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,
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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.
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                                                                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
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    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
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                                                                                                               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
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                                                                    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]) .
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                                                                                      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.
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                                                                                      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.
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                                                                                              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)].
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                              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.
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                                                                                           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.
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                                                                                                                 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.
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                                                                                 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.
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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.
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                                                                              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
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                                                                                                                           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.
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                                                                                            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.
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                                                                                                                           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
-------
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
-------
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
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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
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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
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 (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.
-------
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
-------
            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
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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.
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                                                                                                          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
-------
                                                                                             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
-------
                                                                                             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
-------
                                                                                                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
-------
                                                                                             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
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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               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
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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, 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
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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
                           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
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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  - 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
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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, 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
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                                                                                            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
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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

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
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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             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
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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

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
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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
                                                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
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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
                                                     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
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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, 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
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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

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
-------
                                                                                        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
-------
                                                                                           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

                                     SERVING SOUTHERN CALIFORNIA
                      SPECIALIZING IN CONSTRUCTION,  MEDICAL/TECHNICAL, REAL TIME
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                                    INDEX
       SPEAKER:
            MR. DAWSON

            MR. COX
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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

               ALPHA-OMEGA COURT  REPORTERS
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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

            ALPEA-OMEGA COURT REPORTERS
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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

               ALPHA-OMEGA COURT REPORTERS
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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

                 ALPHA-OMEGA COURT REPORTERS
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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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