
CoE Huntsvilie

Steve Light
Steve Light
DDRW -Tracy
Steve Light

Marshall Cloud
Mr. Marshall Cloud

Steve Light

Steve Light
Marshall Cloud
ASCW-BE
CoE Huntsville
CoE Huntsville
Newspaper Article: DDT Found at Tracy Depot at Day-Care Center
Engineering Evaluation/Cost Analyses (EE/CA) for the Industrial Waste Pipeline, Sew Lagoons, & Industrial
Waste Lagoons Draft Final
Original Data Sheets for Phase II DI-WET Data
Response to comments on DDRW-Tracy Well Monitoring Program
Proposed Easement Acguisitions for Contaminant Plume Management near DDRW - Tracy

Transmittal of Public Meeting Minutes and Copies of Informational Posterboard Sets Prepared for Public
Meetings
Modeling Backup to Montgomery's Letter Dated July 18, 1995
DDRW-Tracy's Draft UST Site Investigation Work Plan (Aug 1995)

Transmittal of Public Meeting Minutes & Copies of Informational Posterboards Sets Prepared for Public
Meetings
Day Care Meeting Minutes, September 5, 1995
Analytical Data Summary Vegetative Layer Barrow Source Sampled on August 17, 1995
Petroleum Contaminated Soil Removal DDRW-Tracy & Sharpe Draft-Draft
Work Task Proposal for the IRM Groundwater Treatment Plant Scale Study, DDRW-Tracy
Work Task Proposal for the Two Phase Extraction Treatability Study, DDRW-Tracy
-------
Date
95/09/29

95/09/29
95/09/30
95/10/04
95/10/04
95/10/04
95/10/05
95/10/05
95/10/10
95/10/10
95/10/11

95/10/11
95/10/16
95/10/18
95/10/19
95/10/24
95/10/24
95/10/25
95/10/26
95/10/26
95/10/30
95/10/30

95/10/31
95/10/31
95/11/10
95/11/02

95/11/02

95/11/03
Author
Curtis & Tompkins,
Lts. Analytical
Laboratories
MW
MW
ASCW-PSM
Jim Pinasco, DTSC
RC
PTASI
WMD/C&C&T
CoE
PTASI
Brian K. Davis, Ph.D
DTSC
RC
RC
EPA
RWQCB
ASCW-BE
RWQCB
RC
DTSC
RC
MW
RWQCB, Karen
Bessett
DDRW- BE
RC
RWQCB
Michael Work,
US EPA
Michael Work,
USE-PA
Jim Pinasco, DTSC
Administrative Record File Index - DDJC Tracy (Continued)

Addressee Subject

Marshall Cloud Preliminary Results from Analysis of Contaminated Soil @ Tracy Daycare Center
Steve Light
COE Huntsville
PTASI
Marshall Cloud
Steve Light
ASCW-BE Sharpe
Davy International
DDRW-Tracy
DDRW - Tracy
Jim Pinasco, DTSC

CoE
Steve Light
DDRW-Tracy
DDRW-Tracy
EPA
Jim Pinasco, DTSC

CEHND
DDRW-Tracy

CEHND
CoE Huntsville
Marshall Cloud

Michael Work, EPA
CoE Huntsville
DTSC, Jim Pinasco
Marshall Cloud

Marshall Cloud

Marshall Cloud
EPA Comments on Human Risk Assessment Technical Memorandum
Extended Prove-Out Report Expanded Interim Remedial Measure System, September 1995 1 copy
Well Monitoring
Quote for Removal of Contaminated Soil @ Tracy Daycare Center
29 Sep 1995 Conference Call Minutes & Monthly Planner for Oct & Nov 1995
Quarterly Monitoring Report, July - September 1995
Test Results for Child Care Center -Tracy Facility
Extended Prove-Out IRM, Design Review Comments, May 5, 1995
Monthly Monitoring Report, September 1995 2 copies
Risk Assessment Evaluation Of DDRW Tracy

Final Integrated Geographic Information System (IGIS) Implementation Guide
Draft DDRW Tracy's Operable Unit 1 Two Phase Extraction Treatability Study Work Plan
Draft Final EE/CA, DDRW Tracy, Removal Action for SWMUs 2,3, and 33
Draft Underground Storage Tank (UST) Site Investigation Work Plan general comments
Approval of DTSC reguest for a 30 day comment extension
Draft Final Engineering Evaluation/Cost Analyses for the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons
Draft Pesticide Evaluation for Day Care Center (DCC) Technical Memorandum DDRW-Tracy
Engineering Evaluation/Cost Analyses (EE/CA) , for the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste C-
Operable Unit 1, 60 Percent Design Review, DDRW-Tracy, DACA87-95-D-0001
Operable Unit 1, Explanation of Significant Difference for Chg of Groundwater Extraction
Draft Final Explanation of Significant Difference for OU 1 ROD, DDRW-Tracy

Decision not to conduct NRDA at DDRW Tracy
Final Operable Unit 1 CPT Study Technical Memorandum, DDRW-Tracy, October 31, 1995 3 copies
Draft Comprehensive RI/FS study Report, DDRW-Tracy
Draft Final BSD for OU-1 Oct95

Ltr. regarding Draft Final BSD for OU-1 (Oct 95)

Draft Comprehensive RI/FS, DDRW Tracy
-------
Date
Author
Administrative

Addressee
95/11/03

95/11/07

95/11/08
95/11/09
95/11/10
95/11/13
95/11/13

95/11/13

95/11/13
95/11/13

95/11/14
95/11/20

95/11/22
95/11/29
95/12/02
95/12/04

95/12/08
95/12/12

95/12/14
95/12/14

95/12/15
95/12/19
95/12/20

95/12/20
Michael Work,
US EPA
Michael Work,
US EPA
RD
DTSC, Jim Pinasco
PTASI
DTSC, Jim Pinasco
Michael Work,
US EPA
Michael Work,
US EPA
MW, Roberta
Schlicher
RC
RWQCB, Robert
Reeves
MW
Michael Work,
US EPA
RC
AMCEN-R
RC
CoE

RC
Michael Work,
US EPA
RWQCB
RWQCB, Robert
Reeves
RC, Slavich
RC
MW, Robert
Schlicher
RWQCB
Marshall Cloud

Marshall Cloud

CoE, Steve Light
Marshall Cloud
DDRW-Tracy
Marshall Cloud
Marshall Cloud

Marshall Cloud

CoE, Steve Light

CoE Hunt svi lie
DTSC, Jim Pinasco

DDRW-Tracy
DDRW-Tracy

CoE, Steve Light
ASCW-BE
CoE, Steve Light
DDRW-
Tracy/Sharpe
CoE, Steve Light
Marshall Cloud

Marshall Cloud
ASCW-BE

CoE, Steve Light
ASCW-BE
CoE, Sieve Light

DDRW-Tracy
Record File Index - DDJC Tracy (Continued)

Subject

Ltr. regarding Example Proposed Plan

Letter regarding Draft Final OU-1 60% Remedial Design (Sep 95)

Document Submission: Draft Interim Remedial Measure (IRM) Study Work Plan, DDRW -Tracy 3 copies
Ltr verifying 30 day extension for comments concerning the Draft Base Wide RI/FS Study Report
Monthly Monitoring Report, Tracy Facility, Report Period October 1995, Report Date November 10, 1995
Review of Draft 60% Design for U-l, DDRW-Tracy
Ltr. DDRW-Tracy FFA Schedule extension Reguest for Draft Final Comprehensive RI/FS/PP and Draft ROD

Ltr DDRW-Tracy FFA Schedule Extension Reguest for Draft Final Comprehensive RI/FS/PP and Draft ROD

OU 1 Explanation of Significant Difference DDRW-Tracy Revised Draft Final

Final Two Phase Extraction Treatability Study Work Plan
Comments on the 60% Remedial Design Report & Analysis for OU-1 & 60% Remedial Action Work Plan for
DDRW-Tracy.
DDRW-Tracy Operable Unit 1 Explanation of Significant Difference
Example Table Format for Risk Assessment Uncertainties

Draft Underground Storage Tank Closure Report, DDRW-Tracy
Proposed Easement Acguisitions for Contaminant Plume Management Near the DDRW-Tracy
Draft Environmental Master Plan, DDRW-Sharpe and DDRW-Tracy
Draft-Draft Site Visit, Petroleum Contaminated Soil Removal.

Work Task Proposal for Tracy Well Management Project
Ltr. OU-1 Remedial Design 60%

Well Abandonment Engineering Report for DDRW-Tracy
Well abandonment Engineering Report, DDRW-Tracy

Final Pesticide Evaluation for Day Care Center Technical Memorandum DDRW-Tracy
Minutes RPM meeting Dec 5-7, 1995
OU-1 Explanation of Significant Difference, DDRW-Tracy Final

Notice, Tentative Waste Discharge Reg. for Tracy OU-1 Groundwater Treatment System
-------
Date
95/12/20
95/12/29
Author

RWQCB, Karen
Bessett
ASCW-BE, Marshall
Cloud
Admini s trative

Addressee

ASCW-BE

RWQCB, Karen
Bassett
95/12/29
96/01/01
96/01/01
96/01/01
96/01/02
96/01/05
96/01/05
96/01/05

96/01/06
96/01/06
96/01/10
96/01/12

96/01/12
96/01/13
96/01/15
96/01/16

96/01/17

96/01/1

96/01/19

96/01/19
96/01/19
RC, Slavich
MW
RC
RC
RC
MW
MW
MW, Roberta
Schlicher
MW
MW
RC
ASCW-BE

PTASI
RC
RC
ASCW-BE, Marshall
Cloud
ASCW-BE, Marshall
Cloud
ASCW-BE, Marshall
Cloud
ASCW-BE

ASCW-BE

MW
MW
CoE, Steve Light
CoE
DDRW-Tracy
CoE
CoE
CoE, Huntsville
CoE
CoE

CoE
CoE
CoE, Steve Light
RWQCB, Karen
Bessett
ASCW-BE
CoE
CoE, Steve Light
Michael Work, EPA

DTSC, Jim Pinasco

RWQCB, Karen
Bessett
EPA, DTSC,
RWQCB, CoE,
MW, RC
EPA, DTSC,
RWQCB, CoE,
MW, RC
CoE
CoE
Record File Index - DDJC Tracy (Continued)

Subject

DDRW-Tracy Groundwater Treatment System, Nov. 95 Report

Ltr stating need for more analytical data to evaluate pesticide problem in groundwater at DDRW-Tracy

Draft Soil Stockpile Disposal Evaluation for Day Care Center Technical Memorandum DDRW-Tracy
95% Construction Cost Estimate OU-1
Well Abandonment/Well Installation (Addendum to DDRW-Sharpe Tracy Master Work Plan) Well
Management Task, January 1996
Draft Sampling and Analysis Plan for SMWUs 2 and 3
Draft Sampling and Analysis Plan for SWMUs 2 & 3
100 Percent Design Submittal
95% Design Submittal
95 Percent Remedial Design Report and Analysis for OU-1

95 Percent Construction Specifications, OU-1 Remedial Design, Vol I & 11, Tracy
Final Remedial Action Work Plan for Operable Unit 1, Tracy
Draft OU 1 Two Phase Extraction Treatability Study Summary Report, January 1996
Ltr with Dec 95 report for DDRW-Tracy Groundwater Treatment System

Monthly Monitoring Report for December 1-31, 1995.
Delivery Order 12 Well Monitoring Work Task Proposal
Draft Master Work Plan (Well Management), Sharpe and Tracy
Ltr. reguesting 208 day extension for Draft/Final Risk Assessment, RI/FS, Proposed Plan, and ROD

Ltr. reguesting 208 day extension for Draft/Final Risk Assessment, RI/FS, Proposed Plan, and ROD

Ltr. reguesting 208 day extension for Draft/Final Risk Assessment, RI/FS, Proposed Plan and ROD

Revised Delivery Schedule tor Risk Assessment, RI/FS, PP and ROD

Fax notifying PMM Feb 1, 1996 at Montgomery Watson
OU-1 Explanation of Significant Difference, DDRW-Tracy
Meeting Notes for RPM Meeting February 1, 1996.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/01/22

96/01/24

96/01/24
96/01/24
96/01/25
96/01/26
96/01/26
96/01/20
96/01/26
96/01/26
96/01/29

96/01/29
96/01/29
96/01/30
96/01/30
96/01/31
96/01/31
96/02/01
96/02/01
96/02/05
96/02/05
96/02/05
96/02/05
96/02/19
96/02/20
96/02/21
96/02/22
Author
RWQCB, Antonia
Vorst
Michael Work,
US EPA
RC, Slavich
RWQCB
RWQCB
MW
MW
RC
RC
RC
Michael Work,
US EPA
RC
RWQCB
Hunter Surveying, Inc.
Hunter Surveying, Inc.
RC
RC
MW, Sue Tiffany
PTASI
RC
RC
RWQCB
Marshall Cloud
RC
ASCW-BE
ASCW-BE
Michael Work,
Addressee
Marshall Cloud

Marshall Cloud

Steve Light
DTSC, Jim Pinasco
DDRW-Tracy
CoE
CoE
Steve Light
CoE
CoE
Marshall Cloud

CoE
DTSC, Jim Pinasco
ASCW-BE
ASCW-BE
CoE
CoE
ASCW-BE
DDRW-Tracy
CoE
CoE, Huntsville
Marshall Cloud
CoE
CoE
CAAE, Dennis Lilli
Regulators
Marshall Cloud
9/02/22
US EPA
Stockton Record
ASCW-BE
Subject

Project Manager for DDRW-Tracy be Robert Reeves while Karen Bessette is on leave, 1- 15-96 to 7-1-96.

DDRW-Tracy FFA Schedule Extension Reguest

Regulatory Agency Comment Responses for Draft Final Engineering Evaluation/Cost Analyses
FFA Time Schedule Extension Reguest, DDRW-Tracy Itr.
Tracy WDR's, RWQCB Meeting Agenda for January 25, 1996
Final Well Monitoring Program Low-Flow Sampling Study Report January 1996
OU-1 Pesticides Consensus Statement, DDRW-Tracy
Draft Site-Specific Health and Safety Plan, Sewage Lagoon (SWMUs 2 & 3) Soil Sampling
Final Engineering Evaluation/Cost Analysis (EE/CA) for the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons
Delivery Order 12/13-Preliminary Draft Well Monitoring Program Work Plan Addendum-QAPP
EPA comments on DDRW-Tracy 95% RD Report OU-1 (Jan 96)

Comments on OU-1, 95% Design Review, DDRW-Tracy
Comments, 95% Design Report for Groundwater OU-1, DDRW-Tracy
Record of Survey, portion of Sec. 26.25., R.5E., M.D.B. & M. San Joaguin Country, CA MAP
MAP, Record of Survey a portion of section 35, T.2S., R.5E.,M.D.B. & M. San Joaguin Country - CA
DDRW-Sharpe and Tracy, Mod-A Draft Work Task Proposal for Underground Storage Tank (UST) Project
Delivery Order 12/13-Preliminary Draft Well Monitoring Program Work Plan Addendum
Draft Action Mem for Rem Act, at Ind Waste Ppln, Sew. Laget
Quarterly Monitoring Report; Report Period Oct-Dec 1995 Report Date: February 1996
Draft Action Memorandum for Removal Actions at the Industrial Waste Pipeline, Sewage Lagoons and
Industrial Waste Lagoons
Draft Action Memorandum for Removal Actions
Notice of Adoption of Waste Discharge Reguirements & Initial Study & Negative Declaration for DDRW-Tracy
OU-1 Groundwater Treatment System
Comments OU 1 Two Phase Extraction Treatability Study Summary Report
January Monthly Treatment Plant Performance Monitoring Report
Reguest for meetings to discuss IGIS and Low Flow groundwater sampling program
Fax Project Managers Meeting Feb 29, 1996
Ltr. Final EE/CA for Ind. Waste Pipeline, Sewage Lag. & Ind. Waste Lag. Draft Sampling & Analysis Plan for
SWMUs 2 & 3.
Proof of Publication on EECA for three Tracy Solid Waste Management Unit Sites
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date

96/02/23

96/02/23
96/02/23
96/02/23

96/02/27
96/02/29

96/03/04
96/03/04
96/03/05

96/03/08
96/03/08

96/03/12
Author

RC
Addressee

CEHNC-PM-ED
RC CEHNC-PM-ED
RC CoE
South Pacific Div. Lab CoE Huntsville
MW
RWQCB

RC
RC
ASCW-BE

RC
RC

MW
CoE
DTSC

CoE
CoE
RWQCB, Karen
Bessette
CoE
CoE

CoE
96/03/13
96/03/14
96/03/14
96/03/14
96/03/18
96/03/19

96/03/21
96/03/28

96/03/29

96/04/01
96/04/01
96/04/01
RC
RC
RC
RWQCB
RC
ASCW-BE

RC
ASCW-BE

PTASI

ASCW-BE
MW
MW
CoE
CoE
CoE
ASCW-BE
CoE
RWQCB, Karen
Bessette
CoE
Regulators,
CEHNC, MW, RC,
CoE-Sac
ASCW-BE, John
Guzman
CoE Regulators
CoE, Huntsville
CoE, Huntsville
Subject

Final Addendum #2 to Comprehensive Field Work Plan for DDRW-Tracy/Sharpe, Sampling and Analysis Plan
for SWMUs 2 and 3.
Comment Responses for Sampling and Analysis Plan/Health and Safely Plan
Final Soil Stockpile Disposal Evaluation for Day Care Center Technical Memorandum
QA Testing, 4th Quarter CY95, Interim Reports for Total Mercury for LM123B, EWA-08, MW402C LM30AA,
LM38A, LM99A, LM102B
Ltr. DDRW-Tracy Background Agreements
EE/CA for the Industrial Waste Pipeline, Sewage Lagoons & Ind Waste Lagoons, Draft Sampling & Analysis
Plan & Action Memo for Removal Actions, DDRW-Tracy
Draft Comprehensive Field Work Plan March 1996, Vol I & II
Draft Well Monitoring Work Plan, Addendum No. 4 to the Comprehensive Field Work Plan
Ltr enclosing Monthly Waste Discharge Requirement Order # 96-021 Report for DDRW-Tracy for Jan 1996.

Draft Solidification Treatability Study Work Plan for SWMUs 2 & 3
Draft Request for Temporary Operating Change Waste Discharge Requirements for DDRW-Tracy Wastewater
Treatment Plant, San Joaquin County
Meeting minutes and videotapes from Feb 29, 1996 Tracy Program Managers Meeting; Formal response to
comments on the Draft RI/FS
Delivery Order 12-Work Task Proposal for Tracy Well Monitoring Program
95% Construction Cost Estimate OU-1
February Groundwater Treatment Plant Monthly Performance Monitoring Report, DDRW-Tracy
Underground Storage Tank Closure Report, DDRW-Tracy
Draft UST Site Investigation Work Plan, Add. 6 to the Comp. Field Work Plan for DDRW-Sharpe/Tracy
Ltr with report for DDRW-Tracy Groundwater Treatment System, February 1996

Modification A-Final Work Task Proposal for Underground Storage Tank Project, DDRW-Sharpe and DDRW-Tracy
RPM Meeting announcement for Apr 18-19, 1996, DDJC, 9:30 am

Sharpe/Tracy Project CDAP/Work Plan Revisions for Monitoring Well Sampling & Analyses at DDRW Tracy
Site
Project Manager's Meeting to be held April 18-19, 1996 at the Tracy site
100 Percent Construction Specifications Vol I & II, DDRW-,Tracy, April 1996
Final Operable Unil Remedial Action Design Report and Analysis
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/04/09
96/04/12
96/04/12
Author

Michael Work,
US EPA
RC

RC
Addressee
Subject
Marshall Cloud EPA Comments on Response to EPA Comments on the Comprehensive RI/FS for DDRW-Tracy
96/04/12
96/04/16
96/04/18
96/04/21
96/04/26
96/04/30
96/04/30
96/05/10
96/05/14
96/05/14
96/05/14
96/05/15
96/05/17
96/05/17
96/05/20
96/05/20
96/05/20
96/05/28
96/05/31
96/06/01
96/06/06
RC
RC
RC
MW
RC
MW
RC
RWQCB
MW
RC
RC
ASCW-BE
RC
RC
COE, Huntsville
RC
RC
EPA
ASCW-BE
DDRW-Tracy
RC
CoE, Huntsville

CoE, Huntsville

CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE Huntsville
Marshall Cloud
CoE, Huntsville

CoE, Huntsville
CoE, Huntsville
Property owners
adjacent to Tracy
Site
CoE, Huntsville

CoE, DTSC,
RWQCB,EPA
Marshall Cloud
CoE, Huntsville

CEHNC
Marshall Cloud
RWQCB, Karen
Bessette
Public, Residents

ASCW-BE
Final Action Memorandum for Removal Actions at the Industrial Waste Pipeline, Sewage Lagoons, and
Industrial Waste Lagoons
Comment Responses For Final EE/CA, Draft Action Memo for Removal Actions at the Ind. Waste Pipeln,
Sewage Lagoons, and Ind Waste Lagoons, & Draft Sampling & Ana. Plan SWMUs 2 & 3
March Monthly Treatment Plant Performance Monitoring Report, DDRW-Shapre/Tracy
Preliminary Draft DDRW-Tracy Well Monitoring Program, 1995 Annual Monitoring Report
Draft UST Site Investigation Field Work Report for DDRW Tracy.
Final Update Construction Cost Estimate OU 1, DDRW-Tracy April 1996
Draft Preferred Alternatives Report for UST Sites 7,9, 10 & 20

RPM meeting minutes for April 18, 1996
Notice of Amended Waste Discharge Requirements for DDRW-Tracy Wastewater Treatment Plant
Submittal of Response to Comments on Draft Comprehensive Site-Wide Baseline Risk Assessment & Tech
Memo, Human Health Risk Assessment at Exposure Units 1, 2, and 7.
April Monthly Treatment Plant Performance Monitoring Report (Well Monitoring), DDRW-Sharpe
Final Underground Storage Tank Closure Report for DDRW-Tracy
Ltr with test results for Oct-Dec, 1995

Ltr with report submission-Well Monitoring Program Quarterly Monitoring Report First Quarter 1996 Sampling
Round, DDRW-Sharpe & Tracy
Well Monitoring Program Quarterly Monitoring Report First Quarter 1996 Sampling Round, DDRW Tracy and
Sharpe
Map,Topographic Surveys of Sewage Lagoons, Industrial Waste Lagoons, & Industrial Waste Pipeland
Del Order 0004,60% Removal Action Design for SWMUs 2, 3, and 33 Drawings, Specifications and Design
Analysis Report (2 Books)
Cone Penetrometer Testing-CPT Results, DDRW-Tracy (Robertson Property)
EPA Comments on DDRW-Tracy's 100 percent RD for OU-1
April 96 Report for DDRW-Tracy Groundwater Treatment System

Fact Sheet #1, Environmental Update, Depot Uses Environmental Evaluation/Cost Analysis (EE/CA) to Speed
Cleanup at Three Waste Sites
Administrative Record Audit, DDRW Sharpe/Tracy
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/06/06
96/06/11
96/06/12
96/06/14
96/06/14
96/06/17
96/06/18
96/06/20
96/06/20
96/06/24

96/06/28
96/06/29
96/07/01
96/07/01
96/07/12
96/07/12
96/07/12
96/07/15
96/07/15
96/07/15
96/07/19
96/07/19
96/07/22
Author
RC
RC
ASCW-BE
RC
RC
ASCW-BE
RC
MW
RC
Michael Work,
US EPA
RC
RC
RC
US EPA
RC
RC
RC
RC
RC
RC
RC
RC
ASCW-BE
96/07/22
RC
96/07/23 ASCW-BE
96/07/23 Michael Work,

96/07/29 ASCW-BE
96/07/31 RC
Addressee

ASCW-BE, John
Guzman
CoE, Huntsville
Regulators,
CEHND, MW, RC
CoE, Huntsville
CoE, Huntsville
RWQCB, Karen
Bessette
CoE, Huntsville
Marshall Cloud
CoE
Marshall Cloud

CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
DTSC, RWQCB,
ASCW-BE
ASCW-BE
CoE, Huntsville
COE, Huntsville
CoE, Huntsville
Regulators
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
RWQCB, Karen
Bessette
CoE, Huntsville

CoE, Steve Light
Marshall Cloud
US EPA
Tracy Residents
CoE, Huntsville
Subject

Administrative Record Audit for DDRW Sharpe Tracy

IGIS User Guides, Final
RPM Meeting invitation for July 15-16,1996, DDSJ

Final Comprehensive Field Work Plan, DDRW-Sharpe & DDRW-Tracy Vol I -Text & Vol 2-QAPP
May 1996 Monthly Treatment Plant Performance Monitoring Report (Well Monitoring)
Ltr. accompanying Monthly Report for Monitoring and Reporting Order No. 96 for May 1996

Final UST Site Investigation Field Work Report for DDRW-Tracy
Low Flow Pump Preliminary Analysis
Draft Hazardous Material Storage Addition to Warehouse 28 Environmental Assessment
EPA Comments on DDRW-Tracy's 60% Removal Action Design for SWMUs 2, 3, and 33, May 1996

Draft Well Monitoring Program 1995 Annual Monitoring Report
Draft Child Care Facility Closure
90% Removal Action Design for SWMUs 2, 3, and 33 Design Analysis Report
Ltr Informant Dispute, DDRW-Tracy Comprehensive RI/FS Baseline Risk Assessment (BRA) and added
comments from July 8, 1996 conference call
Final Draft Administrative Record Assessment Report
Groundwater Treatment Plant Monthly Performance Monitoring Report - June
Groundwater Treatment Plant Monthly Performance Monitoring Report - June 1996
90% Removal Action Design for SWMUs 2, 3, and 33 Specifications
DDRW-Tracy OU-1 Well Installation Status
Comments from RWQCB to include in Final UST Site Investigation Work Plan
Draft Waste Management Plan, DDRW-Sharpe and Tracy
Draft Waste Management Plan, Sharpe and Tracy
Ltr attached to Tracy site monthly Monitoring Report for June 1-30, 1996

Well monitoring Program Quarterly Monitoring Report Second Quarter 1996 Sampling Round, DDRW-Sharpe
and DDRW-Tracy
DDRW Tracy Air Stripper Scaling Problem
EPA Input to DDRW-Tracy's Comprehensive RI/FS/BRA

Test Results from drinking water wells, Jan-Mar 1996
Final Well Monitoring Program Field Work Plan
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
96/07/31
96/08/01
96/08/05

96/08/05
96/08/07
96/08/07
96/08/08
96/08/12
96/08/12
96/08/12
96/08/13
96/08/13
96/08/13
96/08/14
96/08/15
96/08/15
96/08/16
96/08/16
96/08/18
96/08/21
96/08/21
96/08/30
96/09/06
96/09/06
96/09/06
96/09/06
96/09/06
96/09/09
96/06/12
RWQCB
EPA
Michael Work,
US EPA
RC
ASCW-BE
ASCW-BE
MW
ASCW-BE
CEHND
RC
MW
MW
RC
MW
EPA
RC
RC
RC
MW
ASCW-BE
ASCW-BE
RC
MW
RC
RC
RC
RC
EPA
ASCW-BE Re
Addressee

ASCW-BE
ASCW-BE
Marshall Cloud

CoE, Huntsville
RWQCB Karen
Bessette
RWQCB, DTSC,
EPA
CEHND
EPA, Michael Work

MW
ASCW-BE
DTSC
DTSC
CEHND
CEHND
ASCW-BE

CoE
CoE, Huntsville
CoE, Huntsville
COE
RWQCB
RWQCB
CoE, Huntsville
RWQCB
COE, Huntsville
COE, Huntsville
COE, Huntsville
CEHNC
DDRw-Tracy
Regulators, Radian,
Subject

Ltr Well installation Work Plan, DDRW-Tracy
Region 9 Preliminary Remediation Goals (PRGs) 1996
Ltr Response to EPA Comments, Final Comprehensive RI/FS Phase II & III Analytical Data Report

Draft OU I Repairs and Enhancements Work Plan
Ltr with info closure of USTs

Transmittal page with Final Well Monitoring Program Field Work Plan

Draft Final Comprehensive Site-Wide Baseline Risk Assessment
Ltr reguesting two day extension from 8/13/96 to 8/15/96 for DDRW-Tracy Draft Final Comprehensive
Remedial Investigation Feasibility Study
Revised Final Comprehensive RI/FS - Phase II and Phase III Analytical /Data Report to Vol I-III
RPM Meeting Minutes for July 15-16, 1996
Draft Final Baseline Risk Assessment
Ltr w/Draft Final Baseline Risk Assessment
July monthly Treatment Plant Performance Monitoring Report, DDRW-Tracy
Comprehensive Draft Final RI/FS Vol I-III
Response to Tracy's reguest for a 2-day FFA schedule extension, Comprehensive RI/FS/BRA/PP Extension
approved to 8/15/96.
Final Preferred Alternatives Report for UST Sites 7,9, 10, and 20
Draft Final Environmental Master Plan
Final Waste Management Plan (Addendum to Comprehensive Field Work Plan for Sharpe/Tracy
Response to Comments Received on the Draft Comprehensive RI/FS
Tracy Monthly Report for Monitoring and Reporting Order for July 1996
Ltr scaling problem with air stripping system, Tracy Site
Final OU-I Repairs and Enhancements Work Plan
Ltr Aerial Photos at DDRW-Tracy
Draft Final Administrative Record Assessment
Final Child Care Facility Closure Report, DDRW-Tracy
Modification 2, OU I Repairs and Enhancements, PLC I/O Point Lists
Final Drum Storage Facility Environmental Assessment
DDRW-Tracy Well Monitoring Program, Quarterly Monitoring Report Second Quarter 1996 Sampling Round, July 1996
Announcement of RE/FS Approval Meeting for Oct 9-10, 1996 to discuss outstanding issues only.
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
96/09/13
96/09/13
96/09/17

96/09/19
96/09/26
96/09/27
96/10/01
96/10/03
96/10/04
96/10/10
96/10/14
96/10/15
96/10/16

96/10/18

96/10/21
96/10/21
96/10/29

96/10/31
96/10/31
96/11
96/11/01
96/11/01
96/11/04

96/11/05
96/11/06

96/11/08
96/11/12
96/11/12
96/11/18
RC
RC
RC

RC
EPA
ASCW-BE
RC
ASCW-BE
RC
MW
RC
EPA
ASCW-BE

Michael Work,

ASCW-BE
MW
Michael Work,
US EPA
RC
RC
Radian
MW
MW
CoE, Huntsville
CEHNC
CEHNC, DDRW-
Tracy
CEHNC
DDRW-Tracy
RWQCB
CoE, Huntsville
RWQCB
CEHNC
CEHNC
CEHNC
ASCW-BE
RWQCB, Karen
Bessette
Marshall Cloud
US EPA
EPA, Michael Work
CoE, Huntsville
ASCW-BE

ASCW-BE
CEHND
CoE, Huntsville
CEHNC
CEHNC
Davy International CoE, Sacramento
Environmental
Division
RWQCB
ASCW-BE,

RWQCB
RC
RC
RC

ASCW-BE
CEHNC, DTSC,
RWQCB, EPA, RC
ASCW-BE
CEHNC
CEHNC
CEHNC
Subject

Groundwater Treatment Plant Monthly Performance Monitoring Report-August
Final Hazardous Material Storage Addition to Warehouse 28 Environmental Assessment
Technical Memorandum Maintenance of Existing Low Flow Pumps-Summary and Results

DDRW-Tracy Solidification Treatability Study
Ltr Draft Comprehensive RI/FS/BRA/PP DDRW-Tracy, Aug 96
Monthly Monitoring Report for Aug 1-31, 1996
Final DDRW-Tracy Well Monitoring Program, 1995 Annual Monitoring Report
Ltr to describe calcium carbonate scaling problem with air stripper and action taken to improve.
Draft Waste Water Treatment Plant Effluent Diversion, Drawings and Specifications
Draft Groundwater Treatment System Optimization Work Plan
Groundwater Treatment Plant Monthly Performance Monitoring Report-September 1996
Fax questioning review period for ROD documents
Ltr with Tracy Monthly Monitoring and Reporting Order 96 for Sep, 1996

DDRW-Tracy Extension, Comprehensive RI/FS

Ltr Proposed document extension dates.
Meeting /Telecons Conducted Oct 9, 10, 15, 18, 1996
Ltr DDRW-Tracy Extension for the Comprehensive RI/FS/PP/BRA

Draft Environmental Program Status Briefing Report October, 1996, DDRW-Tracy
Well Monitoring Program Quarterly Monitoring Report Third Quarter 1996 Sampling Round
Final Comprehensive Site-Wide Proposed Plan.
Final DDRW-Tracy Response to Comments oil the Draft Final Comprehensive RI/FS Nov 1996
Proposed Plan Information Booklet
Draft Project Work Plan, DDRW-Sharpe & Tracy, Petroleum Contaminated Soil Removal

Fax Comprehensive RI/FS Documentation - COG's to be considered for clean up levels.
Fax Notice of Projected Managers Meeting November 29-21, 1996

Fax feedback on draft response to comment Comprehensive RI/FS Report
Groundwater Treatment Plant Operation and Maintenance Monthly Progress Report for October 1996
Groundwater Treatment Plant 0& M Monthly Progress Report for Oct 1996, DDRW-Sharpe/Tracy
Groundwater Treatment Plant Monthly Performance Monitoring Report-October
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
96/11/21
96/11/25
96/11/26

96/11/26
96/11/27
96/11/27
96/11/27
96/11/27
96/12/02
96/12/02
96/12/10
96/12/12
96/12/13
96/12/13
96/12/13
96/12/13
96/12/16
96/12/17
96/12/19

96/12/18
96/12/18
96/12/19
96/12/19
96/12/19
96/12/19

96/12/21
96/12/31
96/12/31

97/01/02
97/01/03
97/01/06
Author
MW
ASCW-BE
ASCW-BE

RC
RC
RC
RC
RC
EPA
RC
RC
RC
EPA
RC
RC
RWQCB
Addressee
CEHNC
RWQCB
RWQCB, Karen
Bessette
CEHNC
CEHNC
CEHNC
CEHNC
COE
ASCW-BE
CEHNC
CEHNC
CEHNC
ASCW-BE
CEHNC
CoE, Huntsville
ASCW-BE
DTSC,Jim Pinasco DTSC, Brian Davis
RC
ASCW-BE

RC
RC
ASCW-BE
ASCW-BE
ASCW-BE
RC

MW
EPA
Pacific Legacy

RC
Radian
RC
CoE
ASCW-
BPM/ASCW-WG
CoE
CoE
RWQCB
SJCPHS
RWQCB
EPA, RWQCB,
DTSC
CEHNC
ASCW-BE
DDRW-DDJC
Tracy Site
DTSC
CoE, Huntsville
CoE
Subject

Final Comprehensive RI/FS, Appendix R: Comprehensive Site-Wide Baseline Risk Assessment Vol V
November 1996
Ltr Tracy Monthly Report for Monitoring and Reporting Order No. 96 for Oct, 1996
Ltr reguest variance of Waste Discharge Reguirement for the groundwater pump & treat operation, Tracy

Revision Itr re: OU I Repairs and Enhancements Work Plan August 1996
Technical Memorandum of DDRW Tracy Storm Water Pond Investigation
Report of Field Activities and Results for Samples Collected at the DDRW-Tracy Storm Water Pond
Ltr Report of Field Activities and Results for Samples Collected at the DDRW-Tracy Storm Water Pond
Ltr Report of Field Activities and Results for Samples Collected at the DDRW-Tracy Storm Water Pond
Ltr DDRW-Tracy Well Monitoring Program, Quarterly Monitoring Report
Final Waste Water Treatment Plant Effluent Diversion Drawings and Specifications November 1996
Environmental Master Plan Version 1.0, DDRW-Sharpe/Tracy, December 1996
Groundwater Treatment Systems Operation and Maintenance Monthly Update Report-November
Ltr EPA Comments on the Replacement Pages for the Comprehensive RI/FS for DDRW-Tracy
Draft Well Monitoring Program 1996 Annual Monitoring Report
Project Manager's Meeting Minutes for Dec 4-5, 1996
RWQCB comments to RI/FS for Tracy site
Ltr DDRW-Tracy Draft Response to Draft Final Comprehensive RE/FS for Nov 96
Final Scale Study Report for DDRW-Sharpe and DDRW-Tracy
Proposed Rail Over Crossing at DDRW-San Joaguin, Tracy Site

November Monthly Plant Performance Monitoring Report (Well Monitoring)
November Monthly Treatment Plant Performance Monitoring Report (well Monitoring), DDRW-Tracy
Monthly Monitoring Report for Nov 1996
Ltr with Quarterly Monitoring Report
Tracy Monthly Monitoring and Reporting Order No. 96 for Nov 1996
Ltr with Submission of Technical Memorandum for DDRW-Tracy Storm Water Pond Field Effort

Final Comprehensive RI/FS Vol I-III November 1996
First Quarter 1997 Groundwater Sampling Event/Recommendations DDRW-Tracy
Final Archeological & Architectural Inventory & Evaluation fr the DDJC Tracy Site

Ltr Preliminary Recommendations for 1997 Groundwater Monitoring Program DDRW-Tracy
Prelim Draft Well Monitoring Program Field Work Plan, DDRW-Sharpe/Tracy
Draft Acid Cleaning Work Plan (January 1997)
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
Author
Addressee
97/01/08
97/01/09
97/01/14
97/01/15
97/01/16
97/01/17
97/01/20
97/01/21
97/01/22
97/01/22
97/01/24
97/01/27

97/01/27
97/01/31

97/01/31
97/10/31
97/02/04
97/02/06
97/02/10
97/02/10
97/02/11
97/02/13

97/02/18
97/02/19

97/02/24
97/02/25
RC
RC
DTSC
RC
RC
ASCW-BE
RC
RC
Davy Int .
EPA
EPA
ASCW-BE

RC
DDRW-DP

RC
RC
ASCW-BE
ASCW-BE
RC
RC
Radian
ASCW-BE

Radian
CoE, Huntsville
CoE, Huntsville
ASCW-BE
CoE
CoE
RWQCB
CoE
CoE
CoE, Sacramento
ASCW-BE
ASCW-BE
RWQCB, Karen
Bessette
CoE
Public, residents
near Tracy
CoE, Huntsville
CoE, Huntsville
Public
RWQCB
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
Tracy private well
residents
CoE, Huntsville
Peters Shorthand ASCW-BE
Reporting
EPA
CoE, Sac

ASCW-BE
ASCW-BE
Subject

Draft Comprehensive Record of Decision for Tracy
Final Groundwater Treatment System Optimization Work Plan for DDRW-Sharpe/Tracy
Ltr comments Final Comp RI/FS, DDRW-Tracy
Groundwater Treatment Systems Operation & Maintenance Monthly Update Report-December
Groundwater Treatment Plant Monthly Performance Monitoring Report - December 1996
Ltr request modification of the WDR. Change for Monuron or Diuron to meet achievable levels.
Response to Comments on the DDRW-Tracy Well Monitoring Prog. Qtrly Mon Rep., Second Qrt 96 Sampling
Round & Tracy Well Monitoring Prog Qrt Mon. Rep, Third Qtr 96 Sampling Round
Final Site Remediation for the Sewage & Industrial Waste Lagoons, & the Industrial Waste Pipeline Drawing &
Specifications January 97
Final Project Work Plan Sharpe/Tracy, Petroleum Contaminated Soil Removal
Draft Ltr Finalization of Tracy Comp RI/FS, Comments on Overall Quality of Doc, Counsel Comments EPA-
Need for Res of Env Issue from Tech Memo on the Storm Water Pond
Ltr, Finalization of Tracy Comp RI/FS, Comments on Overall Quality of Doc., EPA Region 9 Counsel
Comments, Need for Resolution of Env Issue Raised in Tech Memo for Storm Water Pond
Cover Itr for Tracy's monthly report for Monitoring & Reporting Order #96.

Final 100% Design Site Remediation for the Sewage & Industrial Waste Lagoons, & the Industrial Waste
Pipeline Design Analysis Report January 97
Special Announcement letter inviting public to the Proposed Plan Update and soliciting TRC members

Draft Site-Wide Comprehensive Record of Decision for DDRW-Tracy
Draft Engineering Technical Memorandum OU-1 Well Installation - January 1997
Mailer with Fact Sheet #2, the Proposed Plan info and the Special Announcement letter from the Commander
Transmittal re Waste Discharge Requirements Order #96-122
Groundwater Treatment Systems Operation & Maintenance Monthly Update Report - January
Final Acid Cleaning Work Plan for DDRW-Tracy
Draft Low-Flow Sampling System Installation Work Plan
Results for samples taken July - September 1996.

January 1991 Monthly Treatment Plan Performance Monitoring Report (Well Monitoring) DDRW Tracy
February 19, 1997 Meeting Minutes for Proposed Plan for the Final Cleanup Project

Draft Annual Monitoring Report 1996 DDRW-Tracy
Final Warehouse 28 Well Replacement DDJC, Tracy Site
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
97/03/05
97/03/06
97/03/06
97/03/07
97/03/07
97/03/10
97/03/10
97/03/11
97/03/18
97/03/24
97/03/26

97/03/28
97/03/28
97/03/31
97/04/01
97/04/01
97/04/10
97/04/10
97/04/16
97/04/17
97/04/23
97/04/25
97/04/29
97/04/29
97/05/05
97/05/07
97/05/12
97/05/15
97/05/16
97/05/19
97/05/21
Author
ASCW-BE
Mont Watson
Mont Watson
Radian
Radian
CoE, Sac
Radian
ASCW-BE
Radian
Radian
ASCW-BE

ASCW-BE
Radian
Radian
ASCW-BE
DTSC
ASCW-BE
Radian
Radian
ASCW-BE
Radian
ASCW-BE
Radian
Radian
EPA
ASCW-BE
Radian
Radian
Radian
COE'S
EPA
Addressee
RWQCB
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
ASCW-BE
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, Huntsville
CoE, H & CoE Sac
Real Est
DTSC
CoE, Huntsville
CoE, Huntsville
RWQCB
ASCW-BE
Residents
CoE, H
CoE, H
Residents
CoE, S
RWQCB
CoE, H
CoE, H
ASCW-BE
TRC Members
ASCW-BE
CoE, II
CoE, II
ASCW-BE
ASCW-BE
Subject

Ltr to accompany Jan 97 Monthly Plant Performance Monitoring Report (Well Monitoring) DDRW-
Tracy
Response to comments and slip Sheets On O&M Manual
Response to comments & slip sheets on Extended Prove-out Report
Groundwater Treatment systems Operation and Maintenance Monthly Update Report for Dec 96
Acid Cleaning Evaluation and Prove-Out, (Technical Memorandum)
Ltr OU-I Contract Award
Final Well Monitoring Program Field Work Plan DDRW-Sharpe/Tracy
Response to EPA draft Annual Monitoring Report Comments
Groundwater Treatment Plant Monthly performance Monitoring Report - February
Final Low-Flow Sampling System Installation Work Plan for DDRW-Sharpe/Tracy
Ltr DDRW Tracy Railroad Easement Reguirements

Ltr: Draft Record of Decision
Final Well Monitoring Program 1996 Quality Assurance Procedures Technical Memorandum
Preliminary Draft Groundwater Treatment System Optimization Engineering Technical Memorandum, DDRW-
Sharpe/Tracy
Ltr with Tracy's monthly report for Monitoring & Reporting Order No. 96 for Feb, 1997
Ltr Extension for comments concerning the Draft Site-Wide Comprehensive ROD, DDRW-Tracy Site
Private Well Test Results for Oct - Dec 1996
Groundwater Treatment Systems Operation & Maintenance Monthly Update Report - March
Groundwater Treatment Plant Monthly Performance Monitoring Report - March 97
Ltr Test Results from Private Wells for Jan - Mar 1997
OU-I Groundwater Treatment System, Project Work Plan
Ltr Monthly Report for Monitoring for March 1997
Well Monitoring Program Well Sampling Data Sheets Fourth Quarter 1996 Sampling Round
Well Monitoring Program 1996 Annual Monitoring Report
Ltr Five Year Review
Ltr TRC Meeting Date and Committee Member Acceptance
Map of Proposed Robertson Wells
Systems Operation & Maintenance Monthly Update Report-April for Sharpe & Tracy
Ground water Treatment Plant Monthly Performance Monitoring Report - April
Site Remediation for the Sewage & Industrial Waste Lagoons, and the Industrial Waste Pipeline, Scope & Specifications
Ltr Draft Comprehensive ROD (Feb 97), DDRW, FFA Schedule
-------
Administrative Record File Index - DDJC Tracy (Continued)
Date
97/06/05
Author
Radian
97/06/27
97/06/25
97/06/23
97/06/25
97/05/30
Radian
ASCW-BE
ASCW-BE
Radian
Radian
Addressee
COE, H
97/05/29 ASCW-BE
96/11/21 Kvaerner Davy
97/06/09 Radian
97/06/13 Kvaerner Davy
97/06/17 Radian
97/06/30 Radian
RWQCB
COE, S
ASCW-BE
COE, S
COE, H
CoE, H
COE, H
Joe Rose
RWQCB
COE, H
COE, H
Subject

Well Monitoring Program Quarterly Monitoring Report First Quarter 1997 Sampling Round (DDRW-Tracy-
June 1997)
Ltr with Tracy Monitoring and Reporting Order No. 96 report for April 1997
Technical Proposal OU-1 Groundwater Treatment DDRW-Tracy
Ltr Second Quarter Analytical Results for Private Well & Tap Locations, Rose Property
OU-1 Groundwater Treatment System, Performance Monitoring Report-Plant 1, May 1997
Groundwater Treatment Systems Opr & Maintenance Monthly Update Report for May 1997
Draft Design Site Remediation for the Sewage & Ind. Waste Lagoons and the Waste Pipeline,
Modification 1
Draft Limited Sguestration System Operation Engineering Technical Memorandum
Ltr test results of PW 1 from April to June 1997
Ltr with Tracy Monitoring and Reporting Order No. 96 report for May 1997
Information Repository Bioremediation Technology Evaluation Doc. Draft Technology Evaluation Work Plan
Revised Work Plan Addendum-Sampling of EW 30C, OU-1 Well Installation (April 1996)
-------
APPENDIX B

FIGURES

-------
APPENDIX C

SWMU 4 TECHNICAL MEMORANDA

TECHNICAL MEMORANDUM

Analysis of SWMU 4 - Storm Drain Lagoon
(DACA87-95-D-0001 Delivery Order 014)

SWMU 4 - Storm Drain Lagoon

Background

SWMU 4 is a storm water retention lagoon that collects all storm water runoff from DDRW-Tracy
through a network of underground storm drains and open surface drainage ditches (see Figure
C-l). Semivolatile organic compounds (SVOCs)-including polycyclic aromatic hydrocarbons
(PAHs)-pesticides, and metals have been detected in the lagoon sediment. The Final Comprehensive
Remedial Investigation/Feasibility Study (RI/FS) (Montgomery Watson, 1996a) identified SWMUs 2
and 3, SWMU 8, and SWMU 33 as the primary source areas for pesticides in groundwater; however,
SWMU 4 was also considered a potential source area. Vadose zone modeling was performed and
eguilibrium partitioning limits were determined to develop cleanup standards to protect
beneficial uses and background groundwater guality for SWMU 4. These results were the primary
drivers for defining the scope of the remedial alternatives that were developed in the RI/FS.
Radian has reevaluated the likelihood of impacts to groundwater from sediment and soil
contamination at SWMU 4 using new subsurface soil results (collected just above the water table)
and groundwater monitoring data (see discussion below).

The RI/FS also identified potential impacts to ecological receptors at SWMU 4. The potential
impacts to ecological receptors were not a factor in determining the scope of excavation for the
selected remedy. The contaminants responsible for the estimated risk were mingled with the
contaminants responsible for water guality concerns and were addressed simultaneously through
excavation to address the water guality impacts. As a result, a screening level assessment of
the risk to ecological receptors was performed. The hazard index in the RI/FS was determined
using literature values rather than site-specific data. Using a hazard index of 10, the
screening-level assessment identified ODD, DDE, DDT, and selenium in the lagoon sediment as
potential threats to ecological receptors. Human health is not threatened under either the depot
worker or the construction worker scenario. The uncertainties of the risk assessment have now
been reviewed (see below) and several assumptions were identified that are highly conservative.

Assessment of SWMU 4 as a Potential Source of Contamination in Groundwater

Although SWMU 4, the DDRW-Tracy storm water detention pond, cannot be dismissed as a potential
source of contaminants in groundwater, there is little evidence that contaminants in the
sediment or the soil beneath the pond have affected or will adversely affect groundwater.
Because the concentrations of contaminants in the sediment and the soil beneath the storm water
pond do not indicate a current threat to groundwater guality, no further action to protect
groundwater guality is warranted at SWMU 4 (see Figures C-2a and C-2b for soil and sediment
sampling results). This conclusion is supported by four points:

1. The October 1996 Subsurface Sampling Results Show That Migration from the Surface Sediment
to the Subsurface Soil Is Minimal. The concentrations and numbers of analytes that exceed
background or cleanup concentrations are much lower in the soil samples collected at 1 to
1.5 feet below the bottom of the pond than in the sediment samples collected from 0 to 6
inches below the bottom of the pond (see Table 1). The compounds that are present in the
soil at concentrations greater than background levels (ODD and the PCB Arochlor 1260) have
not been detected in groundwater samples from downgradient monitoring wells (LM004A and
LM027AA). Dieldrin was detected above the practical guantitation limit (3 Ig/kg) in only
one soil sample collected from deeper than 6 inches.

The data from fourteen surface sediment samples (0 to 6 inches below the bottom of the
pond) collected during the remedial investigation (Montgomery Watson, 1996a) and 18
subsurface soil samples collected above the water table (1 to 1.5 feet below the bottom of
the pond) (Radian, technical memorandum, 27 November 1996) indicate that the number of
-------
compounds and their concentrations decrease with depth beneath the storm water pond. The
surface sediment samples had one to five SVOCs reported; however, no SVOCs were reported in
the subsurface soil samples. The PCB Arochlor 1260 was detected in eight surface sediment
samples at concentrations of 41 to 459 Ig/kg; however, this contaminant was only detected
in one of the 18 subsurface soil samples (at a concentration of 160 Ig/kg).

No urea-carbamate pesticides or chlorinated herbicides were reported in the subsurface
soil samples. The pesticide DDD was detected in all the surface sediment samples at
concentrations of 31 to 2,310 Ig/kg. Although this compound was detected in 14 of the 18
subsurface soil samples from 1 to 1.5 feet below the bottom of the pond, the concentrations
ranged from 1.5 to 380 Ig/kg, and only four concentrations were above soil background
concentrations (28.1 Ig/kg) for DDRW-Tracy. The concentrations of DDT, which was detected
in four subsurface soil samples, and DDE, detected in ten subsurface soil samples, were all
less than the soil background concentrations of 2,565 Ig/kg and 1,284 Ig/kg, respectively.
Dieldrin was reported in four surface sediment samples and four subsurface soil samples;
however, the highest reported concentration in the subsurface soil (6.5 Ig/kg) was less
than the lowest concentration in the surface sediment samples.

2. DI-WET Results for Subsurface Soils Do Not Indicate Any Confirmed Impacts to Water Quality.
One subsurface soil sample that had measurable concentrations of DDE (73 Ig/kg), DDD (380
Ig/kg), DDT (1.1 Ig/kg), and dieldrin (2.7 Ig/kg) was subjected to the waste extraction
test with de-ionized water (DI-WET) to determine what fraction of the compounds may be
leachable. Analyses of the leachate from the sample only showed reportable concentrations
of DDE (0.13 Ig/L) and DDD (1.1 Ig/L). DDT and dieldrin concentrations were below reporting
limits in the leachate. Although the leachate results suggest that there is potential for
the frequently reported DDD and DDE to adversely affect groundwater, neither DDD nor DDE
have been reported in any samples collected from LM004A and LM027AA, the wells closest to
SWMU 4 in the downgradient direction.

3. Only Dieldrin Has Been Detected in Both Surface Sediment and Subsurface Soil Samples and in
Downgradient Monitoring Wells. Only dieldrin (one of six samples from LM004A and one of 11
samples from LM027AA), monuron (two of four samples from LM027AA, none from LM004A), diuron
(one of two samples from LM004A and three of four from LM027AA), simazine (one of one from
LM027AA), and manganese (one of one from L14027AA) detections have indicated any adverse
impact on groundwater. However, dieldrin is the only one of these compounds reported in the
groundwater samples that was also reported above background levels in the surface
sediment or subsurface soil samples from the pond.

4. Dieldrin Has Not Been Measured in Downgradient Wells Since 1994. Dieldrin has been detected
in one of six LM004A groundwater samples and one of 11 LM027AA samples. In July 1993, a
dieldrin concentration of 0.011 Ig/L was measured at LM004A. In 1995 and 1996, all dieldrin
results were less than the reporting limit of 0.10 Ig/L Between 1987 and 1993, dieldrin
concentrations at LM027AA ranged from less than 0.005 Ig/L (detection limit) to 0.11 Ig/L.
All dieldrin results were less than the reporting limit (0.1 Ig/L) in 1995 and 1996.

Conclusion. The surface sediment, subsurface soil, soil leachate, and groundwater results
suggest that SWMU 4 is not now, and is unlikely to be in the future, a source of contamination
in groundwater. Although there has been an almost constant downward driving force of standing
storm water in the pond, contaminant concentrations exceeding background levels in the
sediment have not been driven into the groundwater in the 25 years that the pond has been used.
It is not clear from the groundwater analyses that the dieldrin, monuron, and diuron detected in
the groundwater samples can be attributed to the storm water pond. There is no clear evidence
that the remediation of the soil at this site would have any effect on groundwater quality.

The cost of excavating all soils above cleanup standards based on equilibrium partitioning
limits is estimated as $700,000. The above analysis shows that the benefits associated with
excavation at SWMU 4 are doubtful and, therefore, funding excavation to address unlikely
groundwater impacts is not warranted at this site.

Assessment of Impacts to Ecological Receptors

The Final Comprehensive Baseline Risk Assessment (Montgomery Watson, 1996a) provided a screening
level assessment of the risk to ecological receptors at SWMU 4. Spotted sandpipers and great
-------
blue herons were identified as receptors with completed pathways at SWMU 4. DDT, DDE, ODD, and
selenium were identified as contaminants of concern for ecological receptors at SWMU 4 (see
Section 6.6.5 in the draft Record of Decision [Radian, July 1997]). Because of uncertainties in
the assessment of ecological risk, the risk assessment does not provide a good basis for scoping
a remedial action at SWMU 4. The following uncertainties were identified.

1. The Presence of Selenium Above Background Concentrations At SWMU 4 is Questionable. The
risk assessment (Montgomery Watson, 1996a) indicated that the analytical results for
selenium were uncertain. Six surface sediment samples with selenium results ranging from
15.5 to 31.3 mg/kg were considered guestionable and reanalyzed by Montgomery Watson during
the remedial investigation. When reanalyzed, five of these samples had no detectable
selenium above a detection limit of 0.3 mg/kg, and the sixth sample had a selenium
concentration of 1.83 mg/kg. Nevertheless, the 15.5 to 31.3 mg/kg levels were retained for
the calculation of risk to ecological receptors. When Radian took subsurface soil samples
in October 1996, the results for selenium in all subsurface soil samples were below the
reporting limit. Because the subsurface soil samples were collected approximately 12 to 18
inches below where the sediment samples were collected, selenium may not be present above
the background concentration in the sediment.

2. The Impacts of DDT, ODD, DDE, and Selenium on Ecological Receptors Are Probably Not as
Severe as Estimated in the Risk Assessment. The calculation of exposure endpoints and the
toxicity assessment used for the risk characterization relied on conservative estimates and
literature values rather than site-specific data. Conservative uncertainty factors were
applied to estimate chronic toxicity endpoints. The uncertainties in the risk
characterization include the following:

• It was assumed that 50% of the birds' diet of fish and invertebrates was consumed
from SWMU 4. However, it is unlikely that birds do 50 percent of their feeding in
the lagoons.

• It was assumed that the great blue heron's diet was primarily fish. However, the
fish population in SWMU 4 is unconfirmed. Also, the risk assessment used a very
conservative bioaccumulation factor for carnivorous game fish that are not present
in the pond.

• The toxicity values and bioaccumulation factors used in the risk characterization
were derived from the literature. A recalculation of the risk using site-specific
data would almost certainly result in reduced chemical-specific cleanup standards.

Conclusion. Because of these and other uncertainties, the screening level ecological assessment
does not provide a sound basis for remedial decisions about or scoping an excavation of SWMU 4.

Ambient Water Quality Criteria. Surface water concentrations in the pond for dieldrin and DDT
exceed federal ambient water guality criteria (AWQC) for the protection of aquatic life. These
criteria are applicable to storm water discharged from SWMU 4. The water guality criteria
developed under the Clean Water Act Section 304 regulate "waters of the United States." The
storm water detention pond is a human-made structure and does not impound any natural water
body. Therefore, the AWQC apply to the discharge rather than to the pond itself.

Possible Modifications to the Selected Remedy for SWMU 4

Because there has been no indication of an impact to groundwater guality at SWMU 4, it is
recommended that the cleanup standards for bis(2-ethylhexyl)phthalate, fluoranthene,
phenanthrene, pyrene, carbaryl, carbofuran, total chlordane, and dieldrin be deleted (see Table
2, attached). The cleanup standards for each of these compounds were previously identified
solely to protect groundwater guality.

To address potential ecological impacts at SWMU 4, the selected remedy could be modified to
include the following:

1. Two detailed observations of the flora and fauna at the pond will be performed during the
first year following the approval of the ROD. The assessments will be spaced approximately
six months apart. More freguent observations to determine the frequency of occurrence of
-------
the herons and sandpipers will supplement the two detailed assessments. These site
assessments will provide a more accurate estimate of the level of food for the receptors and
their use of it.

2. Following these assessments, the risk characterization in the Baseline Risk Assessment
(BRA) will be reviewed. If sufficient invertebrates and fish are observed to warrant
sampling, samples will be collected and site-specific toxicity values and bioaccumulation
factors will be determined. The risk estimates will be revised using the site-specific data
if sampling is performed.

3. Chemical-specific cleanup standards will be developed using the revised risk
characterization to achieve a hazard index of 10.

Further actions at SWMU 4 are contingent on the results of the revised risk assessment for
ecological receptors. If no sediment concentrations exceed the revised cleanup standards, then
the remedy for SWMU 4 will consist of groundwater monitoring in accordance with the reguirements
of 23 CCR, Section 2550.6. If sediment concentrations exceed the revised cleanup standards,
excavation will be implemented as a remedy at that time.

Five-year site reviews are reguired for the selected remedy, per CERCLA guidance, because
contaminants will be left in place (organochlorine pesticides and dieldrin in the northern
portion of the lagoon).
-------
Table 1. Comparison of Sediment and Soil Results for Organic Constituents at ST/JMU 4
Concentration Range in
Compound
bis (2-Ethylhexyl)phthalate
Fluoranthene
Phenanthrene
Pyrene
Carbaryl
Chlordane
2,4-D
Dieldrin
DDT
DDE
ODD
Selenium
NR = none reported
:ection Frequency in
Surface
Surface Sediment
7
3
2
4
1
4
1
5
1
1
11
4 of
of
of
of
of
of
of
of
of
of
of
of
18/1
18
18
18
18
18
18
18
18
18
18
18
of 18
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sediment
(Ig/kg)
to
to
to
to
to
to
to
to
to
to
to 2
to
10,000
1,600
1,700
1,800
930
828
6.86
205
158
815
,310
31.3
Detection Frequency in
Subsurface Soil
0
0
0
0
0
0
0
4
4
10
13
0
of
of
of
of
of
of
of
of
of
of
of
of
18
18
18
18
18
18
18
18
18
18
18
18
Concentration Range
in Subsurface Soil
(Ig/kg)
NR
NR
NR
NR
NR
NR
NR
NR to 6.5
NR to 18
NR to 73
NR to 380
NR
-------
Table 2. Chemical-Specific Cleanup Standards for SWMU 4
Cleanup Standard In Draft ROD
Chemical
bis(2-Ethylhexyl)phthalate
(Ig/kg)
330
Fluoranthene
330
Phenanthrene
330
Pyrene
330
Carbaryl
550
Comments
Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). bis(2-Ethylhexyl)phthalate was not detected in
subsurface soil samples and has not been detected in LM004A or LM027AA.
These data suggest the model was too conservative for this compound and a soil
cleanup standard is not reguired.

Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Fluoranthene was not detected in subsurface
soil samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil
cleanup standard is not reguired.

Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Phenanthrene was not detected in subsurface
soil samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not reguired.

Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Pyrene was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is riot reguired,

Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Carbaryl was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not reguired.
-------
Table 2. (Continued)
Cleanup Standard In Draft ROD

Chemical (Ig/kg)
Carbofuran
1000
Chlordane, total
20
2,4-D
25
Dieldrin
Comments

Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Carbofuran was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not reguired.
Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Chlordane was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not reguired.
Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). 2,4-D was not detected in subsurface soil
samples and has not been detected in LM004A or LM027AA. These data
suggest the model was too conservative for this compound and a soil cleanup
standard is not reguired.
Modeling was used to establish a cleanup standard to protect water guality
(standard corresponds to PQL). Dieldrin was detected in 4 of 18 subsurface
soil samples. No dieldrin was detected in leachate from a DI-WET analysis
performed on the most concentrated subsurface soil (1 to 1.5 Feet below the
bottom of the pond). Dieldrin was periodically detected in LM004A and
LM027AA prior to 1995. Since 1995, all results for dieldrin have been below
the reporting limit. There is no clear link between the dieldrin concentrations
previously detected in LM004A and LM027AA and SWMU 4. We recommend
continued monitoring for dieldrin at LM004A and LM027AA with revised
(lower) reporting limits, We recommend deleting the cleanup standard for
dieldrin from the ROD and revisiting this issue in the five-year review of the site.
-------
Table 2. (Continued)

Cleanup Standard in Draft ROD
Chemical (Ig/kg)
Comments
DDT
25
DDE
50
ODD
50
Selenium
1,310
The cleanup standard for DDT was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The BRA
included a number of assumptions that were not site-specific. It is
recommended that the ROD reguire some additional evaluation of impacts to
ecological receptors and that the cleanup standard be recalculated using site-
specific data.

The cleanup standard for DDE was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The BRA
included a number of assumptions that were not site-specific. It is
recommended that the ROD reguire some additional evaluation of impacts to
ecological receptors and that the cleanup standard be recalculated using site-
specific data.

The cleanup standard for ODD was developed to attain a hazard index of 10 for
the great blue heron using BRA data (Montgomery Watson, 1996). The BRA
included a number of assumptions that were not site-specific. It is
recommended that the ROD reguire some additional evaluation of impacts to
ecological receptors and that the cleanup standard be recalculated using site-
specific data.

The cleanup standard for selenium was developed to attain a hazard index of 10
for the great blue heron using BRA data (Montgomery Watson, 1996).
Selenium was initially detected in six sediment (0 to 6 inches below the bottom
of the pond) samples during the remedial investigation. These same samples
were reanalyzed and selenium was detected in only one of the six samples.
Selenium was not detected in any of the subsurface soil (1 to 1.5 feet below the
bottom of the pond) samples collected by Radian. The data for selenium are,
therefore, highly suspect. It is recommended that the sediment be resampled for
selenium. If the presence of selenium is confirmed, it is also recommended that
the ROD reguire some additional evaluation of impacts to ecological receptors
and that the cleanup standard be recalculated using site-specific data.
-------
TECHNICAL MEMORANDUM

DDRW-Tracy Storm Water Pond Investigation
November 26, 1996
Summary
A hand auger investigation was performed at the DDRW-Tracy storm water pond to determine: 1) if
soil contamination was present, and 2) if soil contamination is present to determine the extent
of contamination (vertical and lateral), and the potential for contamination to migrate to
groundwater. Eighteen samples were collected at various locations and analyzed for metals,
semi-volatile organic compounds (SVOCs) pesticides and polychlorinated biphenyls (PCBs), urea
and carbamate pesticides and chlorinated herbicides (see Figure 1). Metals, pesticides and PCBs
were detected in samples collected, and one soil sample from each method (with the highest
detected target analyte concentrations) was selected for additional analysis to determine metals
and organic solubilities. Table 1 presents the analytical results for the soil samples that
were collected during the investigation. No analytes were detected above the Soluble Threshold
Limit Concentrations (STLC) which indicates leaching from the soil downward to groundwater is
minimal.

Scope of work

The original scope of work included the collection of 18 soil samples at six boring locations
within the stormwater collection pond. Soil samples were to be targeted for collection at depths
of 1.0, 2.0, and 4.0 feet BGS (three samples per location). However, groundwater encountered at
approximately 1.5 feet BGS prevented the collection of "dry" soil samples for chemical analyses,
therefore, soil samples were collected just above groundwater at approximately 1.5 feet BGS in
all 18 hand auger locations. The scope of work was revised (per CEHNC direction) and twelve
additional soil sample locations were sampled within the pond. Samples were collected at the
following locations to assess soil conditions:

Inlets (HP0101 and HP0102)

Low area (HP0104)

Area with minimal surface mixing (HP0103)

Locations randomly distributed throughout the pond (HP0105 through HP0118).

Field Activities

Samples were collected using a four-inch outer diameter hand auger. Field sampling procedures
and eguipment decontamination were performed in accordance to the Comprehensive Field Work Plan,
Volume 1 of 2 (Radian, June 1996). Samples, were analyzed at CLS Laboratory in Rancho Cordova,
California and at Radian Analytical Services Laboratory in Austin, Texas.

The field work was performed from 9 to 11 October 1996 by RUST Environmental and Infrastructure
Corp. Eighteen (18) soil samples (HP0101 through HP0118) were collected at depths up to 1.5 feet
BGS in the stormwater settling pond. Sample locations are shown on Figure 1. The hand augers
were advanced to total depths ranging from approximately 1.5 feet BGS to 3 feet BGS. Soils
encountered included silts and clays to approximately 1.5 feet BGS and sandy silts below 1.5
feet BGS. In each hand auger, one soil sample was collected from approximately 1.0 to 1.5 feet,
directly above the saturated zone. A duplicate soil sample was collected at the inlet (HP0101
sample location), and the soil sample collected at HP0102 was assigned for a matrix spik-matrix
spike duplicate analysis. All soil samples were analyzed in accordance with U.S. EPA Method
SW8270 for SVOCs, Method SW8150 for chlorinated herbicides, Method SW8081 for organochlorine
pesticides and PCBs, Method E632 for carbamate and urea pesticides, and Method SW6010 for
metals. Following completion of investigation activities, the hand auger borings were backfilled
with the native soil removed and each location was marked with a wooden stake.
-------
Result

Of the five analytical methods performed on the soils collected at the storm water pond, target
analytes were only detected in two of the methods; SW8081 for pesticides and PCBs and SW6010 for
metals. Analytes were not detected above the laboratory reporting limit for Methods E632, SW8150
and SW8270.

Additional analysis for one sample from SW8081 and SW6010 were performed using a deionized water
(DI WET) leaching procedure and the leachate analyzed by SW8081 and SW6010 analysis to determine
the potential for solubility of target analytes. For pesticides and PCBs, sample HP0118 was
selected for DI WET analysis based on the detection of 4,4'-DDD at 380 ug/kg, the highest
detection of a regulated compound. For metals, sample HP0110 was selected for DI WET analyses
because this sample had the highest concentrations of chromium, vanadium, and zinc. The majority
of samples collected contained similar concentrations of detected metal analytes.

The DI WET analysis detected no analytes above the regulated hazardous waste limits for either
metals or pesticides and PCBs, indicating a minimal potential for these contaminants to migrate
towards groundwater.

Quality Assurance/Quality Control

Data validation and assessment for analytical data were performed in accordance to guidelines
specified in the Comprehensive Field Work Plan, Volume 2 of 2, Quality Assurance Project Plan
(Radian, June 1996) . In summary, all of the data can be used to define constituents of concern
at the DDRW-Tracy storm water pond. No data points were rejected and any limitations of specific
data points for use are gualified as estimated results (noted with a J or UJ). A list of all
gualified data points is presented in Table 2.

Figure 1. Storm Water Pond Sampling Locations DDRW-Tracy
-------
E632
All Analytes
Table 1, DDRW-Tracy
Storm Water Pond Sampling, October 1996
SAMPLE IDENTIFICATION
HP0101 HP0101 HP0102
Duplicate
HP0110
Leachata
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
SW8080 (ug/Kg)
4.4'-DDE
4.4'-DDD
Heptachlor Epoxide 1
Heptachlor Epoxide
Dieldrin
4.4'-DDT
Arochlor 1260
All Other analytes
BRL
BRL
BRL
3.2
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
1.4
1.6
BRL
BRL
BRL
BRL
BRL
BRL
17
17
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
18
44
BRL
BRL
BRL
18
BRL
BRL
63
340
BRL
BRL
6.5
1.9
BRL
BRL
BRL
2
BRL
BRL
BRL
BRL
BRL
BRL
BRL
1.5
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
3.2
35
BRL
BRL
BRL
BRL
BRL
BRL
3.4
24
BRL
BRL
BRL
BRL
BRL
BRL
BRL
2.2
BRL
BRL
BRL
BRL
BRL
BRL
2 . 7
5. 1
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
73
380
BRL
BRL
2.7
1.1
BRL
BRL
Aluminum
Antimony
Arsenic
Berlum
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
7860
1.33
4.7
181
0.334
0.294
3000
26.5
7.34
15
19600
5.13
4160
216
24.7
1510
ND

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Calculation of Clean-up Levels Protective of Ecological Receptors

This appendix provides the calculations performed to determine preliminary and conservative
chemical-specific cleanup standards to protect ecological receptors. Concentrations were
estimated using literature intake benchmarks. The total DDK concentrations were based on values
from Heath, Spann, and Kreitzer (1969) and Anderson et al. (1975) . Concentrations for selenium
were based on intake values reported by Heintz, Hoffman, and Gold (1989). Lead concentrations
were based on Edens et al. (1976) and Edens and Garlich (1983). The calculations were
coordinated with and reviewed by Mr. Clarence Callahan of the U.S. EPA and were found to be
reasonable.

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APPENDIX E

WELL MONITORING PROGRAM

El.O INTRODUCTION

E2.0 WELL MONITORING PROGRAM

Prior to completion of the Comprehensive Record of Decision (ROD), the purpose of the well
monitoring program at DDJC-Tracy was to collect the groundwater data necessary for:

• Monitoring and tracking groundwater contamination;

• Validating the effectiveness of the groundwater extraction and treatment systems;

• Confirming that groundwater contaminants have not impacted potable wells within and
downgradient from groundwater with concentrations exceeding aguifer cleanup levels;
and

• Determining the effect of groundwater injection and percolation.

The selected remedy in the ROD includes groundwater monitoring at SWMUs and other areas of soil
contamination. This monitoring adds two objectives to the well monitoring program:

• Determining if a SWMU or area of soil contamination is degrading groundwater; and

• Evaluating the appropriateness of the selected remedies.

E2.1 After an initial sampling period of one year, the freguency of sampling of wells in the
monitoring program is determined by taking each well through an annual decision process that was
introduced in the Environmental Master Plan, Version 1.0 (Radian, 1996e). Figure E-l illustrates
the decision process that is used to determine the sampling freguency in the well monitoring
program after the initial one-year period. The purpose of the freguency decision flowchart is to
reduce the monitoring to essential while continuing to meet the objectives of monitoring. The
monitoring well sampling flowchart is divided into three criterion types: age, location, and
data needs. The freguency decision process in Figure E-l focuses sampling and analysis on
obtaining data needed to assess the effectiveness of remediation systems and progress toward
groundwater cleanup. In coordination with sampling freguency decisions for each well, decisions
on the analyses to be performed should also be reviewed annually.

E2.2 The selection of analytical methods for each monitoring well is driven by the data needs at
the location. Data needs for all DDJC-Tracy locations are driven by the following:

• Contaminants for which aguifer cleanup standards have been established; and

• Potential contaminants in the soils of known or suspected source areas.

E3.0 MONITORING WELL LOCATIONS

Monitoring wells located within or a short distance downgradient from a SWMU or other area of
soil contamination have been identified as part of selected remedy. Figure E-2 illustrates well
locations downgradient from SWMUs, Areas, and Drum Storage Areas with the same color as the area
they are intended to monitor.

The Comprehensive RI/FS and ROD identifies four locations downgradient from SWMUs and the Drum
Storage Area, Building 30 where additional wells should be located to monitor for contaminants
that pose a threat to groundwater. Wells were installed in the four locations during October and
November 1997. The locations of the newly installed wells and pre-existing wells relative to
SWMUs and the Drum Storage Area are shown in Figure E-3.

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