EPA/ROD/R09-98/031
1998
EPA Superfund
Record of Decision:
BARSTOW MARINE CORPS LOGISTICS BASE
EPA ID: CA8170024261
OU 01, 02
BARSTOW, CA
04/22/1998
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EPA 541-R98-031
MARINE CORPS LOGISTICS BASE
BARSTOW, CALIFORNIA - CTO 0298
FINAL
OPERABLE UNITS 1 AND 2
RECORD OF DECISION REPORT
CLE-J02-01F298-B7-0027
3 April 1998
PREPARED BY:
Southwest Division Naval Facilities
Engineering Command
1220 Pacific Highway
San Diego, California 92132-5187
THROUGH:
CONTRACT #N58711-89-D-9296
CTD #0298
DOCUMENT CONTROL NO.
CLE-J02-01F298-B7-0027
WITH:
Jacobs Engineering Group Inc.
401 West "A" Street, Suite 1906
San Diego, California 82101
In association with:
International Technology Corporation
CH2M HILL
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MARINE CORPS LOGISTICS EASE
EARSTOW, CALIFORNIA - CTO 298
FINAL
OPERABLE UNITS 1 AND 2
RECORD OF DECISION REPORT
CLE-J02-01F298-B7-0027
TABLE OF CONTENTS
Page
ACRONYMS AND ABBREVIATIONS ix
1.0 DECLARATION 1-1
1.1 Site Name and Location 1-1
1.2 Statement of Basis and Purpose 1-1
1.3 Assessment of OUs 1 and 2 1-2
1.4 Description of the Selected Remedy 1-2
1.4.1 OU 1 - Yermo Annex Plume 1-3
1.4.2 OU 2 - Nebo North Plume 1-4
1.4.3 OU 2 - Nebo South Plume 1-5
1.5 Statutory Determinations 1-5
2 . 0 SITE BACKGROUND 2-1
2.1 Facility Location and Description 2-1
2 . 2 Present Site Use 2-1
2 . 3 Site History and Enforcement Activities 2-2
2.4 Scope and Role of OUs 1 and 2 2-4
2.5 Summary of Site Characteristics 2-6
2.5.1 General Site Conditions 2-6
2.5.2 Geology 2-7
2.6.3 Hydrogeology 2-8
2.5.4 Groundwater Flow Directions and Gradients 2-9
2.5.5 Groundwater Use 2-11
2.6 Groundwater Removal Actions 2-11
2.7 Risk Characterization/Management 2-12
2.7.1 Assessment of Risk 2-12
2.7.2 Summary of Human Exposure Assumptions 2-13
2.8 Remediation Goals 2-13
2.8.1 Groundwater Cleanup 2-13
2.8.2 Points of Compliance with Groundwater Cleanup Standards ...2-16
2.8.3 Vadose Zone Cleanup Standards 2-18
2.8.4 Criteria for "Shut-off" of AS/SVE Systems 2-19
2.8.5 Vadose Zone and Groundwater Modeling to Determine
AS/SVE System "Shut Off" 2-22
2.8.6 Determination of Asymptotic Conditions for "Shut Off" of AS/SVE
Component of Groundwater Remedy 2-22
2.8.7 Approach to Groundwater and Vadose Zone Cleanup
at CAOC 16 2-23
2.8.8 Approach for Groundwater and Vadose Zone Cleanup
at CAOC 26 2-26
2.8.9 Approach for Groundwater and Vadose Zone Cleanup at
Warehouse 2 (Nebo North Plume) 2-27
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2.8.10 Approach for Groundwater and Vadose Zone Cleanup
at CAOC 6 (Nebo South Plume) 2-28
2.8.11 Remedial Approach for Groundwater at CAOCs 23, 35, and
15/17 2-28
2.8.12 Initial Groundwater and Vadose Zone Primary
FFA Deliverable 2-29
2.9 National Contingency Plan Statutory Balancing Criteria 2-30
2.10 Applicable and Relevant or Appropriate Reguirements 2-31
2.10.1 Chemical-Specific ARARs Driving Remedial Action Objectives 2-33
2.10.2 Location-Specific ARARs 2-36
2.10.3 Action-Specific ARARs 2-36
2.11 Highlights of Community Relations and Participation 2-38
3.0 YERMO ANNEX PLUME (OU 1) DECISION SUMMARY 3-1
3.1 Summary of Plume Characteristics 3-1
3.1.1 Contaminants of Concern 3-1
3.1.2 VOC Contaminant Sources 3-3
3.1.3 Location of Vadose Zone Contamination 3-4
3.1.4 Location of Groundwater Contamination 3-7
3.1.5 Contaminant Migration Routes 3-7
3.2 Summary of Yermo Annex Plume Risks 3-9
3.2.1 Chemicals of Concern 3-9
3.2.2 Summary of Toxicity Values 3-10
3.2.3 Human Health Risk 3-10
3.2.4 Ecological Risk 3-11
3.3 Rationale for Remedial Action Decisions 3-11
3.3.1 Groundwater Cleanup 3-12
3.3.2 Source Reduction 3-14
3.4 Description of Remedial Action Alternatives, Yermo Annex Plume ...3-18
3.4.1 Alternative 1 - No Action 3-18
3.4.2 Alternative 2 - Institutional Controls/Groundwater
Monitoring 3-18
3.4.3 Alternative 3 - Groundwater Removal (Extraction Wells
at Base Boundary), Ex Situ Treatment, and Discharge 3-20
3.4.4 Alternative 4 - Groundwater Removal (Extraction Wells
at Base Boundary and Off-Base Background Boundary),
Ex Situ Treatment, and Discharge 3-21
3.4.5 Alternative 5 - Groundwater Removal (Extraction Wells
at Base Boundary and Off-Base MCL Boundary), Ex Situ
Treatment, and Discharge 3-22
3.4.6 Alternative 6 - Groundwater Removal (Extraction Wells
at Base Boundary and CAOC 26 Boundary), Ex Situ
Treatment, and Discharge 3-22
3.4.7 Alternative 8A - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary and
CAOC 26 Boundary, AS/SVE at CAOC 26), Ex Situ
Treatment, and Discharge 3-23
3.4.8 Alternative 8B - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary and
CAOC 26 Boundary, AS/SVE at CAOC 26 and
Downgradient of CAOCs 16, 15/17, and 35), Ex Situ
Treatment, and Discharge 3-23
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3.4.9 Alternative 8C - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary, Off-Base
MCL Boundary, and CAOC 26 Boundary; AS/SVE
at CAOC 26 and Downgradient of CAOCs 16, 15/17,
and 35) , Ex Situ Treatment, and Discharge 3-24
3.4.10 Alternative 8D - Groundwater Removal and Source
Reduction (Extraction Wells at Base Boundary,
Off -Base Background Boundary, and CAOC 26 Boundary;
AS/SVE at CAOC 26 and Downgradient of CAOCs 16,
15/17, and 35), Ex Situ Treatment, and Discharge 3-24
3.5 Summary of Comparative Analysis of Alternatives 3-25
3.5.1 Threshold Criteria 3-25
3.5.2 Primary Balancing Criteria 3-26
3.5.3 Modifying Criteria 3-29
3.6 Summary of Selected Remedy For the Yermo Annex Plume 3-29
3.6.1 Performance Standards for Groundwater and Source
Reduction 3-33
3.6.2 Infiltration Standards 3-33
3.6.3 Groundwater and Vadose Zone Monitoring 3-33
3.7 Statutory Determination 3-34
3.7.1 Protection of Human Health and the Environment 3-35
3.7.2 Compliance with ARARs 3-35
3.7.3 Cost Effectiveness 3-35
3.7.4 Use of Permanent Solutions to the Maximum Extent
Practicable 3-36
3.7.5 Preference for Treatment as a Principal Element 3-36
3.8 Documentation of Significant Change 3-37
4 . 0 NEBO NORTH PLUME 4-1
4.1 Summary of Plume Characteristics 4-1
4.1.1 Contaminants of Concern 4-1
4.1.2 VOC Contaminant Sources 4-1
4.1.3 Location of Vadose Zone Contamination 4-2
4.1.4 Location of Groundwater Contamination 4-3
4.1.5 Contaminant Migration Routes 4-3
4.2 Summary of Nebo North Plume Risks 4-5
4.2.1 Chemicals of Concern 4-5
4.2.2 Summary of Toxicity Values 4-5
4.2.3 Human Health Risk 4-5
4.2.4 Ecological Risk 4-6
4.3 Rationale for Remedial Action Decisions 4-7
4.3.1 Groundwater Cleanup 4-7
4.3.2 Source Reduction 4-9
4.4 Description of Remedial Action Alternatives, Nebo North Plume 4-10
4.4.1 Alternative 1 - No Action 4-11
4.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring
with Fail-Safe Extraction and Treatment Containment 4-11
4.4.3 Alternative 3 - Groundwater Removal, Ex Situ Treatment,
and Discharge 4-12
4.4.4 Alternative 4 - Groundwater Removal, Ex Situ Treatment, and
Discharge with Source Reduction (AS/SVE)
at Warehouse 2 4-13
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4.4.5 Alternative 5 - Source Reduction (AS/SVE)
at Warehouse 2 4-14
4.5 Summary of Comparative Analysis of Alternatives 4-14
4.5.1 Threshold Criteria 4-15
4.5.2 Primary Balancing Criteria 4-16
4.5.3 Modifying Criteria 4-18
4. 6 Summary of Selected Remedy For the Nebo North Plume 4-18
4.6.1 Performance Standards for Groundwater and Source
Reduction 4-21
4.6.2 Infiltration Standards 4-21
4.6.3 Groundwater and Vadose Zone Monitoring 4-21
4.7 Statutory Determination 4-22
4.7.1 Protection of Human Health and the Environment 4-22
4.7.2 Compliance with ARARs 4-23
4.7.3 Cost Effectiveness 4-23
4.7.4 Use of Permanent Solutions to the Maximum Extent
Practicable 4-23
4.7.5 Preference for Treatment as a Principal Element 4-24
4.8 Documentation of Significant Change 4-24
5 . 0 NEBO SOUTH PLUME 5-1
5 .1 Summary of Plume Characteristics 5-1
5.1.1 Contaminants of Concern 5-1
5.1.2 VOC Contaminant Source 5-2
5.1.3 Location of Vadose Zone Contamination 5-2
5.1.4 Location of Groundwater Contamination 5-2
5.1.5 Contaminant Migration Routes 5-3
5 . 2 Summary of Nebo South Plume Risks 5-4
5.2.1 Chemicals of Concern 5-4
5.2.2 Summary of Toxicity Values 5-5
5.2.3 Human Health Risk 5-5
5.2.4 Ecological Risk 5-6
5.3 Rationale for Remedial Action Decisions 5-6
5.3.1 Groundwater Cleanup 5-6
5.3.2 Source Reduction 5-9
5.4 Description of Alternatives 5-9
5.4.1 Alternative 1 - No Action 5-10
5.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring..5-10
5.4.3 Alternative 3 - Vadose Zone Source Reduction
(AS/SVE at CAOC 6) 5-11
5.4.4 Alternative 4 - Groundwater Removal (Extraction Wells
at MCL/Background Boundary), Source Reduction
at CAOC 6, Ex Situ Treatment, and Discharge 5-12
5.4.5 Alternative 5 - Groundwater Containment and Removal
(Extraction Wells at MCL), Ex Situ Treatment, and Discharge ...5-13
5.5 Summary of Comparative Analysis of Alternatives 5-13
5.5.1 Threshold Criteria 5-14
5.5.2 Primary Balancing Criteria 5-15
5.5.3 Modifying Criteria 5-17
5.6 Summary of Selected Interim Remedy For the Nebo South Plume 5-17
5.6.1 Performance Standards for Groundwater 5-19
5.6.2 Infiltration Standards 5-19
5.6.3 Groundwater and Vadose Zone Monitoring 5-20
5.7 Statutory Determination 5-20
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5.7.1 Protection of Human Health and the Environment 5-20
5.7.2 Compliance with ARARs 5-21
5.7.3 Cost Effectiveness 5-21
5.7.4 Use of Permanent Solutions to the Maximum Extent Practicable ..5-22
5.7.5 Preference for Treatment as a Principal Element 5-22
5.8 Documentation of Significant Change 5-22
6.0 RESPONSIVENESS SUMMARY 6-1
7 . 0 REFERENCES 7-1
Tables
Table 2-1 Operable Units 1 & 2 Contaminants of Concern Groundwater
Cleanup Levels 2-39
Table 2-2 Federal Chemical-Specific ARARs, Operable Units 1 and 2 2-40
Table 2-3 State Chemical-Specific ARARs, Operable Units 1 and 2 2-42
Table 2-4 Federal Location-Specific ARARs, Operable Units 1 and 2 2-45
Table 2-5 State Location-Specific ARARs, Operable Units 1 and 2 2-46
Table 2-6 Federal Action-Specific ARARs, Operable Units 1 and 2 2-47
Table 2-7 State Action-Specific ARARs, Operable Units 1 and 2 2-51
Table 3-1 Yermo Plume - On-Base Maximum Groundwater Concentrations
of VOCs and Associated MCLs 3-39
Table 3-2 Yermo Plume - Off-Base Maximum Groundwater Concentrations
of VOCs and Associated MCLs 3-39
Table 3-3 Carcinogenic Toxicity Values for Chemicals of Concern in
Groundwater and Vadose Zone at Yermo Annex 3-40
Table 3-4 Noncarcinogenic Toxicity Values for Chemicals of Concern in
Groundwater and Vadose Zone at Yermo Annex 3-41
Table 3-5 Summary of Comparative Analysis - Yermo Plume 3-42
Table 3-6 Treated Groundwater Discharge Limitations Lahontan RWQCB
Board Order No. 6-93-106 3-43
Table 4-1 Nebo North Plume - Maximum Groundwater Concentrations of
VOCs and Associated MCLs 4-25
Table 4-2 Summary of Comparative Analysis - Nebo North Plume, NRF-1 ....4-26
Table 5-1 Nebo South Plume Maximum Groundwater Concentrations of
VOCs and Associated MCLs 5-23
Table 5-2 Summary of Comparative Analysis - Nebo South Plume, NEP-4 ....5-24
Figures
Figure 2-1 Location of MCLB Barstow Operable Units 1 and 2 2-57
Figure 2-2 Mojave River Regional Map and Major Topographic Features 2-58
Figure 2-3 Well Locations and Hydrogeologic Cross Section A-A' Yermo
Annex 2-59
Figure 2-4 Hydrogeologic Cross Section A-A' Yermo Annex 2-60
Figure 2-5 Hydrogeologic Cross Section Line Nebo Main Base 2-61
Figure 2-6 Hydrogeologic Cross Section A-A' Nebo Main Base 2-62
Figure 2-7 Yermo Annex Groundwater Table Contour Map January 1994 2-63
Figure 2-8 Nebo Main Base Groundwater Table Contour Map January 1993 ....2-64
Figure 3-1 Operable Unit 1 Yermo Annex Groundwater VOC Plume
Boundaries 3-44
Figure 3-2 PCE Plume in Groundwater from CAOCs 15/17, 26, 35, and
Building 573, Yermo Annex 3-45
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Figure 3-3 TCE Plume in Groundwater from CAOCs 15/17, 26, 35, and
Building 573, Yermo Annex 3-46
Figure 4-1 Operable Unit 2 - Nebo Main Base Groundwater VOC Plume
Boundaries 4-27
Figure 4-2 PCE Plumes in Groundwater from NRF-1 and CAOC 6 Nebo
Main Base 4-28
Figure 4-3 TCE Plumes in Groundwater from NRF-1 and CAOC 6 Nebo
Main Base 4-29
Appendices
Appendix A
Appendix B
Appendix C
DON Positions on POC ARARs
Administrative Record Index
Transcript for Public Meeting
ACRONYMS AND ABBREVIATIONS
ARARs applicable or relevant and appropriate reguirements
AS/SVE air sparging/soil vapor extraction
AT&SF Atchison, Topeka, and Santa Fe Railway
bgs below ground surface
BLRA baseline risk assessment
Cal/EPA California Environmental Protection Agency
Cal/OSHA California Occupational Safety and Health Administration
CAOC CERCLA area of concern
CAP corrective action plan
CCR California Code of Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
cis-1,2-DCE cis-1,2-dichloroethene
COG chemical of concern
CRWQCB California Regional Water Quality Control Board
DON Department of the Navy
DTSC Department of Toxic Substances Control
DWR California Department of Water Resources
EDB ethylene dibromide
EE/CA engineering evaluation/cost analysis
EPA U.S. Environmental Protection Agency
BSD explanation of significant differences
F Fahrenheit
FFA Federal Facility Agreement
FS feasibility study
ft/ft foot per foot
gpm gallons per minute
ILCR incremental lifetime cancer risk
IR Installation Restoration
IRIS Integrated Risk Information System
IWTP industrial wastewater treatment plant
Jacobs Jacobs Engineering Group Inc.
kg kilogram
MCB Maintenance Center Base
MCL maximum contaminant level
MCLB Marine Corps Logistics Base
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MCLG maximum contaminant level goal
mg/kg-day milligrams per kilogram per day
mph miles per hour
MSL mean sea level
MTBE methyl tert butyl ether
Navy U.S. Department of the Navy
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
NTCRA non-time-critical removal action
OU operable unit
O&M operations and maintenance
PCBs polychlorinated biphenyls
PCE tetrachloroethene
ppb parts per billion
RAO remedial action objective
RCRA Resource Conservation and Recovery Act
RD/RA remedial design/remedial action
RFA RCRA facility assessment
RG remediation goal
RVFS remedial investigation/feasibility study
RME reasonable maximum exposure
ROD Record of Decision
ROI radius of influence
RWQCB Regional Water Quality Control Board
SARA Superfund Amendments and Reauthorization Act (1986)
SOV soil organic vapor
SVE soil vapor extraction
SVOC semivolatile organic compound
SWMU solid waste management unit
SWRCB State Water Resources Control Board (California)
TBC to be considered
TCE trichloroethene
TEF technical and economical feasibility (analysis)
TPCA Toxic Pit Closure Act
TPH-D total petroleum hydrocarbons as diesel
USGS United States Geological Survey
UST underground storage tank
VLEACH vadose zone leaching model
VOA volable organic analysis
VOC volatile organic compound
WMA waste management area
WMU waste management unit
WQCP water quality control plan
Ig/L micrograms per liter
1,1-DCA 1,1-dichloroethane
1,1-DCE 1,1-dichloroethene
1,1-TCA 1,1-trichlorethane
1,1,1-TCA 1,1,1-trichiciroethane
1,1,2-TCA 1,1,2-trichloroethane
1,2-DCA 1,2-dichloroethane
1,2-DCE 1,2-dichlorciethene
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1.0 DECLARATION
1.1 Site Name and Location
The Marine Corps Logistics Base (MCLB) Barstow is in San Bernardino County, California, in the
central Mojave Desert approximately 135 miles northeast of Los Angeles. The Base consists of
two areas: the 4,006-acre Nebo Main Base, which includes the Rifle Range, is 3.5 miles east of
Barstow and intersected by Interstate 40; and the 1,680-acre Yermo Annex, which is 7 miles east
of Barstow between Interstates 15 and 40. Groundwater underlying the Yermo Annex and Nebo Main
Base is designated as Operable Units (OUs) 1 and 2, respectively. OUs 1 and 2 comprise two
major groundwater regions separated by the Harper Lake - Camp Rock Fault: Yermo Annex
groundwater in the Yermo Subbasin; and Nebo Main Base groundwater in the Barstow Subbasin. This
Record of Decision (ROD) addresses the cleanup of groundwater contamination at OUs 1 and 2 at
MCLB Barstow. The areal extent of interconnected groundwater in which the contamination occurs
in each OU is designated an aguifer, whereas the areal extent of similarly contaminated
groundwater within the aguifer is designated a plume.
In November 1989, MCLB Barstow was placed on the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) National Priorities List (NPL) due to the presence oil
soil and groundwater contamination on the Base.
1.2 Statement of Basis and Purpose
This decision document presents the selected remedial actions for the three contaminant plumes
identified in the OU 1 (Yermo Annex plume) and OU 2 (Nebo North and South plumes) aguifers at
MCLB Barstow. The actions selected for these OUs were developed in accordance with the
Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and Reauthorization Act (SARA) of 1986, and to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The decisions for these OUs are based on the information contained in the Administrative Record
for MCLB Barstow. The two primary documents used for the basis of the decisions are the
Remedial Investigation (RI) Report for Operable Units 1 and 2 (Jacobs Engineering Group Inc.
[Jacobs] 1995a) and the Feasibility Study (FS) Report for Operable Units 1 and 2 (Jacobs 1995b).
The U.S. Marine Corps, the U.S. Department of the Navy (Navy or DON), the U.S. Environmental
Protection Agency (EPA), and the California Environmental Protection Agency's (Cal/EPA)
Department of Toxic Substances Control (DTSC) and Lahontan Regional Water Quality Control Board
(RWQCB) concur with the selected remedies for these OUs.
1.3 Assessment of OUs 1 and 2
Actual or threatened releases of hazardous substances from OUs 1 and 2 groundwater contaminant
plumes may present a current or future threat to public health, welfare, or the environment if
not addressed by implementing the response actions selected in this ROD.
1.4 Description of the Selected Remedy
This ROD addresses the groundwater contaminant plumes in the OUs 1 and 2 aguifers and related
vadose zone contamination. The selected remedies for each groundwater contaminant plume are
described in this section. The remedial approach to the groundwater and vadose zone
contamination is to reduce the contaminant mass in groundwater and the vadose zone to levels at
or below federal and state maximum contaminant levels (MCLs). The OUs 1 and 2 groundwater
contaminant plumes are primarily characterized by tetrachloroethene (PCE) and trichloroethene
(TCE) but also contain other volatile organic compounds (VOCs). This ROD sets aguifer cleanup
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levels for PCE, TCE, 1,1-dichloroethene (1,1-DCE), and 1,2-dichloroethane (1,2-DCA) as the more
stringent of the federal and state MCLs. The major components of the selected remedies are
described as follows.
Although, under CERCLA Sec. 121 (e) (1), remedial actions are exempt from permitting reguirements,
CERCLA reguires compliance with substantive applicable or relevant and appropriate reguirements
(ARARs) that otherwise would have been addressed in such permits.
1.4.1 OU 1 - Yermo Annex Plume
The selected remedy involves groundwater extraction, ex situ treatment and recharge of treated
groundwater back into the aguifer, and air sparging/soil vapor extraction (AS/SVE) systems for
groundwater and vadose zone VOC mass removal. Groundwater cleanup standards are based on
removing constituents to levels at or below secondary and primary MCLs as measured by
groundwater monitoring wells. Vadose zone cleanup standards are based on removal of VOCs from
soils to levels that will not cause groundwater to exceed the groundwater cleanup standards,
based on an interpretation of soil gas data using appropriate vadose zone fate and transport and
groundwater mixing zone models. Monitoring will be conducted to verify adherence to groundwater
cleanup standards. The major components of the selected remedy include the following.
• Remedy all the contaminant plume that exceeds the MCL, except directly beneath waste
management areas/waste management units (see Section 2.8.2), by extracting
groundwater at three locations: 1) four on-Base wells at the CERCLA area of concern
(CAOC) 26 plume downgradient boundary; 2) eight wells at the Base eastern boundary;
and 3) four off-Base wells at the MCL boundary.
• Treat extracted groundwater aboveground by activated carbon units.
• Operate existing AS/SVE systems for groundwater/vadose zone source removal at CAOC
26, and for groundwater VOC mass removal downgradient of CAOCs 16,15/17, and 35.
• Recharge treated groundwater back into the aguifer via two infiltration galleries
located at the upgradient edge of the plume.
• Monitor the vadose zone at CAOCs 16, 15/17, and 26 for the effectiveness of the
AS/SVE systems.
• Monitor groundwater throughout the duration of the remedial action, which is
estimated to take approximately 30 years, subject to evaluations of treatment
effectiveness at 5-year intervals.
• Monitor groundwater at CAOCs 23 and 35 subject to landfill closure reguirements.
• Sample groundwater guarterly for 1 year for five dissolved metals (nickel, chromium,
antimony, thallium and aluminum) at selected wells in the area of CAOC 16 to
ascertain if these metals are naturally occurring or the result of Base activities.
• Implement institutional controls as described in Section 1.4.2.
1.4.2 OU 2 - Nebo North Plume
The selected remedy involves an AS/SVE system for groundwater and vadose zone VOC mass removal
at Warehouse 2 and natural attenuation (e.g., dispersion, degradation, sorption and
volatilization) to reduce contamination in the groundwater plume to levels at or below MCLs.
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The remedy also includes fail-safe pump-and-treat as a backup in case natural attenuation fails
to stop plume migration. The major components of the selected remedy include the following.
• Use AS/SVE system for groundwater/vadose zone source removal at Warehouse 2.
• Implement institutional controls including access restrictions to prevent the use of
untreated groundwater for drinking water in the area of the plume above MCLs, and
well head treatment of potentially impacted water supply wells.
• Design and implement sampling protocol to monitor and evaluate the progress of
natural processes in achieving remediation goals.
• Activate an existing groundwater extraction and treatment pilot study system on a
contingency basis to provide containment backup if natural processes fail to contain
the plume. This ROD establishes "triggers" for turning the extraction and treatment
system on and off, if required.
• Monitor vadose zone at Warehouse 2 for the effectiveness of the AS/SVE system.
• Monitor groundwater throughout the duration of the remedial action, which is
estimated to take approximately 15 years, subject to evaluations of treatment and
cost effectiveness at 5-year intervals.
1.4.3 OU 2 - Nebo South Plume
The selected remedy is an interim remedy consisting of containment and removal of the
groundwater contaminant plume from the aguifer, followed by ex situ treatment and recharge of
treated groundwater back into the aguifer. The containment measure is a necessary interim
action designed to stop any further migration of the VOC plume. An AS/SVE pilot study is
currently underway to evaluate the feasibility of this technology to reduce remediation time and
thus enhance the cost-effectiveness of containment. The major components of the selected
interim remedy include the following.
• Capture the contaminant plume above MCLs through five groundwater extraction wells at
the leading edge of the plume.
• Treat extracted groundwater by activated carbon units aboveground.
• Recharge treated groundwater back into the aguifer via percolation ponds located on
the northeast corner of the Nebo Main Base, downgradient of the plume.
• Implement institutional controls as described in Section 1.4.2.
• Select the final remedy at a later date with an accompanying Proposed Plan and ROD.
A major component of the selected interim remedy will also include conducting Phase II of the
AS/SVE pilot study to further investigate the extent of vadose zone and groundwater
contamination underlying CAOC 6, and evaluating the technical feasibility and effectiveness of
AS/SVE at this CAOC.
1.5 Statutory Determinations
The selected remedies for the OUs 1 and 2 groundwater contaminant plumes are protective of human
health and the environment, comply with federal and state requirements that are legally
applicable or relevant and appropriate to the remedial actions, and am cost-effective. These
remedies use permanent solutions and alternative treatment technologies to the maximum extent
practicable and satisfy the statutory preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as a principal element.
The effectiveness of the remedial actions for each of the plumes will be reviewed at a minimum
at 5-year intervals, or as otherwise prescribed in this ROD, during operation of the respective
systems to ensure that the remedies continue to adequately protect human health and the
environment and are achieving cleanup goals.
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logistical support to Marine Corps commands throughout the western United States and the
Pacific.
Yermo Annex (Figure 2-1) was acguired in 1946 because Nebo Main Base operations outgrew
escalating mission reguirements. In 1961, a 10-acre central repair shop (Building 573) was
built to provide additional vehicle repair and rebuilding capabilities. The Rifle Range (Figure
2-1) was acguired in the mid-1950s for shooting practice and continues to serve the same
function today with minimal changes.
Until the early 1960s, MCLB Barstow's major industrial operations were conducted at Nebo Main
Base; in the early 1960s, the major industrial operations were moved to the Yermo Annex. The
hazardous waste generation and disposal operations associated with these industrial activities
began at Yermo Annex at this same time.
Operations at MCLB Barstow have included maintaining, issuing, and shipping materials held in
the Marine Corps Stores Distribution System. During its 50 years of operation, MCLB Barstow has
generated industrial waste such as waste oil, fuel, solvent, paint residue, grease, hydraulic
fluid, battery acid, various gases, and other components, including some that are sources of
low-level radiation. Additional waste generated included pesticides, herbicides, polychlorinated
biphenyls (PCBs), calcium hypochlorite, and sodium hypochlorite. In the early years, some of
these wastes were disposed of in landfills, burn trenches, and other areas located throughout
the Nebo Main Base, Yermo Annex, and the Rifle Range.
With the passage of CERCLA in 1980, the Navy began the Installation Restoration (IR) Program to
identify, investigate, and clean up past hazardous waste disposal sites. MCLB Barstow and the
Navy have been actively involved in this program since the early 1980s.
Site assessment activities have been conducted since 1983 to determine the nature and extent of
contamination and hydrogeological conditions underlying the Base. In 1988, chlorinated
solvents, including trichloroethene (TCE), were found in groundwater production wells at the
Yermo Annex, and the wells were connected to a carbon filtration treatment system. Several
groundwater production wells at the Nebo Main Base were abandoned due to groundwater
degradation. In 1977, the Nebo Main Base was connected to the Southern California Water Company
system for its potable water supply.
In November 1989, the Base was placed on the CERCLA National Priorities List (NPL) due to the
presence of soil and groundwater contamination. In October 1990, MCLB Barstow entered into a
Federal Facility Agreement (FFA) with the EPA, the DTSC, and the California Regional Water
Quality Control Board (CRWQCB). The FFA constitutes a legally binding agreement between the
Marine Corps and the regulatory agencies.
The FFA specified a schedule for completing the CERCLA investigation and remediation activities,
and defined seven OUs at the Base. OUs 1 and 2 address the groundwater contamination at the
Yermo Annex and the Nebo Main Base, respectively. OUs 3, 4, 5, and 6 address soil contamination
at 36 CAOCs. OU 7 was created to include any additional CAOCs that may be identified from the
ongoing Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) at the Base.
Groundwater RI activities for OUs 1 and 2 were conducted within the framework of the FFA to
define regional hydrogeologic conditions and assess the nature and extent of groundwater
contamination at the Base. Phase I RI activities were conducted between February and December
1992. The Phase I RI identified the presence of VOCs exceeding federal and state drinking water
standards in the groundwater at both the Yermo Annex and the Nebo Main Base. Phase II RI
activities, conducted between June and September 1994, focused on defining the vertical and
lateral extent of the groundwater contamination detected in Phase I. The investigative approach
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and results of the groundwater RI are presented in the Draft Remedial Investigation Report,
dated 15 June 1995 (Jacobs 1995a).
2.4 Scope and Role of OUs 1 and 2
For investigative purposes, the Federal Facility Agreement groups the inferred hazardous waste
disposal sites (designated CAOCs) at MCLB Barstow into seven operable units as follows. CAOCs
are grouped into OUs on the basis of similar characteristics to facilitate response actions.
• OU 1: Groundwater and vadose zone contamination underlying the Yermo Annex. The RI
identified one large commingled VOC plume emanating from several sources including
CAOCs 16, 15/17, 23, 26, and 35.
• OU 2: Groundwater and vadose zone contamination underlying the Nebo Main Base. The
RI identified two discrete plumes: the Nebo north plume, believed to have originated
from Warehouse 2; and the Nebo South plume, which originated from CAOC 6.
OU 3: Shallow soil contamination at the Yermo Annex from five CAOCs (18, 20, 21, 23,
and 34), for which analytical data existed prior to the RI.
• OU 4: Shallow soil contamination at the Nebo Main Base from four CAOCs (2, 5, 9, and
11), for which analytical data existed prior to the RI.
OU 5: Shallow soil contamination at the Yermo Annex from 16 CAOCs (15/17, 16, 19,
22, 24 through 32, 35, and 36), for which analytical data did not exist prior to the
RI.
OU 6: Shallow soil contamination at the Nebo Main Base from 11 CAOCs (1, 3, 4, 6, 7,
8, 10, 12, 13, 14, and 33), for which analytical data did not exist prior to the RI.
• OU 7: Soil and groundwater contamination from any additional solid waste management
units (SWMUs) that may be identified under the RFA process to have released hazardous
materials into the soils.
This ROD provides information about the alternatives considered for groundwater and vadose zone
remedial actions at OUs 1 and 2, and identifies the selected alternative with the rationale for
its selection.
This information is based on detailed field investigation and engineering reports prepared for
OUs 1 and 2. The three primary documents are the Remedial Investigation (RI) Report for OUs 1
and 2 (Jacobs 1995a), the Feasibility Study (FS) Report for OUs 1 and 2 (Jacobs 1996a) and the
Proposed Plan for OUs 1 and 2 (Jacobs 1996b). The RI and FS reports are part of the MCLB Barstow
Administrative Record. The Draft Final Proposed Plan is undergoing public comment.
2.5 Summary of Site Characteristics
2.5.1 General Site Conditions
In general, both the Nebo Main Base and the Yermo Annex, including those areas near potentially
contaminated groundwater, are located near the Mojave River where topography is relatively flat.
The topographic surface slopes gently north to the river at the Nebo Main Base and the Rifle
Range, and gently slopes south-southeast to the river at the Yermo Annex.
The Mojave River is the dominant surface water feature in the Mojave Desert. The Mojave River
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originates as a series of interconnecting drainages along the northeast front of the San
Bernardino Mountains, extends east-northeast from the mountain front, passes through the Base,
and terminates at Soda Lake about 70 miles east of the Base. Because the river is primarily fed
by mountain front drainages, the river bed is generally dry; flows in the Barstow area are
limited to periods of heavy rainfall. Surficial flow is also evident near areas of bedrock
highs and intermittently along the Harper Lake-Camp Rock fault near the Nebo Main Base.
On average, about 90 percent of the flow of the Mojave River is retained within the Mojave River
drainage basin to recharge several groundwater basins, including the Yermo and Barstow subbasins
(California Department of Water Resources [DWR] 1967). MCLB Barstow is partly within the
100-year floodplain of the Mojave River, which passes through the northern portion of Nebo Main
Base and the southern portion of the Yermo Annex. On-site flooding at the Nebo Main Base is
rare and even less freguent at the Yermo Annex. The surface water drainage systems at both
Yermo Annex and Nebo Main Base have been designed to intercept and convey runoff water to the
Mojave River.
The Barstow area is characterized by intense summer heat, minimal rainfall and low humidity,
strong winds, periodic thunderstorms, and flash floods. Factors that tend to moderate the
weather in other areas of California are absent in the Mojave Desert, resulting in an extreme
climate. Temperature ranges from 12! Fahrenheit (F) to 114! F annually. Winds near Barstow are
primarily from the west at an average annual speed of about 11 miles per hour (mph). Wind gusts
of up to 65 mph have been recorded.
Annual average precipitation in the Barstow area is about 4 inches per year, however,
considerable year-to-year variability occurs, which results in the variable discharge conditions
of the Mojave River. Precipitation in the Mojave Desert occurs primarily with the passing of
weakened winter fronts from the north and the periodic development of brief, localized
thunderstorms during the summer. Periodic episodes of intense rainfall create flash flood
conditions (referred to as floodflows) in the Mojave and in the intermittent washes near the
Base and Barstow.
2.5.2 Geology
MCLB Barstow is within the Mojave Desert Geomorphic Province (Jacobs 1994a). This province is a
wedge-shaped unit bounded by the Garlock Fault on the north and the San Andreas Fault on the
southwest. The approximate eastern boundary is the Bristol-Granite Mountains fault zone in the
eastern Mojave Desert. At this diffuse boundary, the Mojave Desert merges with the Basin and
Range Geomorphic Province.
The Mojave Desert Geomorphic Province is characterized by a series of low-lying,
northwest-trending, fault-block mountain ranges with intermontane basins and local playas (dry
lakes). The ranges are composed primarily of Precambrian granitic and metamorphic rocks,
Paleozoic sedimentary rocks, Mesozoic granitic and volcanic rocks, and late Tertiary sedimentary
and volcanic rocks. The intermontane basins are largely filled with late Tertiary and
Quaternary alluvium. The tectonic grain is essentially defined by a series of closely spaced
northwest-trending faults. East-trending faults are more common near the Garlock fault.
MCLB Barstow is located along the west-northwest-trending Barstow Basin, roughly bounded by the
Blackwater/Calico faults to the northeast and the Lenwood fault to the southwest (Figure 2-2).
The Barstow Basin slopes sharply to the southeast. Bedrock beneath the Base reaches depths of
3,500 feet below ground surface (bgs). Exposed local bedrock consists primarily of Tertiary
sedimentary and volcanic rocks. The basin is filled by a seguence of late Tertiary to early
Quaternary alluvial deposits. The surface is mantled by windblown sand deposits and young
alluvial deposits derived from either the Mojave River or shed from adjacent highlands. The
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southern portion of the facility is underlain by coarse, alluvial fan debris containing abundant
gravel and cobbles.
2.5.3 Hydrogeology
MCLB Barstow is within the Mojave River Drainage Basin, which covers about 3,700 sguare miles
within the south-central Mojave Desert (Jacobs 1995a).
The Mojave River Drainage Basin consists of a series of subbasins separated by largely
impermeable bedrock. MCLB Barstow is within the Lower Mojave subunit. The Lower Mojave subunit
is further divided into several subbasins. The Nebo Main Base and the Yermo Annex are within
the Barstow and Yermo subbasins, respectively. Water-bearing sediments within these subbasins
are composed primarily of late Pleistocene to Holocene alluvial deposits shed from adjacent
highlands. These deposits are unconsolidated to partially consolidated and consist primarily of
sand, silt, and gravel with lenses of clay.
The Barstow subbasin extends over approximately 20 square miles and is delineated by various
hydraulic boundaries. The projection of the Harper Lake-Camp Rock Fault to the east,
consolidated rocks to the west, and the terminus of unconsolidated sediments to the north and
south delineate the Barstow subbasin (Miller 1969). The larger Yermo subbasin, similarly
bounded by groundwater barriers, extends over 65 sguare miles. The Yermo subbasin shares a
common boundary with the Barstow subbasin at the Harper Lake-Camp Rock Fault, but its northwest
boundary is not well defined (United States Geological Study [USGS] 1969).
Groundwater conditions at MCLB Barstow are monitored by an extensive network of shallow,
intermediate, and deep monitoring wells installed during prior and current environmental and
engineering studies (Jacobs 1991; 1993b). The inventory of monitoring wells drilled under this
investigation at the Yermo Annex and Nebo Main Base is provided in the Draft Final RI report.
Figures 2-3 and 2-4 depict the location of monitoring wells and hydrogeologic cross section at
the Yermo Annex, respectively. Figures 2-5 and 2-6 depict the location of monitoring wells and
the hydrogeologic cross section at Nebo Main Base, respectively.
The Mojave River recharges regional groundwater. However, groundwater conditions at the Yermo
Annex are significantly different from conditions at the Nebo Main Base. Monitoring well
gauging results indicate that groundwater is encountered from between 133 and 147 feet bgs at
the Yermo Annex. At the Nebo Main Base, groundwater is encountered between approximately 10 and
75 feet bgs in the central area of the Base and up to 175 feet bgs on the alluvial fan south of
Interstate 40. In the bed of the Mojave River, groundwater has been encountered at depths of
only 4 to 5 feet bgs (Jacobs 1993a).
The depth to the groundwater table has remained relatively stable at the Nebo Main Base but has
been lowered about 70 feet at the Yermo Annex since the 1930s (Miller 1969). The lowering of
the water table can be attributed to regional groundwater withdrawal due primarily to
agricultural irrigation wells, with minor influences coming from private and public production
wells. Two active groundwater production wells at the Yermo Annex are currently being operated
in compliance with the State's drinking water program. Groundwater production wells at Nebo
Main Base have been Inactive since 1975 (Jacobs 1993a).
2.5.4 Groundwater Flow Directions and Gradients
The groundwater table surface beneath the Yermo Annex gently declines towards the
east-southeast, with hydraulic gradients ranging typically from 0.0006 to 0.001 foot per foot
(ft/ft).
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Aquifer recharge from a Mojave River flood in April 1993 redirected groundwater flow at the
Yermo Annex to the north-northeast and increased the hydraulic gradients to approximately 0.005
ft/ft. However, the regional flow direction and gradients returned to pre-flood flow conditions
within 4 months after the recharge event. Figure 2-7 depicts the typical groundwater table
contour map for the Yermo Annex based on groundwater depth measurements collected in January
1994.
The elevation of the groundwater table at the Yermo Annex is approximately 1,810 to 1,825 feet
above mean sea level (MSL), and the groundwater table at Nebo Main Base lies between 1,980 and
2,085 feet above MSL. The average water table elevation difference between shallow wells
(screened across the water table) and intermediate depth wells (screened at depths of 50 to 60
feet below the water table) is at or close to zero, and the absolute values of the maximum and
minimum water table elevation differences are virtually egual. Therefore, no net vertical
gradients have been determined to exist at the Yermo Annex.
At the Nebo Main Base, the groundwater gradient at the southwestern corner, which is the
topographically high area, is directed radically towards the north, northeast, and east, at a
slope of approximately 0.01 to 0.03 ft\ft (Figure 2-8). The groundwater flow gradient decreases
to approximately 0.002 ft\ft near the central part of the Main Base, and the flow direction
changes to predominantly northeast. The flow direction then changes to predominantly eastward
underlying the Base golf course, located at the northern Main Base immediately south of the
Mojave River channel. The change in groundwater flow direction along eastern Nebo Main Base is
attributed to the presence of the Harper Lake-Camp Rock fault and shallow bedrock to the north.
Monitoring well clusters at the Nebo Main Base, consisting of intermediate and shallow depth
wells, were measured for the presence of vertical flow gradients. Wells NSI-6/NSI-7 and
NWP-l/NSlO-1 displayed a net downward vertical gradient of 0.020 and 0.018 ft/ft, respectively.
Monitoring wells NWP-3/NWP-7 and NS2-1/NS2-3 had a net upward vertical gradient of 0.093 and
0.013 ft\ft, respectively. Vertical gradients on all other wells at Nebo Main Base were less
than 0.005 ft/ft.
2.5.5 Groundwater Use
The Lower Mojave subunit, which includes the Barstow and Yermo subbasins, is classified as a
source of drinking water (i.e., Class I Aguifer) in the Comprehensive Water Quality Control Plan
for the Lahontan Region. Groundwater is the sole source of drinking water in this area and its
guality may have been impacted since at least 1952. Both the Yermo, Annex and Nebo Main Base
have evidence of solvent-contaminated groundwater.
The Yermo Annex area relies on on-Base water supply wells to meet its domestic water needs.
Groundwater at the Yermo Annex is extracted from the aguifer and treated through a carbon
filtration system. The Nebo Main Base receives its drinking water through a pipeline from the
City of Barstow, which gets its water supply from groundwater wells in the Mojave River Drainage
Basin, upgradient from the Base.
2.6 Groundwater Removal Actions
As the lead agency, the Marine Corps has adopted the policy that removal actions will take
priority over continued investigation when the removal action is deemed to be protective of
human health and consistent with the final remedy. Two time-critical and one non-time-critical
groundwater removal actions have been Implemented at MCLB Barstow to address groundwater
contamination at both the Yermo Annex and Nebo Main Base. These removal actions, described as
follows, meet the requirements of CERCLA and have been fully incorporated into the remedial
actions selected in this ROD.
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In 1992, TCE concentrations above drinking water MCLs were detected in a private residence
drinking water well located within the off-Base Nebo south plume boundary. A time-critical
removal action was conducted to remove the well from service and connect the residence to the
Base water supply system.
In 1994, levels above drinking water standards were detected off-Base about 2,000 feet
downgradient of the Yermo Annex eastern boundary. Trace levels (less than 1 part per billion
[ppb]) were detected in one of two private residence wells located downgradient of this area.
The Base conducted a time-critical removal action to provide the two private residence wells
with wellhead carbon treatment systems as a precautionary measure.
A non-time-critical removal action (NTCRA) for groundwater containment and cleanup is being
conducted at the Yermo Annex and has been incorporated into this ROD. The purpose of the NTCRA
Is to prevent further migration of contaminants beyond the Base boundary and accelerate
groundwater cleanup activities.
MCLB Barstow has also conducted removal actions for soils under OUs 3 and 5 at the Yermo Annex,
and OU 4 at the Nebo Main Base. These removal actions are described in the respective RODs for
these OUs, which are part of the MCLB Barstow Administrative Record.
2.7 Risk Characterization/Management
2.7.1 Assessment of Risk
The NCP directs the Marine Corps, as the lead agency for MCLB Barstow, to conduct a baseline
risk assessment (BLRA) to determine whether the Base poses a current or potential threat to
human health and the environment in the absence of any remedial action. The BLRA provides the
basis for defining acceptable risk ranges to determine if either no action or a selected remedy
will be protective of human health and the environment.
Cancer risk is expressed in terms of the chance of contracting cancer over a human's lifetime
due to exposure to site chemicals, and is called the incremental lifetime cancer risk (ILCR). A
risk of 1 out of 1 million means that one additional person out of a group of 1 million may
develop cancer as a result of exposure to a chemical. EPA considers a risk of less than 1 x 10
-6 (1 in a million) to be protective of human health, and uses this value as the point of
departure. The EPA also has developed a risk management range represented as 10 -6 to 10 -4 as
the target range for managing cancer risks. An ILCR above 10 -4 (e.g., 10 -3) generally
reguires remedial action.
Non-cancer health effects are evaluated in terms of a hazard index (the ratio of the actual or
potential level of exposure to an acceptable level of exposure). EPA uses a hazard index level
of less than 1 to be acceptable for non-cancer health effects. Non-cancer hazards significantly
above 1 indicate a potential for adverse effects.
2.7.2 Summary of Human Exposure Assumptions
The BLRA for OUs 1 and 2 used a future resident exposure scenario with the following exposure
assumptions for the identified pathways:
• A 70-kg adult on-site resident exposed 350 days per year for 30 years.
• A 15-kg child on-site resident exposed 350 days per year for 6 years.
• Adult and child ingest 2 and 1 liters of water per day, respectively, for the
exposure freguency and duration stated above.
• A resident showers daily with site groundwater.
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• The contaminated groundwater is used as a drinking water source without treatment.
• Users are exposed to the maximum concentrations detected in the plume.
2 . 8 Remediation Goals
2.8.1 Groundwater Cleanup
Primary MCLS
Groundwater cleanup levels for VOCs are established to ensure that any persons exposed in the
future will not be exposed to unsafe levels of chemicals of concern. These cleanup levels are
based on a detailed analysis of chemical-specific applicable or relevant and appropriate
reguirements (ARARs) and health risk-based criteria that are consistent with the present and
projected beneficial uses of the affected aguifers.
MCLB Barstow overlies the Lower Mojave subunit, which is classified as a source of drinking
water (Class I aguifer) in the Comprehensive Water Quality Control Plan (WQCP) for the Lahontan
Region. The Nebo Main Base receives its water supply from the Southern California Water
District. The Yermo Annex obtains its water from the Yermo subbasin. The only two active water
supply wells at the Yermo Annex have carbon filtration systems to meet drinking water standards.
Because the groundwater is a source of drinking water, federal MCLs, nonzero maximum contaminant
level goals (MCLGs), and those state MCLs that are more stringent than federal MCLs are relevant
and appropriate ARARs for the groundwater in the aguifer (EPA 1990). In addition to the
Lahontan Region WQCP and the federal and state drinking water standards, the RCRA groundwater
protection standards have also been determined to be relevant and appropriate for remedial
actions for OUs 1 and 2 due to the nature of the chemicals of potential concern. The RCRA
groundwater protection standards reguire cleanup to background levels (i.e., the water guality
that existed before the discharge), unless background levels can be demonstrated to be
technically and economically infeasible to attain. Concentration limits greater than background
levels cannot exceed MCLs.
Pursuant to the RCRA Water Quality Protection Standard in Title 22 California Code of
Regulations (CCR) Section 66264.94, the DON evaluated two sets of potential concentration limits
for the purpose of establishing groundwater VOC cleanup levels (see Table 2-1).
1) The most stringent federal and state drinking water standards (i.e., MCLs), and
2) Background levels based on readily achievable detection limits (i.e., 0.5 Ig/L).
The ILCRs for chemicals of concern within each plume calculated for both of these standards fall
within the EPA risk management range of 10 -6 to 10 -4. Both set of standards are considered to
be protective of human health and the environment.
The technical and economic feasibility (TEF) of remedial alternatives to achieve both sets of
cleanup standards (i.e., MCLs and background) was evaluated in the OUs 1 and 2 FS for each of
the groundwater plumes at MCLB Barstow. The results, of the TEF evaluation for the Yermo Annex,
Nebo North and Nebo South contaminant plumes are summarized in Sections 3.3.1, 4.3.1, and 5.3.1
of this ROD, respectively. The complete TEF was provided to the agencies as Appendix J of the
OUs 1 and 2 Draft Final FS Report (Jacobs 1997).
Based on the TEF analysis and risk assessment results, the DON concluded that achieving
background levels of constituents in the groundwater is not technically or economically
feasible, and established MCLs as the cleanup levels for groundwater remedial actions under this
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ROD consistent with the requirements, of 22 CCR 66264.94, 23 CCR 2550.4, and SWRCB Resolution
Nos. 68-16 and 92-49. MCLs will be attained throughout the contaminant plume, except directly
beneath WMAs/WMUs. The FFA signatories agreed on and approved this conclusion in the Proposed
Plan for OUs 1 and 2.
Secondary MCLs
The State asserts that the narrative taste and odor water quality objective specified in the
WQCP for the Lahontan RWQCB, which incorporates State primary and secondary drinking water
standards, is an ARAR that applies to the establishment of cleanup levels in these OUs. The DON
and EPA agree that the negative taste and odor water quality objective is an ARAR, but do not
agree that tile secondary standard of three odor units is an ARAR because the measurement is
subjective based upon the sensory determination of a panel. The DON agrees to implement the
taste and odor objective for toluene and xylenes bit using the numeric taste and odor standards
proposed by EPA (see 56 Federal Register 3572, 3573, 30 January 1991), but not promulgated, as
"to-be-considered" standards that will be identified as performance goals in this ROD. If the
DON demonstrates compliance with the performance goals, the DON shall be deemed to be in
compliance with the taste and odor water quality objectives and the secondary MCLs for xylene
and toluene.
2.8.2 Points of Compliance with Groundwater Cleanup Standards
Background
The CERCLA NCP preamble provides that compliance with groundwater cleanup standards should be
attained throughout the affected area of the aquifer or at and beyond the downgradient edge of
the waste management area (WMA) when the waste is left in place (the "point of compliance").
See NCP preamble at 55 Federal Register 8753, 8 March 1990. Title 22 CCR Section 66264.95
contains similar provisions for RCRA "regulated units" and Title 23 CCR Section 2550.5 contains
similar provisions for "point of compliance" for waste management units (WMU) regulated under
Title 23 CCR Chapter 15.
It is the DON's position that the designation of "points of compliance" at the downgradient edge
of all CAOCs addressed in this ROD would be appropriate and is supported by CERCLA, the NCP, and
the administrative record for this ROD, and that the remedial action objective (RAO) of
achieving the federal MCLs for PCE, TCE, and 1,1 DCE should apply throughout the contaminant
plume downgradient from the points of compliance. The DON believes contamination upgradient of
the points of compliance would be adequately contained by the remedial action to ensure
compliance with this RAO and would adequately protect human health and the environment.
The NCP preamble states that there may be certain circumstances where a plume of groundwater
contamination is caused by releases from several distinct sources that are in close geographical
proximity. The NCP preamble provides that, in such cases, the most cost-effective groundwater
cleanup strategy may be to address the problem as a whole rather than on a source-by-source
basis, and to draw a common "point of compliance" that encompasses all the sources of release
(55 Federal Register 8753, 8 March 1990).
See Appendix A for a more detailed explanation of the DON's position regarding the applicability
of "point of compliance" regulatory provisions to the CAOCs addressed in this ROD.
Designation of Point of Compliance
EPA and DTSC agree that CAOCs 23, 35, and the majority of CAOC 15/17 are WMAs/WMUs and that the
designation of a "point of compliance" at the downgradient edges of these units is appropriate.
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The DON hereby designates "points of compliance" at the downgradient edge of CAOC 23 and the
common downgradient edge of CAOCs 35 and 15/17. Portions of CAOC 23 and 35 contain landfill
WMUs that the DON will permanently close in-place. The WMUs at CAOC 15/17 encompass 14
evaporation ponds, four sludge drying beds, a temporary pond, three oxidation ponds, and the
overflow area around the ponds. At CAOC 15/17, waste residues have been removed from the WMUs
and disposed of at an appropriate off-Base facility. The DON is not proposing any further use
of the WMUs at CAOC 15/17 for waste disposal and the WMUs are currently not permitted to receive
waste. The WMUs cover the majority of CAOC 15/17, except for the wet well, and extend from near
the upgradient boundary down to the downgradient edge of the CAOC.
The CRWQCB does not agree with DON's proposed use of the "point of compliance," but the CRWQCB
is not contesting its use in this case, because DON has installed a groundwater monitoring
network throughout the groundwater plume area and agrees to meet groundwater cleanup standards
at all monitoring points within the network mutually agreed upon in the post-ROD groundwater
monitoring plan. The DON has also agreed to install vadose zone monitoring networks in soils
underlying CAOC 26 and Warehouse 2, and meet the vadose zone cleanup standard specified in
Section 2.8.4
The DON is not designating "points of compliance" for CAOCs 6, 16, 26, and Warehouse 2 solely
in the interest of obtaining the concurrence of EPA, DTSC, and the RWQCB on this ROD. The DON's
agreement to comply with groundwater cleanup standards throughout the contaminant plume at these
CAOCs is subject to the express reservation of its rights to propose the use of "points of
compliance" for these areas in the future. The DON shall address such proposed "points of
compliance" in explanation of significant differences (ESDs), ROD amendments, or new RODs that
shall be submitted to the FFA signatories as a primary FFA deliverable. The FFA signatories
agree that this decision will not set precedent for any other CAOCs or installations.
2.8.3 Vadose Zone Cleanup Standards
The DON and regulatory agencies have jointly determined the amount of vadose zone cleanup
necessary to protect human health and environment. Unlike surface soil contamination, vadose
zone contamination does not constitute a "walk-on" health risk (e.g., through direct soil
contact) to a human receptor unless the contaminated soil becomes exposed by human activity
(e.g., excavation). Surface soil contamination and the associated walk-on risk is addressed In
the soil OUs (i.e., OUs 3 to 6).
The RAO for vadose zone cleanup at MCLB Barstow is to remove contaminant mass in the subsurface
soils to the degree necessary to 1) prevent further degradation of the groundwater above
groundwater cleanup standards and 2) minimize the aguifer cleanup time. Vadose zone soils
cleanup goals are source-specific.
Vadose zone sources at the Yermo Annex include CAOCs 15/17, 16, 23, 26 and 35. Vadose zone
remedial actions for these sources are discussed in detail In Section 3.3.2. Vadose zone
sources at the Nebo Main Base include Warehouse 2 In the Nebo North area and CAOC 6 at the Nebo
South area. Vadose zone remedial actions for these sources are discussed in detail In Sections
4.3.2. and 5.3.2 for Nebo North and Nebo South respectively.
Vadose zone cleanup using AS/SVE technology has been selected as part of the remedy for CAOC 26
and Warehouse 2. Criteria for assessing attainment of vadose zone cleanup goals at these
sources are discussed in Sections 2.8.4 through 2.13.6 below.
2.8.4 Criteria for "Shut-off" of AS/SVE Systems
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AS/SVE systems used to remove VOCs from vadose zone and groundwater at MCLB Barstow will be
operated until one of the following two conditions are reached:
1. (a) remaining vadose zone VOC concentrations no longer cause modeled groundwater
concentrations to exceed the groundwater cleanup standards (based on interpretation
of soil gas data using appropriate vadose zone fate and transport and groundwater
mixing zone models), and (b) representative groundwater concentrations measured
within the AS/SVE system radius of influence (ROI) have achieved groundwater cleanup
standards, or
2. VOCs In the vadose zone and groundwater within the ROI of the AS/SVE system have been
removed to the extent technically and economically feasible. That is, the
incremental benefit of attaining further reduction in the concentration of VOCs is
exceeded by the incremental cost of achieving those reductions through pump and
treat.
The DON will demonstrate that vadose zone cleanup standards have been achieved for Part (a) of
Condition 1 through an examination of the current effects of remaining vadose zone contamination
on groundwater based on an interpretation of soil gas data using appropriate vadose zone fate
and transport and groundwater mixing zone model(s) (using a mixing zone extending to a depth of
10 feet below the water table). If it is demonstrated that soil gas concentrations of chemicals
of concern (COCs) in the vadose zone no longer cause modeled groundwater concentrations to
exceed the cleanup standards, the parties agree that the demonstration for Part (a) of Condition
1 has been made.
It is the CRWQCB's position that the purpose of soil remediation as specified in state law and
policy is to remove VOCs so that they no longer cause or threaten to cause pollution in the
groundwater, that is, that VOCs are no longer migrating into the groundwater at greater than, in
this case, the groundwater cleanup standards. The CRWQCB asserts that the Marine Corps'
proposed methodology for determining shutoff of the AS/SVE system does not provide information
to evaluate whether VOCs are no longer migrating into the groundwater at concentrations greater
than the cleanup standard. A model using a 10-foot mixing zone may not be appropriate in
predicting whether VOCs in the vadose zone will enter groundwater at levels that are greater
than the groundwater cleanup standards. However, the CRWQCB will not dispute the proposed
shutoff criteria if the facility agrees to provide detailed results of both the vadose zone
model and associated groundwater model including all model parameters.
The DON will demonstrate that groundwater cleanup standards have been achieved for Part (b) of
Condition 1 through collection of groundwater samples from monitoring wells agreed upon by all
parties. If it is demonstrated that the representative groundwater concentrations of COCs meet
the groundwater cleanup standards, the parties agree that the demonstration for Part (b) of
Condition 1 has been made.
If it is determined that the cleanup standards in Condition 1 cannot be achieved, the DON will
demonstrate that VOCs in the vadose zone and groundwater within the ROI of the AS/SVE have been
removed by AS/SVE to the extent technically and economically feasible as set forth in Condition
2, by analyzing the following seven factors:
1. Whether the mass removal rate is approaching asymptotic levels after temporary
shutdown periods and appropriate optimization of the AS/SVE system;
The additional cost of continuing to operate the AS/SVE system when mass removal
i"o;3 r*Vio c; ^ c;\7mi~i 1~(~it~n r1 1 o^rol <3 *
reaches asymptotic levels;
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3. The predicted effectiveness and cost of further enhancements of the AS/SVE system
(e.g., additional vapor extraction wells, air injection) beyond optimization of the
existing system;
4. Whether the cost of groundwater pump and treat will be significantly more if AS/SVE
is discontinued;
5. Whether discontinuing the AS/SVE will significantly prolong the time to attain the
groundwater cleanup standard;
6. Historic data that present the AS/SVE system operating costs per unit of VOC mass
removed from the vadose zone and groundwater and the concurrent soil gas and
groundwater VOC concentrations, both as a function of time; and
7. Historic data that present the groundwater pump and treat system operating costs per
unit of VOC mass removed from the groundwater and the concurrent groundwater VOC
concentrations, both as a function of time.
The signatory parties agree that the AS/SVE system may be cycled on and off in order to optimize
the operation and/or evaluate the factors listed above.
The DON will submit a primary document under the FFA providing the appropriate demonstrations.
The signatory parties to this ROD will jointly make the decision that the AS/SVE system may be
shut off permanently based on the criteria set forth in this ROD.
2.8.5 Vadose Zone and Groundwater Modeling to Determine AS/SVE System "Shut Off"
Two separate models will be used to determine when to shut-off an AS/SVE system: a vadose zone
contaminant fate and transport model to simulate contaminant migration into groundwater, and a
groundwater mixing zone model to calculate groundwater concentrations from the contaminant mass
fluxes supplied by the vadose zone model.
Under Part (a) of Condition 1, performance parameters for vadose zone modeling will be measured
by using vapor probes located at representative depths in the vadose zone. The vapor probe
monitoring results will provide an indication of the VOC mass removal in the vadose zone. The
DON proposes a 10-foot mixing zone be used to calculate groundwater concentrations from the mass
flux supplied by the vadose zone model because the 10-foot mixing zone is representative of a
typical monitoring well screen Interval at MCLB Barstow.
2.8.6 Determination of Asymptotic Conditions for "Shut Off" of AS/SVE Component of Groundwater
Remedy
The DON will track the cumulative mass of VOCs removed by the AS/SVE system, and plot the data
as function of time, to help determine how guickly the cumulative mass removed approaches
asymptotic levels. It is expected that the resulting graph of cumulative VOC mass removed
versus time will follow the general curve defined by the following exponential decay eguation:
M(t) = Sum(Ml) = K T (1 - e (-tl) )
Where:
M(t) = Total cumulative mass removed at time t.
M 1 = Total mass removed from vapor extraction well "i".
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K T = Maximum cumulative total mass which the AS/SVE system approaches
asymptotically.
T = Time constant, or resident time equal to the amount of time at which the
AS/SVE system removes approximately 63% of KT (theoretically, T is equivalent
to V/Q, or the volume of soil qas in the vadose zone beinq remediated [V]
divided by the volumetric flowrate of the AS/SVE system [Q]).
t = Any time durinq system operation at which cumulative mass removed is
calculated.
i = Any vapor extraction well for which total mass removed is calculated.
The above equation will be used as a quide to help determine when asymptotic conditions have
been reached. The 'asymptote' to the mass removal curve is that total/cumulative maximum mass
(K T - defined above) which the AS/SVE system attempts to remove but approaches with ever
decreasinq speed. Asymptotic conditions will have been reached when the upper limb of this
curve is substantially linear and the slope of the curve approaches zero. The specific
procedures used to evaluate if data are asymptotic will be defined durinq the remedial desiqn
phase of work. However, it is not expected that field data will match the theoretical equation
exactly. Therefore, it will be necessary to use best professional judqment based on field data
to conclude that asymptotic conditions have been reached.
In order to assess if there are zones where the AS/SVE system has not removed VOCs, cyclinq will
be used to allow residual vadose zone contamination to re-equilibrate. The treatment system
will be shut down temporarily for a suitable period of time after asymptotic conditions are
reached. This will allow for VOC concentrations to re-establish in the soil qas. After
cyclinq, soil qas monitorinq probes will be sampled to determine the remaininq VOC
concentrations in the soil qas. If the resultinq VOC levels are not characteristic of the
pre-cyclinq conditions or indicate a spike increase in soil qas concentration, then additional
treatment may be warranted. The decision to shut off or restart any part of the remediation
system will be made jointly by all FFA siqnatories accordinq to the criteria set forth in
Section 2.8.4 of this ROD.
2.8.7 Approach to Groundwater and Vadose Zone Cleanup at CAOC 16
CAOC 16 is a larqe active industrial facility (approximately 60 acres) with a hiqh concentration
of industrial activities, equipment and structures. The RAO for qroundwater cleanup shall be to
achieve and maintain compliance with the qroundwater cleanup standards throuqhout the
qroundwater contaminant plume. The qroundwater RAO will be achieved throuqh continued operation
of the Yermo Annex plume qroundwater pump and treat system and the AS/SVE system downqradient of
CAOC 16. These systems serve the dual purpose of treatinq the contaminated qroundwater to
achieve MCLs and containinq the contaminated qroundwater while the treatment is occurrinq.
Institutional controls will also be implemented to prevent access to the contaminated
qroundwater until cleanup standards are achieved.
Vadose zone contamination beneath CAOC 16 has not been fully characterized because of the
physical limitations posed by the structures and base operational activities coverinq the site.
These limitations and loqistical problems, partially demonstrated durinq construction and
implementation of a small-scale AS/SVE pilot study system for Buildinq 573 In 1994, are
documented in the OUs 1 and 2 Feasibility Study for MCLB Barstow (Jacobs 1997) and include:
• Hiqh density of mission-critical operations (over 90% of CAOC area) with very limited
free space available to construct and accommodate treatment system and equipment.
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• Operational impacts, potential losses, and competitive consequences of down time.
• Numerous underground utilities (electrical, communication, sewer, water, gas) located
throughout the building footprint.
• Inadequate access and vertical clearance inside Building 573 to accommodate large
drilling equipment required.
Due to the above conditions, alternatives designed to address the vadose zone contamination
directly under CAOC 16 (i.e., horizontal and vertical AS/SVE systems) were determined to be
extremely costly and logistically difficult, yet limited in terms of the incremental risk
reduction and protection to human health and the environment.
Despite the uncertainties at CAOC 16, the DON believes the selected remedy for the Yermo Annex
outlined in Section 3.7 of this ROD will effectively achieve the groundwater cleanup goals.
Therefore, the DON is willing to agree to achieve the groundwater cleanup standards throughout
the contaminant plume solely in the interest of obtaining the concurrence of EPA, DTSC, and the
RWQCB on this ROD, but reserves its right to propose a point of compliance (POC) for this CAOC
at a later date as set forth in Section 2.8.2.
At EPA's request, the DON will install nested soil vapor monitoring probes beneath Building 573
at three locations agreed to with the regulatory agencies. The vapor probes will be installed
at shallow, intermediate and deep depths. Data from the three soil vapor probe locations will
be taken initially to establish a baseline, and on an annual basis thereafter. Data will be
submitted on an annual basis as part of the groundwater monitoring report (see Section 2.8.12).
The monitoring frequency may be modified as appropriate as determined by the FFA signatories.
Evaluation of the progress of the selected remedy in meeting groundwater cleanup standards shall
occur every 5 years as an FFA deliverable attached to the CERCLA Section 121 (c) 5-year review
report. The 5-year progress evaluation shall specifically consider the CAOC 16 groundwater
monitoring well and vapor probe data. The signatory parties to this ROD will jointly evaluate
whether the groundwater monitoring well and vapor probe data demonstrate that adequate progress
is being made towards meeting cleanup goals at CAOC 16. If the FFA signatories determine that
the remedial action is not resulting in adequate progress, the DON shall prepare a follow-up FFA
deliverable report to be submitted to the FFA signatories addressing the following subjects.
a) The, potential need for additional remedial action at CAOC 16 (with supporting
rationale, analysis, and documentation).
b) An evaluation of the technical and economic feasibility of further Investigation and
remediation beneath Building 573 and the Building 573 hardstand to meet the RAO.
This feasibility analysis will identify and evaluate one or more approaches to
adequately characterize and remediate CAOC 16. The analysis shall evaluate the
approaches against the nine NCP criteria: overall protection of human health and the
environment; compliance with ARARs; long-term effectiveness and permanence; reduction
of toxicity, mobility, or volume through treatment; short-term effectiveness;
implementability; cost; state acceptance; and community acceptance. Evaluation of
the implementability shall specifically include the impact of the approaches on Base
operations, and any relevant technological advances. Discussion of the overall
protection of human health criteria should include consideration of changes in land
use. The evaluation of community acceptance shall specifically include social and
economic impacts that the approaches may have on the surrounding community. Such
impacts may include the consequences of any related degradation in the economic
viability and competitiveness of MCLB Barstow.
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c) Whether the basis for a CERCLA Section 121 (d)(4)(C) "Technical Impracticability"
waiver from attaining MCLs has been established (with supporting rationale, analysis,
and documentation).
If appropriate, the agencies may reguest amendment of the OUs 1 and 2 ROD in accordance with
paragraph 7.10 of the FFA.
2.8.8 Approach for Groundwater and Vadose Zone Cleanup at CAOC 26
CAOC 26 encompasses a packaging and maintenance shop and the area around it. Significant vadose
zone and groundwater contamination was detected at this CAOC Contamination at this CAOC has been
contained, and source reduction via AS/SVE is ongoing as part of a NTCRA. Pump and treat
remediation enhanced with AS/SVE has been selected as the final remedy which is already in
place. The pump and treat and AS/SVE systems will be operated until RAOs for groundwater and
vadose zone cleanup are achieved.
Achievement of the RAO for vadose zone cleanup will be demonstrated through sampling of the soil
vapor probes already in place at this CAOC. The AS/SVE system will be operated until shut-off
criteria set forth in Section 2.8.4 of this ROD are met. Achievement of the groundwater RAO
will be demonstrated through sampling of compliance groundwater monitoring wells agreed upon by
all parties. The DON will submit an FFA primary document to demonstrate that the RAOs have been
achieved.
Despite agreeing to achieve the groundwater cleanup standards throughout the contaminant plume
at CAOC 26, the DON reserves its right to propose a POC for this CAOC at a later date as set
forth in Section 2.8.2.
2.8.9 Approach for Groundwater and Vadose Zone Cleanup at Warehouse 2 (Nebo North Plume)
Warehouse 2 is the Old Repair Facility where major industrial operations took place from 1942 to
1961. Residual vadose zone VOC contamination has been detected underlying the location of three
former UST sites. Source reduction at Warehouse 2 using AS/SVE has been selected as part of the
final remedial alternative for Nebo North, which also includes natural attenuation of the
groundwater contaminant plume and fail-safe pump-and-treat in the event that natural attenuation
fails to contain the plume.
Vadose zone contamination at Warehouse 2 will be characterized to adeguately design the AS/SVE
system. The AS/SVE system will be installed at appropriate locations. Achievement of the RAO
for vadose zone cleanup will be demonstrated through sampling of soil vapor probes to be
installed upon completion of the remedial design characterization phase. The AS/SVE system will
be operated until both the vadose zone and groundwater RAOs have been achieved within the source
area, according to the AS/SVE shut-off criteria set forth in Section 2.8.4 of this ROD.
Achievement of the groundwater RAO will be demonstrated through sampling of compliance
groundwater monitoring wells agreed upon by all parties. Natural attenuation of the groundwater
plume will be monitored until groundwater RAOs are achieved throughout the entire contaminant
plume. In the event that natural attenuation fails to make adeguate progress towards achieving
the groundwater cleanup standards, the pump-and-treat system will be operated as a backup system
to enhance the remediation time and contain the contaminant plume. The DON will submit an FFA
primary document to demonstrate that the RAOs have been achieved.
Despite agreeing to achieve the groundwater cleanup standards throughout the contaminant plume
at Warehouse 2, the DON reserves its right to propose a POC for this area at a later date as set
forth in Section 2.8.2.
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2.8.10 Approach for Groundwater and Vadose Zone Cleanup) at CAOC 6 (Nebo South Plume)
At CAOC 6, documented releases and disposal of solvents to the ground surface took place dating
back to 1943. Groundwater and vadose zone contamination has been detected at this CAOC. A
pilot study conducted to assess the feasibility of AS/SVE for source reduction yielded
inconclusive results. In addition, additional characterization of the extent of soil and
groundwater contamination is needed to support remedial action decisions. Therefore, an interim
remedy was selected for the Nebo South plume.
Groundwater contamination will be contained by five off-Base groundwater extraction wells as an
interim remedy. During the interim remedy period, Phase II of the AS/SVE pilot study, including
additional characterization, will be conducted at this CAOC. The DON will submit an FFA
deliverable to document the results of these studies (see Section 2.8.12). Determination of
RAOs will be deferred until the final ROD for the Nebo South Plume.
2.8.11 Remedial Approach for Groundwater at CAOCs 23, 35, and 15/17
At CAOCs 23 and 35 waste will be left in place and contained. The waste will be capped and
monitored in accordance with ARARs and the presumptive remedy for CERCLA landfills. The
majority of waste residues from the lined ponds at CAOC 15/17 have been removed and the ponds
closed in conformance with RWQCB Toxic Pit Closure Act (TPCA) reguirements. Vadose zone cleanup
will not be conducted at these WMUs.
Groundwater RAOs for these WMUs will be achieved through continued operation of the Yermo Annex
plume groundwater pump and treat system. When groundwater RAOs are attained at and beyond the
point of compliance, remedial action will be considered complete. Evaluation of progress to
attain the groundwater RAOs (i.e., MCLs at and downgradient of the point of compliance) shall
occur every 5 years, as an FFA deliverable attached to the CERCLA Section 121(c) 5-year review
report. The evaluation of progress will be measured at agreed upon monitoring wells located as
close as practical to the downgradient edge of the WMUs. When MCLs are achieved at the
downgradient edge of the WMUs, the remedial action for these CAOCs will be considered complete.
2.8.12 Initial Groundwater and Vadose Zone Primary FFA Deliverable
The DON will submit to the agencies, as the first primary FFA deliverable, a summary of all
groundwater and vadose zone monitoring within 24 months of the signing of this ROD. This
document will consolidate the vadose zone and groundwater data to be collected from the OUs 1
and 2 source areas (including CAOCs 16, 15/17 and 26 at the Yermo Annex and Warehouse 2 and CAOC
6 at the Nebo Main Base) during the initial ROD implementation period into a single deliverable.
These data will be used to address the specific objectives of each CAOC, as follows:
CAOCs 16;(see Section 3.3.2):
• As reguested by EPA, data collected from the soil vapor monitoring probes for use
during the 5-year review evaluation.
CAOCs 15/17 (see Section 3.3.2):
• As reguested by EPA, data collected from the wet well for use during the 5-year
review evaluation.
CAOC 26 (see Section 3.3.2):
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Evaluate need for shallow vadose zone SVE wells to enhance the cost-effectiveness of
the remediation system.
Warehouse 2 (see Section 4.3.2):
• Characterization of extent of vadose zone contamination underlying Warehouse 2, to be
assessed during the AS/SVE remedial design phase for the Nebo North plume.
• Determination of cost effective AS/SVE system design reguirements.
• Results of additional groundwater monitoring taken up to that time, designed to
support that natural attenuation is occurring at the Nebo North plume.
CAOC 6 (See Section 5.3.2):
• Additional characterization of the extent of vadose zone and groundwater
contamination underlying CAOC 6.
• Evaluation of the technical feasibility of AS/SVE to effectively cleanup contaminants
in vadose zone and groundwater thereby reducing the cleanup time.
• Determination of radius of influence of AS/SVE system.
• Estimate of the amount of VOC mass in soil and groundwater, time for plume cleanup,
and cost of full-scale AS/SVE system implementation.
• Recommendations regarding AS/SVE system capability, and other technologies which may
be more effective if AS/SVE is deemed technically not feasible.
After this initial primary FFA deliverable, monitoring data from groundwater monitoring wells
and soil vapor probes will be submitted on an annual basis as part of the annual groundwater
monitoring report.
2.9 National Contingency Plan Statutory Balancing Criteria
Section 121 of CERCLA and Section 300.430 of the NCP reguires that remedial alternatives be
evaluated to determine which alternative provides the best balance with respect to criteria in
Section 121 of CERCLA and Section 300.430 of the NCP.
The NCP categorized the nine evaluation criteria, discussed in detail in the Draft Final
FS for OUs 5 and 6 (Jacobs 1996a), into three groups.
1) Threshold Criteria address overall protection of human health and the environment,
compliance with ARARs (or invoking a waiver).
2) Primary Balancing Criteria address long-term effectiveness and performance; reduction
of toxicity, mobility, or volume; short-term effectiveness; implementability, and
cost. These primary balancing factors are used to weigh major trade-offs among
alternative remediation strategies.
3) Modifying Criteria address state and community acceptance that are formally taken
into account after public comment is received on the Proposed Plan and incorporated
in the ROD.
The selected alternative must meet the threshold criteria of protection of human health and the
environment and compliance with all ARARs. Any alternative that does not satisfy both of these
reguirements is not eligible for selection. The primary balancing criteria are the technical
criteria upon which the detailed analysis is primarily based. The final two criteria, known as
modifying criteria, assess the public's and the state agency's acceptance of the criteria. The
Marine Corps may modify aspects of a specific alternative based upon these criteria.
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2.10 Applicable and Relevant or Appropriate Requirements
The NCP states, "Overall protection of human health and the environment and compliance with
ARARs (unless a specific ARAR is waived) are threshold requirements that each alternative must
meet in order to be eligible for selection" (EPA 1990a).
Identification of ARARs is a site-specific determination. It involves determining whether a
given requirement is applicable and if it is not applicable, then whether it is relevant and
appropriate.
A requirement is deemed applicable if the specific terms of the law or regulation directly
address the chemical of concern, the remedial action, or the location involved (e.g., cultural
or environmental resources). If the jurisdictional prerequisites of the law or regulation are
not met, a legal requirement may nonetheless be relevant and appropriate if the site's
circumstances are sufficiently similar to circumstances in which the law otherwise applies, and
if the requirement is well suited to the conditions of the site.
Where ARARs do not exist, the NCP also provides agency advisories, criteria, or guidance to be
considered (TBC) useful in helping to determine what is protective at the site or how to carry
out certain actions or requirements (EPA 1990a) (55 Federal Register 8745). The NCP preamble
states, however, that provisions in the TBC category "should not be required as cleanup
standards because they are, by definition, generally neither promulgated nor enforceable, so
they do not have the same status under CERCLA as do ARARs."
As the lead federal agency, the Marine Corps has primary responsibility for identifying federal
ARARs at MCLB Barstow. As the lead state agency, DTSC is primarily responsible for identifying
state ARARs. MCLB Barstow initiated this process and the DTSC forwarded this request to several
state agencies. Responses were received from the California Department of Health Services, the
RWQCB, California Department of Fish and Game, and the California Integrated Waste Management
Board. The ARARs presented in this response have been reviewed and included in the ARARs
evaluation conducted in Appendix D of the FS Report for OUs 1 and 2 (Jacobs 1996a).
In addition, MCLB Barstow identified state ARARs in the Environmental Evaluation/Cost Analysis
(EE/CA) for the OU 1 removal action (Jacobs 1995c). Comments were received from EPA Region IX
and the California Regional Water Quality Control Board, Lahontan Region. These comments and
additional state ARARs that were identified were also included in the ARARs evaluation in
Appendix D of the FS Report for OUs 1 and 2.
Requirements of ARARs and TBCs are generally divided into three categories:
• Chemical-specific ARARs are health- or risk-based numerical values for various
environmental media, specified In state or federal statutes or regulations. These
numerical values establish the acceptable amount or concentration of a chemical that
may be present in a specific medium at a site, or that may be discharged to the site
or the ambient environment during remedial actions.
• Location-specific ARARs address the areas in which the remedial action takes place.
Identified regulations that are potential ARARs may require actions to preserve or
protect aspects of environmental or cultural resources that may be threatened by the
remedial actions to be undertaken at the site.
• Action-specific ARARs are regulations that apply to specific activities or
technologies used to remediate a site. They can include design criteria and
performance standards.
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Chemical-specific, location-specific, and action-specific ARARs driving the development of
remedial actions objectives (RAOs) for groundwater and vadose zone soils at MCLB Barstow are
discussed in the sections that follow and summarized in Tables 2-2 through 2-7. A detailed
discussion of all the ARARs considered for groundwater remedy are included in the FS Report for
OUs 1 and 2 (Jacobs 1996a).
2.10.1 Chemical-Specific ARARs Driving Remedial Action Objective
Based on the above discussion and the evaluation presented in the FS for OUs 1 and 2, the
substantive provisions of the following reguirements have been identified as chemical-specific
ARARs driving the development of remedial action objectives for the contaminant plumes in OUs 1
and 2:
Water Quality Control Plan (WQCP) for the Lahontan Region, 1995 (water guality
objectives, beneficial uses, waste discharge limitations).
• Federal maximum contaminant levels (MCLs) and nonzero maximum contaminant level goals
(MCLGs).
State primary MCLs in Title 22 CCR.
• Resource Conservation and Recovery Act (RCRA) groundwater protection standards in
Title 22 CCR Sections 66264 . 94 (a) (1) , (a) (3) , (c) , (d) , and (e) .
Of these reguirements, the most stringent are the reguirements under the RCRA groundwater
protection standards and Title 22 CCR Section 66264.94 to restore affected groundwater to
background conditions or the best water guality that is reasonable if background levels of water
guality cannot be achieved.
The Department of the Navy (DON) has determined that the substantive provisions of Title 22 CCR
Section 66264.94(a) (1), (a) (3), (c), (d), and (e) constitute 'relevant and appropriate' federal
ARARs for groundwater and vadose zone (i.e., the unsaturated zone) contamination associated with
the Yermo groundwater plume (CAOCs 15/17,16,23,26 and 35) and the Nebo North (Warehouse 2) and
South (CAOC 6) plumes. It is noted that the reguirements at Title 23 CCR Division 3 Chapter 15
Article 5 are applicable for the inactive waste management units at CAOCs 23 and 35 (landfills)
and the majority of CAOC 15/17 (surface impoundments). However, the Title 23 CCR reguirements
are not ARARs because they are no more stringent than relevant and appropriate federal ARARs at
22 CCR. The substantive provisions of Title 22 CCR 66264.94 are considered to be relevant and
appropriate for this remedial action and are federal ARARs because they are federally
enforceable (55 Federal Register 8765, March 8, 1990).
DON'S Position Regarding SWRCB Resolution Nos. 92-49 and 68-16
The DON recognizes that the key substantive reguirements of 22 CCR 66264.94 (and the identical
reguirements of 23 CCR 2550.4 and Section III. G of State Water Resources Control Board [SWRCB]
Resolution 92-49) reguire cleanup to background levels of constituents unless such restoration
proves to be technologically or economically infeasible and an alternative cleanup level of
constituents will not pose a substantial present or potential hazard to human health or the
environment. In addition, the DON recognizes that these provisions are more stringent than the
corresponding provisions of 40 Code of Federal Regulations (CFR) 264.94 and, although they are
federally enforceable via the RCRA program authorization, they are also independently based on
state law to the extent that they are more stringent than the federal regulations.
The DON has also determined that SWRCB Resolution 68-16 is not a chemical- specific ARAR for
determining remedial action goals. However, SWRCB Resolution 68-16 is an action-specific ARAR
for regulating discharged treated groundwater back into the aguifer. The DON has determined
that further migration of already-contaminated groundwater is not a discharge governed by the
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language in Resolution 68-16. More specifically, the language of Resolution 68-16 indicates
that it is prospective in intent, applying to new discharges in order to maintain existing high
guality waters. It is not intended to apply to restoration of waters that are already degraded.
The DON'S position is that SWRCB Resolutions 68-16 and 92-49 and 22 CCR 2550.4 do not constitute
chemical-specific ARARs for this remedial action because they are state reguirements and are not
more stringent than the federal ARAR provisions of 22 CCR 66264.94. The NCP set forth in 40 CFR
300.400(g) provides that only state standards more stringent than federal standards may be ARARs
(see also Section 121(d)(2)(A)(ii) of CERCLA). The determination of which regulations
constitute ARARs is documented in Appendix D of the FS Report for OUs 1 and 2 (Jacobs 1996a).
The substantive technical standard in the eguivalent state ARARs (i.e., Title 23 CCR, Chapter
15, SWRCB Resolution 92-49, and SWRCB Resolution 68-16) is identical to the substantive
technical standard in 22 CCR Section 66264.94. This section of Title 22 CCR will likely be
applied in a manner consistent with eguivalent provisions of other regulations, including SWRCB
Resolutions 92-49 and 68-16.
State of California's Position Regarding SWRCB Resolutions Nos. 92-49 and 68-16
The State does not agree with the Marine Corps' determination that SWRCB Resolutions 92-49 [and
68-16] and certain provisions of Title 23 CCR, Division 3, Chapter 15 are not ARARs for this
ROD. However, the State agrees that actions proposed in this ROD would comply with Resolutions
92-49 [and 68-16] and compliance with the Title 22 provisions should result in compliance with
the Title 23 provisions. The State does not intend to dispute the ROD, but reserves its rights
if implementation of the Title 22 CCR provisions is not as stringent as State implementation of
Title 23 CCR provisions. Because Title 22 CCR regulation is part of the State's authorized
hazardous waste control program, it is also the State's position that Title 22 CCR 66264.94 is a
State ARAR and not a federal ARAR (U.S. v. State of Colorado, 990 F.2d 1565, [1993]).
Whereas the DON and the State of California have not agreed on whether SWRCB Resolution Nos.
92-49 and 68-16 and Title 23 CCR Section 2550.4 are ARARs for the remedial action at the Yermo
plume and the Nebo North and South plumes, this ROD documents each of the parties' positions on
the resolutions but does not attempt to resolve the issue.
2.10.2 Location-Specific ARARs
Location-specific reguirements include those that involve restrictions on how remedial
activities are to be conducted in particular locations. CAOC 6 is near a robust creosote
community that Is home to a significant population of desert tortoise. Because the desert
tortoise is an endangered species, reguirements pertaining to the protection of special-status
species are ARARs as listed in Table 2-4.
2.10.3 Action-Specific ARARs
Action-specific reguirements for OUs 1 and 2 were identified for waste generation, potential air
emissions, discharge of treated water, and groundwater monitoring for RCRA landfill closure.
These action-specific ARARs are listed in Tables 2-6 and 2-7. The following discussion expands
on the groundwater monitoring reguirements for CAOCs 23 and 35.
Landfill Closure Groundwater Monitoring Requirements
To promote efficiency in the implementation of groundwater monitoring reguirements for MCLB
remedial actions, this ROD addresses the groundwater monitoring component of the landfill
closure reguirements for CAM 23 and 35. Federal and State reguirements that pertain to
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groundwater monitoring for RCRA corrective action programs are described below.
Federal
As discussed in Section 2.10.1, portions of the RCRA groundwater protection standards contained
in Title 22 CCR are considered to be relevant and appropriate for the groundwater potentially
impacted by releases from CAOCs 23 and 35 because the hazardous constituents being addressed by
this action are similar or identical to those found in RCRA hazardous wastes. The substantive
reguirements of a corrective action program (CAP) is reguired for CAOCs 23 and 35 under 22 CCR
66264.100 and an evaluation monitoring program Lander 22 CCR 66264.99 is reguired to demonstrate
effectiveness and compliance. Substantive provisions of the following reguirements apply to the
development and implementation of a groundwater monitoring program for CAOCs 23 and 35:
Constituents of concern (22 CCR 66264-93)
Concentration limits (22 CCR 66264.94)
• Monitoring points and points of compliance (22 CCR 66264.95)
Detection monitoring program (22 CCR 66294.98)
Statistical method for detecting a release (22 CCR 66264.97[e])
Method for determining background (22 CCR 66264.97[e][11]).
State
The RWQCB Lahontan region identified the following reguirements for the development of a CAP
monitoring program for landfill closure:
Constituents of concern (23 CCR 2550.3)
Concentration limits (23 CCR 2550.4)
• Monitoring points and points of compliance (23 CCR 2550.5)
• Detection monitoring program (23 CCR 2550.8)
Statistical method for detecting a release (23 CCR 2550.7[e])
Method for determining background (23 CCR 2550.7 [e] [11]).
The Marine Corps has reviewed these provisions and has determined that they are identical to the
corresponding Title 22 Federal ARARs, except for the more prescriptive sampling reguirements
found in 23 CCR 2550.7 (e) (12) (B) and 23 CCR 25450.10(g) (2) . The Marine Corps accepts the more
prescriptive reguirements of 23 CCR 2550.7 (e) (12) (B) and 2550.10(g) (2) as State ARARs. However,
the other Title 23 reguirements cited are not ARARs for OU 1 and OU 2 remedial actions because
they are not more stringent than the Federal ARARs identified under Title 22.
Conclusions
The Federal reguirements for CAP monitoring under Title 22 Article 6 are eguivalent to the State
reguirements for CAP monitoring under Title 23 Article 5. Because State reguirements would only
be considered ARARs to the extent that they are more stringent than Federal reguirements, the
Title 22 reguirements for CAP monitoring would be the controlling ARARs for remedial actions at
CAOCs 23 and 35. The exceptions are the more prescriptive sampling reguirements found in 23 CCR
2550.7(e)(12)(B) and 2550.10(g)(2). The Marine Corps accepts the more prescriptive reguirements
of 23 CCR 2550.7 (e) (12) (B) and 2550.10(g) (2) as State ARARs.
2.11 Highlights of Community Relations and Participation
The community of Barstow is kept well informed about the MCLB Barstow remedial actions for soils
and groundwater under the CERCLA program. The remedial investigation/feasibility study (RI/FS)
and the Proposed Plan for MCLB Barstow OUs 1 and 2 were released to the public on November 3,
-------
1997. The documents were made available to the public through the Administrative record
(Appendix B) contained in the information repositories at the County of San Bernardino Public
Library, Barstow Branch, and at MCLB Barstow Facilities and Services Division, Environmental
Department, Warehouse 3. The notice of availability for the Proposed Plan the supporting
documents were published in the Barstow Desert Dispatch, the Sun (San Bernardino), and the Daily
Press (Victorville), on November 3, 1997. Also, the Proposed Plan was mailed to approximately
1,500 local and interested parties per the site mailing list. A public comment period was held
from November 3 through December 3, 1997. A public meeting was held at the Barstow Holiday Inn
on November 12, 1997. Several minor comments were received from the public during the public
comment period. Transcripts from the meeting, which include the public comments are contained
in Appendix C.
-------
Table 2-1
Operable Units 1 & 2 Contaminants of Concern
Groundwater Cleanup Levels (Ig/L)
Basis for Goal
TBC RBCs b
Contaminant
Drinking water
Standard*
Reference
Cancer
Non-Cancer
1,1,1- Trichloroethene
200
1,2
1,1 -Dichloroethane 5
1,1-Dichloroethene (1,1-DCE) 6
l,l,2-Trichloro-l,2,2-Trifluoroethane (Freon 113) 1200
1,2-Dichloroethane (1,2-DCA) 0.5
cis-l,2-Dichlorethene(cis-1,2-DCE) 6
trans-1,2-Dicthloroethene(trans-1,2-DCE) 10
1,2-Dichloroethene, Total 6
2-Butanone(MEK)
2-Hexanone
4-Methyl-2-Pentanone(Methyl isobutyl Ketone)
Acetons
Benzene
N
N
N
N
1
N
N
N
N
2
N
N
N
N
1,900
N
160
610
Bromodichloromethane 100
Bromoform 100
Carbon Bisulfide N
Carbon Tetrachloride 0.5
Chloroform 100
Chloromethane N
Dibromochloromethane 100
1,2-Difluoro-l,1,2,2 Tetrachloroethane(Freon 112) N
1,2-Dichloro-l,1,2,2-Tetrafluoroethane(Freon 114) N
Methylene Chloride 5
Tetrachloroethene(PCE) 5
1
1
N
2
1
N
1
N
N
1
1,2
21
1.5
N
N
N
N
-------
Toluene c
Trichloroethene(TCE)
Trichloromethane(Freon 11)
Xylenes(Totals) c
425
5
150
175
0
1,2
2
0
Footnotes:
a Most stringent of federal and state MCL
b To be considered (TBC) risk-based criteria (RBC) where drinking water standard is not available. Source: EPA Region IX
Preliminary Remediation Goals, August 1, 1996.
c DON agrees to implement taste and odor objectives for toluene and xylene purposed by EPA, but not promulgated, as
"to-be-considered" standards (See Section 2.8.1)
References
1 - Federal MCL
2 - State MCL
N - None
0 - Other
-------
TABLE 2-2
Federal Chemical-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirement
Determination
National primary drinking water standards
are health-based standards for public water
systems (maximum contaminant levels
[MCLs]).
The National Oil and Hazardous Substance Pollution
Contingency Plan (NCP) defines MCLs as relevant and
appropriate for groundwater determined to be a current or
potential source of drinking water in cases where MCLB
are not ARARs. Groundwater in the vicinity of MCLB
Barstow has been designated for drinking water use.
Maximum contaminant level goals (MCLG s)
pertain to known or anticipated adverse
health effects (also known as recommended
maximum contaminated levels).
Pubic Law No. 99-339
100 Statute 642
(1986)
40 CFR 141
Subpart F
22 CCR 66261.21,
66261.22(a) (1) ,
66261.23,
66261.24(a)(1), and
66261.100
Applicable
MCLGs that have nonzero values am relevant and
appropriate for groundwater determined to be a current or
potential source of drinking water (40 CFR
300. 430 [e] [2] [i] [B] through [D] ) . Groundwater in the
vicinity of the MCLB Barstow has been designated for
drinking water use. Nonzero MCLGs exist for some of
the chemicals of potential concern for Oils 1 and 2 .
Groundwater protection standards:
Owners/operators of RCRA treatment.
storage, or disposal facilities must comply
with conditions in this section that are
designed to ensure that hazardous
constituents entering groundwater from a
regulated unit do not exceed the
concentration limits set forth under Section
66264.94 for contaminants of concern in the
uppermost aguifer underlying the waste
management area beyond the point of
compliance.
Uppermost aguifer underlying a 22 CCR 66264.94,
waste management unit except 66264.94 (a) (2
beyond to point of and 94(b)
compliance; RCRA hazardous
waste, treatment storage, or
disposal.
These standards we not applicable because the
groundwater contamination being addressed by the OUs
1 and 2 did not result from releases from RCRA-regulated
units. However, substantive provisions of these
requirements may be considered relevant and appropriate
for groundwater because the hazardous constituents
being addressed by this action are similar or identical tc
those, found in RCRA hazardous wastes.
U.S. EPA Region
August 1, 1996
-------
TABIiE 2-2
Federal Chemical-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of
the reader. Listing the statutes and policies does not indicate that Navy accepted the statutes or policies as potential ARARs. Specific
potential ARARS are addressed in the table below each general heading; only substantive reguirements of the specific citations are considered
potential ARARs.
ARARs - Applicable or relevant and appropriate reguirements RCRA - Resource Conversation and Recovery Act
CCR - California Code of Regulations SDWA - Safe Drinking Water Act
MCLs - Maximum contaminent levels TCLP - Toxicity characteristics leaching procedure
MCLGs - Maximum contaminent level goals USC - United States Code
NCP - National Oil and Hazardous Substance Pollution Contingency Plan
Chemical-specific concentrations used for feasibility study(FS)evaluation may not be ARARs indicated in this table, but may be concentrations
based upon other factors. Such factors may include the following
Human health risk-based concentrations (risk-based; PRGs 40 CFR 300.430 [e][A][1] and [2]).
Ecological risk-based concentrations (40 CFR 300.430[e][G]).
Practical guantitation limits of contaminants (40 CFR 300.430[e] [A] [3]) .
-------
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirements
Determination
Definition of "Non-RCRA hazardous waste" ;
persistent and bioaccumulative toxic substances total
threshold limit concentrations (TTLCs) and soluble
threshold limit concentrations (STLCs).
22 CCR 66261.22 (a) (3) and
(4),66261.24 (a) (2)to (a) (8),
66261.101,66261.3 (a) (2) (C),
or 66261.3(a) (2) (F)
Applicable The chemical concentrations in all of to OU 1
and 2 monitoring wells are below to STLC
limits; therefore to extracted groundwater
would not be considered a characteristic
hazardous waste.
Hazardous waste determinations for soil cutting
generated from the installation of extraction,
conveyance and treatment systems and spent
carbon from groudwater and off-gas treatment
will be made at the time the wastes are
generated.
CR 64435 and 64444.5 Relevant and Like federal MCLS, state MCLs are tap
appropriate for standards that are relevant and appropriate for
groundwater the drinking water aguifers at MCLB Barstow.
Describes the water basins in Lahontan region.
Establishes beneficial uses of ground and surface
waters. Establishes water guality obj ectives,
inducing narrative and numerical standards.
Establishes Implementation plant to meet water
guality obj ectives and protect beneficial uses, and
incorporates statewide water guality control plans and
policies.
Substantive provisions In Chapters 2,4,and 5 of
the plan we ARARs,including beneficial use
designations, water guality obj ectives, and water
discharge limits.
-------
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirement
Incorporated into all Regional Board Basin Plans.
Designates all ground and surface waters of the State
as drinking water except where the TDS is greater
than 3,000 ppm, the well yield is less than 200 gpd
from a single well, the water is a geothermal resource
or in a water conveyance facility, or the water cannot
reasonably be treated for domestic use using either
best management practiose or best economically
achievable treatment practices.
Incorporated into all Regional Board Basin Plans.
Requires that quality of waters of the state that is
better than needed to protect all beneficial uses be
maintained unless certain findings are made.
Discharges to high-quality waters must be treated
using best practicable treatment or control necessary
to prevent pollution or nuisance and to maintain the
highest quality water. Beneficial uses must, at least,
be protected.
SWRCB Resolution No.68-16
(Policy with Respect to
Maintaining High Quality
Waters in California)(Water
Code 13140, Clean Water Act
regulations 40 CFR 131.12)
ARAR
Determination
Applicable
Applicable
Comments
This resolution provides the basis for drinking
water determinations in California. Substantive
provisions are ARARs. The groundwater at
MCLB Barstow has been identified as a source
of drinking water.
Action-specific ARAR for regulating discharges
of treated groundwater back into aquifer.
Discharges to groundwater that occur as part of
the OUs 1 and 2 remedial actions must meet the
substantive requirements of Resolution 68-16.
This resolution is only applicable to the treated
water discharges and not to the cleanup of the
groundwater or the potential migration of
contaminant plumes.
-------
TABLE 2-3
State Chemical-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirement
Citation
ARAR
Determination
Establishes policies and procedures for the oversight
of investigations and cleanup and abatement
activities resulting from discharge of waste that
affect or threaten water guality. It authorizes the
Regional Boards to reguire cleanup of all waste
discharged and restoration of affected water to
background conditions. Requires actions for cleanup
and abatement to conform to Resolution 68-16 aid
applicable provisions of Title 23 CCR Division 3,
Chapter 15, as feasible.
SWRCB Resolution 92-49
(Policies and Procedures for
Investigation and Cleanup
and Abatement of Discharges
Under Water Code Section
13304)
Provides general waste discharge requirements for
land disposal of treated groundwater. The order
contains discharge specifications that include 30-day
median and daily maximum values. Discharge
monitoring program requirements are also specified
Lahontan RWQCB Resolution TEC
6-93-106 [General Waste
Discharge Requirements for
Land disposal of Treated Groundwater.
As Resolution 92-49 is no more stringent then
22 OCR 66264.94, a relevant and appropriate
federal ARAR, the resolution do" not qualify as
a state ARAR under CERCLA. The State does
not agree with the Maine Corps' determination
that SWRCB Resolutions 92-49 and 68-16 and
certain provisions of Title 23 CCR, Division 3,
Chapter 15 are not ARARs for this ROD.
However the State agrees that actions
proposed in this ROD would comply with
Resolutions 92-49 and 6816 and compliance
with the Title 22 CCR provisions should result in
compliance with Title 23 CCR provisions. The
State does not intend to dispute the ROD, but
reserves its rights if implementation of the Title
22 CCR provisions is not as stringent as State
implementation of Title 23 CCR provisions.
Discharge of treated groundwater to oxidation ponds
or infiltration galleries would need to meet these
discharge and monitoring requirements. See Table 2-
for the treated groundwater discharge limitations.
ARARs Applicable or relevant and appropriate requirements
CAOC CERCLA Area of Concern
CCR California Code of Regulations
CFR Code of Federal Regulations
gpd gallons per day
MC Marine Corps
ppm parts per million
PRG preliminary remediation goal
RCRA Resource Conservation and Recovery Act
RWQCB Regional Water Quality Control Board, Lahontan Region
STLC soluble threshold limit concentration
SWRCB California Side Water Resources Control Board
TEC To be considered
TDS total dissolved solids
TTLC total threshold limit concentration
Chemical-specific concentrations used for remedial action alternative evaluation may not be ARARs indicated in this table, but may be concentrations based upon other factors.
the following:
Human health risk-based concentrations (Risk-based PRGs) [40 CFR 300.430 (e) (A) (1) and (2)].
Ecological risk-based concentrations [40 CFR 300.430(e)(G)].
Practical guantitation limits of contaminants [40 CFR 300.430(e)(A)(3)].
-------
Requirement
TABLE 2-4
Federal Location-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination
Within area
where action
may cause
irreparable harm,
loss, or
destruction of
significant
artifacts
Construction on previously
undisturbed land would
require an archaeological
survey of the area.
Alteration of terrain that Substantive
threatens significant requirements of
scientific, prehistoric, historic, 16 USC 469a-l
or archaeologic data and 38 CFR 65.
Phase I archeological surveys would need to be
conducted if remedial action activities take place
in areas that have not been surveyed for cultural
resources.
Critical habitat
upon which
endangered
species or
threatened
species depend
Action to conserve
endangered species or
threatened species, including
consultation with the
Department of the interior.
Migratory Bird Treaty Act of 1972*
Migratory bird
area
Protects almost all species of
native birds in the U.S. from
unregulated "take," which can
include poisoning at
hazardous waste sites.
Presence of migratory birds.
Relevant and
Appropriate
Migratory birds and nesting activities have been
documented on MCLB Barstow, particularly in the
riparian edge zone on the northern boundary of
Nebo. Actions to be taken as part of OU 1 and 2
remedial alternatives are not expected to impact
migratory bird activities.
-------
TABLE 2-5
State Location-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirement
ARAR
Determination
Projects within the state shall not jeopardize the
existence of any endangered or threatened species
or result in the destruction or adverse modification of
habitat essential to the species, if there are
reasonable and prudent alternatives available
consistent with preserving the species that or its
habitat which would prevent j eopardy. No person
shall import, export, take, possess, or sell any
endangered or threatened species or part or product
thereof.
Threatened or endangered
species determination on or before
1 January 1985 or a candidate
species with proper notification.
Relevant and Actions to be taken as part of OU 1 and 2
appropriate remedial alternatives are not expected to
have any long-term impacts on threatened
or endangered species. Desert tortoise
mitigation measures will be followed
during the implementation of remedial
actions.
-------
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Requirement
ARAR
Determination*
allow movement of contaminants into
underground sources of drinking water
which may result in violations of MCLs or
adversely affect health. Five
may reasonably be expected to be, a
source of drinking water if the
contaminant(s) may cause a violation of
any primary drinking water regulation or
classifications of injection wells provided. may adversely affect human health.
Substantive
requirements of 40
CFR 144, 145, 146,
and 147 under the
conditions noted in the
comment
The infiltration galleries
proposed as part of the
OU 1 remedial alternatives
would be Class V wells under
this rule since the infiltrated
groundwater would not be a
hazardous waste. There are
currently no requirements for
injection into Class V wells.
Substantive provisions of
these requirements are
relevant and appropriate only
to the extent necessary to
ensure that the injection
activities would not cause the
water In the receiving aquifer
to violate primary drinking
water regulations.
Statutes and policies, and their citations, we provided as heading to identify general categories of potential ARARs. Listing the statues and policies does not indicate that the Navy accepts all the
statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are considered potential
ARARs.
Potential actions: 1) Monitoring access restrictions. 2) Groundwater extraction and conveyance. 3) Ex situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of
treated groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging.
-------
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination*
Water Quality Monitoring Program.
Owners/operators of RCRA treatment,
storage, and disposal facilities must
develop and implement a water guality
monitoring program to monitor the
potential for releases from the facility
to demonstrate the effectiveness of a
corrective action program (CAP).
Uppermost aguifer underlying a waste
management unit beyond the point of
compliance; RCRA hazardous waste,
treatment, storage, or disposal.
22 CCR Sections
66264.93; 66264.94,
66264.95,
66264.97(e),
66264.98, 66264.100
The groundwater standards
under RCRA are considered
relevant and appropriate for
remedial actions for
groundwater and the vadose
zone since the hazardous
constituents being addressed
are similar or identical to those
found in RCRA hazardous
waste.
Reguires monitoring and maintenance for
30 years unless it is demonstrated that
human health and the environment are
protected.
The substantive reguirements
of these provisions are
relevant and appropriate for
groundwater monitoring of
CAOCs 35 and 23.
Emissions reduction by at least 85
percent. Exemptions are provided for
emissions of photochemically reactive
solvents that do not exceed 39.6 Ib/day
and for non-photochemically reactive
solvents that do not exceed 2970 Ib/day.
Discharge of organic materials into the Moj ave AQMD
atmosphere from eguipment in which Rule 442
organic solvents or materials containing
organic solvents are used.
The maximum potential
emissions for the vapor
extraction and air sparging
systems are below the limits
set for solvents. Also, the
emissions controls planned for
these systems achieve greater
than 85 percent reduction of
Voc emissions.
-------
Requirements for the preconstruction
review of now or modified facilities to
ensure that construction, or modification
of such facilities does not interfere with
the attainment and maintenance of
ambient air quality standards. This
requlation provides for no net increase in
the emission of any affected air pollutant
from now major facilities or any
modification to an existinq maj or facility.
TABLE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination*
Applies to all new or modified facilities
which are required, under District rules, to
obtain an authority to construct; facilities
for which offsets are required to be
obtained pursuant to Rule 1307; or for
which the use of BACT is required (e.q.,
the potential to emit 25 pounds per day or
more of any affected pollutant).
The new source review
requirement is applicable for
new sources of volatile orqanic
air emissions at the bass since
base emissions exceed the
offset threshold for reactive
orqanic compounds of 25
tons/year. See text in Section
C4 . 1 . 1 for further discussion of
the applicability of this
requirement to emis s ions
controls for the vapor
extraction and air sparqinq
systems.
Standard for approvinq permits requires
that equipment be desiqned, controlled.
or equipped with air pollution control
equipment so that it may be expected to
operate without emittinq air contaminants
In violation of Section 41700 or 41701 of
the State Health and Safety Code or of
the Mojave AQMD Rules.
Mojave AQMD
Rule 212
The vapor extraction and air
sparqinq systems have the
potential to cause issuance of
air contaminants. On-site
actions under CERCLA are
exempt from procedural
requirements such as
permittinq. However,
notification of and concurrence
by the Mojave AQMD will take
place as part of the remedial
action review process.
-------
TABIiE 2-6
Federal Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
A Applicable ppm
AQMD Air Quality Management District RA
ARAR Applicable or relevant and appropriate requirement RCRA
BACT Best available control technology RWQCB
CAA Clean Air Act SWRCB
CCR California Code of Regulations SDWA
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act TBC
CFR Code of Federal Regulations UIC
EPA U.S. Environmental Protection Agency USC
LAER Lowest achievable emission rate VOC
Ib/day pounds per day Ig/m 3
MCLs Maximum contaminant levels
parts per million
Relevant and appropriate
Resource Conservation and Recovery Act
California Regional Water Quality Control Board, San Diego Region
California State Water Resource Control Board
Safe Drinking Water Act
To be considered
Underground Injection control
United States Code
volatile organic compound
micrograms per cubic meter
-------
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2\
MCIiB Barstow, California
ARAR
Determination*
Describes the water basins in the
Lahontan region. Establishes beneficial
uses of ground and surface waters.
Establishes water guality obj ectives,
including narrative and numerical
standards. Establishes implementation
plans to meet water guality obj ectives
and protect beneficial uses, and
incorporates statewide water guality
control plans and policies.
Comprehensive
Water Quality Control
Plan for the Lahontan
Region (Water Code
°1324Q)
Substantive provisions are ARARs for
discharges of treated groundwater. See
Table 2-_ for the treated groundwater
discharge limitations.
Discharges to
land or surface
or groundwater
that could affect
water guality
Authorize the State and regional water
boards to establish in water guality
control plans beneficial uses and
numerical and narrative standards to
protect both surface and groundwater
guality. Authorizes regional water
boards to issue permits for discharges
to land or surface oar groundwater that
could affect water guality, including
NPDES permits, and to take
enforcement actions to protect water
guality.
California Water
Code, Division 7,
Section 13241,
13243,13360,and
13263(a) (Porter-
Cologne Water
Quality Control Act)
Substantive provisions of sections cited, as
implemented through the beneficial use,
water guality obj ectives, and waste
discharge reguirements of the
Comprehensive Water Quality Control Plan
for the Lahontan Region are ARARs for
discharges to groundwater from CAOCs 23
and 35. Minimization of those discharges is
addressed by the CAOCs 23 and 35
proposed remedial actions; however, past
and current discharges to groundwater
from CAOCs 23 and 35 will be addressed
by the removal action planned for OU 1
groundwater and subseguent remedial
actions for groundwater at MCLB Barstow.
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive reguirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
-------
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination*
Citation
Leachate control and monitoring shall
cease only after the operator
demonstrates that leachate is not longer
being produced or the discharges of
leachate will have no affect on water
guality. The guantity and guality of
leachate must be monitored at least
guarterly or whenever groundwater
samples are collected.
Detection and verification monitoring in
accordance with 23 CCR, Chapter 15,
Article 5, must be conducted.
Groundwater monitoring during
postclosure must continue until leachate
is no longer being produced or opposes
no threat to water guality.
ith
Incorporated into all Regional Board SWRCB Resolution 4,5
Basin Plans. Reguires that guality of
waters of the State that is better than
needed to protect all beneficial uses be
maintained unless certain findings are
made. Discharges to high-guality waters
must be treated using best practicable
treatment or control necessary to
prevent pollution or nuisance and to
maintain the highest guality water.
Beneficial uses must, at least, be
protected.
Statutes and policies, and their citations, we provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive reguirements of the specific actions are considered potential ARARs.
Potential action: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
SWRCB Resolution
No. 68-16 (Policy
Respect to
Maintaining High
Quality of Waters in
California)(Water
Code ° 13140, Clean
Water Act regulations
40 CFR °131.12)
14 CCR 17781 (c) (2) cross-references the
reguirements of 23 CCR 2559 for design
reguirements for vadose zone monitoring to
detect the release of leachate. However,
Section 2559 was repealed 7/91, so no
specific regulatory reguirements exist for
the design of the vadose zone monitoring
system.
23 CCR, Chapter 15, Article 5, outlines
reguirements for identification of water
guality protection standards, constituents of
concern, concentration limits, monitoring
points and point of compliance, and
compliance period. It also has
specifications for water guality monitoring
and system reguirements.
Action-specific ARAR for regulating
discharges of treated groundwater back into
aguifer. Discharges to groundwater that occur
as part of the OUs 1 and 2 remedial actions
must meet the substantive reguirements of
Resolution 68-16. This resolution is only
applicable to the treated water discharges and
not to the cleanup of the groundwater or the
potential indignation of contaminant plumes.
-------
TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
Cleanup and
abatement of
wastes that
affect or threaten
water quality
Establishes policies and procedures for
the oversight of investigations and
cleanup and abatement activities
resulting from the discharges of waste
that affect or threaten water guality. It
requires cleanup of waste discharged in
a manner that promotes either
background water quality or the best
water quality that is reasonable if
background levels of water quality
cannot be achieved. Requires actions
for cleanup and abatement to conform to
Resolution 68-16 and applicable
provisions of Title 23 CCR, Division 3,
Chapter 15, as feasible.
SWRCB Re s olut i on
92-49 (Policies and
Procedures for
Investigation and
Cleanup and
Abatement of
Discharges Under
Water Code Section
13304)
The DON has determined that SWRCB
Resolution 92-49 does not constitute an
ARAR for the OUs 1 and 2 remedial actions
because its pertinent requirements are not
more stringent than the ARAR provisions of
Title 22 Section 66264.94. The State does
not agree with the determination that
SWRCB Resolution 92-49 is not ARAR for
this ROD. However, the State agrees that
actions proposed in this ROD would comply
with Resolution 92-49 and compliance with
the Title 22 provisions should result in
compliance with Resolution 92-49. The
State does not intend to dispute the ROD,
but reserves its rights if implementation of
the Title 22 CCR provisions is not as
stringent as State implementation of
Resolution 92-49.
Discharges of
treated
would
groundwater in
the Lahontan
Region
groundwater. The order contains
discharge specifications that include 30-
day median and daily maximum values.
Discharge monitoring requirements are
also specified.
[General Waste
Discharge
Requirements for
Land Disposal of
Treated Groundwater]
need to meet substantive discharge and
limits monitoring requirements. See Table
2-_ for the treated groundwater discharge
limitations.
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
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TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination"
Monitoring requirements for waste
management units; establishes water
quality protection standards for
corrective action including concentration
limits for constituents of concern at
background levels unless infeasible to
achieve. Cleanup levels greater than
background must meet all applicable
water quality standards, must be the
lowest levels technologically or
economically feasible, must consider
exposure via other media, and must
consider combined toxicological effects
of pollutants. A detection monitoring
program must be maintained except
during any periods when an agency
approved corrective action program is
underway.
Chapter 15,
Article 5, Sections
2550.0(a),
2550.1(a)(1),
2550.4(d), (e),(f)
Not an ARAR; no more stringent than Title
22 CCR 66264.94(a)(1),
(a) (3) , (c) , (d) , and (e) . The State agrees
that actions proposed in this ROD would
comply with this ARAR and compliance
with the Title 22 provisions should result in
compliance with this ARAR. The State
does not intend to dispute the ROD, but
reserves its rights if implementation of the
Title 22 CCR provisions is not as stringent
as State implementation of this ARAR.
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
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TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
ARAR
Determination"
A RA TEC
Water Quality Monitoring Program.
Owners or operators of facilities that
treat, store, or dispose of waste at waste
management units must implement a
water guality monitoring program to
monitor the potential for releases from
the unit or to demonstrate the
effectiveness of a corrective action
program.
Article 5, Section;
2550.3,2550.4,
2550.5, 25501 (e)
except (e) (12) (B) ,
2550.8, 2550,10
Not ARARs; not more stringent than 22
CCR Sections 66264.93, 66264.94,
66264.95, 66264.97(e), 66264.98,
662264.100. The State agrees that actions
proposed in this ROD would comply with
this ARAR and compliance with the Title 22
provisions should result in compliance with
this ARAR. The State does not intend to
dispute the ROD, but reserves its rights if
implementation of the Title 22 CCR
provisions is not as stringent as State
implementation of this ARAR.
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes or policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive reguirements of the specific actions are
considered potential ARARs.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
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TABLE 2-7
State Action-Specific ARARs
Operable Units 1 and 2
MCIiB Barstow, California
California Water Code*
Authorizes the regional board to Prescribe
the requirements under which a waste
discharge that take place. These are
referred to as Waste Discharge
Requirements (WDRs).
4,5
A Applicable
ARAR Applicable or relevant and appropriate requirement
CCR California Code of Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
RA Relevant and appropriate
RWQCB California Regional Water Quality Control Board,
SWRCB California State Water Resources Control Board, Lahontan Region
TEC To be considered
CERCLA response actions taken entirely on
site are exempt from permitting requirements.
However, the Oils 1 and 2 remedial action
design will incorporate valid ARARs derived
from the substantive requirements of water
quality control plans, taking into consideration
the beneficial uses to be protected, the water
quality obj ectives reasonably required for that
purpose, other pertinent waste discharges,
and the need to prevent.
Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the statutes and policies does not indicate that
the Navy accepts all the statutes of policies as potential ARARs. Specific potential ARARs are addressed in the table below each general heading; only substantive requirements of the specific action are
considered potential ARARS.
Potential actions: 1) Monitoring and access restrictions. 2) Groundwater extraction and conveyance. 3) Ex-situ groundwater treatment via carbon adsorption or ozone/carbon. 4) OU 2 discharge of treated
groundwater to oxidation ponds. 5) OU 1 discharge of treated groundwater to infiltration galleries. 6) OU 1 vapor extraction and air sparging. 7) Cap/cover of CAOC 35 landfill.
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3.0 YERMO ANNEX PLUME (OU 1) DECISION SUMMARY
3.1 Summary of Plume Characteristics
3.1.1 Contaminants of Concern
3.1.1.1 Organics
The results of the groundwater RI at MCLB Barstow indicate that VOCs are the primary class of
chemicals affecting underlying groundwater at the Yermo Annex. VOC contamination may have
reached groundwater in the Yermo subbasin as long ago as 1961 when major industrial operations
were moved from the Nebo Main Base to the Yermo Annex. The most prevalent contaminants are the
solvents TCE and PCE, which have been used at the Base primarily in cold cleaning, vapor
degreasing, chemical paint stripping, and painting operations. TCE and PCE have been detected
at concentrations exceeding federal and state drinking water standards in over a dozen
groundwater monitoring wells in the Yermo Annex area. Other VOCs detected above federal or
state standards include 1,1-dichloroethene (1,1-DCE), benzene, and 1,2-dichloroethene (1,2-DCA).
Tables 3-1 and 3-2 show the maximum concentrations of VOCs detected in on- and off-Base
groundwater monitoring wells, respectively, along with their associated MCLs. Contaminants
exceeding drinking water standards are shown at the top of the tables. The most commonly
detected VOCs are TCE and PCE that were found in 21 and 20 wells respectively, and 1,1-DCE that
was detected in seven wells. Other VOCs including 1,1-dichloroethane (1,1-DCA), 1,2-
dichoroethane (1,2-DCA), 1,2-dichloroethene (1,2-DCE), 1,1,1-trichloroethane (1,1,1-TCA),
2-butanone, xylenes, and Freons were detected in fewer than four wells. Semivolatiles organic
compounds (SVOCs) and total petroleum hydrocarbons as diesel (TPH-D) were also detected at
Yermo, but at much lower concentrations and detection freguencies.
3.1.1.2 Inorganics
Various metal analyses are present in groundwater throughout the Yermo Annex. These analyses
are typically present in all natural waters in various amounts depending on geologic setting,
contact time between the water and mineral-rich sediments or bedrock, and other factors.
Most of the metal analyses detected in groundwater at the Yermo Annex, including common ions
such as calcium, iron, magnesium, potassium, and sodium, exhibit concentration distributions
that can be explained simply as natural variations due to heterogeneity of the subsurface
environment.
Two metal analyses, nickel and chromium, were found to exceed MCLs and to be elevated relative
to their statistically defined background levels in several wells near the highly industrial
operations at Building 573 on the northern section of the Yermo Annex (i.e., wells YS34-1,
YS35-1, YES-1, YS16-4, and YS16-5). Three other metal analyses, antimony, thallium and
aluminum, were also detected in this area at slightly elevated levels relative to their
background concentrations. However, an evaluation of the spatial and temporal distributions for
these metals indicates that similarly elevated levels were also detected in other on- and
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off-Base areas (e.g., Well Y8-1) not associated with industrial activities.
In addition to spatial variation, large temporal variations in the concentrations of these
metals throughout 4 years of sampling suggest that turbidity or sampling technigues may have
also been a factor in the higher reported concentrations. Turbidity during sampling has been an
ongoing issue due to the nature of the interbedded sands, sib, and clays in the alluvial
aguifers at MCLB Barstow. Changes in iron concentrations from each sampling event (an indicator
of sample turbidity) correlate closely to nickel and chromium concentrations in the suspected
wells. All five wells around Building 573 reported their highest iron and chromium
concentrations, and three of the five wells exhibited their highest nickel concentrations,
during the same January 1994 sampling event. The RI yielded inconclusive answers to the
guestions of whether the concentrations of these five metals are naturally occurring or the
result of Base activities. To resolve this issue, the Marine Corps and regulatory agencies have
agreed to measure the concentrations of these five metals in a few selected groundwater
monitoring wells for a minimum of four additional guarters (1 year). MCLB Barstow has agreed to
amend this ROD to address cleanup options if metals are determined to be a problem after this
additional sampling.
3.1.2 VOC Contaminant Sources
VOCs constitute the only confirmed class of groundwater contaminants originating from sources at
three distinct areas of the Yermo Annex. The areal extent of the VOC plume and location of
contaminant sources are shown on Figure 3-1.
The northern Yermo area of contamination appears to be a result of leaks and breaks in the
industrial wastewater treatment plant piping associated with CAOC 16 (Building 573), past
disposal activities at CAOC 15/17 (former industrial waste treatment plant), and possibly
landfill activities at CAOC 35. The maximum TCE and PCE concentrations in this area were 77 and
230 micrograms per liter (Ig/L), respectively, in the general area of CAOC 16. Maximum
concentrations detected at the Base boundary downgrading from this area were 74 Ig/L for TCE and
66 Ig/L for PCE (state and federal MCLs for TCE and PCE are 5 Ig/L).
The southern portion of Yermo Annex VOC plume contamination appears to have resulted from past
landfill operations at CAOC 23. Maximum TCE and PCE concentrations detected in this area were
34 and 18 Ig/L, respectively.
The central and most upgradient portion of the Yermo Annex VOC plume is attributed to discharges
to a French drain at CAOC 26 (Building 533, Packaging and Maintenance Shop). Maximum TCE and
PCE concentrations in groundwater in this area are 141 and 31 Ig/L, respectively.
3.1.3 Location of Vadose Zone Contamination
Residual vadose zone contamination has been determined to be present in subsurface soils above
the groundwater table in the three general source areas previously described. Vadose zone
contamination can provide a continuous source of contaminants to groundwater, which could
increase overall aguifer cleanup time and costs. Therefore, isolation, reduction or removal of
vadose zone contamination is part of the groundwater remedial actions.
Based on intense site scoping, soil gas and geophysical surveys, visual site inspections, and
soil and groundwater sampling, the Marine Corps narrowed the suspected areas of vadose zone
contamination at MCLB Barstow to a handful of sites. Consistent with the spirit of CERCLA and
the NCP to expedite cleanup, the Marine Corps and regulatory agencies adopted a remediation-
based approach designed to shift the focus of the MCLB Barstow IRP away from site
characterization and towards cleanup. Based on this approach, the extent of vadose zone and
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groundwater contamination were investigated to the degree necessary to confirm the need for
remedial action and support remedial action decisions discussed as follows.
3.1.3.1 CAOC 16
CAOC 16 comprises the Maintenance Center Barstow (MCB) (Building 573) and its perimeter area
(approximately 60 acres) (see Figure 3-1). Building 573 is the main facility of the MCLB
Barstow Repair Division. Activities conducted at this facility include engine repair,
rebuilding and testing, radiator and metal parts cleaning, dynamometer testing, solvent cleaning
of electronic parts, and parkerizing of weapons. Because of potential significant disruptions
to mission-critical operations, very limited vadose zone characterization was conducted at this
site. However, based on the widespread area of VOC contamination in groundwater at levels above
federal and state MCLs, and the high concentration of industrial activity at the site, the RI
conservatively concluded that VOC contamination is present throughout the vadose zone underlying
Building 573. CAOC 16 was therefore included in the FS for evaluation of vadose zone and
groundwater cleanup remedial alternatives.
3.1.3.2 CAOC 15/17
CAOC 15/17 is a 13-acre rectangular area located between Building 573 (CAOC 16) and the Yermo
Class III Landfill (CAOC 35) (see Figure 3-1). The area, encompasses the former industrial
wastewater treatment plant (IWTP) including 14 evaporation basins, four sludge drying beds, a
temporary pond, three oxidation ponds, the overflow area around the ponds, and a wet well. The
depth to groundwater in this area is approximately 140 feet bgs. The site has been inactive
since 1990.
Based on scoping information, an estimated 140,000 gallons of bilge water contaminated with oil
and gasoline were reportedly discharged to the ground during regular operations between 1961 and
1970. In addition, an estimated 3,000 gallons of waste oil may have been spilled during the
process of draining and transferring used oil from vehicles to drums and to tank trucks. Sludge
drying beds reportedly stored both sludge from the evaporation basins for drying and
contaminated soil from fuel spills mixed with sludge. All residual sludge was subject to a
removal action in 1993 (Jacobs 1996) .
Site characterization data including a near-surface soil organic vapor (SOV) survey and soil
sampling revealed localized VOC contamination with the highest concentration along the southern
boundary with CAOC 16. Based on existing data, there is no direct evidence that widespread VOC
contamination is present in the vadose zone at this CAOC, or that it represents an ongoing
source of VOC contamination to groundwater that warrants source removal. Although there is
uncertainty in this conclusion due to the limited vadose zone characterization in the area, the
existing information points to CAOC 16 as the major source of vadose zone impacts to groundwater
in the area (the highest concentrations of VOCs in groundwater at the Yermo Annex have been
detected in wells near and downgrading of CAOC 16).
3.1.3.3 CAOC 26
CAOC 26, which encompasses Building 533 (the Packaging and Maintenance Shop) and the area around
it, has also been identified as a major source of VOC contamination in groundwater at the Yermo
Annex (see Figure 3-1).
The shop operations include cleaning, repairing, preserving, painting, and packaging various
work pieces. The shop consists of a waterfall-type paint booth, several dip tanks for cleaning
and preservation operations, a vapor degreaser, and a sandblasting unit. The perimeter area of
Building 533 contains a steam cleaning rack, an oil/water separator, a darkly discolored area to
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the west, and a French drain area (formerly misidentified as underground storage tank [UST]
T-533). Wastes generated at the facility include solvents, TCE, waste oil, paint wastes, and
preservatives.
Significant soil gas concentrations of TCE, PCE, and cis-1,2-dichloroethene (cis-1,2-DCE) were
detected in the vadose zone in the area near the French drain. A groundwater concentration of
more than 140 Ig/L TCE was also reported. A leaching potential analysis using a vadose zone
leaching model (VLEACH) indicated that groundwater may be affected over the next 100 years.
CAOC 26 was included in the FS to evaluate vadose zone and groundwater remedial alternatives on
the basis of these results.
3.1.3.4 CAOCs 23 and 35 (Municipal Landfills)
CAOCs 23 and 35 at the Yermo Annex were primarily used as municipal landfills (see Figure 3-1).
Wastes disposed of at these sites consist primarily of municipal trash, industrial solid waste,
scrap metal, wood, paper, and plastic packing materials. Consistent with the presumptive remedy
approach, the actual contents of the landfill areas were not sampled. However, soil samples were
obtained from areas beneath and around the disposal areas. The potential for chemicals detected
in these samples to leach to groundwater was assessed using the Marshack and VLEACH models.
Based on downgrading groundwater monitoring data, these CAOCs are believed to have been sources
of groundwater contamination at one time. The vadose zone modeling results indicate that the
current chemical concentrations detected in the soil samples collected will not affect
groundwater. However, these results cannot be considered representative of vadose zone
conditions throughout the entire landfill area. The presumptive remedy for these CAOCs involves
leaving the waste in place, capping, and long-term groundwater monitoring. Capping remedial
actions are being addressed under OU 3 for CAOC 23 and OU 5 for CAOC 35. Groundwater monitoring
under the substantive RCRA landfill closure reguirements for both CAOCs 23 and 35 have been
incorporated into this ROD.
3.1.4. Location of Groundwater Contamination
VOCs were detected in groundwater in and downgrading of the source areas discussed above.
Figures 3-2 and 3-3 show maps of the distribution of PCE and TCE in groundwater throughout the
Yermo Annex. These maps, contoured using Lynx Geosystem (a geostatistical model used to
visualize the extent of migration of each constituent), show the location of the three general
source areas discussed in Section 3.1.2 and the extent of their dissolved plumes. The data
(current as of December 1996) suggest that the dissolved plumes from the three areas have
commingled to form one large plume. Therefore, the three distinct areas of groundwater
contamination have been combined and designated as the Yermo Annex plume.
The Yermo Annex plume, the largest of the three VOC plumes identified at MCLB Barstow, spans an
area of approximately 12,000 by 4,000 feet.
3.1.5 Contaminant Migration Routes
The following potential routes of contaminant migration were identified for OU 1:
1) Vadose Zone Contaminant Transport:
a) Vertical transport through the soil by desorption of chemicals bound to the
surface of soil particles, and percolation of infiltrated water through the
contaminated soil column.
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b) Vertical and horizontal transport of contaminant vapors through soil pore space
from either residual or re-vaporization of material adsorbed/absorbed onto the
soil particles. Vapors can potentially recontaminate the groundwater or be
emitted to the surface.
2) Groundwater Contaminant Transport: Vertical and horizontal transport of contaminants
through the groundwater matrix.
3.1.5.1 Vadose Zone Contaminant Transport
In general, VOC compounds have a high vertical mobility in soils. At the Yermo Annex, VOCs have
percolated into the top 40 feet of groundwater. The available data indicate that PCE and TCE
are the predominant groundwater VOC contaminants in the Yermo Annex plume. PCE predominates in
the area of CAOCs 16, 15/17, and 35, while TCE is more common at CAOCs 23 and 26.
Source leaching modeling was performed using VLEACH 2.0 (Turin 1990) to assess the future impact
to groundwater from vadose zone contaminants. VLEACH modeling results for CAOC 26 indicate that
vadose zone contamination will pose a significant continuous threat to groundwater for the next
100 years. VLEACH modeling results for CAOCs 16, 15/17, 23, and 35 were determined based on the
limited vadose zone characterization conducted at these CAOCs and can not be considered
representative of the existing vadose zone conditions. Because of this uncertainty, the Marine
Corps has conservatively assumed that vadose zone contamination is present at these CAOCs and
poses a threat to groundwater.
3.1.5.2 Groundwater Contaminant Transport
As shown in Figure 3-1, the Yermo Annex VOC plume extends from CAOC 26 on the western side of
the Annex to the current leading edge of the plume, approximately 5,000 feet downgrading of the
eastern Base perimeter. The plume has migrated from west to east in the direction of
groundwater flow at an estimated rate of 60 to 70 feet per year. Contaminant levels above
drinking water standards have been detected off-Base about 2,000 feet downgrading of the Base
boundary. As discussed in Section 2.4, two private residence wells located in this area have
been provided with well-head carbon filtration treatment systems as a precautionary measure.
The next nearest known water supply well is about 2,000 feet downgrading of the leading edge of
the plume. It is estimated that it would take approximately 30 years for the leading edge of
the plume to reach that well. The maximum concentration expected to ever reach the well is
estimated at 2.1 Ig/L (which is below drinking water standards) in approximately 100 years.
Groundwater samples from intermediate depth monitoring wells (screened from 40 to 60 feet below
the groundwater table) resulted in mostly concentrations of VOCs below detection limits.
Therefore, a vertical extent of 40 feet was determined to be the maximum depth of groundwater
VOC contamination for the purpose of designing the groundwater pump and treat system.
3.2 Summary of Yermo Annex Plume Risks
The major risk currently associated with OU 1 of MCLB Barstow is the ingestion of contaminated
groundwater underlying the affected on-Base and off-Base areas. Actual or threatened releases
of hazardous substances from the Yermo Annex, if not addressed by implementing the response
action selected in this ROD, may present a threat to public health, welfare, or the environment.
3.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the Yermo Annex have
been managed, treated, and disposed of on site throughout the Base history. The chemicals
-------
measured in the vadose zone and groundwater during the RI were evaluated for inclusion as
chemicals of potential concern in the risk assessment by application of screening criteria.
Contaminants of concern identified in on- and off-Base groundwater at the Yermo Annex (OU 1) are
listed in Tables 3-1 and 3-2, respectively.
3.2.2 Summary of Toxicity Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for contaminants of concern in
groundwater at the Yermo Annex (OU 1) are provided in Tables 3-3 and 3-4, respectively.
3.2.3 Human Health Risk
For the groundwater under OU 1, the baseline risk assessment (BLRA) reviewed a future
hypothetical residential scenario for on- and off-Base residents in the absence of further
response action (see Section 2.7.2). The BLRA showed that under this scenario for cancer risk,
as many as 20 in 10,000 (2 x 10 -3) additional persons for the on-Base portion of the plume, and
10 in 10,000 (1 x 10 -3) additional persons for the off-Base portion of the plume that exceeds
drinking water standards, have the potential to develop cancer during their lifetimes. These
estimates were developed based on the conservative exposure assumptions outlined in Section
2.7.2. Both these estimates are above EPA's target range of 10 -4 to 10 -6. For the off-Base
portion of the plume impacting groundwater at levels below drinking water standards, the risk
drops to 2 in 10,000 (2 xlO -4) additional persons, which is at the upper end of EPA's target
range. The chemicals of concern contributing the most to estimated cancer risk are TCE, PCE,
and 1,1-DCE.
Considerable uncertainty exists regarding the above estimates relative to the cancer risk
associated with 1,1-DCE, the largest contributor to risk. Specifically, evaluation of all the
animal cancer bioassays suggests that 1,1-DCE is a guestionable animal carcinogen. When
metabolic differences between animals and humans are compared, the potential carcinogenicity of
1,1-DCE in humans is even more guestionable. Therefore, the actual risk to humans may be much
less than the above estimates.
For noncancer health effects, the hazard indices for the on- and off-Base portions of the plume
above drinking water standards are 9.4 and 3.7, respectively. In both cases, the hazard index
exceeds EPA's acceptable criterion of 1. For the off-Base portion of the plume below drinking
water standards, the hazard index is 0.33, which is below the acceptable criterion of 1. The
chemicals of concern contributing the most to estimated non-cancer health effects are TCE, PCE,
and 1,1-DCE.
Based on the above results, groundwater containing VOC contamination above drinking water
standards is a medium of concern for remedial action. In addition, the subsurface soil is a
medium of concern because of potential cross-media chemical transport from subsurface soil to
groundwater.
3.2.4 Ecological Risk
An ecological risk assessment was independently performed by EPA Region IX to evaluate potential
effects on plants and animals from groundwater contaminants at MCLB Barstow. At most areas of
the Yermo Annex, groundwater is found at depths greater than 100 feet and there is no surface
water. Exposure of potential ecological receptors to VOCs in groundwater is unlikely because no
groundwater discharges to local surface waters and is not accessible to plants and animals.
Therefore, no complete exposure pathway to impact ecological receptors exists at the Yermo Annex
(OU 1) .
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3.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make decisions regarding groundwater and vadose
zone cleanup decisions for the Yermo Annex.
3.3.1 Groundwater Cleanup
The extent of VOC contamination at the Yermo Annex was determined during the RI/FS. Because of
the large extent of the plume (approximately 6.13 billion gallons over a 12,000- by 4,000-foot
area), remediation strategies were developed to evaluate cleanup options on the basis of
ARAR-driven remediation goals (i.e., MCLs, background levels). The following remediation
strategies were evaluated in the FS.
1) Containment of groundwater contamination at the Base boundary. This strategy
captures over 90 percent of the total VOC mass estimated to exist in the aguifer, and
prevents further migration of contaminants off Base, but leaves existing levels of
VOCs above drinking water standards off Base untreated.
2) Containment of groundwater contamination at the MCL boundary. This strategy captures
all contamination in excess of drinking water standards (i.e., MCLs) on and off Base.
3) Containment of groundwater contamination at the background boundary. This strategy
captures all contamination in excess of background levels on and off Base.
Illustrations of these three different containment areas are provided in Figure 3-3. This
figure shows that the Base boundary area is contained within the MCL contour area, and the MCL
area is in turn contained within the background contour area. Target remediation volumes were
determined for each of the three containment areas, and alternatives developed to maximize
containment, extraction, and treatment effectiveness.
A technical and economical feasibility analysis (TEF) was conducted to evaluate the three
remediation strategies and determine the most cost-effective, ARAR-compliant remedy that is
protective of human health and the environment. The TEF analysis, presented in Appendix J of
the Draft Final FS for OUs 1 and 2 (Jacobs 1996a), involved an evaluation of the technical
limitations, residual risk (risk remaining in groundwater after cleanup goals have been
achieved), and cost/benefits of incremental risk reduction associated with each alternative.
The following summarizes the TEF analysis results and conclusions.
1) Experience gained over the past decade has shown that restoring groundwater to
drinking water guality (i.e., to MCLs) or more stringent standards (i.e., background)
is much more difficult than expected due to the complexities of hydrogeological and
contaminant related factors. Selection of realistic cleanup goals must consider the
technical limitations, economical practicality, and overall protectiveness to human
health and the environment.
2) Cleanup of contaminated groundwater to MCLs and background levels would result in a
residual risk of 2 x 10 -4 and 2 x 10 -6, respectively. These numbers are based on
very conservative assumptions and involve considerable uncertainties surrounding
cancer risk estimates for 1,1-DCE (see Section 3.2.3). Excluding 1,1-DCE, these
estimates would be approximately 1 x 10 -3 and 5 x 10 -4. Both these levels are
within EPA' s risk management range and are considered protective of human health and
the environment.
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3) Most of the VOC contaminant mass in groundwater is within the Base boundary. Plume
containment, extraction, and treatment at the Base boundary is vital to halt
contaminant migration, protect off-Base resources and receptors, and accelerate
groundwater cleanup. Alternatives designed for this containment strategy can
effectively remove over 90 percent of the VOC contaminants in groundwater. However,
this strategy by itself is not ARAR-compliant because it does not capture and treat
off-Base contamination above MCLs.
4) Plume containment, extraction, and treatment at the Base and MCL boundaries would
reguire extraction and treatment of 17.7 billion gallons oil contaminated groundwater
for about 30 years at an estimated present worth cost of $27.2 million. This
estimate includes AS/SVE at CAOC 26 and downgrading of CAOCs 16, 15/17, and 35. This
strategy would remove 95 percent of the total mass and achieve an incremental risk
reduction of over 90 percent to within EPA's risk management range level. This
strategy is ARAR-compliant because it captures and treats all groundwater
contamination above MCLs.
5) Plume containment, extraction, and treatment at the Base and background boundaries
would reguire extraction and treatment of 46.5 billion gallons of contaminated
groundwater (over 2.5 times the MCL volume), for about 55 years at an estimated
present worth of $49.2 million. The cost estimate includes AS/SVE at CAOCs 26 and
downgrading of CAOCs 16, 15/17. and 35. This strategy would almost double the time
and cost of cleanup to MCLs, and only reduce VOC mass by an additional 4 percent (to
99 percent), and human health risks by an additional 9 percent (to 99 percent).
The cleanup duration and contaminant mass removal estimates used in the above analysis are based
in part on limited vadose zone data available, particularly at CAOCs 16 and 15/17. Additional
soil sampling and vadose zone gas monitoring will be conducted at these and other CAOCs during
implementation of the remedial action. The results of this sampling will be used, among other
tasks, to evaluate the long-term- and cost-effectiveness of the selected remedy as described in
Section 3.3.2. below.
In summary, both background levels and MCLs cleanup goals are considered protective of human
health and the environment. Remediating to background levels versus MCLs would result in only a
minimal incremental difference in risk reduction and mass removal while doubling the cleanup
costs and duration.
Based on these findings, and the technical limitations of extraction and treatment technology,
the TEF analysis concluded that cleanup to background levels is technically and economically
infeasible. Therefore, the Marine Corps selected MCLs as the cleanup goal for the Yermo Annex
VOC plume.
3.3.2 Source Reduction
Vadose zone contamination was determined to exist at five major CAOCs underlying the Yermo
Annex: 16, 15/17, 23, 26, and 35. Continued releases to groundwater from these CAOCs could
reduce the effectiveness of remediation efforts and extend the duration of cleanup. This
section documents the rationale for determining the need for, and extent of, source reduction
for each CAOC.
3.3.2.1 CAOC 16
The Maintenance Center Barstow (Building 573 and its perimeter area) is the most active and
trafficked industrial area at the Yermo, Annex. The entire perimeter of Building 573 is used as
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a passageway for vehicular traffic and testing, maintenance and storage of military eguipment in
the process of being refurbished.
Several source reduction options were evaluated for this CAOC in the FS.
1) Soil excavation. This option is not feasible because of the depth of the
contamination (140 feet to groundwater) and the density of physical improvements
(i.e., buildings, structures, eguipment) and industrial activity at Building 573.
2) In situ vertical AS/SVE. A small-scale AS/SVE pilot study conducted during the RI/FS
demonstrated that this technology would effectively remove VOC contamination from the
vadose zone and groundwater underlying Building 573. However, the pilot study also
evidenced significant logistical problems during installation and operation of the
system due to the high traffic flow and concentration of industrial activity and
infrastructure at this CAOC. These problems would be compounded in an attempt to
install a full-scale system. The presence of numerous underground utilities in the
area would reguire clearance, dictate placement of wells, and could cause significant
disruptions to utility service during system installation. Vertical clearance inside
Building 573 is inadeguate to accommodate the large drilling eguipment reguired.
Overall, these problems would severely limit the efficiency and cost- effectiveness
of any system that could be installed. Based on these limitations, the Marine Corps
determined that installing a full-scale vertical AS/SVE would result in major
disruptions to mission-critical operations, and that this option is not feasible
under the current site conditions.
3) In situ horizontal SVE and AS/SVE. This option was considered as a way to overcome
the limitations of vertical drilling. However, the relatively deep groundwater table
(140 feet), overall length of drilling needed to provide coverage of the Building 573
area (1,000 feet), and high cost of the technology ($500 per linear foot of
drilling), make this option largely ineffective and extremely cost-prohibitive. MCLB
also evaluated a variation of this option which involved SVE only. Under this
variation, samples needed for soil contamination characterization would be collected
using the horizontal drilling technigues. Following the investigative stage, the
same horizontal borings would be cased and completed to function as soil vapor
extraction wells. According to the economic evaluation for this option, a total of
approximately $26 to $38 million would be reguired for soil investigation and
completion of the SVE facilities. There is uncertainty in this initial capital cost,
because the characteristics of the reguired SVE wells are at the practical limits of
the technological for horizontal well construction. The estimated annual operating
cost for the horizontal SVE option is $400,000.
4) In situ vertical AS/SVE downgrading of CAOC 16. This last option involved placing a
vertical AS/SVE system off the hardstand area, downgrading of Building 573, to
overcome the logistical problems encountered by the other options. This option would
intercept and remove VOC contamination from groundwater as it passes through the
system flowing away from the facility. This option would not effectively remove VOC
contamination in the vadose zone directly under Building 573. The existing
10-inch-thick concrete stand provides an effective protection barrier against
potential leaching of vadose zone contaminants into groundwater due to infiltration.
However, VOC contamination in the vadose zone could still migrate to groundwater
through the process of VOC vapor diffusion and dispersion of soil pores.
Based on the existing conditions at CAOC 16, the Marine Corps determined that the last option
(Option 4: In situ vertical AS/SVE downgrading of CAOC 16) is the most practical and
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cost-effective alternative to address VOC contamination. The Marine Corps evaluation indicates
the other options are not feasible at this time, because of technical and economic reasons.
Those options include Option 1 (soil excavation), Option 2 (in situ vertical AS/SVE), Option 3
(in situ horizontal AS/SVE), and the horizontal SVE variation of Option 3.
The DON and regulatory agencies have agreed not to include vadose zone cleanup of this CAOC as
part of the final remedy for the Yermo Annex plume and to further evaluate the technical and
economic feasibility of vadose zone cleanup at this CAOC according to the criteria outlined in
Section 2.8.7 of this ROD.
3.3.2.2 CAOC 26
The Packaging and Maintenance Shop area has been identified as a major source of vadose zone
contamination and included in the groundwater NTCRA being conducted at the Yermo Annex. The
following source reduction options were evaluated for this CAOC in the FS.
1) Soil excavation. This option is not feasible because of the depth of the
contamination (140 feet to groundwater) and the presence of physical improvements
(i.e., buildings, structures, eguipment).
2) In situ vertical AS/SVE. This option involves installing and operating a full-scale
AS/SVE system designed to provide complete coverage of the vadose zone and
groundwater source areas at CAOC 26. This option was selected as the preferred
remedy at CAOC 26 based on the results of the AS/SVE pilot study conducted at CAOC 16
during the RI/FS, which demonstrated that this technology is effective in removing
VOC contamination from the vadose zone and groundwater. AS/SVE is expected to be
effective at CAOC 26 because of its similar hydrogeologic characteristics to CAOC 16.
The AS/SVE system is being implemented as part of the Yermo Annex groundwater NTCRA
and incorporated into the selected remedy for OU 1 documented in this ROD.
Because the existing system's SVE wells at CAOC 26 are screened at depth (i.e., within 10 feet
of the groundwater table), there is some uncertainty at this time regarding the efficiency of
the SVE system to effectively remove contamination from the near-surface soils. Because of
this, there exists the potential for residual VOC contamination in the near-surface soils to
impact future receptors at the site, either through direct soil contact or through vapor
migration and inhalation. To address this, the Navy will perform an evaluation to determine if
residual vadose zone contamination represents a threat to potential future on-site receptors.
If the evaluation demonstrates that a potential threat to human health exists, then the Navy
will include in a written notification to the FFA signatories i) an evaluation of the need for
any additional remedial action and ii) a description of the changes necessary to the selected
remedy for the Yermo Annex plume in the ROD for OU 1. The Navy will add appropriate language to
the MCLB Barstow Master Plan describing the potential threat, along with any restrictions on
site use. The language to be added to the Master Plan will be provided to the FFA signatories
for review and concurrence prior to it being placed in the Master Plan.
The results of the vadose zone monitoring will be incorporated into the FFA primary document to
be submitted to the agencies as established in Section 2.8.12 of this ROD.
Vadose Zone Modeling to Determine AS/SVE System "Shut Off"
Performance parameters for vadose zone modeling will be measured by using the nested vapor
probes located at 30-, 60-, and 90-foot depths in the vadose zone at CAOC 26. The vapor probe
data will provide an indication of the VOC mass removal in the vadose zone and will be used to
derive vadose zone soil concentrations of VOCs for input to the vadose zone model. VLEACH or
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another appropriate vadose zone fate and transport model will be used to assess when residual
VOC levels in the soil no longer pose a threat to groundwater and to demonstrate whether vadose
zone cleanup has been achieved for item 1 of Section 2.8.4 of this ROD.
3.3.2.3 CAOCs 23 and 35
These CAOCs were primarily used as municipal landfills and are believed to have been sources of
groundwater contamination at one time. These CAOCs are no longer in use and are classified as
inactive waste management units. The presumptive remedy approach for CERCLA municipal landfills
is capping and long-term groundwater monitoring. Capping actions are being addressed under OU 3
for CAOC 23 and OU 5 for CAOC 35. The capping options being considered either eliminate or
significantly limit infiltration thus eliminating or minimizing further potential impacts to
groundwater. Therefore, no further vadose zone action is being considered for these CAOCs under
OUs 1 and 2. However, the groundwater monitoring requirements for CAOCs 23 and 35 are being
addressed under OUs 1 and 2.
3.4 Description of Remedial Action Alternatives, Yermo Annex Plume
Ten alternatives for the remediation of groundwater and vadose zone soil in OU 1 are presented
in this section. These alternatives are discussed in detail in the Draft Final FS for OUs 1 and
2 (Jacobs 1996a) and summarized in this section. Alternative 7 was screened out during the
preliminary evaluation stage and is not included in the ten alternatives discussed herein.
3.4.1 Alternative 1 - No Action
Under this alternative, no further action would be taken to clean up or control contamination
from vadose zone soil or groundwater. The existing site conditions would not change. No costs
are associated with this alternative. The no action alternative provides a baseline for
comparing the other alternatives.
3.4.2 Alternative 2 - Institutional Control/groundwater Monitoring
This alternative includes the implementing of institutional controls and initiating a long-term
groundwater monitoring program. This alternative relies on natural processes such as dispersion
degradation, sorption, and volatilization to reduce VOC concentrations. Institutional controls
will ensure that the affected groundwater will not be used in the future, thereby maintaining
the current lack of exposure to, and risks from, chemicals in groundwater.
Institutional controls include restrictions on the use of untreated groundwater for drinking
water, and provisions for wellhead treatment of affected water supply wells within the Yermo
Annex plume. The Institutional controls to restrict access to contaminated groundwater for
on-Base areas will be documented in the Base Master Plan, a document that MCLB Barstow uses to
coordinate and plan future activities (e.g., new construction). For off-Base areas, they could
include but not be limited to zoning ordinances implemented by county agencies that restrict use
of groundwater in these areas. The Marine Corps will provide the necessary information to
appropriate county agencies identifying the areas that have been impacted by groundwater
contamination exceeding MCLs. The Marine Corps will support county agencies with any technical
information needed for the county to implement these restrictions.
This alternative also includes a long-term monitoring program to monitor groundwater beneath and
downgrading of contaminant sources. Groundwater monitoring involves sampling existing and new
monitoring wells as required to monitor trends in contaminant concentrations, evaluate
remediation progress and contaminant migration patterns, and provide early warning to
potentially affected downgrading users. One of the goals of the long-term monitoring program is
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to determine the effectiveness of the selected remedy. To support this determination, the
monitoring program will include vadose zone monitoring at potential sources.
A Post-ROD vadose zone and groundwater monitoring plan for the Yermo Annex remedial action will
be prepared under the authority of this ROD outlining the monitoring well network, sampling and
analytical methods, sampling freguency and major decision points to be made during monitoring
(e.g., adding or removing monitoring wells from the network, changing sampling freguency or
analytical parameters, etc.). The Post-ROD Monitoring Plan will be a primary FFA deliverable to
be submitted to the agencies within one year of the signing of the ROD.
The post-ROD monitoring plan will also include necessary post-closure groundwater monitoring at
CAOCs 23 and 35 landfills.
The cost for Alternative 2 includes approximately $250,000 in capital costs and $140,000 in
yearly operation and maintenance (O&M) costs to put in place institutional controls and
implement the long-term groundwater monitoring programs for a total present worth cost of $2.5
million. Groundwater modeling indicates that it would take this alternative over 500 years to
naturally degrade contaminants to levels below drinking water standards. Except for the no
action alternative, all alternatives include institutional controls and long-term groundwater
monitoring.
3.4.3 Alternative 3 - Groundwater Removal (Extraction Wells at Base Boundary), Ex Situ
Treatment, and Discharge
This alternative involves installing eight groundwater extraction wells at the eastern boundary
of the Base to capture the on-Base portion of the plume, followed by activated carbon treatment
of the extracted water. The treated water is recharged into the aguifer via two infiltration
galleries located upgradient of the contaminant plume. MCLB Barstow estimates that this system
would extract 600 to 800 gallons per minute (gpm) of water from the top 50 feet of the shallow
aguifer. The main purpose of this alternative is to prevent the higher groundwater
contamination on-Base from moving into lower contamination areas off-Base. This also would
begin reducing concentrations of VOCs in groundwater in the Yermo Annex area by removing the
majority of the contamination from the aguifer. The on-Base portion of the plume represents
about 90 percent of the total VOC contamination in the Yermo Annex area. The major components
of this alternative would consist of:
• Implementing institutional controls described in Alternative No. 2.
• Designing and constructing groundwater extraction wells (already in place).
• Designing and installing an on-site aboveground treatment system and a retention and
recycling system including two infiltration galleries (already in place).
• Starting up and operating this system (already in operation).
• Transporting, regenerating, recycling, and disposing of the spent filters.
• Operating a long-term groundwater monitoring program (in progress).
The approximate volume of groundwater reguiring remediation is estimated to be 3.5 billion
gallons. The cost for Alternative 3 includes $4.3 million in capital costs to, construct the
treatment system (all of which has already been constructed as part of the Yermo Annex NTCRA) ,
and $410,000 in yearly O&M costs to operate the system, for an estimated total present worth
cost of $14.1 million. Groundwater modeling indicates that it would take this alternative about
190 years for the on-Base portion and over 500 years for the off-Base portion of the VOC plume
to degrade to levels below drinking water standards.
3.4.4 Alternative 4 - Groundwater Removal (Extraction Wells at Ban Boundary and Off-Base
Background Boundary), Ex Situ Treatment, and Discharge
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This alternative is similar to Alternative 3, but includes 11 additional off-Base wells to
capture the entire plume at the background (leading edge) boundary. MCLB Barstow estimates that
this system would extract 1,400 to 1,900 gpm from the aguifer. This alternative evaluates the
option of cleaning up all VOC-contaminated groundwater to background levels. The major
components of this alternative are the same as for Alternative 3. The approximate volume of
groundwater reguiring remediation under this alternative is 6.13 billion gallons. The cost for
Alternative 4 includes $9.5 million in capital costs to construct the treatment system (of which
$4.3 million have already been constructed as part of the Yermo Annex NTCRA), and $868,000 in
yearly O&M costs to operate the system, for an estimated total present worth cost of $30.1
million. Groundwater modeling indicates that it would take this alternative about 320 years for
the on-Base portion and 70 years for the off-Base portion of the plume to clean up to background
levels.
3.4.5 Alternative 5 - Groundwater Removal (Extraction Wells at Base Boundary and Off-Base MCL
Boundary), Ex Situ Treatment, and Discharge
This alternative provides an intermediate option between Alternatives 3 and 4. Alternative 5 is
also similar to Alternative 3, but includes four additional off-base wells to capture the
off-Base portion at the MCL boundary. This system is estimated to extract 900 to 1,200 gpm from
the aguifer. This alternative evaluates the option of cleaning up all VOC-contaminated
groundwater to meet federal and state drinking water standards. The major components of this
alternative are the same as for Alternative 3. The approximate volume of groundwater reguiring
remediation under this alternative is 3.75 billion gallons. The cost for Alternative 5 Includes
$6.4 million in capital costs to construct the treatment system (of which $4.3 million have
already been constructed as part of the Yermo Annex NTCRA), and $643,000 in yearly O&M costs to
operate the system, for an estimated total present worth cost of $21.8 million. Groundwater
modeling indicates that it would take this alternative about 160 years for the on-Base portion
and 20 years for the off-Base portion of the plume to clean up to levels below drinking water
standards.
3.4.6 Alternative 6 - Groundwater Removal (Extraction Wells at Base Boundary and CAOC 26
Boundary), Ex Situ Treatment, and Discharge
This alternative is a variation of Alternative 3, designed to reduce the time to clean up the
on-Base portion of the contaminant plume to below drinking water standards by 40 years, from 190
to 150 years. Alternative 6 involves four additional on-Base groundwater extraction wells to
intercept the portion of the VOC plume originating from CAOC 26. This system would extract from
900 to 1,200 gpm from the aguifer. The major components of this alternative are the same as for
Alternative 3. The approximate volume of groundwater reguiring remediation under this
alternative is 3.5 billion gallons. The cost for Alternative 6 includes $6.6 million in capital
costs to construct the treatment system (all of which has already been constructed as part of
the Yermo Annex NTCRA), and $662,000 in yearly O&M costs to operate the system, for an estimated
total present worth cost of $19.3 million.
3.4.7 Alternative 8A - Groundwater Removal and Source Reduction (Extraction Wells at Base
Boundary and CAOC 26 Boundary, AS/SVE at CAOC 26) , Ex Situ Treatment, and Discharge
Alternative 8A, and all alternatives that follow, incorporate source removal into the remedial
action. These alternatives are designed to significantly reduce the time to clean up the
groundwater VOC contamination by removing contaminants trapped in the vadose zone soils and
groundwater underneath the original source. The vadose zone is the area of unsaturated
subsurface soil overlying groundwater. Contaminants trapped in the vadose zone can provide a
continuous source of contaminants to groundwater for many years, thus prolonging the cleanup
efforts. Alternative 8A is a variation of Alternative 6, which includes AS/SVE treatment at
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CAOC 26. This alternative is estimated to further reduce the time of Alternative 6 to clean up
the on-Base portion of the plume to below drinking water standards by 110 years, from 150 to 40
years. The cost for Alternative 8A includes $7.5 million in capital costs to construct the
treatment system (all of which has already been constructed as part of the Yermo Annex NTCRA),
and $787,000 in yearly O&M costs to operate the system, for an estimated total present worth
cost of $21.3 million.
3.4.8 Alternative 8B - Groundwater Removal and Source Reduction (Extraction Wells at Base
Boundary and CAOC 26 Boundary, AS/SVE at CAOC 26 and Downgrading of CAOCs 16, 15/17, and
35), Ex Situ Treatment, and Discharge
Alternative 8B further expands on Alternative 8A by adding AS/SVE treatment downgrading of CAOCs
16, 15/17, and 35. This alternative eliminates an additional 10 years of treatment, reducing
the total time to clean up the on-Base portion of the plume to below drinking water standards to
30 years. The cost for Alternative 8B includes $9.4 million in capital costs to construct the
treatment system (all of which has already been constructed as part of the Yermo Annex NTCRA) ,
and $968,000 in yearly O&M costs to operate the system, for an estimated total present worth
cost of $22.1 million.
As mentioned above, Alternative 8B already is being fully implemented in the form of a CERCLA
NTCRA at the Yermo Annex. The objective of the removal action is to stop all further
migration of contaminants off of the Base, begin to address the main sources, and accelerate
groundwater cleanup.
3.4.9 Alternative 8C - Groundwater Removal and Source Reduction (Extraction Wells at Base
Boundary, Off-Base MCL Boundary, and CAOC 26 Boundary: AS/SVE at CAOC 26 and Downgrading
of CAOCs 16, 15/17 and 35), Ex Situ Treatment, and Discharge
Alternative 8C is the same as Alternative 8B, except that it captures and treats the off-Base
portion of the VOCs plume above MCLs to meet federal and state drinking water standards. The
off-Base portion of the plume below MCLs will not be captured; instead it will be allowed to
naturally attenuate because it already meets drinking water standards. The cleanup times to
MCLs are estimated at about 30 years. The cost for Alternative 8C includes $10.9 million in
capital costs to construct the treatment system (of which $9.4 million have already been
constructed as part of the Yermo Annex NTCRA), and $1.2 million in yearly O&M costs to operate
the system, for an estimated total present worth cost of $27.1 million.
3.4.10 Alternative 8D - Groundwater Removal and Source Reduction (Extraction Wells at Base
Boundary, Off-Base Background Boundary, and CAOC 26 Boundary: AS/SVE at CAOC 26 and
Down-gradient of CAOCs 16, 15/17, and 35), Ex Situ Treatment, and Discharge
This alternative is also similar to Alternative 8B, but involves full capture of the off-Base
plume at the background (leading edge) boundary and cleanup of the entire VOCs contaminated
groundwater to background levels. The cleanup times is estimated at about 55 years. The cost
for Alternative 8D includes $14.3 million in capital costs to construct the treatment system (of
which $9.4 million has already been constructed as part of the Yermo Annex NTCRA), and $1.9
million in yearly O&M costs to operate the system, for an estimated total present worth cost of
$49.2 million.
3.5 Summary of Comparative Analysis of Alternatives
This section summarizes the evaluation of remedial alternatives conducted to select the
alternative that provides the best balance with respect to the nine statutory evaluation
criteria in the NCP and discussed in Section 2.9.
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The selected alternative for addressing the groundwater contamination at the Yermo Annex is
Alternative 8C - groundwater removal and source reduction (extraction wells at Base boundary,
off-Base MCL boundary, and CAOC 26 boundary; AS/SVE at CAOC 26 and downgradient of CAOCs 16,
15/16, and 35), Ex Situ Treatment and Discharge. Based on the current information, this
alternative appears to provide the best balance of trade-offs among the alternatives with
respect to the nine EPA evaluation criteria.
The following analysis summarizes the evaluation of remedial alternatives under the three
criteria groups: threshold criteria, primary balancing criteria, and modifying criteria (see
Section 2.9). Table 3-5 presents a comparison between each of the alternatives for achievement
of a specific criterion.
3.5.1 Threshold Criteria
3.5.1.1 Overall Protection of Human Health and the Environment
The no action alternative does not provide adeguate protection of human health and the
environment if the groundwater were to be used as drinking water in the future. The
institutional controls alternative (Alternative 2) provides protection by restricting future
use. The calculated human health risk for Alternatives 3 through 6, 8A, 8B, 8C, and 8D is at
the upper end of the, EPA's target risk range. However, given the conservative nature of the
risk assessment and the uncertainties in the toxicological data used to derive the risk
estimates for 1,1-DCE, it is likely that the actual risk posed to a hypothetical residential
receptor would be well within the EPA target risk range. Assuming that institutional controls
are effective, particularly in off-Base areas, all alternatives except the no action alternative
are considered to be protective of human health and the environment. However, only Alternatives
3 to 8D use active measures to reduce contamination, reduce the future threat to human health
and the environment, and more guickly remediate to cleanup levels.
3.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at MCLB Barstow is
provided In Section 2.10. All alternatives comply with location-specific ARARs because no
ecological, natural, or cultural resources are threatened by the groundwater contamination. All
alternatives also comply with action-specific ARARs; specifically, state antidegradation ARARs
for treated groundwater discharges, VOC emissions control, and groundwater monitoring
reguirements.
The Lahontan RWQCB has classified the aguifer underlying the Yermo Annex as a potential drinking
water source. Alternatives 2, 3, 6, 8A, and 8B do not comply with the chemical-specific federal
and state ARARs for drinking water standards (i.e., MCLs, nonzero MCL goals, or risk-based
concentrations) because they do not capture the off-Base portion of the plume above MCLs.
Alternatives 4, 5, 8C, and 8D comply with all location-, action-, and chemical-specific ARARs.
3.5.2 Primary Balancing Criteria
3.5.2.1 Long-Term Effectiveness and Permanence
Groundwater and vadose zone modeling were used to estimate how long it would take to achieve
MCLs or background concentrations at the point of compliance for all the alternatives evaluated.
All alternatives except Alternative 1 provide moderate to high long-term effectiveness and
permanence. The results indicate that Alternatives 2 through 6 would reguire a relatively long
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time to achieve remedial goals (150 to over 500 years). Alternative 2 can effectively reduce
risk by restricting the use of untreated groundwater for drinking water and providing wellhead
treatment when warranted. However, if these control measures cannot be implemented or
maintained, Alternative 2 would not comply with this criterion. Alternative 8C will meet
cleanup levels by providing a capture zone that will prevent migration of contaminants exceeding
drinking water standards, and will extract and treat all contaminated groundwater above these
standards in an estimated 30-year timeframe. Levels of contamination present in the vadose zone
at CAOCs 16 and 15/17 may affect the long-term effectiveness of the selected remedy and result
in increasing the 30-year remediation time estimate.
3.5.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2, the no action and institutional controls alternatives, would not provide
for a reduction in toxicity, mobility, and volume through treatment because they are not
treatment options. All other alternatives would achieve moderate to high reduction of toxicity,
mobility, or volume through active extraction and treatment and AS/SVE remediation.
3.5.2.3 Short-Term Effectiveness
Due to the length of the remedial action, short-term risks are the same as current risks.
Except for the no action alternative, all alternatives rely on institutional controls for
short-term effectiveness of community protection. Such controls are more effective on-Base. If
off-Base controls cannot be maintained, short-term effectiveness would be compromised.
The no action and institutional control alternatives would have the least immediate harmful
effect on human health and the environment, but would also provide less protection in the short
term. The active remediation alternatives would slightly increase the risk of exposure by
pumping and handling of contaminated groundwater. However, use of proper worker protection and
safety measures would reduce these risks to safe levels.
3.5.2.4 Implementability
The no action alternative is the easiest to implement because there is nothing to implement.
Imposing institutional controls off-Base will reguire state, local, and community involvement.
Extraction and treatment and AS/SVE are proven, commercially available, readily implementable,
and simple to operate technologies. As discussed in Section 3.3.2, constructibility issues at
or near Building 573 will prevent Installing an AS/SVE system directly underneath CAOC 16. In
all other on-Base areas, no problems are expected during installation of extraction wells and
treatment systems. Construction of off-Base extraction wells will reguire obtaining access
to private property through coordination with private land owners and local officials.
3.5.2.5 Cost Effectiveness
The selected alternative (Alternative 8C) is the second most costly, with an estimated present
worth value of $27.1 million, exceeded only by Alternative 8D with a present worth of $49.2
million. Alternative 8C costs more than most of the other alternatives, but is the only
groundwater remedy that meets the threshold criteria for protection of human health and the
environment and complies with ARARs in an estimated 30-year time frame. The higher cost is
therefore justifiable and cost effective. Approximately $10 million in the capital cost of
alternative 8C and 1 year of O&M costs have already been incurred in the implementation of the
groundwater NTCRA at the Yermo Annex.
3.5.3 Modifying Criteria
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3.5.3.1 State Acceptance
The California State DTSC and RWQCB have reviewed and approved the OUs 1 and 2 FS and Proposed
Plan, and agree with the selected final remedy for the Yermo Annex plume.
3.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed actions for OUs 1
and 2. These comments are included on Page 27 of the public meeting transcripts provided in
Appendix C, and in Section 6, "Responsiveness Summary."
3.6 Summary of Selected Remedy For the Yermo Annex Plume
As reguired by CERCLA and the NCP, and based on the results of the detailed analysis of
alternatives presented above, MCLB Barstow selected Alternative 8C as the final remedy to
address groundwater and vadose zone contamination at the Yermo Annex.
For the contaminated groundwater above MCLs, the selected remedy consists of remediation of the
contaminant plume by pump and treat, with ex situ treatment and recharge of treated groundwater
back into the aguifer, and enhanced by AS/SVE. This remedy will consist of containing and
extracting the contaminated groundwater from the upper 50 feet of the aguifer, treating it on
site through a carbon infiltration system and recharging it back into the aguifer through two
infiltration galleries at the upgradient edge of the plume. Air sparge effluent from AS/SVE
systems will be discharged to the atmosphere after it has been filtered for organic compounds.
Air discharges will comply with the discharge standards and reguirements of the local air
pollution control district. The used carbon filter media will be taken off site for recharge
and reused.
The groundwater extraction wells will be arranged at three areas consisting of four on-Base
extraction wells designed to capture the plume originating from CAOC 26, eight wells at the
eastern boundary of the Base to capture the on-Base portion of the plume, and four off-Base
wells at the MCL boundary of the plume to capture the off-Base portion of the plume above MCLs.
The four groundwater extraction wells for CAOC 26 and the eight wells on the eastern boundary of
the Base have already been installed. Locations, sizing, and pumping rates for these wells were
determined by evaluating the results of pumping tests conducted as part of the remedial design
phase. The four off-Base wells at the MCL boundary still need to be located and installed.
Contaminated groundwater will be pumped to the water treatment system, treated, and recharged at
the upgradient edge of the plume through the infiltration galleries. The groundwater carbon
filtration and AS/SVE treatment systems for CAOCs 26 and 16 have already been constructed and
are currently operational. The four off-Base extraction wells at the MCL boundary will
eventually be connected to the existing groundwater treatment system. Because the underlying
aguifer is relatively slow moving (60 ft/yr), the infiltration galleries will be used to help
enhance movement of contaminated groundwater toward the extraction wells. Extracting and
treating the groundwater will continue until the performance standards (see Table 2-1) are
achieved. Clean up of the contaminated groundwater at OU 1 to MCLs is estimated to take 30 to
40 years.
This remedy includes periodic vadose zone and groundwater monitoring to track changes in the
level and extent of contamination. The major components consist of:
• Implementing institutional controls.
• Designing and constructing groundwater extraction wells, monitoring wells and SVE
wells, as necessary.
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• Designing and constructing a groundwater extraction and monitoring system, a
groundwater treatment system, and two infiltration galleries.
• Designing and installing two AS/SVE systems, one at CAOC 26 and a second one
downgradient of CAOCs 16, 15/17, and 35, and conducting vadose zone soil gas
monitoring to assess the effectiveness of these systems.
• Starting and operating these systems.
• Transporting, regenerating, recycling, and/or disposing of the spent filters.
• Operating and maintaining of a long-term vadose zone and groundwater monitoring
program that includes periodic monitoring of selected COCs in soil vapor and
groundwater monitoring and extraction wells, to be specified in a post-ROD OU 1
Remedial Action Groundwater Monitoring Plan (OHM 1996a).
• Conducting guarterly sampling of groundwater for 1 year for five dissolved metals
(nickel, chromium, antimony, thallium and aluminum) at selected wells in the area, of
CAOC 16 to ascertain if these metals are naturally occurring or the result of Base
activities.
• Closure criteria.
To ensure that human health and the environment are protected in the future, institutional
controls will be implemented that include access restrictions to prevent the on-Base use of
untreated groundwater for domestic use, which includes ingestion, dermal contact and inhalation
as routes of exposure. Wellhead treatment will be provided for any existing water supply wells
that fall within the area of the plume exceeding MCLs. The DON will provide necessary
information to appropriate county agencies identifying off-Base areas impacted by groundwater
contamination exceeding MCLs. The DON will support county agencies with any technical
information needed for the county to implement restrictions on construction and use of wells in
the affected areas.
The written concurrence of the FFA signatories is required before the DON takes any action at a
CAOC that would be inconsistent with the prohibition against use of untreated groundwater at the
Yermo Annex for domestic use. If any such action is proposed, the DON must provide the FFA
signatories with written notification of such proposed action. The notice shall include (i) an
evaluation of the risk to human health and the environment, (ii) an evaluation of the need for
any additional remedial action as a result of the proposed action, and (iii) a description of
the changes necessary to the selected remedy for the Yermo Annex plume in the ROD for OUs 1 and
2.
The written notice of proposed action shall be submitted to the FFA signatories at least 60 days
prior to the commencement date for the proposed action. The EPA will advise whether a ROD
amendment or an Explanation of Significant Differences (BSD) document is required. The response
from the FFA signatories is due within 30 days of the DON's written notice of proposed action.
The DON may not commence any action without the written concurrence of the FFA signatories.
The DON shall notify the FFA signatories of any plan to lease or transfer Yermo Annex real
property to a non-federal or federal entity, notify the transferee or lessee of the prohibition
on use of groundwater at the Yermo Annex for domestic use and include the restrictions in the
transfer or lease. Such notification shall be provided at least 45 days in advance of the lease
or transfer conveyance. The DON shall comply with Section 120(h)(3) of CERCLA in any such
transfers.
The DON will also provide the FFA signatories with 30 days advance notice of any amendment to
the Master Plan that could affect either the substance or the language of the Yermo Annex Master
Plan groundwater use restriction amendment.
The MCLB Barstow Base Master Plan will be amended to incorporate the above-mentioned
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restrictions on access to and use of contaminated groundwater for drinking water purposes
on-Base. The Master Plan amendments will include language that 1) prohibits the on-Base use of
untreated groundwater for domestic use; 2) describes the risk to human health and the
environment from use of the contaminated groundwater, and 3) references the MCLB Barstow OUs 1
and 2 RI/FS and ROD. The language in the Master Plan amendments will also include the title and
dates of the above-listed documents and their storage location. These amendments to the Master
Plan will be completed by the DON within 1 year of signing the MCLB Barstow OUs 1 and 2 ROD.
The FFA signatories will be provided with a draft copy for review and comment of the amendments
to the Master Plan reflecting the above language.
The groundwater remedy for OU 1 is consistent with the reguirements of Section 121 of CERCLA and
the NCP. The remedy will reduce the mobility, toxicity, and volume of contaminated groundwater
at the site. In addition, the remedy is protective of human health and the environment, will
attain all federal and state applicable or relevant and appropriate reguirements, is
cost-effective, and uses permanent solutions to the maximum extent practicable. The remedy for
OU 1 is consistent with previous removal actions at the site. Based on the information
available at this time, the selected remedy represents the best balance among the criteria used
to evaluate remedies.
3-6.1 Performance Standards for Groundwater and Source Reduction
Groundwater from the aguifer shall be monitored until cleanup goals (performance standards) set
for in Table 2-1 are achieved as agreed upon by the DON and the regulatory agencies. See
Sections 2.8 and 3.3. for discussion of source reduction performance standards.
3.6.2 Infiltration Standards
Treated groundwater that will be recharged into the aguifer passed through the infiltration
galleries shall comply with the substantive general waste discharge reguirements for land
disposal of treated groundwater, Lahontan RWQCB Board Order No. 6-93-106. These reguirements
are listed in Table 3-6. Meeting these reguirements complies with SWRCB Resolution 68-16 and
the Basin Plan. The general discharge reguirements of Board Order No. 6-93-106 have monitoring
reguirements that verify compliance. A schedule for compliance appropriate for this monitoring
shall be established in the Yermo Annex Remedial Action Groundwater Monitoring Plan.
3.6.3 Groundwater and Vadose Zone Monitoring
Groundwater and vadose zone monitoring shall be conducted for the Yermo Annex plume during the
remedial action in accordance with the Yermo Annex Remedial Action Groundwater Monitoring Plan
(see Section 3.4.2) to verify that the remedial action is being effective towards achieving
remedial action objectives (RAOs). The Remedial Action Groundwater Monitoring Plan will
consists of existing and new groundwater monitoring wells if necessary, to determine if RAOs are
being met. Vadose zone monitoring will consist of the existing soil vapor probes at CAOC 26,
and three additional probes at CAOC 16 to be installed post-ROD. The DON will monitor the
vadose zone and groundwater as specified in the groundwater monitoring plan, until it is
demonstrated that the remedial action has effectively and permanently reduced the VOC
contamination to within the remedial goals (RGs) set forth in Table 2-1. The criteria for
assessing the effectiveness of the remedial action shall also be included in the groundwater
monitoring plan. If monitoring indicates that RGs have not been met in accordance with these
criteria, the groundwater remedial action will continue until the RGs are achieved. The results
of the groundwater monitoring will be evaluated every 5 years, and the duration and freguency of
the groundwater monitoring modified as appropriate until it is determined that the remedial
action has been completed.
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Groundwater monitoring for CAOCs 23 and 35 will entail collection and analysis of groundwater
samples for compliance monitoring per CCR Title 22 (RCRA landfill closure requirements).
Compliance monitoring will involve quarterly collection of one sample per well from at least two
downgradient and one upgradient monitoring wells for 2 years. Groundwater samples will be
analyzed for VOCs (EPA Method 8260) and general chemistry quarterly for 2 years. It is assumed
that the data gathered In the initial two years of monitoring will provide adequate trend data
of the groundwater plume, so that the frequency of sampling events will be reduced to half
(i.e., semiannual) for the following 28 years. The results of the groundwater monitoring will
be reevaluated every 5 years, and the duration and/or frequency of the groundwater monitoring
may be further modified based on the results of the reevaluations.
As discussed in Section 3.1.1.2, groundwater monitoring will be conducted to measure the
concentrations of five metals (nickel, chromium, antimony, thallium and aluminum) in a few
selected groundwater monitoring wells in the area of CAOC 16 for a minimum of four additional
quarters (1 year). The exact wells to be sampled and the sampling schedule will be specified in
the Remedial Action Groundwater Monitoring Plan for the Yermo Annex. Data will be provided to
the agencies in the Quarterly Groundwater Monitoring Report for the Yermo Annex. The
conclusions and recommendations resulting from this sampling will be submitted to the agencies
in a primary FFA document.
3. 7 Statutory Determination
As a lead federal agency, the Marine Corps' primary responsibility at its CERCLA sites is to
undertake remedial actions that achieve adequate protection of human health and the environment.
In addition, Section 121 of CERCLA established several other statutory requirements and
preferences. These specify that, when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental standards as established under
federal and state environmental laws unless a statutory waiver is justified. The selected
remedy also must be cost effective and use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected remedy meets these statutory
requirements.
3.7.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment by remediating the contaminant
plume through extraction, ex situ treatment and recharge of treated groundwater back into the
aquifer. The selected remedy protects human health and the environment by eliminating,
reducing, and controlling risk through remediation and institutional controls.
3.7.2 Compliance with ARARs
As stated in Section 2.10, remedial actions performed under CERCLA must comply with all ARARs.
The selected alternative for the Yermo Annex plume was found to comply with all the ARARs
presented in Tables 2-2 through 2-7.
3.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being considered with
their overall effectiveness to determine whether the costs are proportional to the effectiveness
achieved. The Marine Corps evaluates the incremental cost of each alternative as compared to
the increased effectiveness of the remedy. The selected remedy for groundwater is remediation
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through extraction, with ex situ treatment and recharge of treated groundwater back into the
aguifer. The selected remedy includes groundwater extraction wells at the Base boundary, at the
off-Base MCL boundary, and at the CAOC 26 boundary. It also includes AS/SVE at CAOC 26 and
downgradient of CAOCs 15/17, 16, and 35 to enhance the pump and treat remediation system.
Based on the information obtained, this selected remedy will provide the best balance of
trade-offs among the alternatives with respect to the nine criteria provided by EPA to evaluate
the alternatives. This remedy is more costly than the other alternatives considered except
Alternative 8D. Alternative 8D would remediate groundwater to background levels; however, it
would take almost double the time and cost of Alternative 8C while only marginally reducing the
human health risk. Alternative 8C Is the only alternative projected to remediate groundwater to
MCL in 30 years, making Alternative 8C cost effective. Therefore, the higher cost is justified
and cost effective.
3.7.4 Use-of Permanent Solutions to the Maximum Extent Practicable
MCLB Barstow, EPA, DTSC, and CRWQCB believe that the selected remedy is the most appropriate
remedial approach for the Yermo Annex groundwater and vadose zone and provides the best balance
among the evaluation criteria for the remedial alternatives considered. The AS/SVE enhanced
extraction and treatment remedy for groundwater is a permanent remedy. The selected remedy will
return the groundwater back into the same aguifer, it meets the statutory reguirement to use
permanent solutions and treatment technologies to the maximum extent practicable.
3.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Yermo Annex will be met through remediation of
groundwater by AS/SVE enhanced extraction and treatment of contaminated groundwater.
3.8 Documentation of Significant Change
The final remedy for the Yermo Annex plume, Alternative 8C, has not been changed or refined from
the Proposed Plan.
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Table 3-1
Yermo Plume - On-Base
Maximum Groundwater Concentrations of VOCs and Associated MCLs
Maximum
Groundwater Federal California
Concentration MCL MCL
VOC (ug/L) (ug/L) (ug/L)
Contaminants Exceeding Drinking Water Standards (MCLs)
1,1-Dichloroethene (1,1-DCE) 41
1,2-Dichloroethane (Ethylene Bichloride, or EDC) (1,2-DCA) 4
1,2-Dichloroethene, Total 1
Benzene 13
Tetrachloroethene (PCE) 230
Trichloroethene (TCE) 310
Contaminants Not Exceeding Drinking Water Standards (MCLs]
1,1,1-Trichloroethane 2 200
1,1-Dichlorethane 4
1,1,2-Trichloro-l,2,2-Triflourothane (Freon 113) 4
cis-1,2-Dichloroethene (cis-1,2-DCE) 35 70
trans-1,2-Dichloroethene 0.5 100
2-Butanone (methyl ethyl ketone) 19
2-Hexanone 8 -
4-Methyl-2-Pentanone (methyl isobutyl ketone) 7 -
Acetone 1 11
Bromodichloromethane
Bromoform (Tribromomethane)
Carbon Disulfide
Carbon Tetrachloride
Chloroform 1
Chioromethane 1 1 -
Dibromochloromethane 10 100
1,2-Difluoro-l,l,2,2-Tetrachloroethane (Freon 112) 2
1.2-Difluoro-l,1,2,2-Tetrafluroethane (Freon 112 ) 2
Methylene Chloride 1 35
Toluene
Trichlorofluoromethane (Freon 11)
Xylene (Total)
1 This chemical is a
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Table 3-2
Yermo Plume - Off-Base
Maximum Groundwater Concentrations of VOCs and Associated MCLs
Maximum
Groundwater Federal California
Concentration MCL MCL
VOC (ug/L) (ug/L) (ug/L)
UCL VCL
Contaminants Exceeding Drinking Water Standards (MCLs)
Tetrachloroethene (PCE) 15 5 5
Trichloroethene (TCE) 955
Contaminants Not Exceeding Drinking Water Standards (MCLs)
1,1-Dichloroethene (1,1-DCE)
1,2-Dichloroethene (1,2-DCA)
1,2-Dichloroethene Total (1,2-DCE, TOTAL)
cis-l,2-Dichloroethene (cis-1,2 DCE)
Dibromochloromethane
1,1-Dichloroethane (1,1-DCA)
0.5
1
6
5
0.3
0.3
7
5
70
70
100
Data includes most recent groundwater monitoring conducted by OHM Remediation Services, Inc. (OHM 1994, 1995, 1996)
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Table 3-3
Carcinogenic Toxicity Values for Chemicals of Concern in Groundwater and
Vadose Zone at Yermo Annex
Contaminant
Ingestion
Slope Factor*
(mg/kg-day)
Inhalation
Slope Factor*
(mg/kg-day)
Dermal
Slope Factor*
(mg/kg-day)
1,1,1-Trichloroethane
(1,1,1-TCA)
1,1-Dichloroethane
(1,1-DCA)
1,1-Dichloroethene
(1,1-DCE)
1,2-Dichloroethane
2-Butanone
Bromoform
Chloroform
Dibromochloromethane
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
NA
NA
0.6
NA
NA
0.18
0.091
NA
0.0079
0.0061
0.084
0.052
NA
0.011
0.091
NA
0.0039
0.081
0.084
0.002
NA
0.006
NA
NA
0.6
0.091
NA
0.0079
0.0061
0.084
0.052
NA
0.011
mg/kg-day = milligrams per kilogram per day
NA = Not Available
* Source: Integrated Risk Information System (IRIS). 1996.
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Table 3-4
Noncarcinogenic Toxicity Values for Chemicals of Concern in Groundwater and
Vadose Zone at Yermo Annex
Contaminant
Ingestion
Reference Dose*
(mg/kg-day)
Inhalation
Dermal
Reference Dose* Reference Dose*
(mg/kg-day) (mg/kg-day)
1,1,1-Trichloroethane
(1,1,1-TCA)
1,1-Dichloroethane (1,1-
DCA)
1,1-Dichloroethene (1,1-
DCE)
1,2-Dichloroethane
2-Butanone
Bromoform
Chloroform
Dibromochloromethane
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
0.09
0.1
0.009
NA
0.6
0.02
0.01
0.02
0.01
0.2
0.006
0.29
0.14
0.009
NA
0.29
0.02
0.01
0.02
0.01
0.11
0.006
0.09
0.1
0.009
NA
0.6
0.02
0.01
0.02
0.01
0.2
0.006
mg/kg-day = milligrams per kilogram per day
NA = Not Available
Source: Integrated Risk Information System (IRIS). 1996.
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Table 3-5
Summary of Comparative Analysis - Yermo Plume
MCLB Barstow
Criteria
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume
Short-Term Effectiveness
Implementability
Duration of Remedy
Time to MCLs (years)
Time to Background (years)
Present cost ($millions) 20 Years Duration
Remediation to MCLs
Remediation to Background
* ARARs achieved over time through natural groundwater attentuation (<500 years).
* * Alternatives Y-GW-2 through Y-GW-8D all result in residual risks that fall within EPA1s risk management range of 10 -6 to 10 -4 . Cleanup
to MCLs would result in an upper-bound incremental risk of approximately 2x10-4 (1x10-5 without 1, 1-DCE) while cleanup to background
(0.5 ug/L) would result in a risk of approximately 2 x 10 -5 (5 x 10 -4 without 1,1-DCE).
* * * On-Base portion of plume only. Off-Base portion of plume would achieve ARARs in over 500 years.
Alternative Y-GW-1: No Action
Alternative Y-GW-2: Institutional Controls and Groundwater Monitoring
Alternative Y-GW-3: Groundwater Removal (at Base Boundary), Ex-Situ Treatment, and Discharge
Alternative Y-GW-4: Groundwater Removal (Extraction Wells at Base Boundary and Off-Base at Background Edge of Plume), Ex Situ Treatment, and
Discharge
Alternative Y-GW-5: Groundwater Removal (Extraction Wells at Base Boundary and at Off-Base MCL Edge of Plume), Ex Situ Treatment, and Discharge
Alternative Y-GW-6: Groundwater Removal (Extraction Wells at Base Boundary and in CAOC 26), Ex Situ Treatment, and Discharge Abornmove
Y-GW-8A: Alternative Y-GW-6 with Air Sparging and SVE at CAOC 28
Alternative Y-GW-8A: Alternative Y-GW-6 with Air Sparging and SVE at CAOC 26
Alternative Y-GW-8B: Alternative Y-GW-8A with Additional Air Sparging and SVE downgradient of CAOCs 16, 15/17, and 35.
Alternative Y-GW-8C: Alternative Y-GW-8B with Extraction Wells Off-Base at MCL Edge of Plume
Alternative Y-GW-8D: Alternative Y-GW-8B with Extraction Wells Off-Base at Background Edge of Plume
ARARs - Applicable or relevant and appropriate requirements.
Mod - Moderate
NA - Not applicable.
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Table 3-6
Treated Groundwater Discharge Limitations
Lahonten RWQCB Board Order No. 6-93-106
30-day Median Daily Maximum
Constituent (Ig/L) (Ig/L)
Total Petroleum Hydrocarbons (C2-C46) <50 100
Benzene <0.50 1.0
Toluene <0.50 42.0
Ethylbenzene <0.50 29.0
Total Xylenes <0.50 17.0
Total Lead a <1.0 15.0
Naphthalene <0.5 20
MTBE <40 40
EDB <0.02 0.02
1,2-DCA <0.50 0.50
1,1,1-TCA <0.50 200
PCE <0.50 5.0
TCE <0.50 5.0
Trans-l,2DCE <0.50 10
Cis-l,2DCE <0.50 6
1,1-DCE <0.50 6
1,2-DCE <0.50 5
1,1,2-TCA <0.50 32
Vinyl chloride <0.50 0.5
The discharge shall have a pH of not less than 6.0 pH units nor more than 9.0 pH units.
The discharge shall have a dissolved oxygen concentration not less than 1.0 mg/L.
a These numbers could be higher based on background of the aquifer being discharged to.
Source: The treated groundwater discharge limitations are reproduced here from the California
Regional Water Quality Control Board Lahontan Region, Board No. 6-93-106, General Waste
Discharge Requirements for Land Disposal of Treated Groundwater, Harold J. Singer,
Executive Officer, November, 19, 1993.
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4.0 NEBO NORTH PLUME
4.1 Summary of Plume Characteristics
4.1.1 Contaminants of Concern
4.1.1.1 Organics
The results of the groundwater RI for the Nebo North plume indicated that VOCs are the primary
class of chemicals affecting the groundwater in the northern Nebo Main Base area. The most
prevalent contaminant is the solvent PCE, which has been detected in six groundwater monitoring
wells in the area at concentrations exceeding federal and state drinking water standards. Table
4-1 shows the maximum concentrations of VOCs detected in groundwater in the North Nebo area,
along with the associated MCLs. Contaminants exceeding drinking water standards are shown at
the top of the table. PCE is the only contaminant found to exceed its state and federal
drinking water standards, while benzene and 1,2-DCA exceeded the state standard. PCE was
detected at a maximum concentration of 80 Ig/L, with benzene and 1,2-DCA detected at maximum
concentrations of 1.2 and 3.0 Ig/L, respectively. TCE was the second most common VOC detected
but it did not exceed MCLs.
4.1.1.2 Inorganics
The evaluation of the nature and extent of metal concentrations at the Nebo Main Base indicates
that no metals are present above naturally occurring levels in groundwater. The RI concluded
that there is no evidence that discharge of wastes from the Base has resulted in metal
concentrations above background levels in the underlying groundwater in the northern Nebo Main
Base area.
4.1.2 VOC Contaminant Sources
VOCs are the only confirmed class of groundwater contaminants in the northern Nebo North plume
area. The areal extent of the VOC plume and location of contaminant sources are shown in Figure
4-1. The Nebo North plume appears to be the result of disposal activities originating as long
ago as 1943 when major industrial operations took place at Warehouse 2 (the Old Repair Facility)
and adjacent buildings. Warehouse 2 was constructed in 1942 and operated as a repair facility
until 1961 when operations were suspended and transferred to Building 573 in the Yermo Annex.
The operations at Warehouse 2 included engine repair, rebuilding, and testing; and metal parts
cleaning, etc., similar to the present operations at Building 573. The Warehouse 2 building is
currently used as a general warehouse. Residual vadose zone VOC contamination in the area of
Warehouse 2 has been detected at the location of three former UST sites (SWMU 10.43) identified
as Solid Waste Management Units. Other potential sources have been identified in the northern
Nebo Main Base area under the RCRA Facility Assessment (RFA) program, including SWMUs 10.1,
10.4, 10.5, 10.12, and 10.13. Although an analysis of the available soil data from these
sources indicates they do not pose a threat to groundwater, these data points are generally from
shallow soil samples (0 to 5 feet bgs) and there is some uncertainty regarding the
representativeness of these results for vadose zone contamination.
4.1.3 Location of Vadose Zone Contamination
VLEACH modeling conducted with the soil data from SWMU 10.43, the three UST sites at Warehouse
2, indicated that VOCs present in the vadose zone soils may pose a continuing, long-term source
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of VOCs to groundwater. Groundwater contamination by VOCs has been confirmed to exist at this
site. On the basis of these results, Warehouse 2 was included in the FS for evaluation of
vadose zone and groundwater remedial alternatives.
The three USTs were removed in 1992 under the RFA program. The results of soil samples
collected during the removal of the USTs indicated elevated VOC levels in two of the three UST
locations. Other SWMUs in the vicinity of Warehouse 2 were also found to be contaminated with
VOCs; however, the results of the human health evaluations found no significant health risk.
4.1.4 Location of Groundwater Contamination
Groundwater contamination with VOCs was detected in and downgradient of the source area,
Warehouse 2, discussed in Section 4.1.3. Figures 4-2 and 4-3 show the distribution of PCE and
TCE in groundwater in the area of the northern Nebo Main Base plume. These maps, contoured
using the Lynx Geosystem, show the location of the source area and the extent of the dissolved
VOC plume. The Nebo North plume extends approximately 4,000 by 1,500 feet and appears to be
limited to the upper 20 feet of the aguifer.
In addition to the identified PCE and TCE plumes, various low-level VOC detections have been
reported in monitoring wells throughout the Nebo Main Base. These detections are sporadic and
essentially occur over the entire Nebo Main Base. The results from multiple sampling events
between March 1992 to September 1995 indicate that no discernible plumes exist in these areas.
Since these areas are 1) generally below MCLs and health risk levels, and 2) have no discernible
sources, no further remedial action is necessary for these areas.
4.1.5 Contaminant Migration Routes
The following potential routes of contaminants migration were identified for the Nebo North
plume area:
1) Vadose Zone Contaminant Transport:
a) Vertical transport through the soil by desorption of chemicals bonded to the
surface of the soil particles and percolation of infiltrated water through the
contaminated soil column, and
b) Vertical and horizontal transport of contaminant vapors through soil pore space
from either residual or re-vaporization of material adsorbed/absorbed onto the
soil particles. Vapors can potentially recontaminate the groundwater or be
emitted to the surface.
2) Groundwater Contaminant Transport: Vertical and horizontal transport of contaminants
through the groundwater matrix.
4.1.5.1 Vadose Zone Contaminant Transport
In general, VOCs have a high vertical mobility in soils. The data gathered from the Nebo North
plume area indicate that VOCs have percolated into the shallow groundwater, and that PCE is the
predominant constituent of groundwater contamination.
Source leaching modeling was performed using VLEACH 2.0 (Turin 1990) to assess the future impact
to groundwater from vadose zone contaminants in the northern Nebo Main Base area. The VLEACH
results indicate that Warehouse 2 may continue to release contaminants to the groundwater for
the next 28 years. However, this is based on a conservative model with limited data. VLEACH
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results for other potential contaminant sources in the area indicate no continuous threat to
groundwater.
4.1.5.2 Groundwater Contaminant Transport
As shown in Figure 4-3, the VOC plume extends from Warehouse 2 on the western side of the Nebo
Main Base to the current leading edge of the plume at the eastern Base perimeter. Based on the
hydrogeological characteristics of the aguifer and the estimated date of which the releases
originated (1943), groundwater modeling indicates that the plume should have migrated about
10,000 feet. However, the plume has remained very stable and has not been observed to increase
its size, volume, or mass over the course of 12 guarterly sampling events conducted since 1992.
Fate and transport modeling data generated for the site indicate that shallow groundwater
(approximately 20 to 30 feet), high fluctuation in water table elevations, and predominantly
sandy soil may be contributing to the natural degradation of this plume. As shown in Figure
4-3, the plume appears to be contained within the Base boundary. The nearest known water supply
well is about 3,000 feet downgradient of the leading edge of the plume.
Groundwater samples from intermediate depth monitoring wells (screened from 40 to 60 feet below
the groundwater table), resulted in mostly non-detect concentrations of VOCs below detection
limits throughout the Nebo Main Base.
A vertical extent of 40 feet was conservatively assumed to be the average depth of groundwater
VOC contamination.
4.2 Summary of Nebo North Plume Risks
The major risk currently associated with the Nebo North plume is the ingestion of the
contaminated groundwater underlying the affected on-Base area. Actual or threatened releases of
hazardous substances from the Nebo North plume, if not addressed by implementing the response
action selected in this ROD, may present a threat to public health and the environment.
4.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the Nebo Main Base
have been managed, treated, and disposed of on site throughout the Base history. By application
of screening criteria, the chemicals detected; in the vadose zone and groundwater during the RI
were evaluated for inclusion as chemicals of potential concern in the risk assessment.
Contaminants of concern identified in groundwater at the northern Nebo Main Base area are listed
in Table 4-1.
4.2.2 Summary of Toxicity Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for contaminants of concern in
groundwater at the Nebo North plume area are provided in Tables 3-3 and 3-4, respectively.
4.2.3 Human Health Risk
To evaluate the groundwater at the Nebo North plume under OU 2, the BLRA used a hypothetical
on-Base residential scenario.
The BLRA showed that under this scenario for cancer risk, as many as three additional persons in
10,000 (3 x 10 -4) could develop cancer during their lifetimes. Excluding the contribution from
naturally occurring background metals, the incremental cancer index is approximately 1 x 10 -4
(one in ten thousand). The majority of the risk results are from PCE. As discussed in Section
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3.2.3, the exposure assumptions used to estimate the risk are extremely conservative and tend to
overestimate risk.
For noncancer health effects, the hazard index for the Nebo North plume is estimated to be 2.9,
which exceeds the EPA's acceptable criterion of 1. Approximately 1.4 is attributed to naturally
occurring background metals, with the remainder resulting primarily from PCE.
Hypothetical receptors were also evaluated, assuming exposure at the MCL and background levels
(analytical quantitation limit). At the MCL, the incremental risk from both PCE and 1,2-DCA was
estimated to be approximately 1 X 10 -5 (one in one hundred thousand). The corresponding
incremental risk at the background level is approximately 5 x 10 -6. The noncarcinogenic hazard
index is less than 1.0 from both chemicals.
Based on the above results, on-Base groundwater containing VOC contamination above drinking
water standards is a medium of concern for remedial action. In addition, the subsurface soil is
a medium of concern because of potential cross-media chemical transport from subsurface soil to
groundwater.
4.2.4 Ecological Risk
An ecological risk assessment was independently performed by EPA Region IX to evaluate potential
effects on plants and animals from groundwater contaminants at MCLB Barstow. An area of
potential concern evaluated by the EPA is the riparian habitat on the northeast comer of the
Nebo Main Base. Groundwater in this area surfaces and pools near the Mojave River, creating the
potential for a complete exposure pathway to ecological receptors. The riparian habitat was
investigated to assess the potential for contaminated groundwater to have affected this area.
However, an evaluation of surface waters and associated sediments in this area found that they
do not pose an ecological threat.
4.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make groundwater and vadose zone cleanup decisions
for the Nebo North plume.
4.3.1 Groundwater Cleanup
The areal extent of VOC contamination at the Nebo North plume was determined during the RI/FS.
As discussed in Section 4.1.5, the Nebo North plume is very stable and does not appear to be
increasing in size. In contrast with the Yermo Annex plume, the MCL and background contour
areas for the Nebo North plume are relatively close together and contained on Base. Site
characterization and fate and transport modeling data generated for the site support indications
that the shallow groundwater, high fluctuation in water table elevations, and predominantly
sandy soil conditions in the northern Nebo Main Base area may be resulting in the natural
degradation of this plume. The remediation strategy for this plume is to prevent the VOC
contamination from migrating off-Base. Two groundwater cleanup options were considered in the
FS under this remediation strategy.
1) Remediation of groundwater contamination at the MCL boundary by institutional
controls coupled with vadose zone source reduction and natural contaminant
degradation processes. Based on the evidence that exists in support of plume
degradation by natural processes, the Marine Corps decided to include this process
option in the remedial alternatives evaluated for this plume. Because the RI/FS data
collection program was not designed with natural processes considered as a possible
remedy, the existing data are not sufficient to quantitatively demonstrate how
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natural processes are actually occurring. However, 5 tears of groundwater sampling
since 1992 demonstrate that the plume is at "steady state" (i.e., plume is not
growing and VOC concentrations in groundwater are stable). The data indicate that
the plume is self-contained. However, source reduction at Warehouse 2 will be
implemented under this strategy to enhance the cost-effective containment and natural
degradation of the plume. There are no downgradient receptors at risk within 3,000
feet of the leading edge of the plume.
2) Containment of groundwater contamination at the MCL boundary by active extraction and
treatment technology. This process option was evaluated to determine if extraction
and treatment is a cost-effective remedy to prevent plume migration and provide a
permanent solution. A pilot study consisting of eight extraction wells (four in the
center of the plume near the more highly contaminated area, and four at the leading
edge of the plume to provide containment) was conducted to analyze mass removal rates
and evaluate plume behavior. The pilot study results indicate that the system
removed ten times more VOC mass than was predicted and can effectively remove VOC
contamination from groundwater. The results also support the assessment that the
plume is not migrating. As predicted, most of the VOC contamination was removed at
the upgradlent wells. VOC concentrations decrease significantly by the time they
reach the downgradient wells and at least two of these wells have consistently shown
concentrations below detection limits. Furthermore, there are no obvious upward or
downward trends in mass removal rates or VOC concentrations, which supports earlier
conclusions that the plume has reached a steady state condition.
The pilot study has proven that extraction and treatment can effectively contain and remove VOC
contamination from groundwater and could significantly shorten cleanup duration. However,
existing evidence also supports conclusions that natural contaminant degradation processes are
taking place at an effective rate (e.g., stable plume) to prevent adverse health effects to
potential receptors. Because extraction and treatment would guadruple the cost of cleanup
compared to natural processes without commensurate benefits in risk reduction to receptors, the
Marine Corps prefers the source reduction and natural attenuation option. However, based on the
uncertainties associated with natural attenuation at this time (e.g., limited source
characterization and definition/relative contribution of processes at work and rates of
reduction), the Marine Corps has decided to keep the existing extraction and treatment system in
place, fully maintained and on standby for startup as a fail-safe containment option in case
source reduction and natural attenuation fail to effectively contain the plume. This decision
is consistent with the intent of CERCLA and the NCP that the final remedy be cost-effective and
use permanent solutions and alternative treatment technologies to the maximum extent
practicable.
Selection of the appropriate remedial goal for the Nebo North plume was made based on an
evaluation of the technical and economic feasibility of achieving MCL and background levels, the
residual risk remaining in groundwater after achieving each cleanup goal, and the cost/benefits
of incremental risk reduction. The following summarizes the TEF analysis results and
conclusions.
1) Cleanup of contaminated groundwater to MCLs would reduce baseline risks by 91
percent, resulting in a residual risk of 1 x 10 -5. Cleanup to background levels
would reduce baseline risks by 95 percent, resulting in a residual risk of 5 x 10 -6
(an incremental 4 percent reduction over MCLs). Both cleanup levels are within EPA's
risk management range and are considered protective of human health and the
environment.
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2) Cleanup of contaminated groundwater to MCLs would remove 75 percent of the total
estimated VOC mass, and take from 12 to 45 years depending on the alternative
selected. Cleanup to background levels would remove 100 percent of the total
estimated VOC mass (an incremental 25 percent mass reduction over MCLs), but would
take from 30 to 120 years for the same alternatives (an incremental 150 percent
duration over MCLs).
3) The estimated present worth costs of all alternatives evaluated range from $1.0 to
$5.8 million for cleanup to MCLs, versus $1.1 to $7.3 million for cleanup to
background levels, a cost increase of 14 to 30 percent for background over MCLs.
In Summary, remediating to background levels rather than to MCLs would result in only a minimal
incremental difference in risk reduction and mass removal while increasing cleanup duration by
two- to three-fold and cleanup costs by approximately 20 percent. Based on the prove n
technical difficulties of restoring aguifer guality to background levels with existing
technology discussed in Section 3.3, and the fact that both MCLs and background cleanup goals
are considered protective of human health and the environment, the TEF analysis concluded that
cleanup to background levels is technically and economically impracticable. Therefore, the
Marine Corps selected MCLs as the cleanup goal for the Nebo North plume.
4.3.2 Source Reduction
Vadose zone contamination that may pose a continuing, long-term source of VOCs to groundwater
has been determined to exist in the area around Warehouse 2, the Old Repair Facility. Continued
releases to groundwater from this area could reduce the effectiveness of the remediation and
extend the duration of cleanup.
The following cleanup options for the Warehouse 2 area were evaluated in the FS.
1) Soil excavation. This option is not feasible to remove the residual contamination in
the soil because of the presence of physical improvements (i.e., buildings,
structures) around Warehouse 2.
2) In Situ Vertical AS/SVE. This option involves installing and operating a full-scale
SVE system (four AS and five SVE wells) to provide adeguate coverage of the vadose
zone in the area of Warehouse 2. The relatively sandy soils and shallow groundwater
at this site provide ideal conditions for AS/SVE. Such a system is readily
implementable and could conceivably shorten the remediation time for natural
processes to degrade the groundwater VOC plume by 30 years (from 45 to 15) , at an
approximate cost of $700 K.
Based on the FS results, the Marine Corps has determined that source removal in the northern
Nebo Main Base area would be a cost-effective enhancement to significantly reduce the estimated
cleanup duration from 45 to 15 years and accelerate the natural degradation processes.
Therefore, the Marine Corps has decided to implement source reduction (i.e., AS/SVE) in the
northern Nebo Main Base area as part of the selected final remedy.
Additional vadose zone characterization of Warehouse 2 is needed to delineate the vadose zone
source area sufficiently to design the AS/SVE system. The characterization will be performed as
part of the remedial design for this remedy.
Vadose Zone Modeling to Determine AS/SVE System "Shut Off"
Performance parameters for vadose zone modeling to support AS/SVE shut off decisions will be
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measured in a similar fashion to CAOC 26, using the criteria described in Sections 2.8.4 to
2.8.6 and 3.3.2.2 of this ROD.
4.4 Description of Remedial Action Alternatives, Nebo North Plume
Five alternatives are presented in this ROD for remediating groundwater and vadose zone soil in
the Nebo Main North plume area. These alternatives are discussed in detail in the Draft Final
FS for OUs 1 and 2 (Jacobs 1996) and summarized in this section.
4.4.1 Alternative 1 - No Action
Under this alternative, no further action would be taken to clean up or control contamination
from vadose zone soils or groundwater. The existing site conditions would not change. No costs
are associated with this alternative. The no action alternative provides a baseline for
comparing the other alternatives.
4.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring with Fail-Safe Extraction
and. Treatment Containment
This alternative includes implementing institutional controls and initiating a long- term
groundwater monitoring program. This alternative relies on natural processes such as
dispersion, degradation, sorption, and volatilization to reduce VOC concentrations.
Institutional controls will ensure that the affected groundwater will not be used in the future,
thereby maintaining the current lack of exposure to, and risks from, chemicals in groundwater.
Institutional controls will include restrictions on the use of untreated groundwater for
domestic use and provisions for wellhead treatment of affected water supply wells within the
Nebo North plume area. The institutional controls to restrict access to contaminated
groundwater in this area will be documented in the Base Master Plan.
This alternative also includes a long-term monitoring program to monitor vadose zone and
groundwater beneath and downgradient of contaminant sources. Groundwater monitoring involves
sampling existing monitoring wells to: 1) fully understand the relative contribution and rates
of reduction of the different natural processes that have stabilized and are passively
remediating the plume(s); 2) monitor trends in contaminant concentrations; 3) evaluate
remediation progress and contaminant migration patterns; and 4) provide early warning to turn on
the existing fail-safe extraction and treatment system to prevent contaminant exposure to
potentially affected downgradient users. Vadose zone monitoring involves sampling of soil vapor
probes to 1) monitor trend in contaminant concentrations and 2) assess the effect of the vadose
zone contaminant on the effectiveness of the selected remedy.
A Post-ROD vadose zone and groundwater Remedial Action Monitoring Plan for the Nebo North plume
remedial action will be prepared under the authority of this ROD, outlining the monitoring well
network, sampling and analytical methods, sampling freguency and major decision points during
monitoring (e.g., adding/removing monitoring wells from the network, changing sampling freguency
or analytical parameters, etc.). The Post-ROD Monitoring Plan will be a primary FFA deliverable
to be submitted to the agencies within one year of the signing of the ROD.
This alternative relies on the natural processes that appear to be occurring on the Nebo North
plume to passively remediate VOC contaminated groundwater to meet federal and state drinking
wafer standards (MCLs). The effectiveness of natural degradation processes will be demonstrated
through long-term monitoring.
The cost for Alternative 2 includes approximately $1.22 million in capital costs (including the
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cost of the existing pilot pump-and-treat system), and $55,000 in yearly O&M costs to put in
place institutional controls and install and monitor groundwater monitoring wells, for a total
present worth cost of $2.2 million. Groundwater modeling indicates that it would take this
alternative about 45 years for the VOC plume to naturally degrade to levels below drinking water
standards (MCLs). Except for the no action alternative, all alternatives include institutional
controls and long-term groundwater monitoring.
4.4.3 Alternative 3 Groundwater Removal, Ex Situ Treatment, and Discharge
This alternative involves operating the existing groundwater pump-and-treat pilot study system,
which includes eight existing extraction wells designed to fully capture the portion of the
plume above federal and state drinking water standards (MCLs). The extracted groundwater is
passed through an activated carbon-filtration system, which will remove contaminants to meet
regulatory discharge reguirements. The treated water is then recharged back into the aguifer
via two percolation ponds downgradient of the contaminant plume. This system is estimated to
extract and treat 300 to 400 gallons per minute (gpm) from the plume. This alternative would
actively remediate VOC-contaminated groundwater to meet MCLs. The portion of the plume
currently above MCLs represents about 95 percent of the total VOC contamination in the Nebo
North area.
The approximate volume of groundwater reguiring remediation is estimated to be 0.65 billion
gallons. The cost of Alternative 3 includes $2.4 million in capital costs to construct the
treatment system (all of which has already been constructed as part of the extraction and
treatment pilot study), and $234,000 in yearly O&M costs to operate the system. The total
present worth cost of this alternative is estimated at $7.1 million, ($2.4 million of which has
already been spent). Groundwater modeling indicates that it would take this alternative about
42 years to clean up the groundwater to levels below MCLs.
4.4.4 Alternative 4 - Groundwater Removal, Ex Situ Treatment, and Discharge with Source
Reduction (AS/SVE) at Warehouse 2
This alternative combines the pilot study system from Alternative 3 with AS/SVE at Warehouse 2.
This alternative is designed to significantly reduce the time to clean up the groundwater VOC
contamination by removing the contaminants trapped in the vadose zone soils directly underneath
the original source. Contaminants trapped in the vadose zone can provide a continuous source of
contaminants to groundwater for many years, thus prolonging the cleanup efforts. This
alternative is estimated to reduce the time to clean up the plume to below MCLs by 30 years,
from 42 to 12 years. The cost for Alternative 4 includes $3.2 million in capital costs to
construct the treatment system (of which $2.4 million have already been constructed as part of
the pilot study), and $345,000 in yearly O&M costs to operate the system, for an estimated total
present worth cost of $5.8 million.
4.4.5 Alternative 5 - Source reduction (AS/SVE) at Warehouse 2
This alternative is a variation of Alternative 2 and involves adding AS/SVE source reduction at
Warehouse 2 to enhance natural contaminant degradation processes. This alternative
significantly reduces the total time reguired to passively remediate the groundwater VOC
contamination to below MCLs from 45 to 15 years. The cost for Alternative 5 includes capital
costs of $773,000 to construct the AS/SVE system, $1.2 million for the existing pilot
pump-and-treat system, and $166,000 in yearly O&M costs to operate the system and implement
institutional controls for an estimated total present worth cost of $3.0 million.
4.5 Summary of Comparative Analysis of Alternatives.
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This section summarizes the evaluation of alternatives conducted to determine which alternative
provides the best balance with respect to statutory balancing criteria in Section 121 of CERCLA
and Section 300.430 of NCP. The NCP categorizes the nine evaluation criteria into three groups
as discussed in Section 2.9.
The following analysis summarizes the evaluation of remedial alternatives under these three
categories. Table 4-2 assesses each of the alternatives for achievement of a specific
criterion.
The selected alternative for addressing the groundwater contamination at the Nebo North plume is
Alternative 5 - Source Reduction (AS/SVE) at Warehouse 2 combined with Institutional
Controls/Groundwater Monitoring and fail-safe Extraction and Treatment Containment. This
alternative remediates the contaminant plume through natural attenuation enhanced by AS/SVE at
the source. The groundwater and vadose zone monitoring program will provide an adeguate
understanding of these processes and early warning triggers to start up the existing fail-safe
extraction and treatment system to prevent exposure to potential receptors. The practicality of
the proposed remedy is supported by the results of the extraction and treatment pilot study
recently completed. Based on the current information, this alternative provides the best
balance of trade-offs among the alternatives with respect to the EPA's nine evaluation criteria.
4.5.1 Threshold Criteria
4.5.1.1 Overall Protection of Human Health and the Environment
The calculated human health risk for all alternatives is within the EPA's risk management range.
However, without institutional controls, the no action alternative is at the upper bound of the
risk range (10 -4) and may not provide adeguate protection of human health and the environment
if the groundwater were to be used for domestic use in the future. The institutional controls
alternative provides protection by restricting future use and maintaining a fail-rate extraction
and treatment system. The calculated human health risk for Alternatives 3, 4, and 5 is well
within EPA's target risk range (1 x 10 -5). Assuming that institutional controls are effective,
all alternatives except the no action alternative are considered to be protective of human
health and the environment. However, only Alternatives 3, 4, and 5 use active measures to
reduce contamination, reduce the future threat to human health and the environment, and more
guickly remediate to cleanup levels.
4.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at MCLB Barstow is
provided in Section 2.10. All alternatives comply with location- specific ARARs because no
ecological or cultural resources are threatened by the groundwater contamination. All
alternatives also comply with action-specific ARARs; specifically, state antidegradation ARARs
for treated groundwater discharges, VOC emissions control, and groundwater monitoring
reguirements.
The Lahontan RWQCB has classified the aguifer underlying the Nebo Main Base as a potential
drinking water source. Based on the natural degradation processes that appears to be occurring
at the site, all other alternatives, including the no action and institutional controls
alternatives, provide passive or active remedies that will comply with the chemical-specific
federal and state ARARs for drinking water standards (i.e., MCLs).
4.5.2 Primary Balancing Criteria
4.5.2.1 Long-term Effectiveness and Permanence
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All alternatives except Alternative 1 provide moderate to high long-term effectiveness and
permanence in a relatively short time frame (i.e., 12 to 45 years). Institutional controls
(Alternative 2) can effectively reduce risk by restricting the use of untreated groundwater for
drinking water and providing wellhead treatment fail-safe when warranted. Alternative 2 will
meet cleanup levels through natural contaminant degradation processes in approximately 45 years.
As mentioned previously, the calculated human health risks are within the protective range.
4.5.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment
The no action alternative would not reduce toxicity, mobility, or volume through treatment
because it is not a treatment option. All other alternatives would achieve moderate to high
reduction of toxicity, mobility, or volume through extraction and treatment and AS/SVE
remediation, and satisfy the statutory preference for treatment. Alternative 2 can achieve this
criterion through natural contaminant degradation processes and contingent fail-safe extraction
and treatment.
4.5.2.3 Short-Term Effectiveness
Due to the length of remediation, short-term risks are the same as current risks. All
alternatives, except the no action alternative, rely on institutional controls for short-term
effectiveness of community protection.
The no action and institutional control alternatives would have the least immediate harmful
effect on human health and the environment, but would also provide less protection in the short
term. The active remediation alternatives would slightly increase the short-term risk of
exposure by pumping groundwater and handling contaminated soil. However, use of proper worker
protection and safety measures would reduce these risks to safe levels.
4.5.2.4 Implementability
The no action alternative is the easiest to implement because there is nothing to implement.
Imposing Institutional controls off-Base will reguire state, local, and community involvement.
Extraction and treatment and AS/SVE are proven, commercially available, readily implementable,
and simple to operate technologies. A full-scale extraction and treatment system already has
been constructed and is operating at the Nebo North plume. No constructibility issues that
could affect installation of an AS/SVE system at Warehouse 2 have been Identified. All
alternatives involve reasonable cleanup durations.
4.5.2.5 Cost Effectiveness
The selected Alternative 5 is the second least costly alternative, not including the no action
alternative. The estimated present worth value for Alternative 5 is $3.0 million. The
estimated present worth value of Alternatives 4 and 2 are $5.8 million and $2.2 million,
respectively. The selected alternative will meet the threshold criteria for protection of human
health and the environment, and will comply with ARARs in about 15 years.
4.5.3 Modifying Criteria
4.5.3.1 State Acceptance
The California State DTSC and RWQCB have reviewed the approved FS and Proposed Plan, and agree
with the selected final remedy for the Nebo North plume.
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4.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed actions for OUs 1
and 2. These comments are included on Page 27 of the public meeting transcripts provided in
Appendix C, and in Section 6, "Responsiveness Summary."
4.6 Summary of Selected Remedy For the Nebo North Plume
As reguired by CERCLA and the NCP, and based on the results of the detailed analysis of
alternatives presented in the FS, MCLB Barstow selected Alternative 5 as the final remedy to
address groundwater and vadose zone contamination at the Nebo North plume.
For the contaminated vadose zone and groundwater on site, the selected remedy includes source
reduction using an AS/SVE system at Warehouse 2 to enhance remediation. In the implementation
of this remedy, the DON shall perform sufficient source characterization of the vadose zone to
delineate the source at Warehouse 2, by which to design the AS/SVE system. To ensure that human
health and the environment are protected in the future, institutional controls will be
implemented that include access restrictions to prevent the on-Base use of untreated groundwater
for domestic use. Wellhead treatment will be provided for any existing water supply wells that
fall within the area of the plume exceeding MCLs. The DON will provide necessary information to
appropriate county agencies identifying off-Base areas impacted by groundwater contamination
exceeding MCLs. The DON will support county agencies with any technical information needed for
the county to implement restrictions on construction and use of wells in the affected areas.
All reguirements, procedures and restrictions established in Section 3.6 for development and
implementation of institutional controls, pursuant to Base Master Plan amendment language, shall
apply egually to this section.
Natural attenuation processes and source reduction at Warehouse 2 will be relied upon to
remediate VOC-contaminated soil and groundwater to met the cleanup goals (performance standards)
established in Table 2-1 of this ROD. A sampling protocol will be developed and incorporated in
the Nebo Main Base Remedial Action Groundwater Monitoring Plan to periodically determine VOC
degradation rates and monitor VOC mass reduction In the vadose zone and groundwater plume to
demonstrate the effectiveness of the selected remedy.
The four downgradient extraction wells from the existing groundwater extraction and treatment
pilot study system will be activated if VOC concentrations in downgradient monitoring wells
exceed MCLs as established in the approved post-ROD groundwater monitoring plan. The monitoring
plan will contain a statistical approach for triggering activation and deactivation of the
system In accordance with US and California EPA guidance developed for determining statistically
significant changes in indicator parameter values. The regulatory agencies will be notified
when the pump and treat system is activated. The system will extract contaminated groundwater
from the aguifer at a depth of 50 feet, treat it on site through a carbon filtration system, and
recharge it back into the aguifer through two percolation ponds downgradient of the plume.
Spent carbon filters will be taken off site for regeneration and will be reused. Extraction and
treatment of the groundwater will continue until the VOC concentrations in downgradient
monitoring wells no longer exceed MCLs, as established in the approved groundwater monitoring
plan.
The post-ROD monitoring plan, which will be a primary FFA document to be submitted to the
regulatory agencies within one year of the signing of this ROD, will specify the wells that will
be monitored to determine if an MCL has been exceeded, and the schedule and procedures for
confirming that this excess is statistically significant as described above.
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The selected remedy includes periodic groundwater and vadose zone monitoring to track changes in
the concentrations and extent of contamination. The major components of the remedy consist of:
• Implementing institutional controls
• Designing and implementing a sampling protocol to monitor and evaluate the progress
of natural processes in achieving performance standards
• Designing and constructing groundwater monitoring wells and SVE wells as necessary
• Designing, installing and operating an AS/SVE system in the area of Warehouse 2, and
conducting vadose zone monitoring to assess the effectiveness of the system
• Starting, operating, and shutting down the groundwater extraction and treatment pilot
study system on a contingency basis
• Transporting, regenerating, recycling, and/or disposal of the spent carbon filters
• Operating and maintaining a long-term groundwater monitoring plan, which includes
quarterly, semiannual or annual monitoring of selected COCs in the monitoring and
extraction wells to be specified in a post-ROD OU 2 Remedial Action Groundwater
Monitoring Plan
• Closure criteria.
The groundwater remedy for the Nebo North plume (OU 2) is consistent with the requirements of
Section 121 of CERCLA and the NCP. The remedy will reduce the mobility, toxicity, and volume of
contaminated groundwater at the Nebo North plume. In addition, the remedy is protective of
human health and the environment, will attain all federal and state ARARs, is cost-effective,
and uses permanent solutions to the maximum extent practicable. Based on the information
available at this time, the selected remedy represents the best balance among the criteria used
to evaluate remedies.
4.6.1 Performance Standards for Groundwater and Source Reduction
Groundwater from the aquifer shall be monitored until the cleanup goals (performance standards)
set forth in Table 2-1 are achieved as agreed upon between the DON and the regulatory agencies.
See Sections 2.8 and 4.3.2 for discussion of source reduction performance standards.
4.6.2 Infiltration Standards
Treated groundwater that will be recharged back into the aquifer through the percolation ponds
shall comply with the substantive general waste discharge requirements for land disposal of
treated groundwater, set forth in Lahontan RWQCB Board Order No. 6-93-106 as TBCs. These
requirements are listed in Table 3-6. Meeting these requirements shall ensure compliance with
SWRCB Resolution 68-16 and the Basin Plan ARARs. The general discharge requirements of Board
Order No. 6-93-106 have monitoring requirements that verify compliance. A schedule of
compliance appropriate for this monitoring shall be established in the OU 2 Nebo Main Base
Remedial Action Groundwater Monitoring Plan.
4.6.3 Groundwater and Vadose Zone Monitoring
Groundwater and vadose zone monitoring shall be conducted for the Nebo North Plume during the
remedial action in accordance with the Nebo Main Base Remedial Action Groundwater Monitoring
Plan (see Section 4.4.2) to verify that the remedial action is being effective towards achieving
RAOs. The DON will monitor the groundwater and vadose zone as specified in the groundwater
monitoring plan until it is demonstrated that the remedial action has effectively and
permanently reduced the VOC contamination to within the RGs set out in Table 2-1. The criteria
for assessing the effectiveness of the remedial action shall also be included in the remedial
action groundwater monitoring plan. If monitoring indicates that RGs have not been met in
accordance with these criteria, the groundwater and vadose zone remedial action will continue
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until the RGs are achieved. The results of the groundwater and vadose zone monitoring will be
evaluated every five years, and the duration and frequency of the groundwater monitoring
modified as appropriate and with the concurrence of the FFA signatories, until it is determined
that the remedial action has been completed.
4.7 Statutory Determination
Under its legal authorities, the Marine Corps' primary responsibility at Superfund sites is
to undertake remedial actions that adequately protect human health and the environment. In
addition, Section 121 of CERCLA established several other statutory requirements and
preferences. These specify that, when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental standards as established under
federal and state environmental laws unless a statutory waiver is justified. The selected
remedy also must be cost effective and use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that, as their principal element, employ treatment
that permanently and significantly reduce the volume, toxicity, or mobility of hazardous wastes.
The following sections discuss how the selected remedy meets these statutory requirements.
4.7.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment by remediating the contaminant
plume through natural processes and AS/SVE source reduction at the Nebo North plume. The
selected remedy provides protection to human health and the environment by eliminating,
reducing, and controlling risk through source reduction, natural processes and institutional
controls. The contaminated groundwater in the Nebo North plume will be treated by natural
processes to cleanup levels. In addition, institutional controls and fail-safe extraction and
treatment containment will be used if necessary throughout the remediation process to protect
human health and the environment.
4.7.2 Compliance with ARARs
As stated in Section 2.10, remedial actions performed under CERCLA must comply with all ARARs.
All alternatives considered for the Nebo North groundwater plume were evaluated on the basis of
the degree to which they comply with these requirements. The selected alternative was found to
comply with all ARARs presented in Tables 2-2 through 2-7.
4.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being considered with
their overall effectiveness to determine whether the costs are proportional to the effectiveness
achieved. The Marine Corps evaluates the incremental cost of each alternative as compared to
the increased effectiveness of the remedy. The selected remedy for groundwater and vadose zone
is source reduction, institutional controls, and remediation by natural degradation processes
and through fail-safe pump-and-treat. Based on the information obtained, this selected remedy
will provide the best balance of trade-offs among the alternatives with respect to the nine
criteria provided by the NCP to evaluate the alternatives. The selected remedy is the second
least costly of the alternatives considered that meets the threshold criteria for protection of
human health and the environment and compliance with ARARs for groundwater contamination
removal.
4.7.4. Use of Permanent Solutions to the Maximum Extent Practicable
MCLB Barstow, EPA, DTSC, and CRWQCB believe that the selected remedy is the most appropriate
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remedial approach for Nebo North groundwater and vadose zone cleanup, and provides the best
balance among the evaluation criteria for the remedial alternatives considered. The source
reduction/natural processes remedy for groundwater and vadose zone is a permanent remedy. The
selected remedy meets the statutory reguirement to use permanent solutions and innovative
treatment technologies to the maximum extent practicable.
4.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Nebo North plume will be met through passive
treatment of contaminated groundwater by natural processes and removal of VOCs from the vadose
zone by AS/SVE.
4.8 Documentation of Significant Change
The final remedy for Nebo North plume, Alternative 5, has not been changed or refined from the
Proposed Plan.
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Table 4-1
Nebo North Plume
Maximum Groundwater Concentrations of VOCs and Associated MCLs
Benzene
VOCs
Contaminants Exceeding
roethane (1,2-DCA)
Maximum
Groundwater
Concentration
(Ig/L)
Drinking Water Standards (MCLs)
3
1.2
Federal
MCL
(Ig/L)
5.0
5.0
California
MCL
(Ig/L)
0.5
1.0
PRG
(Ig/L)
-
-
Tetrachloroethene(PCE)
5.0
Contaminants Not Exceeding Drinking Water Standards (MCLs)
1,1-Dichloroethane
1,1,1-TCA
2-Hexanone
1,2-Dichloroethene, Total (1,2-DCE)
2-Butanone (methyl ethyl ketone)
Acetone 1
Carbon Disulfide
Chloroform
Chloromethane 2
Methylene Chloride 1
Toluene
Trichloroethene (TCE)
0.7
2
13
2
5
7
3
2
8.9
2
0.2
4
200
70.0
100 2
5.0
1,000
5.0
5.0
5.0
200
6.0
150
5.0
Not available
1900
610
21
1.5
1 This chemical is a Suspected laboratory contaminant and is not considered representative of plume conditions.
2 MCL is for total trihalomethanes.
Note: Data also include most recent groundwater monitoring conducted by OHM Remediation Services, Inc. (OHM 1994, 1996, 1996)
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Table 4-2
Summary of Comparative Analysis - Nebo North Plume, NRF-1
MCIiB Bar stow
Alternatives
Criteria
NRF1-GW-1
NRF1-GW-2
NRF1-GW-3
NRF1-GW-4
NRF1-GW-5
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume
Short-Term Effectiveness
Implementability
Duration of Remedy
Time to MCLs (years)
Time to Background (years)
Present Cost($ millions) 20 Years Duration
Remediation to MCLs
Remediation to Background
No
*No
Low
Low
Low
High
45
120
0
0
0
*No
Mod
Low
Mod
High
45
120
1.9
2.2
2.3
Within Risk Management Range**
Yes Yes
Mod High
Mod High
Mod High
High High
42
110
5.3
7.1
7.9
12
30
6.6
5.8
7.3
Yes
Hig
High
High
High
15
38
3.1
3.0
3.6
* ARARs achieved over time only through natural groundwater attenuation.
** Alternatives NRF1-GW-2 through NRF1-GW-5 all result in residual risks that fall within EPA's risk management range of 10 -6 to 10 -4. Clean up to MCLs would result in an
upper-bound incremental risk of approximately 1 x 10 -5 while clean up to background (0.5 Ig/L) would result in a risk of approximately 5 x 10 -6.
Alternative NRF1-GW-1: No Action
Alternative NRF1-GW-2: Institutional Controls and Groundwater Monitoring with fail-safe pump-and treat
Alternative NRF1-GW-3: Groundwater Removal, Ex Situ Treatment, and Discharge
Alternative NRF1-GW-4: Groundwater Removal, Ex Situ Treatment, and Discharge with Source Reduction (Air Sparging/Soil Vapor Extration)
Alternative NRF1-GW-5: Source Reduction (Air Sparging/Soil Vapor Extraction)
ARARs - Applicable or relevant and appropriate reguirements.
Mod - Moderate.
NA - Not applicable.
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5.0 NEBO SOUTH PLUME
5.1 Summary of Plume Characteristics
5.1.1 Contaminants of Concern
5.1.1.1 Organics
The results of the groundwater RI for Nebo South plume indicate that VOCs are the primary class
of chemicals affecting the groundwater in the southern Nebo Main Base area. TCE, PCE, and
1,2-DCA have been detected at concentrations exceeding their federal and/or state drinking water
standards. Other VOCs detected at levels not exceeding federal or state standards include
1,1-DCE, chloroform, bromoform, dibromochloromethane, and bromodichloromethane.
Table 5-1 shows the maximum concentration of VOCs detected in the Nebo South groundwater
monitoring wells, along with their associated MCLs. Contaminants exceeding drinking water
standards appear at the top of the table.
TCE appears to be the predominant contaminant in the groundwater at the Nebo South plume and was
detected in all seven wells in the plume area. PCE was detected in three of the seven wells.
5.1.1.2 Inorganics
The evaluation of the nature and extent of metals concentrations at the Nebo South plume
indicates that metals are not present in the groundwater plume at levels above the expected
naturally occurring concentrations. The RI concluded that there is no evidence that discharge
of wastes from the Base has resulted in elevated metals concentrations in the groundwater at the
southern Nebo Main Base area.
5.1.2 VOC Contaminant Source
VOCs are the only confirmed class of groundwater contaminants in the Nebo South plume area. The
areal extent of the VOC plume and location of contaminant sources are shown in Figure 4-1. The
groundwater contamination plume at Nebo South plume appears to be the result of historical
releases and disposal practices for solvents at CAOC 6 between 1946 and 1952. Practices
included disposing of waste liguids in revetments at this CAOC. The maximum concentrations of
PCE and TCE detected in groundwater in this area are 17 and 422 Ig/L, respectively.
5.1.3 Location of Vadose Zone Contamination
Although VOCs were not detected in soil samples at this CAOC during the RI, VLEACH modeling
conducted on soil gas data collected from several vertical profile borings indicated that
organic vapors in the vadose zone soils pose a continuing, long-term source of VOCs to
groundwater. Groundwater contamination by VOCs has been confirmed at this site. The vadose
zone at CAOC 6 has been targeted for remedial action under OU 2 on the basis of these results.
An air sparge/soil vapor extraction (AS/SVE) pilot study is being conducted at CAOC 6 to
evaluate the feasibility of this technology and to help select the most practical and
cost-effective remedial alternative for the Nebo South VOC plume.
5.1.4 Location of Groundwater Contamination
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VOCs were detected in groundwater at and downgradient of CAOC 6 as discussed in Section 5.1.3.
Figures 4-2 and 4-3 show the distribution of PCE and TCE in groundwater in the area of the Nebo
South plume. These maps, contoured using Lynx Geosystem, show the location of the source area
and the extent of the dissolved VOC plume. The areal extent of the plume is approximately 1,000
by 800 feet, and appears to be limited to the upper 40 feet of the aquifer. The groundwater
contaminant plume has migrated off Base; however, the data suggest that the plume has not moved
far off-Base. The leading edge of the plume extends downgradient approximately 600 feet from
the Base boundary. In 1992, TCE concentrations above the MCL were found in a private resident's
well. The Base conducted a time-critical removal action to remove the well from service and
connect the residence to the Base water supply system.
5.1.5 Contaminant Migration Routes
Two potential routes of contaminant migration were identified for the Nebo South plume.
1) Vadose zone contaminant transport:
a) Vertical transport through the soil by desorption of chemicals bonded to the
surface of soil particles and percolation of infiltrated water through the
contaminated soil column.
b) Vertical and horizontal transport of contaminant vapors through soil pore space
from either residual or re-vaporization of material adsorbed/absorbed onto the
soil particles. Vapors can potentially recontaminate the groundwater or be
emitted to the surface.
2) Groundwater contaminant transport: Vertical and horizontal transport of contaminants
through the groundwater matrix.
5.1.5.1 Vadose Zone Contaminant Transport
In general, VOCs have a high vertical mobility in soils and can percolate into the groundwater.
The data gathered from the Nebo South plume area indicate that VOCS have percolated into the
groundwater and that TCE and PCE are the predominant constituents of groundwater contamination.
Soil gas data collected during installation of the pilot study AS/SVE system (OHM 1995b) was
also used for the VLEACH modeling analysis. The results indicated that the maximum
concentration of TCE (5.6 Ig/L), which was slightly above the MCL (5 Ig/L), would reach
groundwater in 1 year.
5.1.5.2 Groundwater Contaminant Transport
As shown in Figure 4-1, the Nebo South plume is restricted to the general CAOC 6 area. The
plume area is estimated, at 800 by 1,000 feet. The longitudinal transport of TCE extends 600
feet downgradient of the Base boundary. The plume appears to have limited longitudinal and
lateral migration. This limited migration appears to be the result of relatively fight soils
that slow the contaminant migration and inhibit groundwater flow in this area.
Groundwater samples from intermediate-depth monitoring wells (screened from 40 to 60 feet below
the groundwater table) resulted in mostly concentrations of VOCs below detection limits through
the Nebo Main Base. A vertical extent of 40 feet was conservatively assumed to be the average
depth of groundwater VOC contamination at the Nebo South plume.
5.2 Summary of Nebo South Plume Risks
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The major risk currently associated with the Nebo South plume is the ingestion of the
contaminated groundwater underlying the affected on- and off-Base areas. Actual or threatened
releases of hazardous substances from the Nebo South plume, if not addressed by implementing the
response action selected in the ROD, may present a threat to public health and the environment.
5.2.1 Chemicals of Concern
The majority of the waste and residues generated by mission operations at the Nebo Main Base
have been managed, treated, and disposed of on site throughout the Base history. By applying
screening criteria, the chemicals detected in the vadose zone and groundwater during the RI were
evaluated for inclusion as chemicals of potential concern in the risk assessment.
Contaminants of concern identified in groundwater at the Nebo Main Base are listed in Table 5-1.
5.2.2 Summary of Toxicity Values
Summaries of the carcinogenic and noncarcinogenic toxicity values for contaminants of concern in
groundwater at the Nebo South plume area are provided in Tables 3-3 and 3-4, respectively.
5.2.3 Human Health Risk
For groundwater at Nebo South plume under OU 2, the BLRA evaluated future hypothetical
residential scenario.
The BLRA showed that under this scenario for cancer risk, as many as 10 persons in 10,000 (1 X
10 -3 ) have the potential to develop cancer during their lifetimes. Excluding the contribution
from naturally occurring metals and laboratory contaminants, the incremental cancer risk is
approximately 4 x 10 -4. The primary contributor to this risk is TCE.
These estimates were developed by taking into account the conservative assumptions about the
likelihood of a person being exposed to groundwater contamination (see Section 2.7.2). The
estimate is above the EPA's target risk management range of 10 -4 to 10 -6.
Evaluations were also performed for hypothetical receptors assuming exposure at the MCL and
background levels (analytical guantitation limit). At the MCL, the incremental risk from both
PCE and TCE was estimated to be approximately 1 x 10 -5. The corresponding incremental risk at
the background level is approximately 5 x 10 -6. The noncarcinogenic hazard index is less than
1.0 for both chemicals.
5.2.4 Ecological Risk
EPA Region IX independently conducted an ecological risk assessment to evaluate potential
effects on plants and animals from groundwater contaminants at MCLB Barstow. At Nebo South, the
groundwater in most areas is found at depths greater than 100 feet bgs and no surface water
exists. Exposure of potential ecological receptors to VOCs in groundwater is unlikely because
groundwater does not discharge to local surface water and is therefore not accessible to plants
and animals. Thus there is no complete exposure pathway to impact ecological receptors at Nebo
South.
5.3 Rationale for Remedial Action Decisions
This section discusses the rationale used to make groundwater and vadose zone cleanup decisions
for the Nebo South plume.
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5.3.1 Groundwater Cleanup
The extent of groundwater VOC contamination at the Nebo South plume was determined during the
RI/FS. As discussed in Section 5.1.4, the Nebo South plume is located in a relatively deep
aguifer (about 180 feet) characterized by fine-grained soil conditions that significantly
inhibit plume movement. Site characterization and fate and transport modeling data generated
for the site indicates that this plume is moving very slowly and will continue to migrate
indefinitely unless it is contained. The plume has already migrated off Base about 600 feet
east of the Base boundary. Due to the site conditions, this plume is not likely to degrade by
natural processes to concentrations below MCLs for over 500 years. As with the Nebo North
plume, the MCL and background contour areas for the Nebo South plume are very close together
(within 300 feet).
Based on site conditions, the containment strategy selected for this plume is to prevent any
further migration of the VOC contamination at the leading edge of the plume, which contains both
the MCLs and background boundaries. This strategy captures 100 percent of the total VOC mass
estimated to exist in the aguifer. Two groundwater cleanup options were considered in the FS
under this containment strategy.
1) Containment of groundwater contamination at the leading edge of the VOC plume by
active extraction and treatment. This process option was evaluated to determine if
extraction and treatment is a cost-effective remedy to prevent further plume
migration and provide a permanent solution. Due to the significant limitations posed
on extraction and treatment technology by the extremely low permeability of the
aguifer (i.e., maximum well yields of 5 gpm), a limited containment system was
determined to be more cost-effective than a more aggressive full-scale system.
2) Removal of VOC contaminant source by AS/SVE at CAOC 6. This process option was
evaluated to determine if AS/SVE is a cost-effective remedy to remove VOC
contamination from the vadose zone and groundwater in the source area and reduce the
time reguired to cleanup the aguifer with the extraction and treatment containment
system. A pilot study consisting of two nested sets of two air sparging wells (one
shallow and one deep) and six vapor extraction wells was conducted to analyze the
effectiveness of AS/SVE in removing VOC mass from the vadose zone and groundwater.
The pilot study yielded inconclusive results. Average radius of influence, mass
removal rates, vacuum levels and flow rates for both AS and SVE wells were greater
than expected, suggesting that coverage of the entire site could be achieved with
about half as many wells as originally anticipated. However, the results also
indicate significant variability from well to well for some of the parameters,
suggesting that localized subsurface conditions could significantly affect the
performance of a full-scale system. In addition, many data gaps in the study make it
difficult to fully assess the results.
Because of the inconclusive results of the AS/SVE pilot study so far, the Marine Corps has
decided to select the plume containment option as an interim remedy at this time. The Marine
Corps believes this interim remedy is necessary to contain the plume while continuing the pilot
study to obtain more conclusive data to characterize the source area and assess the
effectiveness of AS/SVE to reduce remediation costs.
The Marine Corps anticipates that the results of the pilot study will provide data that will
allow for a more accurate determination of the source area and overall cleanup time using the
AS/SVE alternative. If it is determined that AS/SVE is not the best alternative for
remediation, the Marine Corps will recommend a future course of action in the primary FFA
deliverable. The Marine Corps feels that the selected interim remedy is the best option at this
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time, since it is fully protective of human health and the environment, prevents downgradient
migration, and is cost effective.
The appropriate groundwater cleanup goal for the Nebo South plume was selected based on an
evaluation of the technical and economic feasibility of achieving MCL and background levels, the
residual risk remaining in groundwater after achieving each cleanup goal, and the costs/benefits
of incremental risk reduction. The following summarizes the TEF analysis results and
conclusions.
• Cleanup of contaminated groundwater to MCLs would reduce baseline risks by 98 percent
resulting in a residual risk of 1 x 10 -5. Cleanup to background levels would reduce
baseline risks by 99 percent, resulting in a residual risk of 5 x 10 -6 (an
incremental 1 percent reduction over MCLs). Both cleanup levels are within EPA's
risk management range and are considered protective of human health and the
environment.
• Cleanup of contaminated groundwater to MCLs would remove 93 percent of the total
estimated VOC mass, and take from 55 to over 500 years depending on the alternative
selected. Cleanup to background levels would remove 100 percent of the total
estimated VOC mass (an incremental 7 percent mass reduction over MCLs), and would
take from 130 to over 500 years for the same alternatives (an incremental 130 percent
duration over MCLs).
• The estimated present worth costs of all alternatives evaluated range from $1.3 to
15.1 million for cleanup to MCLs, versus $1.3 to 16.2 million for cleanup to
background levels, a cost increase of 1 to 5 percent for background over MCLs.
Hydrogeological conditions in the Nebo South plume may pose significant limitations to aguifer
remediation due to the very low permeability of the aguifer. These conditions can make cleanup
of contaminated groundwater extremely difficult and very unlikely to achieve either MCLs or
background levels within a reasonable time. Although the incremental costs of remediating to
background levels versus MCLs do not appear significant, this is largely due to the masking
effects of present worth analysis caused by the extremely long durations of the remedial
alternatives (the shortest time to achieve background is 130 years). Cleaning up to background
instead of to MCLs would result in only a minimal incremental difference in risk reduction and
mass removal while increasing cleanup duration by two- to three-fold. Based on the above
rationale and the fact that both MCLs and background cleanup goals are considered protective of
human health and the environment, the TEF analysis concluded that cleanup to background levels
is technically and economically infeasible. The Marine Corps therefore selected MCLs as the
cleanup goal for the Nebo South VOC plume.
5.3.2 Source Reduction
Vadose zone contamination that may pose a continuing, long-term source of VOCs to groundwater
has been determined to exist at CAOC 6. Continued releases to groundwater from this area could
potentially re duce the effectiveness of remediation and extend the duration of cleanup.
The following cleanup options were evaluated for the CAOC 6 area in the FS:
1) Soil excavation: This option is not feasible to remove the residual contamination in
the soil because of the depth of the contamination (180 feet to groundwater) at CAOC
6.
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2) In Situ Vertical AS/SVE: This option involves installing and operating a full- scale
AS/SVE system to provide adeguate coverage of the vadose zone and groundwater in the
source area of CAOC 6. As discussed previously, the initial results of the pilot
study were inconclusive regarding whether AS/SVE could effectively remove VOCs from
the source area and reduce the remediation time for the Nebo South plume. Therefore,
the Marine Corps has decided to continue to operate the pilot study until conclusive
results can be obtained.
5.4 Description of Alternatives
Five alternatives are presented in this ROD for remediation of groundwater and vadose zone soil
in the Nebo South plume area. These alternatives are discussed in detail in the Draft Final FS
for OUs 1 and 2 (Jacobs 1996a) and are summarized in this section.
5.4.1 Alternative 1 - No Action
Under this alternative, MCLB Barstow would not take any action to clean up or control
contamination from vadose zone soils or groundwater. Existing site conditions would not change.
No costs are associated with this alternative. The no action alternative provides a baseline
for comparing the other alternatives.
5.4.2 Alternative 2 - Institutional Controls/Groundwater Monitoring
This alternative includes implementing institutional controls and initiating a long- term
groundwater monitoring program. This alternative relies on natural processes such as
dispersion, degradation, sorption, and volatilization to reduce VOC concentrations.
Institutional controls will ensure that the affected groundwater will not be used in the future,
thereby maintaining the current lack of exposure to, and risks from, chemicals in the
groundwater.
Institutional controls include restrictions on the use of untreated groundwater for drinking
water, and provisions for wellhead treatment of affected water supply wells within the Nebo Main
Base South plume area. The Institutional controls to restrict access to contaminated
groundwater in this area will be documented in the Base Master Plan.
This alternative also includes a long-term program to monitor vadose zone and groundwater
beneath and downgradient of contaminant sources. Groundwater monitoring involves sampling
existing monitoring wells to: 1) monitor trends in contaminant concentrations; 2) evaluate
remediation progress and contaminant patterns; and 3) provide early warning to prevent
contaminant exposure to potentially affected downgradient users. Vadose zone monitoring
involves sampling of soil vapor probes to 1) monitor trend in contaminant concentrations and 2)
assess the effect of the vadose zone contamination on the effectiveness of the selected remedy.
A post-ROD vadose zone and groundwater monitoring plan for the Nebo South plume remedial action
will be prepared under the authority of this ROD, outlining the monitoring well network,
sampling and analytical methods, sampling freguency, and major decision points during monitoring
(e.g., adding/removing monitoring wells from the network, changing sampling freguency of
analytical parameters, etc.).
The cost for Alternative 2 includes approximately $90,000 in capital costs and $55,000 in yearly
O&M costs to put in place institutional controls and install and monitor groundwater monitoring
wells, for a total present worth cost of $1.3 million. Groundwater modeling indicates that
minimal natural processes are at work and that it would take this alternative over 500 years to
degrade the groundwater contamination to levels below drinking water standards. Except for the
-------
no action alternative, all of the alternatives include institutional controls and long-term
groundwater monitoring.
5.4.3 Alternative 3 - Vadose Zone Source Reduction (AS/SVE at CAOC 6)
This alternative involves operating the existing AS/SVE pilot study system. This pilot-scale
system does not prevent plume migration and will only remove VOCs from vadose zone soils and
groundwater within a limited portion of the plume. This alternative is intended to reduce the
time to clean up the groundwater VOC contamination by removing contaminants trapped in the
vadose zone soil and groundwater underneath the source.
The cost for Alternative 3 includes $738,000 in capital costs to construct the treatment system,
(all of which has already been constructed as part of the pilot study), and $110,000 in yearly
O&M costs to operate the system. The total present worth cost of this alternative is estimated
at $3.3 million, of which $1 million has been incurred in the pilot study. Groundwater modeling
indicates that it would take this alternative over 500 years to degrade the groundwater
contamination to levels below drinking water standards.
5.4.4 Alternative 4 - Groundwater Removal (Extraction Wells at MCL/Background Boundary),
Source Reduction at CAOC 6, Ex Situ Treatment, and Discharge
This alternative builds upon Alternative 3 by: 1) expanding the existing pilot scale AS/SVE
system to a full-scale AS/SVE treatment system to address source removal at CAOC 6; and 2)
adding a groundwater extraction and treatment system to contain the leading edge of the plume.
The full-scale AS/SVE system would consist of ten nested sets of air sparge wells, each
containing a shallow and a deep well, and 30 soil vapor extraction wells designed to collect the
VOC gases released from the air sparging wells and remove vadose zone contamination that may be
acting as a source of groundwater contamination.
The extraction and treatment system would consist of five groundwater extraction wells spaced
about 200 feet apart, and screened as deep as 60 feet below the groundwater table to capture the
deepest contamination. The extracted groundwater would pass through activated carbon treatment
and be pumped via a pipeline to the percolation ponds used by the Nebo North plume treatment
system to recharge the groundwater. This system would only extract groundwater at an estimated
rate of about 25 gpm (5 gpm per well) due to the very tight soil formation at this site.
Should AS/SVE be determined to be technically and economically feasible at the conclusion of the
pilot study, this alternative would considerably reduce the total time to meet MCLs (from 500 to
55 years). The cost for Alternative 4 includes $3.3 million in capital costs to construct the
treatment system (of which $1 million has already been constructed as part of the pilot study)
and $598,000 in yearly O&M costs to operate the system. The total present worth cost of this
alternative is estimated at $15.1 million.
5.4.5 Alternative 5 - Groundwater Containment and Removal (Extraction wells at MCL), Ex Situ
Treatment, and Discharge
This alternative provides an intermediate option between Alternatives 3 and 4. Alternative 5
consists of the five groundwater extraction wells system in Alternative 4 to contain and extract
the groundwater at the leading edge of the plume. The extracted groundwater would be treated
with activated carbon and then pumped to the percolation ponds to recharge the groundwater.
This alternative evaluates the option of cleaning up the VOCs contaminated groundwater to meet
federal and state drinking water standards without having to address the source. This
alternative is estimated to meet MCLs in approximately 105 years.
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The cost for Alternative 5 includes $892,000 in capital costs and $205,000 in yearly O&M costs
to construct and operate the treatment system, for an estimated total present worth cost of $5.5
million.
5.5 Summary of Comparative Analysis of Alternatives
This section summarizes the evaluation of alternatives conducted to determine which alternative
provides the best balance with respect to statutory balancing criteria in Section 121 of CERCLA
and Section 300.430 of NCP. The NCP categorizes the nine evaluation criteria into three groups,
as discussed in Section 2.9. The following analysis summarizes the evaluation of remedial
alternatives under the three categories. Table 5-2 compares the alternatives for achievement of
a specific criterion.
The selected alternative for addressing the groundwater contamination at the Nebo Main South is
Alternative 5: Groundwater Containment and Removal (Extraction Wells at the MCL/Background
Boundary). This alternative was selected as an interim remedy. Based on current information,
the Marine Corps believes plume containment (Alternative 5) is a necessary interim action to
stop any further plume migration. The agencies agree with this conclusion and concur with the
Marine Corps decision to continue to run the pilot study for a longer duration until useable
data are obtained to fully characterize the source area and assess the effectiveness of AS/SVE
to shorten cleanup times and reduce overall treatment costs.
5.5.1 Threshold Criteria
5.6.1.1 Overall Protection of Human Health and the Environment
The no action alternative does not adeguately protect human health and the environment if the
groundwater were to be used as drinking water in the future. The institutional controls
alternative (Alternative 2) provides protection by restricting future use. The calculated human
health risk for Alternatives 3, 4, and 5 is within EPA's target risk range. Assuming that
institutional controls are effective, particularly in off-Base areas, all alternatives except
the no action alternative are considered to be protective of human health and the environment.
However, only Alternatives 3, 4, and 5 use active measures to significantly reduce
contamination, the future threat to human health and the environment, and more guickly remediate
to cleanup levels.
5.5.1.2 Compliance with ARARs
A summary of the potentially applicable ARARs for groundwater protection at MCLB Barstow is
provided in Section 2.10. All alternatives comply with location-specific ARARs if the existing
tortoise protection measures are followed for alternatives reguiring active remediation. No
natural or cultural resources are threatened by the groundwater contamination. All alternatives
also comply with action-specific ARARs; specifically, state antidegradation ARARs for treated
groundwater discharges, VOC emissions control, and groundwater monitoring reguirements. Only
Alternatives 4 and 5 comply with chemical-specific federal and state ARARs drinking water
standards (i.e., MCLs).
5.5.2 Primary Balancing Criteria
5.5.2.1 Long-Term Effectiveness and Permanence
All alternatives except Alternative 1 provide moderate to high long-term effectiveness and
permanence. However, Alternatives 2 and 3 reguire a very long time to achieve remedial goals
-------
(over 500 years). Institutional controls can effectively reduce risk by restricting the use of
untreated groundwater for drinking water and providing wellhead treatment when warranted.
Alternative 5 can significantly reduce the remediation time over Alternatives 2 and 3 from 500
to 105 years.
5.5.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
The no action and institutional control alternatives would not reduce toxicity, mobility, or
volume through treatment because they are not treatment options. Alternative 3 would not comply
with this criterion because it only provides active AS/SVE treatment within a limited portion of
the plume. Only Alternatives 4 and 5 achieve moderate to high reduction of toxicity, mobility,
or volume through active extraction and treatment and/or AS/SVE remediation and satisfy the
statutory preference for treatment. Alternatives 1, 2, and 3 reduce toxicity, mobility, and
volume through natural degradation of the contaminants over a long time.
5.5.2.3 Short-Term Effectiveness
Due to the length of remediation, short-term risks are the same as current risks. All
alternatives except the no action alternative rely on institutional controls for short-term
effectiveness of community protection. Such controls are more effective on-Base. If off-Base
controls were not maintained, short-term effectiveness would be compromised.
The no action and institutional control alternatives would have the least immediate harmful
effect on human health and the environment, but would also provide less protection in the short
term. The active remediation alternatives would slightly increase the short-term risk of
exposure by pumping and handling of contaminated groundwater and soil. However, use of proper
worker protection and safety measures would reduce these risks to safe levels.
5.5.2.4 Implementability
The no action alternative is the easiest to implement because there is nothing to implement.
Imposing institutional controls off Base will reguire state, local, and community involvement.
Extraction and treatment and AS/SVE are proven, commercially available, readily implementable,
and simple-to-operate technologies. No problems are expected during installation of on-Base
extraction wells and treatment systems. Construction of off-Base extraction wells will reguire
gaining access through coordination with private land owners and local officials. Alternatives
2 and 3 involve very long cleanup duration.
5.5.2.5 Cost Effectiveness
The selected interim alternative (Alternative 5) is the second most costly, with an estimated
present worth value of $5.5 million, exceeded only by Alternative 4, with a present worth of
$15.1 million. Alternative 5 costs more than Alternatives 1, 2, and 3, but is the least costly
groundwater remedy that meets the threshold criteria for protection of human health and the
environment. Furthermore, it significantly reduces cleanup time. Therefore, the higher cost of
Alternative 5 is justifiable.
5.5.3 Modifying Criteria
5.5.3.1 State Acceptance
The California State DTSC and RWQCB have reviewed the approved FS and Proposed Plan, and agree
with the selected interim remedy for the Nebo South plume.
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5.5.3.2 Community Acceptance
Minor verbal comments were received from the public concerning the proposed actions for OUs 1
and 2. These comments are included on Page 27 of the public meeting transcripts provided in
Appendix C and in Section 6.0, "Responsiveness Summary."
5.6 Summary of Selected Interim Remedy For the Nebo South Plume
As reguired by CERCLA and the NCP, and based on the results of the detailed analysis of
alternatives presented previously, MCLB Barstow selected Alternative 5 as an interim remedy to
address groundwater and vadose zone contamination at the Nebo South plume.
The selected remedy is an interim remedy consisting of containment and removal of the
groundwater contaminant plume from the aguifer, followed by ex situ treatment and recharge of
treated groundwater back into the aguifer. Five extraction wells will be arranged to contain
the entire plume originating from CAOC 6. The actual locations, sizing, and pumping rates for
the wells will be determined by evaluating the results of pump tests to be conducted as part of
the remedial design phase.
Based on current information, the DON believes this interim remedy is a necessary containment
measure designed to stop any further migration of the VOC plume and prevent the contamination
from impacting unaffected waters of the state. The DON has decided to implement this interim
remedy while continuing to operate the AS/SVE pilot study at CAOC 6 to obtain the data needed to
assess the effectiveness of AS/SVE. The agencies agree with the above conclusions and concur
with the DON's decision.
The results of the pilot study will be incorporated into an FFA primary document deliverable to
be submitted to the agencies as established in Section 2.8.12 of this interim ROD.
To ensure that human health and the environment are protected in the future, institutional
controls will be implemented that include access restrictions to prevent the on-Base use of
untreated groundwater for domestic use. Wellhead treatment will be provided for any existing
water supply wells that fall within the area of the plume exceeding MCLs. The DON will provide
necessary information to appropriate county agencies identifying off Base areas impacted by
groundwater contamination exceeding MCLs. The DON will support county agencies with any
technical information needed for the county to implement restrictions on construction and use of
wells in the affected areas.
All reguirements, procedures, and restrictions established in Section 3.6 for development and
implementation of institutional controls, pursuant to Base Master Plan amendment language shall
apply egually to this section. The major components of the selected remedy consist of:
• Implementing institutional controls
• Designing and constructing of groundwater extraction and monitoring wells
• Designing and installing a groundwater pumping and monitoring system and a treatment
system (the percolation ponds already exist)
• Starting and operating this system
• Transporting, regenerating, recycling, and/or disposal of the spent carbon filters
• Operating and maintaining a long-term groundwater monitoring program, which includes
guarterly, semiannual, or annual monitoring of selected COCs in extraction and
monitoring wells to be specified in the post-ROD OU 2 Remedial Action Groundwater
Monitoring Plan.
The interim groundwater remedy for the Nebo South plume (OU 2) is consistent with the
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requirements of Section 121 of CERCLA and the NCP. The interim remedy will reduce the mobility,
toxicity, and volume of contaminated groundwater at the Nebo South plume. The interim remedy
for the Nebo South plume is consistent with previous and projected removal actions at the site.
Based on the information available at this time, the selected remedy represents the best balance
among the criteria used to evaluate remedies.
The DON believes that the selected interim remedy is the best option at this time, since it is
fully protective of human health and the environment, prevents downgradient migration of the
contaminant plume, and is cost-effective. Because the selected interim remedy is not a final
remedy, a Proposed Plan and ROD for this plume will be provided at a later date when a final
remedy is decided. The Proposed Plan and ROD would be required to go through public
participation and agency approval pursuant to CERCLA/NCP and the FFA.
5.6.1 Performance Standards for Groundwater
Groundwater from the aquifer shall be monitored until the cleanup goals (performance standards)
set forth in Table 2-1 are achieved, as agreed upon between the DON and the regulatory agencies.
See Sections 2.8 and 5.3.2 for discussion of source reduction performance standards.
5.6.2 Infiltration Standards
Treated groundwater that will be recharged back into the aquifer through the percolation ponds
shall comply with the substantive general waste discharge requirements for land disposal of
treated groundwater, set forth in Lahontan RWQCB Board Order No. 6-93-106 as TBCs. These
requirements are listed in Table 3-6. Meeting these requirements shall ensure compliance with
SWRCB Resolution 68-16 and the Basin Plan ARARs. The general discharge requirements of Board
Order No. 6-93-106 have monitoring requirements that verify compliance. A schedule of
compliance appropriate for the purpose of this monitoring shall be established in the OU 2 Nebo
Main Base Remedial Action Groundwater Monitoring Plan.
5.6.3 Groundwater and Vadose Zone Monitoring
Groundwater monitoring shall be conducted for the Nebo South plume during the interim remedial
action in accordance with the Nebo Main Base Remedial Action Groundwater Monitoring Plan (see
Section 5.4.2) to verify that the remedial action is effectively achieving the interim plume
containment goal. The criteria for assessing the effectiveness of the interim remedial action
shall also be included in the groundwater monitoring plan. Criteria for long-term groundwater
and vadose zone monitoring will be incorporated into the plan when the final remedy is selected.
5. 7 Statutory Determination
As a lead federal agency, the Marine Corps' primary responsibility at its CERCLA sites is to
undertake remedial actions that adequately protect human health and the environment. In
addition, Section 121 of CERCLA established several other statutory requirements and
preferences. These specify that, when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental standards as established under
federal and state environmental laws unless a statutory waiver is justified. The selected
remedy also must be cost effective and use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected interim remedy meets these statutory
requirements.
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5.7.1 Protection of Human Health and the Environment
The selected interim remedy, Alternative 5, protects human health and the environment by
containing contaminated groundwater at the Nebo South plume.
The selected interim remedy provides protection to human health and the environment by
eliminating, reducing, and controlling risk through containment and institutional controls. The
contaminated groundwater will be extracted, contained, and treated to cleanup levels. In
addition, institutional controls will be employed throughout the treatment process to protect
human health and the environment.
5.7.2 Compliance with ARARs
As stated in Section 2.10, remedial action performed under CERCLA must comply with all ARARs.
All alternatives considered for the Nebo South groundwater plume were evaluated on the basis of
the degree to which they comply with these reguirements. The selected interim remedy was found
to comply with all ARARs presented in Tables 2-2 through 2-7.
5.7.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all alternatives being considered with
their overall effectiveness to determine whether the costs are proportional to the effectiveness
achieved. The Marine Corps evaluates the incremental cost of each alternative as compared to
the increased effectiveness of the remedy. The selected interim remedy for groundwater is
containment, extraction, and aboveground treatment for VOC removal and discharge of treated
groundwater back into the aguifer via the percolation ponds. The selected interim remedy
includes extraction wells at the leading edge of the plume and institutional controls.
Based on the current information, the selected interim remedy will provide the best balance of
trade-offs among the alternatives with respect to the nine criteria provided by the NCP to
evaluate the alternatives. The selected interim remedy is more costly than the other
alternatives considered except Alternative 4.
5.7.4 Use of Permanent Solutions to the Maximum Extent Practicable
The DON, EPA, DTSC, and CRWQCB believe that the selected interim remedy is the most appropriate
interim solution for the Nebo South groundwater plume at the present time, and provides the best
balance among the evaluation criteria for the remedial alternatives considered.
5.7.5 Preference for Treatment as a Principal Element
The statutory preference for treatment at the Nebo South plume will be met through treatment of
contaminated groundwater to remove the VOCs.
5.8 Documentation of Significant Change
The permanent (i.e., pump and treat) portion of the interim remedy for the Nebo South plume,
Alternative 5, has not been changed or refined from the Proposed Plan.
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Table 5-1
Nebo South Plume
Maximum Groundwater Concentrations of VOCs and Associated MCLs
Maximum
Groundwater
Concentration Federal MCL California MCL
voc (Ig/L) (Ig/L) (Ig/L)
Contaminants Exceeding Drinking Water Standards (MCLs)
1,2-Dichloroethane (1,2-DCA) 4 5.0 0.5
Tetrachloroethene (PCE) 17 5.0 5.0
Trichloroethene (TCE) 422 5.0 5.0
Contaminants Not Exceeding Drinking Water Standards (MCLs)
Acetone 1 3 610 3
Chloroform 5 1,000
Dibromochloromethane 2 3.0 100
Bromodichloromethane 2 4.0 100
Bromoform 2 1.3 J 100
Methylene Chloride 1 0.4 5.0
1 This chemical is a suspected laboratory contaminant and is not considered representative of
plume conditions.
2 MCL is for trihalomethanes.
3 This chemical does not have a Federal or State primary MCL. Therefore, the PRG is used.
Data also include most recent groundwater sampling results from OHM Remediation Services, Inc.
(OHM 1994, 1995, 1996).
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TABIiE 5-2
Summary of Comparative Analysis - Southern Nebo Plume, NEP-4
MCLB Barstow
Criteria
NEP4-GW-1
Alternatives
NEP4-GW-2
NEP4-GW-3
NEP4-GW-4
NEP4-GW-5
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction and Toxicity, Mobility, or Volume
Short-Term Effectiveness
Implementability
Duration of Remedy
Time to MCLS (years)
Time to Background (years)
Present Cost ($ millions) 20 Years Duration
Remediation to MCLs
remediation to Background
No
No
Low
Low
Low
High
>500
>500
0
0
0
Within Risk Management Range**
NO
Low
Low
Mod
High
>500
>500
0.8
1.3
1.3
Yes
Mod
Mod
Mod
High
>500
>500
2.1
3.3
3.3
Yes
High
High
High
Mod
55
130
10.6
15.1
16.2
Yes
Mod
Mod
Mod
Mod
105
240
3.5
5.5
5.5
ARARs achieved over a very long time only through natural contaminant degradation process.
Alternatives NRF1-GW-2 through NRF-l-GW-5 all result in residual risks that fall within EPAs risk management range of 10 -8 to 10 -4. Cleanup to MCLs would
result in an upper-bound incremental risk of approximately 1 x 10 -5 while cleanup to background (0.5 Ig/L) would result in a risk of approximately 5 x 10 -6.
Alternative NEP4-GW-1:
Alternative NEP4-GW-2:
Alternative NEP4-GW-3:
Alternative NEP4-GW-4:
Alternative NEP4-GW-5:
No action
Institutional controls and groundwater monitoring
Vadose zone source reduction (air sparging/soil vapor extraction)
Groundwater and vadose zone source reduction (air sparging/soil vapor extraction)
and groundwater removal, ex situ treatment, and discharge
Groundwater removal, ex situ treatment, and discharge
ARARs - Applicable or relevant and appropriate reguirements.
MCLs - n Federal and state maximum contaminant levels.
Mod - Moderate.
NA - Not Applicable.
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6.0 RESPONSIVENESS SUMMARY
Two minor verbal questions were received from the public at the public meeting held on November
12, 1997 concerning the proposed actions for OUs 1 and 2. These questions are included on Page
27 of the public meeting transcripts provided in Appendix C, and are reproduced below.
Question. Mr. Chavez: My name is Lewis Chavez. I just like to ask the question, this plume
that we have here, this Yermo, is this around the area of the Silver Valley High School?
Response. Mr. Cox: No. Silver Valley is actually in the opposite direction.
Question. Mr. Chavez: On this side. Okay. So this plume is moving from west to east?
Response. Mr. Cox: Yes.
Comment: Mr. Chavez: Okay. No further questions. Thank you.
No other questions or comments were received on the Proposed Plan at the public meeting or any
other time. The public comments did not result in any changes to the proposed actions for OUs 1
and 2 presented in this ROD.
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7.0 REFERENCES
California Department of Water Resources (DWR). 1967.. Mojave River Ground Water
Basins Investigation. Bulletin No. 84.
Eccles, L.A. 1981. Ground Water Quality Along the Mojave River Near Barstow,
California. 1974-79. U.S. Geological Survey, Water-Resources Investigations
80-109. March.
Hardt, W. 1971. Hydrologic Analysis of Mojave River Basin, Using Electric Analog
Model. U.S. Geological Survey Open-File Report.
Jacobs Engineering Group Inc. (Jacobs). 1991. "Marine Corps Logistics Base, Barstow
California. Final Addendum Sampling and Analysis Plan, Remedial
Investigation/Feasibility Study for Operable Units 1 and 2." November.
Jacobs. 1993a. "Marine Corps Logistics Base, Barstow California. Operable Units 1
and 2 Results of Stage B Groundwater Investigation." Technical Memorandum
0012. Draft. 09 November.
Jacobs. 1993b. Action Memorandum. 12 March.
Jacobs. 1995a. "Marine Corps Logistics Base, Barstow California. Remedial
Investigation / Feasibility Study Remedial Investigation Report for Operable
Units 1 and 2." Draft Final. 31 October.
Jacobs. 1995b. "Marine Corps Logistics Base, Barstow California. Remedial
Investigation / Feasibility Study Feasibility Study for Operable Units 1 and 2."
Draft.
Jacobs. 1995c. "Marine Corps Logistics Base, Barstow California. Engineering
Evaluation / Cost Analysis for Operable Unit 1, Yermo Annex." Draft Final. August.
Jacobs. 1996a. "Marine Corps Logistics Base, Barstow California. Proposed Plan for
Operable Units 1 and 2."
Jacobs. 1996b. "Marine Corps Logistics Base, Barstow California. Feasibility Study for
Operable Units 5 and 6." Draft Final.
Miller, G.A. 1969. "Water Resources of the Marine Corps Supply Center Area,
Barstow, California. U.S. Geological Survey, Water Resources Division. Open-
File Report.
OHM Remediation Services (OHM). 1994. Preliminary Draft Technical Memorandum A.
Project No. 16405. December.
OHM. 1995. Working Draft Technical Memorandum B. Project No. 16405.
OHM. 1996. Working Draft Technical Memorandum B. Project No. 16404. December.
Working Draft Technical Memorandum B. Project No. 16405. December.
OHM. 1996a. Groundwater Monitoring Plan for Operable Unit 1. Draft.
OHM. 1996b. Groundwater Monitoring Plan for Operable Unit 2. Draft.
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Turin, J. 1990. "VLEACH, One-Dimensional Finite Difference Vadose Zone Leaching
Model." Prepared by CH2M Hill, Reading, California, for EPA Region IX. August.
U.S. Environmental Protection Agency (EPA). 1990a. National Oil and Hazardous
substances Pollution Contingency Plan. Final Rule (40 CFR 300). Federal
Register, Volume 55, No. 46. 08 March.
U.S. Geological Survey. (USGS). 1975. Professional Paper 878. "Evaluation of
Groundwater Degradation Resulting from Waste Disposal to Alluviums near
Barstow, California."
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APPENDIX A
DON POSITION ON POC ARARs
Disclaimer: This Appendix represents the views of the Department of the Navy and is not
endorsed or approved by the other FFA signatories.
This appendix discusses the DON's position on the point of compliance (POC) with respect to
groundwater cleanup standards at MCLB Barstow. The DON has agreed, as established in Section
2.8.2 of this ROD, that groundwater cleanup standards will be attained throughout the
contaminant plume, except for immediately below any source area classified as a waste management
unit (WMU) under Title 23 CCR, Division 3, Chapter 15, for which cleanup standards will be
attained at and beyond the edge of the WMU. However, it is the DON's position that the
designation of a POC at the downgradient edge oil source areas not classified at WMUs would be
appropriate and is supported by CERCLA, the NCP, and the administrative record for this ROD.
The DON has decided not to make such designations for non-WMU source areas at this time for
reasons set forth in Section 2.8.2. The following sections provide the basis for the DON's
position.
Regulatory Issues
The regulatory issues in guestion are whether or not the CAOSs at MCLB Barstow addressed in this
ROD are "waste management areas" under specific EPA policy and State regulations relating to the
POC for groundwater cleanup levels, and whether designation of POCs at the CAOSs in this ROD is
appropriate.
The National Contingency Plan
The origins of EPA policy regarding the POC regulatory mechanism can be traced to early EPA RCRA
regulations for groundwater monitoring and corrective action at RCRA regulated units set forth
in 40 CFR Part 264. Subpart F. See 40 CFR Section 264.95 and 47 Fed. Reg. 32273, 3229, July 26,
1982. The cited preamble to these regulations clearly state that groundwater cleanup standard
and corrective action reguirements apply at and beyond the POC at the downgradient edge of
regulated units.
EPA followed the RCRA regulatory model and adopted the POC when it established its CERCLA
groundwater cleanup policy in the 1990 NCP. EPA's CERCLA policy, set forth in the NCP preamble
at 55 Fed. Reg. 8753, March 8, 1990, states that "EPA believes that remediation levels should
generally be attained throughout the contaminated plume, or at and beyond the edge of the waste
management area when the waste is left in place." The NCP preamble on the same page discusses
groundwater cleanup levels and states that "Such restoration may be achieved by attaining MCLs
or non-zero MCLGs in the ground water itself, excluding the area underneath any waste left in
place".
EPA Region IX's position relative to MCLB Barstow is that a POC is only acceptable at
"RCRA-regulated units," and that groundwater cleanup standards must be achieved throughout the
contaminated plume at all other categories of sites. The DON disagrees with EPA Region IX on
this point. The NCP preamble refers to "waste management area" as opposed to RCRA regulated
unit." After all, CERCLA was enacted in large part to support remediation of sites that were
created prior to the effective date of RCRA and is generally intended to address sites that are
not RCRA-regulated units. The NCP preamble clearly indicates that EPA has adopted its early
RCRA POC policy for RCRA regulated units into its CERCLA Groundwater Policy for non-regulated
unit sites.
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The policy reflected in the NCP preamble language guoted above was issued to accommodate both
scenarios, where: 1) complete "clean closure" is selected as a remedial action using the nine
NCP remedy selection criteria and cleanup throughout the contaminant plume is an appropriate
cleanup goal, and 2) the remedy selected under those criteria support leaving some waste in
place and containing it in conjunction with a POC either for cost reasons or technical
feasibility limitations on complete treatment.
EPA's continued support for its POC policy for non-RCRA regulated unit sites is supported by
EPA's 1996 proposed RCRA corrective action rule for RCRA Solid Waste Management Units (SWMUs).
The preamble for that proposed rule states, "For groundwater, program implementors and facility
owners/operators generally set the POC throughout the area of contaminated groundwater or, when
waste is left in place, at and beyond the boundary of the waste management area encompassing the
original source(s) or groundwater contamination." (61 Fed. Reg. 19450, May 1, 1996). This
preamble discussion goes on to reference the NCP preamble POC policy and states EPA's intention
to implement CERCLA and RCRA corrective action in a consistent manner.
A review of past RODs in the ERD-ROD database located many RODs issued or approved by other EPA
regional offices addressing non-RCRA regulated unit sites in which soil contamination/ waste was
left in place (sometimes as residual contamination following treatment of hot spots). The sites
addressed included mining waste impoundments, gravel pits, wood treatment sites, and general
industrial areas impacted by a range of types of repeated contaminant releases. These RODs have
included the establishment of a POC for groundwater at the downgradient edge of the waste
management area where the waste was left in place and reguired compliance with groundwater
cleanup standards at and downgradient from the POC. The EPA regional offices issuing these RODs
have adhered to the EPA POC policy set forth in the NCP preamble and guoted above. The following
RODs offer some examples:
1. Teledyne Wah Chang, USEPA RIO, 6/10/94 (EDR-ID 1000201862)
2. Montana Pole & Treating Plant, USEPA R8, 9/21/93 (EDR-ID 1000396074)
3. Naval Air Station, Ault Field, USEPA RIO, 12/20/93 (EDR-ID 1000141164)
4. Reilly Tar & Chemical, USEPA R5, 9/30/93 (EDR-ID 1000289722)
5. American Crossarm & Conduit, USEPA RIO,6/30/93 (EDR-ID 1000360942)
6. Reilly Tar & Chemical, USEPA R5, 6/30/92 (EDR-ID 1000289722)
In accordance with the NCP preamble, there may be certain circumstances where a plume of
groundwater contamination is caused by releases from several distinct sources that are in close
geographical proximity. In such cases, the most cost-effective groundwater cleanup strategy may
be to address the problem as a whole rather than on a source-by-source basis and to draw a
common point of compliance that encompasses all the sources of release (55 Federal Register
8753, 8 March 1990).
Based on the above provisions, the DON believes that the following designations of points of
compliance for MCLB Barstow WMAs/WMUs would be appropriate:
• CAOCs 15/17, 16, 23 and 35 at the Yermo Annex are contiguous WMAs/WMUs. A common
point of compliance for groundwater cleanup would be defined at the downgradient edge
of these CAOCs, as shown in Figure A-l.
• CAOC 26 at the Yermo Annex is not a contiguous WMA. An individual point of compliance
for groundwater cleanup would be defined at the downgradient edge of this CAOC, as
also shown in Figure A-l.
• Warehouse 2 and CAOC 6 at the Nebo Main Base are not contiguous WMAs. Individual
points of compliance for groundwater cleanup would be defined at the downgradient
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edge of these areas, as shown in Figure A-2.
State Regulations
State of California regulations contain POC provisions that are consistent with the EPA's policy
as set forth in the NCP preamble. These provisions are both potential federal and state ARARs.
The POC at Title 22 CCR 66264.95, which is essentially the same as Title 23 CCR 2550.5, is
defined as a vertical surface, located at the hydraulically downgradient limit of the waste
management area that extends through the uppermost aquifer underlying the regulated unit."
These regulations were promulgated to conform to the RCRA regulated unit POC requirements at 40
CFR Section 264.95. The current language in those provisions was developed to support EPA's
authorization of the State of California's RCRA Subtitle C program in July 1992 (57 Fed. Reg.
32726, July 23, 1992) and was promulgated in order to assure EPA that the State POC provisions
were no less stringent than the Federal requirements set forth in 40 CFR Section 264.95. (Note:
Title 23 CCR Chapter 15 was reviewed as part of the RCRA authorization process because of its
applicability to Class I hazardous waste management units; the relevant language in Title 22 and
Title 23 is identical because of this "overlap" of authorities and because conforming amendments
to both titles were jointly promulgated).
The POC provisions at Title 22 CCR 66264.95 are considered by the DON to be a "relevant and
appropriate" federal ARAR for the CAOCs addressed in this ROD. Significantly, cross-references
from Title 22 CCR Sections 66264.94 to 66264.93 to 66264.92 clearly indicate that both
concentration limits and the POC are integral parts of the RCRA groundwater protection standard.
The POC provisions of Title 22 CCR 66264.95 provide that the water quality standard (including
concentration limits) would apply at the POC and other monitoring locations "determined pursuant
to Section 66264.97". The language of Title 22 CCR 66264.97 provides that in the context of
corrective action such monitoring , locations would be established at appropriate locations to
support evaluation of groundwater compliance with the water quality standard for groundwater
"passing the point of compliance" and downgradient from the POC. See Title 22 CCR Sections
66264.94(d)(4); 66264.97(b)(1)(B)(1), (C)(1), and (D)(1); and 66264.98(n).
The DON also considers the POC provisions of Title 23 CCR Section 2550.5 to be a potential
"applicable" state ARAR for the "closed, abandoned or inactive" WMU CAOCs through Title 23 CCR
Section 2510(g) and to other Title 23 CCR Chapter 15 WMU CAOCs through Article 5. In addition,
they are a potentially "relevant and appropriate" ARAR for non-WMU CAOCs.
In a manner identical to Title 22 CCR 66264.95, cross references from Title 23 CCR Sections
2550.4 to 2550.3 to 2550.2 clearly indicate that both concentration limits and the POC are
integral parts of the groundwater protection standard. The language relating to corrective
action , POC, and monitoring locations set forth in Title 23 CCR Sections 2550.4, 2550.7, and
2550.8 is identical to that referenced above for Title 22 CCR Sections 66264.94, 66264.97, and
66264.98. The POC provisions of Title 23 CCR 2550.5 provide that the water quality standard
would apply at the POC and other monitoring locations "determined pursuant to Section 1550.7".
Consistent with Title 22 CCR Section 66264.97, Title 23 CCR Section 1550.7 provides that, in the
context of corrective action,, monitoring locations would be established at appropriate
locations to support evaluation of groundwater compliance with the water quality standard for
groundwater "passing the point of compliance" and downgradient from the POC.
The current provisions in Title 23 CCR Chapter 15 relating to the POC and corrective action
requirements were promulgated in 1991 amendments to the provisions of "Article 5. Water Quality
Monitoring and Response Programs for Waste Management Units". A December 17, 1990 "Statement of
Reasons" (SOR) discusses the State's intent and rationale for amending these regulations.
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The language in the repealed POC provisions at the former Section 2553(a) had stated: "The
points of compliance" or "compliance points" are the points at which water guality protection
standards shall be applied, and at which monitoring shall be conducted. They describe a surface
usually located hydraulically downgradient of each waste management unit, or cluster of
contiguous waste management units, in both saturated and unsaturated zones." There was no
language in the repealed regulations implying that the water guality protection standard might
apply upgradient of the POC.
The amended POC language in Section 2550(a) states: "The point of compliance is a vertical
surface located at the hydraulically downgradient limit of the waste management unit that
extends through the uppermost aguifer underlying the unit. For each Class I waste management
unit, the regional board shall specify monitoring points at the point of compliance and
additional monitoring points at locations determined pursuant to section 2550.7 of this article
at which the water guality protection standard under section 2550.2 of this article applies and
at which monitoring shall be conducted."
In the SOR for these amendments the SWRCB explains that these amendments were intended to
conform to and demonstrate compliance/eguivalency with the RCRA POC provisions at 40 CFR Section
264.95. See discussion of "Factual Basis" for amendments at Section 2550.5 and the response to
the first comment on page 134 of the SOR and the discussion of "Factual Basis" for amendments at
Section 2550.5(a) on page 137 of the SOR. There is no indication that there was any SWRCB
intent to be more stringent than 40 CFR Section 264.95 by reguiring compliance with the water
guality protection standard upgradient of the POC. To the contrary, the SOR very clearly states
that it was the intent of the amendments to clarity an ambiguity under the old regulations that
could allow placement of the POC further downgradient than the downgradient edge of the waste
management area. Those regulations were less stringent than RCRA reguirements and would have
jeopardized authorization of California's hazardous waste management program under RCRA (Title
23 CCR Class I facilities are hazardous waste facilities).
The SOR explains that the reason for adding the "additional monitoring locations" language to
Section 2550.5(a) was to clarify that downgradient monitoring locations allowed under the
repealed regulations would continue to be acceptable so long as the POC was located at the
downgradient edge of the waste management area in order to ensure compliance with minimum RCRA
reguirements. This "combined" approach is explained in the SOR in the response to the third and
fifth comments in the discussion of comments on Section 2550.5(a).
The SOR discussion of corrective action reguirements now found at Title 23 CCR Section 2550.10
is also relevant to interpretation of the POC provisions in Title 23 CCR Section 2550.10. It
has been argued by SWRCB counsel assigned to MCLB Barstow matters that the current language in
Title 23 CCR Section 2550.10(c) reguiring corrective action "throughout the zone affected by the
release" supports the interpretation that the water guality protection standard applies
upgradient of the POC. DTSC staff assigned to MCLB Barstow matters has made similar
interpretations of the identical provisions of Title 22 CCR Section 66264.100(c). The State's
interpretations are not consistent with other provisions in Title 23 CCR Chapter 15, Article 5,
and the eguivalent provisions of Title 22 CCR discussed above or with the intent of the SWRCB as
set forth in the SOR.
The SOR states that Title 23 CCR Section 1550.10 is based upon RCRA groundwater corrective
action provisions at 40 CFR Section 264.100. See discussion beginning on page 306 of the SOR.
The language "throughout the zone affected by the release" was added to the final rule as a
result of comments received on the proposed rule relating to the Board's authority to reguire
corrective action beyond a facility boundary when the "affected zone" of a release extends
beyond that boundary. The federal RCRA regulations made such corrective action conditional upon
receipt of permission from the adjoining landowner. In the SOR, the Board maintained that it
-------
had authority to mandate such corrective action without such consent. In responding to comments
on Subsection 2550.10(f) on page 314 of the SOR, the Board states: "Rather than continue to
separate the reguirements to implement corrective action measures both at the point of
compliance and beyond the point of compliance, Subsection (c) has been rewritten to reguire
corrective action "throughout the zone affected by the release" and Subsection (e) has been
deleted." The Board's intent is unmistakably clear.
It is the DON's position that the POC provisions of Title 22 CCR Section 66264.95 are a
"relevant and appropriate" federal ARAR, taking precedence over the eguivalent potential
"applicable or relevant and appropriate" Title 23 CCR Section 2550.5 state ARAR, for both WMUs
as well as VOC-contaminated vadose zone source areas not classified as WMUs in Section 2.8.2 of
this ROD. The Title 22 CCR Section 66264.95 provision is an integral component of the water
guality protection standard in Title 22 CCR Section 66264.92.
It is the DON's understanding that the regulatory agencies concur that Title 23 CCR Section
2550.5 is applicable to Title 23 CCR Chapter 15 WMUs including "closed, abandoned or inactive"
waste management units through Title 23 CCR Section 2510(g), but disagree that either Title 23
CCR Section 2550.5 or Title 22 CCR Section 66264.95 constitute ARARs for VOC-contaminated vadose
zone areas that are not classified as WMUs.
The DON's position concerning these regulations is consistent with the EPA's position discussed
previously regarding POC for waste left in place as set forth in the NCP preamble (55 Federal
Register 8753, March 8, 1990). In addition, the DON considers the POC provisions of Title 23
CCR Section 2550.5 and Title 22 CCR Section 66264.95 to apply as ARARs to both groundwater and
vadose zone cleanup standards.
It is also the DON's position that the potential "relevant and appropriate" provisions of the
state point of compliance regulations at Title 22 CCR 66264.95(b)(2) and Title 23 CCR 2550.5(b),
which describe an approach to a "common point of compliance" for contiguous regulated units and
WMUs, are consistent with the NCP approach described previously for sources in close proximity.
Title 22 CFR Section 66264.95(b)(2) provides as follows:
"If the facility contains contiguous regulated units, and monitoring along a shared
boundary would impair the integrity of a containment or structural feature of any of
the units, the WMA may be described as an imaginary line along the outer boundary of
the contiguous regulated units. This provision only applies to contiguous regulated
units that have operated or have received all permits necessary for construction and
operation before July 1, 1991."
Title 23 CCR 2550.5(b) contains nearly identical language for WMUs.
Conclusion
Based on the DON's agreement to comply with groundwater cleanup standards throughout the
contaminant plume for non-WMU sources, it does not appear that the POC ARAR issue is significant
in terms of any practical effect for this ROD. Complying with the groundwater cleanup standards
throughout the plume will be a conservative means of demonstrating attainment at the POC.
However, the DON is addressing the POC issue with an "agree to disagree" compromise with the
regulatory agencies. Under this compromise, the DON reserves the right to propose POCs for
non-WMU areas in the future as provided in Section 2.8.2 of this ROD. In addition, the DON's
agreement to the RAO for non-WMUs under this ROD shall not be construed as establishing
precedent for any other DON or DOD sites.
-------
Appendix B
Administrative Record Index
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
NOTIFICATION OF CHANGE IN THE DEPARTMENT OF TOXIC
SUBSTANCES CONTROL'S REMEDIAL PROJECT MANAGER
ADDRESSEE
MARINE CORPS LOGISTICS BASE
OP UNIT
1,2,3,4,5,
CORRESPONDENCE, TRIP REPO
TRIP REPORT FOR SITE VISIT AT DTSC LONG BEACH RE TECH MEMO TM,
0008 GROUNDWATER REMEDIATION ASSESSMENT
SOUTHWEST DIVISION
REPORT, GROUNDWATER
GROUNDWATER OCCURRENCE AND QUALITY (DWR BULLETIN 106-1)
AND GEOLOGIC, HYDROLOGIC AND WATER QUALITY STUDY RESULTING
IN DELINEATION Of 55 GROUNDWATER BASINS
US DEPT OF WATER RESOURCES
PUBLIC RELEASE
REPORT, GROUNDWATER
BARSTOW GROUNDWATER STUDY, CONCLUDES THAT THE
GROUNDWATER BELOW THE WASTE DISCHARGES IS STILL GRADED
AND EXTENDS 1 MILE FURTHER DOWNSTREAM CONDUCTED FROM MAY
CALIF DEPT OF PUBLIC HEALTH
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, GROUNDWATER
WATER RESOURCES OF THE MARINE CORPS SUPPLY CENTER AREA
GROUNDWATER IN STORAGE IS THE ONLY DEPENDABLE SOURCE OF
WATER AT MCLB
US DEPT OF INTERIOR GEOLOGICAL
SURVEY WATER RESOURCES DIV
REGIONAL WATER QUALITY CONTROL
BOARD
REGULATION, CITY
WASTE DISCHARGE REQUIREMENTS FOR THE CITY OF BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, GROUNDWATER
GROUNDWATER STUDY TO IDENTIFY CURRENT CONDITIONS AND
UPDATE INFORMATION PRESENTED IN THE 1966 REPORT
CALIF DEPT OF HEALTH
PUBLIC RELEASE
REPORT, GROUNDWATER
GROUNDWATER DEGRADATION STUDY IN THE BARSTOW AREA
DESCRIBING FINDINGS ON THEIR PROPOSAL TO DO THE SUBJECT
STUDY
NAVAL FACILITIES ENGINEERING COMMAND
US DEPT OF INTERIOR
STUDY FOR DETERMINING THE FEASIBILITY OF CONNECTING
DOMESTIC AND INDUSTRIAL WASTE FLOW FROM THE SUPPLY CENTER
TO THE MUNICIPAL SEWERAGE SERVICE, MCLB BARSTOW
BROWN AND CALDWELL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, NFEC
BASE REVIEW OF REGIONAL WATER QUALITY CONTROL BOARDS
WASTE DISCHARGE REQUIREMENTS FOR MCLB
NAVAL FACILITIES ENGINEERING COMMAND
US ENVIRONMENTAL PROTECTION
AGENCY
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
GUIDANCE, RWQCB
DATE
1/10/74
SUBJECT
REVISED WASTE DISCHARGE REQUIREMENTS FOR MARINE CORPS
SUPPLY CENTER, YERMO BARSTOW MCLB MEETING OF JANUARY 24,
1974, NO. 6-74-8
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
ENFORCEMENT, BOARD ORDER
MONITORING REPORTING PROGRAM, #74-8 S 74-9 FOR NEBO AND
YERMO ANNEX, RESULTS OF TREATED DOMESTIC WASTEWATER
EFFLUENT, ETC, MONITORING EFFORT
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
PUBLIC COMMUNICATION, NEWS
ARTICLE
60 YEARS OF POLLUTION THREATENS DESERTS MOJAVE RIVER
L A TIMES
PUBLIC RELEASE
REPORT, GROUNDWATER
EVALUATION OF GROUNDWATER DEGRADATION RESULTING FROM
WASTE DISPOSAL TO ALLUVIUM AND DISCUSSES NATURE AND EXTENT
OF CONTAMINATION
US DEPT OF THE INTERIOR
PUBLIC RELEASE
REPORT, INSPECTION
ON-SITE INSPECTION OF YERMO AND NEBO WASTEWATER TREATMENT
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, INSPECTION
ON-SITE INSPECTION OF YERMO AND NEBO WASTEWATER TREATMENT
AND DISPOSAL PLANTS
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, COMPLIANCE
MONTHLY SEWAGE EFFLUENT TEST ANALYSIS RESULTS IN
COMPLIANCE WITH BOARD ORDER NOS 6-74-8 AND 6-74-9
NAVAL FACILITIES ENGINEERING COMMAND
REGIONAL WATER QUALITY CONTROL
BOARD
ENFORCEMENT, BOARD ORDER
BOARD ORDER NO 77-1, FOR CLEAN UP AND ABATEMENT AND
RESCISSION OF WASTE DISCHARGE REQUIREMENTS UNDER BOARD
ORDERS OF 6-74-9, 6-74-8, AND VIOLATION OF BOARD ORDER NOS 6-
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
BOARD ORDER #6-77-50
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT SLUDGE
DATE
5/1/77
INDUSTRIAL WASTE SLUDGE DISPOSAL AT NAVY AND MARINE CORPS
ACTIVITIES
NFEC ENVIRONMENTAL PROTECTION
SUPPORT SERVICE
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT WASTEWATER
MONTHLY DOMESTIC AND INDUSTRIAL WASTEWATER MONITORING
REPORTS IN COMPLIANCE WITH BOARD ORDER NOS 6-74-8 AND 6-74-9
NAVAL FACILITIES ENGINEERING COMMAND
REGIONAL WATER QUALITY CONTROL
BOARD
ENFORCEMENT, BOARD ORDER
ORDER NO 6-78-14 WASTE DISCHARGE REQUIRED SOLID WASTE
DISPOSAL SITE
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
BOARD ORDER LAHONTAN REGION, REVISED WASTE DISCHARGE
REQUIREMENTS NO 6-78-73
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
APPROVAL OF A 1-TIME DISCHARGE OF INDUSTRIAL EFFLUENT FROM
NEBO ANNEX SANITATION FACILITY INTO OXIDATION POND #2
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, GROUNDWATER
REVISED MONITORING AND REPORTING PROGRAMS FOR NEBO AND
YERMO ANNEX, REVISED 10/16/80 RESULTS OF FLOW MONITORING
EFFORT
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, GROUNDWATER
RESULTS OF GROUNDWATER QUALITY ALONG THE MOJAVE RIVER
NEAR BARSTOW FROM 1974-1979, DEGRADATION OF GROUNDWATER
QUALITY IS ATTRIBUTED TO WASTEWATER DISCHARGE PRACTICES
US DEPT OF THE INTERIOR WITH REGIONAL
WATER QUALITY CONTROL BOARD
PUBLIC RELEASE
PERMIT, HAZARDOUS WASTE
DISPOSAL OF TOXIC OR HAZARDOUS WASTE BY UNDERGROUND
INJECTION WALLS, ENCLOSING SITE INSPECTION FORMS
MARINE CORPS LOGISTICS BASE
NFEC f, MCLB
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
DATE
6/26/81
UNDERGROUND INJECTION CONTROL PROGRAM, ADVISING DELETION
OF MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
OP UNIT
1,2
REPORT, WASTEWATER
DESCRIBES FURNISHING WASTEWATER TREATMENT PLANT
CLASSIFICATION
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
ENFORCEMENT, NOTICE
NEBO AND YERMO FACILITIES VIOLATIONS OF EFFLUENT LIMITATIONS
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
ENFORCEMENT, BOARD ORDER
ACTIONS IN RESPONSE TO VIOLATIONS OF INDUSTRIAL WASTEWATER
DISCHARGE REQUIREMENTS AT BARSTOW MCLB YERMO ANNEX
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, WASTEWATER
MONTHLY DOMESTIC AND INDUSTRIAL WASTEWATER MONITORING
REPORTS FROM 1979 THROUGH 1982
MARINE CORPS LOGISTICS BASE
MCLB 5 RWQCB
REPORT, WASTEWATER
REVISED WASTE DISCHARGE REQUIREMENTS FOR INDUSTRIAL
WASTEWATER
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, INSPECTION
COMPLIANCE INSPECTION OF NEBO AND YERMO INDUSTRIAL
WASTEWATER, MCLB, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
COMPLIANCE INSPECTIONS OF NEBO S YERMO INDUSTRIAL
WASTEWATER FACILITIES, BOARD ORDERS 6-83-18 AND 6-83-20
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
CONCEPTUAL STUDY AND REPORT FOR WASTEWATER RECYCLING AT
THE EXISTING VEHICLE WASHDOWN/STREAM RACK AREA ADJACENT TO
BUILDING 573
INTERNATIONAL CONSULTING ENGINEERS,
INC
MARINE CORPS LOGISTICS BASE
MEETING NOTES
VEGETATION AND TREE REMOVAL AT NEBO DOMESTIC WASTEWATER
PERCOLATION PONDS, NOTES FROM THE 9/15/83 MEETING WITH DTS
DISCUSSING VEGETATION CONTROL TECHNIQUES
MARINE CORPS LOGISTICS BASE
DEPT OF HEALTH SERVICES
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PERMIT WASTE
DATE
6/19/84
UNDERGROUND CONTAINERS, HAZARDOUS SUBSTANCE STORAGE
STATEMENT
AUTHOR
MARINE CORPS LOGISTICS BASE
ADDRESSEE
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, DRINKING WATER
AB 1803 SAMPLING AND ANALYSIS OF DRINKING WATER RESULTS FROM
6 STATEWELLS AROUND MCLB AREA AND WELL CONSTRUCTION DATE
SOUTHERN CALIFORNIA WATER CO
SAN BERNARDINO COUNTY
PLAN, WASTE
1 4 - 0042
HAZARDOUS SUBSTANCE MANAGEMENT PLAN AT MCLB TO IMPLEMENT
APPLICABLE REGULATORY REQUIREMENTS AND TO PROVIDE
INSTRUCTIONS FOR THE SAFE HANDLING OF HAZARDOUS MATERIALS
J B YOUNG S, ASSOCIATES
NFEC S, MCLB
REPORT, GROUNDWATER
AB 1803 SAMPLE ANALYTICAL RESULTS FOR GROUNDWATER ANALYSES
FROM STATE OWNED WELLS AROUND MCLB AREA AND WELL
CONSTRUCTION DATE FOR THESE 7 WELLS
STONER LABORATORIES
YERMO WATER COMPANY
PERMIT, WASTE
HAZARDOUS WASTE, FACILITY PERMIT ISSUED BY DTSC, US EPA ID#
CA8170090023, YERMO ANNEX
MARINE CORPS LOGISTICS BASE
DEPT OF HEALTH SERVICES
REPORT, GROUNDWATER
AB 1803 SAMPLE RESULTS FOR GROUNDWATER, AND WELL
CONSTRUCTION DATE
CALIFORNIA WATER LABS INC
MARINE CORPS LOGISTICS BASE
REPORT, GROUNDWATER
STAFF REPORT ON THE PROGRESS BEING MADE BY THE CITY OF
BARSTOW TO CLEAN UP THE POLLUTED GROUNDWATER LOCATED IN
THE MOJAVE RIVERBED
REGIONAL WATER QUALITY CONTROL
BOARD
PUBLIC RELEASE
REPORT, INSPECTION
COMPLIANCE INSPECTION REPORT (ORDER NO 6-78-14) YERMO SOLID
WASTE DISPOSAL SITE
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENVIRONMENTAL SAMPLE ANALYSIS AND RESULTS FOR SOILS AND
GROUNDWATER AT SITE 2, 11, 18, S, 21
A L BURKE ENGINEERS INC
NAVAL FACILITIES ENGINEERING
COMMAND
GUIDANCE, RWQCB
UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX
SOLID WASTE DISPOSAL SITE, BOARD ORDER NO 6-78-14
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
ENFORCEMENT BOARD ORDER
POLICY, MCLB
ENFORCEMENT BOARD ORDER
REPORT, INSPECTION
DATE
7/19/85
UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX
SOLID WASTE DISPOSAL SITE, BOARD CODE NO 6-78-14
UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX
SOLID WASTE DISPOSAL SITE, BOARD ORDER NO 6-85-119
UPDATE OF WASTE DISCHARGE REQUIREMENTS FOR YERMO ANNEX
SOLID WASTE DISPOSAL SITE, BOARD ORDER NO 6-78-14
COMPLIANCE INSPECTION REPORT GROUNDWATER ANNEXES FOR
INDUSTRIAL WASTE DISCHARGE
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
CORRESPONDENCE,
MEMORANDUM
REPORT, ASSESSMENT
REPORT, GROUNDWATER
REPORT, CONFIRMATION
REPORT, CONFIRMATION
REPORT, CONFIRMATION
NAVAL ASSESSMENT 5 CONTROL OF INSTALLATION POLLUTANTS
(NACIP) PROGRAM
PHASE 2, STAGE 2 DRAFT FINAL REPORT MEETING f, PRELIMINARY
ASSESSMENT SUMMARY
MEMORANDUM RE GROUNDWATER QUALITY, NAVAL ASSESSMENT AND
CONTROL OF INSTALLATION POLLUTANTS AT MCLB AND MEETING
MINUTES HELD ON 12/17/85
CONFIRMATION STUDY FOR CAOC 11 (VOL 3 OF 7)
CONFIRMATION STUDY FOR CAOC 2 (VOL 2 OF 7)
CONFIRMATION STUDY FOR CAOC 18 (VOL 4 OF 7)
REGIONAL WATER QUALITY CONTROL
BOARD
US ENVIRONMENTAL PROTECTION AGENCY
REGIONAL WATER QUALITY CONTROL
BOARD
A L BURKE ENGINEERS INC
A L BURKE ENGINEERS INC
A L BURKE ENGINEERS INC
NAVAL FACILITIES ENGINEERING
COMMAND
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
NFEC 5 MCLB
NFEC S, MCLB
NFEC S MCLB
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT CONFIRMATION
REPORT NPL RANKING
SITE RANKING FOR INCLUSION IN NATIONAL PRIORITIES LIST WITH
BACKGROUND INFORMATION
AUTHOR
A L BURKE ENGINEERS INC
US ENVIRONMENTAL PROTECTION AGENCY
ADDRESSEE
NFEC S, MCLB
PUBLIC RELEASE
OP UNIT
1
1
WASTE CATEGORIES GENERATED AND WASTE STREAM INVENTORY
DATED 03/25/86
MARINE CORPS LOGISTICS BASE
DEPT OF HEALTH SERVICES
REPORT, COMPLIANCE
NONSUBMITTAL OF QUARTERLY REPORTS REQUIRED BY MONITORING
AND REPORTING PROGRAM BOARD ORDER NO 6-85-119 FOR USMC
YERMO CLASS III LANDFILL
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
GUIDANCE, EPA
DRAFT GUIDANCE ON REMEDIAL ACTIONS FOR CONTAMINATED
GROUNDWATER
US ENVIRONMENTAL PROTECTION AGENCY
PUBLIC RELEASE
GUIDANCE, EPA
REGULATION, ACT
SUPERFUND PUBLIC HEALTH EVALUATION MANUAL
TOXIC PITS CLEANUP ACT, CLOSURE REQUIREMENTS OF UNAPPROVED
SURFACE IMPOUNDMENTS, ETC
US ENVIRONMENTAL PROTECTION AGENCY
REGIONAL WATER QUALITY CONTROL
BOARD
PUBLIC RELEASE
MARINE CORPS LOGISTICS BASE
REPORT, HYDROGEOLOGICAL
HYDROGEOLOGICAL ASSESSMENT REPORT FOR INDUSTRIAL WASTE
SURFACE IMPOUNDMENTS (2 OF 2)
ALMGREN f, KOPTIONAK INC
NFEC S MCLB
TENTATIVE UPDATED WASTE DISCHARGE REQUIREMENTS FOR MCLB,
NEBO INDUSTRIAL WASTE TREATMENT PLANT, ANNOUNCEMENT OF A
02/10/87 WORKSHOP AND 03/12/87 RWQCB BOARD MEETING
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, INSPECTION
RCRA COMPLIANCE EVALUATION INSPECTION REPORT, CONTAINS A
SUMMARY OF MANAGEMENT PRACTICES, POTENTIAL VIOLATIONS, ETC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
GUIDANCE, EPA
DATE
3/1/87
DATA QUALITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES
DEVELOPMENT PROCESS
AUTHOR
US ENVIRONMENTAL PROTECTION AGENCY
ADDRESSEE
PUBLIC RELEASE
OP UNIT
1,2,3,4,5,6,7
GUIDANCE, EPA
DATA QUALITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES,
EXAMPLE SCENARIO (EPA) 54O/G-87 (004 )
US ENVIRONMENTAL PROTECTION AGENCY
PUBLIC RELEASE
ENFORCEMENT, BOARD ORDER
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6-87-36, NEBO ANNEX
DOMESTIC WASTEWATER TREATMENT PLANT)
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6-87-37, YERMO ANNEX
DOMESTIC WASTEWATER TREATMENT PLANT)
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6-87-38, NEBO ANNEX
INDUSTRIAL WASTEWATER TREATMENT PLANT) FACT SHEET
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
UPDATED WASTE DISCHARGE REQUIREMENTS AND MONITORING AND
REPORTING PROGRAM (BOARD ORDER NO 6-87-39, YERMO ANNEX
INDUSTRIAL WASTEWATER TREATMENT PLANT) FACT SHEET
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER
WASTE DISCHARGE REQUIREMENTS FOR MCLB YERMO INDUSTRIAL
TREAT PLANT UPDATING BOARD ORDER #6-87-39
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, GROUNDWATER
INSTALLATION OF 2 GROUNDWATER WELLS AT YERMO ANNEX FOR
MONITORING UPGRADIENT AND DOWNGRADIENT OF THE SOLID WASTE
DISPOSAL SITE (1 OF 2)
A L BURKE ENGINEERS INC
MARINE CORPS LOGISTICS BASE
REPORT, GROUNDWATER
INSTALLATION OF 2 GROUNDWATER MONITORING WELLS FOR YERMO
ANNEX, DETAILS OF WELL INSTALLATION PROCEDURES IMPLEMENTED
AND PROCEDURES FOR OPERATION AND MAINTENANCE OF
A L BURKE ENGINEERS INC
MARINE CORPS LOGISTICS BASE
REPORT, WASTEWATER
RESULTS OF LABORATORY ANALYSIS AND LAB MONTHLY REPORTS ON
THE DOMESTIC AND INDUSTRIAL WASTEWATER TREATMENT PLANT
MARINE CORPS LOGISTICS BASE
NAVAL FACILITIES ENGINEERING
COMMAND
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CAT - DOCt SUBJECT
ADDRESSEE
REPORT, WASTEWATER 11/13/87
1 4 - 0039 DOMESTIC WASTEWATER OXIDATION PONDS STUDY TO EVALUATE THE
CAUSES OF HIGH MINERAL SALT CONTENT IN THE EFFLUENT OF THE
DOMESTIC WASTEWATER TREATMENT PLANTS AT NEBO AND YERMO
AQUA RESOURCES INC
NFEC 5 MCLB
PLAN, MASTER
1 4 - 0038 MASTER PLAN UPDATE MCLB, CALIFORNIA DRAFT, 1988. SUMMARY OF
ONE FULL YEARS STUDY OF EXISTING OPERATIONS AND FACILITIES,
TO EVALUATE THE CONTINUED EXISTENCE OF MCLB
MIRALLES ASSOCIATES IN ASSOCIATION
WITH CH2M HILL. CANNETT S, FLEMING
MARINE CORPS LOGISTICS BASE 1,2,3,4,5,
REPORT, INSPECTION
11 1 - 0032 RCRA INSPECTION REPORT INSPECTION OF RCRA FACILITY
CONDUCTED BY USEPA AT MCLB, BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
1 7 - 0005 WATER SAMPLE TEST RESULTS, LEVEL OF CONTAMINATE METALS
PRESENT IN THE NEBO AND YERMO WASTEWATER TREATMENT
FACILITY PONDS
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
REPORT, GROUNDWATER
11 1 - 0005 POLLUTED GROUNDWATER NEAR BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
TOPEKA AND SANTA FE RAIL WAY
COMPANY
NAVAL FACILITIES ENGINEERING COMMAND PUBLIC RELEASE
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
CORRESPONDENCE, REQUEST 6/14/E
ENFORCEMENT, NOTICE
11 1 - 0006 REQUEST FOR SUBMITTAL OF GROUNDWATER INVESTIGATION PLAN BY
THE CITY OF BARSTOW AND ATCHISON, TOPEKA S SANTA FE RAILWAYS
11 1 - 0013 SYSTEM DEFICIENCY RECORD (DEFICIENCIES IN DOMESTIC WATER
SUPPLY FACILITIES)
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES CONTROL
TOPEKA AND SANTA FE RAILWAY
COMPANY
REPORT, WASTEWATER
1 4 - 0054 DOMESTIC WASTEWATER OXIDATION PONDS STUDY-CHAPTER 1 ONLY,
TO EVALUATE THE CAUSES OF HIGH MINERAL SALT CONTENT IN THE
EFFLUENT OF THE DOMESTIC WASTEWATER OXIDATION PONDS
AQUA RESOURCES INC
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
GUIDANCE EPA
GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND
FEASIBILITY STUDIES UNDER CERCLA-INTERIM FINAL
AUTHOR ADDRESSEE
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
OP UNIT
1,2,3,4,5,
REPORT, GROUNDWATER
BASE LANDFILL SAMPLING, GROUNDWATER SAMPLING PERFORMED AT
TWO MONITORING WELLS MW-1 AND MW-2
MONTGOMERY LABORATORIES
REPORT, POTABLE WATER 11/11/E
SAMPLE AND ANALYZE MONITORING AND POTABLE WATER WELLS
(REPORT OF ANALYTICAL DATA) AT YERMO ANNEX
REPORT, GROUNDWATER
RESULTS OF GROUNDWATER ANALYSIS, PERFORMED VOA, METALS,
AND OTHER ANALYSIS PERFORMED ON SAMPLE FROM AGATE 4,5, 6
SOUTHERN CALIFORNIA WATER CO
MARINE CORPS LOGISTICS BASE
DRAFT WASTE MINIMIZATION ASSESSMENT OF BUILDING 537 REPORT,
BASED ON QUALITATIVE REVIEW OF BUILDING OPERATIONS AND THE
WASTEWATER TREATMENT SYSTEM CAPABILITY
BATTELLE MEMORIAL INSTITUTE
MARINE CORPS LOGISTICS BASE
2/9/89 1 4 - 0015
SOILS INVESTIGATION, PAINT COMBAT VEHICLE MAINTENANCE SHOP,
SUPPLEMENT TO THE 05/27/88 REPORT
BENTON ENGINEERING INC
ATKINSON, JOHNSON, S SPURPIER, INC
SAMPLING VISIT REPORT, CONDUCTED ON MARCH 7-8, 1989 AT THE
INDUSTRIAL WASTEWATER TREATMENT PLANTS LOCATED IN YERMO
AND NEBO ANNEXES, MCLB, BARSTOW
A KEARNEY, INC S, DPRA INC
US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, INSPECTION
4/15/89 1 4 - 0041
RCRA INSPECTION REPORT AT NEBO ANNEX MCLS, BARSTOW BY EPA
REG 9 CONDUCTED ON MARCH 9-10, 1989
SCIENCE APPLICATION INTERNATIONAL MARINE CORPS LOGISTICS BASE
CORP
REMOVAL OF VOLATILE ORGANIC CONTAMINANTS IN YERMO DRINKING
WATER SYSTEM
MARINE CORPS LOGISTICS BASE
NFEC 5 MCLD
PUBLIC COMMUNICATION, PRES 7/14/89
RELEASE
9 5 - 0034 "GEORGE, BARSTOW BASES PUT ON EPA HAZARD LIST"
SAN BERNARDINO SUN
PUBLIC RELEASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CAT - DOCt SUBJECT
ENFORCEMENT, NOTICE
VIOLATION OF MONITORING ORGANIC CHEMICAL FOR THE WATER
SYSTEM
DEPT Of TOXIC SUBSTANCES CONTROL
MARINE CORPS LOGISTICS BASE
ENFORCEMENT, BOARD ORDER 8/28/89 11 1 - 0017
NOTICE OF VIOLATIONS (BOARD ORDER NO 6-87-38 f, 6-87-39, NEBO
AND YERMO INDUSTRIAL WASTEWATER TREATMENT PLANTS).
REQUEST FOR SUBMITTAL OF REPORT THAT HAVE NOT BEEN
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE
SOLID WASTE ASSESSMENT TEST PERFORMANCE FOR YERMO SOLID
WASTE DISPOSAL SITE, MCLB AND COMMENTS ON THE DUE DATES SET
IN THE RWQCB'S CORRESPONDENCE DATED 05/15/89
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
REPORT, GROUNDWATER
GROUNDWATER INVENTORY OF THE MOJAVE RIVER BASIN PRESENTED
TO THE TECHNICAL ADVISORY COMMITTEE
SUBSURFACE SURVEYS
PUBLIC RELEASE
REPORT, GROUNDWATER
1 7 - 0008 RESULTS OF GROUNDWATER ANALYSIS, 3 WELLS SAMPLED AND
ANALYZED FOR ATRAZINE, SIMAZINE EDB D8CP, VGA
NAVY PUBLIC WORKS CENTER
INTERIM REPORT - MOJAVE RIVER BASIN WATER INVENTORY
INVESTIGATION, NORTHWEST OF HELENDALE, TO DETERMINE DEPTH
OF WATER TABLE WHERE WELL CONTROL IS SPARSE
SUBSURFACE SURVEYS
MOJAVE WATER AGENCY
REPORT, COMPLIANCE
NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL
BOARD
MONITORING REPORT FOR THE GRANULAR CARBON ABSORPTION
UNITS
CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, WASTE MINIMIZATION 11/1/89 1 4 - 0019
INDUSTRIAL WASTE MINIMIZATION STRATEGY AND OPTIONS TO
EVENTUALLY MODIFY OR ELIMINATE THE INDUSTRIAL WASTE
TREATMENT PLANT OPERATIONS
NAVAL CIVIL ENGINEERING LABORATORY MARINE CORPS LOGISTICS BASE
1,2,3,4
PUBLIC COMMUNICATION, PRES 11/24/89
RELEASE
"MARINE BASE ON FINAL SUPERFUND LIST" POLLUTED GROUNDWATER
SOIL SLATED FOR CLEAN UP
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
MARCH 30, 1995
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
PLAN, GROUNDWATER 12/1/89
PUBLIC COMMUNICATION, PRES 12/1/89
RELEASE
PLAN, RUES
CAT - DOCt SUBJECT
GROUNDWATER MONITORING PLAN WITH ANALYTICAL DATA
9 5 - 0036 "CONTAMINATION CLEAN UP PROGRESSES" CARBON TREATMENT OF
DRINKING WATER 5 LONG TERM CLEAN UP MEASURES CURRENTLY
UNDER STUDY FOR MCLB, BARSTOW
4 1 - 0001 SUMMARY REPORT REMEDIAL INVESTIGATION/FEASIBILITY STUDY
WORK PLAN, MCLB, BARSTOW
2 2 - 0004 ANALYTICAL RESULTS, OPERATION OF THE CALGON CARBON MODEL 10
UNITS INSTALLED ON WELLS NOs 3 AND 5
2/26/90 1 7 - 0011 WASTEWATER ANALYSIS RESULTS, VOAS, INORGANICS, ETC
PLAN, SAMPLING S ANALYSIS 3/1/90 4 2 - 0011 SAMPLING PUBLIC AND PRIVATE DRINKING WATER WELLS, YERMO AREA
REPORT, GROUNDWATER
PUBLIC COMMUNICATION, PRES 3/17/90
RELEASE
REPORT, GROUNDWATER
3/1/90 1 4 - 0023 FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW, APPENDICES A THROUGH H (2 OF 4)
REVIEW OF THE WORKPLAN FOR SAMPLING PUBLIC/PRIVATE DRINKING
WATER WELLS AROUND MCLB, BARSTOW
"YERMO WELLS TO BE TESTED FOR GROUNDWATER QUALITY"
FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW, 4 NEW GROUNDWATER WELLS WERE INSTALLED AND
EXTENSIVE LAB ANALYSIS WAS CONDUCTED (1 OF 4)
AUTHOR
JACOBS ENGINEERING GROUP INC
MCLB BARSTOW TODAY
JACOBS ENGINEERING GROUP INC
CALGON CARBON CORPORATION
JACOBS ENGINEERING GROUP INC
GERAGHTY S, MILLER INC
US EPA, DTSC, S RWQCB
MCLB BARSTOW TODAY
GERAGHTY 5 MILLER INC
ADDRESSEE OP UNIT
NFEC, MCLB, RWQCB, DTSC, S, US EPA 1,2
PUBLIC RELEASE 1,2
NFEC, MCLB, RWQCB, DTSC, S, US EPA 1,2
NAVAL FACILITIES ENGINEERING
COMMAND
MARINE CORPS LOGISTICS BASE
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
ATCHISON, TOPEKA 5 SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
MARINE CORPS LOGISTICS BASE
PUBLIC RELEASE
ATCHISON, TOPEKA 5 SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, GROUNDWATER
CAT - DOCt SUBJECT
3/19/90 1 4 - 0024 FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW, APPENDIX I (3 OF 4)
AUTHOR
GERAGHTY S, MILLER INC
ATCHISON, TOPEKA 5 SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
REPORT, GROUNDWATER
3/19/90 1 4 - 0025 FINAL REPORT ASSESSMENT OF GROUNDWATER QUALITY NEAR
BARSTOW, APPENDICES J AND K (4 OF 4)
GERAGHTY S, MILLER INC
ATCHISON, TOPEKA f, SANTA FE
RAILWAY COMPANY AND CITY OF
BARSTOW
PUBLIC COMMUNICATION, PRES
RELEASE
3/28/90 9 5 - 0003 "NICE TO SEE ACTION ON BARSTOW BASE CLEAN UP OF
GROUNDWATER CONTAMINATION"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES
RELEASE
4/6/90 9 5 - 0021 "DMA INSTITUTES TEMPORARY PROCESS FOR INDUSTRIAL
WASTEWATER DISPOSAL"
MCLB BARSTOW TODAY
PUBLIC RELEASE
REPORT, DRINKING WATER
4/19/90 6 4 - 0013 DRAFT SAMPLING AND ANALYSIS REPORT FOR PUBLIC AND PRIVATE
DRINKING WATER WELLS, YERMO AREA
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S, US EPA
REPORT, CARBON ABSORPTION
4/23/90 2 2 - 0005 ANALYTICAL RESULTS, OPERATION OF THE CALGON CARBON MODEL 10
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
4/23/90 1 4 - 0035 SOIL INVESTIGATION, FY 1991, MCON PROJECT P 655, PAINT COMBAT
VEHICLE MAINTENANCE SHOP, MCLB BARSTOW RESULT OF SOIL
INVESTIGATION ARE PRESENTED THE PURPOSE WAS TO DETERMINE
BENTON ENGINEERING INC
ATKINSON, JOHNSON, S SPURPIER, INC
PUBLIC COMMUNICATION, PRES
RELEASE
5/7/90 9 5 - 0033 "MCLB TEST INDICATE WELLS OFF BASE NOT CONTAMINATED"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
REPORT, GROUNDWATER
/7/90 1 4 - 0034 ALTERNATE DRINKING WATER SUPPLY TO
REPLACE/SUPPLEMENT THE GROUNDWATER AT YERMO ANNEX, MCLB,
BARSTOW
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
PUBLIC COMMUNICATION, PRES
RELEASE
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
PUBLIC COMMUNICATION, PRES 5/9/90
CAT - DOCf SUBJECT
9 5 - 0030 "TESTS SHOW MARINE WELLS NOT TAINTED" WATER FROM PUBLIC AND
PRIVATE WELLS EXCEEDS STATE DRINKING WATER STANDARDS
ADDRESSEE
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES
RELEASE
9 5 - 0031 "MCLB IMPROVES WASTE HANDLING, WASTEWATER TRUCKED OFF SITE
FOR DISPOSAL TREATMENT"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES 5/11/90
RELEASE
9 5 - 0029 "GROUNDWATER AT YERMO MEETS SAFE WATER STANDARDS"
MCLB BARSTOW TODAY
PUBLIC RELEASE
0006 ANALYTICAL RESULTS, OPERATION OF THE CALGON CARBON MODEL 10
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, DRINKING WATER 5/29/90
PLAN, SITE INVESTIGATION WORK 6/1/90
4 - 0004 REPORT ON PUBLIC/PRIVATE DRINKING WATER WELLS, YERMO AREA
1 - 0002 SITE INVESTIGATION WORK PLAN FOR THE YERMO ANNEX SANITARY
LANDFILL
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
1,2
REPORT, DRINKING WATER
0012 LETTER ENCLOSING REPORTING WATER ANALYSIS FROM FAUCET AT
NEBO BASE IN BLDG 198
GROUNDWATER TECHNOLOGY INC
MARINE CORPS LOGISTIC BASE
GUIDANCE, STATE
0017 INTERIM GUIDANCE FOR PREPARATION OF ENDANGERMENT
ASSESSMENT REPORT
DEPT OF HEALTH SERVICES
PUBLIC RELEASE
0007 ANALYTICAL RESULTS, OPERATION OF THE CALGON CARBON MODEL 10
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, DRINKING WATER
0014 THIRD QUARTER DRINKING WATER WELL ANALYSIS RESULTS, TITLE 22
WATER TESTING
K BANKS MONTGOMERY LABORATORIES
MARINE CORPS LOGISTICS BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
DATE CAT - DOCt SUBJECT
REPORT, CARBON ABSORPTION 8/13/90 22- 0008 ANALYTICAL RESULTS, OPERATIONS OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5 COMMAND
NAVAL FACILITIES ENGINEERING
PLAN, QAPP
9/1/90 42- 0001 DRAFT RI/FS QUALITY ASSURANCE PROJECT PLAN, MCLB, BARSTOW JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, !,. US EPA
REPORT, CARBON ABSORPTION 9/6/90 22- 0009 ANALYTICAL RESULTS OPERATION OF THE CALGON CARBON MODEL
10 UNITS INSTALLED ON WELLS 3 AND 5
CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
COMMAND
AGREEMENT, FEDERAL FACILITY 9/28/90 11 1 - 0023 FEDERAL FACILITY COMPLIANCE AGREEMENT MCLB NEBO, BETWEEN US EPA f, MCLB
MCLB AND US EPA
MARINE CORPS LOGISTICS BASE
AGREEMENT, FEDERAL FACILITY 9/28/90 11 1 - 0030 FEDERAL FACILITIES COMPLIANCE AGREEMENT MCLB YERMO
BETWEEN MCLB AND EPA
US EPA 5 MCLB
MARINE CORPS LOGISTICS BASE
AGREEMENT, FEDERAL FACILITY 9/29/90 11 1 - 0024 RESPONSE TO THE US EPA ON THE FEDERAL FACILITIES COMPLIANCE MARINE CORPS LOGISTICS BASE
AGREEMENT
US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, CARBON ABSORPTION 10/9/90 2 2 - 0010 ANALYTICAL RESULTS, OPERATION OF THE CALGON CARBON MODEL 10 CALGON CARBON CORPORATION
UNITS INSTALLED ON WELLS 3 AND 5
NAVAL FACILITIES ENGINEERING
COMMAND
PUBLIC COMMUNICATION, PRES 10/10/90
RELEASE
9 5 - 0027 "PACTS SIGNED FOR CLEAN UP OF HAZARDOUS SITE AT MCLB,
BARSTOW"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES 10/19/90
RELEASE
9 5 - 0028 "TEMPORARY TREATMENT UNIT FOR INDUSTRIAL WASTEWATER
TESTED AT DEPOT MAINTENANCE ACTIVITY"
MCLB BARSTOW TODAY
PUBLIC RELEASE
CORRESPONDENCE,
MEMORANDUM
10/22/90 11 1 - 0044 FURTHER INVESTIGATION OF OFF-SITE CONTAMINATION OF
GROUNDWATER
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CAT - DOC# SUBJECT
ADDRESSEE
AGREEMENT, FEDERAL FACILITY 10/24/90 11 1 - 0026
FEDERAL FACILITY AGREEMENT UNDER CERCLA SECTION 120
BETWEEN MCLB, USEPA AND CDHS
US EPA, DTSC 5 NFEC
MARINE CORPS LOGISTICS BASE
PUBLIC COMMUNICATION, PRES
RELEASE
9 5 - 0026
"EPA, STATE AND NAVY SIGN FEDERAL FACILITY AGREEMENTS FOR
MCLB, BARSTOW"
MCLB BARSTOW TODAY
PUBLIC RELEASE
AGREEMENT, FEDERAL FACILITI 10/29/90 11 1 -
RESPONSE TO US EPA ON THE FEDERAL FACILITIES COMPLIANCE
AGREEMENT
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, ANALYTICAL
ANALYTICAL REPORT DATED SEPTEMBER 1990, WELL NOS 3 AND 5
(W/ENCL)
NAVAL FACILITIES ENGINERRING
GUIDANCE, STATE
11/1/90 3 3 - 0001
PROCEDURES FOR ENDANGERED SPECIES ACT COMPLIANCE FOR THE
MOJAVE DESERT TORTOISE
US DEPT INTERIOR FISH AND WILDLIFE
SERVICE REGIONS 1,2 AND 6
PUBLIC RELEASE
REPORT, GROUNDWATER
RESULTS OF GROUNDWATER ANALYSIS, PERFORMED ANALYSIS FOR
REGULATED ORGANIC CHEMICALS AND RADIOACTIVE SUBSTANCES
MONTGOMERY LABORATORIES
MARINE CORPS LOGISTICS BASE
REVIEW OF THE DRAFT RI/FS WORK PLAN FOR MCLB, BARSTOW, DATED
SEPTEMBER 1990
KEPT OF TOXIC SUBSTANCES CONTROL
MARINE CORPS LOGISTICS BASE
REVIEW OF THE DRAFT RI/FS SAP FOR MCLB, BARSTOW, DATED
SEPTEMBER 1990
DEPT OF TOXIC SUBSTANCES CONTROL
MARINE CORPS LOGISTICS BASE
REVIEW OF THE DRAFT RI/FS, HEALTH AND SAFETY PLAN FOR MCLB,
BARSTOW, DATED SEPTEMBER 1990
DEPT OF TOXIC SUBSTANCES CONTROL
MARINE CORPS LOGISTICS BASE
REVIEW OF THE DRAFT RI/FS QUALITY ASSURANCE PROJECT PLAN FOR
MCLB, BARSTOW, DATED SEPTEMBER 1990
DEPT OF TOXIC SUBSTANCES CONTROL
MARINE CORPS LOGITICS BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS, EPA
CAT - DOC# SUBJECT
52- 0005 REVIEW ON THE DRAFT WORK PLAN SAMPLING AND ANALYSIS PLAN
QUALITY ASSURANCE PROJECT PLAN AND COMMUNITY RELATIONS
PLAN FOR MCLB DATED SEPTEMBER 26, 1990
ADDRESSEE
MARINE CORPS LOGISTICS BASE
5 2 - 0021 REVIEW OF THE RI/FS COMMUNITY RELATIONS PLAN, DATED 09/90 DEPT OF TOXIC SUBSTANCES CONTROL
5 2 - 0022 REVIEW OF THE DRAFT RI/FS WORK PLAN FOR MCLB, BARSTOW, DATED
SEPTEMBER 1990
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
MARINE CORPS LOGISTICS BASE
COMMENTS, RWQCB
2 - 0007 REVIEW ON THE DRAFT RI/FS WORK PLAN, SAP QUALITY ASSURANCE
PROJECT PLAN, COMMUNITY RELATIONS PLAN, HEALTH AND SAFETY
PLAN FOR MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
PUBLIC COMMUNICATION, PRES
RELEASE
11/30/90 9 5 - 0024 "MCLB, BARSTOW HOSTS FIRST TRC MEETING"
MCLB BARSTOW TODAY
PUBLIC RELEASE
AGREEMENT, FEDERAL FACILITY
11 1 - 0029 SUBMITTAL TO THE US EPA IN RESPONSE TO FEDERAL FACILITIES
COMPLIANCE AGREEMENT
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
REGULATION, SENATE BILL
3 2 - 0001 CALIFORNIA STATE REQUIREMENTS FOR WATER WELL DESTRUCTION
SENATE BILL NO 1817
ENVIRONMENTAL HEALTH SERVICES,
COUNTY OF SAN BERNARDINO
PUBLIC RELEASE
REPORT, WASTEWATER
LETTER REPORT ON THE SAMPLING OF SLUDGE LAGOON #1 NEBO
DOMESTIC WASTEWATER TREATMENT FACILITY, MCLB, BARSTOW
BROWN AND CALDWELL
NFEC, MCLB, RWQCB, DTSC, S US EPA
COMMENTS RESPONSE
53- 0001 RESPONSE TO REGULATORY AGENCY COMMENTS ON RI/FS WORK
PLAN, MCLB, BARSTOW SEPT 1990
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA 1,2,3,4,5,6,7
CORRESPONDENCE
- 0018 ANALYTICAL REPORT DATED NOVEMBER 1990 ON WELL NOS 3 AND 5
MCLB, BARSTOW
NAVAL FACILITIES ENGINEERING
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, WATER LEVELS
DATE CAT - DOCf SUBJECT
2/14/91 1 1 - 0014 RECORDS OF WATER LEVELS IN WELLS TOWNSHIP 9N RANGE 1W
THROUGH TOWNSHIP 9N RANGE PRINTED 2/14/91 IN RESPONSE TO
JEG'S REQUEST
AUTHOR
US GEOLOGICAL SURVEY
PLAN, COMMUNITY RELATIONS
PLAN, RI/FS WORK
9 2 - 0001 DRAFT FINAL COMMUNITY RELATIONS PLAN, MCLB BARSTOW
4 1 - 0003 DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK
PLAN, MCLB, BARSTOW
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S, US EPA 1,2,3,4,5,
NFEC, MCLB, RWQCB, DTSC, S, US EPA 1,2,3,4,5,
REPORT, CONTAMINATION
RELEASE
3 1 - 0019 GROUNDWATER ISSUE DENSE NON-AQUEOUS PHASE LIQUIDS
1 1 - 0015 RELEASE OF 55-GALLONS OF TRITIUM CONTAMINATED WATER INTO
YERMO ANNEX DOMESTIC SEWER SYSTEM AND DETAILS OF REASONS
WHY SPILL OCCURRED
US ENVIRONMENTAL PROTECTION AGENCY JACOBS ENGINEERING GROUP INC
REGIONAL WATER QUALITY CONTROL
BOARD
1 7 - 0030 ANALYTICAL REPORT DATED FEBRUARY 1991, WELL NOS 3 AND
(W/ENCL)
CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
REPORT, ANALYTICAL
1 7 - 0031 ANALYTICAL REPORT DATED JANUARY 1991, WELL NOS 3 AND 5
(W/ENCL)
NAVAL FACILITIES ENGINEERING
PLAN, HEALTH S SAFETY
COMMENTS, DTSC
4 6 - 0002 UTILITIES INSTALLATION HEALTH AND SAFETY PLAN, MCLB, BARSTOW
5 2 - 0017 REVIEW OF THE DRAFT FINAL RI/FS WORK PLAN, MARCH 1991, MCLB,
BARSTOW
JACOBS ENGINEERING GROUP INC
DEPT OF TOXIC SUBSTANCES CONTROL
NFEC, MCLB, RWQCB, DTSC, S US EPA
NAVAL FACILITIES ENGINEERING
COMMAND
5 2 - 0018 REVIEW OF THE DRAFT FINAL COMMUNITY RELATIONS PLAN, MARCH
1991, MCLB, BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
PLAN, RI/FS WORK
REPORT, ANALYTICAL
CORRESPONDENCE
PLAN SITE
COMMENTS, RWQCB
COMMENTS, EPA
SUBJECT
REVIEW OF THE DRAFT RI/FS WORK PLAN FOR MCLB, BARSTOW
DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY SAMPLING
AND ANALYSIS PLAN, MCLB, BARSTOW
ANALYTICAL REPORT DATED MARCH 1991, WELL NOS 3 AND 5 (W/ENCL)
TIMELY SUBMITTAL OF RI/FS SCOPING DOCUMENTS
SITE MANAGEMENT PLAN FOR MCLB
CONCERNS REGARDING TECHNICAL REVIEW COMMITTEE CHARTER
FOR THE RI/FS AND RFA ACTIVITIES AT MCLB, BARSTOW
REVIEW OF THE RI/FS SAMPLING AND ANALYSIS PLAN AND QUALITY
ASSURANCE PROJECT PLAN SAP AND QAPP, MCLB, BARSTOW
CONDITIONAL APPROVAL AND REVIEW OF THE RI/FS WORK PLAN AND
SAMPLING AND ANALYSIS PLAN, MCLB, BARSTOW
ANALYTICAL REPORT DATED APRIL 1991, WELL NOS 3 AND 5 (W/ENCL)
REVIEW OF THE DRAFT FINAL RI/FS SAMPLING AND ANALYSIS PLAN
AND QUALITY ASSURANCE PROJECT PLAN
REGIONAL WATER QUALITY CONTROL
BOARD
JACOBS ENGINEERING GROUP INC
CALGON CARBON CORPORATION
MARINE CORPS LOGISTICS BASE
JACOBS ENGINEERING GROUP INC
DEPT OF TOXIC SUBSTANCES CONTROL
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
MARINE CORPS LOGISTICS BASE
NFEC, MCLB, RWQCB, DTSC, f, US EPA
NAVAL FACILITIES ENGINEERING
DEPT TOXIC SUBSTANCES CONTROL
NFEC, MCLB, RWQCB, DTSC, S US EPA
MARINE CORPS LOGISTICS BASE
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
CALGON CARBON CORPORATION
DEPT OF HEALTH SERVICES
NAVAL FACILITIES ENGINEERING
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CAT - DOC# SUBJECT
ADDRESSEE
COMMENTS, EPA
REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION, FEASIBILITY
STUDY WORK PLAN MARCH 1, 1991, FOR MCLB, BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE, RESPONSE 5/15/91
CONCERNING APPROVAL OF DRAFT COMMUNITY RELATIONS PLAN AND
HEALTH AND SAFETY PLAN FOR THE RI/FS AND RFA ACTIVITIES AT
MCLB, BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
CORRESPONDENCE
/15/91 5 1 - 0023 RI/FS WORK PLAN, TIME EXTENSION SUBMITTAL FOR MCLB, BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE
5/22/91 5 1 - 0004
TIME EXTENSION FOR SAMPLING f, ANALYSIS PLAN SUBMITTAL FOR
THE RI/FS ACTIVITIES AT MCLB, BARSTOW
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, RESPONSE 5/22/91 5 1 - 0026
RESPONSE TO USE EPA LETTER DATED MAY 15, 1991, ON THE APPROVAL
OF TIME EXTENSION FOR SAP SUBMITTAL
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE
RESPONSE TO THE CONCERNS OF DHS ON TECHNICAL REVIEW
COMMITTEE CHARTER FOR RI/FS AND RFA ACTIVITIES AT MCLB,
BARSTOW
MARINE CORPS LOGISTICS BASE
DEPT TOXIC SUBSTANCES CONTROL
REVISED ANALYTICAL REPORTS, MARCH 5 APRIL 1991, CALGON
CARBON MODEL 10, WELLS #355
MARINE CORPS LOGISTICS BASE
REPORT FOR MAY 1991, CALGON CARBON MODEL 10, WELLS #3s5
MARINE CORPS LOGISTICS BASE
PLAN, RI/FS WORK
DRAFT REMEDIAL INVESTIGATION/FEASIBLITY STUDY WORK PLAN
EXPANDED SECTION ON REGIONAL HYDROGEOLOGY, SAMPLING AND
ANALYSIS RATIONALE FOR INVESTIGATION OF GROUNDWATER
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
REPORT, PLANNING DOCUMENT 6/15/91 4 1 - 0011
DRAFT RI/FS PLANNING DOCUMENTS SUBMITTAL TO REGULATORY
AGENCIES (ENCLOSURE 2)
SOUTHWEST DIVISION
MARINE CORPS LOGISTIC BASE
1,2
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING AGENDA
DATE
6/16/91
SUBJECT
MEETING NOTIFICATION AND TENTATIVE AGENDA
ADDRESSEE
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, REQUEST
REQUEST FOR THE EXTENSION FOR SUBMISSION OF DRAFT REMEDIAL
INVESTIGATION REPORT
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE
1 - 0030 TIME EXTENSION FOR CLARIFICATION TO NFEC LETTER DATED 6/20/91
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, CARBON ABSORPTION 6/25/91 2 2 - 0019 REPORT FOR JUNE 1991, CALGON CARSON MODEL 10, WELLS #3s5
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, ANALYTICAL 6/25/91
MEETING NOTES 6/27/91
MEETING NOTES
REPORT, WATER QUALITY 7/10/91
ANALYTICAL REPORT DATED JUNE 1991 WELL NOS 3 AND 5 (W/ENCL)
DRAFT NOTES FROM PROJECT MANAGERS MEETINGS HELD ON 6/27-
28/91, RE PROJECT SCHEDULE, YERMO SLUDGE REMOVAL, OUs 152
WORK PLAN AMENDMENTS, RI/FS WORK PLAN AMENDMENTS, WASTE f,
JUNE 27-28, 1991, MEETING NOTES FROM PROJECT MANAGER'S
MEETING, MARINE CORPS LOGISTICS BASE, BARSTOW
INDUSTRIAL WATER QUALITY MONITORING REPORT FOR THE MONTH
OF JUNE 1991
CALGON CARSON CORPORATION NAVAL FACILITIES ENGINEERING
NAVAL FACILITIES ENGINEERING COMMAND US EPA, DTSC, S RWQCB
SOUTHWEST DIVISION
MARINE CORPS LOGISTICS BASE
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
PUBLIC COMMUNICATION, PRES 7/26/91
RELEASE
"INSTALLATION RESTORATION PROGRAM AT MCLB, BARSTOW
REVIEWED"
PUBLIC RELEASE
COMMENTS RESPONSE
RESPONSE TO REGULATORY AGENCY COMMENTS ON DRAFT FINAL
WORK PLAN AND SAMPLING AND ANALYSIS PLAN APRIL 1, 1991
JACOBS ENGINEERING GROUP INC
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
REPORT CARBON ABSORPTION 8/1/91
TREATED GROUNDWATER FOR THE CALGON CARSON MODEL 10
WELLS 3 AND 5
ADDRESSEE
MARINE CORPS LOGISTICS BASE
OP UNIT
1,2
ESTIMATING POTENTIAL FOR OCCURRENCE OF DNAPL AT SUPERFUND
SITES
US ENVIRONMENTAL PROTECTION AGENCY JACOBS ENGINEERING GROUP INC
COMMENTS, EPA
REVIEW OF THE RI/FS FIELD SAMPLING PLAN AMENDMENTS FOR
OPERABLE UNITS 1 S 2, WASTE MANAGEMENT PLAN, RISK ASSESSMENT
ON LINE AND SCHEDULED TELE-CONFERENCE CALLS OF JULY 9 AND 29.
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, WASTEWATER
INDUSTRIAL WATER QUALITY MONITORING RESULTS
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
COMMENTS, EPA
REVIEW OF THE RISK ASSESSMENT SCHEDULE RI/FS, MCLB BARSTOW
BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
REVIEW OF THE RISK ASSESSMENT OUTLINE FOR THE RI/FS AT MCLB,
BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
REVIEW OF THE DATA MANAGEMENT PLAN FOR RI/FS AT MCLB,
BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
2 - 0039 REVIEW OF THE WASTE MANAGEMENT PLAN, RI/FS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
2 - 0040 REVIEW OF THE FIELD SAMPLING PLAN FOR OUs >-5 RI/FS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
MEETING NOTES
5 1 - 0041 NOTES FROM CONFERENCE CALLS BETWEEN JEG AND US EPA ON
REMEDIAL INVESTIGATION/FEASIBILITY STUDY, RE OUs 152
GROUNDWATER STAGES ASB OBJECTIVES
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS, EPA
MEETING AGENDA
COMMENTS RESPONSE
CORRESPONDENCE
DATE
8/9/91
REVIEW COMMENTS ON THE DRAFT RI/FS PLANNING DOCUMENTS FOR
THE MCLB BARSTOW DATED JUNE 15, 1991
COMMENTS ON THE DRAFT RI/FS PLANNING DOCUMENTS FOR MCLB,
BARSTOW DATED JUNE 15, 1991 WITH ATTACHMENTS OF INTERIM FIELD
SAMPLING PLAN FOR OUs 1 AND 2, WASTE MANAGEMENT PLAN, DATA
PROJECT MANAGERS MEETING NOTIFICATION ON RI/FS ACTIVITIES AT
MCLB, BARSTOW
REVIEW ON THE RWS STUDY SUBMITTAL TO REGULATORY AGENCIES
ENCLOSURES 1 AND 2, OPERABLE UNITS 1 AND 2, MCLB, BARSTOW
RESPONSE TO AGENCIES COMMENTS ON RI/FS PLAN FOR OPERABLE
UNITS 1 AND 2
DRAFT DETAILED PROJECT SCHEDULE FOR OUs 1,2,3,4,5,6, AND 7 AT
MCLS BARSTOW OF JULY 24, 1991 LETTER
CORRESPONDENCE, REQUEST 8/29/91 5 1 - 0011 TIME EXTENSION FOR RI/FS SAMPLING AND ANALYSIS PLAN
RESPONSE TO AGENCY COMMENTS VOLUME 1 DRAFT FINAL RI/FS
PLANNING DOCUMENTS
REPORT, CARBON ABSORPTION 9/4/91 2 2 - 0021 REPORT FOR AUGUST 1991, CALGON CARBON MODEL 10, WELLS #3s5
9/9/91 5 2 - 0239 COMMENTS ON THE DRAFT RI/FS PLANNING DOCUMENTS FOR THE
MCLB BARSTOW DATED JUNE 15, 1991
AUTHOR ADDRESSEE
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
NAVAL FACILITIES ENGINEERING COMMAD US EPA, DTSC, 5 RWQCB
REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
BOARD
NAVAL FACILITIES ENGINEERING COMMAND US EPA, DTSC, 5 RMQCB
DEPT OF NAVY
US ENVIRONMENTAL PROTECTION
AGENCY
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
SOUTHWEST DIVISION
MARINE CORPS LOGISTIC BASE
NAVAL FACILITIES ENGINEERING
EPA REGION IX SAN FRANCISCO
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
TECHNICAL MEMORANDUM
DATE
9/10/91
TECHNICAL MEMORANDA FRACTURE TRACE ANALYSIS TM-001 FOR
MCLB BARSTOW
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE OP UNIT
NFEC, MCLB, RWQCB, DTSC, f, US EPA 1,2
CORRESPONDENCE
1 - 0034 REGIONAL GROUNDWATER INVESTIGATION
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENTS IN YERMO AND
DAGGET
ANALYTICAL DATA FOR OFFSITE WELLS MCLB, DATED 10/25/90, FOR
OFF-BASE PRIVATE RESIDENT
US DEPT OF INTERIOR
CALIF GEOLOGICAL SURVEY
REPORT, ANALYTICAL
ANALYTICAL REPORT DATED SEPTEMBER 1991, WELL NOS 3 AND 5
(WENCL)
NAVAL FACILITIES ENGINEERING
CORRESPONDENCE,
RECOMMENDATION
PROPOSAL FOR SCHEDULE EXTENSIONS FOR OPERABLE UNITS 1, 2, 3,
AND 4 MCLB
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
MEETING AGENDA
AGENDA FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY PROGRAM
AND WORKSHOP ON 10/03/91
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, REQUEST 10/17/91 5 1 - 0025
INTENT TO EXTEND TIME FOR RESPONDING TO AGENCY COMMENTS
ON OPERABLE UNITS >-5 SAMPLING 5 ANALYSIS PLAN FOR RI/FS, MCLB,
BARSTOW
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, ANALYTICAL
ANALYTICAL REPORT DATED OCTOBER 1991, WELL NOS 3 AND 5 (W/0
ENCL)
CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
REPORT, ANALYTICAL
ANALYTICAL REPORT DATED OCTOBER 1991, WELL NOS 3 AND 5
(W/ENCL)
MARINE CORPS LOGISTICS BASE
PLAN WASTE MANAGEMENT 11/1/91
RI/FS WASTE MANAGEMENT PLAN, MCLB, BARSTOW
JACOBS ENGINEERING GROUP INC
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
GUIDANCE EPA
GUIDE TO MANAGEMENT OF INVESTIGATION DERIVED WASTES FOR
CERCLA SITES
AUTHOR ADDRESSEE
US ENVIRONMENTAL PROTECTION AGENCY PUBLIC RELEASE
PLAN, DATA MANAGEMENT
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
FINAL ADDENDUM SAMPLING AND ANALYSIS PLAN OUs 1-5, MCLB,
BARSTOW
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S, US EPA
MEETING AGENDA
MEETING NOTES
REPORT, ANALYTICAL
PROJECT MANAGEMENT MEETING MCLB, TENTATIVE AGENDA
TECHNICAL REVIEW COMMITTEE MEETING NOTES HELD ON 11/21/91,
RE THERMAL INFRARED PHOTOGRAPHIC SURVEY, FRACTURE TRACE
ANALYSIS, GROUNDWATER S, COMMUNITY RELATIONS EFFORTS
ANALYTICAL REPORT DATED NOVEMBER 1991, WELL NOS 3 AND 5
(W/ENCL)
NAVAL FACILITIES ENGINEERING COMMAND MCLB, RWQCB, DTSC, f, US EPA
NAVAL FACILITIES ENGINEERING COMMAND TECHNICAL REVIEW COMMITTEE
MEMBERS
CALGON CARBON CORPORATION
NAVAL FACILITIES ENGINEERING
REVIEW OF THE RI/FS WASTE MANAGEMENT PLAN FOR MCLB, BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE
REQUEST FOR SCHEDULE EXTENSIONS FOR FEDERAL FACILITY
AGREEMENT (FFA) DELIVERABLES FOR THE MARINE CORPS LOGISTICS
BASE, BARSTOW
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE
RECOMMENDATION
REPORT, USGS DATABASE
PROPOSED REVISION FOR SAMPLING STRATEGY FOR RI/FS ACTIVITIES
AT MCLB, BARSTOW
DATABASE OF USGS WELLS IN BARSTOW VICINITY AND DATABASE FOR
UNIVERSE OF CHEMICALS OF CONCERN
US ENVIRONMENTAL PROTECTION AGENCY NFEC, MCLB, RWQCB, DTSC, f, US EPA
US GEOLOGICAL SURVEY
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
REVIEW OF ADDENDUM SAMPLING AND ANALYSIS PLAN FOR OUs '-4/3/4
AND FINAL DATA MANAGEMENT PLAN FOR RI/FS AT MCLB, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, RWQCB
REVIEW OF THE WASTE MANAGEMENT PLAN RI/FS MCLB, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, QAPP
QUALITY ASSURANCE PROJECT PLAN FOR RI/FS APPENDIX A FOR
MCLB BARSTOW
JACOBS ENGINEERING GROUP INC
REPORT, ANALYTICAL
ANALYTICAL REPORT DATED DECEMBER 1991, WELL NOS 3 AND
(W/ENCL)
NAVAL FACILITIES ENGINEERING
CORRESPONDENCE
RECOMMENDATION
PROPOSED REVISION FOR SAMPLING STRATEGY FOR RI/FS ACTIVITIES
AT MCLB BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NFEC DTSC S, RWQCB
REVIEW OF THE FINAL ADDENDUM, SAMPLING AND ANALYSIS PLAN FOR
OUs 1 AND 2, AND WASTE MANAGEMENT PLAN, FOR RI/FS AT MCLB
BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
REVIEW OF THE FINAL AMENDMENT TO THE SAMPLING S ANALYSIS
PLAN FOR OUs 1 AND 2 FOR MCLB, BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING
COMMAND
MEETING NOTES
PROJECT MANAGERS TELE-CONFERENCE CALL HELD ON 1/13/92, RE
OUs 152 STAGE A, OU 4 SAMPLING PLAN, REDUCED SAMPLING
REQUIREMENTS S FEDERAL FACILITIES AGREEMENT SCHEDULE
NAVAL FACILITIES ENGINEERING COMMAND US EPA, DTSC, S RWQCB
CORRESPONDENCE
REGARDING CHANGES TO THE AMENDMENT OF THE SAMPLING S
ANALYSIS PLAN WHICH COULD BE RESULT IN REDUCED FIELD WORK, LAB
TIME AND PROJECT COSTS
NAVAL FACILITIES ENGINEERING COMMAND US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE
WELL LOGS OF A WELL IN NEBO AREA DRILLED 5/26/66 THRU 6/7/66
US GEOLOGICAL SURVEY
PUBLIC RELEASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
TECHNICAL MEMORANDUM 1/17/92
SEISMIC REFLECTION/REFRACTION SURVEY DURING JULY 1991
TECHNICAL MEMORANDUM TM-0002 FOR MCLB, BARSTOW
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE OP UNIT
NFEC, MCLB, RWQCB, DTSC, S, US EPA 1,2
PLAN, HEALTH 5 SAFETY 2/3/92
REPORT, ANALYTICAL 2/10/92
REVIEW OF RI/FS RCRA, AND UNDERGROUND STORAGE TANK
ACTIVITIES FINAL DATA MANAGEMENT PLAN FOR MCLB, BARSTOW
MASTER HEALTH AND SAFETY PLAN, MCLB, BARSTOW
ANALYTICAL REPORT DATED JANUARY 1992, WELL NOS 3 AND 5
(W/ENCL)
US ENVIRONMENTAL PROTECTION AGENCY
JACOBS ENGINEERING GROUP INC
CALGON CARSON CORPORATION
NAVAL FACILITIES ENGINEERING
COMMAND
NFEC, MCLB, RWQCB, DTSC, S, US EPA
NAVAL FACILITIES ENGINEERING
AGREEMENT, FEDERAL FACILITY 2/21/92 0 1 - 0001
REVIEW OF THE QUALITY ASSURANCE PROJECT PLAN FOR RI/FS AT
MCLB, BARSTOW
DISPUTE CONCERNING SCHEDULE EXTENSION REQUEST TO FEDERAL
FACILITIES ASSESSMENT FOR MCLB, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
NAVAL FACILITIES ENGINEERING
COMMAND
1,2,3,4,5,6,7
1,2,3,4,5,6,7
PUBLIC COMMUNICATION, PRES 3/2/92
RELEASE
PUBLIC COMMUNICATION, PRES 3/5/92
RELEASE
"TEST WELL DRILLED AT MARINE BASE TO MONITOR GROUNDWATER
QUALITY"
"INSTALLATION OF GROUNDWATER MONITORING WELLS AS PHASE 1
OF GROUNDWATER INVESTIGATION FOR MCLB, BARSTOW"
BARSTOW DESERT DISPATCH
MCLB BARSTOW TODAY
PUBLIC RELEASE
PUBLIC RELEASE
COMMENTS RESPONSE
RESPONSE TO AGENCY COMMENTS FINAL RI/FS PLANNING
DOCUMENTS VOL V FOR MCLB, BARSTOW
ANALYTICAL REPORT DATED FEBRUARY 1992, WELL NOS 3 AND 5
(W/ENCL)
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
1,2,3,4,5,6,7
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS EPA
REVIEW OF THE REVISED QUALITY ASSURANCE PROJECT PLAN FOR
RI/FS AT MCLB, BARSTOW
NAVAL FACILITIES ENGINEERING
COMMAND
SAMPLING PUBLIC AND PRIVATE SUPPLY WATER WELLS, YERMO AND
DAGGETT AREAS (VOL 1 OF 2)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
PLAN SAMPLING 5 ANALYSIS 3/16/92 4 2 - 0013
PUBLIC COMMUNICATION PRES 3/26/92
RELEASE
SAMPLING PUBLIC AND PRIVATE SUPPLY WATER WELLS YERMO AND
DAGGETT AREA (VOL 2 OF 2)
"CONTAINMENT AND TREATMENT OF SOLVENT SPILL ON MARCH 18,
1992, AT YERMO"
JACOBS ENGINEERING GROUP INC
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES 3/26/92
RELEASE
"TOXIC DEGREASING SOLVENT (PCE) SPILL AT YERMO DEPOT MARCH
18, 1992"
6 1 - 0026 ORGANIC CHEMICAL ANALYSES REPORT ON SAMPLES DATED 3/13/
TRUESDAIL LABORATORY INC
PUBLIC RELEASE
MEETING AGENDA
CORRESPONDENCE
LETTER ENCLOSING MEETING NOTIFICATION AND OVERVIEW OF
PROJECT COSTS FOR RI/FS, MCLB, BARSTOW
FOLLOW UP ON PROPOSALS FROM MARCH 23, 1992 MEETING RE
DISPUTE RESOLUTION FOR MCAS EL TORO AND MCLB BARSTOW
CROSS REFERf 5.1
NAVAL FACILITIES ENGINEERING COMMAND MCLB, US EPA, DHS, 5 RWQCB
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
REPORT, ANALYTICAL 4/2/92
COMMENTS, EPA 4/6/92
ANALYTICAL REPORT DATED MARCH 1992, WELL NOS 3 AND 5 (W/ENCL)
REVIEW OF NEESA REQUIREMENTS FOR ANALYTICAL DATA AND DATA
VALIDATION AT MCLB BARSTOW
CALGON CARBON CORPORATION
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PERMIT
DRILLING PERMITS FROM COUNTY OF SAN BERNARDINO DEPT OF
ENVIRONMENTAL HEALTH SERVICES
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
DEPT OF HEALTH SERVICES f, MCLB
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR
THE RI/FS, MCLB, BARSTOW
REVIEW OF TECHNICAL MEMORANDUM TM-0002 AND TM-0003, RI/FS
MCLB, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, DTSC
DEPT OF TOXIC SUBSTANCES CONTROL
COMMAND
NAVAL FACILITIES ENGINEERING
MEETING NOTES
PROJECT MANAGERS MEETING NOTES HELD ON 4/9-10/92 RE
GEOPHYSICAL f, SOIL GAS SURVEYS, FIELD AUDITS, DATA S, WASTE
MANAGEMENT OUs >-4 GROUNDWATER STAGE ASB, USGS STATUS.
NAVAL FACILITIES ENGINEERING COMMAND
US EPA DTSC, S RWQCB
DRILLING PERMITS FROM THE COUNTY OF SAN BERNARDINO DEPT OF
ENVIRONMENTAL HEALTH SERVICES
JACOBS ENGINEERING GROUPS INC
DEPT OF HEALTH SERVICES 5 MCLB
REVIEW ON DRAFT FACT SHEET FOR MCLB BARSTOW
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
PUBLIC COMMUNICATION NEWS 4/30/92
ARTICLE
"SOLVENT SPILL CLEAN UP AT YERMO ANNEX DOMESTIC TREATMENT
PLANT SHOWING PROGRESS"
MCLB BARSTOW TODAY
PUBLIC RELEASE
MEETING NOTES
PROJECT NOTE 123 - TELE-CONFERENCE CALL WITH BUREAU OF LAND
MANAGEMENT
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, DTSC, 5 US EPA
PLAN, WASTE MANAGEMENT
PROJECT NOTE 133 - INVESTIGATION-DERIVED WASTEWATER S,
DISPOSAL OPTION TELECONFERENCE BETWEEN JEG 5 RWQCB HELD
ON 5/11/92, RE TREATED IDW WATER DISPOSAL OPTIONS 5 ANALYSIS
JACOBS ENGINEERING GROUP INC
NFEC S, MCLB
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
PUBLIC COMMUNICATION
DATE
5/13/92
PROJECT MANAGERS TELE-CONFERENCE MEETING NOTES HELD ON
5/13/92, RE OUs 1S2 STAGE ASB WELL LOCATIONS, FIELD AUDITS
YERMO SLUDGE REMOVAL, WASTE MANAGEMENT S OFF-SITE
REVIEW OF THE WORK PLAN FOR SAMPLING PUBLIC AND PRIVATE
WATER SUPPLY WELLS, YERMO AND DAGGETT AREA
PROJECTION NOTE 136 - UPDATED MAILING LIST FOR PUBLIC
PARTICIPATION IN RI/FS ACTIVITIES AT MCLB, BARSTOW
AUTHOR
NAVAL FACILITIES ENGINEERING COMMAND
REGIONAL WATER QUALITY CONTROL
BOARD
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
NFEC, MCLB RWQCB, DTSC, S US EPA
COMMENTS, DTSC
REVIEW OF THE WORK PLAN FOR SAMPLING PUBLIC AND PRIVATE
SUPPLY WATER WELLS, YERMO AND DAGGETT AREAS FOR MCLB,
BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, RISK ASSESSMENT WORK 5/28/92
CORRESPONDENCE, RESPONSE 5/29/92
DRAFT HUMAN HEALTH S, ECOLOGICAL RISK ASSESSMENT WORK PLAN
COMPLIMENTS ON THE OPEN HOUSE/COMMUNITY WORKSHOP HELD
ON MAY 12, 1992 FOR THE IRP AND RESPONSE TO REQUEST FOR
COMMENTS AND SUGGESTIONS FOR FUTURE COMMUNITY MEETINGS
JACOBS ENGINEERING GROUP INC
DEPT OF TOXIC SUBSTANCES CONTROL
NFEC, MCLB, RWQCB, DTSC 5 US EPA
MARINE CORPS LOGISTICS BASE
TECHNICAL MEMORANDUM
DRAFT QUALITY ASSESSMENT OF AERIAL PHOTO REVIEW TECHNICAL
MEMORANDUM TM-004 FOR MCLB, BARSTOW
PROJECT NOTE 145 - DRILLING AND GROUNDWATER MONITORING
WELL INSTALLATION PERMIT ON SAN BERNADINO COUNTY FLOOD
CONTROL DISTRICT PROPERTY
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
DEPT OF HEALTH SERVICES S MCLB
TECHNICAL MEMORANDUM
PRELIMINARY DRAFT RESULTS OF STAGE A GROUNDWATER
MONITORING WELL S, PIEZOMETER INSTALLATION DURING FEBRUARY
TO MARCH 1992, TECHNICAL MEMORANDUM 5, FOR OUs 1 5 2 (VOL 1 OF
PRELIMINARY DRAFT RESULTS OF STAGE A GROUNDWATER
MONITORING WELL 5 PIEZOMETER INSTALLATION DURING FEBRUARY
TO MARCH 1992, TECHNICAL MEMORANDUM 5, FOR OUs 1 S 2 (VOL 2 OF
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
NFEC, MCLB, RWQCB, DTSC, S US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
TECHNICAL MEMORANDUM 6/3/92
CORRESPONDENCE
MEETING NOTES
SUBJECT
PRELIMINARY DRAFT RESULTS OF STAGE A GROUNDWATER
MONITORING WELL f, PIEZOMETER INSTALLATION DURING FEBRUARY
TO MARCH 1992, TECHNICAL MEMORANDUM 5, FOR OUs 1 5 2 (VOL 3 OF
ATTORNEY'S LETTER EXPRESSING CONCERN RE CIRCULATION OF
REVIEWS OF SEISMIC REPORT (BISON INSTRUMENTS LETER ATTACHED)
PROJECT NOTE 133 - INVESTIGATION DERIVED WASTE SOILS
MANAGEMENT AND DISPOSAL OPTION, TELE-CONFERENCE CALL HELD
ON 6/22/92, WITH JEG, EPA 5 RWQCB
AUTHOR
JACOBS ENGINEERING GROUP INC
RUTTER AND WILBANKS CORPORATION
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB, DTSC, f, US EPA
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
TECHNICAL MEMORANDUM
REPORT, GROUNDWATER
PRELIMINARY DRAFT STAGE B GROUNDWATER INVESTIGATION PLAN
OUs 1 AND 2, TECHNICAL MEMORANDUM TM-0006
PROJECT NOTE 157 - FIRST QUARTERLY GROUNDWATER
MEASUREMENTS 5 CONFIRMATION OF BASELINE GROUNDWATER
MONITORING DATA
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
PROJECT NOTE 166 - DRILLING PERMIT APPLICATION, BACKGROUND
FOR THE SAN BERNARDINO COUNTY FOR STAGE B GROUNDWATER
MONITORING WELLS LOCATED WITHIN BASE BOUNDARIES
JACOBS ENGINEERING GROUP INC
DEPT OF HEALTH SERVICES 5 MCLB
PROJECT NOTE 153 - SAMPLING AND ANALYSIS OF GROUNDWATER
FOR TOTAL METALS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
COMMENTS RESPONSE
PROJECT NOTE 162 - RESPONSE TO AGENCY COMMENTS ON MARCH
16, 1992 WORK PLAN FOR SAMPLING PUBLIC AND PRIVATE SUPPLY
WELLS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, USGS DATABASE
WATER CHEMISTRY FROM USGS DATABASE - MULTIPLE STATION
ANALYSES
US GEOLOGICAL SURVEY
MARINE CORPS LOGISTICS BASE
MEETING NOTES
PROJECT NOTE 222 - PROJECT MANAGERS TELE-CONFERENCE CALL
HELD ON 8/13/92, RE PUBLIC/PRIVATE WELLS, STAGE B INVESTIGATION,
RI PHASE 1, BLDG 573, DESERT MIX, GEOPHYSICS 5 YERMO SLUDGE
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETINGS
DATE
8/14/92
SUBJECT
PROJECT NOTE 221 - MINUTES OF PROJECT MANAGERS TELE-
CONFERENCE CALL, HELD ON 8/14/92, RE PUBLIC/PRIVATE WELLS, RI
PHASE 1, DESERT MIX, YERMO SLUDGE REMOVAL, WASTE
AUTHOR
JACOBS ENGINEERING GROUP INC
OP UNIT
1,2,3,4,5,6,7
REPORT - INVESTIGATION-DERIV 8/17/92 4 5 - 0002
WASTE
PROJECT NOTE 183 - INVESTIGATION DERIVED WASTE FIELD
MANAGEMENT PROCEDURE FOR STAGE B
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
MEETING NOTES
PROJECT NOTE 203 - COORDINATION AND ANALYSES FOR JOINT
SAMPLING OF THE US GEOLOGICAL SURVEY PIEZOMETER CLUSTERS
NEAR THE NEBO ANNEX, SPECIALLY STAGE A
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
PLAN SAMPLING f, ANALYSIS 9/2/92
PROJECT NOTE 204 - SAMPLING AND ANALYSIS OF GROUNDWATER
FOR PHASE I, STAGE B WELLS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
REPORT INVESTIGATION-DERIV 9/3/92
WASTE
PROJECT NOTE 189 - WASTE MANAGEMENT, INVESTIGATION DERIVED
WASTE EFFLUENT WASTEWATER ANALYTICAL RESULTS FROM STAGE A
DRILLING ACTIVITY FOR OUs 1 S 2, RESULT INDICATE THAT THE
JACOBS ENGINEERING GROUP INC
REPORT INVESTIGATION-DERIV 9/15/92
WASTE
PROJECT NOTE 213 - TELE-CONFERENCE AGREEMENT ON
INVESTIGATION-DERIVED WASTEWATER DISPOSAL
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
PLAN, QAPP
PROJECT NOTE 202 - REVISIONS TO THE APPROVED QUALITY
ASSURANCE PROJECT PLAN, SECTIONS 40 AND 50, DATED
SEPTEMBER 1992
JACOBS ENGINEERING GROUP INC
PROJECT NOTE 202 - REVISIONS TO THE APPROVED SAMPLING AND
ANALYSIS PLAN, SECTIONS 110 AND 120, DATED SEPTEMBER 1992
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
MEETING NOTES
PROJECT NOTE 200 - MINUTES OF PROJECT MANAGERS TELE-
CONFERENCE, HELD ON 9/28/92, RE OUs 152 STAGE ASB SAMPLING
PLAN, PUBLIC/PRIVATE WELLS, TENTATIVELY IDENTIFIED COMPOUNDS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
MEETING NOTES
PROJECT NOTE 198 - TELE-CONFERENCE CALL WITH PRIVATE LAND
OWNER WHICH THE NAVY WISHES TO DRILL A WELL, HELD ON
OCTOBER 12, 1992
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
PROJECT NOTE 223 - WELL INSPECTION BY SAN BERNADINO COUNTY
DEPARTMENT OF HEALTH SERVICES
AUTHOR
JACOBS ENGINEERING GROUP INC
OP UNIT
1,2
REPORT, INVESTIGATION-DERIV 11/5/92 64- 0022
WASTE
REPORT INVESTIGATION-DERIV 11/5/92 64- 0023
WASTE
PROJECT NOTE 225 - INVESTIGATION-DERIVED WASTE SOILS
LABORATORY ANALYTICAL RESULTS FROM 56 STAGE A WELLS AND
PIEZOMETERS, (VOL 2 OF 2)
PROJECT NOTE 225 - INVESTIGATION DERIVED WASTE SOILS
LABORATORY ANALYTICAL RESULTS FROM 56 STAGE A WELLS AND
PEIZOMETERS (VOL 1 OF 2)
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
MEETING NOTES
PROJECT NOTE 230 - PROJECT MANAGERS' MEETING NOTES HELD ON
11/5/92, RE YERMO SLUDGE REMOVAL, RCRA, STRATEGY FOR SOIL
SITE DATA, PROJECT BUDGET, WASTE MANAGEMENT, OUs 152
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
PLAN, QAPP
FINAL QUALITY ASSURANCE PROJECT PLAN, APPENDIX A FOR
SAMPLING AND ANALYSIS PLAN FOR REMEDIAL INVESTIGATION
/FEASIBILITY STUDY
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
MEETING NOTES
MEETING NOTES HELD ON 11/13/93 BETWEEN USGS, NAVY 5 JACOBS
COOPERATIVE SAMPLING WELL EFFORTS
JACOBS ENGINEERING GROUP INC
REPORT, GROUNDWATER
SUBMITTAL OF RESULTS FROM 56 STAGE A WELLS, VOL I AND VOL II,
DATED 11/15/92
MARINE CORPS LOGISTICS BASE
US EPA, DTSC, 5 RWQCB
GUIDANCE, STATE
WELL DESTRUCTION, COMPLIANCE REQUIREMENTS
SAN BERNARDINO COUNTY
ENVIRONMENTAL HEALTH SERVICES
JACOBS ENGINEERING GROUP INC
MEETING NOTES
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, GROUNDWATER
RESULTS OF WELL TESTING ON PRIVATE PROPERTY AND THE INTERIM
ACTION TO SUPPLY BOTTLED WATER TO OFF-BASE RESIDENTS
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
DATE CAT-DOC#
12/4/92 5 1 - 0065
PROJECT NOTE 7 - REMEDIAL PROJECT MANAGERS MEETING NOTES
HELD ON 12/4/92 RE USGS UPDATE OUs 5S6 SAMPLING PROPOSAL,
COMMUNITY RELATIONS, YERMO SLUDGE REMOVAL S CAOC 16
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB, DTSC, S US EPA
OP UNIT
1,2,3,4,5,
CORRESPONDENCE
GROUNDWATER
5 1 - 0245
TRANSMITTAL FOR COMMENTS OF FINAL DRAFT TO GROUNDWATER
REMEDIATION ASSESSMENT FOR GUI AND 2 (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
VARIOUS AGENCIES
CORRESPONDENCE, RESPONSE
RESPONSE TO RESIDENTS CONCERN REGARDING WELL WATER
CONTAMINATION
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT
TECHNICAL MEMORANDUM
DRAFT GROUNDWATER REMEDIATION ASSESSMENT TECHNICAL
MEMORANDUM TM-0008, OUs 1 AND 2
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
MEETING NOTES
PROJECT NOTE 6 - REMEDIAL PROJECT MANAGERS' TELE-
CONFERENCE, HELD ON DECEMBER 21, 1992
JACOBS ENGINEERING GROUP INC
CORRESPONDENCE, RESPONSE 1/6/93
RIGHT-OF-WAY FROM SOUTHERN CALIFORNIA EDISON FOR DRILLING
AT WELLS Y91, Y10-1 S, Yll-1
SOUTHERN CALIF EDISION CO
DEPT OF TOXIC SUBSTANCES CONTROL
JACOBS ENGINEERING GROUP INC
MARINE CORPS LOGISTICS BASE
PROJECT NOTE 248 - ESTABLISHING UNIFORM SAMPLING AND
ANALYSIS OF GROUNDWATER
JACOBS ENGINEERING GROUP INC
MEETING NOTES
PROJECT NOTE 16 - REMEDIAL PROJECT MANAGERS' MEETING NOTES,
HELD 1/19/93, OUs 152 GROUNDWATER, YERMO SLUDGE REMOVAL 5
PUBLIC/PRIVATE WELLS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
MEETING NOTES
PROJECT NOTE 17 - TECHNICAL REVIEW COMMITTEE MEETING NOTES
HELD ON 1/20/93
JACOBS ENGINEERING GROUP INC
1,2,3,4,5,6,7
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
LETTER ON THE CONNCECTION OF THE PRIVATE PROPERTY TO MCLB'
WATER SYSTEM, AND AUTHORIZATION TO PROCEED FROM PROPERTY
OWNER
AUTHOR
MARINE CORPS LOGISTICS BASE
ADDRESSEE
OFF-BASE RESIDENT
REVIEW OF THE DRAFT WATER REMEDIATION ASSESSMENT TECHNICAL
MEMORANDUM 8, DATED 12/92
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
PROJECT NOTE 238 - STAGE A/B INVESTIGATION DERIVED WASTE
EFFLUENT WATER INDICATING THE TREATED WATER MEETS STATE
AND FEDERAL DRINKING WATER STANDARDS
JACOBS ENGINEERING GROUP INC
REGIONAL WATER QUALITY CONTROL
BOARD
PUBLIC COMMUNICATION NEWS 1/27/93
ARTICLE
"RIVER FLOW BRINGS WELL LEVELS UP"
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
CORRESPONDENCE REQUEST 1/29/93
REQUEST TO SIGN AGREEMENT FOR INSTALLATION AND MAINTENANCE
OF WELL EQUIPMENT ON PRIVATE PROPERTY
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT
TRANSMITTAL OF FACT SHEET ON TCE AND THE INSTALLATION
RESTORATION PROGRAM TO A PRIVATE CITIZEN WHO LIVED ON
PROPERTY WITH A WELL SUSPECTED OF BEING CONTAMINATED WITH
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT
MEETING NOTES
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
CORRESPONDENCE,
GROUNDWATER
COMMENTS ON GWOUNDWATER REMEDIATION ASSESSMEENT TECH
MEMO (TM-0008). OU 1 AND 2
US ENVIRONMENTAL PROTECTION AGENCY
SOUTHWEST DIVISION
REVIEW OF DRAFT GROUNDWATER REMEDIATION ASSESSMENT,
TECHNICAL MEMORANDUM 8, DATED 12/92
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS EPA
MARCH 30, 1998
REVIEW OF THE DRAFT GROUNDWATER REMEDIATION ASSESSMENT,
TECHNICAL MEMORANDUM 0008. OUs 152. DATED 12/92
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, INVESTIGATION DERIV 3/15/93
WASTE
PROJECT NOTE 257 - STAGE B INVESTIGATION DERIVED WASTE
ANALYTICAL RESULTS
AUTHOR
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
MEETING NOTES
PROJECT NOTE 10 - REMEDIAL PROJECT MANAGER'S MEETING NOTES
HELD ON 3/17/93, RE PROPOSAL NO FURTHER ACTION CAOCs, BLDG
573 MAY BE OU 8, WASTE MANAGEMENT, OUs 3/4 PHASE 2 PLANNING
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
OCTOBER 1992 ANALYSIS RESULTS FOR 6 PRIVATE AND 2 YERMO
ANNEX WELLS
MARINE CORPS LOGISTICS BASE
US EPA, DTSC, 5 RWQCB
CORRESPONDENCE, REQUEST 4/9/93
REQUEST TO REVIEW THE SCOPE OF WORK FOR THE ENGINEERING
EVALUATION/COST ANALYSIS AND CURRENT RI/FS WORK BY 05/07/93
AND INCLUDES LIST OF TECHNICAL INFORMATION
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, GROUNDWATER
PROJECT NOTE 278 - WELL DEVELOPMENT, SPECIFICALLY WELL
LOCATION AND GROUNDWATER ELEVATION DATA TO USGS, STAGE B,
YERMO ANNEX AND NEBO
JACOBS ENGINEERING GROUP INC
US GEOLOGICAL SURVEY
CORRESPONDENCE
GROUNDWATER
TRANSMITTAL OF FULLY EXECUTED COPY OF RIGHT OF ENTRY PERMIT
TO AUTHORIZE DRILLING GROUNDWATER TEST WELL ON PRIVATE
PROPERTY (W/ENCL)
SOUTHWEST DIVISION
REPORT, ANALYTICAL DATA
PROJECT NOTE 282 - RI/FS OUs 1,2,3,4,5, S 6 PHASE 1 GROUNDWATER JACOBS ENGINEERING GROUP INC
S, SOIL ANALYTICAL LABORATORY RESULTS
NFEC, MCLB, RWQCB, DTSC, S US EPA
MEETING NOTES
PROJECT NOTE 124 - PHONE CONVERSATION ON GROUNDWATER
MONITORING WELLS INSTALLATIONS RE PHASE 1 STAGE B FIST 40
MONITORING WELL LOCATIONS
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
CORRESPONDENCE, PERMIT 5/17/93
2ND REQUEST FOR PERMISSION TO DRILL A TEST WELL ON PRIVATE
PROPERTY (W/0 ENCL)
SOUTHWEST DIVISION
CORRESPONDENCE
PHASE I GROUNDWATER AND SOIL ANALYTICAL DATA FOR RI/FS OUs 1
THRU 7 DATED MAY 6, 1993
MARINE CORPS LOGISTICS BASE, BARSTOW
US EPA, DTSC, RWQCB
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
DATE
5/19/93
PROJECT NOTE 29 - MEETING NOTES FOR REMEDIAL PROJECTS
MANAGERS HELD ON 5/19-20/93, RE BLDG 573, DATA MANAGEMENT S,
YERMO SLUDGE REMOVAL
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB,DTSC, f, US EPA
OP UNIT
1,2,3,4,5,6,7
ENFORCEMENT, BOARD ORDER 7/1/93
BOARD ORDER DISCHARGE REQUIREMENTS FOR LAND DISPOSAL OF
TREATED GROUNDWATER #6-93-106
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
MEETING NOTES
PROJECT NOTE 30 - MINUTES OF REMEDIAL PROJECT MANAGERS
MEETING HELD RE RISK BASED CRITERIA, OUs 152
GROUNDWATER, OUs 556 REVISIONS S PROJECTS SCHEDULE
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
FAX RESPONSE TO REQUEST FOR REVIEW OF SAMPLE RESULTS FROM
6 DOMESTIC WELLS NEAR MCLB, DATED OCTOBER 1992
DEPT OF TOXIC SUBSTANCES CONTROL
CORRESPONDENCE, WASTE 7/12/93
REQUEST CONCURRENCE ON PROJECT NOTE 269, WASTE
MANAGEMENT, OU1 AND 2, PHASE 1, STAGE B (IRP RI/FS STUDY
PROJECT NOTE (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, WASTE 7/12/93
TRANSMITTAL FOR COMMENTS OF IRP RI/FS PROJECT NOTE 269 RE
WASTE MANAGEMENT, OU 1 AND 2 PHASE 1 STAGE B, WELLS IDW SOILS
ANALYTICAL RESULTS AND RECOMMENDATIONS (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
VARIOUS AGENCIES
CORRESPONDENCE, PERMIT
REQUEST PERMIT TO ALLOW JACOGS ENGR TO DRILL TEST WELL ON
PROPERTY TO DETERMINE QUALITY OF GROUNDWATER IN VICINITY OF
MCLB
SOUTHWEST DIVISION
CORRESPONDENCE, PERMIT 7/13/93
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY
(W/0 ENCL. RIGHT OF ENTRY PERMIT)
SOUTHWEST DIVISION
CORRESPONDENCE, PERMIT 7/13/93
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY
(W/0 ENCL. RIGHT OF ENTRY PERMIT)
SOUTHWEST DIVISION
CORRESPONDENCE, PERMIT
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY
(W/0 ENCL. RIGHT OF ENTRY PERMIT)
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
PROJECT NOTE 3 - REMEDIAL PROJECT MANAGERS MEETING HELD 8/5-
6/93. RE OUs 152 PHASE 2 PLANNING OUs 556 WORK PLAN REVISIONS
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB,DTSC, S US EPA
MEETING NOTES
PROJECT NOTE 8 - MEETING NOTES BETWEEN JACOBS ENGINEERING
AND THE REGIONAL WATER QUALITY CONTROL BOARD RE
INVESTIGATION DERIVED WASTE SOILS MANAGEMENT FOR OPERABLE
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB,DTSC, S US EPA
MEETING NOTES
PROJECT NOTE 2 - INVESTIGATION DERIVED WASTE MANAGEMENT
APPROACH FOR OUs 5S6
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB,DTSC, 5 US EPA
REPORT, GROUNDWATER
MEETING NOTES
WELL SAMPLING REPORT ON OFF-BASE GROUNDWATER
PROJECT NOTE 318 - REMEDIAL PROJECT MANAGERS MEETING NOTES
HELD 9/2/93. RE ECOLOGICAL RISK ASSESSMENT S BLDG 573 PLANNING
MARINE CORPS LOGISTICS BASE
JACOBS ENGINEERING GROUP INC
OFF-BASE RESIDENT
NFEC, MCLB, RWQCB,DTSC, S US EPA
TECHNICAL MEMORANDUM
DRAFT SEPTEMBER 1992 GROUNDWATER SAMPLING RESULTS
OPERABLE UNITS 1 AND 2 TECHNICAL MEMORANDUM 0013
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
TECHNICAL MEMORANDUM
DRAFT JUNE 1993 GROUNDWATER SAMPLING RESULTS OPERABLE
UNITS 1 AND 2 TECHNICAL MEMORANDUM 0011
JACOBS ENGINEERING GROUP INC
CORRESPONDENCE,
GROUNDWATER
PLAN, QAPP
REQUEST FOR COMMENTS TO RI/FS DRAFT PHASE II FIELD SAMPLING
WORK PLAN FOR OU 1 AND 2 (REGIONAL GROUNDWATER), DATED
OCTOBER 15, 1993 (W/0 ENCL)
REQUEST FOR COMMENTS TO RI/FS DRAFT PHASE II FIELD SAMPLING
WORK PLAN FOR OU 1 AND 2, DATED 10/15/93
PROJECT NOTE 312 - ELIMINATION OF SPECIFIC CHEMICALS FROM THE
CHEMICALS OF CONCERN AND THE PROJECT TARGET ANALYTE LIST
MARINE CORPS LOGISTICS BASE
MARINE CORPS LOGISTICS BASE
JACOBS ENGINEERING GROUP INC
1,2,3,4,5,6,7
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PLAN RI/FS WORK
RI/FS DRAFT PHASE II FIELD SAMPLING (WORK) PLAN FOR OPERABLE
UNITS 1 AND 2
AUTHOR
JACOBS ENGINEERING GROUP INC
OP UNIT
1,2
REMOVAL ACTION
ON-SITE COORDINATOR REPORT - REMOVAL ACTION OF
TRICHLOROETHENE CONTAMINATED OFF-BASE WELL AT NEBO ANNEX
JACOBS ENGINEERING GROUP INC
NFEC. MCLB. RWQCB. DTSC. 5 US EPA
MEETING NOTES
PROJECT NOTE 322 - REMEDIAL PROJECT MANAGERS' MEETING NOTES
HELD 11/4/93. RE PERSONNEL CHANGES, BLDG 573, OUs 152
GROUNDWATER FIELD SAMPLING, YERMO SLUDGE REMOVAL S USGS
NFEC. MCLB. RWQCB. DTSC. S US EPA
REPORT, INVESTIGATION-DERIV
WASTE
PROJECT NOTE 321 - INVESTIGATION-DERIVED WASTE SOIL FOR
MONITORING WELLS Y7-1 AND Y8-1 TO DISCHARGE CUTTINGS WITH
DTSC CONCURRANCE
JACOBS ENGINEERING GROUP INC
TECHNICAL MEMORANDUM
DRAFT RESULTS OF STAGE B GROUNDWATER INVESTIGATION
TECHNICAL MEMORANDUM 12 OUs >-i
JACOBS ENGINEERING GROUP INC
TECHNICAL MEMORANDUM
DRAFT JANUARY 1993 GROUNDWATER SAMPLING RESULTS OUs
TECHNICAL MEMORANDUM 15
JACOBS ENGINEERING GROUP INC
NFEC. MCLB. RWOCB. DTSC. S US EPA
CORRESPONDENCE
GROUNDWATER
REQUEST FOR COMMENTS TO DRAFT JANUARY 1993 GROUNDWATER
SAMPLING RESULTS GUI AND 2 TECHNICAL MEMO TM-0015. NOVEMBER
9.1992 (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
TECHNICAL MEMORANDUM
SUBMITTAL OF DRAFT GROUNDWATER SAMPLING RESULTS OPERABLE
UNITS 1 AND 2 TECHNICAL MEMORANDUM 15 DATED NOVEMBER 9, 1993
MARINE CORPS LOGISTICS BASE
COMMENTS, EPA
COMMENTS, DTSC
REVIEW OF THE DRAFT PHASE I REMEDIAL INVESTIGATION REPORTS
OUs UNITS 3S4, DATED 9/93. DRAFT PHASE II RI/FS OUS 3S4 FIELD
SAMPLING PLAN, TECHNICAL MEMORANDUM 10. DATED 5/93, AND
REVIEW OF THE DRAFT PHASE II RI/FS SAMPLING WORK PLAN FOR OUs
152, DATED 10/93
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
PROJECT NOTE 330 - TECHNICAL REVIEW COMMITTEE MEET NOTES
HELD ON 12/08/93 AT THE MARINE CORPS LOGISTICS BASE BARSTOW
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
COMMENTS, RWQCB
REVIEW OF RI/FS DRAFT PHASE 2 FIELD SAMPLING (WORK) PLAN,
DATED 10/93, AND REQUESTS INFORMATION BY 01/16/94
REGIONAL WATER QUALITY CONTROL
BOARD
NAVAL FACILITIES ENGWEERING
COMMAND
PLAN, HEALTH S SAFETY
HEALTH AND SAFETY PLAN FOR GROUNDWATER EXTRACTION PILOT
STUDIES AT YERMO ANNEX
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE, REQUEST
REQUEST FOR CONCURRENCE TO CONDUCT AN AQUIFER PUMP TEST
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
CORRESPONDENCE APPROVAL
WRITTEN APPROVAL TO CONDUCT AN AQUIFER PUMP TEST WITH
GUIDELINES
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
MEETING NOTES
PROJECT NOTE 338 - REMEDIAL PROJECT MANAGERS' MEETING HELD
ON 02/04/94, RE PERSONNEL CHANGES, CHEMICALS OF CONCERN,
PILOT GROUNDWATER EXTRACTION STUDY, AGENCY COMMENTS ON
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, GROUNDWATER
PROJECT NOTE 334 - QUARTERLY SAMPLING 5 OFF-SITE WELLS
DRILLING, INVESTIGATION DERIVED WASTE EFFLUENT WATER
NFEC 5 MCLB
MEETING NOTES
PROJECT NOTE 345- REMEDIAL PROJECT MANAGERS' MEETING HELD
ON 3/10/-11/94. PCB STORAGE AREA, FUNDING, PROGRAM SCHEDULE.
PHASE 2 PLANNING, YERMO REMOVAL ACTION STUDY, RCRA FACILITY
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
COMMENTS RESPONSE
PROJECT NOTE 340 - RESPONSE TO DTSC, EPA AND RWQCB
COMMENTS ON THE DRAFT PHASE 2 FIELD SAMPLING WORK PLAN.
REMEDIAL INVESTIGATION/FEASIBLITY STUDY FOR OUs 1/2
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
TECHNICAL MEMORANDUM
PRELIMINARY DRAFT APRIL 1993 GROUNDWATER SAMPLING RESULTS
FOR OUs 1 S 2, TECHNICAL MEMORANDUM 24
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
EPA REQUEST FOR 30-DAY EXTENSION FOR REVIEW OF MCLB DRAFT
OU1S2 RESULTS OF STAGES GROUNDWATER INVESTIGATION TECH
MEMO-0012
AUTHOR ADDRESSEE
US ENVIRONMENTAL PROTECTION AGENCY MARIN CORPS LOGISTICS AGENCY
COMMENTS, EPA
COMMENTS, EPA
REVIEW OF QUARTERLY GROUNDWATER SAMPLING RESULTS FOR
JUNE AND SEPTEMBER 1992 AND JANUARY 1993. TECHNICAL
MEMORANDUM 11, 13, AND 15
COMMENTS ON GROUNDWATER SAMPLING RESULTS AS DESCRIBED IN
DRAFT TECHNICAL MEMORANDUMS 11, 13, AND 15, OUS 1 AND 2 MCLB
BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
COMMENTS, EPA
COMMENTS, EPA
REVIEW OF DRAFT RESULTS OF STAGE 8 GROUNDWATER
INVESTIGATION, TECHNICAL MEMORANDUM 12
REVIEW OF DRAFT PHASE 2 FIELD SAMPLING (WORK) PLAN
US ENVIRONMENTAL PROTECTION AGENCY
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, QAPP
REVISED FINAL QUALITY ASSURANCE PROJECT PLAN FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY
PROJECT NOTE 347 - RESULTS OF A LITERATURE SEARCH RE
APPROPRIATENESS OF USING CENTRIGUGAL SUBMERSIBLE PUMPS
FOR SAMPLING GROUNDWATER AT MCLB BARSTOW
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
NFEC 5 MCLB
COMMENTS, DTSC
REVIEW OF THE DRAFT RESULTS OF STAGE 8 GROUNDWATER
INVESTIGATION, TECHNICAL MEMORANDUM 12, DATED 11/9/93, 5 THE
DRAFT GROUNDWATER EXTRACTION PILOT STUDY FIELD WORK PLAN.
DEPT OF TOXIC SUBSTANCES CONTROL NAVAL FACILITIES ENGINEERING
COMMAND
MEETING NOTES
SAMPLING PLAN
REMEDIAL PROJECT MANAGERS' MEETING HELD ON 04/13/94 - 04/14/94
DRAFT FINAL PHASE II FIELD SAMPLING (WORK) PLAN FOR OU 1/2
(REGIONAL GROUNDWATER)
NAVAL FACILITIES ENGINEERING COMMAND NFEC, MCLB, RWQCB, DTSC, S, US
MARINE CORPS LOGISTICS BASE VARIOUS AGENCIES
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PLAN RI/FS WORK
REMEDIAL INVESTIGATION/FEASIBILITY STUDY DRAFT FINAL PHASE 2
FIELD SAMPLING (WORK) PLAN FOR OUs 152, (Vol 1 of 2)
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWOCB, DTSC S, US EPA
PLAN, SAMPLING S ANALYSIS
PROJECT NOTE 350 - DRAFT FINAL PHASE 2 FIELD SAMPLING WORK
PLAN FOR OUs 1/2, PROGRAM CHANGES BASED ON REGULATORY
AGENCY COMMENTS
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
REMEDIAL INVESTIGATION/FEASIBILITY STUDY DRAFT FINAL PHASE
FIELD SAMPLING (WORK) PLAN FOR OUs 1/2, (VOL 2 of 2)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
PLAN, SAMPLING S, ANALYSIS
PROJECT NOTE 353 COMPARISON OF THE CHEMICAL OF CONCERN
LISTS OF ANALYTES IN THE SAMPLING S, ANALYSIS PLAN VS THE
QUALITY ASSURANCE PROJECT PLAN
JACOBS ENGINEERING GROW INC
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, PILOT STUDY
PROJECT NOTE 15 - DESIGN PACKAGE SUMMARY OF WORK FOR THE
AIR SPARGE/SOIL VAPOR EXTRACTION PILOT STUDY
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
MEETING NOTES
PROJECT NOTE 39 - REMEDIAL PROJECT MANAGERS' MEETING NOTES
HELD ON 5/11/-12/94. DISCUSSIONS ON OUs 5 S 6 PHASE 1 RISK
ASSESSMENT, VADOSE ZONE MODEL, PROJECT SCHEDULE, SITE
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
COMMENTS, EPA
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
REVIEW Of THE DRAFT GROUNDWATER EXTRACTION PILOT STUDY
FIELD PLAN, DATED 3/9/94, FINDS IT ACCEPTABLE 5 OFFERS
SUGGESTIONS FOR IMPROVEMENTS
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
REVIEW OF THE PRELIMINARY DRAFT GROUNDWATER 04/93 SAMPLING
RESULTS FOR OUs 152. TECHNICAL MEMORANDUM 24. DATED 3/94
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, QAPP
ADDENDUM 1 TO PHASE 2 REMEDIAL INVESTIGATION FEASIBILITY
STUDY DRAFT QUALITY ASSURANCE PROJECT PLAN
JACOBS ENGINEERING GROUP INC NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS RESPONSE
COMMENTS RESPONSE
COMMENTS RESPONSE
CORRESPONDENCE
DATE
6/8/94
PROJECT NOTE 354 - RESPONSES TO EPA COMMENTS ON THE DRAFT
PHASE 2 FIELD SAMPLING PLAN FOR OUS 1 S 2, DATED 4/29/94
PROJECT NOTE 355 - RESPONSE TO EPA COMMENTS ON THE DRAFT
GROUNDWATER INVESTIGATION, STAGE B, OUS 1/2, TECHNICAL
MEMORANDUM 12, AND THE DRAFT GROUNDWATER SAMPLING
PROJECT NOTE 7 - RESPONSE TO AGENCY COMMENTS ON THE DRAFT
GROUNDWATER SAMPLING RESULTS FOR OUs 1 5 2, TECHNICAL
MEMORANDUM 24, DATED 04/93
APPROVAL OF RIGHT-OF-WAY RESERVATION CACA 31081 (W/ATTACH)
AUTHOR ADDRESSEE
JACOBS ENGINEERING GROUP INC NFEC, MCLB, RWQCB, DTSC, 5 US EPA
JACOBS ENGINEERING GROUP INC NFEC, MCLB, RWQCB, DTSC, 5 US EPA
JACOBS ENGINEERING GROUP INC NFEC, MCLB, RWQCB, DTSC, f, US EPA
US DEPARTMENT OF THE INTERIOR SOUTHWEST DIVISION
OP UNIT
1,2
MEETING NOTES
CORRESPONDENCE
MEETING NOTES
CORRESPONDENCE, MEMO
MEETING NOTES
CORRESPONDENCE
PROJECT NOTE 47 - RPMs MEETING NOTES HELD 8/3-4/94 RE TM 23,
VPB, GROUNDWATER SAMPLING 5 CLEAN-UP SCHEMATIC INFRARED
THERMAL ANOMALIES, DLM, BASEWIDE SURVEY, INITIAL ASSESSMENT
REQUEST FOR EXTENSION ON SUBMITTAL OF OU2 DRAFT RI REPORT
DIFFERENCES BETWEEN EPA AND MCLB BARSTOW LISTS IDENTIFYING
COMPOUNDS OF CONCERNS
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
JACOBS ENGNEERING GROUP INC
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
JACOBS ENGNEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
FEDERAL FACILITIES SECTION
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
SOUTHWEST DIVISION
NFEC 5 MCLB
1,2,3,4,5,6
AGENDA FOR TECHNICAL REVIEW COMMITTEE MEETING OF 15
DECEMBER 1994
MARINE CORPS LOGISTICS BASE BARSTOW SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
SUBJECT
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER
SAMPLING AND INSTALLING WELL ON PRIVATE PROPERTY, AMEND
RIGHT-OF-WAY RESERVATION CACA 31081 TO INCLUDE ACCES TO
ADDRESSEE
BUREAU OF LAND MANAGEMENT
CORRESPONDENCE
US DEPT OF INTERIOR
SOUTHWEST DIVISION
MEETING NOTES
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
MCLB BARSTOW COMMUNITY UPDATE, ISSUE #2, FOR THE IRP
ACTIVITIES S, ANNOUNCING A PUBLIC MEETING/OPEN HOUSE
SCHEDULED FOR 1/19/95
JACOBS ENGINEERING GROUP INC
RELATIONS MAILING LIST
PUBLIC RELEASE S, IRP COMMUNITY
DRAFT ENGINEERING EVALUATION/COST ANALYSIS FOR OU 1, YERMO
ANNEX (VOL. 1 OF 2)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
DRAFT ENGINEERING EVALUATION/COST ANALYSIS FOR OU 1, YERMO
ANNEX (VOL 2 OF 2)
JACOBS ENGINEERING GROUP INC
MEETING NOTES
PROJECT NOTE 74 - REMEDIAL PROJECT MANAGERS' MEETING NOTES
HELD ON 01/18-20/95, RE RECORDS SEARCH, ABBREVIATED
FEASIBILITY STUDY, BUDGET, S, EE/CA
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
COMMENTS, RWQCB
REVIEW ON BACKGROUND SOILS INVESTIGATION, TECHNICAL
MEMORANDUM 23, DATED 9/26/94, NO COMMENTS
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE, REQUEST
REQUESTS IDENTIFICATION OF POTENTIAL STATE CHEMICAL S,
LOCATION-SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS FOR OUs 1 THROUGH 6
NAVAL FACILITIES ENGINEERING COMMAND DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE
REQUEST FOR 30-DAY EXTENSION FOR SUBMITTING REVIEW
COMMENTS ON MCLB DOCUMENTS
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
COMPLETION OF TASK Bl (GEOLOGIC MAP OF YERMO ANNEX AND
VICINITY). B2(FAULT TRENCHING) AND A (DIRECT CURRENT
RESISTIVITY STUDY)
AUTHOR
US DEPT OF INTERIOR
ADDRESSEE
SOUTHWEST DIVISION
COMMENTS, EPA
52- 0111
REVIEW ON THE DRAFT ENGINEERING EVALUATION/COST ANALYSIS
FOR OU 1, YERMO ANNEX (2 VOLS). FINDS THE DOCUMENT GENERALLY
ACCEPTABLE. HOWEVER, THERE ARE SOME INCONSISTENCIES IN THE
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
MEETING NOTES
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, WATER QUALITY
PROJECT NOTE 31 - BACKGROUND WATER QUALITY DETERMINATION
AND ITS IMPACT ON CONCEPTUAL REMEDIAL DESIGN AT OU 1
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, DTSC
INTERNAL REVIEW OF THE DRAFT ENGINEERING EVALUATION/COST
ANALYSIS FOR OU 1, REMOVAL ACTION, PRIMARY REVIEW OF
GEOLOGICAL PORTION. ATTACHMENT TO DISC'S LETTER DATED 4/25/95
DEPT OF TOXIC SUBSTANCES CONTROL DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE,
GROUNDWATER
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER
SAMPLING AND INSTALLING WELL ON PRIVATE PROPERTY
SOUTHWEST DIVISION
H WINKERLING
CORRESPONDENCE
REQUEST FOR RE-EVALUATION OF FUNDING PLANS AND
JUSTIFICATION FOR NOT PROVIDING FUNDING IN FY 95 FOR OU1
CLEANUP
REGIONAL WATER QUALITY CONTROL SOUTHWEST DIVISION
BOARD
CORRESPONDENCE
PROPOSED REMOVAL ACTION FOR OU 1, CONCERNS WITH SIGNIFICANT
DELAYS IN THE REMOVAL ACTION FOR OU 1 MAY RESULT IN ADVERSE
IMPACTS TO DOWNGRADIENT RECEPTORS (WATER SUPPLY WELLS)
REGIONAL WATER QUALITY CONTROL NAVAL FACILITIES ENGINEERING
BOARD COMMAND
COMMENTS, RWQCB
REVIEW ON THE DRAFT EE/CA FOR OU 1, DATED 01/17/95 f, THE
PRELIMINARY DRAFT CONCEPTUAL DESIGNS DATED 02/14/95. FINDS IT
MAY NOT BE SUITABLE AS THE FINAL REMEDIAL SOLUTION, EE/CA
REGIONAL WATER QUALITY CONTROL DEPT OF TOXIC SUBSTANCES
BOARD CONTROL
CORRESPONDENCE
DTSC REQUEST FOR ADDITIONAL INFORMATION RE ARARS ADDECTING
THE PROPOSED UPCOMING CERCLA ACTIONS
DEPT OF TOXIC SUBSTANCE CONTROL MCLS OU 1-6 MAILING LIST
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
GROUNDWATER
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER
SAMPLING AND INSTALLING WELL ON PRIVATE PROPERTY
ADDRESSEE
MR AND MRS SILER
COMMENTS, DTSC
CORRESPONDENCE, PERMIT
REVIEW ON THE DRAFT EE/CA FOR OU 1, DATED 01/17/95, RECOMMEND
THE DRAFT BE APPROVED WITH MINOR CHANGES
RE APPROVAL FOR THREE NEW MONITORING WELLS AND ACCESS
ROADS ON BLM PROPERTY (REF LETTER DATED APRIL 11, 995 TO BLM)
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT - COUNTY SURVEYOR, SAN
BERNARDINO
NAVAL FACILITIES ENGINEERING
COMMAND
SOUTHWEST DIVISION
CORRESPONDENCE
GROUNDWATER SAMPLING RESULTS OU1 THROUGH 6, RI REPORTS -
SAMPLE TABLE FORMATS ATTACHED
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS, RWQCB
5 2 - 0149
INTERNAL MEMORANDUM RE THE NEED TO INCLUDE GROUNDWATER
SAMPLING RESULT TABLES IN REMEDIAL INVESTIGATION REPORTS FOR
OUs 1 THROUGH 6
REGIONAL WATER QUALITY CONTROL
BOARD
CORRESPONDENCE
CONCERN ABOUT IMPACT OF REDUCTIONS IN DoD CLEANUP PROGRAM
FOR FY-95 AND FUTURE
DEPT OF TOXIC SUBSTANCE CONTROL
OFFICE OF UNDERSECRETARY OF
DEFENSE
CORRESPONDENCE
GROUNDWATER
REQUEST PERMISSION TO CONDUCT EXPLORATORY GROUNDWATER
SAMPLING ON BUREAU OF LAND MGMT PROPERTY
SOUTHWEST DIVISION
COUNTY OF SAN BERNADINO
CORRESPONDENCE, RESPONSE
RESPONSE TO LETTER DATED 04/13/95 EXPRESSING CONCERN OVER
THE DELAYS IN STARTING REMOVAL ACTION
NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL
BOARD
PLAN, FIELD SAMPLING
PROJECT NOTE 39 - DESCRIPTION 5 RATIONALE FOR ADDITIONAL FIELD
WORK ON OUs 152
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE
AGREES WITH RWQCB'S SUGGESTION TO RESAMPLE THE TWO
DOWNGRADRADIENT WELLS AT OU 1 REMOVAL ACTION
NAVAL FACILITIES ENGINEERING COMMAND REGIONAL WATER QUALITY CONTROL
BOARD
-------
MARCH 30, 1998
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS EPA
DATE
5/31/95
REVIEW OF PROJECT NOTE 31, BACKGROUND WATER QUALITY
DETERMINATION. US EPA DOES NOT CONCUR WITH CONCLUSIONS
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
OP UNIT
1
CORRESPONDENCE, COMMENT:
TRANSMITTAL OF REVISION 1 - MINUTES OF RPM MEETING HELD 17
AND 18 MAY 1995 IN MCLB BARSTOW
SOUTHWEST DIVISION
DTSC, US EPA RWQCB, MCLB
COMMENTS RESPONSE
PROJECT NOTE 32 - RESPONSE TO RWQCB'S COMMENTS ON EFFECTS
OF GROUNDWATER CONTAMINATION AT CAOC 26, OU 1 DRAFT
ENGINEERING EVALUATION/COST ANALYSIS
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
REMOVAL RESPONSE,
CONCEPTUAL DESIGN
FINAL CONCEPTUAL DESIGN f, COST ESTIMATE FOR OU 1, YERMO
ANNEX, REMEDIATION SYSTEMS, REVISION 1
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, FIELD SAMPLING
PROJECT NOTE 43 - REVISION #1 TO PROJECT NOTE 39 DATED 5/30/95
DESCRIPTION f, RATIONALE FOR ADDITIONAL FIELD WORK FOR OUS 1 5 2
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S, US EPA
COMMENTS, RWQCB
REVIEW OF PROJECT NOTE 31, BACKGROUND WATER QUALITY
DETERMINATION AT OU 1. ATTACHMENT TO DISC'S LETTER DATED
6/14/95
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS, DTSC
INTERNAL REVIEW OF PROJECT NOTE 31, DATED 4/4/95
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE
FINAL CONCEPTUAL DESIGN AND COST ESTIMATE FOR YERMO ANNEX
OU 1 REMEDIATION SYSTEMS
MARINE CORPS LOGISTICS BASE
COMMENTS, DTSC
REVIEW OF PROJECT NOTE 31, BACKGROUND WATER QUALITY
DETERMINATION AT OU 1
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, DTSC
INTERNAL REVIEW OF PROJECT NOTE 31, BACKGROUND WATER
QUALITY DETERMINATION AT OU 1, DATED 4/5/95
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT OF TOXIC SUBSTANCES
CONTROL
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, REMEDIAL
INVESTIGATION
DATE
6/15/95
SUBJECT
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 5 2, (VOL 1 OF 10)
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB, DTSC, f, US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 5 2, APPENDIX
(VOL 2 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDIX B
(VOL 3 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 5 2, APPENDICES.
C S D (VOL 4 OF 10)
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDIX E.
PART 1 (VOL 5 OF 10)
JACOBS ENGINEERING GROUP INC
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDIX E.
PART 2 (VOL 6 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 5 2, APPENDIX E.
PART 3 (VOL 7 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDIX E.
PART 4 (VOL 8 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDIX E.
PART 5 (VOL 9 OF 10)
JACOBS ENGINEERING GROUP INC
REPORT, REMEDIAL
INVESTIGATION
DRAFT REMEDIAL INVESTIGATION REPORT FOR OUs 1 S 2, APPENDICES
F, G, H, S I (VOL 10 OF 10)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
ARARS
DATE
6/19/95
RESPONSE TO REQUEST FOR APPLICABLE OR RELEVANT S,
APPROPRIATE REQUIREMENTS FOR MCLB
AUTHOR
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE,
GROUNDWATER
CONDUCT Of GROUNDWATER SAMPLING TO EVALUATE QUALITY OF
GROUNDWATER IN OFF-BASE WELLS NEAR MCLB FROM AUGUST 15
THRU SEPTEMBER 30, 1995
SOUTHWEST DIVISION
SID HODGES
CORRESPONDENCE,
GROUNDWATER
CONDUCT OF GROUNDWATER SAMPLING TO EVALUATE QUALITY OF
GROUNDWATER IN OFF-BASE WELLS NEAR MCLB FROM AUGUST 15
THRU SEPTEMBER 30, 1995
SOUTHWEST DIVISION
REVIEW OF THE OU 1 PRELIMINARY DRAFT FINAL ENGINEERING
EVALUATION/COST ANALYSIS, DATED 6/9/95
NAVAL FACILITIES ENGINEERING
COMMAND
NOTIFICATION OF THE DISCOVERY OF CONTAMINANTS IN AN OFF-BASE
MONITORING WELL (Y15-1) EAST OF YERMO ANNEX, CONTAINS MAP
MARINE CORPS LOGISTICS BASE
MEETING NOTES
JACOBS ENGINEERING GROUP INC
PUBLIC COMMUNICATION, NEWS
ARTICLE
"OFF-BASE GROUNDWATER MONITORING WELL NEAR YERMO ANNEX
REVEALS CONTAMINATION" FOR OU 1
MCLB BARSTOW TODAY
PUBLIC RELEASE
PUBLIC COMMUNICATION, NEWS
ARTICLE
BARSTOW DESERT DISPATCH
PUBLIC RELEASE
DRAFT FINAL ENGINEERING EVALUTATION/COST ANALYSIS FOR OU 1,
YERMO ANNEX
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
REPORT, ANALYTICAL DATA
RESULTS OF WATER SAMPLES SHOW THAT VOLATILE ORGANIC
COMPOUNDS FOUND IN THE WATER ARE SLIGHTLY BELOW, OR AT THE
MCLs FOR DRINKING WATER, WILL CONTINUE TO MONITOR THE WELL
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT #4
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REMOVAL ACTION
DRAFT OU 1 ACTION MEMORANDUM REMOVAL ACTION NON-TIME
CRITICAL
OP UNIT
1
PUBLIC COMMUNICATION, NEWS
ARTICLE
"CONTAMINANTS FOUND IN YERMO WELL" OU 1
VICTORVILLE DAILY PRESS
PUBLIC RELEASE
PUBLIC COMMUNICATION, PRES
RELEASE
"TWO YERMO RESIDENTIAL WELLS INVESTIGATED FOR
CONTAMINATION WERE DISCOVERED TO CONTAIN TRACES Of
CLEANING SOLVENTS"
MARINE CORPS LOGISTICS BASE
PUBLIC RELEASE
INTERNAL REVIEW OF DRAFT REMEDIAL INVESTIGATION REPORT FOR
OUs 152
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
REPORT, REMEDIAL
INVESTIGATION
DRAFT FEASIBILITY STUDY REPORT FOR OUs 1 S 2 (VOL 1 OF 2)
JACOBS ENGINEERING GROUP INC
REPORT, REMEDIAL
INVESTIGATION
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, 5 US EPA
COMMENTS, EPA
REVIEW OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY DRAFT
REMEDIAL INVESTIGATION REPORT FOR OUs 1 5 2, DATED 06/15/95
US ENVIRONMENTAL PROTECTION AGENCY
COMMAND
NAVAL FACILITIES ENGINEERING
CORRESPONDENCE
MONITORING WELL INSTALLATION WILL BEGIN AUGUST 28, 1995 BASED
ON PREVIOUS APPROVAL (PREVIOUSLY SIGNED ENTRY PERMIT
ENCLOSED) (W/0 ENCL)
MARINE CORPS LOGISTICS BASE
M/M DE WERFF
COMMENTS, DTSC
INTERNAL REVIEW OF MCLB DRAFT PROJECT NOTE ON STATISTICAL
ANALYSES, ATTACHMENT TO DISC'S LETTER DATED 8/28/95
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT OF TOXIC SUBSTANCES
CONTROL
INTERNAL REVIEW OF THE GEOPHYSICAL ASPECTS OF MCLB OUs 1 S, 2
REMEDIAL INVESTIGATION REPORT, DATED 06/15/95
DEPT OF TOXIC SUBSTANCES CONTROL
DEPT OF TOXIC SUBSTANCES
CONTROL
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS, DTSC
DATE
8/28/95
REVIEW OF THE DRAFT PROJECT NOTE FOR MCLB STATISTICAL
ANALYSIS ON GROUNDWATER METALS
AUTHOR
DEPT OF TOXIC SUBSTANCES CONTROL
ADDRESSEE
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, DTSC
REVIEW OF OUs 1 S 2 DRAFT REMEDIAL INVESTIGATION REPORT,
DATED 06/15/95
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
REMOVAL ACTION
PROJECT NOTE 58-EFFLUENT DISCHARGE MONITORING PROCEDURES
FOR THE OU 1 YERMO GROUNDWATER REMOVAL ACTION, REFER TO
CAT-DOC# 5 1-0144 FOR THE DOCUMENT (ATTACHMENT M)
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC. S US EPA
MEETING NOTES
MEETING NOTES
9/12/95 5 1-0145
PROJECT NOTE 100-RPMs MEETING NOTES HELD ON 09/12-13/95,RE
BACKGROUND METALS, HUMAN HEALTH RISK ASSESSMENT, RCRA
FACILITIES ASSESSMENT, SCHEDULE, PROPOSED PLAN OUs 3 5 4
PROJECT NOTE 101-REMEDIAL PROJECT MANAGERS' MEETING NOTES
HELD ON 09/12-13/95, RE OVERALL GOALS 5 OBJECTIVES OF THE
HUMAN HEALTH BASEWIDE BASELINE RISK ASSESSMENT
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC. 5 US EPA 1,2,3,4,5,6,7
NFEC, MCLB, RWQCB, DTSC. 5 US EPA 1,2,3,4,5,6
TECHNICAL ISSUES RAISED BY EPA COMMENTS ON GUI AND OU2 RI
REPORT
JACOBS ENGINEERING GROUP INC
VARIOUS AGENCIES
COMMENTS ON USEPA REVIEW OF MCLB BARSTOW EE/CA OU 1 DRAFT
FINAL REPORT DATED AUGUST 14, 1995
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
COMMENTS, EPA
MEMO, COMMENTS, REMOVAL
REMOVAL ACTION, MONITORING
PROCEDURES
REVIEW OF THE ENGINEERING EVALUATION/COST ANALYSIS FOR OU 1,
YERMO, DRAFT FINAL REPORT, DATED 06/14/95
COMMENTS ON DRAFT REMOVAL ACTION MEMO FOR MCLB OU1, DATED
SEPTEMBER 7, 1995
PROJECT NOTE 58-EFFLUENT DISCHARGE MONITORING PROCEDURES
FOR THE OU 1 YERMO GROUNDWATER REMOVAL ACTION
US ENVIRONMENTAL PROTECTION AGENCY
DEPT OF TOXIC SUBSTANCES CONTROL
JACOBS ENGINEERING GROUP INC
NAVAL FACILITIES ENGINEERING
COMMAND
JACOBS ENGINEERING GROUP
NFEC, MCLB, RWQCB, DTSC, S US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT FEASIBILITY STUDY
PROJECT NOTE 48-PROPOSED CLEANUP LEVELS FOR REMEDIATION
OF GROUNDWATER CONTAMINATION OUs 1 S, 2 DRAFT FEASIBILITY
STUDY TABLE OF CONTENTS
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
NFEC, MCLB, RWQCB, DTSC f, US EPA
OP UNIT
1,2
CORRESPONDENCE
ON-SCENE COORDINATOR'S REPORT FOR REMOVAL ACTION AT MCLB
BARSTOW OU 3 CAOC 34
DEPT OF TOXIC SUBSTANCE CONTROL
SOUTHWEST DIVISION
TEST RESULTS FROM WATER SAMPLES, TRACE AMOUNTS FOUND BUT
ARE NOT CONSIDERED HAZARDOUS TO HUMAN HEALTH
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT #1
REPORT, ANALYTICAL DATA
TEST RESULTS FROM WATER SAMPLES, TRACE AMOUNTS FOUND BUT
ARE NOT CONSIDERED HAZARDOUS TO HUMAN HEALTH
MARINE CORPS LOGISTICS BASE
OFF-BASE RESIDENT #2
MEETING NOTES
PROJECT NOTE 99-ACTION ITEMS FROM THE REMEDIAL PROJECT
MANAGERS' MEETING HELD ON 9/12-13/95
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCS, DTSC, 5 US EPA
CORRESPONDENCE
USEPA REQUEST FOR A 5 WORKING DAY EXTENSION TO THE COMMENT
PERIOD FOR MCLB REMEDIAL INVESTIGATION/FEASIBILITY STUDY
DRAFT FEASIBILITY STUDY REPORT OUs 1 AND 2 CROSS REFER! 5 3
US ENVIRONMENTAL PROTECTION AGENCY
SOUTHWEST DIVISION
REMOVAL ACTION
DRAFT FINAL ACTION MEMORANDUM FOR GROUNDWATER REMOVAL
ACTION FOR OU 1 AT THE YERMO ANNEX; NON-TIME CRITICAL
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
CORRESPONDENCE, REQUEST
REQUESTS A 5-DAY EXTENSION TO COMMENT PERIOD ON REMEDIAL
INVESTIGATION/FEASIBILITY STUDY DRAFT REPORT FOR OUs 1 S 2
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
2-0179 REVIEW OF THE DRAFT RI/FS REPORT FOR OU 1 5 2 DATED 8/15/95 US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS RESPONSE
5 3-0035 PROJECT NOTE 40-RESPONSE TO EPA'S COMMENTS ON THE DRAFT JACOBS ENGINEERING GROUP INC
FINAL OU 1 ENGINEERING EVALUATION/COST ANALYSIS DATED 09/15/95
NFEC, MCLB, RWQCB, DTSC, S US EPA
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS RESPONSE
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE OP UNIT
NFEC, MCLB, RWQCB, DTSC, f, US EPA 1,2,7,3,4
REMOVAL ACTION
FINAL ACTION MEMORANDUM FOR REMOVAL ACTION AT PRIVATE
RESIDENCES DOMESTIC WATER SUPPLY WELLS LOCATED EAST OF THE
YERMO ANNEX, TIME CRITICAL
MARINE CORPS LOGISTICS BASE
PUBLIC RELEASE
REPORT, RI/FS
DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY RI REPORT JACOBS ENGINEERING GROUP INC
OPERABLE UNITS 1 AND 2 REVISION 0.(VOL I.II S 10 REVISED FROM 87-
0004 DTD 6/15/95 DRFT VOL 1-10JAND VOL 11 S 12 ADDED TO VOLS
MARINE CORPS LOGISTICS BASE
REPORT, RI/FS
DRAFT FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY RI REPORT JACOBS ENGINEERING GROUP INC
OPERABLE UNITS 1 AND 2 VOLUME 12 OF 12 ADDENDUM APRIL 1995 GW
SAMPLING EVENT
MARINE CORPS LOGISTICS BASE
COMMENTS, DTSC
2-0125 REVIEW OF DRAFT FEASIBILITY STUDY REPORT FOR OUs 1 5 2
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
REPORT, TREATMENT SYSTEM
4-0065 PROJECT NOTE 63-DISCUSSION OF THE EFFECTS OF METALS ON THE
YERMO GROUNDWATER TREATMENT SYSTEM AT YERMO ANNEX
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCS, DTSC, S US EPA
8 1-0033 DTSC REQUEST FOR DELAY ON CONCURRENCE OF DRAFT FINAL
REMEDIAL INVESTIGATION FOR OUs 1 S 2, DATED 10/31/95
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
8 1-0042 PROPOSES AN EXTENSION FOR ALL REMAINING FEDERAL FACILITIES
AGREEMENT SUBMITTAL FOR OUs 1 5 2
US ENVIRONMENTAL PROTECTION
AGENCY
AGREEMENT, FEDERAL FACILITIES 11/15/95
8 1-0044 PROPOSES AN EXTENSION FOR ALL THE REMAINING FEDERAL FACILITY NAVAL FACILITIES ENGINEERING COMMAND
AGREEMENT SUBMITTAL FOR OUs 1 S 2
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE
8 1-0047 COMMENDS THE EXCELLENT WORK PERFORMED BY NFEC IN THE
RAPID EXECUTION OF A TIME-CRITICAL REMOVAL ACTION FOR OU 1
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE
AGREEMENT FEDERAL FACILITY 11/15/95
PROPOSAL TO EXTEND ALL REMAINING DELIVERABLES IN THE FEDERAL
FACILITIES AGREEMENT FOR OUs 1 5 2
AUTHOR
NAVAL FACILITIES ENGINEERING COMMAND
ADDRESSEE
US ENVIRONMENTAL PROTECTION
AGENCY
MEETING NOTES
PROJECT NOTE 80-NEW TEXT RE PROTECTIVENESS OF RESIDUAL
RISKS, RESPONSE TO ACTION ITEM til FROM THE 12/5-6/95 REMEDIAL
PROJECT MANAGER'S MEETING
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, f, US EPA
RESPONSE TO NFEC'S REQUEST TO EXTENDING ALL REMAINING
FEDERAL FACILITIES AGREEMENT SUBMITTALS FOR OUs 1 S 2, WILL
DETERMINE DATES PROPOSED AFTER THE RPM'S MEETING ON 12/5-6/95
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
AGREEMENT, FEDERAL FACILITY 11/30/95
RESPONSE TO NFEC'S REQUEST FOR AN EXTENSION OF THE FEDERAL
FACILITIES AGREEMENT REMAINING SUBMITTALS OF OUs 1 S 2.
EXTENSION IS GRANTED
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS RESPONSE
JACOBS ENGINEERING GROUP INC
NFEC, MCLB, RWQCB, DTSC, S US EPA
COMMENTS, EPA
SUBMITTAL OF ANY EPA COMMENTS ON THE REMEDIAL INVESTIGATION
FOR OUs 1 S 2 WILL FOLLOW THE 12/5-6/95 RPM'S MEETING
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
REMOVAL ACTION
GROUNDWATER EXTRACTION 5 TREATMENT SYSTEM, REMOVAL
ACTION PILOT STUDY FOR WAREHOUSE #2, NEBO MAIN BASE, REFER
TO CAT-DOC #5 1-0150 FOR THE DOCUMENT (ATTACHMENT J)
OHM REMEDIATION SERVICES CORP
NFEC, MCLB, RWQCB, DTSC, S US EPA
MEETING NOTES
DRAFT REMOVAL ACTION SITE CLOSEOUT REPORT, TIME-CRITICAL
REMOVAL ACTION AT PRIVATE RESIDENCES DOMESTIC WATER SUPPLY
WELLS LOCATED EAST OF THE YERMO ANNEX, MCLB BARSTOW DATED
PROJECT NOTE 104-TECHNICAL REVIEW COMMITTEE MEETING NOTES
CONDUCTED ON 12/5/95
OHM REMEDIATION SERVICES-IRVINE
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
TECHNICAL REVIEW COMMITTEE
MEMBERS
MEETING NOTES
PROJECT NOTE 102-ACTION ITEMS GENERATED FROM THE REMEDIAL
PROJECT MANAGER'S MEETING CONDUCTED ON 12/5-6/95
JACOBS ENGINEERING GROUP INC
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
MEETING NOTES
DATE
12/5/95
CAT-DOCt
5 1-0150
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE OP UNIT
NFEC, MCLB, RWQCB, DTSC, f, US EPA 1,2,3,4
ENFORCEMENT, BOARD ORDER
TENTATIVE AMENDMENT TO WASTE DISCHARGE REQUIREMENTS FOR
YERMO ANNEX DOMESTIC WASTEWATER TREATMENT FACILITY, BOARD
ORDERS #6-94-24Al s, 6-94-29
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION REPORT FOR
OUs 152 GENERALLY ACCEPTS THE REPORT, DTSC WILL REQUIRE
SAMPLING OF THE MONITORING WELLS AROUND THE CONTAMINATION
DEPT OF TOXIC SUBSTANCES CONTROL
NAVAL FACILITIES ENGINEERING
COMMAND
COMMENTS, EPA
REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION REPORT FOR
OUs 1 S 2, APPROVAL IS CONTINGENT ON MONITORING OF
GROUNDWATER
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
PLAN, CONSTRUCTION
FINAL CONSTRUCTION PLAN FOR GROUNDWATER EXTRACTION 5
MONITORING WELLS, GROUNDWATER REMEDIATION S RECHARGE
SYSTEM FOR OU 1
OHM REMEDIATION SERVICES CORP
NFEC S MCLB
FINAL CONSTRUCTION PLAN FOR OU 1, GROUNDWATER REMEDIATION
SYSTEM
OHM REMEDIATION SERVICES CORP
NFEC, MCLB, RWQCB, DTSC, S US EPA
PLAN, ENVIRONMENTAL
PROTECTION
FINAL ENVIRONMENTAL PROTECTION PLAN, GROUNDWATER
REMEDIATION S RECHARGE SYSTEM FOR OU 1, NOTE REFER TO CAT-
DOC #4 9-0002 "FINAL CONSTRUCTION PLAN FOR GROUNDWATER
OHM REMEDIATION SERVICES CORP
NFEC S, MCLB
PLAN, HEALTH S SAFETY
FINAL SITE HEALTH S SAFETY PLAN, REV 1. GROUNDWATER
REMEDIATION S, RECHARGE SYSTEM FOR OU 1, NOTE REFER TO CAT-
DOC #4 9-0002 "FINAL CONSTRUCTION PLAN FOR GROUNDWATER
OHM REMEDIATION SERVICES CORP
NFEC 5 MCLB
PLAN, QUALITY CONTROL
FINAL CONTRACTOR QUALITY CONTROL PLAN ADDENDUM,
GROUNDWATER REMEDIATION 5 RECHARGE SYSTEM FOR OU 1, NOTE
REFER TO CAT-DOC #4 9-0002 "FINAL CONSTRUCTION PLAN FOR
OHM REMEDIATION SERVICES CORP
NFEC S MCLB
REPORT, DNAPL
DENSE NON-AQUEOUS PHASE LIQUIDS (DNAPL) EVALUATION FOR
CAOCs 6, 7, 23, 26, 5 35
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS, EPA
DATE
1/26/96
CAT-DOCt SUBJECT
ADDRESSEE
US ENVIRONMENTAL PROTECTION AGENCY NAVAL FACILITIES ENGINEERING
COMMAND
OP UNIT
1,5
CORRESPONDENCE
AGREEMENT. FEDERAL FACILITY
REPORT, GROUNDWATER
5 1-0232 TRANSMITTAL OF REVISED PROJECT SCHEDULE FOR FFA DOCUMENTS
8 1-0050 FEDERAL FACILITIES AGREEMENT SCHEDULE UPDATE
4-0087 PROJECT NOTE 82-SUMMARY OF GROUNDWATER CONTAMINANT FATE
5 TRANSPORT MODELING RESULTS FOR OUs 1 5 2
MARINE CORPS LOGISTICS BASE BARSTOW CRWQCB, US EPA, DTSC.
MARINE CORPS LOGISTICS BASE US EPA, DTSC, 5 RWQCB
JACOBS ENGINEERING GROUP INC NFEC, MCLB, RWQCB, DTSC, 5 US EPA
1,2,3,4
1,2,3,4
1,2
3-0046 COMMENTS ON OUs 1 AND 2 DRAFT FINAL REMEDIAL INVESTIGATION
REPORT AND DRAFT FEASIBILITY STUDY MCLB BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
5 2-0164 REVIEW OF THE DRAFT FINAL REMEDIAL INVESTIGATION REPORT S,
DRAFT FEASIBILITY STUDY, NEED MORE JUSTIFICATION TO SUPPORT
ALTERNATIVES FOR OUs 1 S 2
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
REPORT, COMMENTS
5 2-0281 RWQCB COMMENTS REVIEW MEETING ON OU 1 AND 2 DRAFT FS
REGIONAL WATER QUALITY CONTROL
BOARD
TRANSMISSION OF COMMENTS ON SAMPLE COLLECTION AND
ANALYSIS PLAN OF THE SYSTEM START-UP AND TESTING PLAN, GW
EXTRAC ETC
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
COMMENTS, EPA
2-0166 REVIEW OF THE SAMPLE COLLECTION S ANALYSIS PLAN OF THE
SYSTEM START-UP f, TESTING PLAN, GROUNDWATER EXTRACTION S
TREATMENT REMOVAL ACTION PILOT STUDY, WAREHOUSE 2, NEBO
US ENVIRONMENTAL PROTECTION AGENCY
NAVAL FACILITIES ENGINEERING
COMMAND
CORRESPONDENCE,
GROUNDWATER
5 2-0280 COMMENTS TO NOVEMBER 1995 SYSTEM STARTUP AND TESTING PLAN
FOR OU2
REGIONAL WATER QUALITY CONTROL
BOARD
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE, COMMENTS
COMMENTS TO FUNDING AND TARGETED SCHEDULES FOR
COMPLETING SOME PROJECTS AT MCLB AND MCMWTC
REGIONAL WATER QUALITY CONTROL
BOARD
ADDRESSEE
SOUTHWEST DIVISION
OP UNIT
1,2
REPORT, DNAPL
PROJECT NOTE 89-EVALUATION OF DENSE NON-AQUEOUS PHASE
LIQUIDS FOR CAOCs 6, 7, 23, 26, f, 35 PREPARED BY EPA DATED l/2f
JACOBS ENGINEERING GROUP INC
/96
NFEC, MCLB, RWQCB, DTSC, S US EPA
REQUEST FOR AN EXTENSION OF ALL REMAINING FFA SUBMITTALS OF
OUs 1,2,3, S 4 AT MCLB
MARINE CORPS LOGISTICS BASE
SOUTHWEST DIVISION
CORRESPONDENCE, FFA,
SCHEDULE
MCLB REQUEST EXTENSION FOR ALL FFA SUBMITTALS OF OUS 1, 2, 3,
AND 4
MARINE CORPS LOGISTICS BASE
JACOBS ENGINEERING GROUP INC.
REPORT, TCRA
FINAL ON-SITE COORDINATOR REPORT-TCRA AT PRIVATE
RESIDENCES DOMESTIC WATER SUPPLY WELLS LOCATED EAST OF
YERMO ANNEX
OHM REMEDIATION SERVICES-IRVINE
MARINE CORPS LOGISTICS BASE
FINAL ON-SITE COORDINATOR REPORT-TIME-CRITICAL REMOVAL
ACTION AT PRIVATE RESIDENCES DOMESTIC WATER SUPPLY WELLS
LOCATED EAST OF THE YERMO ANNEX, MCLB BARSTOW
OHM REMEDIATION SERVICES-IRVINE
SOUTHWEST DIVISION
COMMENTS ON OU 2 NORTH NEBO PLUME GROUND WATER
EXTRACTION AND TREATMENT REMOVAL ACTION PILOT STUDY
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
FINAL CONSTRUCTION PLAN, INSTALLATION OF A GROUNDWATER
EXTRACTION, TREATMENT S, RECHARGE SYSTEM
OHM REMEDIATION SERVICES CORP
NFEC, MCLB, RWQCB, DTSC, S, US EPA
CORRESPONDENCE
MCLB REQUEST FOR EXTENSION FOR EXISTING FEDERAL FACILITY
AGREEMENT FOR OUs 1, 2, 3, S 4
US ENVIRONMENTAL PROTECTION AGENCY
MARNE CORPS LOGISTIC BASE
CORRESPONDENCE
EXTENSION OF THE FFA SCHEDULE OF OUs 1, 2, 3, AND 4 AT MCLB
BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
MARINE CORPS LOGISTIC BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
RESPONSE TO REQUEST
CAT-DOCt SUBJECT
5 2-0192 EXTENSION OF THE FFA SCHEDULE FOR OPERABLE UNITS 1, 2, 3 AND 4
AT MCLB BARSTOW
DEPARTMENT OF TOXICS SUBSTANCES
CONTROL
ADDRESSEE
MCLB BARSTOW
MEETING NOTES
9 4-0007 MEETING NOTES, SPECIFICALLY REMEDIAL PROJECT MANAGER'S
MEETING HELD ON MARCH 7, f, 8, 1996 IN SAN FRANCISCO
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
CORRESPONDENCE
13 5-0001 RWQCB APPROVAL OF EXTENSION FOR REMAINING FFA SUBMITTALS
FOR OU 1, 2,3, S 4
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTIC BASE
CORRESPONDENCE
5/22/96 5 2-0235 FFA EXTENSION LETTER FROM CRWQCB ON OUs 1, 2, 3, 5 4
REGIONAL WATER QUALITY CONTROL
BOARD
MCLB BARSTOW
MEETING NOTES
RESPONSE TO COMMENTS
5/29/96 9 4-0010 MEETING NOTES MAY 29-30, 1996 RPM MEETING IN BARSTOW
5/29/96 5 3-0057 RESPONSE TO AGENCIES COMMENTS ON THE OUS 1 AND 2 DRAFT FS
AND DRAFT FINAL RI REPORTS
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
1,2,3,4,5,6
1,2
CORRESPONDENCE, RESPONSE
5/29/96 5 3-0069 RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 DRAFT FS AND
DRAFT FINAL RI REPORTS
JACOBS ENGINEERING GROUP INC
CORRESPONDENCE
6/6/96 13 1-0008 REGARDING EXTENSION REQUEST RPM's ARE PRESENTLY ROUTING
FOR SIGNATURE AN ADDENDUM TO THE FFA FOR THE SCHEDULE
EXTENSION
MARINE CORPS LOGISTICS BASE
REGIONAL WATER QUALITY CONTROL
BOARD
6/6/96 5 1-0275 FFA DOCUMENT SCHEDULE EXTENSION CLARIFICATION
MARINE CORPS LOGISTICS BASE
VARIOUS AGENCIES
-0196 GROUNDWATER MONITORING PLAN AS PRESENTED AT THE REMEDIAL
PROJECT MANAGERS MEETING OF MAY 29 AND 30, 1996 AT BARSTOW
CALIFORNIA
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT-DOCf
CORRESPONDENCE COMMENT: 6/19/96 52- 0322
CRWQCB COMMENTS TO OU 7 DRAFT RCRA FACILITIES ASSESSMENT
REPORT
ADDRESSEE
REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE
BOARD
REPORT, RI/FS
MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY STUDY
FEASIBILITY STUDY REPORT OU 1 AND 2 DRAFT FINAL, REVISION 0.
DATED JUNE 21, 1996 (TRANSMITTAL ONLY)
JACOBS ENGINEERING GROUP INC.
SOUTHWEST DIVISION
CORRESPONDENCE
REQUEST FOR DELAY ON REVIEW OF DRAFT RCRA FACILITY
ASSESSMENT FOR MCLB BARSTOW
MARINE CORPS LOGISTICS BASE
SOUTHWEST DIVISION
CORRESPONDENCE
NOTE
PROJECT NOTE 103 - PILOT STUDY MONITORING PLAN DNA SCHEDULE
GROUNDWATER EXTRACTION SYSTEM OU 2 NEBO NORTHERN PLUME
(NRF-1)
JACOBS ENGINEERING GROUP INC. SOUTHWEST DIVISION
COMMENTS ON MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY
STUDY DRAFT FINAL FEASIBILITY STUDY REPORT 01} 1 H 2
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
PROJECT NOTE No 102/CTO 298 REGARDIING MCLB BARSTOW
OPERABLE UNITS 1 AND 2 TECHNICAL AND ECONOMICAL FEASIBILITY
(TEF) OF GROUNDWATER CLEANUP
JACOBS ENGINEERING GROUP INC. SOUTHWEST DIVISION
COMMENTS ON DRAFT FINAL FS REPORT OUS 1 AND 2, AND OUS 5 AND
6
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
CORRESPONDENCE, RESPONSE 8/7/96 5 3 - 0067
RESPONSE TO USEPA NATIONAL RISK MANAGEMENT RESEARCH
LABORATORY COMMENTS ON NATURAL ATTENUATION FOR OUS 1 AND
2, DATED MAY 6, 1996
JACOBS ENGINEERING GROUP, INC. SOUTHWEST DIVISIION
FINAL CHEMICAL DATA ACQUISITION PLAN, GROUNDWATER
REMEDIATION AND RECHARGE SYSTEM OU 1, YERMO ANNEX MCLB
BARSTOW
OHM REMEDIATION SERVICES-SAN DIEGO SOUTHWEST DIVISION
MEETING MINUTES
JACOBS ENGINEERING GROUP INC. SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
CORRESPONDENCE
PROJECT NOTE NO 105
RESPONSE TO COMMENTS
PROPOSED PLAN
CORRESPONDENCE
5 3 - 0055
10/1/96 95- 0065
10/4/96 52- 0211
USEPA REVIEW OF YERMO ANNEX OU 1 DRAFT GROUNDWATER
MONITORING PLAN
USEPA REVIEW OF MCLB CALIFORNIA DRAFT RCRA FACILITY
ASSESSMENT REPORT
COMMENTS ON REVIEW OF YERMO ANNEX OU 1 DRAFT
GROUNDWATER MONITORING PLAN
CTO 298 PROJECT NOTE NO 105 REGARDING NEP-4 DATA FOR OUS 1
AND 2
RESPONSE TO COMMENTS ON THE OUs 1 AND 2 PROPOSED PLAN
DRAFT MCLB OUs 1 AND 2 PROPOSED PLAN
COMMENTS ON DRAFT RCRA FACILITY ASSESSMENT
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 DRAFT FINAL F S
REPORT, REVISION 0
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 PROPOSED PLAN.
DATED OCTOBER 1996
COMMENTS ON THE OUs 1 AND 2 PROPOSED PLAN
AUTHOR
EPA REGION IX SAN FRANCISCO
EPA REGION IX SAN FRANCISCO
EPA REGION IX SAN FRANCISCO
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
DEPARTMENT OF TOXICS SUBSTANCE
CONTROL
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
EPA REGION IX SAN FRANCISCO
ADDRESSEE OF UNIT
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
DISC LONG BEACH
SOUTHWEST DIVISION
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS
COMMENTS
PROPOSED PLAN 11/1/96
CORRESPONDENCE, COMMENT 11/5/96
MEETING MINUTES
MEETING MINUTES
CORRESPONDENCE
MEETING NOTES
CORRESPONDENCE
5 1 - 0154
COMMENTS ON MCLB BARSTOW INSTALLATION RESTORATION
PROGRAM OUs 1 AND 2 PROPOSED PLAN DATED OCTOBER 1996
COMMENTS ON THE REVIEW OF MCLB OUs 1 AND 2 DRAFT PROPOSED
PLAN
DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN
US EPA COMMENTS ON OPERATION f, MAINTENANCE MONITORING
DATA SUMMARY GROUNDWATER EXTRACTION 5 TREATMENT REMOVAL
PILOT STUDY AT NEBO
MEETING AGENDA REMEDIAL PROJECT MANAGERS MEETING OF
NOVEMBER 7, 1996
NOVEMBER 6, 1996, REMEDIAL PROJECT MANAGERS MEETING MINUTES
FINAL SITE HEALTH AND SAFETY PLAN OF OPERABLE UNITS 1 AND 2
(CROSS REFER 13 4)
NOVEMBER 6-7, 1996 REMEDIAL PROJECT MANAGERS MEETING
MINUTES
PROJECT NOTE 109/CTO 296 REGARDING EVALUATION OF
PERFORMING VADOSE ZONE CLEANUP AT CAOC 15/17
RESPONSE TO LETTER OF OCTOBER 31, 1996 EXPRESSING CONCERNS
OVER THE STATE OF CALIFORNIAS COMPLIANCE WITH THE FFA FOR
THE MARINE CORPS LOGISTICS BASE BARSTOW
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
EPA REGION IX SAN FRANCISCO
ADDRESSEE
SOUTHWEST DIVISION
SOUTHWEST DIVISION
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
MARINE CORPS LOGISTICS BASE BARSTOW
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
NAVAL FACILITIES ENGINEERING COMMAND DTSC LONG BEACH
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
MARINE CORPS LOGISTICS BASE
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL MARINE CORPS LOGISTIC BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS EPA
DATE
12/24/96
COMMENTS ON DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN MARINE
CORPS LOGISTICS BASE BARSTOW
AUTHOR
US ENVIRONMENTAL PROTECTION AGENCY
ADDRESSEE
SOUTHWEST DIVISION
OP UNIT
1,2
COMMENTS EPA
COMMENTS ON THE DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN
MARINE CORPS LOGISTICS BASE BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
REVIEW OF THE DRAFT FINAL PROPOSED PLAN FOR OPERABLE UNITS 1
AND 2
DEPARTMENT OF TOXICS SUBSTANCE
CONTROL
SOUTHWEST DIVISION
COMMENTS, RWQCB
COMMENTS ON OUs 1 AND 2, DRAFT FINAL PROPOSED PLAN MARINE
CORPS LOGISTICS BASE BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS ON REVIEW OF THE DRAFT FINAL PROPOSED PLAN FOR
OUs 1 AND 2 MARINE CORPS LOGISTICS BASE BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
CORRESPONDENCE
PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE
UNITED STATES MARINE CORPS LOGISTICS BASE OUs 1 AND 2
PROPOSED PLAN, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
COMMENTS, DEPT OF INTERIOR 2/6/97
COMMENTS ON THE DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN FOR
APPROVAL AT MCLB BARSTOW
DEPT OF INTERIOR
BOARD
REGIONAL WATER QUALITY CONTROL 1,2
PROPOSED PLAN
DRAFT FINAL PROPOSED PLAN MARINE CORPS LOGISTICS BASE
BARSTOW OUs 1 AND 2
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
REPORT, FS
COMMENTS, REQUEST
DRAFT FINAL FEASIBILITY STUDY REPORT ON OUS 1 AND 2 REVISION 1 JACOBS ENGINEERING GROUP INC
REQUEST FOR AN EXTENSION OF DUE DATE FEBRUARY 14, 1997 TO
ALLOW INPUT BY THE REGIONAL BOARD AT THEIR APRIL 3, 1997
MEETING ON DRAFT FINAL PROPOSED PLAN OUs 1 AND 2 MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXICS SUBSTANCE
CONTROL
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, ROD
DRAFT OUs 1 AND 2 RECORD OF DECISION (ROD) REVISION 0 DATED
FEBRUARY 28, 1997
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
SOUTHWEST DIVISION
TECHNICAL MEMORANDUM
PROJECT NOTE NO 116-ECONOMIC ANALYSIS OF VASODE ZONE
CLEANUP AT MCLB BARSTOW DATED 2/28/97
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
COMMENTS, RESPONSE
RESPONSE TO ADDITIONAL US/EPA COMMENTS ON THE DRAFT FINAL
OU 1 AND 2 PROPOSED PLAN. COMMENTS DATED DECEMBER 24, 1996
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
CORRESPONDENCE
OPERABLE UNITS 1 AND 2 DRAFT FINAL FEASIBILITY STUDY AND DRAFT
FINAL PROPOSED PLAN
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
SOUTHWEST DIVISION
COMMENTS ON THE OUs 1/2 DRAFT FINAL ADDENDUM AND DRAFT
FINAL PROPOSED PLAN
DEPT OF TOXIC SUBSTANCES CONTROL
SOUTHWEST DIVISION
COMMENTS FROM VARIOUS AGENCIES ON THE OUs 5 AND 6 DRAFT
PROPOSED PLAN AND DRAFT FINAL FS
DEPT OF TOXIC SUBSTANCES CONTROL SOUTHWEST DIVISION
CORRESPONDENCE, RESPONSE 3/18/97
RESPONSE TO COMMENTS ON OU 1 AND 2 PROPOSED PLAN AND
DRAFT RECORD OF DECISION
REGIONAL WATER QUALITY CONTROL
BOARD
BUREAU OF LAND MANAGEMENT
CORRESPONDENCE
PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE
OPERABLE UNITS 1 AND 2 DRAFT RECORD OF DECISION
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
ADDITIONAL SOIL SAMPLING AT CAOC 15/17 AND SOIL VAPOR
MONITORING AT CAOC 16
SOUTHWEST DIVISION
VARIOUS AGENCIES
CORRESPONDENCE, REQUEST
REQUEST TO ATTEND THE MCLB AND SWD STRATEGY MEETING FOR
THE RECORD OF DECISION (ROD) ON OUS 1 S 2
SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION
AGENCY
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
DATE
4/15/97
COLLABORATIVE POSITION FDA OPERATIVE UNITS 1 AND 2 RECORD OF
DECISION (ROD)
AUTHOR
SOUTHWEST DIVISION
ADDRESSEE
US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, REQUEST
EXTENSION REQUEST FOR AGENCY REVIEW OF MCLB BARSTOW DRAFT
ROD FOR OU 1 AND 2
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTIC BASE
CORRESPONDENCE, COMMENT:
ROD
REVIEW OF THE DRAFT RECORD OF DECISION (ROD) FOR OU >-4
COMMENTS TO DRAFT RECORD OF DECISION FOR OUS 1 AND 2
DEPT OF TOXIC SUBSTANCE CONTROL
CALIFORNIA STATE WATER RESOURCES
CONTROL BOARD
SOUTHWEST DIVISION
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
MEETING NOTES
MEETING NOTES, ROD
FEBRUARY 10-11, 1997 REMEDIAL PROJECT MANAGERS MEETING NOTES JACOBS ENGINEERING GROUP INC
APRIL 17, 1997 RPM MEETING NOTES RE OU >-5 DRAFT RECORD OF
DECISION
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
CORRESPONDENCE, MEETING
INVITATION TO ATTEND REMEDIAL PROJECTS MANAGERS MEETING ON
21-22 MAY 1997
SOUTHWEST DIVISION
VARIOUS AGENCIES
FINAL COMMENTS FOR OU 1 AND 2 RECORD OF DECISION, DATED
FEBRUARY 28 1997
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
CORRESPONDENCE, COMMENT:
REQUEST FOR EXTENSION OF COMMENT PERIOD ON DRAFT RECORD
OF DECISION TO 5/30/97
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
8/1/97 65- 0099 REVISED DRAFT FINAL COPY OF THE PROPOSED PLAN
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE, COMMENT:
CORRESPONDENCE, COMMENT:
CORRESPONDENCE
CORRESPONDENCE, PERMIT
CORRESPONDENCE
CORRESPONDENCE
SUBJECT
COMMENTS TO REVISED DRAFT FINAL PROPOSED PLAN ON OUS 1 AND 2
COMMENTS TO REVISED DRAFT PROPOSED PLAN, DATED AUGUST
1997, GROUNDWATER AND DEEP SOILS
REQUEST FOR SCHEDULE EXTENSION TO FFA DEADLINES FOR ROD
AND PROPOSED PLAN
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY
(W/0 ENCL. RIGHT OF ENTRY PERMIT)
AUTHOR
US ENVIRONMENTAL PROTECTION AGENCY
REGIONAL WATER QUALITY CONTROL
BOARD
SOUTHWEST DIVISION
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
ADDRESSEE
SOUTHWEST DIVISION
VARIOUS AGENCIES
VARIOUS AGENCIES
SOUTHWEST DIVISION
MCLB BARSTOW
PROPOSED PLAN, CLEANUP
RFA PLANNING DOCUMENT
CORRESPONDENCE, COMMENT:
IRP OPERABLE UNITS 1 AND 2 PROPOSED PLAN FOR CLEANUP
DRAFT STRATEGIC PLAN FOR RFA AND LUFT SITES
COLLECTIVE COMMENTS TO DRAFT FINAL PROPOSED PLAN BY
VARIOUS AGENCIES
COLLECTIVE COMMENTS TO DRAFT FINAL FEASIBILITY STUDY AND
DRAFT FINAL PROPOSED PLAN BY VARIOUS AGENCIES
MARINE CORPS LOGISTICS BASE
BECHTEL NATIONAL INC
JACOBS ENGINEERING GROUP INC
PUBLIC
VARIOUS AGENCIES
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
COMMENTS, RESPONSE
CORRESPONDENCE
CORRESPONDENCE
SUBJECT
REQUEST FOR CLARIFICATION OF SVE CLEANUP GOALS
COMMENTS ON RI/FS AND ROD FOR OU >-4, CONCURRENCE WITH RI/FS DEPT OF TOXIC SUBSTANCE CONTROL
COMMENTS ON AIR SPARGE AND SVE PILOT STUDY DRAFT TECH MEMO
OF 7/31/97
1 - 0278 COMMENTS ON CRWQCB'S STAFF REPORT OF 8/29/97
CONCURRENCE WITH DRAFT FINAL PROPOSED PLAN FOR OU
SOLICITATION OF USEPA INTERPRETATION OF CLEANUP STANDARDS
FOR SVE SHUT-OFF CRITERIA
RESPONSES TO AGENCY COMMENTS ON OPERABLE UNITS (OUs) %
WORKING DRAFT FINAL RECORD OF DECISION (ROD) REV 1 DATED
AUGUS T 1997
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
MCLB BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL
JACOBS ENGINEERING GROUP INC
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
U S ENVIRONMENTAL PROTECTION
AGENCY REGION 9
ADDRESSEE
US ENVIRONMENTAL PROTECTION
AGENCY
SOUTHWEST DIVISION
MCLB BARSTOW
CALIF REGIONAL WATER QUALITY
CONTROL BOARD
OP UNIT
1,2
US ENVIRONMENTAL PROTECTION
AGENCY
SOUTHWEST DIVISION
SOUTHWEST DIVISION
MCLB BARSTOW
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PROJECT NOTE
DATE CAT-DOC#
11/12/97 5 1 - 0281
PROJECT NOTE 123 MINUTES OF THE REMEDIAL PROJECT MANAGERS
(RPM) MEETING HELD ON NOVEMBER 12,1997
AUTHOR
JACOBS ENGINEERING GROUP
ADDRESSEE
SOUTHWEST DIVISION
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLG
DEPARTMENT OF THE NAVY
DEPT OF TOXIC SUBSTANCES
CONTROL
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
DEPARTMENT OF THE NAVY
US ENVIRONMENTAL PROTECTION 1,2
AGENCY
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
DEPARTMENT OF THE NAVY
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
SOUTHWEST DIVISION
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
PLAN, PLANNING DOCUMENTS
RECORD OF DECISION
DRAFT FINAL STRATEGIC PLAN FOR RFA AND LUFT SITES
DRAFT FINAL COLLABORATIVE REVIEW LANGUAGE OUs >-4 RECORD OF
DECISION (ROD)
BECHTEL NATIONAL INC
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
REPORT, PROJECT NOTE
CORRESPONDENCE, RESPONSE
PROJECT NOTE#124 VADOSE ZONE MODELING FOR AS/SVE SHUT-OFF
RESPONSE TO LETTERS OF 9/17/97 AND 10/3/97, REQUESTING EPA'S
POSITION ON SEVERAL ISSUES IMPACTING MCLB
JACOBS ENGINEERING GROUP INC
US ENVIRONMENTAL PROTECTION AGENCY
SOUTHWEST DIVISION
SOUTHWEST DIVISION
CORRESPONDENCE
CONCURRENCE REVIEW OF THE DRAFT FINAL STRATEGIC PLAN FOR
RFA/LUFT SITES ON MCLB BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
LIMITED GROUNDWATER SAMPLING RESULTS AT NORTHERN NEBO
PLUME
AUTHOR
OHM REMEDIATION SERVICES - IRVINE
ADDRESSEE
SOUTHWEST DIVISION
REPORT, SURVEYING
DRAFT FINAL RECORD OF DECISION REPORT ON OPERABLE UNITS 1
AND 2
LAND PARCEL SURVEYING AT MCLB BARSTOW, NEBO MAIN BASE AND
YERMO ANNEX
MEMO WORK PLAN FOR OPTIMIZATION OF THE GROUNDWATER
REMEDIATION AND RECHARGE SYSTEMS AT YERMO ANNEX Ou 1
DATED 2/27/98
JACOBS ENGINEERING GROUP INC
OHM REMEDIATION
OHM REMEDIATION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
PLAN MEMO WORK PLAN
MEMO WORK PLAN FOR OPERATION OF THE GROUNDWATER
TREATMENT SYSTEM AT NEBO NORTH, NEBO MAIN BASE, OU 2, DATED
3/6/98
OHM REMEDIATION
SOUTHWEST DIVISION
RESPONSE TO COMMENTS
RESPONSE T AGENCY COMMENTS ON DRAFT FINAL RECORD OF
DECISION ON OPERABLE UNITS 1 AND 2
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE DATE CAT-DOCt
CORRESPONDENCE COMMENT: 6/19/96 52- 0322
CRWQCB COMMENTS TO OU 7 DRAFT RCRA FACILITIES ASSESSMENT
REPORT
ADDRESSEE
MARINE CORPS LOGISTICS BASE
REPORT, RI/FS
MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY STUDY
FEASIBILITY STUDY REPORT OU 1 AND 2 DRAFT FINAL, REVISION 0.
DATED JUNE 21, 1996 (TRANSMITTAL ONLY)
JACOBS ENGINEERING GROUP INC.
SOUTHWEST DIVISION
CORRESPONDENCE
REQUEST FOR DELAY ON REVIEW OF DRAFT RCRA FACILITY
ASSESSMENT FOR MCLB BARSTOW
MARINE CORPS LOGISTICS BASE
SOUTHWEST DIVISION
CORRESPONDENCE
NOTE
PROJECT NOTE 103 - PILOT STUDY MONITORING PLAN DNA SCHEDULE
GROUNDWATER EXTRACTION SYSTEM OU 2 NEBO NORTHERN PLUME
(NRF-1)
JACOBS ENGINEERING GROUP INC.
SOUTHWEST DIVISION
COMMENTS ON MCLB BARSTOW REMEDIAL INVESTIGATION/FEASIBILITY
STUDY DRAFT FINAL FEASIBILITY STUDY REPORT OU 1 5 2
EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
PROJECT NOTE No 102/CTO 298 REGARDING MCLB BARSTOW JACOBS ENGINEERING GROUP INC.
OPERABLE UNITS 1 AND 2 TECHNICAL AND ECONOMICAL FEASIBILITY
(TEF) OF GROUNDWATER CLEANUP
COMMENTS ON DRAFT FINAL FS REPORT OUS 1 AND 2, AND OUS 5 AND EPA REGION IX SAN FRANCISCO
SOUTHWEST DIVISION
SOUTHWEST DIVISION
RESPONSE TO USEPA NATIONAL RISK MANAGEMENT RESEARCH
LABORATORY COMMENTS ON NATURAL ATTENUATION FOR OUS 1 AND
2, DATED MAY 6, 1996
FINAL CHEMICAL DATA ACQUISITION PLAN, GROUNDWATER
REMEDIATION AND RECHARGE SYSTEM OU 1, YERMO ANNEX MCLB
BARSTOW
JACOBS ENGINEERING GROUP, INC.
SOUTHWEST DIVISION
OHM REMEDIATION SERVICES-SAN DIEGO SOUTHWEST DIVISION
MEETING MINUTES
MEETING NOTES, REMEDIAL PROJECT MANAGERS MEETING OF
SEPTEMBER 4-5, 1996
JACOBS ENGINEERING GROUP INC.
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
CORRESPONDENCE
PROJECT NOTE NO 105
RESPONSE TO COMMENTS
PROPOSED PLAN
CORRESPONDENCE
CORRESPONDENCE, RESPONSE 10/8/96
CORRESPONDENCE, RESPONSE 10/29/96
USEPA REVIEW OF YERMO ANNEX OU 1 DRAFT GROUNDWATER
MONITORING PLAN
USEPA REVIEW OF MCLB CALIFORNIA DRAFT RCRA FACILITY
ASSESSMENT REPORT
COMMENTS ON REVIEW OF YERMO ANNEX OU 1 DRAFT
GROUNDWATER MONITORING PLAN
CTO 298 PROJECT NOTE NO 105 REGARDING NEP-4 DATA FOR OUS 1
AND 2
RESPONSE TO COMMENTS ON THE OUs 1 AND 2 PROPOSED PLAN
DRAFT MCLB OUs 1 AND 2 PROPOSED PLAN
COMMENTS ON DRAFT RCRA FACILITY ASSESSMENT
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 DRAFT FINAL F S
REPORT, REVISION 0
RESPONSE TO AGENCY COMMENTS ON OUS 1 AND 2 PROPOSED PLAN.
DATED OCTOBER 1996
AUTHOR
EPA REGION IX SAN FRANCISCO
EPA REGION IX SAN FRANCISCO
EPA REGION IX SAN FRANCISCO
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
DEPARTMENT OF TOXICS SUBSTANCE
CONTROL
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
EPA REGION IX SAN FRANCISCO
ADDRESSEE OF UNIT
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
DISC LONG BEACH
SOUTHWEST DIVISION
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS
COMMENTS
PROPOSED PLAN 11/1/96
CORRESPONDENCE, COMMENT 11/5/96
MEETING MINUTES
MEETING MINUTES
CORRESPONDENCE
MEETING NOTES
CORRESPONDENCE
5 1 - 0154
COMMENTS ON MCLB BARSTOW INSTALLATION RESTORATION
PROGRAM OUs 1 AND 2 PROPOSED PLAN DATED OCTOBER 1996
COMMENTS ON THE REVIEW OF MCLB OUs 1 AND 2 DRAFT PROPOSED
PLAN
DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN
US EPA COMMENTS ON OPERATION f, MAINTENANCE MONITORING
DATA SUMMARY GROUNDWATER EXTRACTION 5 TREATMENT REMOVAL
PILOT STUDY AT NEBO
MEETING AGENDA REMEDIAL PROJECT MANAGERS MEETING OF
NOVEMBER 7, 1996
NOVEMBER 6, 1996, REMEDIAL PROJECT MANAGERS MEETING MINUTES
FINAL SITE HEALTH AND SAFETY PLAN OF OPERABLE UNITS 1 AND 2
(CROSS REFER 13 4)
NOVEMBER 6-7, 1996 REMEDIAL PROJECT MANAGERS MEETING
MINUTES
PROJECT NOTE 109/CTO 296 REGARDING EVALUATION OF
PERFORMING VADOSE ZONE CLEANUP AT CAOC 15/17
RESPONSE TO LETTER OF OCTOBER 31, 1996 EXPRESSING CONCERNS
OVER THE STATE OF CALIFORNIAS COMPLIANCE WITH THE FFA FOR
THE MARINE CORPS LOGISTICS BASE BARSTOW
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
EPA REGION IX SAN FRANCISCO
ADDRESSEE
SOUTHWEST DIVISION
SOUTHWEST DIVISION
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
MARINE CORPS LOGISTICS BASE BARSTOW
JACOBS ENGINEERING GROUP INC SOUTHWEST DIVISION
NAVAL FACILITIES ENGINEERING COMMAND DTSC LONG BEACH
JACOBS ENGINEERING GROUP INC
JACOBS ENGINEERING GROUP INC
MARINE CORPS LOGISTICS BASE
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL MARINE CORPS LOGISTIC BASE
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
COMMENTS EPA
DATE
12/24/96
COMMENTS ON DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN MARINE
CORPS LOGISTICS BASE BARSTOW
AUTHOR
US ENVIRONMENTAL PROTECTION AGENCY
ADDRESSEE
SOUTHWEST DIVISION
COMMENTS ON THE DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN
MARINE CORPS LOGISTICS BASE BARSTOW
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
CORRESPONDENCE
REVIEW OF THE DRAFT FINAL PROPOSED PLAN FOR OPERABLE UNITS 1
AND 2
DEPARTMENT OF TOXICS SUBSTANCE
CONTROL
SOUTHWEST DIVISION
COMMENTS, RWQCB
COMMENTS ON OUs 1 AND 2, DRAFT FINAL PROPOSED PLAN MARINE
CORPS LOGISTICS BASE BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
COMMENTS ON REVIEW OF THE DRAFT FINAL PROPOSED PLAN FOR
OUs 1 AND 2 MARINE CORPS LOGISTICS BASE BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
SOUTHWEST DIVISION
CORRESPONDENCE
PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE
UNITED STATES MARINE CORPS LOGISTICS BASE OUs 1 AND 2
PROPOSED PLAN, BARSTOW
REGIONAL WATER QUALITY CONTROL
BOARD
MARINE CORPS LOGISTICS BASE
COMMENTS, DEPT OF INTERIOR 2/6/97
COMMENTS ON THE DRAFT FINAL OUs 1 AND 2 PROPOSED PLAN FOR
APPROVAL AT MCLB BARSTOW BOARD
DEPT OF INTERIOR
REGIONAL WATER QUALITY CONTROL 1,2
DRAFT FINAL PROPOSED PLAN MARINE CORPS LOGISTICS BASE
BARSTOW OUs 1 AND 2
REGIONAL WATER QUALITY CONTROL
BOARD
DEPT OF TOXIC SUBSTANCES
CONTROL
REPORT, FS
COMMENTS, REQUEST
DRAFT FINAL FEASIBILITY STUDY REPORT ON OUS 1 AND 2 REVISION 1 JACOBS ENGINEERING GROUP INC
REQUEST FOR AN EXTENSION OF DUE DATE FEBRUARY 14, 1997 TO
ALLOW INPUT BY THE REGIONAL BOARD AT THEIR APRIL 3, 1997
MEETING ON DRAFT FINAL PROPOSED PLAN OUs 1 AND 2 MCLB
REGIONAL WATER QUALITY CONTROL
BOARD
VARIOUS AGENCIES
DEPT OF TOXICS SUBSTANCE
CONTROL
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
REPORT, ROD
DRAFT OUs 1 AND 2 RECORD OF DECISION (ROD) REVISION 0 DATED
FEBRUARY 28, 1997
AUTHOR
JACOBS ENGINEERING GROUP INC
ADDRESSEE
SOUTHWEST DIVISION
TECHNICAL MEMORANDUM
PROJECT NOTE NO 116-ECONOMIC ANALYSIS OF VASODE ZONE
CLEANUP AT MCLB BARSTOW DATED 2/28/97
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
COMMENTS, RESPONSE
RESPONSE TO ADDITIONAL US/EPA COMMENTS ON THE DRAFT FINAL
OU 1 AND 2 PROPOSED PLAN. COMMENTS DATED DECEMBER 24, 1996
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
CORRESPONDENCE
OPERABLE UNITS 1 AND 2 DRAFT FINAL FEASIBILITY STUDY AND DRAFT
FINAL PROPOSED PLAN
DEPARTMENT OF TOXIC SUBSTANCES
CONTROL
SOUTHWEST DIVISION
COMMENTS ON THE OUs >-5 DRAFT FINAL ADDENDUM AND DRAFT
FINAL PROPOSED PLAN
DEPT OF TOXIC SUBSTANCES CONTROL
SOUTHWEST DIVISION
COMMENTS, DTSC, EPA RWQCB 3/13/97
COMMENTS FROM VARIOUS AGENCIES ON THE OUs 5 AND 6 DRAFT
PROPOSED PLAN AND DRAFT FINAL FS
DEPT OF TOXIC SUBSTANCES CONTROL SOUTHWEST DIVISION
CORRESPONDENCE, RESPONSE 3/18/97
RESPONSE TO COMMENTS ON OU 1 AND 2 PROPOSED PLAN AND
DRAFT RECORD OF DECISION
REGIONAL WATER QUALITY CONTROL
BOARD
BUREAU OF LAND MANAGEMENT
CORRESPONDENCE
PROPOSED CONSIDERATION OF A RESOLUTION APPROVING THE
OPERABLE UNITS 1 AND 2 DRAFT RECORD OF DECISION
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTICS BASE
CORRESPONDENCE
ADDITIONAL SOIL SAMPLING AT CAOC 15/17 AND SOIL VAPOR
MONITORING AT CAOC 16
SOUTHWEST DIVISION
VARIOUS AGENCIES
CORRESPONDENCE, REQUEST
REQUEST TO ATTEND THE MCLB AND SWD STRATEGY MEETING FOR
THE RECORD OF DECISION (ROD) ON OUS 1 S 2
SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION
AGENCY
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
DATE
4/15/97
COLLABORATIVE POSITION FDA OPERATIVE UNITS 1 AND 2 RECORD OF
DECISION (ROD)
AUTHOR
SOUTHWEST DIVISION
ADDRESSEE
US ENVIRONMENTAL PROTECTION
AGENCY
CORRESPONDENCE, REQUEST
EXTENSION REQUEST FOR AGENCY REVIEW OF MCLB BARSTOW DRAFT
ROD FOR OU 1 AND 2
US ENVIRONMENTAL PROTECTION AGENCY MARINE CORPS LOGISTIC BASE
CORRESPONDENCE, COMMENT:
ROD
REVIEW OF THE DRAFT RECORD OF DECISION (ROD) FOR OU 1/2
COMMENTS TO DRAFT RECORD OF DECISION FOR OUS 1 AND 2
DEPT OF TOXIC SUBSTANCE CONTROL
CALIFORNIA STATE WATER RESOURCES
CONTROL BOARD
SOUTHWEST DIVISION
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
MEETING NOTES
MEETING NOTES, ROD
FEBRUARY 10-11, 1997 REMEDIAL PROJECT MANAGERS MEETING NOTES JACOBS ENGINEERING GROUP INC
APRIL 17, 1997 RPM MEETING NOTES RE OU 1/2 DRAFT RECORD OF
DECISION
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
1,2,3,4,5,6,
1,2
CORRESPONDENCE, MEETING
INVITATION TO ATTEND REMEDIAL PROJECTS MANAGERS MEETING ON
21-22 MAY 1997
SOUTHWEST DIVISION
VARIOUS AGENCIES
FINAL COMMENTS FOR OU 1 AND 2 RECORD OF DECISION, DATED
FEBRUARY 28 1997
REGIONAL WATER QUALITY CONTROL MARINE CORPS LOGISTICS BASE 1,2
BOARD
CORRESPONDENCE, COMMENT:
REQUEST FOR EXTENSION OF COMMENT PERIOD ON DRAFT RECORD
OF DECISION TO 5/30/97
US ENVIRONMENTAL PROTECTION AGENCY SOUTHWEST DIVISION
REVISED DRAFT FINAL COPY OF THE PROPOSED PLAN
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE, COMMENT:
CORRESPONDENCE, COMMENT:
CORRESPONDENCE
CORRESPONDENCE, PERMIT
CORRESPONDENCE
CORRESPONDENCE
SUBJECT
COMMENTS TO REVISED DRAFT FINAL PROPOSED PLAN ON OUS 1 AND 2
COMMENTS TO REVISED DRAFT PROPOSED PLAN, DATED AUGUST
1997, GROUNDWATER AND DEEP SOILS
REQUEST FOR SCHEDULE EXTENSION TO FFA DEADLINES FOR ROD
AND PROPOSED PLAN
REQUEST PERMISSION TO DRILL A TEST WELL ON PRIVATE PROPERTY
(W/0 ENCL. RIGHT OF ENTRY PERMIT)
AUTHOR
US ENVIRONMENTAL PROTECTION AGENCY
REGIONAL WATER QUALITY CONTROL
BOARD
SOUTHWEST DIVISION
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
ADDRESSEE
SOUTHWEST DIVISION
VARIOUS AGENCIES
VARIOUS AGENCIES
SOUTHWEST DIVISION
MCLB BARSTOW
PROPOSED PLAN, CLEANUP
RFA PLANNING DOCUMENT
CORRESPONDENCE, COMMENT:
IRP OPERABLE UNITS 1 AND 2 PROPOSED PLAN FOR CLEANUP
DRAFT STRATEGIC PLAN FOR RFA AND LUFT SITES
COLLECTIVE COMMENTS TO DRAFT FINAL PROPOSED PLAN BY
VARIOUS AGENCIES
COLLECTIVE COMMENTS TO DRAFT FINAL FEASIBILITY STUDY AND
DRAFT FINAL PROPOSED PLAN BY VARIOUS AGENCIES
MARINE CORPS LOGISTICS BASE
BECHTEL NATIONAL INC
JACOBS ENGINEERING GROUP INC
PUBLIC
VARIOUS AGENCIES
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
CORRESPONDENCE
COMMENTS, RESPONSE
CORRESPONDENCE
CORRESPONDENCE
SUBJECT
REQUEST FOR CLARIFICATION OF SVE CLEANUP GOALS
COMMENTS ON RI/FS AND ROD FOR OU 1/2, CONCURRENCE WITH RI/FS DEPT OF TOXIC SUBSTANCE CONTROL
COMMENTS ON AIR SPARGE AND SVE PILOT STUDY DRAFT TECH MEMO
OF 7/31/97
1 - 0278 COMMENTS ON CRWQCB'S STAFF REPORT OF 8/29/97
CONCURRENCE WITH DRAFT FINAL PROPOSED PLAN FOR OU 1/2
SOLICITATION OF USEPA INTERPRETATION OF CLEANUP STANDARDS
FOR SVE SHUT-OFF CRITERIA
RESPONSES TO AGENCY COMMENTS ON OPERABLE UNITS (OUs) 1/2
WORKING DRAFT FINAL RECORD OF DECISION (ROD) REV 1 DATED
AUGUS T 1997
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
MCLB BARSTOW
SOUTHWEST DIVISION
DEPT OF TOXIC SUBSTANCE CONTROL
JACOBS ENGINEERING GROUP INC
REGIONAL WATER QUALITY CONTROL
BOARD, LAHONTAN
U S ENVIRONMENTAL PROTECTION
AGENCY REGION 9
ADDRESSEE
US ENVIRONMENTAL PROTECTION
AGENCY
SOUTHWEST DIVISION
MCLB BARSTOW
CALIF REGIONAL WATER QUALITY
CONTROL BOARD
SOUTHWEST DIVISION
US ENVIRONMENTAL PROTECTION
AGENCY
SOUTHWEST DIVISION
SOUTHWEST DIVISION
MCLB BARSTOW
SOUTHWEST DIVISION
OP UNIT
1,2
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MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
PROJECT NOTE
DATE CAT-DOCf
11/12/97 5 1 - 0281
PROJECT NOTE 123 MINUTES OF THE REMEDIAL PROJECT MANAGERS
(RPM) MEETING HELD ON NOVEMBER 12,1997
AUTHOR
JACOBS ENGINEERING GROUP
ADDRESSEE
SOUTHWEST DIVISION
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLG
DEPARTMENT OF THE NAVY
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
DEPARTMENT OF THE NAVY
US ENVIRONMENTAL PROTECTION 1,2
AGENCY
CORRESPONDENCE, REQUEST
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
DEPARTMENT OF THE NAVY
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
REQUEST FOR EXTENSION FOR SUBMITTAL OF OPERABLE UNITS 1 AND
2 DRAFT FINAL RECORD OF DECISION FOR MCLB
SOUTHWEST DIVISION
REGIONAL WATER QUALITY CONTROL 1,2
BOARD
PLAN, PLANNING DOCUMENTS
RECORD OF DECISION
DRAFT FINAL STRATEGIC PLAN FOR RFA AND LUFT SITES
DRAFT FINAL COLLABORATIVE REVIEW LANGUAGE OUs % RECORD OF
DECISION (ROD)
BECHTEL NATIONAL INC
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
REPORT, PROJECT NOTE
CORRESPONDENCE, RESPONSE
PROJECT NOTE#124 VADOSE ZONE MODELING FOR AS/SVE SHUT-OFF
RESPONSE TO LETTERS OF 9/17/97 AND 10/3/97, REQUESTING EPA'S
POSITION ON SEVERAL ISSUES IMPACTING MCLB
JACOBS ENGINEERING GROUP INC
US ENVIRONMENTAL PROTECTION AGENCY
SOUTHWEST DIVISION
SOUTHWEST DIVISION
CORRESPONDENCE
CONCURRENCE REVIEW OF THE DRAFT FINAL STRATEGIC PLAN FOR
RFA/LUFT SITES ON MCLB BARSTOW
DEPT OF TOXIC SUBSTANCE CONTROL
SOUTHWEST DIVISION
-------
MARINE CORPS LOGISTICS BASE, BARSTOW
FINAL ADMINISTRATIVE RECORD INDEX FOR
OPERABLE UNITS 1 AND 2 FINAL RECORD OF DECISION
DOCUMENT TYPE
CORRESPONDENCE
REPORT, RECORD OF DECISION 2/15/98 7 1 - 0025
REPORT, SURVEYING
RESPONSE TO COMMENTS
LIMITED GROUNDWATER SAMPLING RESULTS AT NORTHERN NEBO
PLUME
DRAFT FINAL RECORD OF DECISION REPORT ON OPERABLE UNITS 1
AND 2
LAND PARCEL SURVEYING AT MCLB BARSTOW, NEBO MAIN BASE AND
YERMO ANNEX
MEMO WORK PLAN FOR OPTIMIZATION OF THE GROUNDWATER
REMEDIATION AND RECHARGE SYSTEMS AT YERMO ANNEX Ou 1
DATED 2/27/98
3/6/98 4 1 - 0024 MEMO WORK PLAN FOR OPERATION OF THE GROUNDWATER
TREATMENT SYSTEM AT NEBO NORTH, NEBO MAIN BASE, OU 2, DATED
3/6/98
RESPONSE T AGENCY COMMENTS ON DRAFT FINAL RECORD OF
DECISION ON OPERABLE UNITS 1 AND 2
AUTHOR ADDRESSEE
OHM REMEDIATION SERVICES - IRVINE SOUTHWEST DIVISION
JACOBS ENGINEERING GROUP INC
OHM REMEDIATION
OHM REMEDIATION
OHM REMEDIATION
JACOBS ENGINEERING GROUP INC
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
SOUTHWEST DIVISION
-------
Appendix C
Transcript for Public Meeting
CERTIFIED COPY
MCLB Barstow
Installation Restoration Program
Marine Corps Logistics Base
Barstow, California
Public Hearing
Date: Wednesday, November 12, 1997
Location: Holiday Inn
1511 East Main Street
Barstow, California
Reported by: Mary L. Anderson, CSR 10319
Alpha-Omega
Certified Court Reporters
Quality Service from Beginning to End!
2048 Orange Tree Lane, Suite 107, Redlands, CA 92374 D Toll Free (888) 335-7171
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INDEX
SPEAKER:
MR. DAWSON
MR. COX
PAGE
3
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 BARSTOW, CALIFORNIA
2 WEDNESDAY, NOVEMBER 12, 1997
3 7:38 P.M.
4
5 LT. KEVIN MORONEY: Good evening. I'm
6 Major Kevin Morony. I'm the environmental officer
7 at MCLB Barstow. On behalf of our commanding
8 officer, Colonel McBride, I welcome you to this
9 public meeting for the proposed plan for
10 Operable Units 1 and 2. The purpose of this meeting
11 in to provide you, the public, with the opportunity
12 to ask guestions and provide input to plans the
13 Marine Corps plans on implementing in order to
14 continue the cleanup of the base.
15 With that I'm going to turn the
16 meeting over to Mr. Dave Dawson, who will be the
17 facilitator for tonight's meeting.
18 MR. DAWSON: Sharp haircut this guy
19 has. As Kevin mentioned, my name is Dave Dawson. I
20 work with Southwest Division. I provide
21 environmental support for the Marine Corps Logistic
22 Base Barstow. I'm the facilitator for this
23 evening's meeting.
24 As you may notice we have a court
25 reporter who's here preparing a transcript of the
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1 meeting. That transcript will be recorded and
2 placed into the administrative record file, which
3 you are more than welcome to look at. One's located
4 at Warehouse 3 at the base. The other one's located
5 at the Barstow Public Library.
6 I'd like to introduce some people here
7 who play an instrumental role in the Installation
8 Restoration Program. Mr. Mike Cox, he in the Base's
9 IR Program Manager. On my left, Mr. Shawn Monahan,
10 he's the IR Program Field Manager for the Base. We
11 also have with us Ms. Anna-Marie Cook, she's the
12 representative of the United States EPA.
13 Mr. Steven Baxter, the representative of California
14 Department of Toxic Substances Control. Curt
15 Shifrer, he's part of the California Regional Water
16 Quality Control Board.
17 What we would like to do tonight is
18 overview the Marine Corps' Installation Restoration
19 Program. I'll start off with a brief overview of
20 CERCLA, then we'll discuss our proposed remedial
21 actions for some of the emanating groundwater that
22 you heard us discuss earlier in our technical review
23 meeting.
24 I'll start off with the CERCLA
25 overview, and then I'll turn it over to Mr. Michael
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1 Cox to give the presentation on the Installation
2 Restoration Program as well as some proposed
3 alternatives for cleanup at the site. We ask at the
4 end of all this, Mike will take any guestions you
5 ask. Please hold all guestions until the end. Jot
6 it down, and we'll address it at the end of the
7 presentation. With that, I'll give a brief
8 background an CERCLA.
9 CERCLA the acronym stands for
10 Comprehensive Environmental Response, Compensation
11 and Liability Act. It is the broadest environmental
12 statute which regulates the cleanup of past
13 hazardous waste sites. Sometimes you hear it in the
14 papers referred to as Superfund.
15 CERCLA was enacted in 1980. As part
16 of that, Department of Defense and the Marine Corps
17 began Installation Restoration Program, which is
18 meant to go out and investigate potential sites and
19 cleanup those sites as reguired by CERCLA. The
20 CERCLA program starts off with a process that begins
21 what we call "Site Discovery." In our case tonight,
22 Operable Units 1 and 2 we are talking about
23 contaminated groundwater. Diverse discovery of the
24 contaminated groundwater at the Yermo Annex of the
25 base.
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1 As a result of this, based an the
2 samples taken of the groundwater, an well as the
3 quality of the groundwater. The Federal EPA ranks
4 the site on what we call a hazard ranking system for
5 those sites that are worthy of being regulated by
6 the EPA placed on what we call the National
7 Priorities List, which is sometimes referred to an
8 the NPL. Barstow was placed on the NPL in November
9 of 1989.
10 Following the site discovery, proceed
11 to the remedial investigation. The goal of the
12 remedial investigation in commonly referred to as
13 the RI. This is to evaluate the nature and extent
14 of all this contamination, in our case it ended up
15 being one plume in the Yermo Annex, two plumes at
16 the Nebo Annex.
17 Following RI, we proceed on to an FS
18 or Feasibility Study whose goal is to evaluate
19 different alternatives to clean up waste found on
20 the site. Finally, after evaluating several
21 alternatives, we proceed with the proposed plan for
22 the site, which is why we're meeting here tonight.
23 This lists the recommended alternatives, gives a
24 short background-on those that were looked at in the
25 Feasibility Study.
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1 Once we've public-commented the
2 proposed plan, which as mentioned is part of
3 tonight's meeting, proceed with what we call "Record
4 of Decision" or ROD. This legally documents our
5 decision for the cleanup at the site. Following
6 signature of the ROD, we proceed with remedial
7 design and remedial action, which is the cleanup of
8 the site.
9 For those of you who aren't familiar,
10 Barstow is divided in three portions. Pictured here
11 we have the Yermo Annex. Yermo consists of mostly
12 industrial operations on the base. The heart of the
13 Yermo Annex, what we call Building 573, your
14 maintenance center Barstow, it's the one-stop shop
15 where vehicles and military eguipment is repaired
16 rehabed and stored on the site. This is pretty much
17 the industrial annex of the base.
18 Second portion of the base is the
19 Nebo Annex. This portion consists mostly of the
20 administrative buildings on the Base, base housing,
21 some recreation and activities on the Base.
22 Finally, we have the rifle rage portion of the Base,
23 which will not be addressed in tonight's public
24 meeting.
25 What we do for each alternative, back
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1 in the FS or the Feasibility Study I mentioned, we
2 take each alternative and compare it against
3 nine NCP criteria. The goal of this is to get a
4 fair comparison of each of the cleanup alternatives
5 that were evaluated.
6 Listed here on my overhead are the
7 nine NCP criteria that it was compared against. We
8 take each alternative and evaluate its overall
9 protection of human health in the environment. Its
10 compliance with ARARs. ARARs is just an acronym for
11 local, state or federal regulation that we need to
12 make sure we comply with as we conduct the cleanup.
13 We evaluate each alternative for
14 short-term and long-term effectiveness at the site.
15 We also evaluate to see if an alternative has a
16 reduction in mobility, toxicity or volume of the
17 site. This shows the EPA's preference for reducing
18 the mobility, toxicity or volume of the
19 contamination at the site. Finally, we look at
20 implementability, whether or not a remedial action
21 in able to actually be put in at a site.
22 We compare each alternative on the
23 basis of cost. We look for state acceptance of the
24 alternative, and finally we look to the public,
25 which our proposed plan is part of tonight, for the
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1 public's acceptance of our recommended
2 alternatives.
3 With that, I'll turn it over to
4 Mike Cox who will give you an overview of the
5 Installation Restoration Program.
6 MR. COX: Good evening. The slide
7 you're currently reviewing is a description of the
8 Operable Units for the Marine Corps' Logistic Base,
9 and they're grouped together. You'll notice each
10 operable unit is broken out.
11 Yermo Annex groundwater is listed
12 OU 1. Nebo main base groundwater is listed as OU
13 2. OU 3 is the Yermo Annex with some
14 preinvestigative data that was done prior to the
15 investigation occurring. OU 4, Rebo main base, also
16 had some preinvestigative data. OU 5 and 6 are soil
17 sites also that had no investigative data, which
18 means there was no information. It was very limited
19 data at all. Mostly just information packets and
20 stuff with people telling you about the site or some
21 information, but nothing real hard evidence to tell
22 us what happened there. OU 7 in the Yermo, Nebo
23 sites that are remaining from the RCRA Facility
24 Assessment. These are sites that are going to be
25 grouped later on after the main one was done.
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1 The types of chemical waste that were
2 found at Barstow during the investigation included
3 petroleum hydrocarbons, solvent materials which are
4 very prevalent in plumes. There were pesticides,
5 herbicides, plating wastes activity from industrial
6 activity, PCBs, metals, as low as solid waste from
7 industrial and domestic facilities.
8 At this time I'd like to provide you a
9 little overview of the major events that brought us
10 to this point today. June 1983 we had initial
11 assessment study done. This was basically a
12 prework-up that was done as part of a Navy process
13 to look at the sites and determine if there were
14 contaminants present. This process noted some
15 contaminant sites.
16 October 1980 groundwater contamination
17 was detected at the Marine base. And November of
18 '89 MCLB Barstow was placed on the National
19 Priorities List, often called NPL, and in October of
20 1990, a Federal Facility Agreement was signed
21 between the Marine Corps and federal and state
22 regulatory agencies.
23 Other major events include 1994 a
24 COAC 16 Air Sparge/Soil Vapor Extraction System
25 Pilot Study. This was done to determine the
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1 effectiveness of the technology in remediating soils
2 and groundwater at the eastern Yermo Annex.
3 October 1995, remedial investigation
4 for groundwater was completed. 1995 and '96
5 separate pilot studies were conducted at the Nebo
6 main base to evaluate the effectiveness of cleanup
7 technologies. And the beginning of 1996 a
8 Non-Time-Critical Removal Action has been underway
9 at the Yermo Annex and begun to clean up
10 contaminated groundwater.
11 Most recent activities have included
12 the finalizing of the Feasibility Study in February
13 of 1997. The Feasibility Study evaluated various
14 alternatives for cleaning up the groundwater
15 operable units.
16 Last month, OU 1 and 2 Proposed Plan
17 was issued to the public and your being here tonight
18 is part of that process to solicit your input, and
19 in December 1997 we are scheduled to complete a ROD
20 or Record of Decision on these operable units.
21 For the next few minutes I'd like to
22 discuss the Proposed Plan and provide a brief
23 discussion on the alternatives evaluated to each of
24 the groundwater OUs. The Yermo groundwater, Yermo
25 Annex, is OU 1 and OU 2 is the Nebo groundwater
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1 Plume, which includes the north and south Plume. If
2 you notice the maps on the other side very quickly,
3 you can notice that for Nebo and Yermo, the plumes
4 are delineated in the pink areas.
5 I would like to begin my discussion by
6 talking about the Yermo Annex Plume. This is the
7 largest of three groundwater contaminant plumes at
8 MCLB Barstow. The most prevalent contaminants are
9 chlorinated solvents. This is a cleaning solvent
10 typical with industrial-type activity. These
11 chemicals were used an a degreaser and cleaner in a
12 wide variety of applications in the auto repair
13 shops over at the maintenance center Barstow and
14 other locations aboard the Base.
15 These chemicals were used primarily
16 for cold cleaning, vapor degreasing, et cetera. The
17 plume originated from past disposal activities at
18 the following locations: CAOC 35, which is a
19 landfill, CAOC 15/17 which in an industrial waste
20 area, CAOC 23 which in a landfill and a french drain
21 location at CAOC 26. Also included are breakage and
22 leakage within the drainage system at Building 573,
23 which is all through portions of the maintenance
24 center Barstow. The plume itself spans 12,000 feet
25 in length and about 4,000 feet wide, traveling at an
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1 estimated 60 to 70 feet per year.
2 First I will discuss the alternatives
3 that were evaluated to address the contamination in
4 groundwater at the Yermo Annex. We evaluated
5 10 remedial alternatives. Each alternative was
6 assessed based on the previously discussed criteria
7 defined in the VCP. These criteria were used to
8 determine which alternatives would provide the most
9 benefits.
10 Again, the assessment criteria are:
11 Overall protection of human health and the
12 environment; compliance with ARARs, these are state
13 and federal regulations; effectiveness of long-term
14 and short-term; reduction of toxicity, mobility or
15 volume; implementability; cost; state acceptance and
16 community acceptance, which in your activity
17 tonight, why you're here.
18 Each of the alternatives have to be
19 evaluated against the criteria except community
20 acceptance. Again, the purpose of this meeting
21 tonight is to get your input into that process.
22 For OU 1, Yermo Annex Plume,
23 Alternative 1 is No Action Alternative. This
24 alternative is reguired by the NCP. It's basically
25 a baseline to evaluate all other alternatives that
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1 are presented. Existing site conditions remain the
2 same and no costs are associated. This means we
3 actually do nothing at all, and everything else is
4 based upon that.
5 Alternative 2 is Institutional
6 Controls of groundwater monitoring. This would
7 restrict the use of untreated groundwater for
8 drinking at the Yermo Annex. It would provide
9 wellhead treatment of affected wellhead water
10 supplies. This alternative would also reguire
11 sampling of selected wells to monitor the
12 contaminant migration. Present cost of this, worth
13 cost of this -- implementing this option would be
14 $3.5 million.
15 Alternative 3 or Yermo Annex Plume
16 would involve the installation of eight groundwater
17 extraction wells at the eastern boundary. The
18 extracted water would be treated with activated
19 carbon and subseguently recharged via two
20 infiltration galleries. I don't know if we have
21 anything on the site. Could you go point out the
22 infiltration galleries at the opposite end of the
23 Base? The alternative would reguire an estimated
24 190 years to clean the on-Base and 500 years to
25 clean the off-Base plume. The present worth cost of
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1 this alternative would be $14.1 million.
2 Alternative 4 utilizes the component
3 of Alternative 3 -- and one thing I want to clarify,
4 tonight you're going to hear a number of
5 alternatives and many of them incorporate
6 information from the other alternatives. So you're
7 going to hear me say this incorporates Alternative 3
8 and 2, whatever, means that when I go to
9 Alternative 5 and I say that 3 and 2 are
10 incorporated, it is part of that one. So they're
11 rolling over into that part of it too.
12 Alternative 4 utilizes components of
13 Alternative 3, which are eight extraction wells
14 installed on the eastern Base boundary and adds
15 11 wells off-Base to capture the entire plume at the
16 background boundary. The difference between this
17 alternative and Alternative 3 is that it would clean
18 all of the contaminated groundwater to background
19 levels. Treatment time reguired is an estimate of
20 320 years for the on-Base cleanup and 70 years for
21 the off-Base. The total present worth cost of this
22 alternative would be $30.1 million.
23 Alternative 5 for the Yermo Annex
24 Plume is the same as Alternative 3 with four
25 additional wells for off-Base capture of the
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1 off-Base plume above the drinking water standards.
2 There would be a total of eight extraction wells
3 along the eastern Base Boundary and four off-Base
4 wells at the drinking water standard boundary.
5 Cleanup time for Alternative 5 would be 160 years
6 for on-Base and 20 years for the off-Base plume.
7 The present worth cost would be $21.8 million.
8 Alternative 6 would involve
9 installation of eight extraction wells along the
10 eastern boundary from Alternative 3, along with four
11 additional wells on the Base at CAOC 26. The
12 alternative would not treat the off-Base portion of
13 the plume. The cleanup of the on-Base plume would
14 take 150 years, and the present worth cost would be
15 $19.3 million.
16 Alternative 8A is the same as
17 Alternative 6 with the addition Air Sparge/Soil
18 Vapor Extraction treatment at CAOC 26.
19 Specifically, there would be eight extraction wells
20 along the eastern Base boundary, four wells
21 downgradient of CAOC 26, and AS/SVE system at
22 CAOC 26. The AS/SVE would clean up the Vadose zone
23 near CAOC 26, which is providing an ongoing source
24 of contamination-to groundwater. The time to clean
25 up the on-Base portion of the plume to below
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1 drinking water standards would be reduced to
2 40 years. The total present worth cost would be
3 $21.3 million.
4 Alternative 8B is the same as
5 Alternative 8A, with the addition of an AS/SVE
6 system downgradient of CAOCs 16, 15/17 and 35. The
7 purpose of the AS/SVE systems at these locations is
8 to further accelerate the groundwater cleanup time.
9 The time to clean the on-Base plume is estimated to
10 be 30 years to a total present worth cost is
11 $22.1 million.
12 Alternative 8C is the same as
13 Alternative 8B, except it captures and treats the
14 off-Base portion of the contaminant plume above the
15 drinking water standards. The cleanup time to
16 drinking water standards would be 30 years on-Base
17 and 20 years off-Base. The total present worth cost
18 would be $27.1 million.
19 Alternative 8D is the same as
20 Alternative 8B with the capture of entire off-Base
21 plume at the background boundary and cleanup of all
22 contaminated groundwater to background levels. The
23 cleanup time for the on-Base portion of the plume is
24 estimated-to be 55 years and 70 years for the
25 off-Base plume. The total present worth cost would
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1 be $49.2 million.
2 For the Yermo Annex Plume the
3 preferred alternative is 8C, which includes
4 extraction wells at the Base boundary at the
5 off-Base drinking water standard boundary and
6 downgradient of CAOC 26 and Air Sparge/Soil vapor
7 Extraction at CAOC 26 and downgradient of CAOC 16,
8 15/17 and 35. This alternative complies with all
9 ARARs.
10 Alternative 8C is protective of human
11 health by achieving safe drinking water standards
12 throughout the entire plume. It controls short-term
13 exposure to contaminated groundwater through
14 monitoring of the plume movement and restricting the
15 use of untreated groundwater for drinking.
16 It provides for source reduction at
17 CAOC 26 to shorten the overall remediation time.
18 Cleanup time for drinking water standards is
19 estimated to be 30 years on-Base and 20 years for
20 the off-Base portion of the plume. The total
21 present worth cost is $27.1 million.
22 Next, I'm going to talk about the
23 Nebo North Plume, which is in OU 2. This plume is
24 the result of operational releases around Warehouse
25 2. The vadose zone contamination in the vicinity of
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1 Warehouse 2 may pose an ongoing long-term threat to
2 groundwater. Chlorinated solvents are the most
3 prevalent contaminants at this site.
4 The Nebo North Plume is approximately
5 4,000 by 1500 feet and appears limited to the upper
6 20 feet of the aguifer. The plume is contained
7 within the Base boundary and appears to be naturally
8 attenuating as a result of shallow groundwater, high
9 fluctuation in water table elevations and sandy soil
10 conditions.
11 Five alternatives were evaluated
12 against NCP criteria for the Nebo North Plume.
13 Briefly, I'd like to discuss each alternative
14 evaluated.
15 Again, Alternative 1 would involve No
16 Action. There would be no action to cleanup the
17 groundwater, and site conditions would remain the
18 same. There's no costs associated with this
19 alternative against its baseline.
20 Alternative 2 is Institutional
21 Controls with Natural Attenuation and fail-safe
22 pump-and-treat containment. This alternative would
23 reguire access restrictions to prevent the use of
24 untreated-groundwater for drinking water purposes.
25 it also reguires wellhead treatment for existing
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1 water supply wells that would be impacted by the
2 plume. There would be long-term groundwater
3 monitoring to tract the movement of the plume and
4 monitor mass reduction, which is expected to occur
5 as a result of natural attenuation. This
6 alternative would also utilize a fail-safe
7 pump-and-treat system that was constructed as part
8 of the existing pilot study. The system would be
9 activated in the event that drinking water standards
10 were exceeded but the downgradient monitoring wells
11 at the site. It would take an estimated 45 years
12 for the contaminant plume to naturally attenuate to
13 levels below the drinking water standards. The
14 total present worth cost of Alternative 2 would be
15 $1 million.
16 Alternative 3 utilizes the existing
17 pump-and-treat system from the pilot study to
18 actively remediate the contaminated groundwater to
19 meet federal and state drinking water standards. It
20 would take about 42 years to cleanup the groundwater
21 to levels below drinking water standards, and the
22 present worth cost of this alternative is
23 $7.1 million.
24 Alternative 4 would be the same an
25 Alternative 3 with the addition of AS/SVE source
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1 reduction around Warehouse 2. This alternative
2 would combine the pilot study pump-and-treat system
3 with AS/SVE system at Warehouse 2. The removal of
4 contaminants in the vadose zone underneath
5 Warehouse 2 is expected to decrease the cleanup time
6 of this plume. Estimated cleanup time for
7 Alternative 4 is 12 years, and the total present
8 worth cost would be $5.8 million.
9 The last remedial alternative
10 evaluated for the Nebo North Plume is Alternative 5,
11 which is the same as Alternative 2, with the
12 addition of AS/SVE at Warehouse 2. Alternative 2
13 included natural attenuation with the fail-safe
14 pump-and-treat and groundwater monitoring. This
15 alternative would clean the groundwater in 15 years,
16 and a total present worth cost of $1.8 million.
17 Each of these alternatives were evaluated against
18 the NCP criteria.
19 The No Action alternative is the only
20 alternative which is not protective of human health
21 and the environment, and therefore, was not
22 considered for further analysis. All other
23 alternatives would be in compliance with ARARs and
24 provide moderate to high long-term effectiveness and
25 performance. They would achieve moderate to high
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1 reduction in toxicity, mobility or volume. All
2 remaining alternatives rely on institutional
3 controls for short-term effectiveness of community
4 protection. They would comply with worker
5 protection requirements and result in minimal
6 environmental impact. Each of the alternatives is
7 readily implemented. The cost range for the various
8 alternatives is from $2.2 to $7.1 million.
9 The preferred alternative for the
10 Nebo North Plume is Alternative 5. This includes
11 Institutional Controls with Natural Attenuation and
12 AS/SVE Source Reduction at Warehouse Number 2. This
13 alternative significantly reduces the total time
14 required to passively remediate the groundwater
15 contamination to levels below the drinking water
16 standard. The total cleanup time is estimated at
17 15 years.
18 Additionally, this alternative is
19 protective of human health, complies with all ARARs,
20 and is cost-effective. The estimated total present
21 worth cost is $1.8 million.
22 Next, I'm going to talk about the
23 Nebo South Plume, which in the result of disposal of
24 cleaning solvents at CAOC 6. Again, chlorinated
25 solvents are the predominant contaminants in these
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1 locations.
2 This plume is approximately 1,000 feet
3 by 800 feet. The leading edge of the plume is
4 downgradient approximately 600 feet from the Base
5 boundary, and it is traveling generally in an east
6 to west direction at 10 to 20 feet per year. Five
7 alternatives were evaluated for the Nebo South
8 Plume.
9 The first alternative in the No Action
10 Alternative. MCLB Barstow would not take any action
11 to cleanup groundwater or limit contaminant
12 migration. Again, this in the baseline. There in
13 no associated costs associated with this. No
14 monitoring or anything else.
15 Second alternative evaluated in
16 Institutional Controls/Groundwater Monitoring. This
17 alternative would reguire access restrictions to
18 prevent the use of untreated groundwater for
19 drinking water purposes. Periodic long-term
20 groundwater monitoring would also be conducted to
21 tract movement of the contaminant plume, monitor the
22 progress contaminant mass reduction and provide
23 advance warning to potentially affected downgradient
24 users. Those are people downstream. It would take
25 over 500 years for the contaminant levels in the
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1 groundwater to drop to levels below the drinking
2 water standards with Alternative 2. The present
3 worth cost of this alternative would be
4 $1.3 million.
5 Alternative 3 for the Nebo South Plume
6 is Groundwater and Vadose Zone Source Reduction at
7 CAOC 6. This alternative involves the existing
8 AS/SVE pilot study system, which is in the vicinity
9 of CAOC 6. This system would not prevent migration
10 of the plume. It would only remove contaminants
11 from the vadose zone soils and groundwater within a
12 limited portion of the plume. This alternative
13 would reguire over 500 years to cleanup the
14 groundwater and contaminant levels below drinking
15 water standards. The present worth cost of this
16 alternative is $3.1 million.
17 Alternative 4 utilizes Alternative 3
18 and expands on the existing pilot scale AS/SVE
19 system to a full-scale AS/SVE treatment system to
20 address source removal at CAOC 6. A groundwater
21 pump-and-treat system is also added to contain the
22 leading edge of this plume. The total time to
23 cleanup the groundwater at Nebo South Plume using
24 this alternative would be 55 years. The present
25 worth cost of this alternative would be
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1 $15.1 million.
2 The last alternative evaluated
3 includes extraction wells at the plume boundary.
4 This alternative provides an interim remedy to
5 contain the contaminant plume until a more effective
6 remedy can be determined. This alternative requires
7 installation of five groundwater extraction wells to
8 contain and extract the groundwater at the
9 downgradient boundary of the plume. The extracted
10 groundwater is treated with activated carbon system
11 and then pumped to the percolating pump to recharge
12 the groundwater. This alternative would take
13 105 years to cleanup the entire plume to levels
14 below drinking water standards. The present worth
15 cost of this alternative is $5.5 million.
16 Each of the five alternatives were
17 evaluated using the criteria previously mentioned on
18 the NCP. Alternative 1, No Action, would not be
19 protective of human health and the environment.
20 Alternatives 2 and 3 for the Nebo South Plume would
21 not be in compliance with ARARs. These two
22 alternatives do not reduce the-chemical-specific
23 contaminant levels to below the federal or state
24 drinking water standards. Alternatives 4 and 5
25 provide long-term effectiveness and permanence and
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1 they reduce toxicity, mobility and volume.
2 Institutional controls are used to minimize
3 short-term risks. Since groundwater cleanup actions
4 require a long-term effort to restore the aguifer,
5 the short-term risks are the same as the current
6 risks. The costs associated with each of the
7 alternatives ranged from $1.3 million for
8 Alternative 2 to $15.1 million for Alternative 4.
9 Alternative 5 is the preferred
10 alternative for the Nebo South Plume. Alternative 5
11 was evaluated and chosen an interim remedy to
12 contain the plume until a final remedy can be
13 determined. This remedy includes groundwater
14 removal and treatment at the downgradient edge of
15 the contaminant plume.
16 This remedy also provides a
17 cost-effective way of preventing further spreading
18 of the contaminated groundwater from this site. The
19 total present worth cost in $5.5 million and would
20 take 105 years to cleanup the entire plume if no
21 further action were taken.
22 This concludes my portion tonight, and
23 I want to thank you. Dave, back to you.
24 MR. DAWSON: This concludes the formal
25 portion of our briefing. I want to respond to any
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1 questions or comments you may have at this time. I
2 would ask -that before you ask questions that you
3 state us; your name and where you're from so it will
4 help create a complete transcript for the
5 administrative record.
6 Are there any questions or comments?
7 MR. CHAVEZ: My name is Lewis Chavez.
8 I just like to ask the question, this plume that we
9 have here, this Yermo, is this around the area of
10 the Silver Valley Hiqh School?
11 MR. COX: No. Silver Valley in
12 actually in the opposite direction.
13 MR. CHAVEZ: On this side. Okay.
14 So this plume in movinq from west to
15 east?
16 MR. COX: Yes.
17 MR. CHAVEZ: Okay. No further
18 questions. Thank you.
19 MR. DAWSON: Any other questions or
20 comments? If not, that will conclude our public
21 meetinq. Thank you for attendinq.
22 (Whereupon, at 8:12 p.m., the public
23 hearinq was adjourned.)
24
25
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1 CERTIFICATE
2 OF
3 COURT REPORTER
4
5 I, MARY ANDERSON, C.S.R. No. 10319, in and
6 for the State of California, do hereby certify:
7 That, prior to being examined, the witness
8 named in the foregoing deposition was by me duly
9 sworn to testify the truth, the whole truth and
10 nothing but the truth;
11 That said deposition was taken down by me in
12 shorthand at the time and place therein named, and
13 thereafter reduced to typewriting under my
14 direction, and the same is a true, correct and
15 complete transcript of said proceedings,
16 I further certify that I am not interested in
17 the event of the action.
18 Witness my hand this 12th day of November,
19 1997.
25
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