SEMS-RM DOCID# 100036901
FINAL
Record of Decision
Newmark Groundwater Contamination Superfund Site
Source Operable Unit
San Bernardino, California
May 9, 2024
EPA Region 5 START V Contract
Document Tracking Number 2216a
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TABLE OF CONTENTS
TABLE OF CONTENTS i
LIST OF ACRONYMS AND ABBREVIATIONS v
PART 1: DECLARATION 1
1.1 Site Name and Location 1
1.2 Statement of Basis and Purpose 1
1.3 Assessment of the Site 1
1.4 Description of Selected Remedy 1
1.5 Statutory Determinations 2
1.6 Data Certification Checklist 3
1.7 Authorizing Signature 4
PART 2: DECISION SUMMARY 5
2.1 Site Name, Location, and Brief Description 5
2.2 Site History and Enforcement Activities 5
2.2.1 Activities that Contributed to the Contamination at the Newmark Site 7
2.2.2 Enforcement Activities at the Newmark Site 8
2.2.3 Community Participation for the Source OU 9
2.3 Scope and Role of Source OU Remedial Action 10
2.4 Conceptual Site Model of the Source Operable Unit 11
2.4.1 Overview 11
2.4.2 Remedial Investigation Strategy 18
2.4.3 Nature and Extent of Contamination 19
2.4.4 Fate and Transport of Contamination 33
2.5 Current and Potential Future Land and Water Uses 33
2.5.1 Land Uses 33
2.5.2 Groundwater 33
2.6 Summary of Site Risks 34
2.6.1 Summary of Human Health Risk Assessment 34
2.6.2 Summary of Ecological Risk Assessment 43
2.6.3 Basis for the Remedial Action 43
2.7 Remedial Action Objectives 43
2.8 Description of Remedial Alternatives 44
2.9 Summary of Comparative Analysis of Alternatives 47
2.9.1 Overall Protection of Human Health and the Environment 47
2.9.2 Compliance with ARARs 48
2.9.3 Long-Term Effectiveness and Permanence 48
2.9.4 Reduction of Toxicity, Mobility, or Volume through Treatment 49
2.9.5 Short-Term Effectiveness 49
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Source Operable Unit, San Bernardino, California
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2.9.6 Implementability 50
2.9.7 Cost 50
2.9.8 State and Community Acceptance 51
2.10 Principal Threat Wastes 52
2.11 Selected Remedy 52
2.11.1 Monitored Natural Attenuation 52
2.11.2 Institutional Controls 53
2.11.3 Vapor Intrusion Assessment 53
2.11.4 Summary of the Estimated Costs for the Selected Remedy 53
2.11.5 Expected Outcome of the Selected Remedy 53
2.12 Statutory Determinations 55
2.12.1 Protective of Human Health and the Environment 55
2.12.2 Compliance with ARARS 55
2.12.3 Cost Effectiveness 55
2.12.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource
Recovery) Technologies to the Maximum Extent Practicable 58
2.12.5 Preference for Treatment as a Principal Element 58
2.12.6 Five-Year Review Requirements 58
2.13 Documentation of Significant Changes 58
2.14 References 59
PART 3: RESPONSIVENESS SUMMARY 61
3.1 Comments Received During the Public Meeting 61
3.2 Questions Asked During the Public Meeting 65
3.3 Comments Received During the Public Comment Period 67
3.4 EPA Responses to SBWMD's Cover Letter Part 1 68
3.5 EPA Responses to SBWMD's Cover Letter Part 2 68
3.6 EPA Responses to SBWMD's Cover Letter Part 3 68
ATTACHMENTS
Attachment A - EPA's Responses to San Bernardino Municipal Water Department's Letter
Dated October 13, 2023
APPENDICES
Appendix A-California Department of Toxic Substances Control Concurrence Letter
Appendix B- Public Meeting Transcript
Appendix C - San Bernardino Municipal Water Department Letter Dated October 13, 2023
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List of Tables
Table 1. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable
Maximum Exposure (RME) Conditions, Residential Receptor EPA Toxicological Values
(from Tetra Tech 2024) 38
Table 2. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable
Maximum Exposure (RME) Conditions, Residential Receptor, DTSC Toxicological
Values (from Tetra Tech 2024) 40
Table 3. Remedial Alternative Cost and Duration 51
Table 4. Remedial Alternative Comparative Analysis 51
Table 5. Chemical-Specific Applicable or Relevant and Appropriate Requirements 56
Table 6. Action-Specific Applicable or Relevant and Appropriate Requirements 57
List of Figures
Figure 1. Site Location and Operable Units (from Tetra Tech 2024) 6
Figure 2. Regional Topography of Source Operable Unit (from Tetra Tech 2024) 12
Figure 3. Structural Geology of the San Bernardino, California Area (from Tetra Tech 2024) .... 14
Figure 4. Geologic Cross-Section Showing How Bedrock Surface Could Represent Faulting or an
Erosional Escarpment (from Tetra Tech 2024) 15
Figure 5. Regional Groundwater Flow Direction in the Bunker Hill Basin: October 2022
(from Tetra Tech 2024) 16
Figure 6. Reduction of PCE Plume Size, Morphology, and Mass: 1997 to 2022
(from Tetra Tech 2024) 20
Figure 7. Reduction of Site-Wide PCE Mass: 2013-2022 (from Tetra Tech 2024) 22
Figure 8. Reduction of PCE Plume Size, Morphology, and Mass: 2019 to 2022
(from Tetra Tech 2024) 23
Figure 9. Concentrations of PCE in Groundwater in Northwest Area Monitoring Wells: Fall 2018-
Fall 2022 (from Tetra Tech 2024) 25
Figure 10. Groundwater Flowpath Analysis Showing Radial Flow Pattern: 2012
(from Tetra Tech 2024) 26
Figure 11. PCE Concentration vs. Time Trends along the Former Steel Mill Flow Path; Northwest
Area (from Tetra Tech 2024) 27
Figure 12. Hydraulic Head and PCE Concentration at Former Hospital Flow Path
(from Tetra Tech 2024) 28
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Figure 13. Locations of Soil Gas and Other Investigations of the Northwest Area of the Source
OU (from Tetra Tech 2024) 30
Figure 14. Results of Soil Gas and Other Investigations in the Northwest Area of the Source OU
(from Tetra Tech 2024) 32
Figure 15. Conceptual Site Model Human Receptors (from Tetra Tech 2024) 35
Figure 16. Proposed Institutional Controls Boundary in the Northwest Area
(from Tetra Tech 2024) 54
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LIST OF ACRONYMS AND ABBREVIATIONS
§ Section
Hg/L micrograms per liter
l-ig/m3 micrograms per cubic meter
3DVA three-dimensional datavisualization and analysis
amsl above mean sea level
ARAR applicable or relevant and appropriate requirement
Basin Plan Water Quality Control Plan for the Santa Ana Basin
bgs below ground surface
CCR California Code of Regulations
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CERCLIS Comprehensive Environmental Response, Compensation, and Liability
Act Information System
CFR Code of Federal Regulations
City City of San Bernardino
COC contaminant of concern
COPC contaminant of potential concern
CSM conceptual site model
DHS California Department of Health Services
DNAPL dense non-aqueous phase liquid
DO dissolved oxygen
DTSC California Department of Toxic Substances Control
EIS extremely impaired source
EPA U.S. Environmental Protection Agency
EPC exposure point concentration
ESD Explanation of Significant Differences
FFS focused feasibility study
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Freon-11 trichlorofluoromethane
Freon-12 dichlorodifluoromethane
GAC granular activated carbon
HERO California DTSC Human and Ecological Risk Office
HHRA human health risk assessment
HRSC high-resolution site characterization
IC institutional controls
IROD Interim Record of Decision
lbs pounds
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
MNA monitored natural attenuation
MWH Montgomery, Watson, Harza
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
Newmark Site Newmark Groundwater Contamination Superfund Site
O&M operation & maintenance
ORP oxygen-reduction potential
OU Operable Unit
PCE tetrachloroethene
PCSM preliminary conceptual site model
RBSL risk-based screening level
RAO remedial action objective
Rl remediation investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
Regional Water Board Santa Ana Regional Water Quality Control Board
SDWA Safe Drinking Water Act
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Stantec
Stantec Consulting Corporation
TCE
Trichloroethene
U.S. Army
United States Department of the Army
U.S.C
United States Code
UU/UE
unlimited use/unrestricted exposure
VISL
vapor intrusion screening level
VOC
volatile organic compound
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PART 1: DECLARATION
1.1 Site Name and Location
Newmark Groundwater Contamination Superfund Site
Source Operable Unit (OU)
San Bernardino, California
The Newmark Groundwater Contamination Superfund Site (Newmark Site) was listed on the
National Priorities List in 1989. The US Environmental Protection Agency (EPA) Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Information System
(CERCLIS) identification number for the site is CAD981434517.
The Newmark Site includes three operable units (OU): Newmark OU, Muscoy OU, and Source
OU. This Record of Decision (ROD) addresses the Source OU.
1.2 Statement of Basis and Purpose
This ROD presents the selected remedy for the groundwater contamination within the Source
OU at the Newmark Site in San Bernardino, California. The remedy focuses on groundwater in
the Northwest Area (formerly known as the Northwest Source Area) of the Source OU because
that is the only remaining portion of the Source OU that requires a remedial action. The remedy
was selected in accordance with CERCLA, as amended by the Superfund Amendments and
Reauthorization Act (SARA), and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
The State of California, acting through the Department of Toxic Substances Control (DTSC),
concurs with the selected remedy. The concurrence letter from DTSC is included as Appendix A.
1.3 Assessment of the Site
EPA has determined that there are potential human health risks associated with exposure to the
chlorinated volatile organic compound (VOC) tetrachloroethene (PCE), which is present in
Northwest Area groundwater at concentrations exceeding the 5 micrograms per liter (|ag/L)
maximum contaminant level (MCL) promulgated under the Safe Drinking Water Act (SDWA).
The remedial action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment. The selected remedy is based on and relies upon the Administrative Record File for
this remedial action.
1.4 Description of Selected Remedy
EPA has selected Alternative 2, Monitored Natural Attenuation (MNA), Institutional Controls
(IC), and a Vapor Intrusion Assessment as the remedy for groundwater contamination in the
Northwest Area of the Source OU. This remedy consists of monitoring the continued natural
attenuation of PCE concentrations in groundwater, implementing ICs to prevent the
construction of groundwater wells in the Northwest Area, and completion of a vapor intrusion
assessment in the Northwest Area.
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The components of the Selected Remedy include:
• Monitored Natural Attenuation -Twenty-five years of groundwater data (from 1997
to 2022) from groundwater monitoring wells in the Northwest Area indicate that
abiotic natural attenuation for groundwater restoration is occurring throughout the
Source OU, which reduced the size of the PCE plume, and reduced PCE concentrations
and mass. Data indicate that PCE concentrations in groundwater continue to approach
the SDWA MCL for PCE of 5 |ag/L. By Fall 2022, PCE exceeded the 5 |ag/L MCL in only
two monitoring wells within the Northwest Area. Estimates of when the MCL will be
achieved in all groundwater wells in the Northwest Area under natural attenuation
processes, developed based on statistical analyses and groundwater fate and
transport modeling, varied from 10 to 47 years. Groundwater monitoring of natural
attenuation progress will continue to provide information on groundwater
contamination conditions in the Northwest Area and indicate when the 5 |ag/L
remediation goal for PCE has been met.
• ICs - ICs, required by San Bernardino Municipal Code at Title 13, Chapter 13.25 and San
Bernardino County, will be used to restrict the construction of groundwater wells in the
vicinity of the Northwest Area plume to prevent human exposure to PCE-contaminated
groundwater.
• Vapor Intrusion Assessment - Based on the remaining PCE concentrations in
groundwater, potential migration of PCE vapors through soil remains a concern.
Therefore, EPA will complete a vapor intrusion assessment in the Northwest Area.
This is the final remedy for the Source OU and the Newmark Groundwater Contamination
Superfund Site.
The Newmark Site was divided into three operable units: Newmark OU (encompassing the
eastern lobe of the VOC groundwater plume); Muscoy OU (encompassing the western lobe of
the VOC groundwater plume); and the Source OU (encompassing the entire Newmark Site). EPA
signed a ROD selecting a remedy for the Newmark and Muscoy OUs in 2015 (EPA 2015). In this
ROD for the Source OU, EPA is selecting a remedy that focuses on the Northwest Area because
it is the only remaining portion of the Source OU for which contamination in groundwater does
not have a remedy in place. This remedy does not affect the groundwater plume in the
Newmark and Muscoy OUs or the final remedy selected for the Newmark and Muscoy OUs in
the 2015 ROD.
1.5 Statutory Determinations
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are applicable or relevant and appropriate (ARAR) to the remedial
action (no ARAR waiver is being sought in this ROD), is cost-effective, and uses permanent
solutions and alternative treatment (or resource recovery) technologies to the maximum extent
practicable.
The remedy in this ROD does not satisfy the statutory preference for treatment as a principal
element of the remedy. Site historical data indicates that concentrations of PCE in groundwater
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at the site are declining through natural attenuation processes such that concentrations of PCE
in only two groundwater monitoring wells in the Northwest Area exceeded the 5 |ag/L MCL
remediation goal as of Fall 2022. The natural decline in PCE concentrations is expected to
continue until the remediation goal is reached in the Northwest Area in an estimated 10 to 47
years. In-situ treatment was evaluated as Alternative 3 in the Remedial Investigation
(RI)/Focused Feasibility Study (FFS) report developed for the Source OU (Tetra Tech 2024). In-
situ treatment under Alternative 3 is expected to reach the remediation goal for PCE in 7 to 20
years; this timeframe is not appreciably faster than the time to achieve the remediation goal
with natural attenuation processes under Alternative 2. Alternative 3 is not cost-effective since
it will not reach the remediation goal much faster, and it is almost 8 times more expensive than
the cost for Alternative 2 (the selected remedy).
CERCLA Section (§) 121 requires five-year reviews (statutory reviews) of sites where the
remedial action does not result in unlimited use and unrestricted exposure (UU/UE). EPA also
completes five-year reviews as a matter of policy (policy reviews) for sites where the remedial
action will result in UU/UE but will take more than 5 years to achieve UU/UE. Achieving the 5
Hg/L MCL remediation goal for PCE will allow for UU/UE for the groundwater. However,
achieving the remediation goal is estimated to take longer than 5 years. Therefore, EPA will
complete CERCLA five-year policy reviews until the remediation goal for PCE is met. EPA
currently completes CERCLA five-year reviews for the Newmark and Muscoy OUs; thus, EPA will
include the five-year review of this remedy for the Northwest Area of the Source OU in future
five-year reviews of the Newmark and Muscoy OUs. The next five-year review will be
completed in 2028.
1.6 Data Certification Checklist
The following information is included in Part 2 - Decision Summary of this ROD.
• Chemicals of concern (COC) and their respective concentrations (Section 2.4);
• Baseline risk represented by the COCs (Section 2.6);
• Cleanup levels established for the COCs and the basis for these levels (Section 2.7);
• How source materials constituting principal threats are addressed (Section 2.10);
• Current and reasonably anticipated future beneficial uses of groundwater used in the
baseline risk assessment and ROD (Section 2.5);
• Potential groundwater use that will be available at the site as a result of the selected
remedy (Section 2.11.2);
• Estimated capital, annual operation and maintenance (O&M), and total present worth
costs, discount rate, and the number of years over which the remedy cost estimates are
projected (Section 2.11.1); and
• Key factor(s) that lead to selecting the remedy (Section 2.11).
Additional information can be found in the Administrative Record File for this remedial action.
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1.7 Authorizing Signature
This ROD documents the remedy selected for the groundwater contamination within the
Northwest Area of the Source OLJ at the Newmark Groundwater Contamination Superfund Site,
located in San Bernardino, California. This remedy is selected by EPA with concurrence by the
State of California, as indicated by the DTSC's concurrence letter (Appendix A). The Director of
EPA's Regional Superfund and Emergency Management Division has been delegated the
authority to approve and sign this ROD.
r a I/-M * ri Digitally signed by MICHAEL
IVll^nAtL MONTGOMERY
MONTGOMERY D0a7te002024 05 21 17:13 14 n
By: ~u/ uu Date:
Michael M. Montgomery, Director
Superfund and Emergency Management Division
U.S. Environmental Protection Agency; Region 9
Pacific Southwest Region
San Francisco, California
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Source Operable Unit, San Bernardino, California
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PART 2: DECISION SUMMARY
Documents supporting this Record of Decision (ROD) are included in the U.S. Environmental
Protection Agency's (EPA) Administrative Record for the Newmark Groundwater Contamination
Superfund Site. An index to the documents is also contained in Administrative Record.
2.1 Site Name, Location, and Brief Description
The Newmark Groundwater Contamination Superfund Site (Newmark Site) is located in San
Bernardino, California and includes a 23 square mile area (Figure 1). The Newmark Site was
listed on the National Priorities List (NPL) in 1989. The EPA CERCLIS identification number for
the site is CAD981434517.
The Newmark Site lies within the San Bernardino Valley, southeast of the San Gabriel
Mountains and southwest of the San Bernardino Mountains. The Newmark Site consists of a
chlorinated volatile organic compound (VOC) plume in groundwater and is located within the
Bunker Hill Groundwater Basin. The Newmark Site was divided into three operable units (OU):
the Newmark OU, Muscoy OU, and Source OU (Figure 1).
EPA has already selected a final remedy for the Newmark and Muscoy OUs in a ROD issued in
2015 (EPA 2015). The remedy selected in this ROD for the Source OU is a final remedy focused
on the Northwest Area (formerly known as the Northwest Source Area) of the Source OU,
because that is the only remaining portion of the Source OU with contamination in
groundwater that requires remedial action. The remedy selected in this ROD does not affect the
groundwater plume in the Newmark and Muscoy OUs or the remedy selected for the Newmark
and Muscoy OUs in the 2015 ROD (EPA 2015).
In accordance with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), EPA Region 9 is the lead agency for the Newmark Site. DTSC is the primary State support
agency.
2.2 Site History and Enforcement Activities
The following sections summarize the history of the Newmark Site and previous remedial
activities and enforcement activities. This section addresses the entire Newmark Site, including
all three of the OUs, because they have a common history and have been subject to common
enforcement activities.
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Figure 1. Site Location and Operable Units (from Tetra Tech 2024)
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2.2.1 Activities that Contributed to the Contamination at the Newmark Site
VOC groundwater contamination was first discovered in San Bernardino in 1980, when the
California Department of Health Services (DHS) initiated a water supply monitoring program to
test water from public water supply wells for the presence of industrial chemicals. The results
of this groundwater monitoring and testing program revealed the presence of VOC
contaminants in groundwater.
Groundwater analytical sampling results collected from eight municipal water supply wells
identified VOCs, primarily PCE and trichloroethene (TCE), at concentrations exceeding federal
and state drinking water standards. Subsequent groundwater investigations conducted from
1980 to 1986 by both DTSC and the Santa Ana Regional Water Quality Control Board (Regional
Water Board) found extensive groundwater contamination, which resulted in the eventual
closure of 20 water supply wells within a 6-mile radius of the site.
Therefore, on October 30,1986, DTSC contracted with the City of San Bernardino (City) to
construct, operate, and maintain groundwater extraction wells and treatment systems
consisting of air stripping and liquid phase granular activated carbon (GAC) units. These
systems, located at existing City facilities, were intended to capture contaminated groundwater
to inhibit the migration of groundwater contamination into clean portions of the aquifer and
treat the contaminated water for use as part of the municipal water supply.
EPA listed the Newmark Site on the NPL on March 31,1989.
The United States Department of the Army (U.S. Army), EPA, DTSC, the City, and the County of
San Bernardino, conducted several investigations to identify sources of the release of the VOCs.
These investigations focused on a number of areas, including the former Camp Ono, the Cajon
Landfill, and a solvent disposal pit near the former San Bernardino International Airport. Based
on historical site investigation work within the Source OU, the original sources of the PCE plume
were determined to be from one or more areas withing the boundaries of former Camp Ono
and the Cajon Landfill in the Northwest Area. The former San Bernardino International Airport
was determined not to be a source of the contamination.
Additional data subsequently indicated the presence of residual contamination in bedrock in
the Northwest Area. The residual contamination appears to be related to releases from the
hospital at former Camp Ono located to the north of the Verdemont Hills and/or an original
release from, or within the area of, a former steel mill located within the footprint of former
Camp Ono to the south of the Verdemont Hills (Tetra Tech 2024). An inspection of the steel mill
site conducted by the County of San Bernardino Department of Environmental Health Services
identified an overturned drum marked PCE and an uncovered water well and a sump, "which
was apparently used to catch waste fluids from operations" (EMCON 1995).
As part of EPA source investigation efforts conducted in 2012, EPA searched a commercial
online environmental database and several federal and state databases to (1) identify sites of
potential interest throughout the Source OU that could be potential sources of contamination
contributing to the Newmark and Muscoy plumes, and (2) further confirm the Northwest Area
as the source for the Newmark and Muscoy plumes (Tetra Tech 2014). The data generated by
these searches were sorted and reviewed to evaluate which sites warranted further inquiry to
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determine whether they were known sites of concern with active or proposed site
investigations or remediation efforts. Sites were sorted based on site types and various
indicator attributes to isolate sites with a reasonable potential for environmental
contamination concerns. For example, all dry-cleaning sites were retained based on their
common association with PCE-contaminated groundwater. Sites with known spills or actively
under federal or state cleanup enforcement were retained. Sites with listings based on low-
impact, compliance-related issues were eliminated. None of these sites was found to be of
environmental concern, supporting the investigation-based conclusion that there were no
indications of any additional significant sources for the groundwater contamination within the
Source OU. Further, three-dimensional data visualization and analysis (3DVA)-based site
evaluation and remedial progress monitoring efforts performed using site data from 2012
through 2023, substantiated that there were no additional significant sources within the Source
OU outside the Northwest Area (Tetra Tech 2014 and 2023).
2.2.2 Enforcement Activities at the Newmark Site
In August 1993, EPA issued an Interim Record of Decision (IROD) for the Newmark OU
groundwater contamination, selecting groundwater extraction (pumping) and treatment at the
leading edge of the contaminant plume (EPA 1993a). The remedy selected in the IROD was
constructed from 1996 to 2000. The Newmark OU system was determined to be operational
and functional in October 2000. The City began operation and maintenance (O&M) of the
Newmark OU interim remedy in October 2000, under a Cooperative Agreement with EPA.
In March 1995, EPA issued an IROD for the Muscoy OU groundwater contamination, selecting
groundwater extraction and treatment at the leading edge of the contaminant plume (EPA
1995). The interim remedy was constructed from 2001 through 2007. The Muscoy OU system
was determined to be operational and functional in September 2007 and the City's O&M of the
Muscoy OU started in October 2007. EPA transferred the Lead Oversight Agency role for the
O&M activities to DTSC.
In 2004, EPA issued an Explanation of Significant Differences (ESD) for the Newmark and
Muscoy IRODs requiring an institutional control (IC) program to protect the performance of the
interim remedies (EPA 2004). These ICs were implemented to ensure that the Newmark and
Muscoy extraction and treatment systems would remain effective in meeting the objectives of
capturing contaminated groundwater and inhibiting the migration of groundwater
contamination into clean portions of the aquifer. The ESD required the City to adopt an
ordinance or develop a groundwater management program to prevent extraction which could
interfere with the integrity of the interim remedies within the zone of influence of the
Newmark and Muscoy systems. The City adopted the necessary ordinance on March 20, 2006,
in Title 13, Chapter 13.25 of the San Bernardino Municipal Code, which requires entities that
propose to install or modify a production well or modify artificial recharge practices within a
designated management zone, to submit a permit application (or functional equivalent)
detailing the location, construction, and pumping rate of the proposed well, or the location and
volume of water of a proposed artificial recharge activity.
In 2005, a Consent Decree (CD) for the Newmark Site was signed between the EPA, U.S. Army,
DTSC, and the City to settle a case brought by DTSC and the City against the U.S. Army. This
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2005 CD established escrow accounts for the City to (1) perform O&M of the Newmark and
Muscoy remedy systems for the time periods specified in the CD and (2) pay for the
construction of additional extraction wells as needed. The O&M requirements for the Newmark
and Muscoy interim remedies are established in the Statement of Work which is included as
Appendix D of the CD. This settlement also provided funding to EPA for response costs under
CERCLA, including for investigation of the Source OU (referred to as the Source Control OU in
the 2005 CD) and to DTSC for oversight requirements.
In 2007, a CD for the Newmark Site was signed between the United States and the County of
San Bernardino to settle a case brought by the United States on behalf of EPA against the
County of San Bernardino. This settlement provides funding to EPA for response costs under
CERCLA at the Newmark Groundwater Contamination Site, including the Source OU (referred to
as the Source Control OU in the 2007 CD).
In August 2015, EPA issued a ROD for the Newmark and Muscoy OUs (EPA 2015). The ROD
selected final remedies for the Newmark and Muscoy OUs by adopting all the components and
performance requirements of the Newmark and Muscoy IRODs and the ESD. Section 2.3
provides information on the 2015 ROD.
2.2.3 Community Participation for the Source OU
EPA has kept the San Bernardino community and other interested parties apprised of activities
at the Newmark Site through informational meetings, fact sheets, press releases, and public
meetings. EPA has conducted community involvement activities to support selection of the final
remedy for the Source OU in accordance with CERCLA Section (§) 117 (42 United States Code
[U.S.C] § 9617) and the NCP at 40 Code of Federal Regulations (CFR) § 300.430(f)(3).
EPA completed the following community involvement activities for this Source OU ROD:
• Notices of the Proposed Plan, public meeting, and public comment period were
published in La Opinion newspaper on August 14, 2023, and in Black Voice News online
newspaper on August 17, 2023.
• Notices of the Proposed Plan and extension of the public comment period were
published in La Opinion newspaper on August 22, 2023, in Black Voice News online
newspaper on August 24, 2023, and in The Press-Enterprise on September 2, 2023.
• Postcard notices were mailed to the community on August 17, 2023, to inform the
community of the Proposed Plan, public meeting, and public comment period.
• The RI/FFS (Tetra Tech 2023), Proposed Plan (EPA 2023b), and other supporting
documents were made available to the public on August 14, 2023. These documents are
contained in the EPA's Administrative Record File and the information repository
maintained at the California State University, San Bernardino's John M. Pfau Library.
• EPA held a public meeting in San Bernardino on August 23, 2023, where the Proposed
Plan (EPA 2023) describing the preferred alternative was presented and oral comments
and questions from the community were formally recorded. Public comments and
questions from the public during the meeting and EPA's responses to the public comments
and questions are summarized in Part 3, Responsiveness Summary. In addition, a copy
of the transcript of the public meeting is included as Appendix B.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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• EPA also held a public comment period from August 14, 2023 through October 13, 2023.
The public could submit comments to the EPA via email, telephone, or the postal
service. Comments from the public received during the comment period and EPA's
responses to the public comments are also summarized in Part 3, Responsiveness
Summary.
• EPA updated the RI/FFS (Tetra Tech 2024) based on comments received during the
public comment period and made the document available to the public through the
Administrative Record.
• EPA will announce the availability of this final Source OU ROD and make it and the
supporting information available to the public through the Administrative Record and
information repository.
2.3 Scope and Role of Source OU Remedial Action
EPA divided the Newmark Site into three OUs to manage cleanup activities (Figure 1): Newmark
OU - to address the Newmark lobe of the groundwater plume; Muscoy OU - to address the
Muscoy lobe of the groundwater plume; and the Source OU - encompassing the entire
Newmark Site to address any additionally identified source(s) of groundwater contamination.
EPA selected final remedies for the Newmark OU and Muscoy OU in the 2015 ROD (EPA 2015).
The selected final remedies include (1) extraction and treatment of contaminated groundwater,
(2) groundwater monitoring to monitor the extent of contamination, hydraulic control, and
cleanup progress, and (3) ICs to prevent exposure to contaminated groundwater (EPA 2015).
Three treatment systems are associated with the Newmark and Muscoy OUs ROD - the
Waterman Treatment System, the Newmark Treatment System, and the 19th Street North
Treatment System. Fourteen extraction wells that are used to supply drinking water to the
public are associated with these three treatment systems. These 14 extraction wells are
designated in the 2015 ROD (EPA 2015) as extremely impaired source (EIS) wells pursuant to
the State of California Department of Public Health Drinking Water Division Policy Memo 97-
005 and San Bernardino Municipal Water Division Public Water Supply Permit Number 03-13-
9P-002. The performance standard for the ElS-designated extraction wells is treatment to no
detectable concentrations of PCE and TCE at the analytical detection limit of 0.5 |ag/L. ICs
identified in the 2015 ROD include a City ordinance. Municipal Code Title 13, Chapter 13.25
identifies a groundwater management zone within which a permit is required to construct new
groundwater wells, or to reconstruct existing groundwater wells to increase the well capacity
(groundwater extraction), or to spread water (spreading). Approval of the permits is predicated
on a demonstration that groundwater extraction or spreading will not affect the Newmark and
Muscoy OUs remedies, compliance with the 2005 CD, or other approved plans using the San
Bernardino Basin Area Groundwater Flow Model1. The model, which was developed and is
maintained by the San Bernardino Municipal Water Department, is currently under review by
EPA.
In this ROD, EPA is selecting a final remedy for the Source OU. Although this Source OU ROD
geographically encompasses the entire Newark Site, the final remedy for the Source OU focuses
only on the Northwest Area because it is the only remaining portion of the Source OU that
1 The San Bernardino Basin Area Groundwater Flow Model was formerly referred to as the Newmark Groundwater Flow Model.
Newmark Groundwater Contamination Superfund Site Final Record of Decision
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requires remedial action and that does not have a final remedy in place. The final remedy
selected in the Source OU ROD does not affect the Newmark or Muscoy OUs, the PCE plume
lobes present within the boundaries of each the OUs, or the final remedies selected in the 2015
ROD. Further, the residual PCE mass present in the Northwest Area is no longer serving as the
source of the Newmark or Muscoy plume lobes, whether at concentrations at and above 5 |ag/L
(the SDWA MCL) or at and above 0.5 |ag/L (the performance standard for the ElS-designated
extraction wells) (Tetra Tech 2024).
2.4 Conceptual Site Model of the Source Operable Unit
This section summarizes the conceptual site model (CSM) for the Source OU, based on
information obtained through remedial investigations, groundwater monitoring, and 3DVA-
based remedial progress monitoring for the site. The nature and extent of groundwater
contamination in the Source OU and within Northwest Area are also described.
2.4.1 Overview
The Source OU lies within the San Bernardino Valley, southeast of the San Gabriel Mountains
and southwest of the San Bernardino Mountains (EPA 1994). Several local topographic highs
are present within the Source OU, most notably Shandin Hills (located to the southeast) (See
Figure 2). These topographic highs are bedrock outcroppings created by tectonic movements
along the northwestward-trending San Jacinto fault, which bounds the basin to the
west/southwest, and the San Andreas fault, which bounds the basin to the east/northeast.
From the northwestern corner of the Source OU, ground surface elevations decline from
approximately 1,750 feet to approximately 1,050 feet above mean sea level (amsl) along the
southeastern boundary of the OU. The maximum topographic elevation within the OU is 1,850
feet amsl at the summit of Shandin Hills (Stantec Consulting Corporation [Stantec] 2008).
The Source OU is located in the Upper Santa Ana River Basin in an area of water-bearing,
alluvial fan-type deposits known as the Bunker Hill-A Groundwater Basin (Stantec 2008). Stream
flow originates from mountainous regions near the groundwater basin and is intermittent.
During storms, stream flow discharges from the mountain canyons and enters the valley,
crossing alluvial fan deposits along its perimeter and then feeding the Santa Ana River, Mill
Creek, Lytle Creek, and Cajon Creek. Lytle Creek flows southeastward in a wide lowland known
as the Cajon Wash, which borders the Source OU to the west. Southeastward-flowing Cable
Creek occupies the lowland area west of Verdemont Hills. Approximately 1.5 miles south of
Verdemont Hills, the Cable Creek Channel bends to the southwest to join Lytle Creek at a point
approximately 2 miles west of Shandin Hills.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Figure 2. Regional Topography of Source Operable Unit (from Tetra Tech 2024)
Verdemont Hills
Note: Portions of the Verdemont Hills were removed to local
grade in 2013/2014 and 2020 in support of building construction.
Shandin Hills
Source OU
~ Source OU Boundary
2 Miles
Newmark Groundwater Contamination
Superfund Site
San Bernadino, California
Figure 2
Regional Topography of Source Operable Unit
(Modified from: Tetra Tech 2014)
"It
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
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Geology beneath the site includes two primary geologic units: unconsolidated sedimentary
deposits and the underlying Pelona schist bedrock (weathered and unweathered). The
unconsolidated sedimentary deposits are primarily water-bearing alluvium derived from the
San Gabriel Mountains to the northwest and the San Bernardino Mountains to the northeast.
The alluvium is highly heterogeneous, including clay, silt, sand, and gravel deposits. Erosion of
the San Gabriel and San Bernardino mountains formed the confluent alluvial fans at the base of
the mountains of the San Bernardino Valley. The thickness of alluvium within the San
Bernardino Valley varies, increasing from 400 feet at the base of the San Bernardino Mountains
to as much as 2,100 feet at the center of the valley in the vicinity of the Loma Linda and San
Jacinto fault zone.
Several faults exist in the region, including the San Andreas, San Jacinto, and Loma Linda faults,
which trend in the northwest/southeast direction (Figure 3) (Stantec 2008). Although significant
faulting exists in the basement bedrock, the overlying sediments show little if any expression of
these faults within the boundaries of the Source OU. The only identified fault within the
Northwest Area is the Loma Linda Fault, which is located downgradient of the potential source
areas in the Northwest Area; therefore, it does not affect contaminant transport in the
Northwest Area. Previous investigations have posited that several additional northwest-striking
faults, subparallel to the San Andreas Fault system are present in the Northwest Area (EMCON
1995; URS 2008). The offset in bedrock elevation between two closely spaced (400 to 600 feet
apart) wells provides the primary support for the existence of a fault in this area. However, as
shown on Figure 4, the results of a seismic survey of the area (EMCON 1995) show that it is also
possible that the abrupt change in the bedrock surface is simply a buried erosional escarpment,
unrelated to faulting.
As shown on Figure 5, the long-term, general groundwater flow direction within the alluvial
aquifer at the Newmark Site is northwest to southeast. The alluvial aquifer at the Newmark Site
is understood to be hydraulically connected to the Pelona Schist bedrock; therefore, the
alluvium and bedrock are assumed to behave as one aquifer system.
The Source OU lies primarily within the limits of the City of San Bernardino. Land use in the City
includes California State University in the northern portion of the city, residential properties
including single and multi-family dwellings, commercial establishments, light industrial facilities,
heavy industrial facilities, public facilities, open space, and golf courses. Land uses within the
Source OU are primarily industrial and commercial, with some residential communities.
Commercial and industrial land use predominantly occurs south of the downtown area;
however, in recent years it has expanded to include portions of the Northwest Area. Urban
commercial development within the Source OU has replaced much of the native habitat and
landscape.
The Northwest Area includes former and current uses such as portions of the former Camp Ono
World War II U.S. Army installation, the Cajon Landfill, a railroad, and more recently, newly
constructed commercial structures and light and heavy industry.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Figure 3. Structural Geology of the San Bernardino, California Area (from Tetra Tech 2024)
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 3
Structural Geology of the San Bernardino, California Area
(Modified from: Stantec 2008)
TETRA TECH
Legend
1 | Model Boundary
Named Feulln/Groundwatef Berrien
Faults (Morion and Miler. 2003)
Mijoi Rood#
mm FWorw SdiW
DRAFT
r aula ana GfounC* ¦ »i 3an*-a adapted sfcn
Mailt'1 a-d Mill#.' 2903 (xNwr r »d)
CXtchcr ami Gar rat 1303 ithomr n uj»:
3 4.000 I7CC3 ?*,xxi
i i i i i i i i I
VM
btafbM. UOtmi^UZmll
For Ctfy of Sari E
Municipal Water Depart mar*
Named Faults and
Groundwater Flow Barriers
Date
10/03/08
Fiqure:
4-2
Newmark Groundwater Contamination Superfund Site Final Record of Decision
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Figure 4. Geologic Cross-Section Showing How Bedrock Surface Could Represent Faulting or an Erosional Escarpment
(from Tetra Tech 2024)
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 4
Geologic Cross-Section Showing How Bedrock Surface Could Represent Faulting or an Erosional Escarpment
Modified from: URS 2008
It
TETRA TECH
Qa Quaternary Alluvium X Groundwater Elevation - Fall 2006
I Groundwater Elevation - Spnng 200C
Quaternary Colluvium
Mzp Pokxia Schist
A
1 Cajon Landfill
URS
Newmark Source OU
Generalized Geologic Cross Section A - A'
Downgradient of Cajon Landfill
with Groundwater Elevation Data
from Spring 2000 and Fall 2006
Bedrock surface based on Spectrum
Geophysical survey (April 1990)
(Dashed where extrapolated)
MWCOE004
CJ-6 CJ-10
Potential Erosional Escarpment
Bedrock Surface
Mzp
Fault Block B
Fault Block A
Newmark Groundwater Contamination Superfund Site Final Record of Decision
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Figure 5. Regional Groundwater Flow Direction in the Bunker Hill Basin: October 2022 (from Tetra Tech 2024)
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 5
Regional Groundwater Flow Direction in Bunker Hill Basin: October 2022
"It
TETRA TECH
LEGEND
• 25-foot Potentiometric
Isocontour Interval
General Groundwater
Flow Direction
Newmark Groundwater Contamination Superfund Site Final Record of Decision
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According to an EJSCREEN Community Report for the Source OU (produced using EPA's
Environmental Justice Screening and Mapping Tool), data from the Census Bureau American
Community Survey (ACS) for the 2017-2021 time period indicates that 192,365 people lived
within 1 mile of the Source OU during this period. Approximately 7 percent of the population at
that time was between the ages of 1 and 4 years old, 30 percent was between the ages of 1 and
18 years old, 61 percent was between the ages of 18 and 64 years old, and 9 percent was age
65 years and older. The racial make-up of the population was 47 percent White, 12 percent
Black, 3 percent Asian, 1 percent Native American, 27 percent Other Race, and 11 percent
identified as Two or More Races. Seventy-one (71) percent of the population also identified as
Hispanic (Tetra Tech 2024).
According to the EJSCREEN Community Report, the per capita income was $20,819 for the
Source OU. The number of low-income earners was 49 percent for the Source OU, compared to
the state average of 28 percent and national average of 31 percent. The unemployment rate for
the Source OU was 9 percent, compared to the state average of 7 percent and national average
of 6 percent.
According to the EJSCREEN Community Report for the Northwest Area, using data from the
Census Bureau's ACS for the 2017-2021 period, 36,649 people lived within 1 mile of the
Northwest Area. Approximately 9 percent of the population was between the ages of 1 and 4
years old, 30 percent was between the ages of 1 and 18 years old, 63 percent was between the
ages of 18 and 64 years old, and 7 percent was age 65 years and older (Tetra Tech 2024). The
racial make-up of the population was 54 percent White, followed by 9 percent Black, 4 percent
Asian, 1 percent Native American, 18 percent Other Race, and 14 percent identified as Two or
More Races. Seventy (70) percent of the population also identified as Hispanic (Tetra Tech
2024).
A review of socioeconomic indicators within a 1-mile radius of the Northwest Area of the
Source OU indicated that (Tetra Tech 2024):
• Approximately 35 percent of the population qualified as low income; compared to the
state average of 28 percent;
• Eighty-five (85) percent of the population consisted of persons of color; compared to a
state average of 61 percent;
• Approximately 26 percent of the population had less than a high school education;
compared to the state average of 16 percent;
• Six (6) percent of the population was characterized as Limited English-Speaking
Households; compared to the state average of 9 percent;
• The average life expectancy was 78 years;
• Per capita income was $22,828;
• The unemployment rate was 10 percent; compared to the state average of 7 percent;
and
• There were 9,163 households; 64 percent of these were owner occupied.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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2.4.2 Remedial Investigation Strategy
In 2012, EPA began using 3DVA software and methods to develop a preliminary conceptual site
model (PCSM) for the site to support the planning of an Rl for the Source OU (Tetra Tech 2014).
The objective of the initial 3DVA effort was to evaluate site groundwater data collected from
1997 through 2012 to answer the following key technical questions in support of PCSM
development:
1. Is there evidence of ongoing sourcing from the Northwest Source Area?
2. Is it possible for Northwest Source locations to be the sole source of the Newmark and
Muscoy plumes?
3. Are Newmark/Muscoy plume distribution and mass:
o Increasing / decreasing / not changing with time and installation of treatment
systems?
4. Is the time to achieve restoration using the present treatment systems reasonable
without system modification or additional monitoring points?
o If not, what can be done to ensure restoration within a reasonable time frame?
Because the Source OU includes the entire footprints of both the Newmark and Muscoy OUs,
all of the data generated during the Rl and interim remedial action (IRA) efforts for the
Newmark and Muscoy OUs were determined to be directly applicable to the Source OU and
thus, adequate to characterize the nature and extent of contamination throughout the Source
OU. Therefore, additional field investigation efforts were determined to be unnecessary to
complete the Source OU Rl.
Key findings from the 2012 3DVA effort included: the confirmation of a single, large, low-
concentration PCE plume that bifurcated near the northern edge of Shandin Hills and divided
into two lobes; the Newmark plume lobe to the northeast (formed under low groundwater
elevation conditions) and the Muscoy plume lobe to the southwest (formed under high
groundwater elevation conditions). Findings additionally indicated that the large plume was
sourced from the Northwest Source Area (now known as the Northwest Area).
As discussed in Section 2.2.1, the results of a comprehensive online environmental database
search of the Source OU indicated that there were no additional sites within the Source OU
acting as sources to the plume. This was further supported by 3DVA results, wherein PCE
concentrations detected in over 180 monitoring wells throughout the plume, showed no
indications of any additional sources located outside of the Northwest Area contributing PCE to
the plume.
Initial investigations in the Source OU into potential sources of contamination were unable to
definitively identify the original primary source(s) within the former Camp Ono. Site data and
the results of 3DVA-based site evaluation and remedial progress efforts performed from 2012
through Fall 2022, indicate that the current residual source in bedrock may be related to former
releases from the hospital at former Camp Ono located to the north of the Verdemont Hills
and/or from or within the area of, a former steel mill located within the footprint of former
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Camp Ono to the south of the Verdemont Hills (Tetra Tech 2024). Details on the results of the
initial 3DVA effort and the subsequent 3DVA remedial progress monitoring for the Northwest
Area of the Source OU are presented in Section 2.4.4.
Further, the RI/FFS for the Source OU concluded that the PCE plume in the Northwest Area no
longer serves as the source of groundwater contamination by PCE at and above 5 |ag/L (the
federal drinking water standard) and at and above 0.5 |ag/L (the EIS performance standard) for
14 groundwater extraction wells in the Newmark and Muscoy plume lobes (Tetra Tech 2024).
Analysis of potential exposure routes during the RI/FFS concluded that the only measurable
human exposure to the VOCs would be through use of untreated Northwest Area groundwater
as a water supply.
Several historical State and EPA investigations did not identify VOC contamination at the surface
or within 10 feet of the soil surface at the Newmark Site. Consequently, direct contact with
VOCs via surface soil is not a possible exposure route. Further, the depth to contaminated
groundwater is generally 100 feet below ground surface (bgs) throughout the Northwest Area,
indicating that vapor intrusion from the contaminated groundwater does not present a
significant exposure pathway.
2.4.3 Nature and Extent of Contamination
Chemicals in groundwater identified by previous investigations included the chlorinated
ethenes PCE and TCE, their degradation products (including cis-l,2-dichloroethene and trans-
1,2-dichloroethene), and trichlorofluoromethane (Freon 11), and dichlorodifluoromethane
(Freon 12). As stated in the Muscoy OU IROD (EPA 1995), risk assessment efforts concluded that
there was no increased risk to human health and the environment from Freon 11 and Freon 12;
therefore, these chemicals were removed from further consideration. Based on this, the
primary COCs were determined to be PCE and TCE.
2.4.3.1 Groundwater in the Source Operable Unit
Figure 6 shows the results of the 3DVA effort to evaluate the PCE plume throughout the Source
OU (which is equivalent to "site-wide").
The initial 3DVA findings showed that: (1) the size and mass of the overall PCE plume decreased
from 1997 to 2012, resulting in a significant decrease in the potential for the Northwest Area to
deliver dissolved phase mass to the Newmark and Muscoy plume lobes; and (2) there were no
active sources of contaminant release in the Northwest Area that would result in an increase in
the concentration or size of the present Newmark and Muscoy plume lobes (Tetra Tech 2024).
This was evidenced by the decrease in the mass of PCE in groundwater at concentrations at and
above the 5 |ag/L MCL, which decreased from approximately 9,000 pounds (lbs) in 1997 to
approximately 819 lbs in 2012, an approximate mass reduction of 90 percent. In addition,
existing data indicated no active sources that would increase the concentration or size of the
Newmark and Muscoy plume lobes (Tetra Tech 2024).
Subsequent to the initial CSM-focused 3DVA effort for the time period from 1997 to 2012, EPA
continued a 3DVA-based, remedial progress monitoring program at the Newmark Site, updating
the 3DVA for the periods 2012 to 2015; 2015 to 2019; and 2019 to 2022.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Figure 6. Reduction ofPCE Plume Size, Morphology, and Mass: 1997 to 2022 (from Tetra Tech 2024)
NW
SE NW
Sitewide
Mass Reduction
1997-2022
~99.9%
NW
SE
2022: PCE @>5 ng/L
Total Mass =
~6.4 lbs
, I TETRA TECH
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 6
Reduction of PCE Plume Size, Morphology and Mass: 1997-2022
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
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As shown on Figure 6, for the period 2012 to 2015, 3DVA remedial progress monitoring
demonstrated significant remedial progress continuing at the site. The size, morphology, and
mass of the PCE plume had significantly reduced. Plume areas with PCE concentrations at and
above the 5 |ag/L MCL in groundwater were reduced from six to two primary areas (the
Northwest Area and an area southwest of the 19th Street North Treatment System Area within
the Muscoy OU) and two small areas (located north of the 19th Street North Treatment System
Area and near the Waterman Treatment Area). As of 2015, the site wide PCE mass (based on
PCE present in groundwater at concentrations at and above 5 |ag/L reduced from approximately
820 pounds (lbs) in 2012 to approximately 45 lbs in 2015, an approximate 95 percent reduction.
As of 2015, approximately 3.25 lbs of remaining mass was present at concentrations at and
above 10 |ag/L, and mass was no longer present at concentrations at and above 20 |ag/L (Tetra
Tech 2024).
As shown on Figure 6, for the period from 2015 to 2019, the 3DVA remedial progress
monitoring update again showed significant reduction of groundwater contamination at the
site. The size, morphology, and mass of the PCE plume reduced further, so that the plume
portions with PCE at concentrations at and above the 5 |ag/L MCL remained in two primary
areas (Northwest Area and southwest of the 19th Street North Treatment System Area within
the Muscoy OU). As shown on Figure 7, the estimated site-wide mass of PCE remaining (based
on PCE present in groundwater at concentrations at and above 5 |ag/L) reduced from
approximately 45 lbs in 2015 to approximately 23 lbs in 2019, representing an approximate 49
percent reduction. Approximately 0.5 lbs of remaining mass was estimated for groundwater
with PCE concentrations at and above 10 |ag/L, and no mass was identified for groundwater
with PCE concentrations at and above 20 |ag/L (Tetra Tech 2024).
As shown on Figure 8, the 3DVA remedial progress monitoring update for the most recent
period of 2019 to 2022 showed the site-wide size and morphology of the PCE plume had not
reduced significantly since the 2015 to 2019 update. However, as shown on Figure 7, the site-
wide PCE mass (estimated for groundwater with concentrations of PCE at and above the 5 |ag/L
MCL) had reduced further (from approximately 23 lbs in 2019 to approximately 6.4 lbs as of
2022, an approximate 72 percent reduction). As shown on Figure 8, approximately 0.12 lbs of
remaining mass was estimated for groundwater with PCE concentrations at and above 10 |ag/L;
no mass was estimated to remain for groundwater with PCE concentrations at and above 20
l-ig/L. Two portions of the PCE plume remained at concentrations at and above 5 |ag/L; the
Northwest Area and a small area within the Muscoy OU (southwest of the 19th Street North
Treatment System Area which remains divided into two smaller plume portions) (Figure 8). The
sizes and morphologies of these plume portions are slightly reduced compared to the 2015 to
2019 results. In addition, the Northwest Area no longer serves as the source of PCE at
concentrations at and above the 5 |ag/L MCL or the 0.5 |ag/L EIS performance standard to the
downgradient areas of the Source OU (Tetra Tech 2024).
As shown in Figure 6, 3DVA efforts to date show that from 1997 to 2022, the site-wide PCE
mass (based on concentrations in groundwater at and above the 5 |ag/L MCL) reduced from
approximately 9,000 lbs to approximately 6.4 lbs, a reduction of approximately 99.9 percent
(Tetra Tech 2024).
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Figure 7. Reduction of Site-Wide PCE Mass: 2013-2022 (from Tetra Tech 2024)
Estimated Site-Wide PCE Mass 2013 Through 2022 (Pounds)
Monitoring Year
2013
2014
2015
2016
2017
2018
2019
2022
Based on NGFM*
Lithology
Based on Revised Lithology
in Northwest Area
PCE Mass at
Concentration
Equal to and
Greater than
5 ng/L (MCL)
127
83
45
35
29
23
23
7.4
6.4
(Total)
4.7
(Overburden)
1.7
(Bedrock)
% Reduction from
Prior Year
~34.6%
~45.8%
~22%
~17%
~20.7%
0%
~68%
~72%
N/A
Estimated Site-Wide PCE Mass (lbs) 2013 Through 2022
140
— 100
60
40
2016 2017
Year
> Rate of mass reduction
approaching asymptotic state in
2017 to 2019
> Continued mass reduction
between 2019-2022
> Asymptotic state related to mass
in low hydraulic conductivity (K)
zones
¦ Overburden
¦ Weathered and
Unweathered Bedrock
*NGFM = Newmark Groundwater Flow Model
Newmark Groundwater
ContaminationSuperfund Site
San Bernardino, California
Figure 7
Reduction of Site-Wide PCE Mass: 2013-2022
TETRA TECH
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
22
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Figure 8. Reduction ofPCE Plume Size, Morphology, and Mass: 2019 to 2022 (from Tetra Tech 2024)
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 8
Reduction of PCE Plume Size, Morphology and Mass: 2019-2022
TETRA TECH
It
TETRATECH
2022: PCE @>5 ng/L
Total Mass =
~ 6.4 lbs
Total Mass =
~23 lbs
2019: PCE @>5 ng/L
Northwest Area
Newmark Sitewide PCE Mass Calculation
5JOOO
PCE at and above 5 |xg/L
PCE Mass Remaining
> 5 |-ig/L = 6.4 lbs
> 10 H-g/L = 0.12 lbs
> 20^g/L = ~0lbs
19th Street North
Treatment System
Northwest
Area
19th Street North
Treatment System
Area
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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While data indicate that the remaining low concentration PCE mass in the Source OU is
approaching an asymptotic state, the additional order-of-magnitude reduction from 2019
(approximately 23 lbs) to 2022 (approximately 6.4 lbs) shows that mass reduction is still
occurring at the site. Additional evaluation in Figure 7 also shows that the 6.4 lbs of site-wide
residual PCE mass was distributed between overburden (approximately 4.7 lbs) and bedrock
(approximately 1.7 lbs). PCE present in bedrock is a condition unique to the Northwest Area
due to the relatively shallow depth to bedrock compared to the depth to bedrock in
downgradient areas of the plume in the Newmark and Muscoy OUs, where all wells are
screened within alluvium at depths ranging up to several hundreds of feet bgs (Tetra Tech
2024).
2.4.3.2 Groundwater in the Northwest Area
As shown on Figure 9 as of Fall 2022, only two wells in the Northwest Area (G-6 and G-10) had
remaining PCE concentrations exceeding the 5 |ag/L MCL.
The evaluation of PCE contamination in groundwater in the Northwest Area suggests that
residual PCE plumes are localized along two known flow paths: (1) the steel mill flow path from
monitoring well CJ-10 through G-6 ending at G-3 (where it merges with groundwater flow
along the axis of the basin); and (2) the former Camp Ono hospital flow path from well CJ-17 to
CJ-16. Figure 10 shows the monitoring wells and the flow paths. Contaminant concentrations
have been higher along these flow paths than in the other Northwest Area monitoring wells,
including those wells located around the perimeter of the Cajon Landfill. Until recently, PCE
concentrations were above the 5 |ag/L MCL in monitoring wells along both flow paths. Fall 2022
monitoring results indicate that PCE concentrations were above the 5 |ag/L MCL in wells CJ-6
and CJ-10 along the steel mill flow path; however, PCE concentrations were below the 5 |ag/L
MCL in both wells (G-16 and G-17) along the former hospital flow path (Tetra Tech 2024).
Figure 11 provides PCE concentration trends from 1997 to 2022 at three monitoring wells (G-
10, CJ-6 and G-3, from upgradient to downgradient) along the steel mill flow path. The highest
PCE concentrations were detected at the downgradient well (G-3) at the very beginning of the
monitoring period. The interpretation provided in the RI/FFS is that higher PCE concentrations
in the advective groundwater plume had already migrated downgradient from the source area
at the beginning of the monitoring period (Tetra Tech 2024). This was followed by a rebound in
PCE concentrations caused by the back-diffusion of contaminants from low-permeability
geologic materials. PCE concentrations are now greatest in groundwater from bedrock well CJ-
10, close to where PCE is back-diffusing from the secondary, bedrock source.
PCE concentrations at the former hospital flow path appear to be decreasing at a faster rate
than at the former steel mill flow path. Figure 12 shows the PCE concentrations in groundwater
from wells CJ-16 and CJ-17 (along the former hospital flow path). PCE concentrations have
attenuated to levels below the 5 |ag/L MCL in a much shorter time frame than what will likely be
required for wells and CJ-6 and CJ-10 (along the former steel mill flow path) (Tetra Tech 2024).
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
24
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Figure 9. Concentrations of PCE in Groundwater in Northwest Area Monitoring Wells: Fall 2018- Fall 2022 (from Tetra Tech 2024)
PCE Time Series from Late 2018-2022
Well screened in
weathered bedrock
Well screened
in alluvium
, ~
4
:
MCI.« S ugrt.
«•
Well
CJ-10
CJ-17
CJ—6
MW-142
MWCOE004
MA = Method MA 3149.0
for Trace Volatiles
Srin'Oiinti i-.i I (:
Well
CJh
CJ-1C
U- 17
MW-142
MWCOEOG4
Tall 2018
12
32
10
Spring 2019
10
25
1!
Fall 2019
10
22
4.7
4.8
Spring 2022
12
20
6.4
5
Spring 2022 MA
n
21
5.4
li.7
Fall 2022
8.1
15
Fall 2022 MA
9.5
18
3.4
4.1
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 9
Concentrations of PCE in Groundwater in Northwest Area Monitoring Wells: Fall 2018-Fal! 2022
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
25
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Figure 10. Groundwater Flowpath Analysis Showing Radial Flow Pattern: 2012 (from Tetra Tech 2024)
ImwcoeoosI
IMWCQE0Q61
-*-*1mWCOEQQ7
JJJ Former
fJJ Hospital Fl OW
U^Path Former Steel
[ M WCQE009 lIVTi 11 FlOW
h yvath j&bu
[CJ-17
I/WCOE004
MWCQE008
MWCQE002I
CJ-15
MVVCO£gg3
Groundwater Potentiometric Surface - 2012
Groundwater Flow paths - 2012
Newmark Groundwater
Contamination Superfund Site
San Bernadino, California
Figure 10
Groundwater Flowpath Analysis Showing Radial Flow Pattern
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
26
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Figure 11. PCE Concentration vs. Time Trends along the Former Steel Mill Flow Path; Northwest Area (from Tetra Tech 2024)
Advection-driven plume
Diffusion-driven plume
Notes:
ESA 1 estimated source area
Open symbols indicate PCe was not detected (plotted at the
Method Detection Limit
Well CI-10 is 200 feet downgradient of ESA, screened in bedrock
Well CJ-3 is 1,330 feet downgradient of ESA, screened in alluvium
m i
I/I4/
-------
Figure 12. Hydraulic Head and PCE Concentration at Former Hospital Flow Path
(from Tetra Tech 2024)
31.75 Inches of Rain in 5 Days
January 7 to 11, 2005
Figure 12
Hydraulic Head and PCE
Concentration at Former Hospital
Flow Path
It
TETRA TECH
i '
%
Date
pet *«-a-i7K(
PCJe Concentrations
hydraulic Head
Date
Newmork Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
28
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A suite of three analytical models was used to estimate the combined effects of advection,
dispersion, sorption and matrix back-diffusion on contaminant concentrations along the former
steel mill flow path from well G-10 to CJ-6, ending at well CJ-3. The models estimated the PCE
concentration at G-10 would decrease below the 5 |ag/L MCL by the year 2070. This estimate is
substantially longer than the estimates which were obtained through trend projections. The
modeling results provided an alternate assessment that incorporated the fate-and-transport
processes believed to be significant in the Northwest Area. The sensitivity analysis of eleven key
input parameter changes in the analytical models did not identify any issues with the input
parameters that would require additional data collection (Tetra Tech 2024).
2.4.3.3 Soil Gas in the Northwest Area
In addition to investigations into the contamination of groundwater, EPA and the U.S. Army
completed soil gas investigations to evaluate potential source areas for chemicals detected in
monitoring wells in the Northwest Area from 1999-2005. In 2014, four soil gas samples were
collected from the vadose zone adjacent to the upper screened interval of monitoring well CJ-
10 to evaluate potential sourcing in the area of the well. These investigations and results are
described in detail in EPA's Vapor Intrusion Technical Memorandum (EPA 2018). Figure 13
shows the locations of the soil gas investigations. One of the soil gas investigations was a survey
of nine sites throughout the former Camp Ono conducted in April and May 2000 (Montgomery
Watson Harza [MWH] 2002). The investigation included the drilling of 96 shallow borings and
10 deep borings from which soil gas samples were collected. Samples were collected from the
shallow borings at depths of 10 and 30 feet bgs. Samples were collected from the deep borings
at 10 and 30 feet bgs and every 30 feet thereafter, to a total depth which ranged from 90 to
210 feet bgs (Tetra Tech 2024).
For seven of the sites, which are associated with activities at the former Camp Ono, PCE and
TCE were generally present in soil gas at low concentrations in the shallow borings and
increased gradually with the depth in the deep borings. However, the deep samples at all seven
sites were below site-specific soil gas screening levels developed in the study (MWH 2002), and
it was concluded that none of the seven sites likely represented sources to the groundwater
plume. The eighth site was located upgradient of the plume and concentrations were also
below soil gas screening levels.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
29
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Figure 13. Locations of Soil Gas and Other Investigations of the Northwest Area of the Source OU (from Tetra Tech 2024)
iCajon County
I Landfill Area (Si
'otential Grease Pit (Site 3]
'otential Trenches and Pit (Site 2)|
[Potential Grease/Wash Rack (Site 6)|
|VeNde Driver Taming Center (Site 5)|
(Cat Pit Are.
|Lower Motor Pool (Site 4)1
[Potential Oil Change
Newmark Groundwater
Contamination Superfund Site
San Bernadino, California
Figure 13
Locations of Soil Gas and Other Investigations of Northwest Area of Source OU
(Source: EPA 2018)
TETRA TECH
|Legend
Sod Gas Bomg (2005) I
So*I Gas Bomg (2002) I
Sol Gas Bor^g (2001) |
| Previous investa3t
-------
The Cajon Landfill was the ninth site investigated, with 24 shallow and 2 deep soil borings
drilled around its perimeter (MWH 2002) (see Figure 13). Three of the shallow borings were
conducted at locations along the steel mill flow path in close proximity to monitoring wells CJ-
10, CJ-6 and G-3, respectively. All of the PCE concentrations in soil vapor sampled from the
three shallow borings were below 10 parts per billion by volume (ppbv). In addition, four
borings were sampled on the access road between the Southwest Waste Module of the Cajon
Landfill and Institution Road (approximately 1,400 to 1,600 feet southwest of monitoring well
CJ-3 and immediately west of the former seepage ponds) in the west-central portion of the
Northwest Area. In contrast to the PCE concentrations near the steel mill flow path, PCE
concentrations in soil gas from these borings ranged from 38 to 130 ppbv in the 10-foot bgs
samples and from 130 to 340 ppbv in the 30-foot bgs samples. PCE concentrations in the
deepest boring sample increased with depth to a maximum of 980 ppbv at 150 feet bgs, before
decreasing to 470 ppbv at the bottom of the boring at 210 feet bgs (MWH 2002). The
investigation report indicated there were former seepage ponds located to the east of these
borings (MWH 2002).
PCE has never been detected in groundwater at a concentration greater than 2.7 |ag/L at any of
the monitoring wells that bound the former seepage pond area (CJ-2, G-13, and CJ-14), which
is evidence that the high concentrations of soil gas do not represent off-gassing of PCE from
groundwater. Conversely, although the former seepage ponds may be the source of elevated
soil gas in this area, they do not appear to have had a significant impact on groundwater.
The relationship between PCE in vadose zone soil gas and in saturated zone groundwater was
also investigated at monitoring well CJ-10, immediately downgradient of the former steel mill
(Gilbane in EPA 2018). Well G-10 is screened over two depth intervals: from 79 to 89 feet bgs
(in vadose zone colluvium) and from 135 to 145 feet bgs (in saturated zone bedrock). Soil gas
samples were collected from the vadose zone adjacent to the upper screened interval in May
2014 (Gilbane in EPA 2018). The upper screened interval was isolated with straddle packers and
soil gas samples were collected after various volumes were purged from the well screen.
Samples were collected following a purge of 31 liters, which was approximately one volume
from the isolated interval, with additional samples collected at cumulative purge volumes of 65,
102 and 303 liters. PCE concentrations steadily rose from 2,100 micrograms (per cubic meter
(|ag/m3) in the first sample to 3,400 |-ig/m3 in the final sample (or from 310 ppbv to 500 ppbv,
respectively). The increasing concentrations indicated that elevated concentrations of PCE were
present at that depth of the vadose zone adjacent to the well screen. The evaluation
concluded: "soil gas results suggest the potential presence of a contaminant source in the
vadose zone in the vicinity of the CJ-10 upper well screen, with concentrations moderately
greater than those in groundwater from the lower screen." (Gilbane in EPA 2018). These results
support the interpretation that the elevated and sustained concentrations in groundwater from
CJ-10 are potentially related to the former steel mill building, which was located approximately
500 feet upgradient of the well. Figure 14 shows the results of the soil gas and other
investigations and indicates that near-surface (less than 13 feet bgs) detections of PCE in soil
gas are limited to a few areas (Tetra Tech 2024).
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
31
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Figure 14. Results of Soil Gas and Other Investigations in the Northwest Area of the Source OU (from Tetra Tech 2024)
Legend
Monitoring Well
Soil Gas Bonng (2005)
Soil Gas Boring (2002)
Soil Gas Boring (2001)
Source OU Boundary
"NW Source Area"
INSET #7
Sod gas samples above
O 13-ft bgs with Elected PCE
>67 ug/m3
(DTSC-modified
Commeraal/Inclustnai VISL)'
INSET #10
INSET #6
INSET #5
INSET #9
INSET #8
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 14
Results of Soil Gas and Other Investigations in Northwest Area of Source OU
(Source: EPA 2018)
ft
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
32
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2.4.4 Fate and Transport of Contamination
Groundwater fate and transport modeling was performed as part of the RI/FFS effort to
estimate the timeframe of remediation (Tetra Tech 2024). The contaminant transport modeling
is discussed in Section 2.8 (Description of Remedial Alternatives).
The mass sustaining the PCE concentrations in various Northwest Area monitoring wells is
located in colluvium, weathered bedrock, and/or unweathered bedrock. The relatively low, yet
persistent, concentrations indicate that PCE is present in the dissolved phase and is immobile
with respect to advective groundwater flow. PCE is released to mobile groundwater at rates
that overall site data and leading hydrogeologic studies would indicate are controlled by matrix
back-diffusion from the fine-grained materials in which it is present. While considered highly
unlikely today based on the relatively low concentrations in the wells, it was considered
possible that residual dense non-aqueous phase liquid (DNAPL) may have been present in
fractured bedrock in the past.
The most likely locations for the original releases and the remaining mass of PCE in the
Northwest Area are at the former steel mill at the southern slope of the Verdemont Hills and
the former Camp Ono hospital near the northwest end of the Verdemont Hills.
2.5 Current and Potential Future Land and Water Uses
This section discusses the current and reasonably anticipated future land and groundwater uses
at the Source OU. This information forms the basis for reasonable exposure assessment
assumptions and risk characterization conclusions.
2.5.1 Land Uses
The Source OU lies primarily within the limits of the City of San Bernardino. Land use in the City
includes California State University in the northern portion of the City, residential properties
including single and multi-family dwellings, commercial and retail establishments, light
industrial facilities, heavy industrial facilities, public facilities, open space, and golf courses.
While the majority of residences are located in the downtown area, population increases over
time have expanded development across a larger area.
Light industrial and commercial properties and the majority of residential properties are largely
located within the Newmark and Muscoy OUs (EPA 2008). Land uses within the Source OU are
primarily industrial and commercial with some residential communities. Commercial and
industrial land use predominantly occurs south of the downtown area; however, in recent years
it has expanded to include portions of the Northwest Area.
The Northwest Area, the focus of previous source location investigations, includes former and
current uses such as former Camp Ono, Cajon Landfill, the former steel mill, a railroad, and
newly constructed commercial structures, and light and heavy industry.
2.5.2 Groundwater
Groundwater at the Newmark Site is within the Bunker Hill-A groundwater management zone
pursuant to the Water Quality Control Plan for the Santa Ana River Basin (Basin Plan). Table 3-1
of the Basin Plan designates the following existing or potential beneficial uses of the
groundwater in the Bunker Hill-A groundwater management zone: municipal and domestic
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
33
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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supply, agricultural supply, industrial service supply, and industrial process supply.
Groundwater in the Newmark and Muscoy OUs is currently being used as a source of drinking
water. Groundwater in the Northwest Area of the Source OU is not currently being used as a
source of drinking water; however, groundwater was evaluated in the human health risk
assessment as a potential source of drinking water. Further, the remedy selected for the
Northwest Area of the Source OU is intended to restore groundwater to its beneficial use as a
source of drinking water.
2.6 Summary of Site Risks
Existing groundwater and soil gas data were evaluated to estimate potential risks to human
health and the environment associated with residual PCE groundwater contamination within
the Northwest Area of the Source OU. Although the footprint of the Source OU encompasses
the Newmark and Muscoy OUs, the Newmark and Muscoy OUs have a final remedy in place.
Further, the residual PCE mass in the Northwest Area no longer serves as the source of the
Newmark or Muscoy plume lobes at concentrations at and above the 5 |ag/L MCL or at and
above the 0.5 |ag/L EIS extraction well performance standard (Tetra Tech 2024). Accordingly, to
address the remaining site-related contamination outside of the Newmark and Muscoy OUs,
the human health and ecological risk assessment focused only on the Northwest Area of the
Source OU.
2.6.1 Summary of Human Health Risk Assessment
The human health risk assessment (HHRA) performed for the Northwest Area of the Source OU
evaluated risks for groundwater and soil gas pathways. Soil was not evaluated in the HHRA
because there is no evidence of surface or near surface soil contamination. Detailed discussion
of the HHRA is contained in the RI/FFS (Tetra Tech 2024).
2.6.1.1 Identification of Chemicals of Potential Concern
The HHRA provided a full assessment of all chemicals recently detected in the Northwest Area.
These four groundwater monitoring events were conducted in 2019 through Fall 2022, with
two events conducted in each of those years. All chemicals detected in the last four
groundwater monitoring events were included as chemicals of potential concern (COPC) as
identified in Table 1 and Table 2; the COPCs identified were PCE and TCE. Table D.l in Appendix
D of the RI/FFS summarizes the detection frequency, minimum and maximum detected
concentrations, locations, and dates of the maximum detected concentrations for each COPC
(Tetra Tech 2024). The maximum detected concentration for each COPC was used as the
exposure point concentration (EPC) in the HHRA.
2.6.1.2 Exposure Assessment
Land use within the Source OU, including the Northwest Area, is residential, commercial, and
industrial. As such, potentially exposed populations include residents and workers. The HHRA
assessed future use of untreated groundwater for the Northwest Area. Additional potential
receptors evaluated for potential risk included construction workers and trench workers. Other
potential human receptor exposures included vapor intrusion through soil gas migration into
occupied structures located over, or near, the area of known groundwater contamination in the
Northwest Area. Figure 15 presents the CSM for human health risk receptors.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
34
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Figure 15. Conceptual Site Model Human Receptors (from Tetra Tech 2024)
Potential
Primary
Source(s)
Primary
Release
Mechanism(s)
Secondary
Source(s)
Secondary
Release
Mechanism(s)
Exposure
Medium
Exposure
Route
Potential Human Receptor(s)
Commercial /
Industrial
Worker
Construction
Worker
Trench
Worker
Future
Resident
Former
Chlorinated
Solvent
Sources
Volatilization
Indoor Air
A
~ CXjtdoorAir
Inhalation
Inhalation
•(1)
o(1,2)
o(l,2)
•(1)
Ingestion
Dermal Contact
o (1,3)
o(1,3)
o(1,3)
o(1,3)
Leaching /
Groundwater
Ingestion
o (4)
o(1,5)
o(1,5)
o (4)
Percolation
Dermal Contact
O (4)
o(l,5)
o(1,5)
o (4)
Inhalation
0(4)
o(1,5)
o(1,5)
o (4)
o (6)
o (6)
o (6)
o(6)
o(6)
o(6)
o (6)
o(6)
Notes:
1 - Depth to groundwater is greater than 100 feet in most areas of the site.
2 - Outdoor construction and trench workers are not exposed to indoor air.
3 - Exposure to outdoor air anticipated to be much lower than to indoor air.
4 - Groundwater from the OU is treated prior to distribution to consumers.
5 - Outdoor construction and trench workers are not expected to be exposed to
groundwater.
6 - Commercial/industrial workers are not expected to be exposed through
showering and bathing.
7 - There are no known sources of soil contamination within the OU.
Legend:
o(X)
Potentially Complete Exposure Route
Incomplete Exposure Route
Potentially Complete Exposure Pathway
Potentially Complete Exosure Pathway Between Media
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 15
Conceptual Site Model Human Receptors
It
TETRA TECH
Newmark Groundwater Contamination Superfund Site Final Record of Decision
San Bernardino, California EPA Region 9 Region 5 START V Contract: Document Tracking Number 2216a
35
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Vapor intrusion does not present an unacceptable risk under current conditions in the
Northwest Area based on the depth to groundwater, soil gas concentrations in historical
samples (that decrease from deep to shallow depths), the significant reduction of the
groundwater plume size, concentration and mass over time and the present, current
groundwater contaminant concentrations, and no receptors being present in the areas with
concentrations exceeding EPA residential and commercial vapor intrusion screening levels
(VISL) (EPA 2022b). As a result, risk from the vapor intrusion pathway was not evaluated
quantitatively in the risk assessment.
Depths to groundwater in two wells within the Northwest Area in April 2022 were less than 100
feet bgs, including a depth of 87.93 feet bgs for monitoring well MW-142 and a depth of 90.36
feet bgs for monitoring well MWCOE009. Based on this, depths to groundwater in both wells
are within 10 to 13 feet of 100 feet bgs. For the purposes of the HHRA, this differential was
considered insignificant, especially when normal groundwater elevation fluctuations were
considered.
The only potentially complete exposure pathways considered quantitatively in the HHRA were
ingestion and dermal/inhalation exposure through showering and bathing for the residential
receptor based on groundwater being used as a source of municipal and domestic supply.
Because all potable groundwater in the Source OU is treated water supplied by the City,
commercial and industrial exposure to untreated groundwater was not evaluated quantitatively
in the HHRA. Further, hypothetical exposure of residents to untreated groundwater is expected
to be protective for commercial and industrial exposures because of lower ingestion rates,
exposure durations, and exposure frequencies.
2.6.1.3 Toxicity Assessment
The HHRA evaluated both carcinogenic risk and noncarcinogenic hazards for future residential
receptors in the Northwest Area. Oral and dermal exposure were assessed using oral slope
factors for carcinogenic risk, and oral reference doses for noncarcinogenic hazard. Inhalation
risks were assessed using inhalation unit risks for carcinogenic risk, and reference
concentrations for noncarcinogenic hazards.
Two approaches were used to estimate the risk in the Northwest Area. One approach used EPA
toxicity values, while the other used toxicity values specified by DTSC. The two approaches are
described briefly below.
EPA toxicity values were not directly used to calculate risk-based screening levels (RBSL).
Instead, default EPA Regional Screening Levels (RSL) were used as RBSLs. However, the RSLs
were based on toxicity values included in the EPA Regional Screening Levels website (EPA
2022a). In addition to an assessment of risk using the EPA toxicity value hierarchy, risk was
estimated using toxicity values provided in DTSC's Health and Ecological Risk Office (HERO)
Human Health Risk Assessment Note 10, Toxicity Criteria (DTSC 2019). For all COPCs, where a
Note 10 value was available, that toxicity value was used. For COPCs where no Note 10 toxicity
value was available, the EPA toxicity values were used.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
36
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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2.6.1.4 Risk Characterization
Carcinogenic risk and noncancer hazard within the Northwest Area were estimated using a risk
ratio calculation approach. EPA RSLs for the EPA default residential receptor (EPA 2022a) were
used to assess risk using EPA toxicity values. The online EPA RSL calculator2 was also used to
develop residential RBSLs for the DTSC scenario using toxicity values from DTSC HERO Note 10
(DTSC 2019).
Table 1 (Table D.3 from Appendix D of the RI/FFS; Tetra Tech 2024) presents the total
estimated risks and hazards using the EPA approach. Table 2 (Table D.4 from Appendix D of the
RI/FFS; Tetra Tech 2024) presents the total estimated risks and hazards using the DTSC
approach. A summary of the results is presented below:
• Using EPA toxicity values:
o The total carcinogenic risk is 1E-05, which is within the EPA risk management range
of 1E-06 to 1E-04. Both PCE and TCE have total carcinogenic risks exceeding 1E-06;
¦ Carcinogenic risk exceeds 1E-06 for PCE only in the inhalation pathway; and
¦ Carcinogenic risk exceeds 1E-06 for TCE in both the ingestion and inhalation
pathways.
o The total noncarcinogenic hazard index is 2, which is above the point of departure of
1. No individual COPC or target organ exceeds a noncarcinogenic hazard of 1.
• Using California DTSC toxicity values (DTSC 2019):
o The total carcinogenic risk is 3E-04, which is above the EPA risk management range
of 1E-06 to 1E-04. The carcinogenic risk is primarily associated with PCE, which has a
risk of 3E-04. Both PCE and TCE have total carcinogenic risks exceeding 1E-06 for
both the ingestion and inhalation pathways; and
o The total noncancer hazard index is 2, which is above the point of departure of 1. No
individual COPC or target organ exceeds a noncarcinogenic hazard of 1. There are no
significant differences between the EPA and California DTSC results for noncancer
hazards.
PCE and TCE are the only risk drivers for groundwater in the Northwest Area of the Source OU.
In addition, current concentrations of PCE exceeded the federal MCL of 5 |ag/L in only two
groundwater monitoring wells (CJ-6 and CJ-10) as of Fall 2022. Concentrations of TCE do not
exceed the federal MCL of 5 |-ig/L. As a result, TCE was not identified as a COC for groundwater
the Northwest Area of the Source OU.
2 EPA On-Line RSL Calculator: httDs://eDa-Dras.ornl.aov/cai-bin/chemicals/csl search
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
37
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Table 1. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable Maximum Exposure (RME) Conditions,
Residential Receptor EPA Toxicological Values (from Tetra Tech 2024)
EPC
Carcinogenic RBSL (ng/L) b
Carcinogenic Risk d
Medium
Pathway
Chemical
(Hg/L)a
Ingestion
Dermal
Inhalation
Overall
Ingestion
Dermal
Inhalation
Total
1,1-Dichloroethane
0.41
14
180
3.5
2.8
2.9E-08
2.3E-09
1.2E-07
1.5E-07
1,1-Dichloroethene
0.31
-
-
-
-
-
-
-
-
1,4-Dichlorobenzene
0.13
14
21
0.51
0.48
9.3E-09
6.2E-09
2.5E-07
2.7E-07
2-Butanone
6.8
-
-
-
-
-
-
-
-
Acetone
97
-
-
-
-
-
-
-
-
Carbon disulfide
0.65
-
-
-
-
-
-
-
-
Carbon tetrachloride
0.27
1.1
4.3
0.94
0.46
2.5E-07
6.3E-08
2.9E-07
6.0E-07
Chlorobenzene
0.13
-
-
-
-
-
-
-
-
Tapwater
Ingestion
Chloroform
Chloromethane
cis-l,2-Dichloroethene
Cyclohexane
Dichlorodifluoromethane
0.22
0.64
0.63
0.97
17
2.5
29
0.24
0.22
8.8E-08
7.6E-09
9.2E-07
1.0E-06
Methyl tert-butyl Ether
0.19
43
2,000
22
14
4.4E-09
9.5E-11
8.6E-09
1.3E-08
Tetrachloroethene
26
37
65
22
11
7.0E-07
4.0E-07
1.2E-06
2.3E-06
Trichloroethene
2.8
1.2
7.4
0.96
0.49
2.3E-06
3.8E-07
2.9E-06
5.6E-06
Trichlorofluoromethane
1.6
-
-
-
-
-
-
-
-
Total
-
-
-
-
3.4E-06
8.6E-07
5.7E-06
1E-05
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Table 1. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable Maximum Exposure (RME) Conditions,
Residential Receptor EPA Toxicological Values, continued (from Tetra Tech 2024)
EPC
Noncancer RBSL (|Jg/L) b
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Table 2. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable Maximum Exposure (RME) Conditions,
Residential Receptor, DTSC Toxicological Values (from Tetra Tech 2024)
Medium
Pathway
Chemical
EPC
(Hg/L)a
Carcinogenic RBSL (ng/L) b
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Table 2. Risk Calculations for Newmark Site, Northwest Area of the Source OU. Reasonable Maximum Exposure (RME) Conditions,
Residential Receptor, DTSC Toxicological Values, continued (from Tetra Tech 2024)
EPC
Noncancer RBSL (|Jg/L) b'c'd
Noncancer Hazard 8
Medium
Pathway
Chemical
(Hg/L)a
Ingestion
Dermal
Inhalation
Overall
Ingestion
Dermal
Inhalation
Total
1,1-Dichloroethane
0.41
4,000
58,000
1.700
1.200
0.00010
0.0000071
0.00024
0.00035
1,1-Dichloroethene
0.31
1,000
8,500
150
130
0.00031
0.000036
0.0021
0.0024
1,4-Dichlorobenzene
0.13
1,400
2,200
1,700
570
0.000093
0.000059
0.000076
0.00023
2-Butanone
6.8
12,000
1,500,000
10,000
5,600
0.00057
0.0000045
0.00068
0.0013
Acetone
97
18,000
4,400,000
65.000
14.000
0.0054
0.000022
0.0015
0.0069
Carbon disulfide
0.65
2,000
20,000
1,500
810
0.00033
0.000033
0.00043
0.00079
Carbon tetrachloride
0.27
80
340
83
36
0.0034
0.00079
0.0033
0.0074
Chlorobenzene
0.13
400
1,300
100
78
0.00033
0.00010
0.0013
0.0017
Tapwater
Ingestion
Chloroform
0.22
200
2,500
200
97
0.0011
0.000088
0.0011
0.0023
Chloromethane
0.64
-
-
190
190
-
-
0.0034
0.0034
cis-l,2-Dichloroethene
0.63
40
360
17
12
0.016
0.0018
0.037
0.055
Cyclohexane
0.97
-
-
13,000
13,000
-
-
0.000075
0.000075
Dichlorodifluoromethane
17
4,000
38,000
210
200
0.0043
0.00045
0.081
0.086
Methyl tert-butyl Ether
0.19
-
-
6,300
6,300
-
-
0.000030
0.000030
Tetrachloroethene
26
120
230
83
41
0.22
0.11
0.31
0.64
Trichloroethene
2.8
10
69
4.2
2.8
0.28
0.041
0.67
0.99
Trichlorofluoromethane
1.6
6,000
36,000
2.500
1.700
0.00027
0.000044
0.00064
0.00095
Total
-
-
--
-
0.53
0.16
1.1
2
Notes
a EPCs are the maximum concentrations measured in all Northwest Area wells from 2019 to 2022.
b All RBSLs were calculated using the EPA online RSL calculator (EPA 2022a) with DTSC Note 10 toxicity values, a target carcinogenic risk of 1E-06, and a target noncancer
hazard of 1 (DTSC 2019).
c Underlined RBSL values, risks, and hazards are different from the EPA RSLsforthe chemical and pathway,
d Noncancer RSLs are forthe child receptor.
e Shaded results are carcinogenic risks exceeding 1E-06 or noncancer hazards exceeding 1.
There is no RBSL for the chemical, therefore no carcinogenic risk (for carcinogenic RBSLs) or no noncancer hazard (for noncancer RBSLs).
IJg/L Micrograms per liter
DTSC California Department of Toxic Substances Control
EPA U.S. Environmental Protection Agency
EPC Exposure point concentration
OU Operable Unit
RBSL Risk-based screening level
RSL Regional Screening Level
References
California Department of Toxic Substances Control (DTSC). 2019. Human and Ecological Risk Office (HERO), Note Number 10, Toxicity Criteria. February 25.
https://dtsc.ca.gov/wp- content/uploads/sit es/31/2019/02/HHRA-Note-10-2019-02-25.pdf?emrc=76f9f9
U.S. Environmental Protection Agency (EPA). 2022. Regional Screening Levels. November. On-Line Address: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
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2.6.1.5 Uncertainty Evaluation
Uncertainties associated with the HHRA include those associated with the selection of
chemicals to be evaluated and the EPCs, the exposure assessment, the toxicity assessment, and
the risk estimates. These uncertainties are summarized below.
There are two primary uncertainties associated with the selection of chemicals to be evaluated
and the EPCs. First, all chemicals detected in any groundwater sample collected from 2019 to
2022 were included. Several chemicals had extremely low detection frequencies, and their
inclusion may have overestimated risk based on the use of maximum concentrations as the
EPC. Second and conversely, exclusion of VOCs that were only detected before 2019 may have
underestimated risk if those VOCs are currently present in areas between wells sampled
between 2019 to 2022. These uncertainties are probably relatively small because risks from
other chemicals are likely much lower than those for PCE and TCE because years of
investigation have not identified any other COCs at the Newmark Site.
The exposure assessment includes uncertainties based on the receptors identified and the
assumed exposure parameters used for those receptors. The residential receptor was assumed
for the HHRA, which likely overestimated risk since the maximum concentrations used for EPCs
are not observed in groundwater in residential areas. In addition, all groundwater is treated
before distribution for use; therefore, residential risk is also overestimated. Exposure
parameters used to develop EPA RSLs are generally conservative and based on upper 90th or
95th percentile values to estimate reasonable maximum exposure, and therefore also likely
overestimate risk. Overall, the combined uncertainties associated with the exposure
assessment are likely to have overestimated risk considerably.
Toxicity assessment uncertainties included extrapolations from animal experiments and route-
to-route extrapolations. These uncertainties may have resulted in overestimated or
underestimated risk.
Uncertainties associated with risk characterization include the assumption that risks are
additive, and that exposure occurs as described in the risk assessment (residential exposure to
groundwater including ingestion, and dermal contact and inhalation associated with showering
and bathing). Potential synergistic or antagonistic effects of chemicals are not evaluated under
current EPA risk assessment guidance. This uncertainty may have resulted in overestimated or
underestimated risks. Since exposure to untreated water is not anticipated, the assumption
that exposure occurs as described likely significantly overestimated risk. Vapor intrusion from
groundwater at depths greater than approximately 100 feet bgs and exposure to potentially
contaminated soil in one possible location of the original release (former steel mill) were both
assumed to be negligible. If this assumption is incorrect, their exclusion may have
underestimated risk. However, based on depth to groundwater, soil gas concentrations in
historical samples that decrease from deep to shallow depths, the significant reduction of the
groundwater plume over time, current groundwater contaminant concentrations, and that
there are no receptors in the areas with concentrations exceeding EPA residential and
commercial VISLs, the risk of vapor intrusion concerns associated with each media is likely
negligible to non-existent.
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2.6.2 Summary of Ecological Risk Assessment
Qualitative evaluations of potential environmental risks were conducted during the preliminary
baseline risk assessments completed for the Newmark and Muscoy OUs (EPA 1993b; EPA 1994).
EPA concluded that urbanization has replaced habitat potential; therefore, no significant
number of ecological receptors are present and there was no indication that future site plans
would reinstate habitat and recreate a potential for environmental receptors in the future (EPA
1993a). Based on this information and general knowledge of increased development in the area
since 1993, it would appear that current environmental conditions in the Northwest Area still
do not support suitable habitat for ecological receptors. Further, data available for the site do
not indicate that there is a hydrogeologic connection of groundwater to surface water, so a
complete exposure pathway to potential ecological receptors does not exist (EPA 2013).
Therefore, a further evaluation of ecological risk was not completed for the Source OU RI/FFS.
2.6.3 Basis for the Remedial Action
The remedial action selected in this ROD is necessary to protect public health and the
environment from actual or threatened releases of hazardous substances. PCE and TCE have
been detected in groundwater at the Northwest Area of the Source OU. PCE and TCE were
found to pose risk to future residential receptors who may use the groundwater as a source of
municipal and domestic supply (including ingestion by drinking or cooking, dermal contact or
inhalation through bathing and showering, or the use of household appliances such as washing
machines). Although TCE was identified in the HHRA, concentrations of TCE do not exceed the
federal MCL of 5 |ag/L promulgated under the SDWA. As a result, TCE was not carried forward
into the remedial action objectives (RAO).
2.7 Remedial Action Objectives
RAOs are environmental medium-specific objectives that identify what is necessary to protect
human health and the environment. The RAOs for groundwater in the Northwest Area include:
• Restore PCE-contaminated groundwater to its remediation goal, which EPA has
identified as the SDWA MCL of 5 |ag/L, to achieve beneficial use as a source of municipal
and domestic supply within a reasonable timeframe (aquifer restoration); and
• Prevent human exposure to PCE in groundwater above the remediation goal.
The remediation goal for PCE is 5 |ag/L, which is the federal MCL promulgated under the SDWA.
The 5 |ag/L concentration is the same concentration promulgated by the State of California in
the Water Quality Control Plan for the Santa Ana River Basin as the numerical water quality
objective for groundwater that is designated with a municipal and domestic supply beneficial
use designation. Groundwater in the Northwest Area of the Source OU meeting the federal
MCL will result in achieving the State of California water quality objective. Restoring
groundwater as a source of municipal and domestic supply means PCE shall not exceed 5 |-ig/L.
As indicated in Section 2.6.1, the COCs for the Northwest Area of the Source OU are PCE and
TCE. However, TCE does not currently exceed its SDWA MCL of 5 |ag/L; therefore, the RAOs and
remedial alternative development are based on PCE and no remediation goal for TCE is being
established. Further, if degradation products of PCE are found in the Northwest Area of the
Source OU through groundwater monitoring, concentrations of the degradation products also
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shall not exceed their drinking water standards when remediation is complete.
2.8 Description of Remedial Alternatives
EPA evaluated three cleanup alternatives for the Newmark Site: (1) No Action; (2) Monitored
Natural Attenuation (MNA), Institutional Controls (IC), and a Vapor Intrusion Assessment; and
(3) In-Situ Treatment with MNA, ICs, and a Vapor Intrusion Assessment. For each alternative,
the key components, length of time to achieve the RAOs, and present value costs are included.
Alternative 1: No Action. No remedial action would be taken in the Northwest Area. PCE
concentrations would remain in the groundwater and no actions would be taken to collect
information on the plume or prevent exposure of the public to the contaminated groundwater.
This alternative served as a baseline to compare other alternatives and was used to determine
the risks that would be posed to public health and the environment if no action were taken to
prevent exposure to, remove, treat, or contain the contamination. No costs are associated with
Alternative 1.
Alternative 2: MNA, ICs, and a Vapor Intrusion Assessment. Alternative 2 includes MNA of PCE
concentrations in the groundwater, ICs, and a vapor intrusion assessment. This alternative
would rely on existing abiotic natural attenuation for groundwater restoration as a future
source of drinking water, groundwater monitoring to provide information on the status of the
plume, ICs to maintain protectiveness until the remediation goal is met, and a vapor intrusion
assessment to evaluate the potential for vapor intrusion based on historical soil gas data.
A modified version of the existing Northwest Area groundwater monitoring program would be
used to monitor the state of the plume. Modifications would include expanding the monitoring
network to include existing monitoring wells CJ-1A, G-2, G-3, and CJ-11, which are not
currently monitored. Adding these wells would improve plume delineation by increasing data
density for future 3DVA-based remedy progress monitoring updates.
Groundwater monitoring would involve periodic groundwater sampling and analysis at a
frequency that is anticipated to decrease overtime. The monitoring parameters would include
field water quality parameters (such as, pH, oxidation-reduction potential [ORP], and dissolved
oxygen [DO]), groundwater elevations, and VOCs [through laboratory analysis]). Data analyses
would include periodic 3DVA-based remedial progress monitoring updates, COC concentration
trend analyses, and projections of the time required for PCE in groundwater to reach the
remediation goal.
ICs would include placement of governmental controls by San Bernardino County for affected
areas in the Northwest Area that overlie the PCE plume and are outside San Bernardino city
limits. Areas that overlie the PCE plume that are inside the San Bernardino city limits are
already controlled by ICs placed through City of San Bernardino Municipal Code Ordinance Title
13, Chapter 13.25 and the 2015 ROD for the Newmark and Muscoy OUs. The affected areas
that are outside the San Bernardino city limits are under the sole jurisdiction of San Bernardino
County. The San Bernardino County ICs would prohibit the installation of all wells other than
wells related to the remediation of the plume until the remediation goal is met.
Vapor intrusion from contaminated groundwater is unlikely to be a concern in the Northwest
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Area based on the depth to groundwater, soil gas concentrations in historical samples that
decrease from deep to shallow depths, the significant reduction of the groundwater plume over
time, current groundwater contaminant concentrations, and that there are no receptors in the
areas where concentrations exceed EPA criteria. However, a vapor intrusion assessment would
be performed in the Northwest Area as part of the remedy to evaluate the potential for vapor
intrusion based on historical soil gas data.
The estimated present value cost of Alternative 2 is $1.24 million. This includes $0.14 million in
capital expenses, $0.81 million in O&M expenses, and $0.29 million in contingency expenses
(30 percent of capital and O&M costs).
Non-linear regression analyses and analytical modeling were both used to estimate the time
needed to reach the remediation goal via natural attenuation. Non-linear regression trend
estimates were constructed for groundwater wells with sufficient historical PCE or TCE data (n >
10). Trends for PCE were estimated using data through 2022, with the additional stipulation
that at least one measurement had to have been collected since 2018. The trend analyses were
conservatively limited through the year 2027. Northwest Area groundwater monitoring wells
CJ-6 and CJ-10 are the only two wells that exceeded the remediation goal as of Fall 2022.
For monitoring well G-6, none of the PCE analytical results have been below the MCL since
2006. The trend for CJ-6 statistically exceeded the MCL and was projected to remain above the
remediation goal through 2027. For CJ-10, PCE concentrations had generally declined since
1995, but not enough to reduce concentrations below the remediation goal. The most recent
concentrations for CJ-10 fluctuate between 15 and 20 |ag/L, and the current trend estimate
statistically exceeds the remediation goal. Nonetheless, the trend shows that the concentration
is slowly declining and is projected to decrease further in the next 5 years.
A suite of three analytical models was used to estimate the combined effects of advection,
dispersion, sorption and matrix back-diffusion on contaminant concentrations along a profile
from well CJ-10 to G-6, ending at well G-3. The models estimated that the PCE concentration
at G-10 would decrease below the 5 |ag/L MCL by the year 2070. This estimate is substantially
longer than the estimates which were obtained through the trend projections. The analytical
modeling results provided an alternate assessment that incorporated the fate-and-transport
processes believed to be important in the Northwest Area.
Alternative 3: In-Situ Treatment with MNA, ICs, and a Vapor Intrusion Assessment. Alternative
3 would include in-situ treatment of groundwater contaminated with PCE in excess of 10 |ag/L,
MNA, ICs, and a vapor intrusion assessment. This alternative would rely on (1) in-situ treatment
for the rapid reduction of PCE concentrations within the targeted treatment zone, and (2)
natural attenuation to restore untreated groundwater. Continued long-term groundwater
monitoring would provide information on the state of the plume during the progress of the
remedy, ICs would maintain protectiveness until the 5 |ag/L MCL remediation goal is met, and a
vapor intrusion assessment would be performed to evaluate the potential for vapor intrusion
based on historical soil gas data.
In-situ treatment would involve injections of a sorptive amendment into the targeted
treatment zone within the Northwest Area. To develop this alternative, this amendment was
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presumed to be an activated carbon product. A sufficient quantity of the product would be
injected into groundwater to reduce and maintain the PCE concentration below the
remediation goal within the targeted treatment zone. To design the in-situ remedy, a limited
pre-design investigation would be required. One goal of the investigation would be to refine the
extent of the targeted treatment zone. This would involve high-resolution site characterization
(HRSC) of groundwater within the plume where COC concentrations have historically been
interpolated during 3DVA efforts from existing monitoring well data. If data from the
investigation reveal that the plume is smaller than the current conservative estimate, this could
provide significant savings by reducing the volume of media requiring treatment. Following the
HRSC effort, a pilot test would be conducted to estimate injection radii of influence,
amendment dose, injection pressures, and other parameters necessary for full-scale design.
At most locations within the targeted treatment zone, the amendment could be distributed in
the subsurface via direct push technology injections through uncased, pre-drilled boreholes
backfilled with bentonite. Injections deeper than 180 feet bgs would require larger diameter
boreholes cased in the overburden and weathered bedrock, with the fractured bedrock
uncased. Injections into the uncased portion of the borehole could then be performed using
packers to isolate specific vertical intervals.
As with Alternative 2, the existing Northwest Area groundwater monitoring program, with
some modifications, would be relied upon to monitor the state of the plume. Existing
monitoring wells CJ-1A, G-2, CJ-3, and CJ-11, which are not currently monitored, would be
added to the groundwater monitoring program, or replaced as needed if the conditions of any
of these wells prevents groundwater elevation measurement and sampling. Adding these wells
would improve plume delineation and increase the data density for any future 3DVA-based
remedy progress monitoring. Groundwater monitoring would involve periodic groundwater
sampling and analysis at a frequency that decreases over time. The monitoring parameters
would include field water quality parameters (such as, pH, ORP, and DO), groundwater
elevations, and VOCs (through laboratory analysis). Data analysis would include periodic 3DVA-
based remedial progress monitoring, COC concentration trend analysis, and projections of the
time required for PCE in groundwater to reach the remediation goal.
As with Alternative 2, ICs would include governmental controls by San Bernardino County for
affected areas in the Northwest Area that overlie the PCE plume and are outside San
Bernardino city limits. Areas that overlie the PCE plume that are inside the San Bernardino city
limits are already controlled by ICs placed through City of San Bernardino Municipal Ordinance
Title 13, Chapter 13.25 and the 2015 ROD for the Newmark and Muscoy OUs. The affected
areas that are outside the San Bernardino city limits are under the sole jurisdiction of San
Bernardino County. San Bernardino County ICs would prohibit the installation of all wells other
than wells related to the remediation of the plume until the remediation goal is met.
Vapor intrusion from contaminated groundwater is unlikely to be a concern in the Northwest
Area based on the depth to groundwater, soil gas concentrations in historical samples that
decrease from deep to shallow depths, the significant reduction of the groundwater plume
between that time period and the present, current groundwater contaminant concentrations,
and that there are no receptors in the areas where concentrations exceed EPA criteria.
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However, a vapor intrusion assessment will be performed in the Northwest Area as part of the
remedy to evaluate the potential for vapor intrusion based on historical soil gas data.
The estimated present value cost of Alternative 3 is $8.68 million. This includes $5.91 million in
capital expenses, $0.76 million in O&M expenses, and $2.0 million in contingency expenses (30
percent of the capital and O&M costs).
The targeted treatment zone (that is, groundwater containing more than 10 |ag/L of PCE) is
expected to meet the remediation goal within several months to a few years. The portion of the
plume outside the targeted treatment zone is estimated to take 7 to 20 years to meet the
remediation goal (approximately 30 to 60 percent faster than Alternative 2).
2.9 Summary of Comparative Analysis of Alternatives
To determine which remedial alternative to select, EPA evaluated and compared them using
the following nine evaluation criteria prescribed in the NCP at 40 CFR § 300.430(e)(9)(iii):
• Overall protection of human health and the environment;
• Compliance with applicable or relevant and appropriate requirements (ARAR);
• Long-term effectiveness and permanence;
• Reduction of toxicity, mobility, or volume through treatment;
• Short-term effectiveness;
• Implementability;
• Cost;
• State Acceptance; and
• Community Acceptance.
The first two criteria - overall protection of human health and the environment and compliance
with ARARs - are threshold criteria that must be met for an alternative to be selected as the
final remedy. If an alternative does not meet these two criteria, it is not eligible for selection.
The next five criteria are defined as balancing criteria. These criteria are used to weigh major
trade-offs among alternatives. The last two criteria, state and community acceptance, are
defined as modifying criteria. In the final comparison of alternatives, modifying criteria and
balancing criteria are of equal importance.
The nine NCP criteria and how each alternative does or does not meet the nine NCP criteria are
explained in the following subsections. Table 3 in Section 2.8 presents the cost estimates and
the estimated remediation duration for each alternative. Table 4, at the end of Section 2.9.8,
presents the results of the comparative analysis of alternatives.
2.9.1 Overall Protection of Human Health and the Environment
Overall Protection of Human Health and the Environment addresses whether an alternative can
meet the RAOs that were developed to protect human health and the environment and how
risks posed through each exposure pathway are eliminated, reduced, or controlled.
Alternative 1 would be the least protective because, although natural attenuation processes are
reducing PCE concentrations in the groundwater, Alternative 1 does not take any actions to
monitor site conditions or prevent exposure until concentrations attain the 5 |ag/L MCL
remediation goal.
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Alternative 2 would rely on existing abiotic natural attenuation to attain the remediation goal,
while Alternative 3 would also incorporate in-situ treatment. The overall protectiveness of
Alternatives 2 and 3 are similar, with Alternative 3 posing slightly more risk to workers and the
community during construction because in-situ treatment is more intrusive and would generate
more waste. However, Alternative 3 is estimated to attain the remediation goal 30 to 60
percent sooner because of faster cleanup within the targeted treatment zone. Both alternatives
include groundwater monitoring and ICs to evaluate cleanup progress and prevent exposure
during remedy implementation and both include a vapor intrusion assessment to evaluate the
potential for vapor intrusion based on historical soil gas data.
2.9.2 Compliance with ARARs
CERCLA § 121(d) requires that the remedial action attain, or justify the waiver of, federal or
more stringent state laws and regulations determined to be applicable to the hazardous
substance, pollutant, or contaminant or is relevant and appropriate under the circumstances of
the release.
Applicable requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal environmental or
state environmental or facility siting laws that specifically address a hazardous substance,
pollutant or contaminant, remedial action, location, or other circumstance found at a CERCLA
site. An applicable state requirement is an ARAR only if it is more stringent than the
corresponding federal requirement.
Relevant and appropriate requirements are those cleanup standards, standards of control, and
other substantive requirements criteria, or limitations promulgated under federal
environmental or state environmental or facility siting laws that, while not legally applicable to
a hazardous substance, pollutant, or contaminant, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations sufficiently similar to those
encountered at the CERCLA site such that their use is well-suited to the particular site. A state
requirement that is relevant and appropriate is an ARAR only if it is more stringent than the
corresponding federal requirement.
ARARs for the remedial action are selected in the ROD. The ARARs identified for the selected
remedy for the Northwest Area of the Source OU are described in Section 2.11.5.
Alternative 1 may meet the potential chemical-specific ARAR (the MCL for PCE promulgated
under the SDWA identified as the remediation goal) because natural attenuation processes are
reducing concentrations of PCE in the groundwater. However, no actions would be
implemented to determine when concentrations of PCE would attain the remediation goal and
no actions would be implemented to prevent exposure to the PCE-contaminated groundwater
until the remediation goal is met.
Alternatives 2 and 3 would comply with ARARs.
2.9.3 Long-Term Effectiveness and Permanence
The long-term effectiveness and permanence criterion evaluates the magnitude of residual risk
associated with contamination remaining after completion of the remedial activities and the
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adequacy and reliability of the remedy.
Alternative 1 would be the least effective in the long term because there would be no action
taken to control potential exposure to contaminated groundwater while the existing abiotic
natural attenuation processes are reducing concentrations of PCE.
Both Alternatives 2 and 3 would attain the remediation goal through gradual depletion of
contaminant mass from groundwater. Alternative 2 would accomplish this entirely through
existing abiotic natural attenuation, while Alternative 3 would incorporate in-situ treatment of
concentrations of PCE greater than 10 |-ig/L. The statistical analyses and predictive modeling
performed indicate that the remediation goal would be met in 10 to 47 years in Alternative 2
and 7 to 20 years in Alternative 3. In addition, both alternatives would likely need up to 5 years
of additional groundwater monitoring to confirm that the remediation goal has been attained
because of the potential for fluctuation in PCE concentrations (as evidenced in the historical
groundwater monitoring record). Moreover, with Alternative 3, there would be some potential
for contaminant concentration rebound if the sorptive amendment dosing or amendment
distribution were insufficient. Both alternatives would use ICs to prevent future potential
receptors from exposure to the contamination until the remediation goal has been attained
because of the significant time needed to attain the remediation goal. Both Alternatives 2 and 3
would evaluate vapor intrusion based on historical data and are equally rated for long-term
protectiveness.
2.9.4 Reduction of Toxicity, Mobility, or Volume through Treatment
This criterion identifies whether the alternative reduces the toxicity, mobility, or volume of
contamination through treatment and reflects EPA's statutory preference for remediation
alternatives that use treatment to permanently reduce contamination significantly.
Alternative 3 is the only alternative that would reduce the contamination in the Northwest Area
of the Source OU through treatment, thus it is rated high for this criterion. Both Alternative 1
and Alternative 2 would reduce PCE concentrations; however, the reduction would be though
natural processes, not engineered treatment.
2.9.5 Short-Term Effectiveness
Assessment of alternatives for short-term effectiveness may include: (1) evaluation of short-
term risks to the community during remedial action, (2) risks to workers involved in remedial
activities and the reliability of protective measures, (3) potential environmental impacts and
reliability of measures to mitigate such impact, and (4) the time required to implement the
remedial alternative and achieve the RAOs.
Alternative 1 rates high in short-term effectiveness because it would pose the least short-term
risk to workers, the community, and the environment since contaminated groundwater poses
no immediate risk, and this alternative would not require any actions that could pose risk to
workers or the community.
Alternative 2 also rates high in short-term effectiveness because the infrastructure for this
alternative is already in place and therefore, would not require construction that would pose a
risk to the community or remediation workers. The groundwater sampling would pose potential
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risks to workers during groundwater sampling which would be mitigated using personal
protective equipment (PPE) and following safe work practices.
Alternative 3 rates lower than Alternatives 1 and 2 in short-term effectiveness because
Alternative 3 would pose some risk to workers from the physical hazards associated with
remedial action construction. Additionally, site-related traffic during the construction phase
may cause some inconvenience to the community for 2 to 3 years. Amendment injections
associated with Alternative 3 would involve some risk of spreading the plume; however, this
risk could be controlled through injection sequencing.
2.9.6 Implementability
Assessing the ease or difficulty of implementing a remedial alternative may include: (1) its
technical feasibility or challenges associated with its construction and operation, the ease of
undertaking additional action, and the ability to monitor the remedy; (2) its administrative
feasibility or non-technical challenges to implementation, such as the need for approvals or
permits and the associated time and effort; (3) the availability of technical services and
materials; and (4) the availability of necessary equipment or other resources.
Although Alternative 1 is physically easy to implement, it is not administratively feasible (would
not receive approval) because it does not control risk to human health and the environment. As
a result, it is rated low on implementability.
Alternative 2 is technically and administratively feasible because a groundwater monitoring well
network already exists and groundwater monitoring has been ongoing for decades. As a result,
it is rated high on implementability.
Alternative 3 would involve the challenges associated with drilling and injecting into bedrock,
and distributing amendments within a very large targeted treatment zone. This alternative
would require specialized services and would take much greater effort to implement than
Alternatives 1 or 2. As a result, this alternative was rated moderate in implementability.
2.9.7 Cost
Assessing the costs associated with each alternative includes estimating (1) capital costs
(construction and professional); (2) O&M costs; (3) contingency costs; and (4) the net present
value of capital and O&M costs for each alternative. The net present value of each alternative
was calculated by summing the present values of capital and O&M costs. The present value is
the estimated value of a future expense in current year dollars. Present values were calculated
by discounting future costs using a 2 percent annual discount rate obtained from the U.S. Office
of Management and Budget circular A-94, Appendix C, dated December 12, 2022. Therefore,
the estimated cost of every alternative was calculated in 2023 dollars and projected over the
anticipated duration of each alternative.
An alternative is considered cost effective if its costs are proportionate to its overall
effectiveness.
The present value costs for the three groundwater remedial alternatives, from highest to
lowest, are as follows: (1) Alternative 3 is $8.68 million; (2) Alternative 2 is $1.24 million; (3)
Alternative 1 is $0.
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Table 3 summarizes the estimated cost and remedial duration of each alternative.
Table 3. Remedial Alternative Cost and Duration
Alternative
Cost
Remedial Duration
Capital
O&M
Contingency
Total
Construction
O&M
1
$0 MM
$0 MM
$0 MM
$0 MM
0 years
0 years
2
$0.14 MM
$0.81 MM
$0.29 MM
$1.24 MM
0 years
10 to 47 years
3
$5.91 MM
$0.76 MM
$2.00 MM
$8.68 MM
2 to 3 years
7 to 20 years
Notes: MM = Million; O&M = operations and maintenance
2.9.8 State and Community Acceptance
Assessing the acceptance by the state and community of the proposed remedy includes: (1)
evaluating comments received from the community when the proposed remedy is released to
the community in the Proposed Plan; and (2) evaluating comments received from DTSC, the
lead state regulatory agency.
EPA released the Proposed Plan to the community on August 14, 2023. EPA held a public
meeting for the community on August 23, 2023, and held a public comment period from August
14 to October 13, 2023. EPA received comments from the community at the public meeting and
during the public comment period. Part 3, Responsiveness Summary of this ROD presents
EPA's responses to these comments. Comments from the community stated support for EPA's
proposed remedy; no comments indicate a change in the proposed remedy was necessary.
The DTSC concurs with EPA's proposed remedy as indicated by its concurrence letter, which is
included as Appendix A.
Table 4 presents a summary of the results of the comparative analysis of alternatives.
Table 4. Remedial Alternative Comparative Analysis
Criterion
Alternative 1 -
No Action
Alternative 2 -
MNA, ICs, Vapor
Intrusion Assessment
Alternative 3 -
In-Situ Treatment,
ICs, Vapor Intrusion
Assessment
Overall protection of human health and
the environment
Not Protective
Protective
Protective
Compliance with ARARs
Meets ARARs
Meets ARARs
Meets ARARs
Long-term effectiveness and
permanence
Low
High
High
Reduction of toxicity, mobility, or volume
through treatment
Low
Low
High
Short-term effectiveness
High
High
Moderate
Implementability
Low
High
Moderate
Cost (estimated net present value)
$0
$1.24 MM
$8.68 MM
State and Community Acceptance
No
Yes
Yes
Notes: ARAR = Appliable or relevant and appropriate; IC = Institutional controls; MM = Million; MNA = Monitored natural
attenuation.
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2.10 Principal Threat Wastes
The NCP at 40 CFR § 300.430(a)(l)(iii) establishes an expectation that treatment will be used to
address the principal threats at a site whenever practicable. Engineering controls, such as
containment, may be used for wastes that pose a relatively low long-term threat or where
treatment is impractical. Principal threat wastes are those source materials considered to be
highly toxic or highly mobile which cannot be reliably contained or that would present a
significant risk to human health, orthe environment should exposure occur. The medium of
concern for the Northwest Area of the Source OU is groundwater. EPA generally does not
consider groundwater to be source material, and therefore, it is not considered a principal
threat waste. Further, concentrations of PCE in the groundwater are low, and potential risk
should exposure occur is in the middle of the EPA's risk management range.
2.11 Selected Remedy
Based on information currently available, EPA believes the selected remedy of MNA, ICs, and
vapor intrusion assessment meets the threshold criteria and provides the best balance of trade-
offs among the alternatives with respect to the balance and modifying criteria.
Key factors in selecting Alternative 2 (MNA, ICs, and a vapor intrusion assessment) as the
remedy include that this alternative would protect human health and the environment and
meet ARARs. Based on 25 years of data, EPA has demonstrated that natural attenuation is
occurring in the Northwest Area of the Source OU, and concentrations of PCE are decreasing.
Groundwater in the Northwest Area is designated for beneficial use as a municipal and
domestic supply (drinking water) in the Basin Plan; however, the groundwater is not currently
being used as a municipal and domestic supply, so there is time for the natural attenuation
processes to decrease contaminant concentrations so that the groundwater can be restored to
its designated beneficial use. Further, 3DVA remedial progress monitoring has demonstrated
that the PCE plume in the Northwest Area is not acting as a source for the Newmark or Muscoy
OU plumes at either the 5 |ag/L MCL or the 0.5 |ag/L EIS performance standard, so the
Northwest Area plume is not impacting the use of the groundwater in these OUs as a source of
municipal and domestic supply.
EPA will monitor the groundwater to obtain information on PCE degradation and the plume and
to periodically update remediation timeframe estimates. Until concentrations of PCE meet the
5 |ag/L MCL remediation goal, ICs will be implemented to restrict the installation of
groundwater wells to prevent exposure to the contaminated groundwater. In addition,
although vapor intrusion is unlikely to be a concern in the Northwest Area of the Source OU,
EPA will complete a vapor intrusion assessment to further evaluate the potential for future risk
in the Northwest Area.
Specific activities associated with the selected remedy are described below.
2.11.1 Monitored Natural A Herniation
The RAO for the groundwater remedial action is to restore groundwater to its beneficial use as
a source of municipal and domestic supply as designated in the Basin Plan. Twenty-five (25)
years of data (from 1997 to 2022) show PCE concentrations and mass in the Northwest Area
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have declined and are still declining. Statistical analysis shows decreasing trends and suggests
attainment of the remediation goal in approximately 10 to 30 years using different regression
models and observed PCE concentrations at monitoring well CJ-10, which was used as the
representative well because it has had the highest PCE concentrations (Tetra Tech 2024). In
addition, natural attenuation was modeled using screening-level analytic tools to corroborate
the statistical estimates, and the predicted duration to attain the remediation goal is 47 years.
Therefore, natural attenuation could attain the remediation goal in 10 years (based on the
statistical analyses) to 47 years (based on groundwater fate and transport model). During that
time, groundwater monitoring would provide information on the state of the plume and
support periodic refinement of cleanup duration estimates (Tetra Tech 2024).
2.11.2 Institutional Controls
Until the remediation goal is met, ICs will be implemented to prevent exposure to
contaminated groundwater. EPA will rely on two different ICs to restrict the installation of
groundwater wells in the Northwest Area plume. A small portion of the plume in the Northwest
Area is located within the San Bernardino city limits. City of San Bernardino Municipal
Ordinance Title 13, Chapter 13.25 requires a permit before a groundwater well can be
constructed. ICs would prohibit the installation of all wells other than wells related to the
remediation of the plume. Most of the plume in the Northwest Area affects areas that are
outside the San Bernardino city limits and under the sole jurisdiction of San Bernardino County.
San Bernardino County will prohibit the construction of groundwater wells in areas located
outside the San Bernardino city limits. Figure 16 shows the areas subject to the ICs.
2.11.3 Vapor Intrusion Assessment
Vapor intrusion is unlikely to be a concern in the Northwest Area based on: (1) the depth to
groundwater, (2) soil gas concentrations in historical samples that decrease from deep to
shallow depths, (3) the significant reduction of the groundwater plume area between that time
period and the present, (4) current contaminant concentrations, and (5) no receptors being
present in the areas with concentrations above EPA VISLs. However, a vapor intrusion
assessment will be performed in the Northwest Area as part of the remedy to evaluate the
potential for future vapor intrusion risk.
2.11.4 Summary of the Estimated Costs for the Selected Remedy
The estimated cost is $1.24 million, including $0.14 million in capital expenses, $0.81 million
(present worth) in O&M expenses, and $0.29 million in contingency expenses (30 percent of
capital and O&M).
2.11.5 Expected Outcome of the Selected Remedy
The expected outcome of the selected remedy is to meet the RAOs (identified in Section 2.7)
and restore the groundwater to its designated beneficial use with concentrations of PCE at or
below the 5 |ag/L MCL remediation goal in approximately 10 to 47 years. Once the remediation
goal is met, ICs will no longer be required.
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Figure 16. Proposed Institutional Controls Boundary in the Northwest Area (from Tetra Tech 2024)
MWCOEOP7
Proposed San Bernardino County
IC Boundary
Verdemont Hills %%
MWCO6009 I
Existing IC Area
CJ-lfi
Northwest Area
Cajon Landfil
Legend
C3
Monitoring Well screened in
bedrock and overburden
Monitoring Well - unknown
Soil Boring Location
PCE Plume at and above 5 ys'L
in bedrock and overburden
(dashed = inferred)
I Proposed Institutional Controls
Boundary
j Northwest Area
~
Parcel Boundary
Existing IC Area from Newmark
and Muscoy OUs ROD August 2015
(City of San Bernardino Ordinance,
Municipal Code Title 13.25)
PCE - Tetrachloroethene
pg/L - micrograms per Liter
IC - Institutional Controls
OU - Operable Unit
ROD - Record of Decision
Notes:
t. The PCE plume boundary is based on Fall 2021.
Spring 2022 & Fall 2022 data.
2. Monitoring wells outside the proposed IC boundary
Newmark Groundwater
Contamination Superfund Site
San Bernardino, California
Figure 16
Proposed Institutional Controls Boundary in the Northwest Area
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2.12 Statutory Determinations
This section describes how the selected remedy satisfies the statutory requirements of CERCLA
§ 121 and requirements of the NCP at 40 CFR § 300.430(f)(5)(ii). The lead agency must select
remedies that are: (1) protective of human health and the environment; (2) comply with ARARs
(unless a statutory waiver is justified); (3) are cost-effective; (4) use permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable; and (5) employ treatment to permanently and significantly reduce the volume,
toxicity, or mobility of hazardous substances, pollutant, or contaminants as a principal element.
In addition, the lead agency must determine if five-year reviews of the remedy are required.
2.12.1 Protective of Human Health and the Environment
The selected remedy will meet the RAOs, which identify what is necessary to protect human
health and the environment. Potential risk to human health was identified if the groundwater is
used as a source of municipal and domestic supply (drinking water). The selected remedy will
restore the groundwater to its beneficial use as a source of municipal and domestic supply and,
in the period before the groundwater is restored, will restrict the construction of groundwater
wells to avoid the use of the contaminated groundwater.
2.12.2 Compliance with ARARS
CERCLA § 121(d)(2)(A) requires that remedial actions meet any federal or more stringent state
standards, requirements, criteria, or limitations that are determined to be ARARs; which are
generally divided into three categories: chemical-, location-, and action-specific requirements.
Chemical-specific ARARs are generally risk-based numerical values applied to site-specific
conditions that result in the establishment of a remediation goal (cleanup level). Location-
specific ARARs are identified based on various attributes of the site location (such as habitat for
threatened or endangered species or the presence of historic or cultural resources). No location
specific ARARs are identified because no protected resources are in the Source OU or would be
affected by the selected remedy. Action-specific ARARs are triggered by the remedial action
being selected and present requirements for how the remedial action must be conducted. The
requirements determined to be ARARs for the selected remedy are presented in Table 5 and
Table 6. The selected remedy will meet these ARARs, and no ARAR waiver is being sought.
2.12.3 Cost Effectiveness
The NCP at 40 CFR § 300.430(f)(l)(ii)(D) defines how cost-effectiveness is determined. Cost-
effectiveness is determined by the overall effectiveness, which looks at long-term effectiveness
and permanence, reduction of toxicity, mobility, or volume through treatment, and short-term
effectiveness. A remedy is cost-effective if its costs are proportional to its overall effectiveness.
The selected remedy (Alternative 2) scored high in two of the three cost-effectiveness criteria. The
selected remedy does not reduce the toxicity, mobility, or volume through treatment. However,
natural attenuation processes are at work in the Northwest Area plume, so concentrations of PCE
are reducing, just not "through treatment." Therefore, EPA has determined that the selected
remedy is cost effective because it scored high on long-term effectiveness and permanence and
short-term effectiveness, while PCE concentrations are reducing.
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Table 5. Chemical-Specific Applicable or Relevant and Appropriate Requirements
Media
Requirement
Requirement Synopsis
Prerequisites, Status and Rationale
Groundwater
FEDERAL
Safe Drinking
Water Act
Maximum
Contaminant
Levels
40 CFR § 141.61(a)
Drinking water standards
that are applicable to
public water supply
systems and must be met
at the tap for end users.
Relevant and Appropriate
MCLs are applicable requirements for public water supply systems and apply at the tap
for the end user. MCLs are not applicable to in situ groundwater. MCLs and non-zero
MCLGs are relevant and appropriate requirements for groundwater that is a current or
potential future source of drinking water. Groundwater in the Northwest Area of the
Source OU is not currently being used as a source of drinking water; however, the City
of San Bernardino, the City of Riverside, and surrounding communities rely on drinking
water supply wells downgradient of the Northwest Area. Further, the groundwater is
in the Bunker Hill-A groundwater management zone of the Upper Santa Ana River
Basin and is designated with a municipal and domestic supply beneficial use in the
Water Quality Control Plan for the Santa Ana Basin. So, the EPA has determined that
restoration of groundwater to that beneficial use is an objective of the remedial
action. As a result, MCLs are relevant and appropriate requirements. EPA has
identified the MCL for PCE at 40 CFR § 141.61(a) (5 ng/L) as a chemical-specific ARAR
and has used it as the basis for the remediation goal. The MCLG for PCE is zero, so it is
not identified as a relevant and appropriate requirement.
Groundwater
STATE
Water Quality
Control Plan Santa
Ana River Basin
Chapter 3, Table 3-
1
Bunker Hill-A Groundwater
Management Zone in the
Upper Santa Ana River
Basin has the following
designated beneficial uses:
(1) municipal and domestic
supply; (2) agricultural
supply; (3) industrial
service supply; and (4)
industrial process supply.
Applicable
Groundwater in the Northwest Area is in the Bunker Hill-A Groundwater Management
Zone. EPA has identified restoration of the groundwater to its beneficial use as a
source of municipal and domestic supply as an objective of the remedial action.
The Basin Plan identifies State of California MCLs as water quality objectives for
sources of drinking water. The State of California MCL for PCE (5 ng/L) is equal to the
federal MCL. So, the State of California MCL is not identified as an ARAR.
Notes: § = Section; iug/L = micrograms per liter; Basin Plan = Water Quality Control Plan for the Santa Ana River Basin; EPA = United States Environmental Protection Agency; CFR
= Code of Federal Regulations; MCL = Maximum Contaminant Level; MCLG = Maximum Contaminant Level Goal; PCE Tetrachloroethene.
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Table 6. Action-Specific Applicable or Relevant and Appropriate Requirements
Activity
Requirement
Requirement Synopsis
Prerequisites, Status and Rationale
Place ICs
STATE
California Code of
Regulations
Requirements for
Land Use
Covenants
22 CCR
§ 67391.1(f)
Whenever DTSC finds it is not
feasible to establish a land use
covenant as a component of a
remedy for a site, it may use other
IC mechanisms to ensure future
land use will be compatible with
levels of hazardous materials,
hazardous waste constituents, or
hazardous substances that remain
on the property.
Applicable
ICs are necessary to prevent exposure to groundwater until concentrations of
PCE in groundwater reach the remediation goal. It is not feasible to enter into
and record a land use covenant because the PCE plume in groundwater
underlies several different parcels of property with several different property
owners. Instead, other institutional control mechanisms in the form of
government controls will be used. EPA will rely on two governmental controls
to restrict the construction of groundwater wells. A small portion of the plume
is within the San Bernardino city limits. The existing San Bernardino City
Municipal Code Ordinance at Title 13, Chapter 13.25 will be used to control
construction of groundwater wells within the city limits. San Bernardino County
will enact a second control to restrict the construction of groundwater wells in
the area overlying the plume under the sole jurisdiction of the County.
Notes: § = Section; CCR = California Code of Regulations; DTSC = California Department of Toxic Substances Control; EPA = United States Environmental
Protection Agency; IC = Institutional Control; PCE =Tetrachloroethene
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2.12.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and alternative treatment (or resource recovery) technologies can be used
in a practicable manner at the Northwest Area of the Source OU. There is no longer a
continuing source emanating from the Northwest Area and concentrations of PCE in
groundwater are declining naturally and are expected to be at or below the 5 |ag/L MCL
remediation goal. In the interim, EPA will rely on ICs to prevent exposure to the groundwater
contamination and will continue to monitor the groundwater until EPA demonstrates that the
remediation goal is met. Since concentrations of PCE are expected to meet the remediation
goal, resulting in groundwater being restored to its beneficial use as a source of municipal and
domestic supply, the selected remedy represents a permanent solution.
2.12.5 Preference for Treatment as a Principal Element
The selected remedy does not satisfy the statutory preference for treatment as a principal
element. Concentrations of PCE are declining due to natural attenuation processes; however,
that is not considered an engineered treatment. EPA evaluated an alternative (Alternative 3)
that included in-situ treatment. However, Alternative 3 is not the preferred alternative because
it includes extensive drilling for injection of the treatment materials, which would be disruptive
to the community, pose logistical challenges, and present increased impacts to remediation
workers. Furthermore, Alternative 3 would not significantly reduce the time to achieve the
remediation goal compared to the selected remedy and would have significantly higher costs
(approximately 8 times more than Alternative 2).
2.12.6 Five-Year Review Requirements
CERCLA § 121 requires five-year reviews (statutory reviews) of sites where the remedial action
does not result in unlimited use and unrestricted exposure (UU/UE). EPA also completes five-
year reviews as a matter of policy (policy reviews) of sites where the remedial action will result
in UU/UE but will take more than five years to achieve UU/UE. Achieving the remediation goal
for PCE will allow for UU/UE for the groundwater. However, achieving the remediation goal is
expected to take longer than 5 years; therefore, EPA will complete CERCLA five-year policy
reviews until the remediation goal for PCE is met. EPA currently completes five-year reviews for
the Newmark and Muscoy OUs, so EPA will include the five-year review of the remedy for the
Northwest Area of the Source OU in its five-year reviews of the Newmark and Muscoy OUs.
2.13 Documentation of Significant Changes
EPA issued a Proposed Plan for the Source OU on August 14, 2023. The Proposed Plan identified
EPA's preferred cleanup alternative, which includes MNA, ICs, and a vapor intrusion
assessment. EPA also held a public meeting on August 23, 2023, and a public comment period
from August 14, 2023, through October 13, 2023. EPA received verbal comments at the public
meeting and written comments during the public comment period. The verbal and written
comments expressed support for EPA's preferred cleanup alternative, so EPA has determined
that no significant changes to the remedy as originally described in the Proposed Plan are
necessary or appropriate.
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2.14 References
California Department of Toxic Substances Control. 2019. Human Health Risk Assessment
(HHRA) Note Number 10, Toxicity Criteria. February.
EMCON. 1995. Cajon Landfill Site Assessment Report, Evaluation Monitoring Program. Volume
1. August.
Gilbane. 2014. Mid 2014 Final Technical Memorandum of Results, Semiannual Groundwater
Sampling, Newmark Groundwater Superfund Site, San Bernadino, California. Prepared
for EPA Region 9. November.
Montgomery Watson Harza. 2002. Final Investigation Report, Initial Soil Vapor Survey in the
Vicinity of the San Bernadino Engineer Depot. September.
Stantec Consulting Corporation. 2008. Newmark Groundwater Flow Model Report, Newmark
Groundwater Contamination Superfund Site, San Bernardino, California. Prepared for
EPA Region IX, California Department of Toxic Substances Control, and the City of San
Bernardino, November 5.
Tetra Tech. 2014. Final Technical Memorandum. Source Identification, Plume Delineation,
Restoration Timeframe Estimation and Transition from Interim to Final Remedy.
Newmark Groundwater Contamination Superfund Site. Source Operable Unit. San
Bernardino, California. May 19.
Tetra Tech. 2023. Final. Remedial Investigation and Focused Feasibility Study. Newmark
Groundwater Contamination Superfund Site. Source Operable Unit. San Bernardino,
California. August 9.
Tetra Tech. 2024. Final (Revision 1). Remedial Investigation and Focused Feasibility Study.
Newmark Groundwater Contamination Superfund Site. Source Operable Unit. San
Bernardino, California. March 20.
United States Environmental Protection Agency (EPA). 1993a. Newmark Ground Water
Contamination Superfund Site, Interim Record of Decision - Newmark OU. August.
EPA. 1993b. Newmark Operable Unit Remedial Investigation/Feasibility Study Report. March.
EPA. 1994. Muscoy Operable Unit Remedial Investigation/Feasibility Report. December.
EPA. 1995. Newmark Ground Water Contamination Superfund Site, Interim Record of Decision -
Muscoy OU. EPA/ROD/R09-95/133. March.
EPA. 2004. Explanation of Significant Differences (to 1993 and 1995 Interim RODs), Newmark
and Muscoy Operable Units
EPA. 2013. Second Five-Year Review Report for Newmark Groundwater Contamination
Superfund Site. September.
EPA. 2015. Record of Decision, Newmark Groundwater Contamination Superfund Site, Newmark
and Muscoy Operable Units, San Bernadino, California. August.
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EPA. 2018. Vapor Intrusion Technical Memorandum, Soil Gas Investigation Summary of
Findings, Newmark Groundwater Contamination Superfund Site, San Bernardino,
California, March.
EPA. 2022a. Regional Screening Levels. November. Accessed in May 2023 at:
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
EPA 2022b. Vapor Intrusion Screening Levels. November. Accessed in May 2023 at:
https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator
EPA. 2023a. Newmark Groundwater Contamination Superfund Site, Source Operable Unit,
Proposed Plan. August 2023.
EPA. 2023b. Fourth Five-Year Review Report for the Newmark Groundwater contamination
Superfund Site, San Bernardino, California. September.
URS Corporation. 2008. Hydrologic Investigation Report. Newmark Groundwater Contamination
Superfund Site, Source Operable Unit Interim Remedial Action. March.
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PART 3: RESPONSIVENESS SUMMARY
This Responsiveness Summary provides the United States Environmental Protection Agency's
(EPA) responses to oral and written comments received from the public on EPA's August 2023
Proposed Plan for the Newmark Groundwater Contamination Superfund Site (Newmark Site).
The Proposed Plan presented EPA's proposed remedy for the Northwest Area of the Source
Operable Unit (OU). The proposed remedy consists of Monitored Natural Attenuation (MNA),
Institutional Controls (IC), and a Vapor Intrusion Assessment.
On August 14, 2023, EPA released the Proposed Plan to the public for review and comment. On
August 14, 2023, EPA mailed a notice to the public within an approximate 2 mile radius of the
Northwest Area of the Source OU that EPA (1) was proposing a remedy, (2) would hold a public
meeting on August 23, 2023, where EPA would explain the proposed remedy and accept
comments and questions, and (3) would have a public comment period during which comments
or questions could be submitted in writing or via telephone. EPA also published a notice of the
public meeting and the public comment period in several newspapers. More detailed
information on EPA's community involvement activities can be found in Part 2: Decision
Summary, Section 2.2.3.
EPA received verbal comments and questions during the public meeting and received written
comments from the San Bernardino Municipal Water Department (SBMWD) in a letter dated
October 13, 2023 during the public comment period. The verbal comments and questions
received during the public meeting and EPA's responses are presented in Sections 3.1 and 3.2
of this Responsiveness Summary, respectively. SBMWD's written comments are provided in
Appendix C and EPA's responses to SBWMD's written comments are presented in Section 3.3
and Attachment A to this Responsiveness Summary.
3.1 Comments Received During the Public Meeting
Comment No. 1 (from Ms. Heather Dyer): My name is Heather Dyer. I serve as the CEO General
Manager of the San Bernardino Valley Municipal Water District, the regional wholesale agency
responsible for ensuring a reliable safe supply of water to the people of this region. I also serve
as the Court-Appointed Water Master on behalf of the San Bernardino parties of our 1969
adjudication and judgment.
First, I'd like to thank you for providing an extension to the public-comment period. This is a
substantial document and we appreciate the time for our staff to conduct a thorough review of
the information before coming to a decision on our position regarding your conclusions.
Second, I would like to reiterate that the groundwater aquifer is a critical shared resource to
millions of people throughout our region and its long-term health, sustainability, and safety are
of utmost importance.
We urge you to take a precautionary approach to the science and to your decision regarding
this project and your commitment to our safe water supply.
EPA Response to Comment No. 1: EPA understands that the aquifer is a shared source of
drinking water for the communities of San Bernardino. With respect to safe water supply, EPA
has identified a remedial action objective (RAO) in the Record of Decision (ROD) for the Source
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Operable Unit (OU) to restore the groundwater in the Northwest Area to use as a source of
drinking water and expects that the selected remedy will meet that RAO. Since the Newmark
Site was added to the National Priorities List in 1989, EPA has conducted investigations with
diligent scientific methods and analysis for more than 30 years to better understand the
Newmark Site and evaluate potential risks to human health and the environment associated
with the contamination. In addition, EPA selected final remedies for the Newmark and Muscoy
OUs in a ROD issued in 2015. These remedies are operating successfully as documented in the
most recent five-year review of the Newmark Site3. EPA has determined that it can now enter
the remedy selection phase for the Northwest Area of the Source OU, the only remaining
groundwater contamination at the Newmark Site that does not have a remedy in place.
Comment No. 2 (from Miguel Guerrero): My name is Miguel Guerrero. I am the General
Manager of the City of San Bernardino Municipal Water Department.
The water department appreciates confirmation that treatment of the drinking water to
remove PCE and TCE must continue as part of the Consent Decree work for as long as necessary
to comply with state drinking water permit obligations of 0.5 micrograms per liter.
Under the terms of the 2005 Consent Decree with the Army, if EPA were to prematurely declare
the work finished, the state water supply permit would require the city's costly treatment
obligations for the Army's PCE contamination to continue, even as the water department had
to return large sums of money to the United States. That outcome would be especially
intolerable and unfair for this environmental justice community.
The water department appreciates EPA's public confirmation that the work is not finished at
this site until drinking water treatment at the key remedial wells is no longer necessary under
our permits.
EPA Response to Comment No. 2; EPA agrees that remediation activities at the Newmark Site
are not completed. Final remedies are in place and operational for the Newmark and Muscoy
OUs. EPA is presently finalizing a ROD for the Source OU focusing on the Northwest Area, as it is
the only remaining portion of the Source OU that requires implementation of a remedial action.
This action will complete remedial action decision making for all three OUs at the Newmark
Site. Once EPA finalizes the ROD for the Source OU, the remedial action selected for the
Northwest Area will be designed and implemented, and will remain in place until
concentrations of tetrachloroethene (PCE) in the Northwest Area groundwater plume meet the
remediation goal of 5.0 micrograms per liter (|ag/L), the maximum contaminant level (MCL)
promulgated under the Safe Drinking Water Act. EPA notes that the "key remedial wells"
referred to in the comment are the 14 extraction wells designated in the 2015 ROD as
Extremely Impaired Source (EIS) wells located within the Newmark and Muscoy OUs.
Groundwater extracted from these wells is required to be treated to the state drinking water
permit obligations performance standard of 0.5 |ag/L. The ROD for the Source OU instead
focuses only on the Northwest Area of the Source OU and does not affect the remedies or RAOs
for the Newmark and Muscoy OUs.
3 U.S. Environmental Protection Agency, 2023. Fourth Five-Year Review Report for Newmark Groundwater Contamination
Superfund Site. San Bernardino, California. September 12.
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Comment No. 3 (from Miguel Guerrero): For the record, the water department is operating 14
production wells that are connected to treatment plants built to remove the PCE and TCE
contamination caused by the Army. These efforts have made substantial progress reducing the
mass of contaminants in the aquifer since the Consent Decree was entered in 2005.
The water department recognizes this progress and plans to go to the state's division of
drinking water soon to ask that the permit provisions for three of these wells be amended so
treatment is no longer required. The basis for this amendment request is the consistent
production of water that, even without treatment, already meets the 0.5 micrograms per-liter
standard. Last month, the water department submitted its technical memorandum to EPA and
to DTSC concerning the proposed amendment. We look forward to working with EPA and DTSC
in the cooperative effort.
EPA Response to Comment No. 3: Comment noted. EPA notes that the 14 production wells
that are the subject of this comment are associated with the Newmark and Muscoy OUs. EPA
selected a final remedy for the Newmark and Muscoy Operable Units in a ROD in 2015. The
ROD EPA is currently finalizing for the Source OU focuses only the Northwest Area of the Source
OU and does not impact the remedies selected in the Newmark and Muscoy OUs ROD.
Comment No. 4 (from Miguel Guerrero): The water department agrees with the EPA's
recommendation for the remedy of contamination in the Northwest portion of the site,
particularly in and around the Army's World War II base called Camp Ono and the base General
Depot.
The water department believes that, in this situation, monitored natural attenuation is
reasonable from the engineering, environmental, and cost standpoints. The remaining mass of
contaminants in and near the old Army base is small, is located several miles distant from the
current production wells, is too deep to pose a vapor hazard to people in surface structures and
will be tracked by the proposed monitoring well program. If PCE migrating from this location
requires additional action, the monitoring will allow EPA and DTSC to take timely steps to
protect the water supply.
EPA Response to Comment No. 4: EPA appreciates the SBMWD support for its proposed
remedy of MNA, ICs, and a vapor intrusion assessment.
Comment No. 5 (from Miguel Guerrero): Under the 2005 settlement, using federal money, the
water department has for the last 18 years undertaken the treatment and monitoring work
needed to halt the advance of the contaminant plume, while providing safely treated water to
the San Bernardino community. Using a similar approach, the water department is willing to
consider undertaking the required monitoring under this proposed plan, provided that the
United States makes a lump sum payment to the water department for this additional work.
The water department is already doing extensive monitoring and reporting as part of its
existing work, which makes the water department a logical candidate to address the additional
work and to do so efficiently.
Under the 2005 Consent Decree, the Army has not been released from its liability for response
costs incurred after August 14, 2023, the date of publication of the proposed plan. Given the
limited scope of work involved and the comparatively modest funding needed, the most
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efficient way to address this additional work may be to amend the Consent Decree so that
additional federal funds are provided for the water department to defray the additional work in
exchange for appropriate covenants not to sue for the parties.
EPA Response to Comment No. 5: EPA appreciates SBMWD's continued cooperation with the
terms of the 2005 Consent Decree, which primarily addresses the Newmark and Muscoy OUs.
EPA also appreciates SBMWD's willingness to support the Proposed Plan for the Northwest
Area of the Source OU. At this time, EPA plans to perform the work required under the
Proposed Plan for the Northwest Area of the Source OU with contractor support and previously
collected special account funds.
Comment No. 6 (from Miguel Guerrero): While the water department agrees that with EPA's
recommendation for monitored natural attenuation to complete the work for this site, the
water department will be submitting technical comments concerning the RI/FFS [Remedial
Investigation/Focused Feasibility Study].
EPA Response to Comment No. 6: Comment noted. The comments on the RI/FFS were
reviewed separately by EPA and EPA's response is provided in Attachment A to this
Responsiveness Summary. Please note that the Final RI/FFS was revised and published in the
Administrative Record for the site.
Comment No. 7 (from Miguel Guerrero): While most of our procedural concerns are addressed
by the extension for water agencies and the public to comment, the water department asks
that the factual portions of the 2001 SAIC study be posted promptly, given their importance to
EPA's interpretation of groundwater flow in the area near the landfill and the old Army base.
Our counsel will submit the legal basis for EPA to release the factual portions of the document
in a letter later this week.
EPA Response to Comment No. 7: EPA provided this document to the City of San Bernardino
Municipal Water Department on September 1, 2023, and a copy of the document will be
provided in the next update to the Administrative Record.
Comment No. 8 (from Rikke Van Johnson): I have served on the Board of the City of San
Bernardino Municipal Water Department. I previously served three terms as city Counselman
[sic] for the city of San Bernardino and have lived in the city for over 55 years. I have been a
long-time resident as well as represented the west side community, which has been historically
marginalized when dealing with government entities... the water department is pleased that
the U.S. Environmental Protection Agency recognizes that the city, particularly the west side
where much of the remediation is being done, is an environmental justice community, meaning
one where people are of very modest means and predominantly from ethic minority groups.
Figure 2-11, in that study, notes that 49 percent of the people in the Source Operable Unit area
are low income, 88 percent are people of color, and that median per capita annual income is
$20,819. For comparative purposes, the Census Bureau reports that the median per capita
annual income for the State of California is $41,276, roughly twice the San Bernardino figure.
Under California law, our water rates must reflect the true cost of providing the water,
regardless of the wealth or poverty of our ratepayers. Watching lines of underprivileged people
paying their water bills in cash reminds the Water Board to pay very close attention to what we
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spend to provide safe water to our residents. Thus, we are acutely sensitive to the cost the
water department has incurred and continues to incur to address the Newmark Groundwater
Contamination Site.
It took over eight years of litigation, from fall 1996 through March 2005, to bring the Army to
settle its liability for the Newmark Groundwater Contamination Site, even though EPA had
publicly stated starting in 1993 that the Army was the only source for that contamination. In
that settlement, the water department gave up a claim for roughly 10 million dollars in past
treatment and related costs incurred starting in the 1980s and going up to the start of the
litigation.
Also in that settlement, the water department agreed to incur substantial ongoing cost
increases for energy and related expenses resulting from the reconfiguration of the city's water
system to accommodate the locations of the EPA designed extraction wells and treatment
plants... the city had previously tried to maximize water production from the wells in highest
locations, so that water distribution relied on gravity rather than pumping up hill. Because of
the spread of the Army's contamination under the upper half of the city, when the treatment
systems came online to stop contaminate migration, the production wells had to be located at
much lower elevations than desirable from a distribution standpoint. In some instances, the
wellheads are nearly 1,000 feet lower than some customers the water department serves. At
maximum production, the water department is pushing over 10,000 gallons per minute of
water far up hill, with substantial energy costs running into the millions of dollars over the life
of the remedial work. Because of the Army's contamination, the city's ratepayers, from the
wealthiest to the poorest, are bearing that cost without any reimbursement from the
settlement...
...the Newmark Groundwater Contamination Site, was not addressed until the water
department spent over eight years in court to bring the Army to take partial responsibility for
that contamination. Given EPA's conclusions about the Army being the source of
contamination, the water department never should have had to file or pursue that litigation to
protect its residents from the Army's contamination.
We ask that the EPA bring the Army back to the table to pay for the remaining Source Operable
Unit work outlined in EPA's proposed plan, work the water department is willing to undertake if
the Army will pay for it.
The water department believes that it can do the work so more efficiently than an EPA
contractor as part of the ongoing work that the water department is already doing to protect
the remedial system and monitor the movement of the Army's contamination.
EPA Response(s) to Comment No. 8: Comment noted. EPA appreciates the SBMWD's
willingness to support the Proposed Plan for the Northwest Area of the Source OU. At this time,
EPA plans to perform the work required under the Proposed Plan for the Northwest Area of the
Source OU with contractor support and previously collected special account funds.
3.2 Questions Asked During the Public Meeting
Question No. 1 (from Jane Hunt-Ruble): I've been involved in this since the '90's. And, in fact,
they did testing in front of my house and my block. And I was curious about, this started - it
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started in the '80's. concerned about the map - I couldn't really clarify where the Northwest
area is in regard to, like - it looked like Cajon Boulevard. Does it go up to Institution Road or
Palm Avenue?
EPA Response to Question No.l: The southern border of the Northwest Area of the Source OU
extends to University Boulevard, tracks along the border of the Shandin Hills, then traverses
west on 1st Avenue. See Figure 1 in Part 2: Decision Summary. Based on this, Institution Road
and Palm Avenue are included within the Northwest Area. The PCE groundwater plume that will
be addressed by the selected remedy is located approximately 400 feet north of Palm Avenue.
Question No. 2 (from Jane Hunt-Ruble): What remedial action did you take on, the other two,
you know, like the Muscoy plume?
EPA Response(s) to Question No.2 [provided during the meeting by Ms. Sharissa Singh and
noted in the transcript on page 23]: So the other two operable units are they're currently
groundwater extraction systems - that are operated by the City of San Bernardino Municipal
Water District [Department].
Question No. 3 (from Jane Hunt-Ruble): Another question I have is risk assessment...I've lived
in Muscoy since 1965... you said there's no risk... But what about us old-timers that were
drinking this water probably back then, in the '60's and the '70's and the '80's?
EPA Response to Question No.3 [provided during the meeting by Mr. Harris-Bishop and noted
in the transcript on page 23]: It's a really great question and it's really hard to answer, because
we don't know what water you were drinking, if that water had contamination. The Safe
Drinking Water Act didn't exist back then. California State had regulations to monitor for certain
things, but a lot of these chemicals we weren't looking for in drinking water. It's hard for us to
be able to go back because we don't know what you were looking at. So all our risk assessment
can do is look forward...Just because it's in the ground, it may not be - you may not be exposed
to it. So we just don't know.
[Additional response provided during the meeting by Ms. Sharissa Singh in the transcript on
page 24]: So the important thing is you're not drinking the water right now. The water right
now is being treated by the city.
Question No. 4 (from Jane Hunt-Ruble): What kind of illnesses could you get from it, you know,
if you drank - I thought perchlorate was involved also in the Muscoy plume.
EPA Response(s) to Question No.2 [provided during the meeting by Mr. Harris-Bishop and
noted in the transcript on page 25 ]: We can put you in touch with somebody who's more of a
health professional to let you know what the health effects are of the exposure to PCE.
[Additional response provided during the meeting by Mr. Jody Edwards of Tetra Tech, EPA's
environmental consultant, in the transcript on page 25]: The chemical that you referred to
before is Perchlorate. It's actually an alternative term for Tetrachloroethylene, which is
Perchloroethylene. That's probably the one you're thinking of, which is a totally different
chemical than Perchlorate.
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Question No. 5 (from Adekunle Ojo): What happens if your drinking water standard for any
reason goes below 5 milligrams per liter in the future?
EPA Response(s) to Question No.5 [provided during the meeting by Mr. Harris-Bishop and
noted in the transcript on page 27]: Because this is being served as municipal drinking water
supply, you know, it's subject to way more than just the requirements we have for the
Superfund Sites. So the two remedies that are currently in place will continue to meet all state
and federal drinking water standards as well as requirements of the Superfund Site. So for this
remedy, if we determine that if, say, the level - the PCE drinking water standard goes to 2.5,
then we would continue to monitor to make sure that that plume gets down below 2.5 before
we say that it's done.
3.3 Comments Received During the Public Comment Period
EPA held a public comment period from August 14, 2023, to October 13, 2023. The only
comments EPA received during the public comment period were from the SBMWD. On October
13, 2023, EPA received written comments from the SBMWD in the form of a cover letter, which
contained comments, and three attached exhibits. SBWMD's letter and exhibits are provided in
Appendix C.
The cover letter submitted by SBMWD was divided into three parts:
• Part 1 - Factual Background of the Newmark Site;
• Part 2 - SBMWD's comments on the Proposed Plan for the Source OU; and
• Part 3 - SBMWD comments on the RI/FFS for the Source OU.
The cover letter included three attached exhibits:
• Exhibit 1, Table 1, SBMWD comments on the Source OU RI/FFS;
• Exhibit 2, "Training and Supply Activities at the Desert Training Center in World War II
and Their Relation to the Base General Depot at Camp Ono," William T. Bowers (Colonel
U.S. Army, Retired), June 2, 2005, describing the history of the Desert Training Center
and Camp Ono; and
• Exhibit 3, SBMWD Letter to EPA, dated February 28, 2018, regarding revised calculation
of PCE mass remaining in Newmark Groundwater Contamination Superfund Site for the
Third Five-Year Review report for the site.
EPA's technical responses to the specific comments in SBMWD's Exhibit 1, Table 1 are provided
in Table A-l of Attachment A to this Responsiveness Summary.
EPA reviewed SBWMD's Exhibit 2, the document regarding the history of the Desert Training
Center and former Camp Ono, and determined that the document does not contain any
comments; nor any information previously unknown to EPA or relevant to the remedy for the
Northwest Area of the Source OU described in the Proposed Plan. Based on these findings, EPA
has not provided responses to the information in SBWMD's Exhibit 2.
SBWMD's Exhibit 3 contains comments from SBMWD that PCE plume mass for EPA's then
upcoming Third Five-Year Review Report (finalized in 2018) should be calculated based on the
0.5 |ag/L performance standard in the 2015 ROD for the Newmark and Muscoy OUs, not the 5.0
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|ag/L MCL for PCE. EPA has not provided a response to SBWMD's Exhibit 3 because SBMWD
made the same comment in conjunction with its review of the RI/FFS for the Source OU and
EPA has provided a response to this comment/issue in Attachment A to this Responsiveness
Summary.
3.4 EPA Responses to SBWMD's Cover Letter Part 1
SBWMD cover letter Part 1 contains statements regarding the history of the Newmark Site and
the Newmark and Muscoy OUs; however, it does not contain comments on the remedy
presented by EPA in the Proposed Plan for the Source OU. Therefore, EPA has not provided
responses to statements made in Part 1.
3.5 EPA Responses to SBWMD's Cover Letter Part 2
SBWMD cover letter Part 2 contains SBWMD's comments and associated discussions on the
Proposed Plan for the Source OU. Following are SBWMD's comments and EPA's responses:
Part 2 Comment a: The Water Department Appreciates EPA's Confirmation in the Proposed Plan
that Remediation Work is Not Finished Until Treatment of Drinking Water for These
Contaminants Is No Longer Required by State Drinking Water Permits.
EPA Response: EPA stated in the Proposed Plan for the Source OU that EPA's cleanup plan was
focused on the Northwest Area of the Source OU and does not affect the 2015 ROD or decisions
made for the Newmark and Muscoy OUs. Accordingly, the determination of when remediation
work is finished for the Newmark and Muscoy OUs will be made pursuant to the 2005 Consent
Decree and the 2015 ROD.
Part 2 Comment b: The Water Department Supports EPA's Monitored Natural Attenuation
Remedial Choice.
EPA Response: EPA appreciates SBWMD's support.
Part 2 Comment c: The Water Department is Willing to Consider Adding Federally Funded
Monitoring to its Scope of Work.
EPA Response: Comment noted.
3.6 EPA Responses to SBWMD's Cover Letter Part 3
SBMWD submitted general comments on the RI/FFS for the Source OU in Part 3 of its cover
letter and specific comments on the RI/FFS in Exhibit 1, Table 1, (attached to SBMWD's cover
letter).
EPA's response to the general comments made by SBMWD in Part 3 of its cover letter are
provided below. EPA presents brief summaries of SBWMD's general comments to combine
similar points and to make the content easier for the public to review.
Part 3 Summarized Comment 1: There are technical problems with the RI/FFS and there are
contradictions between the RI/FFS and prior work done by EPA's contractors. The site
conceptual model of groundwater flow direction, groundwater barriers, and related issues will
need to be more carefully addressed.
EPA Response: The RI/FFS for the Source OU is based on decades of data collected for the
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Newmark Site, including the Northwest Area. All data were appropriately considered and
evaluated to develop an understanding of the Northwest Area and were subject to rigorous
technical review by the EPA and the State of California. EPA stands behind the technical
approach and results of the RI/FFS. EPA responds to specific technical comments on the RI/FFS
(Exhibit 1, Table 1 of SBMWD comments) in Attachment A to this Responsiveness Summary.
After reviewing the comments contained in Exhibit 1, Table 1, EPA determined that revisions to
the RI/FFS were warranted to correct some textual errors, or to explain more fully certain site
information and Rl findings. EPA revised the RI/FFS and the final revised version was published
in the Administrative Record for the site.
Part 3 Summarized Comment 2: Tetra Tech (the environmental engineering company that
completed the RI/FFS for the Source OU), has an organizational and financial conflict of interest
at the Newmark Site due to contracts awarded to it by the Army, and therefore, Tetra Tech
excuses the potential liability of the Army at the Newmark Site.
EPA Response: The United States, through EPA and the Department of Justice, determines
liability for the releases of contamination at the Newmark Site; EPA consultants do not make
such decisions. The United States has entered into two Consent Decrees for the Newmark Site
for payment of response costs incurred in addressing releases into the groundwater. The first
Consent Decree was completed in 2005 and required the Department of the Army to pay $78.5
million in response costs. The second Consent Decree was completed in 2007 and required San
Bernardino County to pay $11 million in response costs. EPA has been very clear about the
responsibility of the Department of the Army for the releases at the Newmark Site.
Further, the RI/FFS for the Source OU recognizes that the original source(s) for the
Newmark/Muscoy plume was from one or more areas within the boundaries of the former
Camp Ono, a former Department of the Army facility. While this point was recognized
throughout the RI/FFS, an inadvertent error in Section 7.2.2 Historical Evaluations of Potential
Sources with the Source OU, indicated that the Former Camp Ono was determined not to be
one of the sources of the Newmark Site PCE plume. The RI/FFS was revised to correct this error
and additional document modifications were made to reinforce that original source(s) for the
Newmark/Muscoy plume were from one or more areas within the boundaries of the former
Camp Ono. The ROD for the Source OU reflects this same information.
The United States has determined that there is no organizational or financial conflict of interest
with Tetra Tech pursuant to its contractual terms and legal requirements. EPA evaluates all
conflicts of interest on a site-specific basis. In 2009, Tetra Tech initially confirmed that there
was no conflict of interest in supporting EPA on the Newmark Site. This was again confirmed in
2011 and 2015. EPA confirmed that Tetra Tech had never worked for the Department of the
Army on the Newmark Site, and Tetra Tech has worked exclusively as EPA's environmental
contractor on the Site.
SBMWD attached in Appendix Ato its cover letter listing Tetra Tech press releases announcing
awards of contracts with the Department of the Army. Tetra Tech has provided diverse
consulting services to the Department of the Army for more than two decades. None of the
contract awards listed have involved, or will involve, services to the Department of the Army
associated with the Newmark Site.
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Attachment A
EPA's Responses to San Bernardino Municipal Water Department's Letter
Dated October 13, 2023
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Attachment A
EPA's Responses to San Bernardino Municipal Water Department's Letter
Dated October 13, 2023
Final Remedial Investigation/Focused Feasibility Study
Newmark Groundwater Contamination Superfund Site
San Bernardino, California
1.0 INTRODUCTION
This document provides responses to the San Bernardino Municipal Water Department's
(SBMWD) October 13, 2023 review comments of the Final Remedial Investigation/Focused
Feasibility Study (RI/FFS) for the Newmark Groundwater Contamination Superfund Site (dated
August 9, 2023); entitled Exhibit 1 Table 1, SBMWD's Comments on the Source OU RI/FFS.
The document includes EPA's:
• General response to SBMWD's Comment 2 in Exhibit 1, Table 1; and
• Specific responses to each of SBMWD's comments in Table A.l, a response-to-comment
matrix developed based on SBMWD's Exhibit 1, Table 1; attached to this document.
Certain of EPA's specific responses in Table A.l refer back to EPA's general response to
SBMWD's Comment 2 as foundational support for the responses.
2.0 OVERVIEW OF SBMWD COMMENT #2
SBMWD Comment 2 incorrectly suggests that the discussions of geology, hydrogeology, and the
nature and extent of contamination presented in the RI/FFS are in conflict with, or ignore the
content of, the hydrogeologic findings and interpretations of a previous site investigation
report on the hydrogeology of the Northwest Area of the Source Operable Unit (OU) (URS
2008)4, specifically, with respect to the potential presence of geologic faults in the Northwest
Area and the effect such faults would have on being barriers to groundwater flow.
Comment 2 further states that: "The hydraulic barrier effects of faulting are dismissed in the
RI/FFS without proper justification, in support of a more simplistic conceptual model where it
is surmised that there is no effects of faulting on groundwater flow within the Source OU, and
therefore, water level data are contoured across the faults with no consideration of the flow
barrier effects across these hydraulic features." This issue, which SBMWD terms the "barrier
effect," was also the subject of SBMWD's review Comments 7, 22, 50 through 54, and 59.
3.0 EPA'S RESPONSE TO SBMWD COMMENT #2
The RI/FFS presents an independent assessment of hydrogeologic conditions in the Northwest
Area based on reviewing historical site reports and the results of 3-dimensional data
visualization and analysis (3DVA)-based remedy progress monitoring performed for the site
(based on data from 1997 through October 2022). Accordingly, the interpretations of site
conditions in the RI/FFS do not exactly replicate those presented by URS (2008). However, site
descriptions in the RI/FFS actually have more in common with the URS (2008) document than is
4 URS 2008. Source OU Interim Remedial Action Hydrogeological Investigation Report. August 26.
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evident in SBMWD's comment.
The RI/FFS does not use the terms "barrier" or "barrier effect." These terms, which were
introduced by EMCOM (1995) and URS (2008), suggest a structure is present that significantly
impedes or prevents groundwater flow in both directions; however, there is no confirming
evidence that such a structure exists. Furthermore, the term "barrier," as it is used in the Site
Assessment Report (SAR) (EMCON 1995) implies the "barrier" does not interfere with the flow
of groundwater, as demonstrated by the following excerpt from the SAR (bold added for
emphasis):
"The northwest trending fault zone that transects the northeastern WMU
appears to be acting as a groundwater "barrier,"juxtaposing the Pelona Schist
against alluvial sediments. During periods of drought, a steepened south to
southeasterly directed gradient may be created allowing increased flow from the
impacted groundwater of the schist into the alluvial aquifer."
Both EMCON (1995) and URS (2008) also address the juxtaposition of two different geologic
materials at the fault boundary. The RI/FFS agrees that different geologic materials may be in
contact at the inferred fault boundary; specifically, Pelona schist in the upthrown block
juxtaposed against alluvium in the downthrown block. However, the RI/FFS acknowledges that,
in this case, groundwater flow is moving from a material (bedrock) that has a relatively low
hydraulic conductivity (K) to a material (alluvium) with a relatively high K. It follows that the
higher conductivity receiving material (alluvium) will not create a "barrier" to groundwater flow
discharging from adjacent, upgradient bedrock.
Previous reports present the sharp change in the elevation of the Pelona Schist bedrock surface
as the primary indication that one or more faults are present in this area. The RI/FFS concurs
with this possibility; however, it also points out that a steep erosional escarpment could
account for the sharp change in the elevation of the bedrock surface, as described in Section
3.1, which further addresses evidence of potential faults. Section 3.2 addresses the influence of
potential faults.
3.1 Evidence of Faults in the Northwest Area
As indicated in the following paragraphs, SBMWD's interpretations do not accurately reflect
what the URS (2008) document states about the potential presence of faults and their little to
no likely impact on groundwater flow.
Section 7.1.3 (RI/FFS pages 43-44). The RI/FFS specifically states: "Previous investigations have
posited that several additional northwest-striking faults, subparallel to the San Andreas Fault
system are present in the Northwest Area;" it then summarizes the main findings of a previous
seismic study (EMCON 1995), including the possible evidence for faulting in the Northwest
Area, based on the observed offset in the bedrock surface elevation at closely-spaced
boreholes.
Similarly, URS (2008) was not conclusive in confirming the presence of faults. The "interpreted
locations of the inferred faults (or fault zones) and corresponding fault blocks" were described
as being derived from a combination of information sources, including variations in the
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structural top of the schist, data previously collected and interpreted by others, and similarities
in the hydrographs of the groups of wells that correspond to the fault blocks. The structural top
of the schist is equivalent to the bedrock surface, which the RI/FFS states was "also possible
that the abrupt change in the bedrock surface is simply a buried erosional escarpment,
unrelated to faulting." This interpretation is based on a desktop analysis performed in support
of RI/FFS development; this evaluation showed that faulting was not required to produce the
bedrock slope; rather, surface erosion could have formed an erosional escarpment. Cross-
section A-A' from the Hydrogeologic Investigation Report (Figure 4-1 from URS [2008]),
reproduced below as Figure A.l, shows the results of this analysis. This figure has been
incorporated into the Revised Final RI/FFS as Figure 7.2B.
Section 7.1.6 (RI/FFS: pages 46-47). The RI/FFS describes possible faulting in the Northwest
Area based on the analysis of hydrographs and horizontal hydraulic gradients. The revised
conceptual site model (CSM) indicates that the steep hydraulic gradient in the Verdemont Hills
area may be caused by a fault or possibly by an erosional escarpment, and in either case,
represents a discontinuity in the potentiometric surface. This is supported in the RI/FFS by a
comparison of the hydraulic gradient calculated when all three wells in the analysis are located
within Fault Block A (0.06 to 0.07 feet per foot [ft/ft]), versus hydraulic gradients calculated
when the third well is located on the downgradient side of Inferred Fault A (0.30 ft/ft). URS
(2008) arrived at essentially the same conclusion, however, the URS report used the term
"segregation" to describe the observed effects, such as the discontinuity in the potentiometric
surfaces on Figures 3-4 and 3-5 of the URS (2008) report.
Section 7.2.4 (RI/FFS: pages 51-53). The RI/FFS evaluated observed trends in precipitation,
groundwater elevations, and PCE concentrations in groundwater at two monitoring wells (CJ-16
and CJ-17) that straddle the inferred fault zone. The RI/FFS concluded there is evidence of
hydraulic separation at the inferred fault boundary. This is attributed to different sources of
recharge: the bedrock block (Fault Block A) receives recharge from infiltration to the exposed
bedrock in the Verdemont Hills and from Cable Creek, while the alluvial block (Fault Block B)
receives recharge from Cajon Wash, which drains a much larger area than Cable Creek. A similar
conclusion is made in the URS (2008) report, "a major effect of this fault block segregation
appears to be that the alluvial groundwater beneath the Cajon Landfill is most affected by
recharge from the larger drainage basins to the northwest (e.g., Cajon Wash), while bedrock
groundwater beneath Camp Ono appears to be most affected by recharge from the smaller
basins of the San Bernardino Mountains to the north (e.g., Cable Creek)."
3.2 Influence of Potential Faults on Groundwater Flow
Section 7.1.3 (RI/FFS page 44). The RI/FFS includes, but the SBMWD comment does not
consider, the conclusions of (1) the seismic study, which states that "there is no compelling
evidence in the data that the faults act as significant groundwater dams." (EMCON 1995); and
(2) the Review of Fault/Ground Water Barrier Beneath Cajon Landfill report (SAIC 2001), which
indicates that even during decreased groundwater elevation conditions, groundwater in the
weathered bedrock at monitoring well G-10 may still reach the adjacent alluvial aquifer by
flowing across the fault trace/alluvium contact.
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While the RI/FFS includes Inferred Fault A, it intentionally does not incorporate aspects of URS'
(2008) hydrogeologic interpretation that are speculative or misleading. For example, paragraph
2 of Section 4.1 (URS 2008) states, "Groundwater flow is apparently restricted wherever a
fault has juxtaposed bedrock (or colluvium) against alluvium." This statement might be true
were groundwater flowing from alluvium, in a down-dropped block, towards lower-
permeability bedrock, in an upthrown block. However, in the Northwest Area, the reverse
structural relationship is true and there is no barrier to flow, as discussed in Section 3.0 above.
Newmark Groundwater Contamination Superfund Site
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Figure A.l- Geologic Cross-Section Showing How Bedrock Surface Could Represent Faulting or an Erosional Escarpment
Cajon Landfill
Bedrock surface based on Spectrum
Geophysical survey (April 1990)
Fault Block B
Potential Erosional Escarpment
Bedrock Surface
A"
Qa
Mzp
Quaternary Alluvium
Quaternary Colluvium
Pelona Schist
I Groundwater Elevation - Fall 2006
I Groundwater Elevation - Spring 200C
SCALE IN FEET
VERTICAL EXAGGERATION = 2X
Figure 3-6.
Newmark Source OU
Generalized Geologic Cross Section A - A*
Downgradient of Cajon Landfill
with Groundwater Elevation Data
from Spring 2000 and Fall 2006
Modified from: URS 2008
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The text in Section 4.2.1 of the EMCON (1995) report suggests that faults "...act as barriers that
have historically separated the alluvial aquifer or separated the alluvial aquifer from
bedrock." However, the EMCON (1995) report subsequently states: "...the faults do not
generally appear to act as a barrier to groundwater flow between juxtaposed alluvial
deposits, as evidenced by similar water levels at CJ-3 and CJ-6 once groundwater has risen to
the point that younger alluvial deposits on either side of the faults are saturated."
Furthermore, if the "barrier effect" did exist in the manner with which SBMWD asserts, by
preventing groundwater flow from Fault Block A (wells G-10 and G-17) to Fault Block B' (wells
CJ-6 and CJ-16), it would serve to provide even greater isolation from the downgradient points
of exposure than is currently envisioned in the RI/FFS.
It is more appropriate to refer Inferred Faults A and B as "boundaries" rather than "barriers,"
with respect to groundwater flow. They do represent discontinuities in the potentiometric
surface, but not physical barriers that significantly restrict flow from the upgradient to
downgradient sides of the inferred fault traces.
4.0 SUMMARY
The RI/FFS provides the most plausible explanation for the current extent of groundwater
contamination in the Northwest Area, given the existing data set. Because of the nature of
groundwater flow and contaminant transport in a fractured bedrock setting, uncertainty
remains in some aspects of the nature and extent of contamination in the Northwest Area.
However, the RI/FFS demonstrates that groundwater flows from the upgradient to
downgradient sides of the inferred faults and that the remediation goal of 5 micrograms per
liter (|-ig/L) Safe Drinking Water Act (SDWA) Maximum Contaminant Level (MCL) has been met
for both tetrachloroethene (PCE) and trichloroethene (TCE) in groundwater in all but two of the
more than 140 groundwater monitoring or extraction wells throughout the Source Operable
Unit (OU).
Lastly, the RI/FFS demonstrates that the residual PCE groundwater contamination that remains
in the bedrock in the Northwest Area is no longer acting as a source of contamination impacting
the downgradient points of exposure in the Newmark and Muscoy OUs. Thus, if the inferred
faults did act as barriers to groundwater flow as SBMWD asserts, they would actually serve to
provide greater isolation of contamination with respect to the downgradient points of
exposure.
5.0 REFERENCES
EMCON. 1995. Cajon Landfill Site Assessment Report, Evaluation Monitoring Program. August.
Science Applications International Corporation (SAIC). 2001. Review of Fault/Ground Water
Barrier Beneath Cajon Landfill - Addendum to March 27, 2001 Memorandum. July 2.
URS Group, Inc. (URS). 2008. Hydrologic Investigation Report, Revised Draft. August.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Table A-l
EPA RESPONSES TO
SAN BERNARDINO MUNICIPAL WATER DEPARTMENT COMMENTS [EXHIBIT 1 TABLE 1]
FINAL REMEDIAL INVESTIGATION/FOCUSED FEASIBILITY STUDY
NEWMARK GROUNDWATER CONTAMINATION SUPERFUND SITE
SOURCE OPERABLE UNIT
Comment
No.
Topic
Comment
EPA Region 9 Responses
General Comments
1
RI/FFS
These comments presented in these tables are for the technical document (i.e., the Source OU RI/FFS) that form the technical basis for the EPA
Proposed Final Cleanup Plan for the Source OU , dated August 14, 2023. The Source OU RI/FFS for the Source Operable Unit was published as a Final
Report on August 9, 2023, without allowing SBMWD an opportunity to comment on a draft version of the document. As the operator of the Newmark
OU and Muscoy OU RA systems, which are encompassed by the current boundaries of the Source OU, information presented in the RI/FFS is of key
importance to SBMWD. The City is not the responsible party for the Newmark Groundwater Contamination Superfund Site (NGCSS), but is responsible
for serving untainted groundwater to their 206,000 municipal customers from an aquifer system that was impacted by the US Army's activities at the
Camp Ono army base. The City is a major contributor to the success of the NGCSS RAs and thus should have been afforded the opportunity to
comment on the Source OU RI/FFS in draft form. Many of the comments raised below could have been addressed prior to finalizing the RI/FFS
document. As this opportunity was not afforded to the City, we are forced to provide our comments on the RI/FFS in Public Comments on the EPA
Proposed Final Cleanup Plan for the Source OU, and to have these comments entered into the public record. These comments will also be published in
the Second Semi-Annual 2023 Progress Report to be submitted by March 1, 2023. We look forward to EPA's public responses to these comments.
Comment noted.
2
Rl
The Rl largely ignores the previous hydrogeological investigation study performed by URS, under contract to EPA, as reported in the URS document
titled Source OU Interim Remedial Action Hydrogeological Investigation Report, dated August 26, 2008. This report included key hydrogeological
interpretations of lithology, water level and contaminant data for the Northwest Area of the Source OU that is the main subject of the Source OU
RI/FFS and EPA's associated Proposed Final Cleanup Plan for the Source OU . The URS document is only referenced twice in the RI/FFS document and
without reviewing or considering the URS interpretations. The RI/FFS references to the URS Report are as follows:
1) Section 6.1.6, page 46 - "Figure 7.6 provides hydrographs for groundwater elevations measured in monitoring wells located upgradient (MW-142, CJ-
10 and CJ-17) and downgradient (CJ-3, CJ-6 and CJ-16) of inferred Fault "Athe approximate location of Fault "A" was shown in several earlier
documents (URS 2008a) and is depicted on Figure 7.3."
2) Section 7.2.3, page 50 - "The Cajon Landfill investigations (EMCON1995, URS 2008a) encompassed the parts of the basin surrounding the landfill,
including the Verdemont Hills. Wells installed for these investigations have a "CJ" prefix."
The URS hydrogeologic interpretations include the hydraulic barrier effects of Fault A and B, which appear to hydraulically separate opposing sides of
the faults (Fault A full time and Fault B during low groundwater periods). The hydraulic barrier effects of faulting are dismissed in the RI/FFS without
proper justification, in support of a more simplistic conceptual model where it is surmised that there is no effects of faulting on groundwater flow
within the Source OU, and therefore, water level data are contoured across the faults with no consideration of the flow barrier effects across these
hydraulic features. Subsequently, flow path analyses are presented showing flow lines through the perceived faults with no effects on flow direction.
This is in direct contradiction to the interpretations presented in the water level contour maps for Spring 2000 and Fall 2006, as presented in URS
Figures 3.4 and 3.5. Simplistic contaminant transport modeling performed for the Source OU and presented in Section 7.4 of the RI/FFS also ignored
the effects of Fault A and B on groundwater flow and are therefore questionable.
Specific comments with respect to the hydraulic barrier effects of the forementioned faults and flow path analysis are provided in Comments 22, and
50 through 55.
To support comprehensive responses to Comments 22, and 50 through 55, a
General Response to Comment 2 is provided prior to this response-to-
comment matrix.
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San Bernardino, California EPA Region 9
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Specific Comments
1
1.0 and
Figure 1.1
1/9
In 1993 and 1994, EPA designated the
Newmark and Muscoy plume areas as
the Newmark OU (EPA 1993a) and
Muscoy OU (EPA 1994) and defined an
area encompassing both OUs as the
Source OU (Figure 1.1).
The Source OU boundary originally did not include the Newmark or Muscoy OU. It was
limited to the area northwest of the Newmark OU and Muscoy OU. The boundary was
redrawn by EPA sometime after August 2008 based on examination of Figure 1-1 of the
Source OU Interim Remedial Action Hydrogeological Investigation Report (prepared by URS
and dated August 26, 2008). The first portrayal of the current Source OU boundary appears
to be shown in Figure 1 of the EPA First 5-Year Review Report for the Newmark Groundwater
Contamination Superfund Site, dated September 25, 2008. This figure was created by the
EPA by altering a SECOR (now Stantec) figure previously submitted as part of the Draft
Operational Sampling and Analysis Plan without obtaining permission or noting the EPA
alterations to the SECOR figure.
The text was modified as follows as shown in bold, italic, underline text
below:
"In 1993 and 1994, EPA designated the Newmark and Muscoy plume
areas as the Newmark OU (EPA 1993a) and Muscoy OU (EPA 1994);
respectively.. and EPA later defined an area encomoassina both OUs as
the Source OU (Figure 1.1).
EPA acknowledges the original source of the figure used to create Figure
1.1 was not indicated on the figure. The figure was modified to include
the full reference for the original source of the figure: Stantec Consulting,
Inc. (Stantec) 2009. Operational Sampling and Analysis Plan. Newmark
and Muscoy Operable Unit. Interim Remedial Actions. Newmark
Groundwater Contamination Superfund Site, California. October.
2
1.0
2/2
As also shown on Figure 1.3, based on
additional RI/FS results, an interim P&T
remedy was installed in 2005 at the
leading edge of the Muscoy plume (19th
Street North Treatment System
Extraction Wells).
The Muscoy OU extraction wells were installed upgradient of the leading edge of the Muscoy
OU Plume, as evidenced by the installation and sampling of the downgradient monitoring
wells, several of which were suspended from meeting contaminant performance criteria due
to pre-existing PCE contamination conditions.
The text was modified to indicate that the extraction wells were installed
upgradient of the leading edge of the Muscoy plume.
3
1.0
2/2
Fourteen (14) extraction wells associated
with these treatment systems are
considered Extremely Impaired Sources
(EIS) pursuant to the State of California
Department of Public Health Drinking
Water Division Policy Memo 97-005 and
the 2015 Record of Decision (ROD)
because the treated groundwater serves
as public water supply for the city.
It should be recognized that the 14 extraction wells are considered EIS both under Policy
Memo 97- 005 and by the 2015 ROD, requires PCE treatment to the laboratory method
reporting limit (MRL), which is currently 0.5 mg/L, per the terms of the City's Water Supply
Permit.
The text was modified as follows:
"Per the Citv's Water Supplv Permit 03-13-99P-002. PCE in aroundwater
extracted from the 14 ElS-desianated wells must be treated to a
performance standard of 0.5 microarams per liter (ua/L)."
4
1.0
2/3
Groundwater data generated during the
original Newmark and Muscoy plume
investigations led investigators to believe
that that both plumes originated from a
light industrial/commercial area located
northwest of Shandin Hills (EPA 1993a).
The area, then referred to as the
Northwest Source Area, occupied
approximately the northwestern third of
the Source OU (Figure 1.1).
The Northwest Source Area term appears to have been first used in 2008, not 1993.
The text was modified as follows:
"The area, encompassina all three potential sources, was then
subseauentlv referred to as the Northwest Source Area, occupied
approximately the northwestern third of the Source OU (Figure 1.1)."
5
1.3,
Table 1.1
5
Sean McCarthy, Eric Zuniga, Andre
Aguirre designated as part of the
RWQCB.
The named staff are all part of the State Water Resources Control Board (SWRCB) Division of
Drinking Water (DDW) which is not part of the RWQCB. Mr. Aguirre's first name is Andres.
Table 1.1 and associated notes were modified to correct the indicated
errors.
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San Bernardino, California EPA Region 9
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2.4
7/2
EPA has supported the development of
the NGFM, which has been subjected to
peer review; including in 2012 by the
1997 - 2012 3DVA project team with
respect to advising the NGFM team of
3DVA-derived information on alluvial
lithology, resulting in the modification of
the NGFM to include additional geologic
layers to better represent heterogeneity
in the model's geologic framework.
a) The EPA has been very supportive in the development of the NGFM (more recently
referred to as the SBBA Model). However, the notion included in RI/FFS that the 2012
3DVA work influenced the modification of the NGFM is incorrect. In fact, the 2012 3DVA
work is substantially based on Stantec's interpretation of borehole and geophysical data
used to develop the lithologic model that was, in turn used as the basis for refining
model layer elevations and model aquifer properties of the NGFM. This notion is
supported by the following excerpt from the EPA report documenting the 2012 3DVA
work titled Final Technical Memorandum Source Identification, Plume Delineation,
Restoration Timeframe Estimation and Transition from Interim to Final Remedy, dated
May 19, 2014. The excerpt from Section 5.4 Geologic Data is as follows:
"One hundred and twenty-nine boring logs were used to construct the lithology and related
components (for example, relative hydraulic conductivity [KR]) of the Source OU
visualizations. Figure 5.2 shows the spatial distribution of these logs. Their complete listing,
with location coordinates, is included as Table 5.2. Site lithology (unconsolidated soils) was
derived from the boring log information available from the EarthVision model previously
developed for the NGFM constructed for the site area (Stantec 2008). Stantec furnished an
MS Access database with classifications for each of the 129 boring logs."
Groundwater flow model layering was established during the refinement of the USGS Basin
Model into the NGFM/RBFM, at which point the model was transitioned from 2 layers to 5
layers based on the EarthVision model referred to in the excerpt above. During the most
recent model update for the NGFM/RBFM, which is now referred to as the SBBA Model, the
5 layer model structure was preserved, and the layer top and bottom elevations and
associated aquifer properties were updated based on refinements to the EarthVision model,
which now uses Petrel as the main modeling platform. The model update and associated
revisions are provided in the report titled San Bernardino Basin Area Groundwater Flow
Model Update Report (SBBA Model Update Report), prepared by Stantec and dated
September 11, 2023 (Stantec, 2023b).
Refinements to the lithologic model were performed based on peer review comments
provided by Balleau Groundwater, Inc. (Balleau) and discussed in length with the Modeling
Technical Advisory Committee (MTAC), consisting of representative from SBMWD, Valley
District, USGS, Stantec, Geoscience Support Services, Inc (Geoscience), Numerical Solutions
Inc (NSI), Balleau and Wildermuth Environmental Inc (WEI). The 3DVA work was not
considered during these updates, as the lithologic basis of the 3DVA work originated from
the work performed on the NGFM.
We recognize that the SBBA Model Update Report was not available at the time of the
preparation of the RI/FFS. We are merely attempting to clarify the basis of the SBBA Model
Update.
a) The text has been revised as follows:
"Extensive reviews and documentation of the regional geology and
hydrogeology was produced during the development of the Newmark
Groundwater Flow Model (NGFM) (Stantec 2008a; Geoscience 2009),
which the San Bernardino Valley Water Conservation District
(SBVWCD) uses to evaluate basin-wide management strategies. EPA
has supported the development of the NGFM.", which has boon
subjected to peer review; including in 2012 by the 1997—2012
3DVA project team with respect to advising the NGFM. team of
3DVA derived information on alluvial lithology, resulting in the
modification of the NGFM to include additional geologic layers to
better represent heterogeneity in the model's geologic framework
EPA acknowledges that the lithologic data used in the 2012 3DVA effort
(and all subsequent 3DVA updates) was provided by Stantec. This
was done on purpose to provide the maximum alignment of the
3DVA and the NGFM.
b) Comment noted.
7
2.4
7/5 and
Figure 2-7
In addition, the only identified faults that
could potentially affect groundwater flow
are outside the Source OU boundaries.
The Loma Linda Fault is partially within the Source OU, does effect groundwater flow, and is
represented in the NGFM or SBBA Model. The partial groundwater barrier effect of the Loma
Linda Fault appears to increase with depth within the southwestern portion of the Source
The text was updated to cite the 2008 reference to the NGFM.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
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Region 5 START V Contract: Document Tracking Number 2216a
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Faults, therefore, were not represented
in the 3DVA of the Source OU. Within the
Source OU boundary, this approach to
handling faults is consistent with the
lithologic interpretation used to develop
the NGFM.
OU. In addition, the 2008 URS Report titled Hydrogeological Investigation Report Newmark
Groundwater Contamination Superfund Site Operable Unit Interim Actions (URS, 2008a)
shows a significant groundwater barrier effect of the Fault A in the Northwest Area that
should not be ignored in the 3DVA work (see General Response Comment 2 and Specific
Comments 22, 50 through 55 for additional input) as it appears to significantly affect
groundwater flow as interpreted in URS, 2008a. The barrier effect in the Northwest Area can
clearly be identified on the water level contours shown in Figure 2.7, where water levels
differences of more than 100 feet are observed between a narrow cluster of wells.
EPA acknowledges that the Loma Linda Fault is represented in the SBBA
model (Stantec 2023) (which is presently under EPA review); although the
fault is located to the southwest of the Northwest Area of the Source OU.
However, Figure 6-5 of the SBBA model update report does not show that
any faults were incorporated into the portion of the model that includes
the Northwest Area of the Source OU.
See General Response to Comment 2 with respect to inclusion of faults in
the 3DVA effort.
8
2.5
8/2
The alluvial aquifer at the Newmark site
is understood to be hydraulically
connected to the Pelona Schist bedrock;
therefore, for the 3DVA effort, the
alluvium and bedrock were assumed to
behave as one aquifer system.
This is an unsupported assumption used to simplify the site conceptual model, thereby
simplifying the constraints on the 3DVA visualizations. Although there is interaction between
the bedrock aquifer and adjacent alluvial aquifer, this interaction is complex, affected by the
presence and displacement along faults, and in many areas of the NGCSS, has not been
investigated. The issue with the "one aquifer system" simplifying assumption is very
apparent in the visualization presented for Figures 3-1, 3-2, and 3-4, where PCE
contaminated groundwater from the alluvial aquifer system is interpreted to flow through
the Pelona Schist in the Shandin Hills (see comment 12) without identification of any wells or
associated PCE sample results from the Shandin Hills that supports this interpretation.
Re: "PCE contaminated groundwater from the alluvial aquifer system is
interpreted to flow through the Pelona Schist in the Shandin Hills."
The plume is not interpreted to flow through the Pelona Schist in the
Shandin Hills. Figure 3.3 illustrates the location and causes of bifurcation
of the PCE plume upgradient of Shandin Hills, wherein the Newmark and
Muscoy lobes of the plume flow around the hills. Due to figure
transparency settings, and viewing angle, the plume visualizations in
Figures 3-1, 3-2, and 3-3 appear to be flowing through the Shandin Hills;
however, this appearance is an artifact of the viewing angle and
visualization transparency.
See General Response to Comment 2 with respect to inclusion of faults in
the 3DVA effort.
9
2.9
12/1
As 1,1-Dichloroethane (1,1-DCA), cis-1,2-
Dichloroethene (cis-l,2-DCE), and trans-
1,2-Dichloroethene (trans-1,2-DCE) are
breakdown products of PCE and TCE,
they were not considered primary COCs.
1,1-DCA is not a degradation product of PCE or TCE.
The text and List of Acronyms and Abbreviations were revised to indicate:
"1,1-Dichloroethene (1,1-DCE)."
10
3
13
3.0 Remedial History of Source OU
The section title is misleading. With respect to items 1 and 2 of paragraph 2 this is a remedial
investigation history rather than a remedial history as no remediation has been performed in
the Northwest Area of the Source OU.
The section title was changed to: "Remedial Progress Monitoring of
Source OU."
The 2nd and 3rd sentences were deleted as they referred to work
performed before remedial progress monitoring efforts.
11
3
13/3
Because the Source OU encompasses the
footprints of both the Newmark and
Muscoy OUs, all of the data generated
during the Rl and IRA efforts for the
Newmark and Muscoy OUs were
It should be noted that the data generated during the Remedial Action or RA was also
included, as the Interim Remedial Action or IRA, was declared the Final RA in the 2015 Final
ROD for the Newmark OU and Muscoy OU.
The text in the paragraph following was modified as follows:
"The results of the original 3DVA evaluation provided the basis for EPA to_
transition the containment interim remedies in place as the final
restoration remedy for the site and to issuemtt a Final ROD for the
Newmark and Muscoy OUs." The text and List of Acronyms and
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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determined to be directly applicable to
the Source OU.
Abbreviations was revised to include "RA Remedial Action." A citation for
the 2014 Technical Memorandum (Tetra Tech 2014) was also added, as it
served as the documentation of efforts to demonstrate the performance
of the interim remedies.
12
3.1
Figures 3-1,
3-2 and 3-4
PCE plume extending through the
crystalline bedrock beneath of the
Shandin Hills bedrock outcrop.
There appears to be a fundamental flaw in the site conceptual model in these portrayals of
the plume. No wells are located within the Shandin Hills bedrock outcrop to support this
interpretation. Previous interpretations by others, including Stantec, support a site
conceptual model whereby significant accumulation of PCE within the Shandin Hills is
unlikely due to limited interconnectivity and cross communication between the alluvial
aquifer and bedrock. As portrayed in the referenced figures, the bedrock could provide a
long-term residual low level source of PCE to the Muscoy OU alluvial fill
aquifer in the future, which is likely not the case.
As indicated in Response to Comment 8, the plume is not interpreted to
flow through the Pelona Schist in the Shandin Hills. Figure 3.3 illustrates
the location and causes of bifurcation of the PCE plume upgradient of
Shandin Hills, wherein the Newmark and Muscoy lobes of the plume flow
around the hills. Due to figure transparency settings, and viewing angle,
the plume visualizations in Figures 3-1, 3-2, and 3-3 appear to be flowing
through the Shandin Hills; however, this appearance is an artifact of the
viewing angle and visualization transparency.
13
3.1
14/bullet 2
As shown in Figure 3.4, the size and mass
of the overall PCE plume decreased with
time, resulting in a significant decrease in
the potential for the then Northwest
Source Area plume to deliver mass to the
Newmark/Muscoy plumes. This was
evidenced by PCE in groundwater in
concentrations at and above 5 ng/L
decreasing from a mass of approximately
9,000 pounds (lbs) in 1997 to a mass of
approximately 820 lbs in 2012, an
approximate mass reduction of 90
percent.
This statement with respect to the PCE mass statement is misleading and implies there was a
PCE mass reduction of 8,180 lbs between 1997 and 2012. It should be noted that much of
the 90% of mass, inferred to no longer exist, is not a mass reduction but instead is still
present in the groundwater system at concentrations below 5 mg/L. Accounting for the mass
remaining between 0.5 and 5 mg/L would be a more transparent way of describing changes
in PCE mass, and estimating true mass remaining (see Comment 17 for additional insight).
As shown in Figure 3.4, and indicated in the response to Comment 3, the
plume visualization is of PCE at concentrations at and above the Federal
Drinking Water MCL of 5.0 mg/L, the remediation goal for the Source OU.
Estimates of mass remaining between 0.5 and 5 mg/L relate to the 14 EIS
wells only; which although acknowledged in the RI/FFS, are regulated in
the 2015 ROD for the Newmark and Muscoy OUs.
The text was modified as follows:
"• As shown in Figure 3.4, the size and mass of the overall PCE plume
decreased with time, resulting in a significant decrease in the potential for
the then Northwest Source Area plume to deliver mass to the
Newmark/Muscoy plumes. This was evidenced by PCE in groundwater in
concentrations at and above the 5 ua/L MCL decreasina from a mass of
approximately 9,000 pounds (lbs) in 1997 to a mass of approximately 820
lbs in 2012, an approximate mass reduction of 90 percent".
14
3.1
14/bullet 3
Existing data indicated no active sources
that would result in an increase in the
concentration or size of the present
Muscoy/Newmark plumes; specifically,
there was no evidence of a continuing
source emanating from the Northwest
Source Area. Groundwater from one
monitoring well (CJ-10) in the Northwest
Source Area continued to have relatively
consistent PCE concentrations, generally
ranging from 30 and 50 ng/L.
If CJ 010 is believed to be where PCE accumulated from a nearby source discharge at or near
the ground surface, then the elevated concentrations should be considered residual or
secondary source to the adjacent alluvial aquifer. It is agreed that these source residuals do
not present a significant threat to the Newmark or Muscoy plumes, as the concentrations
are relatively low, and the rate of transfer to the alluvial aquifer is also likely low as
evidenced by the accumulation of PCE in the bedrock behind the Fault A (URS, 2008a).
EPA agrees with the comment and advises that residual sourcing is
addressed as a key finding in the RI/FFS in the Executive Summary: Key
Findings from Additional Evaluation of the Northwest Area -
"Contaminant concentrations at monitoring wells CJ-10 and CJ-17 appear
to be representative of current residual source areas, from or within the
area of, the former steel mill and/or former Camp Ono hospital,
respectively."
Residual sourcing is also addressed in:
• Section 7.2.4 Plume Development and Current Conditions
• Section 7.4 Contaminant Transport Modeling
• Section 7.5 Summary of Key Findings
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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• Section 9.4 Evaluation of the Northwest Area of the Source Operable
Unit
15
3.1
14/bullet 6
The existing interim remedies appeared
to be (1) effective at containing and
restoring the PCE plume and (2)
adequate to reach the site remedial goal
of 5 ng/L PCE in groundwater (with the
exception of the remedial goal of 0.5
Hg/L PCE for ElS-designated wells) within
the following estimated times at the
three treatment facilities: 19th Street
North - 4 years; Newmark - 17 years;
and Waterman - 9 years. Estimations
were derived using mass results from the
3DVA for each treatment area combined
with historical monthly PCE removal data
from the three interim treatment
systems.
The method used to estimate cleanup time for the 2012 3DVA study is fundamentally
flawed. Comparing the PCE mass remaining estimates for areas above 5.0 mg/L to treatment
plant PCE/TCE influent mass removal trends that are based on influent concentrations down
to 0.5 mg/L is misleading. Application of this method would be much more appropriate if
PCE mass remaining estimates were also based on concentrations down to 0.5 mg/l. SBMWD
has prepared PCE mass remaining estimates down to 0.5 mg/L for a portion of the NGCSS
(see Comment 17).
The text was corrected to indicate the method used to estimate mass
removal performed for the 1997-2012 period. Specifically, that the total
treatment system monthly production (volume of water extracted), in
acre-feet, and the total pounds of PCE/TCE removed for each month of
production from March 2005 through December 2012 for each treatment
system were used to evaluate contaminant removal efficiency and
estimate the remaining time to achieve restoration.
16
3.1
Figures 3-1, 3-
2
and 3-4, 3.5
and 3.6
Location of wells used to support PCE
plume volumetric analysis.
None of the PCE plume maps portrayed in these figures, which show the inferred extents of
PCE in groundwater above 5 mg/L at various times, includes identification of the well
locations and PCE sample results used to support this analysis. Without identification of the
location and reported PCE concentrations, it is not possible to understand the underlying
data distribution and assess the areas of uncertainty where data supporting the plume
interpretations are lacking.
The identification of the well locations and PCE sample results used to
support the 1999-2012 3DVA are provided in the 2014 Technical
Memorandum (Tetra Tech 2014); particularly, Table 5.3 Groundwater
Level Observation Wells and Table 5.5 Master Well List Generated from
Newmark Master Well and Chemistry Database. These are depicted on
Figure 5.3 Locations of Groundwater Level Observation Wells Used to
Construct the Visualizations and Figure 5.4 Locations of Groundwater
Monitoring Wells Used to Construct the Visualizations.
The well locations and PCE sample results used to support the 2022 3DVA
effort are identified on RI/FFS Figure 4.2 Wells Used for Contaminant
Chemistry Visualizations: October 2022.
A new Figure 6.1 Locations of Wells Used for Statistical Trend Analyses,
was developed and incorporated into the revised RI/FFS. This figure shows
all groundwater monitoring and observation wells, extraction wells,
companion piezometers to extraction wells, and production wells with
sufficient historical PCE and TCE analytical data used to generate the time
versus PCE concentration plots.
17
3.1, 3.2
3.3 and
5.2
Figures 3.1,
3.2
and 3.4, 3.5,
3.6,
3.7, 5.1, 5.2
and 5.3
Limiting PCE mas remaining estimates to
plume areas above 0.5 mg/L.
a) The PCE mass remaining estimates presented in this report are limited to the
estimation of mass above 5 mg/L. Given recognition in this report that the 14
extraction wells operated as part of the NGCSS RAs are considered Extremely
Impaired Sources (EIS), and the 14 wells are subjected to State Water Resources
Control Board Division of Drinking Water (DDW) Water Supply Permit mandated
treatment requirements for PCE to be treated to 0.5 mg/L, consideration of the
mass remaining between 0.5 and 5 mg/L is appropriate, and would provide better
a) PCE mass estimates provided in the FFS are based on the 5 mg/L PCE
isoconcentration contour because the remediation goal for the
Northwest Area of the Source OU is the Safe Drinking Water Act MCL
of 5 mg/L. Therefore, PCE mass remaining between 0.5 mg/L and 5
mg/L is not relevant to the RI/FFS for the Source OU. Estimates of
mass remaining between 0.5 and 5 mg/L relate to the 14 EIS wells
only; although these are acknowledged in the RI/FFS, they are
regulated in the 2015 ROD for the Newmark and Muscoy OUs.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-12
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b)
d)
context for considering restoration of this drinking water source to levels no longer
requiring treatment.
These issues identified by the City have been brought to the attention of the EPA on
multiple occasions, including in a letter dated February 28, 2018, a copy of which is
provided in Exhibit 3 of the letter transmitting these comments. A copy of February
28, 2018 letter has been resent to the EPA on multiple occasions, most recently in
an email dated November 4, 2022 addressed to Sharissa Singh. EPA has yet to
address the City's request outlined in the February 28, 2018 letter.
Therefore, Stantec, on behalf of the City, has prepared annual estimates of PCE
mass remaining for the period between 2007 and 2023 and presented these
estimates in the First Semi-Annual 2023 Progress Report - Newmark OU and Muscoy
OU Remedial Action - Report No. 66, dated August 31, 2023 (Stantec, 2023a). The
PCE mass estimates are based on a 2-dimensional (2D) analysis of the PCE plume
maps presented in the progress report since 2007. The results are summarized in
Table 5-3, Figure 5-4, and Figure 5-5, and a description of the methodology used is
provided in Appendix I of the Progress Report (Stantec, 2023a). This is a fairly
simplistic approach to estimating mass that has some practical limitations identified
in the progress report, one of which is limiting the estimation of mass to the
contoured plume areas, thus not considering mass upgradient of the contoured
plumes extending all the way back to the Northwest Area of the Source OU.
To provide context on the difference in the EPA/Tetra Tech based estimates
presented in Figures 3.6 and 5.2, which limit the PCE mass estimation to areas
above 5 mg/L, and the SBMWD/Stantec PCE mass estimates utilizing 0.5 mg/L as the
lower threshold as presented Progress Report (Stantec, 2023a), the following
comparison is provided:
Year EPA/Tetra Tech PCE Mass (lbs) SBMWD/Stantec PCE Mass (lbs)
1997
9,000
NA
2007
NA
5,544
2012
820
3,669
2015
45
2,749
2019
23
2,338
2022
6.4
1,863
b) Comment Noted.
PCE mass estimates provided in the FFS are based on the 5 mg/L PCE
isoconcentration contour because the remediation goal for the
Northwest Area of the Source OU is the Safe Drinking Water Act MCL
of 5 mg/L Therefore, PCE mass remaining between 0.5 mg/L and 5
mg/L is not relevant to the RI/FFS for the Source OU. Estimates of
mass remaining between 0.5 and 5 mg/L relate to the 14 EIS wells
only; although these are acknowledged in the RI/FFS, they are
regulated in the 2015 ROD for the Newmark and Muscoy OUs.
Notwithstanding, the results of SBMWD's calculations reflect an
approximately 66% reduction in plume mass over time, which
demonstrates that the PCE plume has significantly decreased in size
(and mass) since 1997, which is a primary reason EPA selected
Alternative 2 Monitored Natural Attenuation, as the preferred
alternative.
d) See responses to Comments 3,13,15 and 17c.
17
(continued)
3.1, 3.2
3.3 and
5.2
Figures 3.1,
3.2
and 3.4, 3.5,
3.6,
3.7, 5.1, 5.2
and 5.3
This comparison demonstrates why it is important to consider PCE mass down to 0.5 mg/L
when considering how long treatment will be required.
For tracking purposes, SBMWD/Stantec will publish annual estimates of remaining PCE
mass in the progress reports using this 2D analysis method in the progress reports. In
addition, SBMWD is considering adding a more rigorous 3D-based methodology to
estimate PCE mass remaining above 0.5 mg/L that would be performed on a five-year
basis and would extend upgradient into the Northwest Area. The 3D method would
utilize the EVS software platform, the Stantec site conceptual model, along with data
Comment noted.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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and outputs generated during the development and refinement of the SBBA Model.
Additional comments with respect to the EPA/Tetra Tech plume volume estimates are
provided in Comment 42.
18
3.2
15/last
paragraph
Site-wide PCE mass, based on PCE
present in groundwater at
concentrations at and above 5 ng/L,
reduced from approximately 820 lbs in
2012 to approximately 45 lbs in 2015, an
approximate 95 percent reduction.
This statement with respect to PCE mass is misleading (see comment 13) implying a mass
decrease of 775 lbs (820 lbs to 45 lbs) between 2012 and 2015. It should be noted that much
of the 775 lbs of PCE, inferred to no longer exist, is not a mass reduction but instead is still
present in the groundwater system at concentrations below 5 mg/L.
The text has been modified as follows:
"Site-wide PCE mass, based on PCE present in groundwater at
concentrations at and above the 5 jig/L MCL, reduced from approximately
820 lbs in 2012 to approximately 45 lbs in 2015, an approximate 95
percent reduction."
Estimates of mass remaining between 0.5 mg/L and 5 mg/L relate to the
14 EIS wells only; although these are acknowledged in the RI/FFS, they are
addressed in the 2015 ROD for the Newmark and Muscoy OUs.
19
3.3
16/3
The estimated site-wide mass of PCE
remaining, based on PCE present in
groundwater at concentrations at and
above 5 ng/L, reduced from
approximately 45 lbs in 2015 to
approximately 23 lbs in 2019,
representing an approximate 49 percent
reduction.
This statement with respect to PCE mass is misleading (see comment 13) implying a mass
decrease of 27 lbs (45 lbs to 23 lbs) between 2015 and 2019. It should be noted that much of
the 27 lbs of PCE, inferred to no longer exist, is not a mass reduction but instead is still
present in the groundwater system at concentrations below 5 mg/L.
The text has been modified as follows:
"The estimated site-wide mass of PCE remaining, based on PCE present in
groundwater at concentrations at and above the 5 jig/L MCL, reduced
from approximately 45 lbs in 2015 to approximately 23 lbs in 2019,
representing an approximate 49 percent reduction."
Estimates of mass remaining between 0.5 and 5 mg/L would relate to the
14 EIS wells only; while these are acknowledged in the RI/FFS, they are
addressed in the 2015 ROD for the Newmark and Muscoy OUs.
20
3.3
16/last
paragraph
From 1997 to 2019, site-wide mass
reduced from approximately 9,000 lbs to
approximately 23 lbs, an approximate
99.7 percent reduction.
This statement with respect to PCE mass is misleading (see comment 13) implying a mass
decrease of 8,977 lbs (9,000 lbs to 23 lbs) between 1997 and 2019. It should be noted that
much of the 8,977 lbs of PCE, inferred to no longer exist, is not a mass reduction but instead
is still present in the groundwater system at concentrations below 5 mg/L.
The text has been modified as follows:
"From 1997 to 2019. site-wide mass of PCE remainina in aroundwaterat
concentrations at and above the 5 ua/L MCL reduced from approximately
9,000 lbs to approximately 23 lbs, an approximate 99.7 percent reduction.
Estimates of mass remaining between 0.5 and 5 mg/L would relate to the
14 EIS wells only; while these wells are acknowledged in the RI/FFS, they
are addressed in the 2015 ROD for the Newmark and Muscoy OUs
21
3.4
17/2
Desktop evaluations included re-
examination of historical aerial
photographs and maps to determine
which of the following were potential
sources:
•Cajon Landfill, located southwest of CJ-
10;
•Former Waste Lagoons and Levees,
located south of CJ-10;
•Former Hospital Area, located north of
CJ-10 and the Verdemont Hills;
•Former railroad spur located
a) Desktop analysis should have included historical information regarding usage, storage
and discharge/disposal of PCE/TCE and other COCs or identify the lack of information if
that is the case.
b) With respect to Camp Ono, the City has collected extensive information regarding the
Army's usage, storage and discharge of PCE at Camp Ono. None of this information
appears to have been used in this desktop analysis.
a) The text was modified as follows:
"Desktop evaluations included re- examination of historical reports,
aerial photographs and maps to determine which of the following
were potential sources:.."
The evaluations reinforced the primary findings of the Rl that that the
original source for the Newmark/Muscoy plume was from one or
more areas within the boundaries of the former Camp Ono, and that
current residual contamination sustaining the PCE plume in the
Northwest Area is either an original release from, or within the area
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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significantly northwest of CJ-10; and
•Former Steel Mill, located north of CJ-
10, but south of the Verdemont Hills.
of, a former steel mill (located south and adjacent to the Verdemont
Hills) and/or the former Camp Ono hospital (located northeast of the
Verdemont Hills). Various sections of the RI/FFS were updated to
include additional information supporting these findings.
The text was also modified to include more discussion of Camp Ono and
the activities that were conducted there, including some information
obtained from Exhibit 2 of SBMWD's cover letter, entitled: "Training
and Supply Activities at the Desert Training Center in World War II and
Their Relation to the Base General Depot at Camp Ono," William T.
Bowers (Colonel U.S. Army, Retired), June 2, 2005, describing the
history of the Desert Training Center and Camp Ono."
Detailed information regarding usage, storage, and
discharge/disposal of PCE/TCE and other COCs is not available to
evaluate.
b) This response is deferred to EPA Region 9.
22
3.4
17/4
Based on the evaluations, it was
determined that the former steel mill
appeared to be the most likely source of
PCE contamination in monitoring well CJ-
10 because the mill area was located
directly upgradient of well CJ-10, as
supported by groundwater elevation
isocontour maps and flow vector
analysis. The hospital area of former
Camp Ono was determined unlikely to be
the source based on flow vector analysis
indicating that it was not upgradient of
well CJ-10.
a) SBMWD disagrees with this conclusion regarding the former steel mill being the most
likely source.
b) The interpreted groundwater elevation contours and flow vectors ignore the
groundwater barrier effects of Fault A and B and the associated bedrock aquifer/alluvial
aquifer interaction across these faults, as presented in URS, 2008a.
a) The text was modified as follows:
"Based on the evaluations, it was determined that a release from, or
within the area of. the former steel mill appeared to be the most
likely source of PCE contamination in monitoring well CJ-10 because
the mill area was located directly upgradient of well CJ-10, as
supported bv the results of an inspection conducted bv the Countv of
San Bernardino Department of Environmental Health Services,
which identified an overturned drum marked PCE. a sump "which
was apparently used to catch waste fluids from operations" and an
associated unlined soil pit (EMCON1995); as well as groundwater
elevation isocontour maps and flow vector analysis performed as part
of3DVA efforts. The hospital area of former Camp Ono was
determined unlikelv to be the source of PCE in the CJ-10 area based
on surface and subsurface bedrock topoaraphv. and aroundwater
flow vector analysis indicating that it was not upgradient of well CJ-
10."
"In Auaust 2019. EPA and Tetra Tech performed field reconnaissance
efforts before the area of the former steel mill was redeveloped as a
commercial shippina transfer station. At the time, the surface of the
area was confirmed to be covered with araded steel slaa and soil."
b) See General Response to Comment 2 and Specific Comments 50
through 55 for additional details.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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23
4.4.2
23/6
"Table 1-Sampling Locations and
Construction Detailsprovided by EPA,
contained the depth of the PDB samples
and for 3DVA purposes, a screened
interval was assumed to be 1.0 foot of
influence above and below the PDB
depth. For all other wells, it was assumed
that the sample for the BP, piezometer,
WHS, and packer systems- related data
were collected from the entire length of
the screened interval.
This implies that PDB sample results are not indicative of the entire screen length or
aquifer/zone thickness, which may minimize the vertical plume dimensions. This assumption
likely limits the interpolated vertical distribution of PCE used in associated mass estimates.
The text was modified as follows:
"Table 1 - Sampling Locations and Construction Details," provided by EPA,
contained the depth of the PDB samples and to be consistent with all
prior 3DVA efforts, a screened interval was assumed to be 1.0 foot of
influence above and below the PDB depth. For all other wells, as described
further in Section 4.5.3. it was assumed that the sample for the BP.
piezometer, WHS, and packer systems-related data were collected from
the entire length of the screened interval.
The originally assumed 1.0 foot of influence above and below the PDB
depth was established during the 2012 3DVA efforts and has been
maintained since then for consistency in comparative results.
EPA agrees that the assumed PDB sample interval may limit the
contaminated vertical interval encompassed by wells with long well
screens. However, regardless of the accuracy of any given well-specific
analytical results, site-wide data still show significant reductions in plume
volume, concentration and mass over time.
24
4.4.2
24/2
Detection limit (DL) values play a crucial
role in bounding a contaminant plume;
however, DLs can be problematic if
analyses included dilutions and elevated
DLs; which can result in concentrations
elevated above MCLs or other criteria of
interest. While DLs are provided by
laboratories for each compound or
analyte, 3DVA requires decisions
regarding what value to use as
representative of an analyte
concentration and considering that the
analyte may be present at some
concentration below the DL. However,
formal guidelines have not been
established for determining the fraction
of the DLthat should be used to account
for the potential presence of an analyte
below the DL. Based on past 3DVA
project experience, it was determined
that 10 percent of the DL value would be
used, which is a common industry
practice that EPA OSRTI has applied to all
3DVA projects with similar issues.
In review of the following EPA guidance document for RISK assessment:
https://www.epa.gov/risk/regional-guidance-handling-chemical-concentration-data-near-
detection- limit-risk-assessments
Several methods are proposed including using the DL value, 1/2DL value, or statistical
estimation techniques. Is there a reference document supporting the use of 10% of the DL?
A more conservative approach would be the value of the DL or 1/2 the DL. This is important
as SBMWD is required to treat down to the common DL of 0.5 mg/Lfor PCE, per the EIS and
DDW permit.
The text was modified to indicate that "50 percent (1/2)" of the detection
limit was used in the 3DVA effort, which is consistent with the "more
conservative approach" indicated by the reviewer.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-16
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Region 5 START V Contract: Document Tracking Number 2216a
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25
4.4
25/1
During the 2019 - 2022 3DVA update,
the lithology component database and
bedrock surface file were refined based
on review of:
• Boring logs and monitoring well
construction diagrams for all wells in the
Northwest Area to confirm lithology of
each boring, well screen intervals, and
lithologic material well screened within;
and
• Data in Report of Findings for Initial
Source Investigation Apex Parcel
(Kleinfelder 2000) and incorporation of
lithologic data from 18 additional soil
borings into the lithologic component
database and bedrock surface file.
A reference for the bedrock surface file is not provided. Is this the bedrock surface file from
the Stantec 2008 groundwater flow model EarthVision work that was provided to EPA/Tetra
Tech?
The text was revised as follows:
"Site litholoaies of unconsolidated deposits and the bedrock surface were
derived from the boring log information available from the
EarthVision P4F5P model previously developed for the NGFM constructed
for the site area (Stantec 2008)."
26
4.4
25/1
bulleted
items
Boring logs and monitoring well
construction diagrams for all wells in the
Northwest Area to confirm lithology of
each boring, well screen intervals, and
lithologic material well screened within;
and Data in Report of Findings for Initial
Source Investigation Apex Parcel
(Kleinfelder 2000) and incorporation of
lithologic data from 18 additional soil
borings into the lithologic component
database and bedrock
surface file.
There is no indication of which boring logs were reviewed, and how this was used to refine
the lithology database or bedrock surface. In addition, the text states that 8 [18] additional
boring logs were added from the Kleinfelder report, with no figure showing the location of
the boring logs. No references to Table A.4 or A.5 are included. Do the newly added logs in
Table A.5, follow the coding nomenclature from Table A.4? Section 4.5.5 partially addresses
this, indicating the previous classification scheme was followed (Table A.4) and the data is
presented in Table A.5, but no indication of which wells were specifically updated as part of
this scope of work.
The text in Section 4.4 was modified as follows:
"• Data in Report of Findings for Initial Source Investigation Apex Parcel
(Kleinfelder 2000) and incorporation of lithologic data from 18 additional
soil borings into the lithologic component database and bedrock surface
file. Section 4.5.5 describes the methods used to incorporate the
additional litholoaic data."
The text in Section 4.5.5 was modified as follows:
"To support the Rl of the Source OU, and particularly, the evaluation of
the Northwest Area, additional aeoloaic data resources from 18 borina
loas (Kleinfelder 2000) were evaluated incorporated into the litholoaic
component database to provide a hiaher resolution of site unconsolidated
lithology and the bedrock surface in the Northwest Area than was
available from the current litholoaic data. Consistent with prior 3DVA
efforts, the updated litholoav database assianed a litholoaic code from 1
to 15 based on USCS classifications (shown in Table A.4 in Appendix A.
Table A.5 in Appendix A presents a complete listing of lithologic logs,
includina the 18 additional loas. with location coordinates and litholoaic
codes.
Table A.4 was modified to identify the 18 boring logs added to the
lithologic component database.
27
4.5.2
26/1
Figure 4.3, Figure 4.5 and Figure 4.6,
show the "domain" used for each
dataset. A domain is a perimeter formed
by all of the spatially outermost sample
points within the overall dataset. The
data were interpolated within the
domain using kriging methods. No data
How has the domain varied from previous work? Encanto Park B well is currently reported as
"Dry"; historically, the well had concentrations of PCE. This appears to be outside of the
current domain. What is a reasonable buffer around a domain to let the data extrapolate?
The domain is very limited in the area formerly defined as the Northwest Area of the Source
OU.
The domains varied slightly from year to year based on the dataset for the
wells sampled for each year. Visualizations and associated mass
calculations of PCE at and above 5 mg/L were not substantially affected by
the domain variations.
The 3DVA is based on interpolation of data within the domain and does
not include any extrapolation.
5 httos://www. dai.com/earthvision-software-for-3d-modelina-and-visualization/
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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were kriged to extrapolate information
beyond this domain.
EPA acknowledges that the portion of the site-wide domain is somewhat
limited in the Northwest Area. It is for this reason that Alternative 2 in the
Proposed Plan includes re-incorporation of wells in the area that have not
been sampled in recent years.
28
4.5.3
26/3
This sensitivity analysis was conducted by
calculating the PCE plume mass at 5 ng/L
for values of max-gap ranging from 5 to
100 feet. The mass versus max-gap
results were plotted and indicated that
the mass calculation stabilizes with a
max-gap greater than 35 feet. A
conservative max-gap of 50 feet was
chosen for all site-wide PCE plume kriging
to ensure that max-gap did not impact
the representativeness of the PCE
geostatistical analysis. This method is
consistent with the max-gap used in
previous 3DVA efforts for the Newmark
site.
a) Presentation of the table and/or visuals to show the range of variation and the effect
this has on plume modeling is needed. Previous modeling efforts by Sundance/Tetra
Tech did use a Max Gap of 50. How does this compare to the aquifer thickness? Has
that been considered, or only screen lengths relative to one another?
b) What seems to be missing in this analysis is a site conceptual model for the plume and
what it theoretically looks like distributed across the shallow, intermediate, and deep
well screens. Is it appropriate to visualize the plume as one continuous dataset,
irrespective of the hydrogeologic framework?
a) The max-gap analysis was performed to determine how groundwater
contaminant concentrations would be distributed along the vertical
span of each long well screen. Max-gap analysis does not consider
aquifer thickness.
b) The 3DVA methodology involves separate kriging of chemistry,
hydrogeology (groundwater potentiometric), and geology (lithology-
based) data. Based on this, the plume was kriged as one continuous
dataset, independent of the influences of the other data sets. The
reviewer is also referred to Figure 5.5, which shows that site lithology
and 3D hydraulic head isocontours do not indicate a shallow,
intermediate and deep aquifer framework, hence kriging of the
plume as one continuous dataset is appropriate.
These approaches to 3DVA are best practices used to develop conceptual
site models (CSM) for sites using existing site data; these best practices
are supported by EPA's Office of Superfund Remediation and Technology
Innovation (OSRTI) and have been consistently used for the Newmark site
since 2012; as described in the Final Technical Memorandum. Source
Identification, Plume Delineation, Restoration Timeframe Estimation and
Transition from Interim to Final Remedy. Newmark Groundwater
Contamination Superfund Site. Source Operable. Unit San Bernardino,
California (Tetra Tech 2014).
29
4.5.3
26/4
All non-detected values were recorded as
"less than" the DL and the less than
multiplier was set to 0.5 (50 percent of
the DL).
Section 4.4.2 indicates DL values set to 10% of DL. The of 50% seems to be a more
appropriate conservative approach. The method used should be clarified.
The text was modified to indicate that "50 percent (1/2)" of the detection
limit was used in the 3DVA effort, which is consistent with the "more
conservative approach" indicated by the reviewer.
30
4.5.4
27/1
Groundwater elevation data for April and
October 2022 were evaluated for use in
the 3DVA effort to represent
hydrogeologic conditions at the site. The
groundwater elevations for the shallow
monitoring wells were kriged as the
potentiometric surface, which was used
to "cut" the surface of the groundwater
chemistry plume components (limiting
the upper surface of the groundwater
contaminant plumes to the water table).
This elevation surface is used to "cut" the top of the plume. Figure 4.2 shows the
visualization domain, but does not indicate that the groundwater chemistry is kriged within
the geologic block model. What is the kriging method's upper, lower and lateral boundary? If
it's the domain shown in Figure 4.2, the data is effectively communicating through bedrock.
The domain or lateral extent of data used to krige is shown on Figure 4.2.
The upper extent of the domain is the groundwater potentiometric
surface. The lower extent of the domain is defined by the depths of each
groundwater sample, not the geologic materials within which the wells
are screened.
The sampling depths within bedrock used in the visualization were based
on the operable wells located in the Northwest Area that are completed
in shallow weathered and unweathered bedrock, as indicated in revised
text in Section 4.5.2. All other wells used in the Source OU-wide domain
are screened within the alluvial overburden.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-18
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Lastly, as indicated in the RI/FFS, groundwater in the overburden and
bedrock in Northwest Area "...are hydraulically connected units behaving
as one aquifer system..."
31
4.5.4
27/2
Figure 4.5 presents the October 2022
data points used to create the
potentiometric surface and the
potentiometric surface. Gridding
parameters for visualizations of the 2D
potentiometric surface are shown in
Table 4.3. Three-dimensional
groundwater hydraulic head gradient
analyses were also performed to better
understand hydraulic gradients and their
relationships with potential contaminant
migrant pathways.
Horizontal and vertical cross-sectional
views show the hydraulic head
distributions and variability with
elevation.
No cross-sectional views are presented on figures for hydraulic gradient analysis.
Cross-sectional views of hydraulic gradients were presented in Figures 5.5
and 7.0, as follows:
• Figure 5.5 PCE Concentrations At and Above 5 jxg/L MCL Located
Proximal to Active Extraction Wells shows a hydrogeologic cross-
section with isocontours of the vertical component of hydraulic head.
The purpose of this hydraulic gradient analysis was to show how the
remaining PCE in these locations was located within the capture
zones of the adjacent Extraction Wells EW-109, EW-110 and EW-111.
• Figure 7.20 Conceptual Cross-Section of Groundwater Flow Path from
Former Steel Mill; Northwest Area also shows the current
understanding of the vertical component of hydraulic head in that
area.
32
4.5.4-
4.5.5
General
Grid parameters Chemistry = 150x150,
shallow gw 115x120, hydraulic head =
103 xl02, lithology 155x148
Understanding that each model component is using a unique convex shell to define the
lateral domain, why not use a consistent cell size or map all data to a consistent grid?
Grid parameters were a reflection of varying domain (size) for each data
set used, based on the dataset for the wells sampled for each year.
33
4.5.5
29/2
To support the Rl of the Source OU, and
particularly, the evaluation of the
Northwest Area, additional geologic data
resources were evaluated to provide a
higher resolution of site unconsolidated
lithology and the bedrock surface in the
Northwest Area than was available from
the current lithologic data.
The additional logs used are not identified.
See the response to Comment 26.
34
4.5.5
29/Table 4.5
Number of Boring Locations = 3099
This value likely represents entering all boring data intervals as unique locations in EVS,
however, there is very little description of the EVS lithology modeling to indicate why 129+18
lithologic logs = 3099 boring locations in EVS. In addition, this section does not detail if the
data is kriged within the confines of the structure model or is independently kriged.
The table was edited as follows:
"Total Number of Borina Locations Individual Litholoaic Intervals"
The total number of individual lithologic intervals is the number of unique
(JSCS code-based values used in the input file. This is based on each
boring log having variable numbers of lithologic intervals; based on the
original field boring log descriptions.
Each data set (lithology, groundwater elevations, chemistry) is
independently kriged and is not influenced by any of the other
component data sets.
35
4.5.5
29/Table 4.5
Anisotropy Ratio = 75 (horizontal to
vertical)
The anisotropy ratio of 75 appears to be qualitatively reasonable to get EVS to simulate
horizontal layering. The anisotropy value of 10 used for chemistry, may be appropriate, but
there is no discussion of why these values are so different in the visualization. Nor is any
The anisotropy ratio of 10 to 1 used for chemistry was selected based on
an iterative process of evaluating visualization results derived from use of
variable ratios to provide the greatest degree of data representativeness.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-19
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Region 5 START V Contract: Document Tracking Number 2216a
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discussion presented to indicate why these ratios were selected or what the sensitivity is to
varying these parameters.
Use of this method and resulting anisotropy ratio were consistent with
previous 3DVA efforts.
36
4.6
30/2
However, applying a constant effective
porosity to estimate plume mass over an
area as large as the Source OU with
varying lithologic properties, lowers the
accuracy of the resulting mass estimate.
Therefore, the Volumetric module was
used to calculate plume mass that
allowed for spatially varying effective
porosity, which improves the accuracy of
contaminant mass calculations. Instead
of multiplying the summation of the
concentration by the volume over the
entire domain at a constant effective
porosity, a spatially varying effective
porosity was estimated for each grid cell.
This more precise effective porosity value
was then multiplied by the concentration
and volume of each grid cell according to
the following equation:
How was the porosity distribution interpolated? Was the same set of parameters used for
the lithology kriging with effective porosity replacing the lithology code?
Lithology code was replaced with effective porosity and was kriged using
the same gridding parameters as the chemistry concentration file in order
to have a matching grid so that the porosity could be multiplied by the
PCE concentrations.
37
4.7
30/3
The independent component
visualizations ensure that the
correlations of physical features and
contaminant properties seen in the
integrated visualizations reflect site
conditions and are not a result of
computational artifacts.
Interpolation of groundwater PCE concentrations across the entire source OU without
barriers, such as the Pelona Schist, seems problematic. The model is effectively ignoring
barriers between data points and only treats them as a function of distance, but it seems to
suggest the distribution is inherently related. In general, the entire approach of this
visualization modeling is fundamentally different from that of the SBBA groundwater flow
model. The groundwater flow model creates a physical basin and simulations flow and
distribution within that framework. This visualization creates separate datasets at differing
scales with independent visualization and then attempts to integrate those visuals into a
single framework without sharing boundary or physical constraints. For instance, this
visualization produces plumes within the Shandin Hills or above groundwater. Overall, this
section of the report does not provide clarity on the vertical boundaries of any dataset and
instead suggests how they were fitted to the framework after constructed.
3DVA and groundwater flow modeling are not equivalent methods of site
evaluation.
The 3DVA methodology involves separate kriging of chemistry,
hydrogeology (groundwater potentiometric), and geology (lithology-
based) data. Based on this, the plume was kriged as one continuous
dataset, independent of the influences of the other data sets. The data
sets are then integrated at the same scale relative to each other, enabling
the evaluation of the site with respect to these data sets. Integration of
the data sets is a standard function of the Earth Volumetrics Studio
software; therefore, their integration was not randomly attempted.
The software did not produce plumes above groundwater or within the
Shandon Hills. All chemistry data kriging is "cut" at the groundwater
surface as part of the domain design; therefore, it is not possible to
produce plumes above groundwater. The appearance of plumes above
groundwater and within the Shandin Hills is dependent upon the view
orientation of the 3D imagery and relative transparencies of the visualized
media, which can give the visual impression that plume is within the
bedrock Shandin Hills.
The approaches used 3DVA are best practices used and supported by
EPA's Office of Superfund Remediation and Technology Innovation
(OSRTI), and have been applied for the Newmark site since 2012; as
described in the Final Technical Memorandum. Source Identification,
Plume Delineation, Restoration Timeframe Estimation and Transition from
Interim to Final Remedy. Newmark Groundwater Contamination
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-20
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Text and/or Comment Topic
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EPA Region 9 Responses
Superfund Site. Source Operable. Unit San Bernardino, California (Tetra
Tech 2014).
38
4.8
31/8
Bullet 1
Data comparability and
representativeness were reviewed.
Comparability was assessed between the
various sampling methods used and
differences in analytical method
reporting limits. No notable
discontinuities or trends in the datasets
were identified that appeared strictly
laboratory-or method-related (that could
not be explained by other factors such as
pumping effects or hydrogeology).
Reporting limits were fairly comparable
and caused no significant effects in the
overall trends in the datasets.
No specific methodology, reference or tabulation of comparative results in presented.
The analytical results data used in the 3DVA effort were all derived by
third parties; specifically, SBMWD and EPA Region 9's site contractor.
Therefore, the data received had already been subjected to independent
data validation efforts, wherein the typical quantitative review of
precision, accuracy, representativeness, completeness and comparability
(PARCC) had already been performed.
As described in the RI/FFS, the focus of data review was to evaluate the
comparability to data sets received and used for prior 3DVA efforts,
including sampling locations and depths; sampling methods; analytical
methods, detection limits and reporting limits; and general data QC for
transcription errors.
39
5.2
33/5
Figure 5.1 shows that while site-wide
plume size and morphology has not
reduced significantly, the site-wide PCE
mass (estimated for groundwater with
concentrations of PCE at and above 5
Hg/L) has reduced further (from
approximately 23 lbs in 2019 to
approximately 6.4 lbs as of 2022, an
approximate 72 percent reduction).
This statement with respect to PCE mass is misleading (see comment 13) implying a mass
decrease of 16.6 lbs (23 lbs to 6.4 lbs) between 2019 and 2022. It should be noted that much
of the 16.6 lbs of PCE, inferred to no longer exist, is not a mass reduction but instead is still
present in the groundwater system at concentrations below 5 mg/L
The text was modified as follows:
"Figure 5.1 shows that while site-wide plume size and morphology has not
reduced sianificantlv since 2019. the site-wide PCE mass (estimated for
aroundwater with concentrations of PCE at and above the 5 ua/L MCL)
has reduced further (from approximately 23 lbs in 2019 to approximately
6.4 lbs as of 2022, an approximate 72 percent reduction)."
Estimates of mass remaining between 0.5 and 5 mg/L would relate to the
14 EIS wells only; while these are acknowledged in the RI/FFS, they are
addressed in the 2015 ROD for the Newmark and Muscoy OUs.
40
5.2
33/6
As shown in Figure 5.2, from 1997 to
2022, site-wide mass reduced from
approximately 9,000 lbs to approximately
6.4 lbs, a reduction of approximately 99.9
percent.
This statement with respect to PCE mass is misleading (see comment 13) implying a mass
decrease of 8,993.6 lbs (9,000 lbs to 6.4 lbs) between 1997 and 2022. It should be noted that
much of the 8993.6 lbs of PCE, inferred to no longer exist, is not a mass reduction but
instead is still present in the groundwater system at concentrations below 5 mg/L
The text was modified as follows:
"As shown in Fiaure 5.2. from 1997 to 2022. site-wide mass of PCE at and
above the 5 ua/L MCL reduced from approximately 9,000 lbs to
approximately 6.4 lbs, a reduction of approximately 99.9 percent."
Estimates of mass remaining between 0.5 and 5 mg/L would relate to the
14 EIS wells only; while these are acknowledged in the RI/FFS, they are
addressed in the 2015 ROD for the Newmark and Muscoy OUs.
41
5.3
33/8 and
Table 5.1
Table 5.1 shows four site-wide wells
where PCE concentrations remained at
and above the 5 ng/L in April 2022;
including one extraction well and one
extraction well piezometer in the Muscoy
OU, and two monitoring wells in the
Northwest Area.
The text introducing Table 5.1 indicates that the data included in the table are for April 2022
samples; however, the Table title says October 2022. The sample collected from EPA 110PC
appears to have been collected on November 17, 2022. The sample shown in Table 5.1
collected from EPA 111 was collected on November 22, 2022, following a long maintenance
outage for pump replacement. It should be noted that if a corresponding sample was
collected from EPA 111PC following the restart of EPA 111, PCE in that sample would also
likely exceed 5 mg/L A sample collected from EPA 111PC on May 16, 2023 contained PCE
reported at 7.8 mg/L.
Table 5.1 was based on data received as reported for October 2022, which
included wells sampled by the City through December 2022, which was
chosen as the most complete and recent dataset at the time of the 3DVA
effort. The text in the Executive Summary and Section 1 were modified to
clarify the date confusion.
Table 5.1 was edited to change "5.45.6" to "5.6".
42
5.3.1
34/1 and
Figure 5.4
Figure 5.4 shows that the wells with PCE
remaining in concentrations at and above
the 5 ng/L in the Muscoy OU is present
NOTE: SBMWD's comment has been manually sub-numbered to support response to the
various topics addressed within the comment.
a) The visualization is an interpolation between locations with analytical
data, thus a direct function of data density between the locations.
Data from wells with non-detections and detections at less than 5
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-21
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Text and/or Comment Topic
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EPA Region 9 Responses
within heterogenous interbedded
silt/clays and sand/gravel, wherein
contaminant persistence is controlled by
matrix back-diffusion.
a) Figure 5.4 portrays both a map view and a cross-section view of the volume of water
estimated to contain PCE above 5 mg/L This figure suggests that the PCE
concentrations exceeding 5 mg/L are limited to aquifer volumes within the immediate
vicinity of the well from which they were sampled with no continuity in concentration
between wells. This is an unrealistic portrayal of the PCE plume in excess of 5 mg/L
and is not supported by the data. There are no data points between EPA 110 and EPA
111 for which to conclude that the intervening PCE concentrations between these two
wells are less than 5 mg/L.
b) The cross-section shows projection of two downgradient wells between EPA 110 and
EPA 111 (i.e., MW 137B and MW 138B), which is misleading as these wells are
downgradient of the extraction well network.
c) The PCE concentration for EPA 110PD is shown in the Figure as 4.8 mg/L. The legend
indicates this is the "2022 PCE Annual Max Concentration". The maximum PCE
concentration for samples collected from EPA 110PD in 2022 was 8.2 mg/L, as
reported for the sample collected on May 17, 2022.
d) A more reasonable interpretation is that the volume of aquifer with PCE exceeding 5
mg/L encompasses and extends beyond EPA 110 and EPA 111 within the intermediate
zone, rather than limiting this area to 2 individual masses, one of which is shown to
extend only 200 feet from the well (EPA 110PC drops from 8.2 mg/L to 5 mg/L in 200
feet with no supporting data for this drop off in concentration over such a short
distance). Furthermore, the Figure 5.4 portrayal suggests that the concentration drops
off vertically within the EPA 110 piezometer cluster immediately outside the screen
interval of EPA 110PC. This is equally unrealistic and ignores the PCE samples collected
from EPA 110PD with a maximum PCE concentration of 8.2 mg/L for 2022, rather than
the 4.8 mg/L shown on Figure 5.4.
e) The cross-section appears to show an intervening concentration of 3.2 mg/L, which
appears to correspond to the October 2022 grab sample from the EPA 110 extraction
wellhead.
f) Using this sample result in this way is also misleading, as this is a composite sample of
production over the entire screen interval, which includes the shallow aquifer and
intermediate zone. Monitoring data have demonstrated that intermediate zone PCE
concentrations at EPA 110 are higher than the shallow aquifer PCE concentrations.
This is evidenced by comparing PCE concentrations in EPA 110PB to those of EPA
110PC or EPA 110PD.
g) The maximum 2022 concentration in samples collected from EPA 110PB is 2.7 mg/L,
compared to 8.1 mg/L and 8.2 mg/L for EPA 110PC and EPA 110PD, respectively. For
the reasons mentioned in this comment, the portrayal of the vertically and laterally
very restricted volume of aquifer in excess of 5 mg/L in the vicinity of EPA 110 and EPA
111 is unrealistic. Therefore, the mass computed using these volumes is also
unrealistic.
h) SBMWD/Stantec estimate the PCE mass above 5 mg/L in the vicinity of EPA 111 and
EPA 111 was 142 pounds in May of 2022 (Stantec, 2023), as opposed to the combined
estimate of 6.4 pounds for both the vicinity of EPA 111/EPA 111 and the Northwest
Source Area presented in the RI/FFS. The SBMWD/Stantec estimate is of PCE mass in
excess of 5 mg/L is 2,219% higher than the EPA/Tetra Tech estimate and does not
include the Northwest Source Area that is included in the EPA/Tetra Tech estimate.
Hg/L serve to constrain the interpolative connection between
proximal locations. This is further affected by data from EPA-110 and
EPA-111 being single data points collected from extraction wells with
long well screens and differences in non-detections and detected
concentrations between the extraction wells and their companion
piezometers. For example, PCE in EPA-111 was 5.6 ng/L while the
piezometer results ranged from non-detection (ND) to 2.5 ng/L.
Similarly, for EPA-110, the PCE concentration was 3.2 ng/L, whereas
concentrations in adjacent piezometers ranged from ND to 8.1 ng/L.
b) While image B-B' is a conventional cross-section, image A-A' is
actually a northeasterly view angle of the 3D image, thus MW 137B
and MW 138B appear to be between EPA-110 and EPA-111, but as
shown on the inset map in the upper lefthand corner, they are not
located between them.
c) The legend in Figure 4 ("2022 PCE Annual Max Concentration") was
changed to "October 2022 PCE Concentration*" with an asterisk to
reference Section 4.5.3 in the RI/FFS report text for further
information on the specific time periods for select locations for which
October 2022 data were not available.
d) See response to Comment "a)" above.
e) The 3.2 mg/L PCE concentration, which is from the October 2022 grab
sample, was distributed every 50 feet along the screened interval of
EPA 110 using the Max-Gap method. The PCE concentrations of 2.6,
8.1, 4.8 and <2.5 mg/L are results from four EW-110 piezometers. The
view orientation results in the wells being visually overlain, thus
appearing to be the same long screen interval, thus the 3.2 mg/L PCE
concentration only appears to be between (that is, "intervening") the
8.1 and 4.8 mg/L PCE concentrations, when in reality the results are
from different wells.
f) See responses to Comments "a)" and "e)"above. The reviewer is also
referred to Figure 5.5, which shows that site lithology and 3D
hydraulic head isocontours do not indicate a shallow, intermediate,
and deep aquifer framework, hence kriging of the plume as one
continuous dataset is appropriate.
g) The PCE mass was computed based on the kriged volume using the
concentrations from the wells indicated in responses to "a)" and "e)"
above.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-22
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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h) It is expected that mass calculations from 3DVA and groundwater fate
and transport modeling would not be equivalent, given the manner in
which each software calculates mass; in combination with the
variable parameter assumptions (for example, porosity) used for
each. However, if the basis for SBMWD/Stantec's estimate is
understood correctly, the percent difference between 6.4 pounds and
142 pounds is approximately only 183%. Notwithstanding these
differences, it is clear that PCE mass has reduced to below the 5 mg/L
MCL for the majority of the Source OU, and that the mass remaining
above the 5 mg/L MCL near EPA-110 is relatively limited.
43
5.0
Figure 5.7
through 5.12
EPA006 PCE
The green font in the text box for EPA 006 incorrectly indicates the 0.66 mg/L PCE
concentration is below the EIS criteria of 0.5 mg/L.
Modified versions of Figures 5.7 through 5.12 with the coloration error
corrected were developed and incorporated in the revised RI/FFS.
The PCE plume visualizations were not impacted by the coloration error as
they are based on the 0.66 mg/L concentration at well EPA 006.
44
5.0
Figures 5.8
through 5.12
Maps and 3D images of PCE plume mass
above a stated level
To provide proper context of the data points used to support these plume renderings, the
locations of the data points used to support this analysis should be shown. A simple black
dot could be added to the map view to accomplish this. Otherwise, the effects of potential
data gaps in developing these rendering is not apparent.
Modified versions of Figures 5.7 through 5.12 showing the network of
wells used to generate the 2D PCE plume visualizations were developed
and incorporated in the revised RI/FFS.
45
6.1
35/3
Trend estimates were constructed for
everv Newmark site groundwater well
with sufficient historical PCE and/or TCE
data (that is with a number greater than
or equal to 10 [n > 10]).
a) MW 132A was not included in the trend analysis. Graphs presented in URS, 2008a show
that this well was sampled 12 or more times through mid-2008. URS 2008a Section 4.2
noted that "...relatively high PCE concentrations detected in samples from alluvial well
MW-132A (6 to 25 ng/L) have not significantly decreased since its installation in summer
2000." The Final Technical Memorandum of Results Mid 2014 Semi-Annual Groundwater
Sampling, prepared for EPA by Gilbane Federal, shows that 3 additional samples were
collected from MW 132A in 2013 and early 2014. Data reported in Table A-2 of this
report indicate that samples from MW 132A were not collected in 2022. No explanation
was provided.
b) Based on review of the time vs. PCE concentration graphs presented in URS, 2008a and
data presented in Gilbane Federal, 2014, other source OU wells with 10 or more historic
samples that were not included in the trend analysis presented in Section 6.0 included
CJ-1, CJ- 1A, CJ-2, CJ-3, CJ-7, CJ-12, CJ-13, CJ-14, MWCOE001A, MWCOE008, MW 127B,
MW 131A/B/C, MW 132B, MW 133A/B, MW 134 and MUNI 201.
There is no location map included in the RI/FFS report that shows the location of all of
the wells for which time vs. PCE concentration plots were prepared. There are three
maps presented in Section 7.0 that show a limited number of the Source OU well
locations (Figures 7.3, 7.5 and 7.8).
a) MW-132 was not included in the trend analysis because the sampling
information provided indicated "inadequate water in well"; which
confirmed that no sample had been collected and analyzed for that
location.
b) The updated statistical trends for PCE only included those wells for
which at least one measurement had been collected since 2018.
Therefore, the wells listed in the comment were not included. A new
Figure 6.1 - Locations of Wells Used for Statistical Trend Analyses;
was developed and incorporated into the revised RI/FFS, which shows
all groundwater monitoring and observation wells, extraction wells,
companion piezometers to extraction wells, and production wells
with sufficient historical PCE and TCE analytical data used to generate
the time vs. PCE concentration plots.
46
6.4
38/3
For EW-111, the historical PCE data have
been highly variable since 2005, with
periods both below and above the 5 ng/L
MCL. The current PCE trend estimate is
close to, but slightly below, the MCL, and
projected to reduce further over time.
However, there is uncertainty in the
confidence band around this trend and
its future projection. Also, no
The LOESS projection graph shows there is substantial uncertainty with the PCE trend for
EPA 111, with an increasing trend falling within the 95% confidence band. The Quadratic
Exponential graph shows an increasing trend above the MCL through the end of the
projection period.
Due to the substantial variability over time in PCE at EW-111, the two
trend estimation methods provide somewhat different results.
EPA agrees that determining whether or not the current and future trends
exceed or will exceed the 5 ng/L MCL is uncertain. It must also be noted
that any trend *projection*, as an extrapolation into the future from
which no data have been observed, will always be substantially more
uncertain than any current trend estimate.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-23
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EPA Region 9 Responses
measurements have been observed
below the MCL since around 2017. The
trend does not currently statistically
exceed the MCL, nor is it projected to
exceed through 2027.
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6.4
38/3
For EW-110PZC, PCE concentrations have
been mostly declining since 2007. A
recent observation at the end of 2021
was below the MCL; however, the most
recent value was slightly above. The
current LOESS trend is very close to 5
Hg/L, with a 5-year projection that is
mostly 'flat' and quite close to the MCL.
The degree of statistical uncertainty in
the projected trend estimate is again
substantial; however, it is not forecast to
statistically exceed the MCL.
a) Although the PCE trend for EPA 110PC is slightly below the MCL, an increasing trend
falls within the 95% confidence band.
b) EPA 110PD is not discussed although the PCE concentration projected trend graphs
shows an increasing trend above the MCL and thus should not be ignored in this
discussion.
a) As the text explains, confidence bands help to estimate the possible
uncertainty associated with a given trend estimate. Although the
confidence band at EW-110PZC indicates the possibility of a current
and future trend above the 5 ng/L MCL, the single best current
estimate is provided by the estimated current trend and its future
projection. This estimate reflects the general decline in PCE
concentrations since approximately 2005.
b) The text has been modified to include a description of the projected
trend graph for PCE concentrations at EW-110PZD.
48
6.5
34/bullet 2
and 3
Bullet 2: For CJ-6, none of the PCE
sampling results have been below the
MCL since 2006. The current trend
statistically exceeds the MCL and is
projected to remain above 5 ng/L
through 2027. However, the degree of
statistical uncertainty around the trend
projection is large enough to make the
confidence band slightly 'straddle' the
MCL over the last few years of the
projected time frame.
Bullet 3: For CJ-10, PCE concentrations
have generally declined since 1995, but
not enough to reduce concentrations
below the MCL. The most recent
sampling results fluctuate between 15
and 20 ng/L, and the current trend
estimate statistically exceeds the MCL.
Nonetheless, the trend shows the
concentration is slowly declining and is
projected to decrease further in the next
5 years. Although the projected trend is
forecast to exceed the MCL in 2027, the
confidence band around the projection
begins to straddle the 5 ng/L MCL around
2024.
If this section is going to include discussion of the lower reaches of the projected 95%
confidence band approaching PCE MCL of 5 mg/L, discussion of the projected upper reaches
of 95% confidence band exceeding the MCL should also be included (see Comments 46 and
47) as to not bias the discussion towards inclusion of the low end of the confidence band
only.
The text has been revised to indicate that statistical uncertainty around
the trend projections are large enough to cause the confidence bands to
"straddle" the MCL (that is, the upper and lower reaches of 95%
confidence are both represented).
It must also be noted that any trend *projection*, as an extrapolation into
the future from which no data have been observed, will always be
substantially more uncertain than any current trend estimate. Often, a
trend projection will straddle a regulatory limit even when the probable
direction of the trend seems clear. So it is sensible to also consider other
features or patterns of the prior data when considering what might
happen next.
49
6.6
39 through 41
SUMMARY RESULTS OF STATISTICAL
ANALYSES FOR EIS-DESIGNATED
EXTRACTION WELLS
This section is very helpful in placing context around the status of the remedy extraction
wells with respect to SBMWD's treatment obligations per the EIS designation and the terms
of the DDW Water Supply Permit which SBMWD operates under. The contents of this
section, when evaluated together with PCE mass remaining estimates above 0.5 mg/L,
EPA agrees and appreciates SBMWD's support.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-24
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prepared by the SBMWD and presented in Comment 17/42 and the SI 2023 Progress Report
(Stantec, 2023b), provide proper context as to the status of the remedy extraction wells and
achieving the EIS based treatment levels required under DDW Policy Memo 97-005 and the
City's DDW water supply permit.
50
7
42/4
Data show that the highest remaining
concentrations of PCE in groundwater
monitoring wells in the Northwest Area
are now downgradient of the former
steel mill. Wells CJ-10, CJ-6 and CJ-3 are
all downgradient of the former steel mill.
a) The assertion of the CJ-10 being downgradient of the former steel mill is questionable
based on the URS, 2008a interpretation. The water level contours presented in URS,
2008a account for hydraulic separation across Fault A and show groundwater flowing to
the southeast along the fault on the up- thrown block or northeast side of the fault in
the vicinity of CJ 10 for Spring 2000.
b) The URS interpretation suggests of the source of PCE in CJ-10 may have originated from
groundwater flow through bedrock fractures northwest of CJ 10.
c) Similar PCE concentrations are historically observed in CJ-17 which is also located
northeast of Fault A suggest accumulation of PCE may have historically occurred along
Fault A between CJ 10 and CJ 17 due to the fault related hydraulic barrier effect. This
would suggest the source of PCE ponding along the fault between CJ 10 and CJ 17
originated from a source northwest of the Former Steel Plant, in the vicinity of the
Former Camp Ono Hospital Area.
a) The text has been modified throughout to that indicate that (1) the
original source for the Newmark/Muscoy plume was located within
the boundaries of former Camp Ono and (2) current residual
contamination sustaining the PCE plume in the Northwest Area is
either an original release from, or in the area of, a former steel mill
(located south and adjacent to the Verdemont Hills) and/or the
former Camp Ono hospital (located northeast of the Verdemont
Hills). Further, the text makes clear that data show that the highest
remaining concentrations of PCE in groundwater monitoring wells in
the Northwest Area are now downgradient of both of these areas.
b) The URS Hydrogeologic Investigation Report (URS 2008) did not
hypothesize or suggest that the source of PCE at CJ-10 may have
originated from groundwater flow through bedrock fractures
northwest of CJ-10. The report did, however, note that the highest
concentrations of PCE in soil gas from two separate investigations
(one conducted by Kleinfelder, summarized in Section 2.3.1, and one
conducted by Weiss Associates, summarized in Section 2.3.2) were
collected in the vicinity of the former steel rolling mill.
c) There are no PCE concentrations in the monitoring record of any
Northwest Area well that would indicate the presence of "ponded"
PCE. If the contamination at CJ-10 were caused by PCE ponding (PCE
present as a dense non-aqueous phase liquid [DNAPL]) along the
fault, PCE concentrations would be at parts per million (ppm)
concentrations in wells downgradient of CJ-17, and would be
particularly high at CJ-17 and CJ-16, where PCE concentrations have
instead declined to levels below the 5 mg/L MCL Furthermore, the
highest PCE concentration ever measured at any of the Northwest
Area wells is 130 ng/L, or approximately 0.1 ppm.
51
7.1.3
44/2
The offset in bedrock elevation between
these closely spaced (400 to 600 feet
apart) wells provides the primary support
for the existence of a fault in this area.
However, it is also possible that the
abrupt change in the bedrock surface is
simply a buried erosional escarpment,
unrelated to faulting.
The large differences in water level on opposing sides of the Fault A are indicative of the
presence of a groundwater barrier effect in this area that is consistent with fault related
hydraulic separation of the juxtaposed bedrock and alluvial aquifer blocks. The trend of Fault
A, when considered along with the proximity to the tectonic environment associated with
the San Andres Fault Zone and Verdemont Hills bedrock high also supports this abrupt
change in bedrock elevation is fault related. It appears that the report is trying to minimize
the potential effects of faulting/groundwater barriers on groundwater flow and present a
simplistic site conceptual model of groundwater flow paths across this hydraulic feature
reported as Fault A by URS (URS, 2008a) with no effect on groundwater flow direction.
See General Response to Comment 2.
The difference in the potentiometric contours on opposing sides of
inferred Fault A is likely related to two factors: (1) the depth to
unfractured bedrock (the relatively impermeable base of the aquifer) is
much greater in the alluvial block than the bedrock block, and (2) there
appears to be confining pressure in the bedrock groundwater block (the
initial site assessment report (EMCON 1995) notes that water levels in the
bedrock wells rise to an elevation above than the elevation where "first
saturation" is noted on the wells' borehole logs).
52
7.1.3
44/3
Notwithstanding, the seismic study
concluded that "there is no compelling
The differential head across the Fault A, which is often in excess of 100 feet indicates there
are two distinctly different hydraulic areas on opposing sides of Fault A. Groundwater
See General Response to Comment 2.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-25
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evidence in the data that the faults act as
significant groundwater dams." Even
during decreased groundwater elevation
conditions, groundwater in the
weathered bedrock at monitoring well
CJ-10 may still reach the adjacent alluvial
aquifer by flowing across the fault
trace/alluvium contact (SAIC 2001).
contour maps prepared by URS for Spring 2000 and Fall 2006 best show this distinction (URS,
2008a). The URS interpretation shows a component of flow on the northeast or bedrock side
of the fault flowing to the southeast subparallel to the fault in the vicinity of CJ-10. This
interpretive finding is not discussed in this report.
The bedrock groundwater in Fault Block A and the alluvial groundwater in
Fault Blocks B and B' are two distinct groundwater systems; however,
groundwater can flow from Fault Block A to Fault Block B down its
seepage face; thus, there is no evidence that Fault A acts as a barrier to
flow. Groundwater will follow the path of least resistance, which is down
the bedrock/alluvium contact, a buried seepage face, as described in
Section 7.1.6 of the RI/FFS and in the General Response to Comment 2.
The difference between a hydraulic boundary that permits flow in one
direction and a hydraulic barrier, which permits little or no flow in either
direction, is further discussed in the General Response to Comment 2.
The URS maps show a component of flow to the southeast within Fault
Block A; however, in the vicinity of well CJ-17 it indicates that a stronger
component of flow is oriented perpendicular to the fault trace, as
evidenced by the narrow contour spacing between wells MWCOE009 and
Q-17. Flow tubes constructed at a perpendicular angle to the contours
would indicate flow is directed toward the fault trace at this point (CJ-17),
not parallel to the fault.
53
7.1.6
46/2 and
Figures 2- 7,
4-5, 7-5
and 7-14
The highest hydraulic heads measured in
the Verdemont Hills area are at
MWCOE009 (screened in bedrock) and
flow appears to be radially away from
this portion of the Verdemont Hills as
shown on Figure 7.5.
MWCOE009 is screened higher than all other bedrock wells completed in the up-thrown
block area on the northeast side of Fault A. This well may have an impeded hydraulically
connection through the bedrock fracture system to the other up-thrown block bedrock wells
(CJ 10, CJ 17, MWCOE004, MWCOE 005, MWCOE 007 and MWCOE008) which are all
screened at a similar lower elevation. This interpretation ignores the presence of Fault A
which clearly has created hydraulic separation between the opposing sides of the fault.
There is over 100 feet of water level difference across this feature in Spring 2000 and
approximately 60 feet in Fall 2006 (URS, 2008a).
See General Response to Comment 2.
MWCOE009 and all of the other wells cited in the comment are located
upgradient of Fault A; thus, differences in groundwater levels between
any of these wells are not influenced by Fault A because they are not on
opposing sides of Fault A.
54
7
7.1.4 and
7.1.6
General comment on site conceptual
model for groundwater flow and the
effects of faulting in the Vicinity of the
Northwest Source Area.
a) It has been recognized for many years that the area referred to by EPA/Tetra Tech as
the Northwest Area is the source area for the Newmark OU and Muscoy OU plumes.
EPA has recognized on several occasions, that the most plausible source of PCE/TCE
groundwater impacts in the Newmark and Muscoy OU plumes is the activities
performed at Camp Ono during the 1940s.
b) SBMWD and their experts have provided extensive data regarding the Army's activities
at Camp Ono, much of which is summarized in the letter this comments table is
attached to.
c) It is possible that multiple army PCE sources have impacted groundwater in the
Northwest Area, which was transported up to 10 miles downgradient to the location of
the extraction well networks. Much of this transport occurred prior to discovering this
contamination in the 1980's. Based on what we know about the extensive area of
groundwater impacts originating from the Northwest Area and the changes in PCE
distribution with time, most of the contamination that originated from the Northwest
Source Area has been flushed out of the area and is currently being addressed by the
RA extraction systems.
a) EPA concurs that the original source of PCE/TCE groundwater
contamination was from activities performed at former Camp Ono
during the 1940s. Subsequently, a former steel mill, has been
identified as a potential additional original source.
b) Responses to the SBMWD's October 13 cover letter are provided in
the DRAFT RECORD OF DECISION PART 3: THE RESPONSIVENESS
SUMMARY
c) EPA concurs with SBMWD's comment.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-26
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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d) The groundwater flow dynamics and effects of localized Northwest Source Area faulting
have played a large role in the evolution of the PCE plumes and the residual levels that
remain in the Northwest Source Area today. The URS 2008a Hydrogeological
Investigation Report provides a plausible site conceptual model for historic and current
groundwater contamination conditions in the Northwest Source Area. The following
two excerpt from the URS 2008a report are provided to illustrate this conceptual
understanding.
d)
See General Response to Comment 2.
"A major effect of this fault block segregation appears to be that the alluvial
groundwater beneath the Cajon Landfill is most affected by recharge from the larger
drainage basins to the northwest (e.g. Cajon Wash), while bedrock groundwater
beneath Camp Ono appears to be most affected by recharge from the smaller basins of
the San Bernardino Mountains to the north (e.g. Cable Creek). Accordingly, the alluvial
hydrologic unit beneath the Cajon Landfill may be periodically "flushed out" during
large recharge events, as large amounts of fresh water move through the system, while
the bedrock hydrologic unit below Camp Ono appears to be less dynamic."
"It appears that the relatively high PCE concentrations (up to 130 ng/L) detected in the
area down- gradient of the Cajon Landfill (Fault Block B) (EMCON, 1995) at the
beginning of the Source OU investigation in the late 1980s have migrated down-
gradient and been diluted within the Newmark Site. However, relatively high PCE
concentrations (up to 65 ng/L) detected in wells screened in bedrock beneath northern
Camp Ono and the area between Camp Ono and the Cajon Landfill (Fault Block B')
appear to have been relatively stable since 1995 (when the first of these wells was
installed). This contaminated bedrock unit may be slowly adding contamination to the
alluvial units to the southwest by fractured flow impeded by fault zone materials, but
the overall effect does not seem to include significant dilution of the contamination in
the bedrock unit below northern Camp Ono (Fault Block A). Additionally, relatively high
PCE concentrations detected in samples from alluvial well MW-132A (6 to 25 ng/L)
have not significantly decreased since its installation in summer 2000."
e) These concepts, when considered along with other interpretations included in the URS
report, suggest that PCE originating southwest of the Fault A or migrating across Fault
A/B, have been largely flushed out of the area and transported downgradient towards
the extraction wells.
e)
See General Response to Comment 2.
f) Residual PCE in the bedrock aquifer of the up-thrown block (northeast) of Fault A
appears to be pooling against the faulting related partial hydraulic barrier segregating
the juxtapose bedrock aquifer and alluvial vadose zone/aquifer.
f)
See Response to Comment 50 regarding DNAPL.
g) Groundwater elevation differences across Fault A appear to juxtapose saturated
bedrock against unsaturated alluvium at shallower depths (i.e., the depth of the screen
interval of CJ 10). The URS site conceptual model interprets the transfer of PCE laden
water from the up-thrown block to the down-thrown block, occurs across a seepage
face between the saturated bedrock fractures and unsaturated alluvial materials, with
g)
See General Response to Comment 2.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-27
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the mechanical effects of faulting creating a zone of decreased hydraulic conductivity
associated with dynamic movement along the fault. This concept is illustrated in Figure
4-1 of URS 2008a.
h) Groundwater elevation differences across Fault A appear to juxtapose saturated
bedrock against unsaturated alluvium at shallower depths (i.e., the depth of the screen
interval of CJ 10). The URS site conceptual model interprets the transfer of PCE laden
water from the up-thrown block to the down-thrown block, occurs across a seepage
face between the saturated bedrock fractures and unsaturated alluvial materials, with
the mechanical effects of faulting creating a zone of decreased hydraulic conductivity
associated with dynamic movement along the fault. This concept is illustrated in Figure
4-1 of URS 2008a.
This appears to be a more plausible site conceptual model then the one proposed in
the RI/FFS that doesn't consider the separation of the bedrock/alluvial groundwater
systems, interprets Fault A as an erosional feature, and interprets horizontal gradients
of 0.30 or 30% across Fault A as reasonable for a single aquifer system void of barrier
effects. The simplistic RI/FFS interpretation is used to justify flow path analysis and
contaminant transport modeling that do not consider the barrier effects of Fault A, and
are therefore flawed.
h) See General Response to Comment 2.
55
7
General
Comment
Focus on CJ 10
The highest concentration reported on the up-thrown block side of Fault A is found in CJ 10
and CJ 17, which are both located along the inferred location of Fault A and completed in
bedrock. CJ 16 is located south of the Former Camp Ono Hospital Area. When speaking of
the area of elevated PCE residuals, much of the focus has been on CJ 10, as this is the well
with the highest PCE concentrations. CJ 17 has historically had elevated PCE concentrations
relative to other Northwest Source Area monitoring wells, with reported concentrations
largely above MCLs through 2022 (range 3.5 to 48 mg/L). There are no other monitoring
wells located along Fault A between CJ 10 and CJ 17. It is possible that the area between
these wells is a continuous area of elevated PCE levels ponding against Fault A, and seeping
through into the vadose zone alluvium of the down-thrown fault block.
See General Response to Comment 2.
Section 7.2.4 Plume Development and Current Conditions discusses
plume conditions in both areas, which are described in the document as
the "former steel mill flow path" near CJ-10, and the "former hospital flow
path" near CJ-17. The two different flow paths were distinguished on
Figure 7.14, which provides a groundwater flow analysis. A monitoring
well installed between wells CJ-10 and CJ-17 would potentially help refine
the extent of residual contamination, however, it would not change the
mapping of the downgradient plume and thus would not have an impact
on the evaluation of alternatives in the FFS.
56
General
Comment
Figures 2- 7,
4-5, 7-5 and
7-14
Groundwater contour maps do not
include posted water level data.
It is a standard industry practice to include posted water level data used to prepare
groundwater contour maps on the subject maps. The four water level contour maps in this
report do not provide a posting of the underlying data used to prepare the water level
contour maps. This limits the ability of a reviewer to assess the interpolated groundwater
surface in context with the actual underlying data.
EPA concurs that it is standard industry practice to include posted water
level data used to prepare groundwater contour maps on the subject
maps. However, as can be seen on Figure 2.7 Regional Groundwater Flow
Direction in Bunker Hill Basin: October 2022 posting the groundwater
elevations on the map would greatly obscure the well locations used to
create the figure, as well as the groundwater isopotentiometric contours.
This is similar to the situation for Figure 6.9 Simulated Water Level
Contours Layer 1 and 3, December 2016 Extracted SBBA Model V4.1 in
the San Bernardino Basin Area Groundwater Flow Model Update Report
(Stantec 2023), where groundwater elevation data also are not included
on the figure.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-28
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Region 5 START V Contract: Document Tracking Number 2216a
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The data used to generate the groundwater isopotentiometric contours in
the RI/FFS are included in Table A.3 Newmark April and October 2022
Groundwater Hydrogeology Database.
57
7.2.2
48/3
Past investigations identified the
following primary suspected sites where
plume constituents may have been
released to groundwater:
• Former Camp Ono:....
• Cajon Landfill:....
• San Bernardino International Airport:...
As none of these locations were
determined to be sources of the
Newmark site PCE plume, an online
database search was performed in 2012
as part of the 1997 to 2012 3DVA effort.
This section dismisses Former Camp Ono as being a potential source of the Newmark Site
PCE plume with no defensible justification presented and is patently incorrect. This is a
complete reversal from the positions previously adopted by EPA and contrasts with
statements made by EPA during the August 23, 2023 public meeting. As described in the
cover letter transmitting these comments, EPA has historically recognized that Camp Ono is
the primary source of PCE groundwater contamination for the Newmark Site.
Subsequent analysis included in this section evaluates the Former Camp Ono Hospital Area
as a potential source of PCE observed in CJ 10 and CJ 17, which is a contradiction to the
premature conclusion that Camp Ono is not a source of PCE to the Newmark Site plume that
was presented in this subsection.
EPA acknowledges there was in an inadvertent error in the text which
indicated that former Camp Ono was determined to not be one of the
sources of the Newmark site PCE plume.
The RI/FFS was revised to correct this error and additional document
modifications were made to reinforce that the original source(s) for the
Newmark/Muscoy plume was from one or more areas within the
boundaries of the former Camp Ono and that the current residual
contamination sustaining the PCE plume in the Northwest Area is either
an original release from, or in the area of, a former steel mill (located
south and adjacent to the Verdemont Hills) and/or the former Camp Ono
hospital (located northeast of the Verdemont Hills). The ROD for the
Source OU reflects this same information.
58
7.2.3
51/3
The relationship between PCE in vadose
zone soil gas and in saturated zone
groundwater was also investigated at
well CJ-10, close to the former steel mill.
Well CJ-10 is screened over two depth
intervals: from 79 to 89 feet bgs (in
vadose zone colluvium) and from 135 to
145 feet bgs (in saturated zone bedrock).
Soil gas samples were collected from the
vadose zone adjacent to the upper
screened interval in May 2014 (Gilbane
2014) The increasing concentrations
indicated that elevated concentrations of
PCE were present at that depth of the
vadose zone adjacent to the well screen.
An estimated PCE pore water
concentration of 180 ng/L was calculated
from the maximum soil gas
concentration, which was five to seven
times greater than the two previous
concentrations of PCE in groundwater
collected from CJ-10 (27 and 35 ng/L).
The evaluation concluded: "soil gas
results suggest the potential presence of
a contaminant source in the vadose zone
in the vicinity of the CJ-10 upper well
screen, with concentrations moderately
greater than those in groundwater from
the lower screen." These results support
the interpretation that the elevated and
sustained concentrations in groundwater
PCE detections from soil gas samples collected in the vadose zone directly adjacent to CJ-10
do not provide conclusive evidence of the source of said PCE in soil gas contamination which
is inferred to be the former steel mill. The RI/FFS provides no justification for the statement
"these results support the interpretation that the elevated and sustained concentrations in
groundwater from CJ 10 are related to the former steel mill." The spread of high PCE
concentrations in groundwater in bedrock in the area between CJ 10 and CJ 17 is not
considered.
The conclusion cited from the soil gas report is that the elevated and
increasing concentrations from the upper screen soil gas sampling event
indicates a local vadose zone source because the equivalent pore water
concentration was significantly greater than groundwater concentrations
measured at any time in well CJ-10.
The RI/FFS text was revised as follows:
"These results support the interpretation that the elevated and sustained
concentrations in aroundwater from CJ-10 are potentially related to the
former steel mill buildina. which was located approximately 500 feet
uparadient of the well. An inspection of the former steel mill site
conducted bv the Countv of San Bernardino Department of
Environmental Health Services identified an overturned drum marked
PCE. an uncovered water well and a sump "which was apparently used
to catch waste fluids from operations." (Table 3 within EMCON1995).
The former Camp Ono hospital area is cited as the most probable source
of contamination at well CJ-17 because the former hospital area is directly
upgradient of well CJ-17. The former steel mill is cited as the most
probable current, residual source of contamination at well CJ-10 because
it is directly upgradient of the well.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-29
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from CJ-10 are related to the former
steel mill.
59
7.2.4
52/4 and
Figure 7-14
Figure 7.14 shows the wells with the
highest PCE concentrations in 2015
superimposed on a plot of advective
groundwater flow paths. Monitoring well
CJ-10 had the maximum PCE
concentration (29 ng/L) while CJ-17 had
the second highest at 11 ng/L. The flow
path analysis shows that PCE
concentrations from these two wells may
have been derived from two different
sources. Although a distinct source for
the PCE in groundwater at well CJ-17 has
not been identified, it may have
originated from within the former
hospital area (hereafter; the "former
hospital flow path").
As discussed in Comments # 50 through 55, the flow path analysis presented in Figure 7-14 is
overly simplistic and flawed as the barrier effects of Fault A are ignored. Therefore, the
inference that CJ 10 and CJ 17 originate from separate sources based on the presented flow
path analysis is unsupported. Groundwater contours presented by URS for Spring 2000 (URS
2008a; Figure 3-4) are suggestive of a flow path from the Former Camp Ono Hospital Area
through CJ 17 and then downgradient towards CJ 10. The URS site conceptual model
includes leakage from the bedrock aquifer in the vicinity of CJ 10/CJ 17 of the up-thrown
block across Fault A and into the adjacent vadose zone alluvium, thus providing a mechanism
for transfer of contamination across the fault partial barrier in a restricted manner. This may
be a more plausible explanation of the elevated PCE concentrations observed in CJ 6.
See Responses to Comments 2 and 58.
60
7.3.1
54/2
There are two flow paths of interest
within the Northwest Area:
• The "former steel mill flow path" which
extends from bedrock well CJ-10 (the
well with the highest PCE concentrations
in the Northwest Area), through well CJ-6
(screened across colluvium and bedrock)
to well CJ-3 (screened in alluvium). The
suspected original source area for this
flow path is the former steel mill, located
less than 500 feet upgradient from CJ-10.
• The "former hospital flow path" which
extends from CJ-17, the well that until
recently generally had the second-
highest concentrations in the Northwest
Area, to well CJ-16. Both wells appear to
be screened in unweathered bedrock.
The original source of the contamination
for this flow path remains uncertain;
however, it appears likely that it would
have been within the former hospital
area.
a) These hypothesized flow paths are the basis for some simplistic contaminant fate and
transport analyses presented in Section 7.3. The hypothesized flow paths extend
through Fault A and Fault B, as if the faults have no effect on groundwater flow. As
discussed in Comment 54, this is contrary to the interpretations advanced by URS in the
2008 Hydrogeological Investigation Report. Ignoring the effects of the fault is to a large
extent the fundamental basis of the contaminant Fate and transport modeling results
presented in Section 7.3. The simplistic models cannot quantitatively account for this
much more complex groundwater flow and contaminant transport system present in
the Northwest Area. Therefore, the results of these analyses are considered unreliable.
b) However, the underlying monitoring data for the Northwest Source Area are supportive
of the conclusion that residual PCE groundwater contamination remaining in the
Northwest Source Area does not pose a significant threat of further impacts to
downgradient supply wells.
See General Response to Comment 2.
a) The primary purpose of the contaminant fate and transport analysis
was to predict future concentrations in the vicinity of CJ-10 and to
support the hypothesis that the PCE concentration trend observed at
CJ-10 is best understood as being the result of a combination of
processes that includes matrix diffusion as well as advection,
dispersion and sorption. Flow path length, from the source to CJ-10,
is a variable, but the inclusion of faults located hundreds of feet
downgradient of CJ-10 would have no bearing on concentrations at
CJ-10.
b) EPA concurs with SBMWD's comment and support of the primary
conclusion the RI/FFS.
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A modified version of the existing
Northwest Area component of the site-
wide groundwater monitoring program
would be used to monitor the state of
the plume. Modifications would include
expanding the monitoring network to
include existing monitoring wells CJ-1A,
a) Based on Figure 13.2, the preliminary proposed monitoring program for the Northwest
Source Area would include 17 existing monitoring wells. A review of the Figure
indicates that some of the Northwest Source Area monitoring wells that have
historically been included in the monitoring program are not included in the Alternative
2 - MNA monitoring program. A review of the Alternative 2 cost estimate presented in
Appendix A indicates that this alternative includes preparation of a monitoring plan.
a) The basis for the design of the monitoring program will be explained
in the remedial design document which will provide a monitoring
plan inclusive of plans to rehabilitate or replace current monitoring
wells, as necessary.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
A-30
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Comment
No.
Section
Page/
Paragraph or
Item
Text and/or Comment Topic
Comment
EPA Region 9 Responses
CJ-2, CJ-3, and CJ-11, which are not
currently monitored. As discussed in
Section 7.5, adding these wells would
improve plume delineation by increasing
data density for any future 3DVA-based
remedy progress monitoring. Figure 13.2
shows the locations of monitoring wells
to be used for MNA groundwater
monitoring.
The rationale for the inclusion/exclusion of existing monitoring wells from the MNA
monitoring program should be clearly documented in the monitoring plan.
b) If SBMWD were to integrate the MNA monitoring program into their existing Newmark
Site monitoring program responsibilities, as discussed in the cover letter transmitting
these comments, SBMWD would need to be involved in the decision making process as
to which wells should be included.
b) Comment noted.
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Groundwater monitoring would involve
periodic groundwater sampling and
analysis at a frequency that is anticipated
to decrease over time.
Groundwater would be monitored semi-
annually for 2 years, then annually for 3
years, and then once every 5 years until
the PRG is attained.
The monitoring frequency for the MNA program should coincide with the frequency
established in the Consent Decree for site-wide monitoring wells, which is performed annual
basis.
EPA will consider monitoring frequency options when developing the
remedial design for the Northwest Area.
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The present worth costs for the three
groundwater remedial alternatives, from
highest to lowest, are as follows:
(1) Alternative 3 is $8.68 million; (2)
Alternative 2 is $1.24 million; (3)
Alternative 1 is $0. The cost estimate is
presented in Appendix F.
a) The cost for the Alternative 2 (preferred alternative) of monitored natural attenuation
appear to be low. The present worth costs for Alternative 2, as presented in Appendix F,
are as follows:
Capital Cost $141,500
O&M Cost $809,356
Contingency Cost (30%) $285,257
Total $1,236,113
Remedial Duration 10 to 47 years
b) The duration of the program (10 to 47 years) is not well constrained. Information
regarding the current condition of the monitoring wells, assumed
maintenance/replacement requirements are not provided, as is reasonable at this FFS
level cost analysis.
c) If EPA and SBMWD were to enter into discussions regarding the integration of the MNA
program into the Newmark OU/Muscoy OU RA monitoring program, a detailed cost
analysis would need to be performed by SBMWD and scope of work and underlying
assumptions would need to be more clearly defined by both parties.
a) The FFS does not stipulate the duration of the program; however, the
monitoring program must continue until the remedial action
objectives for the Source OU are met. The FFS estimates a range of
natural attenuation durations (10 to 47 years) to meet these
objectives and is justified in assuming a mid-range duration
(approximately 30 years) for the purpose of estimating cost in
support of alternatives analysis.
b) The expected accuracy of feasibility study cost estimates is -30% to
+50 percent, which implies that the actual cost could be higher or
lower than the estimated cost. For instance, if monitoring in some
wells is terminated in less than 30 years, then the estimated cost
could be higher than the actual cost. Moreover, the alternative
includes a lump sum contingency cost of $285,257 to cover
unforeseen costs (such as well replacement) which are not itemized
in the FFS cost estimate. A detailed cost estimate will be provided at
the time of the remedial design of the selected alternative.
c) Commented noted.
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
A-31
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Appendix A
California Department of Toxic Substances Control Concurrence Letter
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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Department of Toxic Substances Control
Yana Garcia
Secretary for
Environmental Protection
Meredith Williams, Ph.D., Director
5796 Corporate Avenue
Cypress, California 90630
Gavin Newsom
Governor
SENT VIA ELECTRONIC MAIL
November 15, 2023
Sharissa Singh, P.G.
Remedial Project Manager
U.S. Environmental Protection Agency
600 Wilshire Boulevard, Suite 940 Los Angeles, California 90017
Singh.Sharissa@epa.gov
CONCURRENCE WITH THE FINAL REMEDIAL INVESTIGATION AND FOCUSED
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE NEWMARK GROUNDWATER
CONTAMINATION SUPERFUND SITE, SOURCE OPERABLE UNIT
Dear Sharissa Singh:
The Department of Toxic Substances Control (DTSC) has reviewed the above-referenced
documents. The Final Remedial Investigation and Focused Feasibility Study (RI/FFS)
(dated August 9, 2023) and Proposed Plan (dated August 2023) were developed by Tetra
Tech, Inc. and provided to DTSC by the Superfund Division of the United States
Environmental Protection Agency, Region 9 (USEPA).
In 1980 several municipal groundwater wells were identified in San Bernardino with
volatile organic compounds (VOCs), primarily tetrachloroethylene (PCE) and
trichloroethylene (TCE). In 1989, the USEPA placed the area on the National Priorities
List as the Newmark Groundwater Contamination Superfund Site. Through investigation,
the Source Area Operable Unit (OU), which encompasses the entire area of
contamination and remediation, was divided into three areas: Northwest Area (source of
contamination to the following operable units), Newmark OU and Muscoy OU. In 2015,
the USEPA issued a Record of Decision (ROD) for the Newmark and Muscoy OUs. The
implemented remedy for those OUs is groundwater extraction and treatment prior to
inclusion in the domestic water delivery. Additional investigations, including soil and soil
vapor investigation, have been conducted since that time as well as ongoing monitoring
® Printed on Recycled Paper
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Sharissa Singh, P.G.
November 15, 2023
Page 2 of 3
of contaminated groundwater. Soil vapor investigation identified some areas of VOC
impact which could be sourced from groundwater but reportedly occur at levels which do
not represent an unacceptable risk, apart from locations at the Cajon Landfill.
Remedial Investigation and Focused Feasibility Study
The RI/FFS describes cleanup alternatives with the intention of issuing a final ROD
covering the remaining Northwest Area portion of the Source Area OU.
Groundwater concentrations in the Northwestern Area have been decreasing over time,
with only five wells currently exhibiting PCE concentrations above 5 micrograms per liter
(ug/L), which is the maximum contaminant level (MCL) for drinking water.
The RI/FSS describe the USEPA's preferred remedial alternative (Alternative 2) for the
Northwest Area which includes natural attenuation, with monitoring, and institutional
controls to prevent the installation of groundwater extraction wells within the boundary of
the defined OU. Groundwater modelling has indicated that MCL concentrations for PCE
will be achieved in all wells in approximately 10 to 47 years.
In a comment letter regarding the RI/FFS, dated July 6, 2023, as well as in a verbal
discussion on June 22, 2023, DTSC suggested that further vapor intrusion (VI)
investigations should be conducted.
Proposed Plan
The Proposed Plan (PP) presents the cleanup plan for the Northwest Area. The PP is
based on the results of USEPA's investigations, assessment of risk, and evaluation of all
cleanup alternatives presented in the RI/FFS. The report summarizes the site history,
environmental investigations, risk assessments, and remedial alternatives evaluation at
the site. It also describes the basis for choosing the Preferred Alternative. The PP
underwent a 30-day comment period between August 14, 2023 and September 14, 2023,
which was extended an additional 30 days by request from the public.
DTSC has no further comment and concurs with the RI/FFS and PP. DTSC looks forward
to reviewing the responsiveness summary and the future remedial design work plan for
the Northwest Area of the Source OU.
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Sharissa Singh, P.G.
November 15, 2023
Page 3 of 3
DTSC appreciates the USEPA's continued diligence in protecting public health and the
environment at this Site. If you have any questions, please contact the Project Manager,
Shelly Micucci via e-mail at michelle.micucci@dtsc.ca.gov, or you may contact her
supervisor, eileen.mananian@dtsc.ca.gov.
Sincerely,
A. Edward Morelan, PG, CEG
Branch Chief
Cypress Cleanup Branch
Site Mitigation and Restoration Program
cc: Eileen Mananian, M.S.
Unit Chief
Site Mitigation and Restoration Program
eileen.mananian@dtsc.ca.gov
Greg Neal, P.G.
Senior Engineering Geologist
Geological Services Branch
greg.oeal@dtsc. ca.gov
Michelle Micucci
Project Manager
Site Mitigation and Restoration Program
m ichelle.m icucci@dtsc. ca. gov
RizA. Sarmiento, Ph.D
Staff Toxicologist
Human and Ecological Risk Office
loveriza.sarmiento@dtsc.ca.gov
-------
Appendix B
Public Meeting Transcript
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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IN REGARDING:
NEWMARK GROUNDWATER
CONTAMINATION SUPERFUND SITE
SAN BERNARDINO, CA
SOURCE OPERABLE UNIT
Transcript of
PUBLIC MEETING
Taken on
AUGUST 23, 2023
Reported By:
BRENDA ELI A, CSR NO. 11830
REPORTERS • VIDEOGRAPHERS • INTERPRETERS
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
NEWMARK GROUNDWATER
CONTAMINATION SUPERFUND SITE
SAN BERNARDINO, CA
SOURCE OPERABLE UNIT
PUBLIC MEETING
REPORTER'S TRANSCRIPT OF ORAL PROCEEDINGS
WEDNESDAY, AUGUST 23, 2023
LOCATION:
HILTON GARDEN INN
1755 S. WATERMAN AVENUE,
SAN BERNARDINO, CA 92408
APPEARANCES:
SHARISSA SINGH
KIRBY BIGGS
JODY EDWARDS
CHIT CHRISTIAN
KAREN MILLER
SUZANNE PYATT
TOMMIE JEAN VALMASSY
Reported by: Brenda Elia, C.S.R.
Official Reporter, C-11830
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GROUNDWATER CONTAMINATION PUBLIC MEETING
AUGUST 23, 2023
WEDNESDAY, AUGUST 23, 2023
PUBLIC MEETING
MS. SINGH: Welcome, everyone. Good evening. Thank you
for attending EPA's public meeting to discuss our proposed
cleanup approach for the Newmark Groundwork Contamination
Superfund Site located in San Bernardino, California.
Before we start, I have a safety announcement. So there
are three exits in this room that you could potentially use in
the event of an --
MR. EDWARDS: They can't hear. That goes to the booth,
Ki rby.
MS. SINGH: All right. I'll start again. There are
three exits in the room in the event there's an emergency --
the two on your right and the one on the left. And I'm not
sure where it goes out to, but at least you can get out of the
room and be safe.
A couple of other announcements: There will be a court
reporter that will be recording all of my presentation, all of
your comments and statements. We are requesting that you state
and spell your name for the record, and I'll do that in a
mi nute.
And we also have a Spanish translator in the back in
that booth. This microphone is connected directly to them. So
if you need a Spanish translator, we have headphones that
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GROUNDWATER CONTAMINATION PUBLIC MEETING
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you'll put on and speak into the microphone and have a direct
translation at that time.
We also have an American Sign Language interpreter in
the event that you need one. Just let us know, and we'll be
able to provide that resource for you.
So, again, my name is Sharissa Singh. I'm the Remedial
Project Manager for this site, s-h-a-r-i-s-s-a; last name
Singh, S-i-n-g-h.
So as a reminder today, we are soliciting comments from
the public, and you can do so by using the comment cards that
are outside. They're available on the table outside. There
are also copies of the proposed plan and copies of this
presentation. So you can submit your comments today on these
postcards, comment cards, or send me an email or mail me your
comments as long as they're postmarked by October 13th. And
that's my mailing address.
And then on the bottom, you can also send them to
Georgia Thompson, she's our Community Involvement Coordinator.
She's based out of San Francisco and that's her contact
i nformation.
MR. EDWARDS: Sharissa, you might want to say you're
also taking oral comments.
MS. SINGH: Yeah, I was going to say that at the end,
but I can say it now.
MR. EDWARDS: Yeah, I just wanted to make sure.
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GROUNDWATER CONTAMINATION PUBLIC MEETING
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MS. SINGH: So we'll take oral comments at the end. So
at the end of my presentation, we'll take some clarification
questions regarding the presentation and then we'll open up the
floor for the official public public-comment period of this
meeting. As a reminder, the public comment period opened on
August 14th. But for today, if you want to leave verbal
comments, you can do so at the end of my presentation.
Then, the refreshments in the corner -- I just had a
cookie and it's pretty delicious. And there's lemonade, iced
tea, coffee, and water.
I would like to introduce my team that was -- I can't
even thank them enough for helping me, my manager and my
colleagues and my contracting team. And so I will introduce my
manager -- he's sitting right here -- Rusty Harris-Bishop. And
I will give him the microphone so he can state and spell his
name for the record, and then he'll hand it over to Kirby.
And then, Kirby, you can introduce your team.
MR. HARRIS-BISHOP: All right. It's Rusty, R-u-s-t-y.
My last name is Harris dash Bishop. H-a-r-r-i-s, dash,
B-i-s-h-o-p. I'm an Assessment Manager with the EPA and I'm
based out of San Francisco.
MR. BIGGS: Thanks, Rusty.
My name is Kirby Biggs. I'm an EPA headquarters
employee. My title is the National Authorization Operation
Program Manager. And my job is to provide technical support to
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GROUNDWATER CONTAMINATION PUBLIC MEETING
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our RPM, such as Sharissa. I've been doing that since the
program has been in operation since 1999. I've done 350 sites
and 480 studies supporting sites of this nature. And I've been
at the Newmark site -- or, we've been at the Newmark site with
my program since 2012, working on 3D visualization and
analysi s.
Let me introduce the rest of the team. Jody, do you
want to --
Oh, by the way, it's Kirby; K-i-r-b-y, B-i-g-g-s.
MR. EDWARDS: I'm Jody Edwards with Tetra Tech.
J-o-d-y, E-d-w-a-r-d-s. I'm a Principal Hydrogeologist and
Proto Manager with the company. And I've actually been the
project manager for all the support we provided to EPA since
the 2012 period. So I've been on the project the whole time.
And I have one of our folks with us. Chit, you want to
introduce yourself?
MR. CHRISTIAN: Sure.
I am chit Christian with Tetra Tech. I'm an
environmental engineer, and I was --
MS. SINGH: You need to speak up a little bit, Chit.
MR. CHRISTIAN: I was part of the team that worked on
the remedial investigation and the feasibility study and this
proposed plan.
MR. EDWARDS: You want to spell your name?
MR. CHRISTIAN: c-h-i-t, c-h-r-i-s-t-i-a-n.
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GROUNDWATER CONTAMINATION PUBLIC MEETING
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MR. BIGGS: And, Karen?
MS. MILLER: Hi. I'm Karen Miller; K-a-r-e-n,
M-i-l-l-e-r. Probably the easiest spelled name in the room.
And I'm the Regulatory Specialist with Tetra Tech, and I've
worked on the RI/FFS and the proposed plan.
MS. SINGH: Thank you.
And I would be remiss not to introduce our EPA attorney,
who is very instrumental in helping us get a lot of this work
done.
So, Suzanne.
MS. PYATT: Hi. I'm Suzanne Pyatt; S-u-z-a-n-n-e,
P-y-a-t-t, and I'm the site attorney for Newmark.
MR. BIGGS: p-y-a-t-t.
MS. SINGH: So a little bit of how the meeting is
structured: We went through the introduction and meeting
logistics. I'll go through the purpose of this meeting, a
little bit about the site history, some site overview. We'll
go into some details about the groundwork contamination and our
evaluation of the progress of the cleanup, some key findings.
We'll go through some of the results from our human and
ecological risk assessment, how we developed the alternatives
for the cleanup, what our preferred approach is for the
cleanup, and then what our next steps are going to be based on
all the information that we've reviewed.
So this is the Newmark Groundwork Contamination
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Superfund Site. It's outlined in this -- the entire area is
outlined by this red line. That's the entire site. The site
consists of three operable units: the Muscoy Operable Unit, the
Newmark Operable Unit, and the Northwest -- I'm sorry -- and
the Source Operable Unit. And so the Newmark and Muscoy
Operable Units already have remedial action in place that was
selected in 2015.
And so the purpose of this meeting is to discuss the
area outside of those two operable units that's remaining that
does not have remedial action associated with it, which is the
Northwest area. So all three of these areas are encompassed in
the Source Operable Unit. And I hope I didn't confuse
everyone.
It's the -- the entire site is known as the Source
Operable Unit, within that is the Newmark and Muscoy Operable
Units. And then remaining outside of those two, Newmark and
Muscoy Operable Units, is the Northwest area.
So there's a portion of the Northwest area that's
hashed on this map, and this is the historic location of the
former Camp Ono which was run by the Army in the 1940s; and
that's significant as we go through this presentation.
So back in the 1940's when Camp Ono was operational, it
was thought to be the source of the contamination for --
because of the dry cleaning operations. So if you look at
those old photos, the first photo on the upper left is an
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GROUNDWATER CONTAMINATION PUBLIC MEETING
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aerial view of what the camp looked like in the 1940's. And
then the three other photos are the stockpiles of the materials
that they dry cleaned at the camp. So those materials are
uniforms, tents, and other miscellaneous items that they would
dry clean and then store on the camp.
So this is a regulatory timeline of some key dates that
pertain to the site. In the 1980's, PCE contamination was
discovered in drinking water wells. And as a result, the site
was listed with EPA and put on our national priorities list in
1989. And because drinking water supply was affected, there
was a Record of Decision that was prepared and finalized in
2015, for the Newmark and Muscoy OUs; and those two operable
units are currently undergoing remedial action. And so the
only area that was left that wasn't addressed through a
regulatory action is the Northwest area of the Source OU. So
in 2023, based on all the data that we reviewed, EPA thought it
was appropriate to move forward with selecting a final remedy
for the Northwest area of the Source OU.
So as I said before, PCE was detected in drinking water
wells in the 1980's, and the -- so the primary contaminant was
Tetrachloroethene, and it's commonly known as dry cleaning
fluid. There's some other uses for that compound and that
chemical, but predominantly it was coming from the former Camp
Ono dry cleaning operations that occurred while the camp was
operational.
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So because there was contaminants found in the drinking
water supply, three water treatment systems were brought online
to address the public water supply and those three extract --
so those three systems consist of fourteen extraction wells,
and so they are depicted on this map. So you got the Waterman
Treatment System, the Newmark Treatment System and the 19th
Street North -- North 19th street Treatment System.
And all three of those systems are operated by the City
of San Bernardino Municipal Water District. And that -- those
three systems are responsible for providing your drinking
water. And the water that comes out of those systems is clean
and it is not contaminated and it is treated for public
consumption. So no one is drinking contaminated water in this
area.
So since the time we discovered -- or since the time the
contamination was discovered in these eight -- or sixteen
drinking water wells, there was a ton of investigations and
samples that were collected throughout -- throughout -- from
1997 to 2012. We collected more than $40,000 groundwater
samples, more than 250,000 chemical analyses in an effort to
evaluate what's happening at the Newmark site. We then took
that data and we put it into a computer program to visualize
and analyze what's happening underground and looking at it in
three dimensional.
So our initial evaluation was from 1997 to 2012. Then
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we did three subsequent updates: one from 2012 to 2015, 2015 to
2019, 2019 to 2020. And that's the data that we used to create
and evaluate the data for the remedial investigation and the
focused feasibility study. It's important to know that we
focused only on the Northwest area because that's the area that
has no remedial action associated with it and all this
information provide the technical basis for our proposed plan.
So I'll go through what our evaluations look like from
1997 through 2022, and what the data told us.
So in 1997, this is what the plume looked like under the
ground. So you can see up here that's the Northwest area.
That's where the former Camp Ono operations existed and so
that's identified as the Source area. And then you can see
that the plume moved downgradient and there is this -- these
are the shandin Hills. So it went around the shandin Hills and
split, and that's what it looked like 3D. So if you were
underground and looking at it in three dimensional, that's what
it would look like. But if you put on x-ray goggles and you
looked down from on top, if you were in an airplane and you
looked down and you were able to see through the ground, this
is what it would look like horizontally. And that's the
horizontal extent and that's the horizontal and vertical extent
of the plume.
So it's important to note that in 1997, we had about
9,000 pounds of mass of PCE in the ground. And another
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important note is that we're looking at PCE concentrations at
and above 5 micrograms per liter, which is our drinking water
standard. I think that's all we can say about that.
So from 1997 through 2012, you know, the site was
operating and time was going on. We looked at the site again
in 2012, and we collected samples and we looked at it through
our computer program, this 3DVA -- 3D-visualization Analysis,
and this is what the plume looked like in 2012. So as you can
see, there was a significant decrease in the footprint of the
plume. We went from about 9,000 pounds to about 820 pounds of
mass, still at and above 5 micrograms per liter, which is our
drinking water standard. And you can see on the map this is
where the three water treatment systems are and then that's
what's left in the Northwest area in 2012.
So we did another update in 2015, you know, looking at
the groundwater samples. We noticed further decrease in the
mass -- in the PCE mass at and above 5 micrograms per liter,
and we went from about 820 pounds of PCE to 45 pounds of PCE.
And visually this is what it looked like. That's what's left
in the Northwest area and that's what's left in the 19th street
treatment area at 5 micrograms per liter and above.
So then we looked again in 2019. And we went from 45
pounds of PCE mass to 23 pounds of mass in the Northwest area.
MR. EDWARDS: Total. Site total.
MS. SINGH: site total, at 5 micrograms per liter.
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And then in 2022 -- this is the best part. In 2022, we
looked at it again and we had a total of 6.4 pounds of mass
total in the Northwest area and the 19th street treatment area
at 5 micrograms --at and above 5 micrograms per liter.
So from 1997 to 2002, we went from 9,000 pounds to about
6-and-a-half pounds of mass that's left in the groundwater,
which is about 99.9-percent reduction in contaminant mass. And
a major finding from all of this data evaluation is that the
PCE that's left in the Northwest area is not a continuing
source of contamination for the treatment areas located further
downgradient at and above 5 micrograms per liter.
So because -- because the other two operable units,
Newmark and Muscoy, already have remedial action, we focused in
on the Northwest area. And in the Northwest area there is only
about 1.97 pounds of mass left out of the 6-and-a-half pounds
total at 5 micrograms per liter and above.
And so the meeting today is to discuss our preferred
cleanup approach for the 1.97 pounds of mass that's left in the
Northwest area, because the other two operable units are
currently undergoing remedial action.
So because there's still groundwater that exhibits
contamination that's above our drinking water standard, we
looked at the risk -- risk to human health and risk to the
environment. And so our risk evaluation determined that
because no one is being exposed to contaminated groundwater,
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there is no current risk to human health. No one is drinking
the water in the Northwest area.
We looked at risk associated with vapor intrusion. And
vapor intrusion is the process by which contamination from the
groundwater goes through the soil and up into buildings via
piping or cracks in the foundation or conduits that extends
down into the ground. And so we evaluated historical data that
was collected and determined that vapor intrusion is not
occurring in the Northwest area, because groundwater in the
area is generally greater than 100 feet below the ground
surface. So there's a huge -- so there's a significant
distance between the water table and the surface. It's 100
feet; so it's unlikely that vapors are getting up through the
100 feet of material to get to the surface.
Soil gas concentrations in the historical samples that
we evaluated, as you get to the surface, those historical
samples decrease. The concentrations of contaminant decreased
as you got to the surface. As I showed you before, the --
there's an insignificant amount of contamination that's left in
the Northwest area, 1.97 pounds of mass. And then there are no
residences in the Northwest area. It's a predominantly
industrial area. And so where the historical samples were
collected, there was -- there are no residences in that area.
So then we looked at risk to the environment. And
because there's no evidence of shallow soil contamination,
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groundwater does not impact surface water and the area is
highly industrialized so there's -- you know, the wildlife is
at a minimum over there. There's no risks to plants and/or
animals in the Northwest area. But because there's still a
small amount of groundwater that is above our drinking water
standard, we identified a need to take remedial action in the
Northwest area and also to protect the future use of the
aquifer in the Northwest area as a potential source of drinking
water.
And so we developed a scope and role for the proposed
remedy that we're sharing with you tonight. And the scope and
role is that the final remedial action for the Source OU will
only address the Northwest area of the Source Operable Unit.
And the cleanup approach does not affect any decisions that
were made -- any remedial actions that were made for the
Newmark and Muscoy OUs because it is under an existing remedial
action and what we're looking at in the Northwest area is
completely separate from that action.
And so, you know, we have to go through this process and
the -- you know, we did the remedial investigation, the
feasibility study based on our evaluation of the data that we
collected, and right now we're in the proposed plan phase.
And, you know, after we solicit comments from you at the end of
the public-comment period and we -- you know, we'll collect
them and respond to them in a Responsiveness Summary and we'll
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draft a Record of Decision. And then from the Record of
Decision, we'll move into the remedial design and
remedial-action phase and then site completion based on the
performance of the remedy.
So, again, this meeting in this proposed plan is only to
discuss the remedial action for the Northwest area of the
Source Operable Unit. The other two operable units are
currently undergoing remedial action; that's stated in the 2015
Record of Decision. And so the area that we're discussing
tonight is limited to the Northwest area.
So after we've identified the scope and the role of the
proposed remedy, we've gotta come up with goals that we would
like to meet in order to protect human health and the
environment. And the two goals that we've identified is
restoring the aquifer back to its beneficial use, which would
be drinking water standards, and then prevent human exposure to
the minimal amount of PCE that's left in the groundwater above
our drinking water standard.
So we evaluated some remedial technologies and came up
with these three alternatives that we thought were best suited
for this site:
Alternative 1 is no action.
Alternative 2 is monitored natural attenuation,
institutional controls, and vapor intrusion assessment.
Alternative 3 is in-situ treatment with groundwater
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monitoring, institutional controls, and vapor intrusion
assessment.
And I'll go into details about what these mean as we go
into the slide.
Alternative 1 is no action. So it's basically a
baseline for -- we're required -- the EPA is required to
evaluate a no-action remedy, which is basically what would the
site look like if we did nothing. It provides a baseline for
all the other alternatives to compare it against. So that's
why it's always going to be any remedy that we evaluate.
So Alternative 2, monitored natural attenuation. It's
basically a natural process of the ground -- of the
contaminants in the groundwater breaking down by a variety of
different mechanisms or different reasons.
MR. EDWARDS: May I make a comment?
MS. SINGH: Yes.
MR. EDWARDS: So basically in addition to the pumping
that's been going on, the rest of the plume in the other area
has been — the concentration has been decreasing by natural
attenuation that's abiotic, when you look at the contaminant
profiles —
MS. SINGH: But what does that mean?
MR. EDWARDS: Abiotic means no biological -- it's not
degradation. It's actually natural attenuation where
dispersion and natural decay of chemistry. That's why.
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MS. SINGH. So by natural processes, over time the
contaminants are going to -- the concentrations are going to
reduce over time. You'll see this reduction in the
concentrations over time.
Institutional controls is when we restrict groundwater
use in the area because there's minimal amount of contamination
that's left above our drinking water standard.
And because there was some historic samples that, you
know, were collected in the past in this area for vapor
intrusion, we just want to confirm what those samples -- the
data from those samples and so we would do a vapor intrusion
assessment and evaluate our next steps for vapor intrusion in
the area.
Alternative 3, in-situ treatment with groundwater
monitoring with institutional controls and vapor intrusion
assessment. So for Alternative 3, we would inject some type of
chemical or bacteria into the ground to help eat up and destroy
some of the contamination in the groundwater. The groundwater,
again, would be monitored until we met our cleanup goals, and
we would also restrict the use of groundwater in the area as
well as conduct a vapor intrusion assessment in the Northwest
area.
So we've -- as part of our process, we have these
evaluation criteria that we -- that we look at to see how our
alternatives are racked and stacked against each other.
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The first two alternatives we are required to meet --
they are the threshold criteria. And we are required to
protect the overall health -- the overall human health in the
environment, and we are required to meet all of our regulatory
standards. That's nonnegotiable.
Criterias 3, 4, 5, and 6 are balancing criteria. That's
where we rate. We look at, you know, how easily can we
implement this? what's the short term effectiveness? what
does it look like in the long term and what does it look like
if it's a permanent remedy? How much is it going to reduce the
contamination? You know, is it going to immobilize it? So
these are the questions while we're looking at these
alternatives.
And then, of course, 7 is the cost. How much is it
going to cost us?
And then 8 and 9 are state and community acceptance. We
look at it; we evaluate, you know, how does the state, our
regulatory counterpart feel about it? How do you guys feel
about these remedies that we've proposed? And then we'll make
modified, you know -- we'll modify all alternatives based on
your statements and comments.
So here's the summary of how we compare these three
alternatives: The no action obviously didn't rack and stack
with our threshold criteria.
Monitored natural attenuation and in-situ treatment, as
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you can see, they were given stars from -- one star from poor
performance against the criteria all the way to four stars,
which is excellent performance against the criteria.
And then we looked at the cost and we looked at the time
frame. And so this is the approximate costs of the
alternatives that we screened from 1. -- from nothing to 1.2 --
1.25 million to almost 10 million dollars for Alternative 3.
And so based on all the data that we collected and the
balancing criteria that we used, threshold criteria, EPA
determined -- or EPA thinks that Alternative 3 is the best
approach, which is the monitored natural attenuation,
institutional controls, and vapor intrusion assessment. We
felt that that was the best alternative and cleanup approach
for the Northwest area of the Source OU. And that's why you're
here tonight so that we can talk about it, and we provided
additional details in our proposed plan -- sorry. Alternative
2. Alternative 2.
Did you get that, Court Reporter? Alternative 2.
So monitor natural attenuation, like I said, is just the
natural decline of contaminant concentrations. Nature is doing
the work for us basically, and we would implement a monitoring
program. Wells would be added or removed from the program
based on additional evaluation. This is the monitoring well
network that currently exists in the Northwest area that we
would be focusing on.
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And the other part is institutional controls. And this
black line is the PCE plume that's left in the Northwest area.
And so the institutional controls would be this -- or the area
that would be restricted for groundwater use is defined by this
red outline. And then you can see a zoomed-out version of it
in this inset over here.
MR. EDWARDS: The one thing for that shape is because
that's where the county and the city's boundaries all intersect
with each other. It's jurisdictional related.
MS. SINGH: Yeah. So we had to get -- we had to contact
the city and the county and work out the boundaries with them.
So that's why the boundary of the institutional control is
larger than the area of the -- the area that's contaminated --
or the area that has residual contamination.
So here we are with the next steps. This is a timeline
from the point we released the proposed plan describing our
preferred cleanup approach. It was released on August 14th.
That started the 30-day public-comment period, but we received
your request to extend the public comment period 30 days.
Today is the community meeting, August 23rd. And then so
because we received the extension -- the request for extension,
the public-comment period is now going to end on October 13th
instead of September 13th. And then our target date to
finalize the Record of Decision selecting our final remedial
action for the Northwest area of the Source Operable Unit is
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November 10th.
So I'm going open up the floor for any questions,
clarification questions that you may have regarding my
presentation. And then after that we'll officially open the
floor for the public-comment period of this meeting.
I'm done. Any questions about my presentation?
Yes, ma'am?
MS. HUNT-RUBLE: I live in Muscoy. My name is Jane
Hunt-Ruble; J-a-n-e; Hunt, H-u-n-t, hyphen, Ruble, R-u-b-l-e.
And I've been involved in this since the '90's. And, in fact,
they did testing in front of my house and my block. And I was
curious about, this started -- it started in the '80's.
People started noticing the contaminants. But I'm
concerned about the map -- I couldn't really clarify where the
Northwest area is in regard to, like -- it looked like Cajon
Boulevard. Does it go up to Institution Road or Palm Avenue?
'Cause I noticed there's Cajon wash there, too; so I was just
wondering what area, 'cause I can't tell on the map. I think
that's Cajon Boulevard. I can't read that.
That's Cajon Wash right there. And I was wondering -- I
can't see from here but -- so I was just wondering what the
area is -- what that one street is. But anyway -- if I can see
it better. I can't see that far away.
That's the only -- what remedial action did you take on
the other two, you know, like the Muscoy plume? 'Cause I
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forget. I got all that info at home.
MS. SINGH: So the other two operable units are --
they're currently groundwater extraction systems --
MS. HUNT-RUBLE: Yeah, that's what I --
MS. SINGH: -- that are operated by the City of
San Bernardino Municipal Water District. Yeah.
MS. HUNT-RUBLE: Another question I have is risk
assessment. But after, you know, the '90's, when it was
discovered and they were doing something about it -- but I've
lived in Muscoy since 1965, and I'm wondering what about us
people? Of course since then there's been a lot new
developments and people moved in there. So my question is how
can you tell -- you said there's no risk, you know. But --
there's new people. But what about us old-timers that were
drinking this water probably back then, in the '60's and the
'70's and the '80's? I mean, what possible --
MR. HARRIS-BISHOP: Yeah, it's --
MS. HUNT-RUBLE: I was wondering about that. I said,
"Hmm."
MR. HARRIS-BISHOP: It is. It's a really great question
and it's really hard to answer, because we don't know what
water you were drinking, if that water had contamination. A
lot of our science, you know, we didn't have -- the Safe
Drinking Water Act didn't exist back then. California State
had regulations to monitor for certain things, but a lot of
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these chemicals we weren't looking for in drinking water. We
were looking for typical contamination that people were
concerned with like bacteria. That's why we chlorinate our
water.
It's hard for us to be able to go back because we don't
know what you were looking at. So all our risk assessment can
do is look forward. If we had data from previously, we have
health assessors in -- the California Department of Public
Health has epidemiologists who can look at and see if they
could kind of back calculate what your exposure was. But
without knowing what was in the groundwater at the time and if
you were drinking it — that's the most important thing. Just
because it's in the ground, it may not be -- you may not be
exposed to it. So we just don't know. It's a frustrating
answer but —
MS. HUNT-RUBLE: 'Cause I live in the northern part of
Muscoy and we have — I was surprised 'cause I thought we'd be
on Muscoy mutual. But above 1st Avenue -- going to 1st Avenue
we're on San Bernardino City water. So that's what we were
always on.
MS. SINGH: So the important thing is you're not
drinking the water right now. The water right now is being
treated by the city.
MS. HUNT-RUBLE: Right. But what kind of illnesses
could you get from it, you know, if you drank -- I have a
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thyroid problem now in the past ten years, but I was just
curious. I thought perchlorate was involved also in the Muscoy
piume.
MR. HARRIS-BISHOP: I don't know. It was detected
but --
MS. SINGH: It was detected but it's not --
MR. HARRIS-BISHOP: We can put you in touch with
somebody who's more of a health professional to let you know
what the health effects are of the exposure to PCE. I don't
know myself. I'm not a medical person. I'm an engineer. But
we do have people --
MS. HUNT-RUBLE: Good thing you didn't say just an
engi neer.
MR. EDWARDS: Rusty, you want to clear -- so the
chemical that you referred to before is Perchlorate, which is
actually mostly related to explosive compounds. It's
actually -- there's an alternative term for
Tetrachloroethylene, which is Perchloroethylene. That's
probably the one you're thinking of, which is a totally
different chemical than Perchlorate, which has never been --
MR. HARRIS-BISHOP: That's what TCB is. We call it
Tetrachloroethylene, Perchloroethylene.
MS. HUNT-RUBLE: I know all these.
MR. HARRIS-BISHOP: I don't know why chemists can't
settle on one name.
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MS. HUNT-RUBLE: I know.
MR. EDWARDS: But it would be easy to confuse it with
Perchlorate, but it's a totally different compound.
MR. HARRIS-BISHOP: if an engineer was writing these,
you would have one word for it. But we can certainly get your
contact information.
MS. HUNT-RUBLE: Yeah, 'cause I was curious about that,
you know. I said, what about those of us that lived there
before they discovered it?
MR. HARRIS-BISHOP: Exactly.
MS. HUNT-RUBLE: Some of them passed away already,
especially the lady that discovered where her dad used to work
at Camp Ono, and he would direct it after World War II and they
would just dump everything into the ground. So she helped the
EPA back in the '90's where they were wondering where it was
coming from. But she passed away two years ago. So she really
appreciated this.
Wei 1, thank you.
MS. SINGH: Yeah, of course. Thank you.
Anybody else? Questions regarding my presentation?
Yeah, sure.
MR. OJO: Thank you. My name is Adekunle Ojo.
A-d-e-k-u-n-1-e. That's what my first name is,
A-d-e-k-u-n-1-e. And the last name is Ojo, O-j-o.
My question is simple. And the question is: what
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happens if you're drinking water standard for any reason goes
below 5 milligrams per liter in the future?
MR. HARRIS-BISHOP: So part of the Superfund Program
that this is, is as long as there's contamination that still
remains, we are required every five years to evaluate how that
remedy is performing. In fact, we are finishing up I think the
fourth or the fifth five-year review right now for the Muscoy
and Newmark remedies. So we have to look at that and see if
anything has changed -- do we know more about the toxicity of
the chemical? Has the regulatory standard changed? And are we
still protective?
If they do change the drinking water standard, either
California or EPA or the federal government changes the
standard, we will look to make sure that we're still protective
of human health and the environment. And because this is being
served as municipal drinking water supply, you know, it's
subject to way more than just the requirements we have for the
Superfund Sites. So the two remedies that are currently in
place will continue to meet all state and federal drinking
water standards as well as requirements of the Superfund Site.
So for this remedy, if we determine that if, say, the
level -- the PCE drinking water standard goes to 2.5, then we
would continue to monitor to make sure that that plume gets
down below 2.5 before we say that it's done. And as long as
there's contamination in the ground, we'll probably be
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monitoring. And then the municipalities are required to
monitor, you know, around their supply wells to make sure
nothing is coming in to their drinking water system that can
impact the drinking water supply.
MS. SINGH: Anybody else? Clarification questions for
the presentation?
(No response.)
I don't know if that's a good thing or a bad thing. So,
then, at this time we'll take a -- like a five-minute break.
Then we'll open up the floor officially for your comments for
this meeting tonight and then we'll go from there. Thank you,
guys.
(Break.)
MS. SINGH: So welcome back after this five-minute
break. Right now we'll begin the official public-comment
period for this meeting. As a reminder when you come up to
make your comment and/or question, please state your name if
you would like for the record. Say it and spell it if you
would like for the record so that we're able to capture it.
As a reminder, if you do have a question, we won't be
answering your question at the moment. It would be considered
a comment and then we would respond to it in our official
Responsiveness Summary at the end of the public-comment period.
And also as a reminder, there are comment cards outside.
If you feel like you don't want to talk today, you can feel
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free to write your comments down and drop it in the box or you
can mail it back to me, whatever your preference is.
So with that, I will put the microphone back and I will
be right here cheering you on.
MR. EDWARDS: So I'll put this out here so people can
walk up if they want, if they choose to. There you go.
MS. DYER: Thank you. My name is Heather Dyer;
H-e-a-t-h-e-r, D-y-e-r.
I serve as the CEO General Manager of the San Bernardino
Valley Municipal Water District, the regional wholesale agency
responsible for ensuring a reliable safe supply of water to the
people of this region. I also serve as the Court-Appointed
Water Master on behalf of the San Bernardino parties of our
1969 adjudication and judgment.
First, I'd like to thank you for providing an extension
to the public-comment period This is a substantial document and
we appreciate the time for our staff to conduct a thorough
review of the information before coming to a decision on our
position regarding your conclusions.
Second, I would like to reiterate that the groundwater
aquifer is a critical shared resource to millions of people
throughout our region and its long-term health, sustainabi1ity,
and safety are of utmost importance.
We urge you to take a precautionary approach to the
science and to your decision regarding this project and your
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commitment to our safe water supply.
Thank you for the opportunity to comment.
MR. GUERRERO: Good evening. My name is Miguel
Guerrero; M-i-g-u-e-1, G-u-e-r-r-e-r-o.
I am the General Manager of the City of San Bernardino
Municipal Water Department. This evening my comments will
cover several issues raised by EPA's proposed plan to address
the Source Operable Unit of the Newmark Groundwater
Contamination Superfund Site.
Let me start by thanking EPA for its confirmation of a
critical piece of the 2005 settlement with the Army and the
EPA. Specifically, the water department appreciates
confirmation that treatment of the drinking water to remove PCE
and TCE must continue as part of the Consent Decree work for as
long as necessary to comply with state drinking water permit
obligations of 0.5 micrograms per liter.
Under the terms of the 2005 Consent Decree with the
Army, if EPA were to prematurely declare the work finished, the
state water supply permit would require the city's costly
treatment obligations for the Army's PCE contamination to
continue, even as the water department had to return large sums
of money to the United States. That outcome would be
especially intolerable and unfair for this environmental
justice community. Water Board Commissioner Johnson will
address the environmental justice issues in more detail. The
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water department appreciates EPA's public confirmation that the
work is not finished at this site until drinking water
treatment at the key remedial wells is no longer necessary
under our permits.
For the record, the water department is operating 14
production wells that are connected to treatment plants built
to remove the PCE and TCE contamination caused by the Army.
These efforts have made substantial progress reducing the mass
of contaminants in the aquifer since the Consent Decree was
entered in 2005.
The water department recognizes this progress and plans
to go to the state's division of drinking water soon to ask
that the permit provisions for three of these wells be amended
so treatment is no longer required. The basis for this
amendment request is the consistent production of water that,
even without treatment, already meets the 0.5 micrograms
per-liter standard. Last month, the water department submitted
its technical memorandum to EPA and to DTSC concerning the
proposed amendment. We look forward to working with EPA and
DTSC in the cooperative effort.
The water department agrees with the EPA's
recommendation for the remedy of contamination in the Northwest
portion of the site, particularly in and around the Army's
World War II base called Camp Ono and the base General Depot.
These Army activities contaminated the Bunker Hill Aquifer.
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EPA has reported that PCE contamination remains about EPA's
groundwater standard in a relatively small area that includes
part of the Cajon Landfill and the old Army base. EPA's
proposed plan recommends that the remaining contamination be
addressed through monitored natural attenuation.
The water department believes that, in this situation,
monitored natural attenuation is reasonable from the
engineering, environmental, and cost standpoints. The
remaining mass of contaminants in and near the old Army base is
small, is located several miles distant from the current
production wells, is too deep to pose a vapor hazard to people
in surface structures, and will be tracked by the proposed
monitoring well program. If PCE migrating from this location
requires additional action, the monitoring will allow EPA and
DTSC to take timely steps to protect the water supply.
Under the 2005 settlement, using federal money, the
water department has for the last 18 years undertaken the
treatment and monitoring work needed to halt the advance of the
contaminant plume while providing safely treated water to the
San Bernardino community.
Using a similar approach, the water department is
willing to consider undertaking the required monitoring under
this proposed plan, provided that the United States makes a
lump sum payment to the water department for this additional
work. The water department is already doing extensive
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monitoring and reporting as part of its existing work which
makes the water department a logical candidate to address the
additional work and to do so efficiently.
Under the 2005 Consent Decree, the Army has not been
released from its liability for response costs incurred after
August 14, 2023, the date of publication of the proposed plan.
Given the limited scope of work involved and the comparatively
modest funding needed, the most efficient way to address this
additional work may be to amend the Consent Decree so that
additional federal funds are provided for the water department
to defray the additional work in exchange for appropriate
covenants not to sue for the parties.
while the water department agrees that with EPA's
recommendation for monitored natural attenuation to complete
the work for this site, the water department will be submitting
technical comments concerning the RI/FFS.
The water department's initial review of that study
suggests that there are significant contradictions between the
RI/FFS and prior work done by EPA's contractors, particularly
URS and its 2008 work concerning the location of fault lines
near the Cajon Landfill and the Verdemont Hills, where
contaminants are more concentrated. Especially where the
recommended remedy is monitored natural attenuation, the water
department believes groundwater flow direction, groundwater
barriers, and related issues will need to be more carefully
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addressed than the RI/FFS has done. Otherwise, the design of
the monitoring well network, the placement of additional
monitoring wells, and the monitoring frequency will be
incorrect, potentially requiring costly corrections.
The water department is also concerned that the RI/FFS,
judging by the Administrative Record Index, completely ignored
substantial evidence about Army activities potentially causing
the contamination while failing to seek any additional
information from the Army about activities at the base between
the September 1945 surrender of Japan and the closure of the
base in 1947.
The water department will be submitting substantial
additional evidence it has gathered about the Army's activities
that EPA's contractor never sought but which suggest that
contaminants may have resulted from other activities generating
liquid wastes in the former hospital parcel, upgradient of the
area of most elevated remaining contamination.
The water department appreciates the EPA's extension of
the written comment deadline until October 13th. The RI/FFS
and the studies it relies upon are complex and require careful
review to make helpful comments regarding the groundwater flow
direction and the potential sources of contamination, which are
important factors in designing the appropriate monitoring
network.
While most of our procedural concerns are addressed by
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the extension for water agencies and the public to comment, the
water department asks that the factual portions of the 2001
SAIC study be posted promptly, given their importance to EPA's
interpretation of groundwater flow in the area near the
landfill and the old Army base. Our counsel will submit the
legal basis for EPA to release the factual portions of the
document in a letter later this week.
Thank you very much for your time and opportunity to
comment. We look forward to EPA's responses.
MS. SINGH: Thank you for your comments.
MR. JOHNSON: Good evening. I am Commissioner Rikke Van
Johnson. Rikke, R-i-k-k-e; middle of Van, v-a-n; last of
Johnson, J-o-h-n-s-o-n. And I have served on the Board of the
City of San Bernardino Municipal Water Department. I
previously served three terms as city counselman for the city
of San Bernardino and have lived in the city for over 55 years.
I have been a long-time resident as well as represented
the west side community, which has been historically
marginalized when dealing with government entities. For
example, in 1959 when the 1-215 Freeway was constructed, the
on-ramps and off-ramps led to the east side of the freeway.
Many businesses on the west side community faced economic
starvation until new on-ramps and off-ramps were completed in
2014.
In 2000, the Hub Project on San Bernardino's south side
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was launched to develop 255,000 square feet of commercial
space. It was funded by using census data obtained from the
west side community. But once the funds were procured, they
were shifted to the Hub Project on the south side.
with that being said, the water department is pleased
that the U.S. Environmental Protection Agency recognizes that
the city, particularly the west side where much of the
remediation is being done, is an environmental justice
community, meaning one where people are of very modest means
and predominantly from ethic minority groups. I am told that
the EPA's remedial investigation for the Source Operable Unit
recognizes these facts and provides detailed statistics to
support classification as an environmental justice community.
Figure 2-11, in that study, notes that 49 percent of the
people in the Source Operable Unit area are low income, 88
percent are people of color, and that median per capita annual
income is $20,819. For comparative purposes, the Census Bureau
reports that the median per capita annual income for the State
of California is $41,276, roughly twice the San Bernardino
fi gure.
In real terms, anyone watching people pay their water
bills in San Bernardino will recognize that many residents are
of very limited means. They come to the water department
offices to pay their water bills in cash because they do not
have the means to maintain checking accounts or credit cards.
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Under California law, our water rates must reflect the
true cost of providing the water, regardless of the wealth or
poverty of our ratepayers. Watching lines of underprivileged
people paying their water bills in cash reminds the Water Board
to pay very close attention to what we spend to provide safe
water to our residents. Thus, we are acutely sensitive to the
cost the water department has incurred and continues to incur
to address the Newmark Groundwater Contamination site.
It took over eight years of litigation, from fall 1996
through March 2005, to bring the Army to settle its liability
for the Newmark Groundwater Contamination site, even though EPA
had publicly stated starting in 1993 that the Army was the only
source for that contamination. In that settlement, the water
department gave up a claim for roughly 10 million dollars in
past treatment and related costs incurred starting in the
1980's and going up to the start of the litigation.
Also in that settlement, the water department agreed to
incur substantial ongoing cost increases for energy and related
expenses resulting from the reconfiguration of the city's water
system to accommodate the locations of the EPA designed
extraction wells and treatment plants.
Put simply, the city had previously tried to maximize
water production from the wells in highest locations, so that
water distribution relied on gravity rather than pumping up
hill. Because of the spread of the Army's contamination under
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the upper half of the city, when the treatment systems came
online to stop contaminate migration, the production wells had
to be located at much lower elevations than desirable from a
distribution standpoint. In some instances, the wellheads are
nearly 1,000 feet lower than some customers the water
department serves. At maximum production, the water department
is pushing over 10,000 gallons per minute of water far up hill,
with substantial energy costs running into the millions of
dollars over the life of the remedial work. Because of the
Army's contamination, the city's ratepayers, from the
wealthiest to the poorest, are bearing that cost without any
reimbursement from the settlement.
As EPA's studies helps make clear, our city is the
perfect example of an environmental justice community, one that
has absorbed an unfair burden of the environmental
contamination. In our case, that includes two major Superfund
Sites resulting from the actions of the U.S. Military.
One is the Norton Air Force Base, which contaminated the
aquifer in the southern portion of this city with chlorinated
solvents apparently from aircraft maintenance and repair as
part of flight line operations.
The Air Force closed the base in 1994, taking away the
good jobs but leaving behind the contamination. To its credit,
the Air Force took responsibility for the contamination and has
been working to address and contain it.
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As a board member at that time for the San Bernardino
International Airport, I was very thankful that the Air Force
took ownership of the contamination problem.
The other major Superfund Site, the Newmark Groundwater
Contamination site, was not addressed until the water
department spent over eight years in court to bring the Army to
take partial responsibility for that contamination. Given
EPA's conclusions about the Army being the source of
contamination, the water department never should have had to
file or pursue that litigation to protect its residents from
the Army's contamination.
We ask that the EPA bring the Army back to the table to
pay for the remaining Source Operable Unit work outline in
EPA's proposed plan, work the water department is willing to
undertake if the Army will pay for it. The water department
believes that it can do the work so more efficiently than an
EPA contractor as part of the ongoing work that the water
department is already doing to protect the remedial system and
monitor the movement of the Army's contamination.
In closing, the residents did not have the capability
nor the means to contaminate this area. Therefore, the Army
needs to own up to their responsibility in this matter.
I thank you for your time and your consideration.
MS. SINGH: Thank you for your comments.
Anybody else? We'll maybe leave it open for, like, a
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couple minutes — another five minutes in case you change your
mi nd.
MS. VALMASSY: Can we pause the record for five minutes
so she does not have to --
MS. SINGH: Of course.
(Pause in meeting.)
MS. SINGH: Well, I think we can call it. If anybody
else — going once, twice, three times.
I want to thank you all for coming -- did you have --
oh, all right. I would like to thank you all for coming and
spending the evening with us. We really appreciate your
comments and your support and your questions. And we will
continue to keep the public-comment period open until
October IB, and then we will respond to your comments and our
Responsiveness Summary.
Thank you, al1.
(Proceedings were concluded.)
-oOo-
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
NEWMARK GROUNDWATER
CONTAMINATION SUPERFUND SITE
SAN BERNARDINO, CA
SOURCE OPERABLE UNIT
I, Brenda Elia, Official Reporter of the State of
California, for the County of San Bernardino, do hereby certify
that to the best of my ability, the foregoing pages, 2
through 40, comprise a full, true, and correct transcript of
the proceedings held in the above-entitled matter on
August 23, 2023.
REPORTER'S
CERTIFICATE
Dated this 29th day of August, 2023.
Brenda Elia, CSR No. 11830
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Appendix C
San Bernardino Municipal Water Department's Letter
Dated October 13, 2023
Newmark Groundwater Contamination Superfund Site
San Bernardino, California EPA Region 9
Final Record of Decision
Region 5 START V Contract: Document Tracking Number 2216a
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CITY OF SAN BERNARDINO
MUNICIPAL WATER DEPARTMENT
CITY OF SAN BERNARDINO
WATERBOARD
TONICALLICOTT
President
Commissioners
WAYNE HENDRK
DAVID E. MLYNARSKI
RIKKE V. JOHNSON
THOMAS BRICKLEY
"Trusted, Quality Service since 1905"
MIGUEL J. GUERRERO. P.E.
General Manager
ROBIN L.OHAMA
Deputy General Manager
STEVE R. MILLER
Director of Water Utility
KEVIN T. STEWART. P.E.
Director of Water Reclamation
JENNIFER L. SHEPARDSON
Director of Environmental &
Regulatory Compliance
CYNTHIA J. MOUSER
Director of Finance
October 13, 2023
Delivered Via E-Mail
Sharissa Singh, P.G.
Remedial Project Manager
U.S. EPA Region 9
600 Wilshire Blvd., Suite 940
Los Angeles, CA 90017
RE: Comments of the City of San Bernardino Municipal Water Department Regarding Proposed
Environmental Protection Agency Region 9 Proposed Plan and Remedial Investigation and
Focused Feasibility Study for the Newmark Groundwater Contamination Superfund Site Source
Operable Unit
Dear Ms. Singh:
The City of San Bernardino Municipal Water Department (Water Department) hereby submits its formal
written comments concerning the U.S. Environmental Protection Agency (EPA), Region 9's (Region 9)
Proposed Plan for the Source Control Operable Unit (Source OU) Record of Decision (ROD) for the
Newmark Groundwater Contamination Superfund Site (Newmark Site). The Water Department
appreciates the opportunity to submit its detailed written comments and to explain the City of San
Bernardino's (the City) position and supporting evidence in the event later proceedings should arise.
EPA posted the Source OU ROD for comment on Monday, August 14, 2023, and subsequently extended
the deadline for comments until October 13, 2023 at the request of the San Bernardino Valley Municipal
Water District (Valley District), the water master for the affected Bunker Hill Groundwater Basin. That 30-
day extension was mandated by the National Contingency Plan (NCP), 40 C.F.R. Section
300.430(f)(3)(i)(C).
The Water Department, Valley District, and members of the public commented orally at EPA's August 23,
2023 Public Meeting, nine days after the proposed Source OU ROD and notice of the public meeting and
the opportunity for oral comments was released.
1350 South "E" Street, San Bernardino, California 92408 P.O. Box 710, 92402 Phone: (909) 384-5141
FACSIMILE NUMBERS: Administration: (909)453-6399 Customer Service: (909)453-6396 Finance: (909)453-6383 Engineering: (909)453-6385
Corporate Yards: (909) 453-6389 Water Reclamation Plant: (909) 453-6395 Environmental & Regulatory Compliance: (909) 453-6391
Environmental Control: (909) 453-6394
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The following comments are divided into three parts: Part 1: Factual Background; Part 2: The Water
Department's Comments on EPA's Proposed Plan for the Source OU; and Part 3: The Water Department's
Comments on the Final Remedial Investigation and Focused Feasibility Study (RI/FSS). The comments
are detailed below, but the following is a summary of the Water Department's positions.
In Part 1 below, the Water Department lays out some of the extensive factual background of the
Newmark Site, the hard-fought litigation, the settlement and the 2005 Consent Decree, and the Water
Department's lengthy implementation of the remedy which included remediating widespread
contamination affecting over eight square miles of the Bunker Hill aquifer. This contamination was
caused by the U.S. Army's World War II operations in the northwestern part of the City. The long history
of this remediation explains the Water Department's insistence that certain terms negotiated in prior
contentious settlement talks be fully honored by EPA.
As noted by Commissioner Rikke Johnson at the EPA Public Meeting on August 23, 2023, San Bernardino
is the classic example of an environmental justice community whose residents are of very modest
means, and whose average incomes are only about sixty percent of the California average. Further, the
City's residents are predominantly from ethnic and language minorities. The U.S. military has left not
one, but two large National Priorities List (NPL) sites within the City limits, the Norton Air Force Base and
the Newmark Site.
In the Norton Air Force Base example, the military closed the base in 1994, a major blow to the City's
economy as steady jobs for skilled workers were lost. The Air Force took responsibility for the
remediation of extensive contamination of the local ground water and paid for substantial cleanup work.
By contrast, the Army refused to take responsibility for its contamination of the primary water supply for
200,000 people at the Newmark Site until after eight years of hard-fought litigation despite EPA's public
statements to the contrary that the Army bore responsibility for the contamination.
EPA's willingness to hold the Army accountable for the work remaining for the Source OU is an important
test of EPA's credibility to make good on the Biden Administration's public statements to promote and
ensure environmental justice.
In Part 2 below, the Water Department provides its comments on EPA's Proposed Plan for the Source OU.
In sum, the Water Department:
1. Endorses EPA's preferred remedy, Monitored Natural Attenuation (MNA);
2. Appreciates EPA's confirmation that the remedy is not complete unless the extraction wells meet
state drinking water permit requirements and unless the Groundwater Model developed under the
Consent Decree shows that the plumes have been fully contained; and
3. Confirms that the Water Department is willing to consider undertaking the additional monitoring
sought in the Proposed Plan, provided the work is funded in an upfront settlement of the Army's
remaining liability in a sum adequate to underwrite the true costs of that work.
These are the same major comments on the Proposed Plan presented by the Water Department at the
August 23, 2023 EPA Public Meeting.
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In Part 3 below, the Water Department comments on the final RI/FSS, which was not made available by
EPA to the public until August 14, 2023. The Water Department, despite its extensive knowledge of the
remedial work it has been conducting for decades and of the aquifer it is cleaning up, was not offered an
opportunity to confer informally with EPA about the methods and findings of the RI/FSS before it was
issued.
As a result, the Water Department is offering its major technical and procedural comments about the
RI/FSS in this document, with the full set of technical, detailed comments laid out at greater length in the
accompanying table, keyed to specific parts of the RI/FSS. This lengthy table is attached as Exhibit 1 to
these Comments.
The Water Department believes there are significant technical flaws in the RI/FSS and the technical work
on which it is based. In particular, the RI/FSS' discussion of remaining contaminant mass is misleading,
because it ignores the large mass of the contaminants present in concentrations less than 5 micrograms
per liter (ug/L), even though the remedial wells must continue to treat the extracted water down to the
much lower standard of 0.5 ug/L. That significant omission results in overoptimistic projections of the
completion date of the remedial work, suggesting premature completion. Beginning in 2014, the Water
Department has repeatedly noted this problem in its comments on the 3DVA modeling work done by
EPA's consultant, but that misleading approach continued into the RI/FSS despite the Water
Department's detailed past objections.
Further, the groundwater movement near monitoring well C-10 is badly flawed because it suggests that
groundwater moves easily across a fault line that causes a difference of 150-feet in water level across
that fault. The RI/FSS approach to this fault line issue conflicts sharply with the work of EPA's prior
contractor, URS, which had worked on this project for EPA for nearly two decades. In 2008, when URS
analyzed this issue for EPA, the report made clear that significant water movement across that fault line
was highly unlikely. The RI/FSS assertion now to the contrary is based on simplistic and unsupported
assumptions, some of which conflict with other portions of the RI/FSS.
The Water Department's concerns are accentuated by the fact that EPA's lead contractor has received
over one billion dollars in Army contracts in the two years prior to the issuance of the RI/FSS, according
to that contractor's own press releases (summarized in Appendix A to this comment), even as the RI/FSS
seemed focused on dismissing or minimizing any suggestion that the Army was a significant potential
source of the contamination at monitoring well CJ-10. To the Water Department's knowledge, EPA has
not recognized or taken any steps to mitigate this serious organizational and financial conflict of interest
by EPA's lead contractor on the RI/FSS. EPA's failure to do so undercuts public confidence in the RI/FSS
analysis as it affects the Army.
1. Factual Background.
a. Site Discovery and DTSC and City Remedial Work.
The contamination at the Newmark Site was first identified around 1980 when the Water Department
began to find that some of its major supply wells in the Bunker Hill Groundwater Basin were significantly
contaminated with chlorinated solvents, and that the contamination was migrating to additional Water
Department supply wells. This discovery has required the Water Department to actively remediate the
contaminated groundwater for more than four decades. The State of California's Department of Toxic
Substances Control (DTSC) and EPA Region 9 worked collaboratively with the Water Department starting
in the 1980s. EPA placed the Newmark Site on the Superfund NPL in March 1989, more than 34 years
ago. 54 Fed. Reg. 13296 (March 31, 1989).
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The Water Department and DTSC spent millions of dollars of ratepayer and state taxpayer funds through
the 1980s and 1990s to install and operate treatment technology (and close some wells) to respond to
the chlorinated solvent contamination. EPA, for its part, conducted substantial field work to track the
origin of the contamination, which consisted primarily of Perchloroethylene (PCE) and Trichloroethylene
(TCE).
Based on that field work in the early 1990s, EPA determined that the contamination to the north and
east of the Shandin Hills in the City of San Bernardino, known as the "Newmark plume," and the
contamination to the west and southwest of the Shandin Hills, known as the "Muscoy plume," were in
fact lobes of a connected contaminant plume that originated to the northwest of the Shandin Hills.
b. Extensive Army Operations at the Plume Origin During World War II from Late 1941 until
1947.
The northwest area of the City of San Bernardino is now the subject of EPA's proposed Source OU
Proposed Plan. It was the location of a substantial World War II Army base on almost three square miles
of leased land, an installation known as the Base General Depot for the Desert Training Center (Base
General Depot) as well as Camp Ono and other designations. The Army occupied the property from late
1941 through 1947. As late as February 23, 1999, EPA's website for the Newmark Site stated
unequivocally that "the results from these cooperative investigations [with the state and county] show
no other reasonable point of origin for the Newmark Superfund site contamination other than the
former military operation" at Camp Ono. EPA's remedial project manager, Kevin Mayer, PE, supported by
Keith Takata, head of EPA Region 9's superfund program, apparently reached this conclusion. They did so
after review of the groundwater movement, the contaminant data, and the aerial photography showing
the undeniable and massive Army presence at the time the contamination most likely occurred. They
determined this in large part based on the time it would take for the contaminants to move several miles
through the Bunker Hill Groundwater Basin.
The Army later contended that the contamination originated in the mid-1960s from near the Cajon
Landfill. However, those claims required assumptions about extraordinarily fast sustained speeds for
groundwater contaminant migration to move to multiple wells miles away by 1980, just fifteen years
later. The known groundwater data contradicted the Army's unsupported contentions.
At the height of operations from 1942 to April 1944, the Base General Depot covered nearly three
square miles, housed around 15,000 servicemen and women, and supplied, maintained, repaired,
salvaged, and refurbished equipment and supplies for the Army Corps of Engineers, the Quartermaster
Corps, the Signal Corps, the Chemical Warfare Service, and the Medical Corps. These operations also
included extensive training using smoke munitions at the weapons ranges at Cajon Wash and at Cable
Canyon, munitions that the Army's own studies show expel PCE-laden residues to the ground when
these smoke pots are used. The Cable Creek range location, different than the Cajon Wash range, is very
close to the nearby origin of Cable Creek, uphill and upgradient of the apex parcel of the Army base and
upgradient of monitoring well C-10.
In Spring 1944, with the deployment of most Army units to combat theaters overseas, the Army changed
the base operations into a major center to salvage and recondition quartermaster and engineer
equipment. This salvage work involved the combined washing and water proofing of tens of thousands
of shelter halves, as well as work on as many as 10,000 tents per month from late 1944 through August
1945.
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This salvage work also included the repair and painting of nearly 300,000 steel "jerry cans/' in an
outdoor assembly line in 1944, and the indoor repair and painting of tens of thousands of helmets in the
latter part of 1944.1
The Army's operations discharged liquid wastes to lagoons and to Cable Creek, often percolating into the
ground, as shown by the aerial photography and as the Army intended in the case of the lagoons. The
lagoons were known as an "Imhoff tank," a rudimentary wastewater treatment system located very near
the current location of the Cajon Landfill.
After the conclusion of World War II, the Army used the base as a collection point for large volumes of
U.S. Army surplus supplies and equipment brought there from all over California and elsewhere to be
offered for sale to the public. Stories abounded about Army and civilian personnel burying or discarding
supplies and equipment at the base. Indeed, one of the witnesses at the August 23, 2023 Public
Meeting testified that her father had worked at the base after the war's end and recounted such
incidents in later stories. The base closed and the leases were terminated in 1947, over 75 years ago.
c. EPA's Division of the Plume into Three Operable Units. DTSC and Water Department
Litigation against the Army, Beginning in Fall 1996.
In its August 3, 1993 Record of Decision, EPA Region 9 split the areas of contamination between the
Newmark and Muscoy OUs. During the 1990s, EPA further split the site into three OUs: the Newmark
Plume to the north and east of the Shandin Hills, the Muscoy Plume, to the southwest of the Shandin
Hills, and the Source OU, largely corresponding to the approximate boundaries of the old Army base,
mostly to the northwest of the Shandin Hills. In its 1995 ROD for the Muscoy OU, EPA stated that the
"identification, characterization and remediation of the source contamination will constitute a third
Operable Unit." Muscoy ROD, p. 7, March 22, 1995. In the responsiveness summary, EPA indicated that
the Army base - located in the area later referred to in EPA's late 1990s studies as the Source OU -
appeared to be the most likely source of the contamination.
EPA began formally to demand information from the U.S. Army in its March 19, 1993 information request
under Section 104(e) of the Comprehensive Response, Compensation and Liability Act (CERCLA), 42
U.S.C. Section 9601 et seq., to Lewis Walker, Deputy Assistant Secretary of the Army for information
about the former Army base and the personnel stationed there, among other topics. EPA SFund Records
Center 2363-00068.
Despite EPA's compelling evidence and demands of the U.S. Army starting in the early 1990s, by late
summer 1996, the Army had still done nothing to take responsibility for the cleanup and moved slowly in
its search for documents and witnesses to respond to EPA's information requests. Faced with the Army's
intransigence, the State of California filed its lawsuit on behalf of DTSC under CERCLA to recover DTSC's
response costs and to obtain a declaration of the Army's liability. After DTSC filed its action under
CERCLA, the Water Department filed its CERCLA action in the U.S. District Court for the Central District of
California. The court consolidated the two cases.
1A copy of the June 2, 2005 Report, entitled Training and Supply Activities at the Desert Training Center in World War II and Their
Relation to the Base General Depot at Camp Ono, by William T. Bowers (Col. U.S. Army, Retired), addresses these salvage operations
in more detail. See p. 18, n.25 (300,000 jerry cans reconditioned at Base). General Depot in 1944); p. 41 (statistics on tents, gasoline
cans, cots, and other equipment); 41-45, salvage activities. This report was prepared by the late Colonel Bowers, a well-respected
military historian, is submitted as part of this comment. This Report is attached as Exhibit 2 to these comments.
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Fact discovery proceeded with dozens of depositions in 1997 through June 1999, after extensive archival
research located key documents that the Army's contractor failed to locate in response to EPA's
administrative requests, documents showing the extensive Base General Depot operations among other
missing materials. The Water Department's counsel reviewed unit histories and unit rosters of the
specific Army units shown to be stationed at the Base General Depot to identify potential witnesses all
over the United States. Investigators used this information to locate and interview about veterans
previously stationed at the Base General Depot more than 50 years before. The youngest witnesses
were in their seventies, and a great many had died or became unable to testify.
In at least one case, a potential witness died the night before he was to be interviewed. Had the Army
cooperated with EPA in the early 1990s, many more witnesses could have been interviewed and their
knowledge of the base's operations preserved in usable form.
d. Settlement with the Army and 2005 Consent Decree.
After fact discovery concluded in 1999, the U.S. Army finally began serious settlement discussions in
2000. After lengthy stays of the litigation, the parties finally reached a settlement in 2004 in the form of
a Consent Decree, which the court approved and entered in March 2005 (the Consent Decree).
The Consent Decree addressed the financial responsibility for the cleanup of the Nemark OU and the
Muscoy OU. On behalf of the Army, the United States paid the City of San Bernardino $69 million to the
Water Department and smaller sums to the State of California. In exchange, the Water Department
agreed to continue to operate the remedial systems for the Newmark and Muscoy OUs for up to fifty
years. For its part, the Water Department agreed to drop its CERCLA claim for over $10 million in past
response costs, and agreed to incur increased, unreimbursed operating costs related to the
reconfiguration of the potable water system to use the water produced by the remedial system. That
water came from much lower elevations within the City limits than was true before the remediation
started. That change imposed a substantial energy cost penalty on the Water Department's water
supply operations, millions of dollars over the life of the cleanup.
The Consent Decree recognized that because EPA had intentionally placed the remedial wells in an
extremely impaired groundwater source (the contaminated aquifer), the California drinking water permit
standards for the produced water were much more stringent because the water was put into the potable
water system that supplied over 200,000 people.
In practice, this extremely impaired source designation has meant that the Water Department must treat
the water down to 0.5 ug/L of PCE and TCE, which was the detection limit when standards were first set
for these parameters in the 1980s. The Consent Decree recognized this obligation by defining the term
"Performance Standards" to include "the acceptance of the extracted, treated water by the City into its
potable water supply, provided that the water meets all federal and State permit requirements for
drinking water,. . .." Consent Decree, p. 24.
The Consent Decree also provided that if, after the remediation work has been certified as complete by
EPA pursuant to the Consent Decree, and money remains from the federal settlement payment, that half
the remaining funds are to be paid by the Water Department to the [EPA] Future Cost Account. Consent
Decree, Paragraph 60.a.2, 5.
The combination of these requirements means that if EPA mistakenly succeeds in Certifying Completion
based on a federal standard of 5 ug/L for drinking water, while the Water Department must continue to
meet a 0.5 ug/L standard for drinking water in the applicable permits, that the Water Department will
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have to repay large sums to the Future Cost Account even as it must continue to pay for costly treatment
until the more stringent permit limits are met.
e. EPA's Expansion of Source OU Boundaries to Cover the Entire Geographic Site.
One major element of the settlement in the Consent Decree was EPA's issuance of an Explanation of
Significant Differences (ESD) on August 9, 2004. That ESD described the OUs and stated that "the Source
OU is generally located in the area northwest of the Shandin Hills." ESD, p. 2. EPA received extensive
comments on the ESD from other water agencies in the area, raising issues that took several months to
resolve, thereby delaying the United States' motion to enter the Consent Decree until January 2005.
The Consent Decree settled the parties' claims related to the Newmark OU and Muscoy OU, and for
sitewide monitoring, but expressly reserved the Source Control OU claims for costs incurred after EPA
issued its Proposed Plan for the Source OU. Consent Decree, p. 24, Definition of "Past U.S. Response
Costs." At the time the Consent Decree was entered in 2005, the parties understood the Source Control
OU to be defined geographically to cover the area in the vicinity of the former Army base.
In EPA's September 2007 Report entitled, "Long Term Groundwater Monitoring Optimization Newmark,
Muscoy, and Source Operable Units Newmark Superfund Sites, San Bernardino California,"
(https://semspub.epa.gov/work/09/1146481.pdf, last visited on October 10, 2023), EPA explained that:
• Outlines of the OUs are shown on Figure 1. A brief description of each OU is provided below.
• Source OU. The Source OU is located on the northern /northeastern edge of the site, north of the
Shandin Hills and covers approximately 6.3 square miles. The OU is bounded on the west/southwest
by Lytle Creek, and on the east by Highway 215. The Source OU contains both the Cajon Landfill and
former Camp Ono supply depot and represents the most upgradient area of affected groundwater.
Id., P. 2. The rest of the September 2007 Report uses consistent representations of the Source OU so
defined. Id., pp. 14-17, 41-42 (Source OU discussion); Data tables, 1-3; Data Table B.ll, B. Source OU
data. Figure 1, PDF, page 81, shows the spatial delineation of each of the three OUs, with data from the
Source OU wells depicted by well site on pp. 82-83 of the PDF. Moreover, in EPA's fact sheets for March
1, 2005, April 2004, November 2001, October 2000, February 2000, and October 1998, EPA had used
similar depictions of the OU boundaries, including the Source OU to the northwest.
By November 2007, EPA settled its claims against San Bernardino County in a separate consent decree
resolving all claims against the County related to the entire Newmark Site in exchange for a payment of
$11 million. EPA apparently believed that it had adequately characterized the Newmark Site, particularly
the area around Cajon Landfill, so that it did not need to reserve any claims related to the Source OU.
In August and September 2008, in its review of the Operational Sampling and Analysis Plan (OSAP) and
the five-year review, without any prior notice to the public, EPA changed the prior boundaries of the
Source OU. After this boundary change, the Source OU boundaries encompassed the entire geographic
area of the Newmark site, including the territory of the Newmark and Muscoy OUs. That boundary
change has created needless confusion among the public ever since, including at the August 23, 2023
Public Meeting. Unlike the situation with the 2004 ESD and with the 2007 settlement with San
Bernardino County, EPA gave no public notice and invited no comment about the big changes in the
Source OU boundaries.
The Water Department raised these issues repeatedly with EPA in informal efforts to resolve concerns
that the boundary changes might be read as a re-write of the Consent Decree and would confuse the
public and the neighboring water agencies. After informal efforts to resolve the Water Department's
concerns proved unsuccessful, the Water Department submitted its detailed objections by letter dated
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September 24, 2009 in response to EPA's demands for changes in pending documents to conform to
EPA's complete re-definition of the Source OU boundaries.
The Water Department also raised concerns in 2009 and 2010 that EPA's contractor for the analysis of
the Source OU did over a billion dollars of work for the U.S. Army, a serious conflict of interest in this
case. EPA had been telling the public since the mid-1990s that the Army was the most probable source of
the contamination. DTSC and the Water Department, based in part on the EPA work in the 1990s, had
litigated EPA's claims of Army liability to the point of receiving a very large settlement from the federal
government to carry out the remedial work for the Newmark and Muscoy OUs. EPA for its part, had
received $6.5 million from the Army to reimburse EPA costs.
This contentious litigation history with the Army, and the 2005 Consent Decree's express reservation of
claims against the Army for the Source OU after the publication of the Proposed Plan, made EPA's use of
any major Army contractor a serious conflict problem for EPA for work assessing the Source OU. EPA
subsequently changed to the current contractor Tetra Tech, which has its own conflict of issues arising
from Army contracts.
f. Issuance of the 2015 Record of Decision for Newmark and Muscoy OUs.
In 2015, EPA issued a final ROD to address both the Newmark and Muscoy OUs, concluding that the
remedial systems as installed and operated by the Water Department were working appropriately and
should result in eventual cleanup of the Newmark Site.
In May 2014, EPA had initially sought to issue a Proposed Plan that claimed the work would be
completed in a few years based on the federal standard of 5 ug/L. The Water Department responded in
detail, explaining that EPA's contemplated approach was contrary to the requirements of the drinking
water permits as well as contrary to the Consent Decree's definition of the Performance Standards for
the produced water, which had to meet the more stringent permit requirements. The Water
Department set forth its concerns in its May 19, 2014 letter from counsel and in subsequent
correspondence found in the Administrative Record.
As the Water Department pointed out, by operation of paragraph 60 of the Consent Decree, a premature
EPA certification of completion would require the Water Department to repay the federal government
over $10 million at that point, even as the City was still addressing its 2012 bankruptcy. As noted
repeatedly in discussions with EPA, the City of San Bernardino is an environmental justice community,
with a population whose average income is well below the average for California, most of whom are
ethnic minorities. The City and its residents could ill afford to take on this unfunded liability to cleanup
contamination caused by the Army's operations.
The Water Department raised specific concerns about EPA's modeling efforts and the 3D visualization,
which showed various implausible results, such as the migration of contaminated groundwater through
the crystalline bedrock of the Shandin Hills, a phenomenon that the known information about the
location of the aquifer and the contaminants flatly contradicted. The Water Department's February 28,
2018 letter to EPA, attached as Exhibit 3, raised the issue again in connection with the misleading
estimates of remaining PCE mass.
g. Stipulated 2020 Consent Decree Amendments to Facilitate Ongoing Upgrades of the
Groundwater Model.
After more than two years of careful consultations and discussions among the Water Department, EPA,
DTSC, and the U.S. Department of Justice, the parties stipulated two amendments to the Consent
Decree. On August 25, 2020, the District Court approved the stipulation.
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The first stipulated amendment allows the Water Department to spend more of the settlement money -
up to $3 million Net Present Value (using 2003 as the base year) to upgrade the Groundwater Model.
The second stipulated amendment clarifies the Water Department's authorization to spend settlement
funds to close and decommission inoperable or unneeded monitoring wells.
2. The Water Department's Comments on EPA's Proposed Plan for the Source OU.
a. The Water Department Appreciates EPA's Confirmation in the Proposed Plan that
Remediation Work is Not Finished Until Treatment of Drinking Water for These
Contaminants Is No Longer Required by State Drinking Water Permits.
As the Water Department has repeatedly explained over the past decade, and again at the August 23,
2023 EPA public meeting, prior EPA contractor reports, including a draft Proposed Plan, had suggested
that EPA might try to force premature certification of completion, based on the wrong standard.
Such premature certification would force the Water Department to return well over $10 million to the
federal government, while leaving the Water Department to face a costly unfunded obligation to pay for
costly continuing treatment to meet permit requirements. Those requirements were imposed because
of the Army's contamination and EPA's decision to use the water supply wells as the remedial system to
address that federal government contamination of the water supply for this environmental justice
community.
As stated at the August 23, 2023 EPA Public Meeting, the Water Department greatly appreciates EPA's
clear recognition in the Proposed Plan that the work provided for in the Consent Decree requires
continued treatment to meet the California drinking water permit requirements, currently treatment of
PCE and TCE down to 0.5 ug/L, rather than the 5 ug/L standard that EPA's contractors have repeatedly
used in their analyses suggesting that completion is near.
The Water Department also greatly appreciates EPA's confirmation that Certification of Completion
under the Consent Decree will be based on the sophisticated Groundwater Model developed under the
Consent Decree, and not on the simplistic 3DVA visualizations done by EPA's contractor in the Proposed
Plan and the RI/FFS. While the visualizations may be attractive, the graphic results of that analysis do
not quantify groundwater flow and suggest implausible groundwater movements. For example, some
presentations of that modeling have suggested that the contaminated groundwater plume moves
through the crystalline rock of the Shandin Hills, a phenomenon never observed in the field.
The Water Department is operating fourteen production wells that are connected to treatment plants
built to remove the PCE and TCE contamination caused by the Army. These efforts have made
substantial progress reducing the mass of contaminants in the aquifer since the Consent Decree was
entered in 2005.
The Water Department recognizes this progress and plans to go to the State's Division of Drinking Water
soon to ask that the permit provisions for three of these wells be amended so treatment is no longer
required. The basis for this amendment request is the consistent production of water that, even without
treatment, already meets the 0.5 ug/L standard. In July 2023, the Water Department submitted its
technical memorandum to EPA and to DTSC concerning the proposed amendment. We are awaiting
EPA's comments about the draft technical memorandum, a first step in this cooperative effort.
b. The Water Department Supports EPA's Monitored Natural Attenuation Remedial Choice.
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The Water Department agrees with EPA's recommendation for the remedy of contamination in the
northwest portion of the Newmark Site, particularly including and around the Army's World War II base
called Camp Ono and the Base General Depot. These Army activities contaminated the Bunker Hill
Aquifer.
EPA has reported that PCE contamination remains above EPA's groundwater standard in a small area that
includes part of the Cajon Landfill and the old Army Base. EPA's proposed plan recommends that the
remaining contamination be addressed through Monitored Natural Attenuation (MNA) of elevated levels
in deep groundwater near monitoring well C-10.
The Water Department believes that in this situation MNA is a reasonable remedial choice from the
engineering, environmental, and cost standpoints. The remaining mass of contaminants in and near the
old Army base is small, is located several miles distant from current production wells, is too deep to pose
a vapor hazard to people in surface structures and will be tracked by the proposed monitoring well
program. If PCE migrating from this location requires additional action, the monitoring will allow EPA
and DTSC to take timely steps to protect the water supply.
c. The Water Department Is Willing to Consider Adding Federally Funded Monitoring to its
Scope of Work.
Under the 2005 settlement and Consent Decree, using federal money, the Water Department has for the
last 18 years undertaken the treatment, monitoring, and reporting work needed to halt the advance of
the contaminant plume while providing safely treated water to the San Bernardino community.
Using a similar approach, the Water Department is willing to consider adding the required monitoring
and reporting under the Proposed Plan into the existing Newmark and Muscoy OU monitoring and
reporting program. This willingness to consider such consolidation is dependent on the United States (for
the Army) making a lump sum payment to the Water Department at the start of such work. The Water
Department is already doing extensive monitoring and reporting as part of its existing work, making the
Water Department a logical candidate to address the additional work and to do so efficiently.
Under the 2005 Consent Decree, the Army has not been released from its liability for response costs
incurred after August 14, 2023, the date of publication of the Proposed Plan. Given the limited scope of
work involved and the comparatively modest funding needed as compared to the amounts in the 2005
Consent Decree, the most efficient way to address this additional work may be to amend the Consent
Decree so that additional federal funds are provided for the Water Department to defray the additional
work, in exchange for appropriate covenants not to sue for the parties.
As noted at the August 23, 2023 EPA Public Meeting, the Water Department's willingness to move
forward with this approach is contingent upon reasonable funding being provided at the outset in a lump
sum settlement from the Army. The Water Department notes that EPA's cost estimates in the Proposed
Plan appear substantially inadequate for the proposed scope of monitoring, but those issues can be
addressed in later discussions among the parties.
3. The Water Department's Technical Comments on the Remedial Investigation and Focused
Feasibility Study (RI/FSS).
On August 14, 2023, EPA also posted the Final RI/FSS. Although the RI/FSS presents EPA's scientific,
engineering, and economic rationale for its proposed Source OU ROD, EPA did not circulate the draft
RI/FSS in advance for comment by the Water Department. EPA declined to do so, even though the
Water Department has been implementing the remedy prescribed by the Consent Decree since the year
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2000 and is the lead agency that has prepared and has been progressively updating the Groundwater
Model required to be developed by the Consent Decree.
Consequently, the Water Department is also submitting detailed comments in the attached table, noting
significant technical problems in the RI/FSS.
The combination of these technical problems with the RI/FFS, together with the Tetra Tech billion dollar
conflict of interest (discussed below) with respect to any assessment affecting potential Army liability for
remaining work at the Newmark Site, causes the Water Department substantial concern.
The Water Department's initial review of the RI/FSS suggests that there are significant contradictions
between the RI/FSS and prior work done by EPA's contractors, particularly URS and its 2008 work
concerning the location of fault lines near the Cajon Landfill and the Verdemont Hills, where
contaminants are more concentrated. Especially where the recommended remedy is MNA, the Water
Department believes the site conceptual model of groundwater flow direction, groundwater barriers,
and related issues will need to be more carefully addressed than the RI/FSS has done. Otherwise, the
design of the monitoring well network, the placement of additional monitoring wells, and the
monitoring frequency may be incorrect, potentially requiring costly corrections.
The Water Department is also concerned that the RI/FSS, judging by the Administrative Record Index,
completely ignored substantial evidence about Army activities potentially causing the contamination,
while failing to seek any additional information from the Army about activities at the base between the
September 1945 surrender of Japan and the closure of the base in 1947.
The Water Department is further concerned because the RI/FSS discussion effectively ignores the Army's
large and undeniable presence in the vicinity, as explained more fully below. That omission is deeply
troubling because EPA's contractor, Tetra Tech, a publicly traded company, has been awarded over one
billion dollars in U.S. Army contracts since January 1, 2021 according to Tetra Tech's own press releases.
Those announcements are required by federal law because these contracts are material to the
company's performance and its share price. A compilation of these press releases and links to them is
found in Appendix A of these comments.
With due respect, Tetra Tech's receipt of Army contracts of over $1,000,000,000 since January 1, 2021
creates a substantial unresolved financial conflict of interest by the author of the RI/FFS insofar as it
purports to analyze and apparently excuse remaining potential Army liability for the Newmark Site,
particularly in the area formerly occupied by the Army base.
At no point has EPA acknowledged this serious conflict of interest by its contractor. EPA's failure to
address this conflict of interest undermines public confidence in the RI/FSS analysis, particularly given
the serious technical concerns the Water Department has already identified in the contractor's analysis
of groundwater movement across documented faults. As noted above, the Water Department had
noted similar conflict of interest concerns in 2009 by a prior RI/FFS contractor with substantial Army
work.
That Army presence and the various liquid discharges have been documented in aerial photographs,
maps, and documents, showing the generation and discharge of liquid wastes to the ground. In
particular, there are undeniable liquid discharges to the ground in the Hospital Parcel quite visible in
aerial photography from August 1945, photography already in the record from the Aero-Data
presentation in 2010.
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There is also testimony from several Army witnesses present at the base in 1943 and 1944 that the Army
trained its personnel to operate under machine gun fire by having them run an obstacle course, known
as the infiltration course, located at the Cable Creek weapons range. As part of that training, the Army
personnel were placed under machine gun fire as they crawled through barbed wire while smoke was
generated from Army smoke pots.2 According to the Army's own studies, when these smoke munitions
are ignited, they expel PCE-laden solid waste onto the ground. (The Cable Creek weapons range is
different than the Cajon Wash Rifle Range, which is more distant from the Hospital Parcel.) The Cable
Creek range is very close to the origin of Cable Creek, which flows downhill in an unlined channel just
across Kendall Drive from the Hospital Parcel. EPA's contractor never assessed this potential source of
PCE contamination at the Hospital Parcel, and nearby monitoring wells C-10 and C-17.
At no point did EPA's contractor request any additional information from the Water Department to
explore the potential Army contributions to the area around monitoring well CJ-10 and CJ-17 or
elsewhere, even though the Water Department has additional information about the broad scope of
Army activities at the Base. This information goes beyond the expert declaration of Hugh Farber and the
aerial photography study by Wayne Grip of Aero-Data presented by the Water Department to EPA in
2010.
Instead, the RI/FSS has focused on a 1995 Report by EMCON, a contractor for San Bernardino County,
which was trying to point to potential sources other than Cajon Landfill. (The County later paid $11
million to resolve EPA's Superfund claims against it.)
EMCON reported a hearsay comment by an unnamed former employee of the "steel mill" about claimed
waste discharges there. To the Water Department's knowledge, neither EPA nor the EPA contractor took
any steps to identify the witness, verify the EMCON report of his recollection, or to check the dates and
locations of the supposed discharges. EPA's credulous acceptance of the EMCON statements, apparently
without any independent verification, is troubling and undercuts the credibility of EPA's assertions about
the supposed steel mill as the most likely source of the remaining contamination at monitoring well C-
Additionally, EPA's contractor has presented, without any discussion of the methods used, an aerial
photograph that purports to show slag heaps in the area, implying that these are the source of the PCE.
The photograph of the supposed steel mill is not consistent with the footprint of an integrated steel mill
with blast furnaces and slag, such as existed about twenty miles away in Fontana. Contrary to the
RI/FSS's assertions about "slag," Aero-Data has reported to the contrary that these are stacked materials
that do not appear to be processing waste.
Again, the Water Department appreciates the opportunity to submit its detailed written comments and
to explain the City's position and supporting evidence with regards to EPA's Proposed Plan for the Source
OU and the Final RI/FSS for the Newmark Site.
Respectfully submitted,
10.
Miguel Guerrero, PE
General Manager
City of San Bernardino Municipal Water Department
2 Bowers Report, pp. 26-27 (regarding infiltration courses, use of smoke munitions, and citations to deposition testimony); p. 28
(photographs of Cajon Wash Rifle Range). The information about the Army reports comes from over 500 requests for admission to
the Army in the litigation in 1998 and 1999, admissions based on many Army reports.
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APPENDIX A - Tetra Tech Press Releases Announcing Awards of Army Contracts (2021-2023) Totaling
Over One Billion Dollars
https://investor.tetratech.com/press-releases/news-d etails/2023/Tetra-Tech-Wins-34-Million-U.S.-Armv-
Corps-of-Engineers-A-E-Services-Contract/default.aspx
https://investor.tetratech.eom/press-releases/news-details/2023/Tetra-Tech-Wins-200-Million-U.S.- Armv-
Corps-of-Engineers-A-E-Services-Contract/default.aspx
https://investor.tetratech.com/press-releases/news-details/2023/U.S.-Armv-Corps-of-Engineers-Awards-
Tetra-Tech-200-Million-Contract-for-Architect-Engineer-Services/default.aspx
https://investor.tetratech.com/press-releases/news-details/2022/Tetra-Tech-Wins-49.5-Million-
Environmental-Remediation-Services-Contract/default.aspx (Army Corps of Engineers)
https://investor.tetratech.com/press-releases/news-details/2022/Tetra-Tech-Wins-50QM-Contract-for-
Environmental-Remediation-Services/default.aspx (Army Corps of Engineers)
https://investor.tetratech.com/press-releases/news-details/2Q21/Tetra-Tech-Wins-110-Million-USACE- Dam-
Safety-and-Risk-Management-Contract/default.aspx
https://investor.tetratech.com/press-releases/news-details/2Q21/Tetra-Tech-Wins-36-Million-USACE- Flood-
Risk-Reduction-Contract/default.aspx
https://investor.tetratech.com/press-releases/news-details/2Q21/Tetra-Tech-Wins-49-Million-USACE-
Environmental-Services-Contract/default.aspx
https://investor.tetratech.com/press-releases/news-details/2021/Tetra-Tech-Wins-6Q-Million-USACE- Dam-
Safety-and-Risk-Management-Contract/default.aspx
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EXHIBIT LIST
1. Table 1, SBMWD's Comments on the Source OU RI/FFS
2. Training and Supply Activities at the Desert Training Center in World War II and Their Relation
to the Base General Depot at Camp Ono, by William T. Bowers (Col. U.S. Army, Retired), June 2,
2005 (54 pages)
3. February 28, 2018 Water Department Letter to EPA regarding PCE Mass Estimates
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Exhibit 1
Table 1, SBMWD's Comments on the Source OU RI/FFS
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SBMWD's Comments on the Source OU RI/FFS - General Comments
Comment
No.
Topic
Comment
1
RI/FFS
These comments presented in these tables are for the technical document (i.e., the Source OU RI/FFS) that form the technical basis for the EPA
Proposed Final Cleanup Plan for the Source OU , dated August 14, 2023. The Source OU RI/FFS for the Source Operable Unit was published as a
Final Report on August 9, 2023, without allowing SBMWD an opportunity to comment on a draft version of the document. As the operator of the
Newmark OU and Muscoy OU RA systems, which are encompassed by the current boundaries of the Source OU, information presented in the RI/FFS
is of key importance to SBMWD. The City is not the responsible party for the Newmark Groundwater Contamination Superfund Site (NGCSS), but is
responsible for serving untainted groundwater to their 206,000 municipal customers from an aquifer system that was impacted by the US Army's
activities at the Camp Ono army base. The City is a major contributor to the success of the NGCSS RAs and thus should have been afforded the
opportunity to comment on the Source OU RI/FFS in draft form. Many of the comments raised below could have been addressed prior to finalizing
the RI/FFS document. As this opportunity was not afforded to the City, we are forced to provide our comments on the RI/FFS in Public Comments
on the EPA Proposed Final Cleanup Plan for the Source OU, and to have these comments entered into the public record. These comments will also
be published in the Second Semi-Annual 2023 Progress Report to be submitted by March 1, 2023. We look forward to EPA's public responses to
these comments.
2
Rl
The Rl largely ignores the previous hydrogeological investigation study performed by URS, under contract to EPA, as reported in the URS document
titled Source OU Interim Remedial Action Hydrogeological Investigation Report, dated August 26, 2008. This report included key hydrogeological
interpretations of lithology, water level and contaminant data for the Northwest Area of the Source OU that is the main subject of the Source OU
RI/FFS and EPA's associated Proposed Final Cleanup Plan for the Source OU . The URS document is only referenced twice in the RI/FFS document
and without reviewing or considering the URS interpretations. The RI/FFS references to the URS Report are as follows:
1) Section 6.1.6, page 46 - "Figure 7.6 provides hydrographs for groundwater elevations measured in monitoring wells located upgradient (MW-142,
CJ-10 and CJ-17) and downgradient (CJ-3, CJ-6 and CJ-16) of inferred Fault "A"; the approximate location of Fault "A" was shown in several earlier
documents (URS 2008a) and is depicted on Figure 7.3."
2) Section 7.2.3, page 50 - "The Cajon Landfill investigations (EMCON 1995, URS 2008a) encompassed the parts of the basin surrounding the landfill,
including the Verdemont Hills. Wells installed for these investigations have a "CJ" prefix."
The URS hydrogeologic interpretations include the hydraulic barrier effects of Fault A and B, which appear to hydraulically separate opposing sides
of the faults (Fault A full time and Fault B during low groundwater periods). The hydraulic barrier effects of faulting are dismissed in the RI/FFS
without proper justification, in support of a more simplistic conceptual model where it is surmised that there is no effects of faulting on
groundwater flow within the Source OU, and therefore, water level data are contoured across the faults with no consideration of the flow barrier
effects across these hydraulic features. Subsequently, flow path analyses are presented showing flow lines through the perceived faults with no
effects on flow direction. This is in direct contradiction to the interpretations presented in the water level contour maps for Spring 2000 and Fall
2006, as presented in URS Figures 3.4 and 3.5. Simplistic contaminant transport modeling performed for the Source OU and presented in Section
7.4 of the RI/FFS also ignored the effects of Fault A and B on groundwater flow and are therefore questionable.
Specific comments with respect to the hydraulic barrier effects of the forementioned faults and flow path analysis are provided in Comment #s 22,
and 50 through 55.
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1.0 and
Figure
1.1
1/9
In 1993 and 1994, EPA designated the
Newmark and Muscoy plume areas as
the Newmark OU (EPA 1993a) and
Muscoy OU (EPA 1994) and defined an
area encompassing both OUs as the
Source OU (Figure 1.1).
The Source OU boundary originally did not include the Newmark or Muscoy OU. It was limited to the
area northwest of the Newmark OU and Muscoy OU. The boundary was redrawn by EPA sometime
after August 2008 based on examination of Figure 1-1 of the Source OU Interim Remedial Action
Hydrogeological Investigation Report (prepared by URS and dated August 26, 2008). The first
portrayal of the current Source OU boundary appears to be shown in Figure 1 of the EPA First 5-Year
Review Report for the Newmark Groundwater Contamination Superfund Site, dated September 25,
2008. This figure was created by the EPA by altering a SECOR (now Stantec) figure previously
submitted as part of the Draft Operational Sampling and Analysis Plan without obtaining permission or
noting the EPA alterations to the SECOR figure.
2
1.0
2/2
As also shown on Figure 1.3, based on
additional RI/FS results, an interim P&T
remedy was installed in 2005 at the
leading edge of the Muscoy plume
(19th Street North Treatment System
Extraction Wells).
The Muscoy OU extraction wells were installed upgradient of the leading edge of the Muscoy OU
Plume, as evidenced by the installation and sampling of the downgradient monitoring wells, several of
which were suspended from meeting contaminant performance criteria due to pre-existing PCE
contamination conditions.
3
1.0
2/2
Fourteen (14) extraction wells
associated with these treatment
systems are considered Extremely
Impaired Sources (EIS) pursuant to the
State of California Department of Public
Health Drinking Water Division Policy
Memo 97-005 and the 2015 Record of
Decision (ROD) because the treated
groundwater serves as public water
supply for the city.
It should be recognized that the 14 extraction wells are considered EIS both under Policy Memo 97-
005 and by the 2015 ROD, requires PCE treatment to the laboratory method reporting limit (MRL),
which is currently 0.5 ng/L, per the terms of the City's Water Supply Permit.
4
1.0
2/3
Groundwater data generated during the
original Newmark and Muscoy plume
investigations led investigators to
believe that that both plumes originated
from a light industrial/commercial area
located northwest of Shandin Hills (EPA
1993a). The area, then referred to as
the Northwest Source Area, occupied
approximately the northwestern third
of the Source OU (Figure 1.1).
The Northwest Source Area term appears to have been first used in 2008, not 1993.
5
1.3,
Table
1.1
5
Sean McCarthy, Eric Zuniga, Andre
Aguirre designated as part of the
RWOCB.
The named staff are all part of the State Water Resources Control Board (SWRCB) Division of Drinking
Water (DDW) which is not part of the RWOCB. Mr. Aguirre's first name is Andres.
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2.4
7/2
EPA has supported the development of
the NGFM, which has been subjected to
peer review; including in 2012 by the
1997 - 2012 3DVA project team with
respect to advising the NGFM team of
3DVA-derived information on alluvial
lithology, resulting in the modification
of the NGFM to include additional
geologic layers to better represent
heterogeneity in the model's geologic
framework.
The EPA has been very supportive in the development of the NGFM (more recently referred to as the
SBBA Model). However, the notion included in RI/FFS that the 2012 3DVA work influenced the
modification of the NGFM is incorrect. In fact, the 2012 3DVA work is substantially based on Stantec's
interpretation of borehole and geophysical data used to develop the lithologic model that was, in turn
used as the basis for refining model layer elevations and model aquifer properties of the NGFM. This
notion is supported by the following excerpt from the EPA report documenting the 2012 3DVA work
titled Final Technical Memorandum Source Identification, Plume Delineation, Restoration Timeframe
Estimation and Transition from Interim to Final Remedy, dated May 19, 2014. The excerpt from
Section 5.4 Geologic Data is as follows:
"One hundred and twenty-nine boring logs were used to construct the lithology and related
components (for example, relative hydraulic conductivity [KR]) of the Source OU visualizations. Figure
5.2 shows the spatial distribution of these logs. Their complete listing, with location coordinates, is
included as Table 5.2. Site lithology (unconsolidated soils) was derived from the boring log information
available from the EarthVision model previously developed for the NGFM constructed for the site area
(Stantec 2008). Stantec furnished an MS Access database with classifications for each of the 129 boring
logs."
Groundwater flow model layering was established during the refinement of the USGS Basin Model into
the NGFM/RBFM, at which point the model was transitioned from 2 layers to 5 layers based on the
EarthVision model referred to in the excerpt above. During the most recent model update for the
NGFM/RBFM, which is now referred to as the SBBA Model, the 5 layer model structure was preserved,
and the layer top and bottom elevations and associated aquifer properties were updated based on
refinements to the EarthVision model, which now uses Petrel as the main modeling platform. The
model update and associated revisions are provided in the report titled San Bernardino Basin Area
Groundwater Flow Model Update Report (SBBA Model Update Report), prepared by Stantec and dated
September 11, 2023 (Stantec, 2023b).
Refinements to the lithologic model were performed based on peer review comments provided by
Balleau Groundwater, Inc. (Balleau) and discussed in length with the Modeling Technical Advisory
Committee (MTAC), consisting of representative from SBMWD, Valley District, USGS, Stantec,
Geoscience Support Services, Inc (Geoscience), Numerical Solutions Inc (NSI), Balleau and Wildermuth
Environmental Inc (WEI). The 3DVA work was not considered during these updates, as the lithologic
basis of the 3DVA work originated from the work performed on the NGFM.
We recognize that the SBBA Model Update Report was not available at the time of the preparation of
the RI/FFS. We are merely attempting to clarify the basis of the SBBA Model Update.
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2.4
7/5 and
Figure 2-7
In addition, the only identified faults
that could potentially affect
groundwater flow are outside the
Source OU boundaries. Faults,
therefore, were not represented in the
3DVA of the Source OU. Within the
Source OU boundary, this approach to
handling faults is consistent with the
lithologic interpretation used to develop
the NGFM.
The Loma Linda Fault is partially within the Source OU, does effect groundwater flow, and is
represented in the NGFM or SBBA Model. The partial groundwater barrier effect of the Loma Linda
Fault appears to increase with depth within the southwestern portion of the Source OU. In addition,
the 2008 URS Report titled Hydrogeological Investigation Report Newmark Groundwater
Contamination Superfund Site Operable Unit Interim Actions (URS, 2008a) shows a significant
groundwater barrier effect of the Fault A in the Northwest Area that should not be ignored in the 3DVA
work (see General Comment #2 and Specific Comment it's 22, 50 through 55 for additional input) as it
appears to significantly affect groundwater flow as interpreted in URS, 2008a. The barrier effect in the
Northwest Area can clearly be identified on the water level contours shown in Figure 2.7, where water
levels differences of more than 100 feet are observed between a narrow cluster of wells.
8
2.5
8/2
The alluvial aquifer at the Newmark site
is understood to be hydraulically
connected to the Pelona Schist bedrock;
therefore, for the 3DVA effort, the
alluvium and bedrock were assumed to
behave as one aquifer system.
This is an unsupported assumption used to simplify the site conceptual model, thereby simplifing the
constraints on the 3DVA visualizations. Although there is interaction between the bedrock aquifer and
adjacent alluvial aquifer, this interaction is complex, affected by the presence and displacement along
faults, and in many areas of the NGCSS, has not been investigated. The issue with the "one aquifer
system" simplifying assumption is very apparent in the visualization presented for Figures 3-1, 3-2, and
3-4, where PCE contaminated groundwater from the alluvial aquifer system is interpreted to flow
through the Pelona Schist in the Shandin Hills (see comment 12) without identification of any wells or
associated PCE sample results from the Shandin Hills that supports this interpretation.
9
2.9
12/1
As 1,1-Dichloroethane (1,1-DCA), cis-1,2
Dichloroethene (cis-l,2-DCE), and trans-
1,2-Dichloroethene (trans-l,2-DCE) are
breakdown products of PCE and TCE,
they were not considered primary
COCs.
1,1-DCA is not a degradation product of PCE or TCE.
10
3
13
3.0 Remedial History of Source OU
The section title is misleading. With respect to items 1 and 2 of paragraph 2 this is a remedial
investigation history rather than a remedial history as no remediation has been performed in the
Northwest Area of the Source OU.
11
3
13/3
Because the Source OU encompasses
the footprints of both the Newmark and
Muscoy OUs, all of the data generated
during the Rl and IRA efforts for the
Newmark and Muscoy OUs were
determined to be directly applicable to
the Source OU.
It should be noted that the data generated during the Remedial Action or RA was also included, as the
Interim Remedial Action or IRA, was declared the Final RA in the 2015 Final ROD for the Newmark OU
and Muscoy OU.
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3.1
Figures
3-1, 3-2
and 3-4
PCE plume extending through the
crystalline bedrock beneath of the
Shandin Hills bedrock outcrop.
There appears to be a fundamental flaw in the site conceptual model in these portrayals of the plume.
No wells are located within the Shandin Hills bedrock outcrop to support this interpretation. Previous
interpretations by others, including Stantec, support a site conceptual model whereby significant
accumulation of PCE within the Shandin Hills is unlikely due to limited interconnectivity and cross
communication between the alluvial aquifer and bedrock. As portrayed in the referenced figures, the
bedrock could provide a long-term residual low level source of PCE to the Muscoy OU alluvial fill
aquifer in the future, which is likely not the case.
13
3.1
14/bullet 2
As shown in Figure 3.4, the size and
mass of the overall PCE plume
decreased with time, resulting in a
significant decrease in the potential for
the then Northwest Source Area plume
to deliver mass to the
Newmark/Muscoy plumes. This was
evidenced by PCE in groundwater in
concentrations at and above 5 ng/L
decreasing from a mass of
approximately 9,000 pounds (lbs) in
1997 to a mass of approximately 820
lbs in 2012, an approximate mass
reduction of 90 percent.
This statement with respect to the PCE mass statement is misleading and implies there was a PCE mass
reduction of 8,180 lbs between 1997 and 2012. It should be noted that much of the 90% of mass,
inferred to no longer exist, is not a mass reduction but instead is still present in the groundwater
system at concentrations below 5 ng/L. Accounting for the mass remaining between 0.5 and 5 |_ig/L
would be a more transparent way of describing changes in PCE mass, and estimating true mass
remaining (see Comment #17 for additional insight).
14
3.1
14/bullet 3
Existing data indicated no active sources
that would result in an increase in the
concentration or size of the present
Muscoy/Newmark plumes; specifically,
there was no evidence of a continuing
source emanating from the Northwest
Source Area. Groundwater from one
monitoring well (CJ-10) in the
Northwest Source Area continued to
have relatively consistent PCE
concentrations, generally ranging from
30 and 50 ng/L.
If CJ 010 is believed to be where PCE accumulated from a nearby source discharge at or near the
ground surface, then the elevated concentrations should be considered residual or secondary source
to the adjacent alluvial aquifer. It is agreed that these source residuals do not present a significant
threat to the Newmark or Muscoy plumes, as the concentrations are relatively low, and the rate of
transfer to the alluvial aquifer is also likely low as evidenced by the accumulation of PCE in the bedrock
behind the Fault A (URS, 2008a).
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3.1
14/bullet 6
The existing interim remedies appeared
to be (1) effective at containing and
restoring the PCE plume and (2)
adequate to reach the site remedial
goal of 5 ng/L PCE in groundwater (with
the exception of the remedial goal of
0.5 ng/L PCE for ElS-designated wells)
within the following estimated times at
the three treatment facilities: 19th
Street North-4 years; Newmark-17
years; and Waterman -9 years.
Estimations were derived using mass
results from the 3DVA for each
treatment area combined with
historical monthly PCE removal data
from the three interim treatment
svstems.
The method used to estimate cleanup time for the 2012 3DVA study is fundamentally flawed.
Comparing the PCE mass remaining estimates for areas above 5.0 |_ig/L to treatment plant PCE/TCE
influent mass removal trends that are based on influent concentrations down to 0.5 |_ig/L is misleading.
Application of this method would be much more appropriate if PCE mass remaining estimates were
also based on concentrations down to 0.5 jj.g/1. SBMWD has prepared PCE mass remaining estimates
down to 0.5 |_ig/L for a portion of the NGCSS (see Comment #17).
16
3.1
Figures
3-1, 3-2
and 3-4,
3.5 and 3.6
Location of wells used to support PCE
plume volumetric analysis.
None of the PCE plume maps portrayed in these figures, which show the inferred extents of PCE in
groundwater above 5 |_ig/L at various times, includes identification of the well locations and PCE
sample results used to support this analysis. Without identification of the location and reported PCE
concentrations, it is not possible to understand the underlying data distribution and assess the areas of
uncertainty where data supporting the plume interpretations are lacking.
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3.1,3.2
3.3 and
5.2
Figures
3.1,3.2
and 3.4,
3.5, 3.6,
3.7,5.1,
5.2 and 5.3
Limiting PCE mas remaining estimates
to plume areas above 0.5 ng/L.
The PCE mass remaining estimates presented in this report are limited to the estimation of mass above
5 |-ig/L. Given recognition in this report that the 14 extraction wells operated as part of the NGCSS RAs
are considered Extremely Impaired Sources (EIS), and the 14 wells are subjected to State Water
Resources Control Board Division of Drinking Water (DDW) Water Supply Permit mandated treatment
requirements for PCE to be treated to 0.5 ng/L, consideration of the mass remaining between 0.5 and
5 |_ig/L is appropriate, and would provide better context for considering restoration of this drinking
water source to levels no longer requiring treatment. These issues identified by the City have been
brought to the attention of the EPA on multiple occasions, including in a letter dated February 28,
2018, a copy of which is provided in Exhibit 3 of the letter transmitting these comments. A copy of
February 28, 2018 letter has been resent to the EPA on multiple occasions, most recently in an email
dated November 4, 2022 addressed to Sharissa Singh. EPA has yet to address the City's request
outlined in the February 28, 2018 letter. Therefore, Stantec, on behalf of the City, has prepared annual
estimates of PCE mass remaining for the period between 2007 and 2023 and presented these
estimates in the First Semi-Annual 2023 Progress Report - Newmark OU and Muscoy OU Remedial
Action - Report No. 66, dated August 31, 2023 (Stantec, 2023a). The PCE mass estimates are based on
a 2-dimensional (2D) analysis of the PCE plume maps presented in the progress report since 2007. The
results are summarized in Table 5-3, Figure 5-4, and Figure 5-5, and a description of the methodology
used is provided in Appendix 1 of the Progress Report (Stantec, 2023a). This is a fairly simplistic
approach to estimating mass that has some practical limitations identified in the progress report, one
of which is limiting the estimation of mass to the contoured plume areas, thus not considering mass
upgradient of the contoured plumes extending all the way back to the Northwest Area of the Source
OU. To provide context on the difference in the EPA/Tetra Tech based estimates presented in Figures
3.6 and 5.2, which limit the PCE mass estimation to areas above 5 ng/L, and the SBMWD/Stantec PCE
mass estimates utilizing 0.5 |_ig/L as the lower threshold as presented Progress Report (Stantec,
2023a). the following comDarison is Drovided:
Year EPA/Tetra Tech PCE Mass (lbs) SBMWD/Stantec PCE Mass (lbs)
1997 9,000 NA
2007 NA 5,544
2012 820 3,669
2015 45 2,749
2019 23 2,338
2022 6.4 1,863
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(continued)
3.1,3.2
3.3 and
5.2
Figures
3.1,3.2
and 3.4,
3.5, 3.6,
3.7,5.1,
5.2 and 5.3
This comparison demonstrates why it is important to consider PCE mass down to 0.5 |_ig/L when
considering how long treatment will be required. For tracking purposes, SBMWD/Stantec will publish
annual estimates of remaining PCE mass in the progress reports using this 2D analysis method in the
progress reports. In addition, SBMWD is considering adding a more rigorous 3D-based methodology
to estimate PCE mass remaining above 0.5 |_ig/L that would be performed on a five-year basis and
would extend upgradient into the Northwest Area. The 3D method would utilize the EVS software
platform, the Stantec site conceptual model, along with data and outputs generated during the
development and refinement of the SBBA Model. Additional comments with respect to the EPA/Tetra
Tech plume volume estimates are provided in Comment #42.
18
3.2
15/last
paragraph
Site-wide PCE mass, based on PCE
present in groundwater at
concentrations at and above 5 ng/L,
reduced from approximately 820 lbs in
2012 to approximately 45 lbs in 2015,
an approximate 95 percent reduction.
This statement with respect to PCE mass is misleading (see comment #13) implying a mass decrease of
775 lbs (820 lbs to 45 lbs) between 2012 and 2015. It should be noted that much of the 775 lbs of PCE,
inferred to no longer exist, is not a mass reduction but instead is still present in the groundwater
system at concentrations below 5 jj.g/L.
19
3.3
16/3
The estimated site-wide mass of PCE
remaining, based on PCE present in
groundwater at concentrations at and
above 5 ng/L, reduced from
approximately 45 lbs in 2015 to
approximately 23 lbs in 2019,
representing an approximate 49
percent reduction.
This statement with respect to PCE mass is misleading (see comment #13) implying a mass decrease of
27 lbs (45 lbs to 23 lbs) between 2015 and 2019. It should be noted that much of the 27 lbs of PCE,
inferred to no longer exist, is not a mass reduction but instead is still present in the groundwater
system at concentrations below 5 jj.g/L.
20
3.3
16/last
paragraph
From 1997 to 2019, site-wide mass
reduced from approximately 9,000 lbs
to approximately 23 lbs, an
approximate 99.7 percent reduction.
This statement with respect to PCE mass is misleading (see comment #13) implying a mass decrease of
8,977 lbs (9,000 lbs to 23 lbs) between 1997 and 2019. It should be noted that much of the 8,977 lbs
of PCE, inferred to no longer exist, is not a mass reduction but instead is still present in the
groundwater system at concentrations below 5 jj.g/L.
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3.4
17/2
Desktop evaluations included re-
examination of historical aerial
photographs and maps to determine
which of the following were potential
sources:
•Cajon Landfill, located southwest of CJ-
10;
• Former Waste Lagoons and Levees,
located south of CJ-10;
• Former Hospital Area, located north of
CJ-10 and the Verdemont Hills;
• Former railroad spur located
significantly northwest of CJ-10; and
• Former Steel Mill, located north of CJ-
10, but south of the Verdemont Hills.
Desktop analysis should have included historical information regarding usage, storage and
discharge/disposal of PCE/TCE and other COCs or identify the lack of information if that is the case.
With respect to Camp Ono, the City has collected extensive information regarding the Army's usage,
storage and discharge of PCE at Camp Ono. None of this information appears to have been used in this
desktop analysis.
22
3.4
17/4
Based on the evaluations, it was
determined that the former steel mill
appeared to be the most likely source
of PCE contamination in monitoring
well CJ-10 because the mill area was
located directly upgradient of well CJ-
10, as supported by groundwater
elevation isocontour maps and flow
vector analysis. The hospital area of
former Camp Ono was determined
unlikely to be the source based on flow
vector analysis indicating that it was not
upgradient of well CJ-10.
SBMWD disagrees with this conclusion regarding the former steel mill being the most likely source.
The interpreted groundwater elevation contours and flow vectors ignore the groundwater barrier
effects of Fault A and B and the associated bedrock aquifer/alluvial aquifer interaction across these
faults, as presented in URS, 2008a (see General Comment #2 and Specific Comments #50 through 55
for additional details).
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4.4.2
23/6
"Table 1 - Sampling Locations and
Construction Details," provided by EPA,
contained the depth of the PDB samples
and for 3DVA purposes, a screened
interval was assumed to be 1.0 foot of
influence above and below the PDB
depth. For all other wells, it was
assumed that the sample for the BP,
piezometer, WHS, and packer systems-
related data were collected from the
entire length of the screened interval.
This implies that PDB sample results are not indicative of the entire screen length or aquifer/zone
thickness, which may minimize the vertical plume dimensions. This assumption likely limits the
interpolated vertical distribution of PCE used in associated mass estimates.
24
4.4.2
24/2
Detection limit (DL) values play a crucial
role in bounding a contaminant plume;
however, DLs can be problematic if
analyses included dilutions and elevated
DLs; which can result in concentrations
elevated above MCLs or other criteria
of interest. While DLs are provided by
laboratories for each compound or
analyte, 3DVA requires decisions
regarding what value to use as
representative of an analyte
concentration and considering that the
analyte may be present at some
concentration below the DL. However,
formal guidelines have not been
established for determining the fraction
of the DL that should be used to
account for the potential presence of an
analyte below the DL. Based on past
3DVA project experience, it was
determined that 10 percent of the DL
value would be used, which is a
common industry practice that EPA
OSRTI has applied to all 3DVA projects
with similar issues.
In review of the following EPA guidance document for RISK assessment:
https://www.epa.gov/risk/regional-guidance-handling-chemical-concentration-data-near-detection-
limit-risk-assessments
Several methods are proposed including using the DL value, 1/2DL value, or statistical estimation
techniques. Is there a reference document supporting the use of 10% of the DL? A more conservative
approach would be the value of the DL or 1/2 the DL. This is important as SBMWD is required to treat
down to the common DL of 0.5 |_ig/L for PCE, per the EIS and DDW permit.
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During the 2019 - 2022 3DVA update,
the lithology component database and
bedrock surface file were refined based
on review of:
A reference for the bedrock surface file is not provided. Is this the bedrock surface file from the
Stantec 2008 groundwater flow model EarthVision work that was provided to EPA/Tetra Tech?
25
4.4
25/1
• Boring logs and monitoring well
construction diagrams for all wells in
the Northwest Area to confirm lithology
of each boring, well screen intervals,
and lithologic material well screened
within; and
• Data in Report of Findings for Initial
Source Investigation Apex Parcel
(Kleinfelder 2000) and incorporation of
lithologic data from 18 additional soil
borings into the lithologic component
database and bedrock surface file.
26
4.4
25/1
bulleted
items
Boring logs and monitoring well
construction diagrams for all wells in
the Northwest Area to confirm lithology
of each boring, well screen intervals,
and lithologic material well screened
within; and Data in Report of Findings
for Initial Source Investigation Apex
Parcel (Kleinfelder 2000) and
incorporation of lithologic data from 18
additional soil borings into the lithologic
component database and bedrock
surface file.
There is no indication of which boring logs were reviewed, and how this was used to refine the
lithology database or bedrock surface. In addition, the text states that 8 additional boring logs were
added from the Kleinfelder report, with no figure showing the location of the boring logs. No
references to Table A.4 or A.5 are included. Do the newly added logs in Table A.5, follow the coding
nomenclature from Table A.4? Section 4.5.5 partially addresses this, indicating the previous
classification scheme was followed (Table A.4) and the data is presented in Table A.5, but no indication
of which wells were specifically updated as part of this scope of work.
27
4.5.2
26/1
Figure 4.3, Figure 4.5 and Figure 4.6,
show the "domain" used for each
dataset.A domain is a perimeter formed
by all of the spatially outermost sample
points within the overall dataset. The
data were interpolated within the
domain using kriging methods. No data
were kriged to extrapolate information
beyond this domain.
How has the domain varied from previous work? Encanto Park B well is currently reported as "Dry";
historically, the well had concentrations of PCE. This appears to be outside of the current domain.
What is a reasonable buffer around a domain to let the data extrapolate? The domain is very limited
in the area formerly defined as the Northwest Area of the Source OU.
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4.5.3
26/3
This sensitivity analysis was conducted
by calculating the PCE plume mass at 5
Hg/L for values of max-gap ranging from
5 to 100 feet. The mass versus max-gap
results were plotted and indicated that
the mass calculation stabilizes with a
max-gap greater than 35 feet. A
conservative max-gap of 50 feet was
chosen for all site-wide PCE plume
kriging to ensure that max-gap did not
impact the representativeness of the
PCE geostatistical analysis. This method
is consistent with the max-gap used in
previous 3DVA efforts for the Newmark
site.
Presentation of the table and/or visuals to show the range of variation and the effect this has on plume
modeling is needed. Previous modeling efforts by Sundance/Tetra Tech did use a Max Gap of 50. How
does this compare to the aquifer thickness? Has that been considered, or only screen lengths relative
to one another? What seems to be missing in this analysis is a site conceptual model for the plume
and what it theoretically looks like distributed across the shallow, intermediate, and deep well screens.
Is it appropriate to visualize the plume as one continuous dataset, irrespective of the hydrogeologic
framework?
29
4.5.3
26/4
All non-detected values were recorded
as "less than" the DL and the less than
multiplier was set to 0.5 (50 percent of
the DL).
Section 4.4.2 indicates DL values set to 10% of DL. The of 50% seems to be a more appropriate
conservative approach. The method used should be clarified.
30
4.5.4
27/1
Groundwater elevation data for April
and October 2022 were evaluated for
use in the 3DVA effort to represent
hydrogeologic conditions at the site.
The groundwater elevations for the
shallow monitoring wells were kriged as
the potentiometric surface, which was
used to "cut" the surface of the
groundwater chemistry plume
components (limiting the upper surface
of the groundwater contaminant
plumes to the water table).
This elevation surface is used to "cut" the top of the plume. Figure 4.2 shows the visualization domain,
but does not indicate that the groundwater chemistry is kriged within the geologic block model. What
is the kriging method's upper, lower and lateral boundary? If it's the domain shown in Figure 4.2, the
data is effectively communicating through bedrock.
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4.5.4
27/2
Figure 4.5 presents the October 2022
data points used to create the
potentiometric surface and the
potentiometric surface. Gridding
parameters for visualizations of the 2D
potentiometric surface are shown in
Table 4.3. Three-dimensional
groundwater hydraulic head gradient
analyses were also performed to better
understand hydraulic gradients and
their relationships with potential
contaminant migrant pathways.
Horizontal and vertical cross-sectional
views show the hydraulic head
distributions and variability with
elevation.
No cross-sectional views are presented on figures for hydraulic gradient analysis.
32
4.5.4-
4.5.5
general
Grid parameters Chemistry = 150x150,
shallow gw 115x120, hydraulic head =
103 xl02, lithology 155x148
Understanding that each model component is using a unique convex shell to define the lateral domain,
why not use a consistent cell size or map all data to a consistent grid?
33
4.5.5
29/2
To support the Rl of the Source OU, and
particularly, the evaluation of the
Northwest Area, additional geologic
data resources were evaluated to
provide a higher resolution of site
unconsolidated lithology and the
bedrock surface in the Northwest Area
than was available from the current
lithologic data.
The additional logs used are not identified.
34
4.5.5
29/Table
4.5
Number of Boring Locations = 3099
This value likely represents entering all boring data intervals as unique locations in EVS, however, there
is very little description of the EVS lithology modeling to indicate why 129+18 lithologic logs = 3099
boring locations in EVS. In addition, this section does not detail if the data is kriged within the confines
of the structure model or is independently kriged.
35
4.5.5
29/Table
4.5
Anisotropy Ratio = 75 (horizontal to
vertical)
The anisotropy ratio of 75 appears to be qualitatively reasonable to get EVS to simulate horizontal
layering. The anisotropy value of 10 used for chemistry, may be appropriate, but there is no discussion
of why these values are so different in the visualization. Nor is any discussion presented to indicate
why these ratios were selected or what the sensitivity is to varying these parameters.
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4.6
30/2
However, applying a constant effective
porosity to estimate plume mass over
an area as large as the Source OU with
varying lithologic properties, lowers the
accuracy of the resulting mass estimate.
Therefore, the Volumetric module was
used to calculate plume mass that
allowed for spatially varying effective
porosity, which improves the accuracy
of contaminant mass calculations.
Instead of multiplying the summation of
the concentration by the volume over
the entire domain at a constant
effective porosity, a spatially varying
effective porosity was estimated for
each grid cell. This more precise
effective porosity value was then
multiplied by the concentration and
volume of each grid cell according to
the following equation:
How was the porosity distribution interpolated? Was the same set of parameters used for the
lithology kriging with effective porosity replacing the lithology code?
37
4.7
30/3
The independent component
visualizations ensure that the
correlations of physical features and
contaminant properties seen in the
integrated visualizations reflect site
conditions and are not a result of
computational artifacts.
Interpolation of groundwater PCE concentrations across the entire source OU without barriers, such as
the Pelona Schist, seems problematic. The model is effectively ignoring barriers between data points
and only treats them as a function of distance, but it seems to suggest the distribution is inherently
related. In general, the entire approach of this visualization modeling is fundamentally different from
that of the SBBA groundwater flow model. The groundwater flow model creates a physical basin and
simulations flow and distribution within that framework. This visualization creates separate datasets
at differing scales with independent visualization and then attempts to integrate those visuals into a
single framework without sharing boundary or physical constraints. For instance, this visualization
produces plumes within the Shandin Hills or above groundwater. Overall, this section of the report
does not provide clarity on the vertical boundaries of any dataset and instead suggests how they were
fitted to the framework after constructed.
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4.8
31/8
Bullet 1
Data comparability and
representativeness were reviewed.
Comparability was assessed between
the various sampling methods used and
differences in analytical method
reporting limits. No notable
discontinuities or trends in the datasets
were identified that appeared strictly
laboratory-or method-related (that
could not be explained by other factors
such as pumping effects
orhydrogeology). Reporting limits were
fairly comparable and caused no
significant effects in the overall trends in
the datasets.
No specific methodology, reference or tabulation of comparative results in presented.
39
5.2
33/5
Figure 5.1 shows that while site-wide
plume size and morphology has not
reduced significantly, the site-wide PCE
mass (estimated for groundwater with
concentrations of PCE at and above 5
Hg/L) has reduced further (from
approximately 23 lbs in 2019 to
approximately 6.4 lbs as of 2022, an
approximate 72 percent reduction).
This statement with respect to PCE mass is misleading (see comment #13) implying a mass decrease of
16.6 lbs (23 lbs to 6.4 lbs) between 2019 and 2022. It should be noted that much of the 16.6 lbs of
PCE, inferred to no longer exist, is not a mass reduction but instead is still present in the groundwater
system at concentrations below 5 ng/L.
40
5.2
33/6
As shown in Figure 5.2, from 1997 to
2022, site-wide mass reduced from
approximately 9,000 lbs to
approximately 6.4 lbs, a reduction of
approximately 99.9 percent.
This statement with respect to PCE mass is misleading (see comment #13) implying a mass decrease of
8,993.6 lbs (9,000 lbs to 6.4 lbs) between 1997 and 2022. It should be noted that much of the 8993.6
lbs of PCE, inferred to no longer exist, is not a mass reduction but instead is still present in the
groundwater system at concentrations below 5 ng/L.
41
5.3
33/8 and
Table 5.1
Table 5.1 shows four site-wide wells
where PCE concentrations remained at
and above the 5 ng/L in April 2022;
including one extraction well and one
extraction well piezometer in the
Muscoy OU, and two monitoring wells
in the Northwest Area.
The text introducing Table 5.1 indicates that the data included in the table are for April 2022 samples;
however, the Table title says October 2022. The sample collected from EPA 110PC appears to have
been collected on November 17, 2022. The sample shown in Table 5.1 collected from EPA 111 was
collected on November 22, 2022, following a long maintenance outage for pump replacement. It
should be noted that if a corresponding sample was collected from EPA 111PC following the restart of
EPA 111, PCE in that sample would also likely exceed 5 ng/L. A sample collected from EPA 111PC on
May 16, 2023 contained PCE reported at 7.8 i-ig/L.
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5.3.1
34/1 and
Figure 5.4
Figure 5.4 shows that the wells with PCE
remaining in concentrations at and
above the 5 pg/L in the Muscoy OU is
present within heterogenous
interbedded silt/clays and sand/gravel,
wherein contaminant persistence is
controlled by matrix back-diffusion.
Figure 5.4 portrays both a map view and a cross-section view of the volume of water estimated to contain
PCE above 5 |ig/L. This figure suggests that the PCE concentrations exceeding 5 |ig/L are limited to aquifer
volumes within the immediate vicinity of the well from which they were sampled with no continuity in
concentration between wells. This is an unrealistic portrayal of the PCE plume in excess of 5 |ig/L and is not
supported by the data. There are no data points between EPA 110 and EPA 111 for which to conclude that
the intervening PCE concentrations between these two wells are less than 5 |ig/L. The cross-section shows
projection of two downgradient wells between EPA 110 and EPA 111 (i.e., MW 137B and MW 138B), which
is misleading as these wells are downgradient of the extraction well network. The PCE concentration for
EPA 110PD is shown in the Figure as 4.8 |ig/L. The legend indicates this is the "2022 PCE Annual Max
Concentration". The maximum PCE concentration for samples collected from EPA 110PD in 2022 was 8.2
|ig/L, as reported for the sample collected on May 17, 2022. A more reasonable interpretation is that the
volume of aquifer with PCE exceeding 5 |ig/L encompasses and extends beyond EPA 110 and EPA 111
within the intermediate zone, rather than limiting this area to 2 individual masses, one of which is shown to
extend only 200 feet from the well (EPA 110PC drops from 8.2 |ig/L to 5 |ig/L in 200 feet with no supporting
data for this drop off in concentration over such a short distance). Furthermore, the Figure 5.4 portrayal
suggests that the concentration drops off vertically within the EPA 110 piezometer cluster immediately
outside the screen interval of EPA 110PC. This is equally unrealistic and ignores the PCE samples collected
from EPA 110PD with a maximum PCE concentration of 8.2 |ig/L for 2022, rather than the 4.8 |ig/L shown
on Figure 5.4. The cross-section appears to show an intervening concentration of 3.2 |ig/L, which appears
to correspond to the October 2022 grab sample from the EPA 110 extraction wellhead. Using this sample
result in this way is also misleading, as this is a composite sample of production over the entire screen
interval, which includes the shallow aquifer and intermediate zone. Monitoring data have demonstrated
that intermediate zone PCE concentrations at EPA 110 are higher than the shallow aquifer PCE
concentrations. This is evidenced by comparing PCE concentrations in EPA 110PB to those of EPA 110PC or
EPA 110PD. The maximum 2022 concentration in samples collected from EPA 110PB is 2.7 |ig/L, compared
to 8.1 |ig/L and 8.2 |ig/L for EPA 110PC and EPA 110PD, respectively. For the reasons mentioned in this
comment, the portrayal of the vertically and laterally very restricted volume of aquifer in excess of 5 |ig/L in
the vicinity of EPA 110 and EPA 111 is unrealistic. Therefore, the mass computed using these volumes is
also unrealistic. SBMWD/Stantec estimate the PCE mass above 5 |ig/L in the vicinity of EPA 111 and EPA
111 was 142 pounds in May of 2022 (Stantec, 2023), as opposed to the combined estimate of 6.4 pounds
for both the vicinity of EPA 111/EPA llland the Northwest Source Area presented in the RI/FFS. The
SBMWD/Stantec estimate is of PCE mass in excess of 5 |ig/L is 2,219% higher than the EPA/Tetra Tech
estimate and does not include the Northwest Source Area that is included in the EPA/Tetre Tech estimate.
43
5.0
Figure 5.7
through
5.12
EPA 006 PCE
The green font in the text box for EPA 006 incorrectly indicates the 0.66 |_ig/L PCE concentration is
below the EIS criteria of 0.5 ng/L.
44
5.0
Figures 5.8
through
5.12
Maps and 3D images of PCE plume
mass above a stated level
To provide proper context of the data points used to support these plume renderings, the locations of
the data points used to support this analysis should be shown. A simple black dot could be added to
the map view to accomplish this. Otherwise, the effects of potential data gaps in developing these
rendering is not apparent.
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6.1
35/3
Trend estimates were constructed for
everv Newmark site groundwater well
with sufficient historical PCE and/or TCE
data (that is with a number greater than
or equal to 10 [n > 10]).
MW 132A was not included in the trend analysis. Graphs presented in URS, 2008a show that this wells
was sampled 12 or more times through mid-2008. URS 2008a Section 4.2 noted that "...relatively high
PCE concentrations detected in samples from alluvial well MW-132A (6 to 25 ng/L) have not
significantly decreased since its installation in summer 2000." The Final Technical Memorandum of
Results Mid 2014 Semi-Annual Groundwater Sampling, prepared for EPA by Gilbane Federal, shows
that 3 additional samples were collected from MW 132A in 2013 and early 2014. Data reported in
Table A-2 of this report indicate that samples from MW 132A were not collected in 2022. No
explanation was provided. Based on review of the time vs. PCE concentration graphs presented in
URS, 2008a and data presented in Gilbane Federal, 2014, other source OU wells with 10 or more
historic samples that were not included in the trend analysis presented in Section 6.0 included CJ-1, CJ-
1A, CJ-2, CJ-3, CJ-7, CJ-12, CJ-13, CJ-14, MWCOE001A, MWCOE008, MW 127B, MW 131A/B/C, MW
132B, MW 133A/B, MW 134 and MUNI 201.
There is no location map included in the RI/FFS report that shows the location of all of the wells for
which time vs. PCE concentration plots were prepared. There are three maps presented in Section 7.0
that show a limited number of the Source OU well locations (Figures 7.3, 7.5 and 7.8).
46
6.4
38/3
For EW-111, the historical PCE data
have been highly variable since 2005,
with periods both below and above the
5 ng/L MCL. The current PCE trend
estimate is close to, but slightly below,
the MCL, and projected to reduce
further over time. However, there is
uncertainty in the confidence band
around this trend and its future
projection. Also, no measurements
have been observed below the MCL
since around 2017. The trend does not
currently statistically exceed the MCL,
nor is it projected to exceed through
2027.
The LOESS projection graph shows there is substantial uncertainty with the PCE trend for EPA 111, with
an increasing trend falling within the 95% confidence band. The Quadratic Exponential graph shows
an increasing trend above the MCL through the end of the projection period.
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6.4
38/3
For EW-110PZC, PCE concentrations
have been mostly declining since 2007.
A recent observation at the end of 2021
was below the MCL; however, the most
recent value was slightly above. The
current LOESS trend is very close to 5
Hg/L, with a 5-year projection that is
mostly 'flat' and quite close to the MCL.
The degree of statistical uncertainty in
the projected trend estimate is again
substantial; however, it is not forecast
to statistically exceed the MCL.
Although the PCE trend for EPA 110PC is slightly below the MCL, an increasing trend falls within the
95% confidence band. EPA 110PD is not discussed although the PCE concentration projected trend
graphs shows an increasing trend above the MCL and thus should not be ignored in this discussion.
48
6.5
34/bullet 2
and 3
Bullet 2: For CJ-6. none of the PCE
sampling results have been below the
MCL since 2006. The current trend
statistically exceeds the MCL and is
projected to remain above 5 ng/L
through 2027. However, the degree of
statistical uncertainty around the trend
projection is large enough to make the
confidence band slightly 'straddle' the
MCL over the last few years of the
projected time frame.
Bullet 3: For CJ-10. PCE concentrations
have generally declined since 1995, but
not enough to reduce concentrations
below the MCL. The most recent
sampling results fluctuate between 15
and 20 ng/L, and the current trend
estimate statistically exceeds the MCL.
Nonetheless, the trend shows the
concentration is slowly declining and is
projected to decrease further in the
next 5 years. Although the projected
trend is forecast to exceed the MCL in
2027, the confidence band around the
projection begins to straddle the 5 ng/L
MCL around 2024.
If this section is going to include discussion of the lower reaches of the projected 95% confidence band
approaching PCE MCL of 5 jj.g/L, discussion of the projected upper reaches of 95% confidence band
exceeding the MCL should also be included (see Comment #s 46 and 47) as to not bias the discussion
towards inclusion of the low end of the confidence band only.
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6.6
39 through
41
SUMMARY RESULTS OF STATISTICAL
ANALYSES FOR EIS-DESIGNATED
EXTRACTION WELLS
This section is very helpful in placing context around the status of the remedy extraction wells with
respect to SBMWD's treatment obligations per the EIS designation and the terms of the DDW Water
Supply Permit which SBMWD operates under. The contents of this section, when evaluated together
with PCE mass remaining estimates above 0.5 |_ig/L, prepared by the SBMWD and presented in
Comment #17/42 and the SI 2023 Progress Report (Stantec, 2023b), provide proper context as to the
status of the remedy extraction wells and achieving the EIS based treatment levels required under
DDW Policy Memo 97-005 and the City's DDW water supply permit.
50
7
42/4
Data show that the highest remaining
concentrations of PCE in groundwater
monitoring wells in the Northwest Area
are now downgradient of the former
steel mill. Wells CJ-10, CJ-6 and CJ-3 are
all downgradient of the former steel
mill.
The assertion of the CJ-10 being downgradient of the former steel mill is questionable based on the
URS, 2008a interpretation. The water level contours presented in URS, 2008a account for hydraulic
separation across Fault A and show groundwater flowing to the southeast along the fault on the up-
thrown block or northeast side of the fault in the vicinity of CJ10 for Spring 2000. The URS
interpretation suggests of the source of PCE in CJ-10 may have originated from groundwater flow
through bedrock fractures northwest of CJ 10. Similar PCE concentrations are historically observed in
CJ-17 which is also located northeast of Fault A suggest accumulation of PCE may have historically
occurred along Fault A between CJ 10 and CJ 17 due to the fault related hydraulic barrier effect. This
would suggest the source of PCE ponding along the fault between CJ 10 and CJ 17 originated from a
source northwest of the Former Steel Plant, in the vicinity of the Former Camp Ono Hospital Area.
51
7.1.3
44/2
The offset in bedrock elevation between
these closely spaced (400 to 600 feet
apart) wells provides the primary
support for the existence of a fault in
this area. However, it is also possible
that the abrupt change in the bedrock
surface is simply a buried erosional
escarpment, unrelated to faulting.
The large differences in water level on opposing sides of the Fault A are indicative of the presence of a
groundwater barrier effect in this area that is consistent with fault related hydraulic separation of the
juxtaposed bedrock and alluvial aquifer blocks. The trend of Fault A, when considered along with the
proximity to the tectonic environment associated with the San Andres Fault Zone and Verdemont Hills
bedrock high also supports this abrupt change in bedrock elevation is fault related. It appears that the
report is trying to minimize the potential effects of faulting/groundwater barriers on groundwater flow
and present a simplistic site conceptual model of groundwater flow paths across this hydraulic feature
reported as Fault A by URS (URS, 2008a) with no affect on groundwater flow direction.
52
7.1.3
44/3
Notwithstanding, the seismic study
concluded that "there is no compelling
evidence in the data that the faults act
as significant groundwater dams." Even
during decreased groundwater
elevation conditions, groundwater in
the weathered bedrock at monitoring
well CJ-10 may still reach the adjacent
alluvial aquifer by flowing across the
fault trace/alluvium contact (SAIC
2001).
The differential head across the Fault A, which is often in excess of 100 feet indicates there are two
distinctly different hydraulic areas on opposing sides of Fault A. Groundwater contour maps prepared
by URS for Spring 2000 and Fall 2006 best show this distinction (URS, 2008a). The URS interpretation
shows a component of flow on the northeast or bedrock side of the fault flowing to the southeast
subparallel to the fault in the vicinity of CJ-10. This interpretive finding is not discussed in this report.
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7.1.6
46/2 and
Figures 2-
7, 4-5, 7-5
and 7-14
The highest hydraulic heads measured
in the Verdemont Hills area are at
MWCOE009 (screened in bedrock) and
flow appears to be radially away from
this portion of the Verdemont Hills as
shown on Figure 7.5.
MWCOE009 is screened higher than all other bedrock wells completed in the up-thrown block area on
the northeast side of Fault A. This well may have an impeded hydraulically connection through the
bedrock fracture system to the other up-thrown block bedrock wells (CJ10, CJ17, MWCOE004,
MWCOE 005, MWCOE 007 and MWCOE008) which are all screened at a similar lower elevation. This
interpretation ignores the presence of Fault A which clearly has created hydraulic separation between
the opposing sides of the fault. There is over 100 feet of water level difference across this feature in
Spring 2000 and approximately 60 feet in Fall 2006 (URS, 2008a).
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7
7.1.4 and
7.1.6
General comment on site conceptual
model for groundwater flow and the
effects of faulting in the Vicinity of the
Northwest Source Area.
It has been recognized for many years that the area referred to by EPA/Tetra Tech as the Northwest
Area is the source area for the Newmark OU and Muscoy OU plumes. EPA has recognized on several
occasions, that the most plausible source of PCE/TCE groundwater impacts in the Newmark and
Muscoy OU plumes is the activities performed at Camp Ono during the 1940s. SBMWD and their
experts have provided extensive data regarding the Army's activities at Camp Ono, much of which is
summarized in the letter to this comments table is attached to. It is possible that multiple army PCE
sources have impacted groundwater in the Northwest Area, which was transported up to 10 miles
downgradient to the location of the extraction well networks. Much of this transport occurred prior to
discovering this contamination in the 1980's. Based on what we know about the extensive area of
groundwater impacts originating from the Northwest Area and the changes in PCE distribution with
time, most of the contamination that originated from the Northwest Source Area has been flushed out
of the area and is currently being addressed by the RA extraction systems. The groundwater flow
dynamics and effects of localized Northwest Source Area faulting have played a large role in the
evolution of the PCE plumes and the residual levels that remain in the Northwest Source Area today.
The URS 2008a Hydrogeological Investigation Report provides a plausible site conceptual model for
historic and current groundwater contamination conditions in the Northwest Source Area. The
following two excerpt from the URS 2008a report are provided to illustrate this conceptual
understanding.
"A major effect of this fault block segregation appears to be that the alluvial groundwater beneath the
Cajon Landfill is most affected by recharge from the larger drainage basins to the northwest (e.g. Cajon
Wash), while bedrock groundwater beneath Camp Ono appears to be most affected by recharge from
the smaller basins of the San Bernardino Mountains to the north (e.g. Cable Creek). Accordingly, the
alluvial hydrologic unit beneath the Cajon Landfill may be periodically "flushed out" during large
recharge events, as large amounts of fresh water move through the system, while the bedrock
hydrologic unit below Camp Ono appears to be less dynamic."
"It appears that the relatively high PCE concentrations (up to 130 ng/L) detected in the area down-
gradient of the Cajon Landfill (Fault Block B) (EMCON, 1995) at the beginning of the Source OU
investigation in the late 1980s have migrated down-gradient and been diluted within the Newmark
Site. However, relatively high PCE concentrations (up to 65 ng/L) detected in wells screened in bedrock
beneath northern Camp Ono and the area between Camp Ono and the Cajon Landfill (Fault Block B')
appear to have been relatively stable since 1995 (when the first of these wells was installed). This
rArtfumiiratorl horlrr\rU i mif mow ho clrwu/lw orlrlinn rr\nfominofir\n fr\ fho ollnwiol i mifc fr\ fho cr\i ifh\*;ocf
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(continued)
7
7.1.4 and
7.1.6
fractured flow impeded by fault zone materials, but the overall effect does not seem to include
significant dilution of the contamination in the bedrock unit below northern Camp Ono (Fault Block A).
Additionally, relatively high PCE concentrations detected in samples from alluvial well MW-132A (6 to
25 ng/L) have not significantly decreased since its installation in summer 2000."
These concepts, when considered along with other interpretations included in the URS report, suggest
that PCE originating southwest of the Fault A or migrating across Fault A/B, have been largely flushed
out of the area and transported downgradient towards the extraction wells. Residual PCE in the
bedrock aquifer of the up-thrown block (northeast) of Fault A appears to be pooling against the
faulting related partial hydraulic barrier segregating the juxtapose bedrock aquifer and alluvial vadose
zone/aquifer. Groundwater elevation differences across Fault A appear to juxtapose saturated
bedrock against unsaturated alluvium at shallower depths (i.e., the depth of the screen interval of CJ
10). The URS site conceptual model interprets the transfer of PCE laden water from the up-thrown
block to the down-thrown block, occurs across a seepage face between the saturated bedrock
fractures and unsaturated alluvial materials, with the mechanical effects of faulting creating a zone of
decreased hydraulic conductivity associated with dynamic movement along the fault. This concept is
illustrated in Figure 4-1 of URS 2008a.
This appears to be a more plausible site conceptual model then the one proposed in the RI/FFS that
doesn't consider the separation of the bedrock/alluvial groundwater systems, interprets Fault A as an
erosional feature, and interprets horizontal gradients of 0.30 or 30% across Fault A as reasonable for a
single aquifer system void of barrier effects. The simplistic RI/FFS interpretation is used to justify flow
path analysis and contaminant transport modeling that do not consider the barrier effects of Fault A,
and are therefore flawed.
55
7
General
Comment
Focus on CJ 10
The highest concentration reported on the up-thrown block side of Fault A is found in CJ 10 and CJ 17,
which are both located along the inferred location of Fault A and completed in bedrock. CJ 16 is
located south of the Former Camp Ono Hospital Area. When speaking of the area of elevated PCE
residuals, much of the focus has been on CJ 10, as this is the well with the highest PCE concentrations.
CJ 17 has historically had elevated PCE concentrations relative to other Northwest Source Area
monitoring wells, with reported concentrations largely above MCLs through 2022 (range 3.5 to 48
l_ig/L). There are no other monitoring wells located along Fault A between CJ 10 and CJ 17. It is
possible that the area between these wells is a continuous area of elevated PCE levels ponding against
Fault A, and seeping through into the vadose zone alluvium of the down-thrown fault block.
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General
Comment
Figures 2-
7, 4-5, 7-5
and 7-14
Groundwater contour maps do not
included posted water level data.
It is a standard industry practice to include posted water level data used to prepare groundwater
contour maps on the subject maps. The four water level contour maps in this report do not provide a
posting of the underlying data used to prepare the water level contour maps. This limits the ability of a
reviewer to assess the interpolated groundwater surface in context with the actual underlying data.
57
7.2.2
48/3
Past investigations identified the
following primary suspected sites where
plume constituents may have been
released to groundwater:
• Former Camp Ono:....
• Cajon Landfill:....
• San Bernardino International
Airport:...
As none of these locations were
determined to be sources of the
Newmark site PCE plume, an online
database search was performed in 2012
as part of the 1997 to 2012 3DVA
effort.
This section dismisses Former Camp Ono as being a potential source of the Newmark Site PCE plume
with no defensible justification presented and is patently incorrect. This is a complete reversal from
the positions previously adopted by EPA and contrasts with statements made by EPA during the August
23, 2023 public meeting. As described in the cover letter transmitting these comments, EPA has
historically recognized that Camp Ono is the primary source of PCE groundwater contamination for
the Newmark Site.
Subsequent analysis included in this section evaluates the Former Camp Ono Hospital Area as a
potential source of PCE observed in CJ10 and CJ17, which is a contradiction to the premature
conclusion that Camp Ono is not a source of PCE to the Newmark Site plume that was presented in this
subsection.
58
7.2.3
51/3
The relationship between PCE in vadose
zone soil gas and in saturated zone
groundwater was also investigated at well
CJ-10, close to the former steel mill. Well
CJ-10 is screened over two depth
intervals: from 79 to 89 feet bgs (in
vadose zone colluvium) and from 135 to
145 feet bgs (in saturated zone bedrock).
Soil gas samples were collected from the
vadose zone adjacent to the upper
screened interval in May 2014 (Gilbane
2014) The increasing concentrations
indicated that elevated concentrations of
PCE were present at that depth of the
vadose zone adjacent to the well screen.
An estimated PCE pore water
concentration of 180 |_ig/L was calculated
from the maximum soil
PCE detections from soil gas samples collected in the vadose zone directly adjacent to CJ-10 do not
provide conclusive evidence of the source of said PCE in soil gas contamination which is inferred to be
the former steel mill. The RI/FFS provides no justification for the statement "these results support the
interpretation that the elevated and sustained concentrations in groundwater from CJ 10 are related
to the former steel mill." The spread of high PCE concentrations in groundwater in bedrock in the area
between CJ 10 and CJ 17 is not considered.
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(continued)
7.2.3
51/3
gas concentration, which was five to
seven times greater than the two
previous concentrations of PCE in
groundwater collected from CJ-10 (27 and
35 |_ig/L). The evaluation concluded: "soil
gas results suggest the potential presence
of a contaminant source in the vadose
zone in the vicinity of the CJ-10 upper
well screen, with concentrations
moderately greater than those in
groundwater from the lower screen."
These results support the interpretation
that the elevated and sustained
concentrations in groundwater from CJ-
10 are related to the former steel mill.
59
7.2.4
52/4 and
Figure 7-
14
Figure 7.14 shows the wells with the
highest PCE concentrations in 2015
superimposed on a plot of advective
groundwater flow paths. Monitoring
well CJ-10 had the maximum PCE
concentration (29 ng/L) while CJ-17 had
the second highest at 11 ng/L. The flow
path analysis shows that PCE
concentrations from these two wells
may have been derived from two
different sources. Although a distinct
source for the PCE in groundwater at
well CJ-17 has not been identified, it
may have originated from within the
former hospital area (hereafter; the
"former hospital flow path").
As discussed in Comments # 50 through 55, the flow path analysis presented in Figure 7-14 is overly
simplistic and flawed as the barrier effects of Fault A are ignored. Therefore, the inference that CJ10
and CJ 17 originate from separate sources based on the presented flow path analysis is unsupported.
Groundwater contours presented by URS for Spring 2000 (URS 2008a; Figure 3-4) are suggestive of a
flow path from the Former Camp Ono Hospital Area through CJ 17 and then downgradient towards CJ
10. The URS site conceptual model includes leakage from the bedrock aquifer in the vicinity of CJ
10/CJ17 of the up-thrown block across Fault A and into the adjacent vadose zone alluvium, thus
providing a mechanism for transfer of contamination across the fault partial barrier in a restricted
manner. This may be a more plausible explanation of the elevated PCE concentrations observed in CJ
6.
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7.3.1
54/2
There are two flow paths of interest
within the Northwest Area:
• The "former steel mill flow path"
which extends from bedrock well CJ-10
(the well with the highest PCE
concentrations in the Northwest Area),
through well CJ-6 (screened across
colluvium and bedrock) to well CJ-3
(screened in alluvium). The suspected
original source area for this flow path is
the former steel mill, located less than
500 feet upgradient from CJ-10.
• The "former hospital flow path" which
extends from CJ-17, the well that until
recently generally had the second-
highest concentrations in the Northwest
Area, to well CJ-16. Both wells appear
to be screened in unweathered
bedrock. The original source of the
contamination for this flow path
remains uncertain; however, it appears
likely that it would have been within the
former hospital area.
These hypothesized flow paths are the basis for some simplistic contaminant fate and transport
analyses presented in Section 7.3. The hypothesized flow paths extend through Fault A and Fault B, as
if the faults have no effect on groundwater flow. As discussed in Comment #54, this is contrary to the
interpretations advanced by URS in the 2008 Hydrogeological Investigation Report. Ignoring the
effects of the fault is to a large extent the fundamental basis of the contaminant Fate and transport
modeling results presented in Section 7.3. The simplistic models cannot quantitatively account for this
much more complex groundwater flow and contaminant transport system present in the Northwest
Area. Therefore, the results of these analyses are considered unreliable. However, the underlying
monitoring data for the Northwest Source Area are supportive of the conclusion that residual PCE
groundwater contamination remaining in the Northwest Source Area does not pose a significant threat
of further impacts to downgradient supply wells.
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13.2
83/4
A modified version of the existing
Northwest Area component of the site-
wide groundwater monitoring program
would be used to monitor the state of
the plume. Modifications would include
expanding the monitoring network to
include existing monitoring wells CJ-1A,
CJ-2, CJ-3, and CJ-11, which are not
currently monitored. As discussed in
Section 7.5, adding these wells would
improve plume delineation by
increasing data density for any future
3DVA-based remedy progress
monitoring. Figure 13.2 shows the
locations of monitoring wells to be used
for MNA groundwater monitoring.
Based on Figure 13.2, the preliminary proposed monitoring program for the Northwest Source Area
would include 17 existing monitoring wells. A review of the Figure indicates that some of the
Northwest Source Area monitoring wells that have historically been included in the monitoring
program are not included in the Alternative 2 - MNA monitoring program. A review of the Alternative
2 cost estimate presented in Appendix A indicates that this alternative includes preparation of a
monitoring plan. The rationale for the inclusion/exclusion of existing monitoring wells from the MNA
monitoring program should be clearly documented in the monitoring plan. If SBMWD were to
integrate the MNA monitoring program into their existing Newmark Site monitoring program
responsibilities, as discussed in the cover letter transmitting these comments, SBMWD would need to
be involved in the decision making process as to which wells should be included.
62
13.2
83/5
Groundwater monitoring would involve
periodic groundwater sampling and
analysis at a frequency that is
anticipated to decrease over time.
Groundwater would be monitored semi-
annually for 2 years, then annually for 3
years, and then once every 5 years until
the PRG is attained.
The monitoring frequency for the MNA program should coincide with the frequency established in the
Consent Decree for site-wide monitoring wells, which is performed annual basis.
63
15.7
94/9
The present worth costs for the three
groundwater remedial alternatives,
from highest to lowest, are as follows:
(1) Alternative 3 is $8.68 million; (2)
Alternative 2 is $1.24 million; (3)
Alternative 1 is $0. The cost estimate is
presented in Appendix F.
The cost for the Alternative 2 (preferred alternative) of monitored natural attenuation appear to be
low. The present worth costs for Alternative 2, as presented in Appendix F, are as follows:
Capital Cost $141,500
O&M Cost $809,356
Contingency Cost (30%) $285,257
Total $1,236,113
Remedial Duration 10to47vears
The duration of the program (10 to 47 years) is not well constrained. Information regarding the
current condition of the monitoring wells, assumed maintenance/replacement requirements are not
provided, as is reasonable at this FFS level cost analysis. If EPA and SBMWD were to enter into
discussions regarding the integration of the MNA program into the Newmark OU/Muscoy OU RA
monitoring program, a detailed cost analysis would need to be performed by SBMWD and scope of
work and underlying assumptions would need to be more clearly defined by both parties.
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Exhibit 2
Training and Supply Activities at the Desert Training Center in World
War II and Their Relation to the Base General Depot at Camp Ono,
by William T. Bowers (Col. U.S. Army, Retired), June 2, 2005 (54 pages)
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June 2,2005
Training and Supply Activities at the
Desert Training Center in World War II
and Their Relation to the Base General Depot at Camp Ono
by William T. Bowers (Colonel, U.S. Army, Retired)
The Desert Training Center was a key element in the U.S. Army's plan during
World War II to field an Army capable of meeting its enemies in battle, overcoming them
in combat, and logistically sustaining large forces to drive into vital enemy territory for the
final knockout blows. During the war, the Desert Training Center became the largest
American Army base in the world, covering a 60,000 square mile area, some 350 miles by
250 miles in extent, larger than the state of Pennsylvania. Over a two-year period from the
spring of 1942 to the spring of 1944, between 800,000 and 1,000,000 troops trained at the
Desert Training Center, including eight corps headquarters, seven armored divisions,
thirteen infantry divisions, and about 400 smaller units.1 A unique feature of the Desert
Training Center, and one that made it the best training area for large-size units in the
United States, was its capability of replicating a complete theater of operations with a
combat zone (where corps and divisions maneuvered in training) and a communications
zone (from which logistical support flowed to corps and divisions). The Base General
Depot, located at Camp Ono near San Bernardino, California, west of the main training
area, served as the nerve center and key support base for the communications zone, without
which the combat training in the maneuver area could not be accomplished.
1 A glossary of military terms used in this paper is on page 51.
2 For size of the Desert Training Center, see Headquarters, Desert Training Center, Memorandum No. 7, 25
January 1943, p. 2 (SB 1238), National Archives and "Histoiy of the Communications Zone, CAMA," no
date, p. 44 (SBC 7826), National Archives; for number of individuals trained, see California State Military
Museum, "California/Arizona Maneuver Area (Desert Training Center)" and "Camp Young," both accessed
1
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June 2,2005
Figure 1 - The Desert Training Center In the Mojave Desert Between Los Angeles
and Phoenix. The expanded view shows the key terrain of the training area.
Logistical support facilities were located between the training area and Los Angeles.3
20 July 2004, http://www.militaiymuseum.org/CAMA.html and
http://www.militaiymuseum.org/CpYoung.html; for numbers of units, see Headquarters, Army Ground
Forces, "Report of Desert Training Center and California-Arizona Maneuver Area," no date, inclosure 4
(SBC 7431), National Archives. The division organization changed during the war, but by 1944 an infantry
division contained 16,363 men and 2,115 vehicles; an armor division contained 12,317 men, 299 armored
vehicles and 2,663 motor vehicles; a corps consisted of a number of divisions plus additional support units
such as logistical, engineer, chemical and communication. For the value of the center see comment of Lt.
Gen. Lesley J. McNair in Lt. Col. Bell I. Wiley, Training in the Ground Army, 1942-1945, Army Ground
Forces Study No. 11, Historical Section, Army Ground Forces, 1948, p. 6.
3 Map from XX Corps History, Walton Walker Papers, Box 1, U.S. Army Military History Institute.
2
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June 2,2005
The Army established the Desert Training Center four months after the attack on
Pearl Harbor, in the midst of rapid expansion and hurried efforts to send troops overseas to
begin the fight against the Japanese and Germans. The Desert Training Center evolved
into a massive maneuver area where large formations could realistically practice the
combat and logistical skills needed to succeed on the battlefield. The role that the Desert
Training Center assumed was a reflection of the experience gained in preparing for combat
in World War I and a pragmatic appreciation of the capabilities of the formidable enemies
faced by the United States in World War II. Gen. George C. Marshall, the Chief of Staff of
the Army, was determined that the mistakes of the past would not be repeated and that
American troops would be thoroughly prepared before meeting the enemy in battle.
Marshall's deputy in charge of training Army ground forces, Lt. Gen. Leslie J. McNair, had
the vision, experience, and skills to ensure that Marshall's goals were achieved.
Historical Background
World War I. In World War I Army training was inefficient, disjointed, and
largely ineffective. The main problem was the failure to prepare realistically for war in
peacetime by developing doctrine, training adequate numbers of leaders, and preparing
specific plans to rapidly mobilize and train a large Army in an emergency. With inadequate
peacetime preparations, the mobilization in 1917 and early 1918 overwhelmed the meager
resources of the Army, which expanded from about 200,000 partially trained troops to over
3.5 million soldiers nineteen months later at the time of the November 1918 Armistice.4
4 Marvin A. Kriedberg and Merton G. Henry, History of Military Mobilization in the United States Army,
1775-1945 (Washington: Department of the Army, 1955), pp. 281-374; Russell F. Weigley, History of the
United States Army (New York: Macmillan, 1967), pp. 371-389; Timothy K.Nenninger, "American Military
3
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June 2,2005
The Army in World War I never recovered from its lack of peacetime preparations.
By the end of 1917, thirty-two division-size mobilization and training camps had been
constructed, all but three of which were in the eastern half of the country. Hurriedly thrown
up and lacking adequate space for realistic weapons firing and the maneuver of large-size
formations, the camps provided training that was inefficient, unrealistic, and did not meet
the requirements established by Gen. John J. Pershing, the commander of the American
Expeditionary Forces (AEF) in France. Training in France was also inadequate, with only
one of the forty-three divisions that deployed overseas completing the entire specified
training cycle, which included a final phase of large-scale field maneuvers for the entire
division. Additionally, the training in the United States and France did not reflect the
realistic conditions on the Western Front, encompassing not only front line fighting but
also the massive logistical support requirements of World War I combat. Support units
were short of personnel and not trained for the enormous and complex task of moving
supplies forward from seaports and rear area depots to the battlefield to sustain the fight.
At certain times during the American Meuse-Argonne offensive that began in September
1918, a number of soldiers in combat units were on the verge of starvation. By November
when the war ended, the logistical situation of the AEF bordered on chaos. Inevitably,
soldiers paid a high price on the battlefield for the Army's failure to prepare them for
combat and logistically sustain them in battle.5
Effectiveness," in Allan R. Millett and Williamson Murray (eds.), Military Effectiveness (Boston: Allen and
Unwin, 1988), 1:148.
5 Nenninger, p. 149; Kriedberg and Henry, pp. 311-318; Leonard L. Lerwill, The Personnel Replacement
System in the United States Army (Washington: Department of the Army, 1954), pp. 179-215; Paul F. Braim,
The Test of Battle (Newark: University of Delaware Press, 1987), pp. 53-56,103, 107,162-3; Annual Report
of the Chief of Staff, 1919, p. 35.
4
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June 2, 2005
In World War I, George Marshall and Lesley McNair were AEF staff officers
charged with preparing the Army for combat, and they were intimately familiar with the
costly failures. Indeed, a number of Army and Congressional leaders were fully aware of
the training and logistical shortfalls in the Army and realized that the United States
succeeded in the World War, only because our Allies (Britain and France) were able to
contain the enemy until the American Army could mobilize, prepare for combat, and learn
the hard way how to succeed on the battlefield. They understood that in a future war, we
might not be as fortunate.6
Interwar Years. At the end of the World War, the Army rapidly demobilized. The
National Defense Act of 1920 created a realistic training program for peacetime
preparations for war, but because of inadequate funding and public and Congressional lack
of interest, most of the act could not be implemented. Unable to conduct practical training
for Regular Army, National Guard, and Reserve units (including large-scale maneuver
exercises with combinations of infantry, tanks, and aircraft), the Army focused its
resources on its school system to prepare leaders for increased responsibilities in the event
of a future emergency requiring massive mobilization and rapid training of the Army.
During this period, both Marshall and McNair were directly involved with preparing the
Army for a future war, Marshall at the Infantry School and McNair at the Field Artillery
School. Beginning in the mid-1930s, the Army developed specific training plans based on
the lessons learned in the World War and doctrine that had been written during the 1920s
and 1930s. Thus as Europe moved towards war in the late 1930s, the Army, although still
6 In World War I Marshall was the G-3 of the 1st Division and later First Army; McNair was in charge of
artillery training for the AEF.
5
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June 2,2005
in many ways poorly trained and woefully short of personnel and modern equipment, had a
solid, workable basis for building up large forces and preparing them for future combat.7
The Limited Emergency. Gen. George C. Marshall became Chief of Staff of the
Army on 1 September 1939, the same day that Germany invaded Poland and initiated a
major war once again in Europe. War was not a surprising development. Both in Europe
and in Asia, Germany, Italy, and Japan had demonstrated their aggressive intentions for
several years. Germany and Japan employed large, well-trained, ground and air forces
utilizing the most modem equipment. Because of the increased threat of general war in
both Europe and Asia and specifically the invasion of Poland and subsequent declaration
of war on Germany by France and Britain, President Franklin D. Roosevelt proclaimed a
limited national emergency, allowing the Army to expand from 188,000 to 227,000. With
this modest increase, Marshall was able to organize new Regular Army divisions and corps
and army headquarters, which immediately began basic soldier and small unit training.
Marshall brought these efforts together by conducting three corps-level field exercises,
involving up to 70,000 Regular Army troops with National Guard commanders and staffs
observing, in April and May 1940 in Georgia, eastern Texas, and Louisiana.8
Marshall firmly believed in large-scale maneuvers, which when conducted
properly, produced more effective forces with improved coordination between combat
elements, increased efficiency in supply and communications, and more experienced staffs
at all levels. Such exercises were also invaluable for testing new organizations, methods,
7 Kriedberg and Henry, pp. 378-492; Mark S. Watson, Chief of Staff: Prewar Plans and Preparations
(Washington: GPO, 1950), p. 17-30; Lerwill, pp. 234-239; Forrest C. Pogue, George C. Marshall: Education
of a General, 1880-1939 (New York: Viking, 1963), pp. 251-252.
8 "Biennial Report of the Chief of Staff, July 1, 1939 to June 30,1941," in Report of the Secretary of War to
the President, 1941 (Washington: GPO, 1941), pp. 48-49, 63; Watson, p. 204.
6
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June 2,2005
and tactics under realistic field conditions. For Marshall, perhaps the greatest benefit was
the opportunity to train and evaluate commanders in order to identify those most suitable
for higher command and the demands of field operations.9
Meanwhile in February 1940, Marshall temporarily suspended classes at many
Army schools and used the faculty to write doctrinal and technical manuals based upon the
latest combat operations witnessed in Europe and Asia. Over the next year, these
instructors wrote 60 field and 160 technical manuals and contributed to a comprehensive
training film program, which produced 80 films by the summer of 1941. The production of
doctrinal and training materials, along with an increased emphasis on National Guard
training, was a key part of Marshall's preparations for the mobilization and training of a
much larger force based upon the world situation. After the swift defeat of Poland in
September 1939, the war in Europe had stabilized along the fortified French-German
border. Marshall did not believe that the stalemate would last. His assessment was
confirmed in April, May, and June 1940 when Germany rapidly overran Denmark,
Norway, the Netherlands, Belgium, and France and drove British forces from the European
continent. German combat operations were called "blitzkrieg" and skillfully employed
ground and air forces in combined attacks using the most modern equipment to achieve
quick and decisive results.10
Peacetime Mobilization and Training. The events in Europe produced an
immediate shift in Congressional and public sentiment toward issues of war preparation. In
late May and June 1940, even before the fighting in France ended, Congress began to
9 "Biennial Report, 1939-1941," p. 49; Forrest C. Pogue, George C. Marshall: Ordeal and Hope, 1939-1942
(New York: Viking, 1966), pp. 89, 91.
10 "Biennial Report, 1939-1941," p. 65; Watson, p. 187
7
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June 2,2005
consider legislation calling the National Guard into federal service, providing money for
weapons and equipment for a force of over a million men, and establishing a peacetime
draft, an action that had never before been taken. With obvious Congressional and public
support for the proposed readiness measures, the Army shifted its focus from training the
small Regular Army and improving the status of the National Guard to mobilizing a large
force and preparing it for combat. Marshall activated a new organization, General
Headquarters (GHQ), in July 1940 to control the training of all Army field units in the
United States and selected Brig. Gen. (later Lt. Gen.) Lesley J. McNair as GHQ chief of
staff to oversee its day-to-day activities.11
Marshall and McNair proceeded with a carefully timed, sequential program.
Between June and August 1940, even before passage of the draft legislation, the Army
formed six Regular divisions and rapidly expanded its school system. In late August,
legislation federalizing the National Guard passed Congress, and by the middle of the next
month, the Selective Service and Training Act became law thus establishing a peacetime
draft. The total Army strength was set at 1.4 million with 500,000 Regulars, 270,000
National Guards, and 630,000 draftees. In September the War Department called up the
first of the National Guard divisions. The activations continued through the fall and winter,
and by March 1941, a total of eighteen National Guard divisions had been federalized and
19
filled to authorized strength with draftees.
Throughout this buildup, Generals Marshall and McNair faced a complex and
difficult situation. In addition to the expected confusion and disorder associated with a
11 Watson, pp. 164-165,206-207; "Biennial Report, 1939-1941," pp. 49-50; Weigley, pp. 429-430; Pogue,
Ordeal and Hope, pp. 82-83.
12 Watson, pp. 184, 188; "Biennial Report, 1939-1941" pp. 52-53; Robert R. Palmer, Bell I. Wiley, and
William R. Keast, Army Ground Forces: the Procurement and Training of Ground Combat Troops
(Washington: Center of Military History, 1948), pp. 489-493.
8
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June 2,2005
large and rapid expansion of the Army, training was severely hampered by widespread
shortages of weapons and equipment, exacerbated by British demands for military material
of all types to replace their battlefield losses. However, to Marshall and McNair, the
biggest factor was the uncertainty of the situation. Army leaders had always assumed,
based on historical precedent, that there would be no manpower draft until after a formal
declaration of war. As in World War I, they expected that recruits and newly raised units
would be able to move quickly through the mobilization centers and training camps to an
overseas theater of operations for further training before commitment to battle. Now with a
peacetime draft and federalized National Guards expected to produce an Army of over one
million and with no declaration of war or overseas theater in which to deploy troops, the
existing military facilities in the United States were inadequate to accommodate the
expanded force. Major construction on existing sites was needed to house troops, but work
could not begin until Congress passed the necessary legislation, which occurred so late
(August 1940) that construction could not be completed before the onset of winter. Even
after the completion of new buildings to house soldiers, the number of existing posts and
camps that could accommodate a division or more of troops was insufficient. Moreover,
there were only a limited number of government-controlled areas that were suitable for
large-scale maneuvers needed to complete the training of divisions, corps, and armies.
Marshall and McNair hesitated to acquire additional training areas because the
Congressional legislation passed in August 1940, which authorized the increased force of
13
draftees and federalized National Guards, was only effective for one year.
In June 1941, as the war in Europe spread with the German invasion of the Soviet
Union, the subject of extending the service of the one-year men came under serious
13 Watson, pp. 183, 196-197
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June 2,2005
consideration. A lively and heated debate ensued in Congress and the press. The matter
was settled in mid-August when Congress extended the service of the draftees and Guards
thus ensuring that the Army that had been built up and prepared so carefully over the last
year would not disintegrate. However, the act passed by only one vote in the House of
Representatives, reflecting the division in the nation over the prospects of actively entering
, 14
the war.
The Louisiana and Carolina Maneuvers. The program laid out by General
McNair's GHQ called for each division to undergo one year of training divided into three
four-month periods. The first was devoted to basic training for individuals (thirteen
weeks), followed by unit training for squads, companies, and battalions. The second
emphasized progressive combined arms (infantry, armor, artillery, engineers, air,
communications, and logistics) training. The third, scheduled to take place in the late
summer and fall of 1941, involved extensive field maneuvers of entire corps and field
armies. With the passage of the new legislation extending the service of draftees and
Guardsmen, the maneuvers could proceed.15
In September 1941 over 350,000 men and 1,000 planes concentrated in Louisiana
for army-level maneuvers involving five corps and eighteen divisions. In late November, a
slightly smaller force, which featured massed armor formations, exercised in North and
South Carolina. Much of the area of the maneuvers lay outside the boundaries of
established Army posts. The maneuvers were designed to be free, meaning that each force
commander received a general tactical mission and then operated at his own discretion in
14 Watson, pp. 214,220, 230-231.
15 "Biennial Report, 1939-1941," p. 64.
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response to changing battle conditions. However, realism was affected by peacetime safety
regulations, lack of equipment, and shortage of aviation and armored elements in
proportion to the number of troops engaged. Despite these problems, General McNair
directed that measures be taken to achieve the realism of actual warfare, except for
casualties and destruction of property.16
Despite McNair's guidance, the conditions of combat could not be realistically
duplicated, particularly in a civilian environment with existing infrastructure that could be
utilized by enterprising soldiers to provide shortcuts and lessen the rigors of combat
operations. The maneuvers did demonstrate the progress the Army had made in the last
year when it had increased sevenfold and achieved marked improvements in organization
and technical proficiency. The maneuvers also revealed specific training deficiencies that
could be addressed in future training, such as air support of ground operations. But McNair
was realistic when he stated at the end of November 1941 that training deficiencies
persisted to such an extent that it appeared that "finished troops could not be trained in one
year." In summary, he said
The question is asked repeatedly, "Are these troops ready for war?"
It is my judgment that, given complete equipment, they certainly could fight
effectively. But it is to be added with emphasis that the losses would be
unduly heavy, and the results of action against an adversary such as the
Germans might not be all that could be desired.17
With the stipulation noted above, McNair stated that of the 34 divisions under
GHQ, only half were ready for combat. Efforts were undertaken to correct the deficiencies
16 Christopher R. Gabel, The U.S. Army GHQ Maneuvers of 194], Washington: Center of Military History,
1991).
17 Kent Roberts Greenfield, Robert R. Palmer, and Bell I. Wiley, The Army Ground Forces: the Organization
of Ground Combat Troops (Washington: Center of Military History, 1947, 1987), pp. 43-46; quotes from p.
46.
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identified in the Louisiana and Carolina maneuvers. Planning was also begun to determine
the best way to increase the number of divisions ready for combat while maintaining and
improving the proficiency of those divisions that had already completed their training
cycle and had gone through extensive field maneuvers. A limiting factor was the lack of
adequate training facilities, particularly for large-scale free maneuvers. One War
Department option was to create twenty-seven Regular Army divisions in a reserve status
over a three-year period by releasing from active duty draftees who had completed their
training and creating a full-time cadre for the divisions. It was expected that these partially
trained divisions could be rapidly called to duty in an emergency and quickly reach a fully
trained status. McNair pointed out that twenty-seven divisions represented only 430,000
soldiers of the 2.7 million that current Selective Service legislation would provide in the
next three years. Obviously, other measures were required to train the complete force. This
planning became obsolete on 7 December 1941 when Japan attacked the United States.
18
Within days, the nation was at war with Japan, Germany, and Italy.
Training in World War II
The New Plan. With the outbreak of war, the situation confronting the Army
completely changed. Faced with a global war against two formidable opponents, only an
extraordinary effort could produce a military force capable of launching attacks across vast
oceans against hostile shores, logistically sustaining the massive endeavor, and ultimately
defeating the veteran soldiers of Germany and Japan in battle. There was now a need for an
even more rapid and immense expansion of the Army, unlike anything previously
experienced. The mobilized force must receive the most realistic and rigorous training
,8 Greenfield, Palmer, and Wiley, pp. 51-52.
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possible. General Marshall began with a reorganization to meet the new challenge. The
reorganization, which became effective in March 1942, assigned most major activities to
three commands directly under Marshall: the existing Army Air Forces (AAF) and the
newly created Army Ground Forces (AGF) and Services of Supply, later renamed Army
Service Forces (ASF). The AGF under General McNair, was responsible for organizing
and training all ground force units and individuals. The AAF and ASF focused on aviation
and logistics respectively. With limited manpower and material resources, not everything
could be accomplished at once. McNair put maximum effort into organizing and training
combat divisions at the expense of service units and replacement training. During 1942 the
Army planned to increase the number of divisions by over 100 percent, going from 36 to
74 with the total in 1943 reaching over 100.19
By the end of 1941, General McNair had perfected the process of activating and
training divisions. A new infantry division's cadre of experienced personnel (172
commanders and key staff officers and 1,200 enlisted soldiers) was selected and trained
two to three months prior to the division activation. Within a month of activation, the cadre
was brought together for additional training at the designated activation camp, where they
were joined by the remaining officers and about 50 percent of the unit's equipment. On the
date of activation, the remaining enlisted men, over 13,000, began to arrive, and division
training began two weeks after activation. The training proceeded through four phases: 17
weeks of individual instruction, 13 weeks of unit training, 14 weeks of combined arms
exercises, and 8 weeks of large-scale maneuvers emphasizing air-ground and mechanized
19 Pogue, Ordeal and Hope, pp. 289-290; Greenfi eld, Palmer, and Wiley, pp. 152-153; Palmer, Wiley, and
Keast, pp. 1,114, 433. Because of later adjustments to activation forecasts, only 89 divisions were deployed
for combat during the war.
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operations. If all went well, one year after its formation, the new division would be
considered trained and ready for deployment into combat.
Preparing for Realistic Training. To ensure realistic training, and in particular,
adequate space for free maneuver exercises, General McNair took steps to acquire
additional and more suitable training areas. Moreover, it was clear that the Army must
prepare for a variety of specialized combat operations in different environments, ranging
from jungles to deserts to mountains. McNair emphasized that specialized training would
only be given to units that had already completed their standard training and only if a
specific requirement existed. Furthermore, he believed that much of the specialized
training could best be given in the theater in which the forces would be employed.
After careful study of requirements, the AGF created four special installations
between March and September 1942. Each had the mission of testing equipment and
developing requirements for its particular activity and of supervising the training of units
(which had already completed their standard training program) in its specialized type of
combat operations. The four specialized training centers were:
• The Airborne Center. On 23 March 1942 the Airborne Command (later Center)
was activated at Fort Benning, Georgia to prepare for airborne operations such as
those conducted by the Germans in the Netherlands in 1940 and Greece in 1941.
The Airborne Command assumed control of the Parachute School and all airborne
units in the United States (two parachute regiments and one glider battalion in
1942). The Airborne Center continued in operation through the war, although the
focus of its efforts became school training.
20 Pabner, Wiley, and Keast, pp. 434-443.
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• The Desert Training Center. On 7 April 1942 the Desert Training Center was
activated at Indio, California to prepare units for operations in a desert environment
such as North Africa, where extensive combat had occurred beginning in 1940
between the British and the Italians and Germans.
• The Amphibious Training Center. On 20 May 1942 the Amphibious Training
Command (later Center) was activated because of dissatisfaction with training
conducted jointly with the Navy and Marine Corps. Eventually the Amphibious
Training Center was located at Carrabelle, Florida near Tallahassee, although
amphibious training was conducted at Camp Edwards, Massachusetts and Fort
Lewis Washington. The Amphibious Training Center remained under the AGF
until it was dissolved in June 1943.
• The Mountain Training Center. On 3 September 1942, the Mountain Training
Center was activated at Camp Carson (later Camp Hale), Colorado, although
extensive testing and training had been conducted prior to that time based on the
recognition of German mountain warfare capabilities in Norway (1940) and the
Balkans (1941). In addition to the 10th Mountain Division that trained at Camp
Hale, units designated for the invasion of Sicily (36th and 45th Infantry Divisions)
were trained in mountain warfare near Buena Vista, Virginia by personnel from the
Mountain Training Center. This was so successful that the training area was
transferred to the vicinity of Elkins, West Virginia. In mid-1944 all Mountain
Training Center activities in Colorado and West Virginia were terminated and
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personnel were transferred to the 10th Mountain Division, which deployed to Italy
in late 1944.2]
The Desert Training Center.
Establishment by General Patton: In March 1942, Maj. Gen. George S. Patton,
Jr. established the Desert Training Center (DTC) in southern California in a remote area of
the Mojave Desert. Patton believed the site to be ideal not only for armored training but
also for all types of combat exercises. He declared it to be "probably the largest and best
training ground in the United States." From a support perspective, the area had an adequate
supply of water, was serviced by three rail lines, and had access to electricity and
telephone lines. Almost 80 percent was already owned by the government. From a training
perspective, the site contained a variety of terrain, ranging from desert to mountains (some
exceeding 7,000 feet in elevation) to areas of extensive vegetation, although mostly of the
prickly variety. It had few populated areas. It was arid, with an average yearly rainfall of
less than five inches, although there were wet months when rain of perhaps 1/3 of an inch
might be received at one time. In addition to sudden cloudbursts (with associated flash
floods in low areas), there were other abrupt changes in weather, such as extremes of
temperature in both winter and summer and unexpected wind or sandstorms.22
21 Greenfield, Palmer, and Wiley, pp.90-93, 339-350,402; Thomas P. Govan, Training for Mountain and
Winter Warfare: Army Ground Forces Study No. 23, Historical Section, Army Ground Forces, 1946;
Marshall O. Becker, The Amphibious Training Center: Army Ground Forces Study No. 22, Historical
Section, Army Ground Forces, 1946; Rod Crossley, "The Desert Training Center in World War II," La Posta,
28:5 (November 1997).
22 Sidney L. Meller, The Desert Training Center and C-AMA [California-Arizona Maneuver Area]; Army
Ground Forces Study No. 15, Historical Section, Army Ground Forces, 1946, pp. 1-5 (U.S. 00021591-
00021595); quote from p. 3 (U.S. 00021593). See also John W. Kennedy, John S. Lynch, Robert L. Wooley,
"Patton's Desert Training Center," Periodical: Journal of the Council on America's Military Past, vol. II, no.
2, December 1982.
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Although the Army Ground Forces (AGF) was responsible for the overall operation
of the DTC, the Services of Supply (later the Army Service Forces or ASF) and the Army
Air Forces (AAF) were tasked to assign units to the DTC to provide support for training
exercises, and in the case of the ASF, operate and maintain the fixed camp installations in
the DTC. During prewar buildup and the rapid expansion in World War II, the ASF and
AAF operated their own specialized training centers and schools as well as unit training
programs. However, in order to provide realistic combat training, ASF and AAF units were
integrated into AGF maneuver training whenever possible. The DTC provided an ideal
training environment for the ASF and AAF, just as it did for the AGF.23
The AGF directed that General Patton accomplish the following at the DTC:
• Develop appropriate tactical doctrine, techniques, and training methods for desert
operations;
• Test the suitability of current equipment and supplies and develop necessary items;
• Determine the nature of any necessary changes to tables of organization and basic
allowances; and
• Undertake training that would emphasize 1) sustained operations remote from
railheads and under constant threat of hostile air and mechanized attack, 2) rapid
fuel (using "jerry" cans) and ammunition resupply to include night operations, 3)
laying and removal of minefields, 4) personal survival and equipment maintenance
in a desert environment, and 5) combined training with the Army Air Forces.
23 Headquarters, Army Service Forces, Statistics Branch, Control Division, Statistical Review of World War
II: A Summary of ASF Activities, 1946, pp. 61-62,219-228; Meller, pp. 55-60 (U.S. 00021647-00021652).
17
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Figure 2 - "Jerry" Fuel Cans Used For Rapid Refueling of Multiple Vehicles.
Maneuvers at the DTC in June and July 1943 required 122,000 5-gallon jerry cans to
supplement normal fuel truck resupply to sustain extended operations. An armored
division required 2,200 gallons to move one mile, an infantry division 275 gallons.24
Pattern's I Armored Corps, with a strength of about 10,000 or less than one division,
was moved to the DTC from Fort Benning, Georgia by rail and motor vehicle and began
arriving in April with food and water for three days. At the same time quartermaster,
engineer, and other support units began to move into the area to establish base support
facilities, all initially living in tents while buildings were constructed.
24 Photo from U.S. Army Quartermaster Museum, accessed 29 December 2004,
www.qmmuseum.lee.army.mil/ historyweek/Red Bal... The photo shows a fuel depot for the Red Ball
Express in France in the fall of 1944. For an example of use of jerry cans at the DTC, see "G-4 Report June-
July Maneuvers, Desert Training Center," 19 July 1943, p. 2 (SBC 7246), National Archives.
25 Meller, pp. 7, 9-11 (U.S. 00021598, 00021600-00021602). As an example of the importance of the five-
gallon "jerry'Vfuel can, some 300,000 required reclamation upon inactivation of the DTC/C-AMA; see James
W. Bennett, Labor at the Mira Loma Depot, n.d., p. 226 (SBC 10111), National Archives, Pacific Region,
Laguna Niguel, RG92.
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Patton and his staff developed a six-week training program consisting of four
phases. The first would focus on individuals and small units up to the platoon level, the
second on companies, the third on battalions, and the fourth on combined arms combat
teams featuring field exercises of several days duration. During the final field exercises,
units would move some 300 miles through the desert, utilizing night moves and
establishment of advance supply bases to sustain operations; tactical bivouacs utilizing
cover and concealment were to be established under the threat of hostile air and ground
attack, and certain portions of the exercises would feature the use of live ammunition to
include air-delivered bombs. Throughout all phases of training, Patton and his staff
observed, analyzed, and made necessary changes to improve training. As Patton
commented, the Desert Training Center provided a training environment without parallel:
To all who for years have been bedeviled by arbitrary restrictions on
maneuvers, the situation at the Desert Training Center is truly as inspiring
as it is unusual. In the whole 12,000,000 odd acres the only restrictions as to
movement are those imposed by nature. Even so, these are more accurately
deterrents rather than restrictions, for, with time and perspiration, you can
go anywhere.
Another point about desert training that is alluring, particularly to
artillery men, is the fact that one can open fire with live ammunition and
drop bombs at any time and in any direction without endangering
anyone....The situation is ideal. It should be remembered that from October
to the end of May the weather in the desert is what babies cry for and old,
rich people pay large sums of money to obtain.26
Training was hampered by personnel turbulence, a serious epidemic of yellow
jaundice, and the threat of a Japanese attack on the West Coast requiring Patton and his
staff to develop defense plans for southern California. Despite these distractions, by 5 July
the I Armored Corps' training had progressed sufficiently that a seven-day field exercise
was conducted with good results. Patton began planning for the movement of VII Corps
26 Maj. Gen. George S. Patton, Jr., "The Desert Training Corps," The Cavalry Journal, September-October
1942.
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units (3d and 5th Armored and 7th Infantry Divisions) to the DTC to join his I Armored
Corps and undergo the training program. However, as the new units began to move to the
DTC, Patton was abruptly called to Washington, and his I Armored Corps was transferred
to the East Coast in preparation for overseas deployment for the invasion of North Africa.
Considerable confusion ensued as Patton's troops hastily departed the Desert Training
Center.27
Evolution of the Desert Training Center. On 2 August 1942 Maj. Gen. Alvin C.
Gillem, the commanding general of the II Armored Corps, assumed command of the DTC.
At that time, the II Armored Corps, with most of General Gillem's staff, was undergoing
maneuvers in the Carolinas that would not conclude until 15 August. The abrupt departure
of General Patton's I Armored Corps meant that an orderly transition between the two
commanders was not possible. General Gillem was charged with conducting maneuvers
between VII Corps and his own II Armored Corps that were to begin on 24 August, two
days after the II Armored Corps arrived at the DTC.
Base support and training operations, and associated research and experimentation
in desert warfare at the DTC had been improvised hastily in the spring and summer of
1942 amidst equipment and personnel shortages and substantial personnel turbulence. As a
result there was not an established and fully developed organization to support and conduct
large-scale training exercises. To make matters even more difficult, units that were to
undergo training in both II Armored and VII Corps were being alerted for deployment for
the North African operation. Newly arrived soldiers and units would require extensive
27 Meller, pp. 12-18 (U.S. 00021603-00021609); Maj. Bell I. Wiley, Preparation of Units for Overseas
Movement, Army Ground Forces Study No. 21, Historical Section, Army Ground Forces, 1946, pp. 13-14.
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acclimatization before they could effectively and safely perform in the desert. They would
have to deal with a major maintenance problem of 500 vehicles disabled through hard
usage in the desert and left behind by the I Armored Corps and a critical shortage of spare
parts.28
Figure 3 - M-4 Sherman Tanks at a Tank Depot at the Desert Training Center
Awaiting Issue to Units Arriving for Training29
In most other training centers, there were two commanders: one for troops
undergoing training and the other for the base support element that remained in place as
different units cycled through the training center. General Patton had decided that at the
DTC the senior commander of the troops undergoing training would be the commander for
all activities, to include base support operations. Consequently, supply, maintenance,
communications, and engineer activities would be considered an aspect of organizational
training under combat conditions. The few permanent camps at the DTC would be
regarded as field bases. However, the ASF support units stationed at the DTC continued to
operate under the ASF and their relationship to the DTC remained unclear.
28 Meller, pp. 19-31 (U.S. 00021610-00021622).
29 Photo from XX Corps History, Walton Walker Papers, Box 1, U.S. Army Military History Institute.
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General Gillem and his staff worked through these problems, and the maneuvers
began on 31 August and lasted until 18 October. Valuable experience was gained by
tactical units in being forced to perform their own supply and maintenance functions over
extended distances in the desert environment. However, the support system was artificial
because the logistical base and lines of supply were located between opposing units. As a
result, General Gillem and planners from the AGF headquarters developed a new plan for
the DTC. On 1 November 1942, the AGF issued a new mission statement for the DTC:
• Training, maintenance, and supply of troops realistically in a theater of operations;
• Developing tactics, techniques, and training methods suitable for desert warfare;
• Conducting fire under desert conditions;
• Hardening troops physically, and
• Testing and developing equipment and supplies.
Under this plan, ASF units would gain realistic training experience by supporting AGF
an
tactical units from a communications zone surrounding the maneuver area.
On 8 November 1942, Maj. Gen. Walton Walker, commander of IV Armored
Corps, assumed command of the Desert Training Center from General Gillem. General
Walker was charged with transforming the DTC into a theater of operations consisting of a
combat zone in the center and surrounded by a communications zone. Support sites in the
communications zone were selected, needed construction undertaken, and the area
organized and staffed. As a result, the DTC became a close approximation of an overseas
theater of operations, complete with an extensive area for combat maneuvers between two
opposing forces and a realistic support area featuring activities such as mobile bakeries,
30 Meller, pp. 25-26, 31-38 (U.S. 00021616-00021617, 00021622-00021629).
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laundries, shoe-repair companies, and delousing units. Elements of the IV Armored Corps
(primarily 4th and 6th Armored and 6th Motorized Divisions) began intensive training that
culminated with extensive field maneuvers from 18 February to 6 March 1943. Under
these conditions, the soldiers of the IV Armored Corps "grew quickly to the stature of
hardened soldiers ... and officers and men alike gained that sinewy toughness and the
stamina that are the trademark of a successful fighting force." Upon the conclusion of the
maneuvers, the divisions of the IV Armored Corps began departing to be replaced by IX
Corps under Maj. Gen. Charles White on 29 March 1943.3]
Under General White the area of the DTC was enlarged to become an oval about
350 miles wide from Pomona, California and Phoenix, Arizona and 250 miles deep from
Yuma, Arizona to Boulder City, Nevada, an area larger that Pennsylvania. The training of
IX Corps culminated in maneuvers lasting from 27 June to 15 July 1943 and primarily
involving the 7th Armored Division and the 8th, 33d, and 77th Infantry Divisions. The
rotation of corps and divisions continued with
• XV Corps, which trained the 9th Armored and 85th Infantry Divisions from 9 July
to 18 October 1943, the 79th and 81st Infantry Divisions from 6 August to 13
November 1943, and the 90th and 93d Infantry Divisions from 13 September to 13
December 1943.
• IV Corps (13 November 1943 to 17 January 1944), 11th Armored and 95th Infantry
Divisions.
• X Corps (17 January to 30 April 1944), 80th and 104th Infantry Divisions.
31 Quote from History of the XX Corps, p. 8, Walton Walker Papers, Box 1, U.S. Army Military History
Institute; the IV Armored Corps was redesignated the XX Corps later in 1943.
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Under XV Corps on 20 October 1943 the name of the DTC was changed to the California-
Arizona Maneuver Area (C-AMA) to reflect the purpose of general combat training instead
• • 32
of merely desert training.
DTC Training: Commanders and Staff. Invariably, the commanding generals of
the DTC and C-AMA stated that it was the best training experience of the war for them
and their staffs. They were required to step into a complex and challenging situation, take
charge, and direct their resources, both combat and support, to accomplishing the mission.
Initiative, determination, and intelligence were essential for success. In some instances,
DTC commanders and their staffs were reassigned in the midst of field exercises, requiring
the new commanders to assume immediate control and continue with the exercise, just as
they would in combat. Logistical support was critical in all activities, not only to achieve
training objectives, but more importantly for survival in the harsh and unforgiving desert
environment. The experience was a test of individuals and units, and successful completion
served to weld men and organizations together to create solid cohesion.33
The AGF recognized this value of the DTC and focused their observation efforts on
how well the center's commander and his subordinates performed. Of the seven
commanding generals of the DTC and C-AMA, two became army commanders and four
successfully commanded corps in combat in Europe. The exception was General White of
IX Corps, who as commander of the DTC, emphasized more efficient administration of the
32 Meller, pp. 39-41 (U.S. 00021630-00021632); Wiley, Training in the GroundArmy, 1942-1945, Army
Ground Forces Study No. 11, table following p. 12.
33 For an example of the consequences of failure to heed the desert environment, see Paul Schultz, The 85th
Division in World War 71, extracted in 85th Division Veteran's Association, "The 85th 'Custer' Division at
Desert Training Center," accessed 29 December 2004, http://members.aol.com/Custermen85/Desert
Camps.htm; Schultz describes the death of three soldiers during a training exercise when they became
separated from their food and water supply; the incident is also mentioned in Meller, pp. 53-54 (U.S.
00021645-00021646)
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communications zone and soldier comfort at the expense of realistic training. After the
DTC, he was assigned to command a replacement training center in Arkansas.34
DTC Training Realism. Combat experience in North Africa in late 1942 and early
1943 revealed numerous deficiencies in the training of soldiers, units, and commanders
and staffs. General McNair sought to correct the deficiencies by introducing more realistic
training tailored to the reality of war. He believed that training could never be too realistic.
In September 1943 he said, "The American soldier who goes green into battle has had
more realistic precombat training than the soldier of any other nation in the world,
"If
including Germany."
Soldiers who went through the DTC or C-AMA believed that it was the best, most
realistic training in their Army service and that it prepared them for combat. Although life
in the desert was unpleasant, it hardened individuals physically and mentally. Soldiers in
training gained a respect for their environment and learned that all of their issued personal
equipment was important, including jackets that were not needed during the hot day but
were essential at night or shelter halves that were bulky to carry but provided protection in
adverse weather conditions. Shelter halves were also used when soldiers bivouacked
during lulls in field exercises. In April 1943 the DTC received an additional training
34 Meller, pp. 42,44, 50-52 (U.S. 00021634, 00021636, 00021642-00021644). See also "Brief History of the
Desert Training Center," Army Motors Magazine, No. 40, (1987); IX Corps also stopped training in the
afternoon and encouraged soldiers to take naps.
35 Quote from E.J. Kahn, Jr., McNair: Educator of an Army, (Washington: The Infantry Journal, 1945), p. 31.
For the assessments of training deficiencies revealed in the North African campaign, see Rick Atkinson, An
Army at Dawn: The War inNorth Africa, 1942-1943 (New York: Henry Holt, 2002) and George F. Howe,
Northwest Africa: Seizing the Initiative in the West (Washington: CMH, 1993), pp. 671-673.
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mission - the requirement to train soldiers mentally for the shock of battle and to conduct
firing under battle conditions. Training realism at the DTC received increased emphasis.
Figure 4 - Soldiers Stand Inspection of their Individual Equipment. Two soldiers
could produce a tent by snapping their shelter halves together
37
Some of the ways in which realism was achieved at DTC or C-AMA included:
• Battle courses, such as the infiltration course. Battle courses, sometimes called
battle inoculation courses, were designed to prepare soldiers psychologically for the
sights and sounds of different types of combat, such as close combat and village
fighting. One of the most effective battle courses, which was used extensively at
the DTC and C-AMA, was the infiltration course. The purpose of the infiltration
course was to accustom soldiers to overhead fire and to the noise and effect of near-
by explosions and other battle experiences. Soldiers had to move forward and
negotiate barbed wire entanglements while machine guns fired live ammunition
36 Meller, pp. 12-14 (U.S. 00021603-00021605); Headquarters, Army Ground Forces, "Report of Desert
Training Center and California-Arizona Maneuver Area," no date, p. 2 (SBC 7416), National Archives, RG
337, Entry 55.
37 Photo from National Archives, RG 111, World War II, SC180845.
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over their heads and other explosive devices and smoke munitions were detonated
in their path. At the DTC/C-AMA the infiltration course was used to train ASF as
well as AGF units to include medical personnel. This training was conducted even
at the busy Base General Depot (BGD) to ensure that all ASF units would
participate. Reportedly, one soldier was killed on the infiltration course at the BGD
when he stood up in order to get away from a snake and was hit by a machine gun.
The infiltration course was considered of such great value that its successful
completion, both the day and night versions, was a requirement for all units prior to
overseas deployment. Higher headquarters carefully tracked the status of unit
70
completion of the infiltration course requirement.
• Use of smoke at weapon ranges and battle courses. The natural combat
environment is one of smoke and dust created by exploding shells and fires. Vision
is obscured, confusion is present, control is difficult, and firing is inaccurate.
Smoke munitions (HC smoke pots and smoke grenades) were valuable training aids
and were used to simulate combat conditions at weapon ranges and battle courses,
even those at the BGD, to force soldiers to leam to fight and make sound decisions
under more realistic conditions.39
38 Kahn, pp. 31-32; Army Ground Forces, Principles and Methods of Training in the Army Ground Forces:
Army Ground Forces Study No. 10, Historical Section, Army Ground Forces, 1946; Wiley, Army Ground
Forces Study No. 77,pp. 19-21,39-41. For an example of a unit training report, see Letter, 531st
Quartermaster Salvage Repair Company, Subject: Report of Training Deficiencies, 21 October 1943
(SB1006), National Archives, RG 407. For individual experiences see Depositions, Agnes Groth, 16 June
1999, pp. 31-32; William A. Bullock, 7 June 1999, pp. 29-31; Harold E. Bowman, 11 December, 1998, pp.
105-106; and Declaration of George Judd, 11 February 1999.
39 War Department, Technical Manual 3-305, Use of Chemical Agents and Munitions in Training, 2 June
1944, p. 39. For personal experiences, see depositions, Agnes Groth, 16 June 1999, p. 31; William A.
Bullock, 7 June 1999, p. 31, and Declaration of George Judd, 11 February 1999.
27
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Figure 5 - View of the Rifle Qualification Course at Cajon Wash near the Base
Genera] Depot. After learning basic marksmanship skills, soldiers were
introduced to a more realistic combat environment by firing at targets through
smoke.40
Figure 6 - Soldiers From the Base General Depot Firing Their Weapons at the
Rifle Range at Cajon Wash41
40 Photo from National Archives, RG 111, World War II, SC 296786.
41 Photo from National Archives, RG 111, World War II, SC 296787.
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Figure 7 - Map of the Base General Depot and Cajon Wash Firing Range. The
Base General Depot is on right side of the map and was located between the two
roads to San Bernardino (off the map to the right). The Cajon Wash firing range
was to the northwest of the Base General Depot.42
• Use of smoke in unit field maneuvers. In addition to weapon ranges and battle
courses, trainers used smoke munitions during field maneuvers to simulate
battlefield haze from bursting shells and fires and dust churned up by moving
vehicles. This required units to perform their missions under realistic field
conditions. Smoke was also used during field maneuvers for tactical purposes, such
as screening troop movements and marking positions for artillery fire or air attack.
Extensive use was made of smoke grenades and HC smoke pots, with the HC
42 Map from Power Point Presentation, P4382, San Bernardino - Newmark, ] 0 August 2004, Aero Data
Corporation, Slide 79.
29
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smoke pots being placed on their side after ignition so that the smoke would flow
parallel to the ground. For example, during the maneuvers of the IV Armored
Corps from 15 February to 6 March 1943, some 3,000 smoke pots were used for
screening operations and marking artillery fires. On occasion, artillery smoke
rounds were also used to mark positions for artillery or air attack. Much more
limited use was made of smoke generators, which had the capability of creating
smoke screens extending several miles to shield troop movements or positions.43
Figure 8 - Troops at the Desert Training Center Attacking Through a Simulated
Enemy Artillery Barrage Created by Smoke Munitions and Small Explosive
Charges44
43 Leo P. Brophy and George J.B. Fisher, The Chemical Warfare Service: Organizing for War (Washington:
Center of Military History, 1959), pp. 393-397, 473; War Department, Technical Manual 3-300, Irritant
Candles, Tear Pots, Smoke Pots, and Chemical Land Mines, 13 April 1942, pp. 7-12; War Department,
Technical Manual 3-305, Use of Chemical Agents and Munitions in Training, 2 June 1944, pp. 39, 41;
Deposition of Harold E. Bowman, 11 December 1998, pp. 54-56, 123-124, 141. For field exercises at
DTC/C-AMA involving the use of smoke, see Meller, p. 62 (U.S. 00021654) and Letter, Commanding
General DTC to Commanding General Army Ground Forces, Subject: Final Report DTC Maneuvers, 20
March 1943, National Archives, RG 337 (SB 1882). For guidance on use of smoke at DTC/C-AMA, see
Headquarters, Desert Training Center, Maneuver Memorandum #16, 21 August 1942, B.T. Hudspeth Papers,
Box 1, U.S. Army Military History Institute.
44 Photo from XXCorps History, Walton Walker Papers, Box 1, U.S. Army Military History Institute.
30
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Figure 9 - Soldiers Carrying HC Smoke Pots Forward to Create a Smoke Screen
Prior to the Rapido River Crossing in Italy.45
• Chemical Warfare Training. In World War I gas or toxic chemicals were
used extensively in combat. Of American casualties, almost half of those
admitted to hospitals (70,552 of 147,651) were due to exposure to gas. In
World War II it was known that both Japan and Germany possessed chemical
munitions, as did the United States. Consequently, Army training emphasized
the possibility that chemical warfare could be initiated at any time and that
individuals and units must be prepared to operate in a chemical environment. A
War Department directive of 15 June 1942 left no doubt when it stated, "The
probability of the early use of toxic gas by the enemy in the present war
45 Photo from Brooks E. Kleber and Dale Birdsell, The Chemical Warfare Service: Chemicals in Combat
(Washington, Center of Military History, 1990), p. 348.
31
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requires imparting to our troops a thorough knowledge of how chemical
warfare can be wagecL.against us and the placing of added emphasis upon
training in defense against chemical attack." Soldiers were issued individual
protective equipment, such as masks and clothing, and were required to carry
this protective equipment in training and use it when under gas attack, usually
simulated by smoke munitions. The use of persistent agents, such as mustard
gas, required the decontamination of individuals and equipment. Individuals
were trained to decontaminate themselves using special kits. Vehicles were
hastily decontaminated using the M2 Decontaminating Apparatus, a normal
part of each vehicle's equipment, filled with Decontaminating Agent
Noncorrosive (DANC). The M2's capacity of 1 1/2 quarts was usually only
sufficient to decontaminate the driver's compartment of vehicles. A 3-gallon
decontaminating apparatus was used to assist in decontaminating larger items
of equipment. Larger decontamination tasks required outside support from
specially equipped and trained decontamination units. Although Germany and
Japan never used chemical agents against the United States, American
commanders expected chemical warfare to be initiated at any time, but
especially during the invasion of Normandy.46
The Army prepared for chemical warfare through realistic training, such
as at the DTC/C-AMA. Units at the DTC/C-AMA, to include those at the BGD,
46 Greenfield, Wiley, and Keast, p. 387; War Department, Technical Manual 3-305, Use of Chemical Agents
and Munitions in Training, 2 June 1944, p. 39; War Department, Technical Manual 3-220, Decontamination,
15 November 1943, pp. 4-10, 24; Leo P. Brophy, Wyndham D. Miles, and Rexmond C. Cochrane, The
Chemical Warfare Service: From Laboratory to Field (Washington: Center of Military History, 1988), pp.
208-214, 332-341. Decontamination equipment is described in War Department, Field Manual 21-40,
Defense Against Chemical Attack, 1 September 1942, pp. 204-207. Quote is from War Department, War
Department Chemical Warfare Training Directive, 15 June 1942 contained in Brophy and Fisher, 7he
Chemical Warfare Service: Organizing for War, p. 472-474.
32
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conducted specific chemical warfare training on the use and care of individual
and unit chemical equipment and participated in standard chemical exercises,
such as the gas chamber. Additionally during field maneuvers, simulated
chemical attacks were made on units by using smoke munitions. Chemical
warfare training was emphasized at the DTC/C-AMA not only because of War
Department directives, but also because of previous experience from unit
commanders. Three commanders of the DTC/C-AMA (Generals Walker, Patch,
and Haislip) had witnessed at first hand gas warfare during the Meuse-Argonne
offensive in World War I. In the Meuse-Argonne between September and
November 1918, the American Army had suffered a total of 117,313 casualties,
of which 19,601 were from gas. General Patch served as an infantry battalion
commander in the 1 st Division, and his division lost over 1,600 men to gas in
less than a week.47
Role of the Base General Depot (BGD). The DTC's training was unique because
of its replication of the realistic logistical support requirements of a theater of operations,
including extended distances between support and supported units and meager
47 For chemical warfare training at the DTC/C-AMA, see depositions Harold Bowman, 11 December 1998,
pp. 13-14,16, 20-140; Harry K. Goodman, 29 June 1999, pp. 11-42; Agnes Groth, 16 June 1999, pp. 34-36;
William Bullock, 7 June 1999, pp. 9-10, 34-38; and Declarations of Harry K. Goodman (21 January 1999),
Agnes Groth (15 December 1998). Chemical warfare training at the DTC is also described in various
documents published before and after maneuvers; see for example, "Chemical Warfare Training During
Problem Number Two, 18 January 1944, pp. 1-4 (SBC 8131-8134), "Final Report on DTC Maneuvers, 31
August -19 October 1942," pp. 35-37 (SBC 1172-1174); "Report of Desert Training Center Maneuvers," 19
July 1943, Section VII, paragraph 7, Chemical, p. 2 (SB2376), "Condensation of Chemical Warfare Service
Observers Reports, DTC Maneuvers, 1943," 20 September 1943, (SBC7212-7225), all from National
Archives, Record Groups 337 and 338. For chemical warfare in World War I and the Meuse-Argonne, see
Rexmond C. Cochrane, The Use of Gas in the Meuse-Argonne Campaign, September-November 1918, Gas
Warfare in World War I, Study No. 10, U.S. Army Chemical Corps Historical Office, 1958; gas casualty
statistics are on p. 79. For WW II general's assignments in WW I, see Adjutant General's Office, Official
Army Register, 1 December 1918; Walker commanded a machinegun battalion in the 5th Division, and
Haislip was in the 3d Division.
33
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infrastructure and facilities from which to operate. Failure to deliver needed supplies
would result in probable failure of training tests. Additionally, for the logisticians, there
was the stress of knowing that failed logistical support would result in the supported units
going without food, water, and fuel; poor maintenance would mean broken down vehicles -
all occurring in a harsh and unforgiving desert environment. The BGD, located at Camp
Ono near San Bernardino, California, was critical to the successful functioning of the
Communications Zone which supported the combat training of the DTC. The Operating
Procedures for the Communications Zone of the DTC stated that the
TO DCATH VAU-E*
tCASANT VALLEY
DESERT TRAINING CENTER
FIASSQFF seftLcmuLfs
6 % a fi ^
LEGEND
*0*03
IMEftVRS CP OKMffHfC
4o
SCALE IN MICE*
loo"
Figure 10 - The Expanded Desert Training Center Showing Division-Sized Camps
and the Location of the Base General Depot at San Bernardino, East of Los Angeles48
commanding officer of the BGD "will furnish the DTC with all required supplies except
48 Figure from California Bureau of Land Management, http:Wwww.ca.blm.gov/pdfs/needles pdfs/map2.pdf,
accessed 29 December 2004. Original map produced by the 671st Engineer Company (Topographical).
34
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ordnance." Some of the supplies, such as quartermaster, signal, medical, engineer, and
chemical warfare, were provided from stocks maintained at the BGD; this included
cleaning and preserving material essential for proper equipment functioning in a desert
environment and decontaminating agents used in chemical warfare training
49
Figure 11 - Flow of Supplies from the Base General Depot to Forward Depots and
Units in the Communications Zone (Com. Z). Supplies moved by rail and truck to
railheads (RHD) and truckheads (TKHD) from which divisions and other units in
training would pick up. This chart shows divisions located in the northern sector of
the training area. Large-scale maneuvers featured opposing units in the north and
south, which would maneuver against each other and draw supplies from the Com. Z
infrastructure in their sector.
so
Circular No. 1, Operating Procedures Communications Zone, Desert Training Center, 8 February 1943,
pp. 3-29 (SBC 9886-9914); quote from p. 3 (SBC 9888), in James W. Bennett, Desert Training, A Supply
Problem, no date, National Archives, Pacific Region, Laguna Niguel, RG 92, Box 7.
50 Figure from James W. Bennett, Desert Training, A Supply Problem, Appendix 5, p. 2 (SBC 9945).
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Food supply was a difficult problem because of the frequent movement of units and
the perishability of a number of food items. The Base General Depot utilized refrigerator
cars for temporary storage of food at Camp Ono until the items could be transported to
units. The supply of other items, such as fuel and petroleum products, were directed and
controlled by the BGD but were normally delivered directly by truck or rail from other
depots to forward depots within the communications zone that directly serviced combat
units. Additionally, the BGD operated a stationary laundry, salvage and repair services,
and a 250-bed station hospital.51
Figure 12 - View of the Station Hospital at the Base General Depot, September 194352
51 James W. Bennett, Desert Training, A Supply Problem, pp. 97-122 (SBC 9797-9822)
52 Photograph from National Archives, Record Group 111, Signal Corps World War II, No. 296789,
reproduced in Power Point Presentation, P4382, San Bernardino - Newmark, 10 August 2004, Aero Data
Corporation, Slide 39.
36
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Of particular importance at the BGD were its salvage and repair operations.
Training at the DTC was hard on equipment, both individual and unit items. If possible,
unserviceable equipment had to be repaired in order for soldiers and units to continue field
operations. When units departed the DTC for other training areas or movement overseas,
much of their equipment was left behind since it was easier to issue equipment at the new
destination than it was to transport it, particularly overseas. Contributing to the large
quantities of materiel that became unserviceable was the average American soldier's
traditional attitude towards his equipment. Most were convinced of the nation's capacity to
produce unlimited quantities of commodities and hence were careless in their care of
equipment. The result at the DTC was vast amounts of uniforms, canvas items, and other
equipment that had to be repaired and cleaned (and if necessary waterproofed again) for
reissue to soldiers and units undergoing training or salvaged. Complicating supply
operations at the BGD were the Santa Ana winds that funneled through the area reaching a
velocity of sixty to seventy miles an hour and raising great blinding clouds of sand.
Closure of the Desert Training Center. During 1942 the War Department
activated thirty-eight divisions, bringing the total to seventy-four. Fourteen divisions
deployed overseas as task forces were created for operations in the Pacific and in North
Africa and the buildup of a logistical base in Britain, in preparation for a projected invasion
of the European continent in 1943. This was a hectic period with divisions struggling to
complete training or deploy in the midst of extensive personnel turbulence and equipment
53 Ema Risch and Chester L. Kieffer, The Quartermaster Corps: Organization, Supply, and Services, vol 11
(Washington: CMH, 1955), pp. 3-5; Mira Loma Depot Historian [James W. Bennett] The Storage Division:
the Mira Loma Quartermaster Depot, no date, pp. 4-17 (SB 7923-7933), National Archives, Pacific Region,
Laguna Niguel, RG 92. See also deposition of Harold E. Bowman, 11 December 1998, pp. 72-84.
37
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shortages. Despite these difficulties, General McNair ensured that all divisions completed
their required training before deployment, to include the critical large-scale field exercises
under realistic conditions. With so many divisions in training and preparing to deploy, the
DTC/C-AMA provided needed relief in maneuver and training space, as well as a realistic
environment in which to prepare for combat. In 1943 the last seventeen divisions were
activated. The DTC/C-AMA trained fifteen divisions in 1943 and two additional divisions
in early 1944.54
By mid-1943, there was a recognition that the limit was being reached in
manpower mobilization for Army Ground Forces. The total number of divisions was
reduced from 100 to 88, and planning was begun to reallocate manpower resources in the
training base. Large training centers suitable for training divisions and for large-scale
maneuvers were to be inactivated or scaled back with the saved resources diverted to
replacement training. Despite these measures, a replacement crisis developed in late 1943
due to heavy fighting in the Pacific and Mediterranean. As a consequence, General McNair
reluctantly stripped fourteen divisions in training to provide enlisted and officer
replacements. This action created havoc in the orderly training program of these divisions.
Because of the disruptions in training and in order to meet deployment dates, several
divisions were forced to eliminate the final phase of their training. It was at this point, that
the decision was made to terminate training at the DTC because of the reduced number of
divisions undergoing training, the lack of ASF units to provide support because of their
overseas deployment, and the need to shift training resources to other areas. On 15 April
1944 the DTC/C-AMA was discontinued as a training area.
54 Palmer, Wiley, and Keast, pp. 246-249, 457-458; Greenfield, Palmer, and Wiley, pp. 48-51.
38
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The DTC/C-AMA was considered the "graduate of combined training," and its
closure was a serious blow to the training program. Of the 64 infantry divisions trained in
the United States, 13 had training at the DTC/C-AMA. Of the 87 divisions of all types
trained in the United States, 20 underwent training at the DTC/C-AMA. Some 400
nondivisional units trained at the DTC. Those units that did conduct training at the DTC
received quality training in a realistic environment that thoroughly prepared them for
combat.55
Later Activity at the Base General Depot and Camp Ono.
Evacuation of the Maneuver Area and New BGD Mission. As units began to
depart from the DTC/C-AMA and preparations were made for its closure, the BGD
assumed new responsibilities for the rehabilitation and evacuation of equipment from the
DTC/C-AMA. One problem was the large quantity of equipment that required
maintenance or salvage. For example, in early 1944 approximately 5,400 vehicles
requiring extensive maintenance were located in the maneuver area; another 600 vehicles
were beyond repair. The ordnance depot at Pomona, California that normally handled
maintenance for the DTC/C-AMA had limited storage space and could only accept 1,000
vehicles. The remainder had to be evacuated someplace, and the BGD was the only
feasible solution, at least on a temporary basis until further evacuation elsewhere in the
United States could be arranged.56 As facilities in the DTC/C-AMA were closed, all depot
55 Lerwill, p. 275; Palmer, Wiley, and Keast, pp. 188, 190-191,194-195,200-205,470-475,479; Meller, pp.
43, 88 (U.S. 00021635, 00021680); Wiley, Army Ground Forces Study No. 11, pp. 65-66; quote from p. 65.
56 Meller, p. 88 (U.S. 00021680); storage space problems were compounded by the closure in February 1944
of the Advanced Ordnance Service at Palm Village, California, which at the height of the maneuvers had
over 7,000 vehicles in the facility; see "History of the Communications Zone, CAMA," no date, pp. 46-50
(SBC 7828-7832), National Archives.
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supply stocks in the communications zone were to be shipped to the BGD and the Pomona
Ordnance Base. All tents, stoves, and similarly movable items, including communication
wire (some 5,800 miles), were to be shipped to the BGD for further disposition. Finally,
the entire maneuver area was to be thoroughly searched for abandoned equipment and
supplies and other debris; material used in the fortification of Palen Pass was to be
removed. Troops were designated to dispose of unexploded shells at established artillery
firing ranges, however, it was recognized that all of the maneuver area could not be cleared
because at one time or another, almost the entire area had been used as an artillery impact
area.
The task of evacuating and properly disposing of the equipment and supplies in the
maneuver area required a significant amount of manpower, and in February 1944 a work
force of Italian prisoners of war arrived to assist a sizeable number of soldiers already
engaged in the task. The last of the combat divisions departed on 5 April, and by 15 April
seven principal camps, two general hospitals, and three major supply installations were
evacuated. The clearing of material from the maneuver area and smaller camps
C*T
continued.
57 Meller, pp. 88-92 (U.S. 00021680-00021684); Headquarters, California-Arizona Maneuver Area, Engineer
Plan for Evacuation ofC-AMA, 8 February 1944 (U.S. 00021714-00021723).
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With the evacuation of the maneuver area, the work at the BGD began in earnest,
as indicated by the amounts processed for selected items in the figure below.
Amount Processed Amount Processed Balance on Hand
Item
Tents
March 1944
55,921
1-20 April 1944
37,859
20 April 1944
694
Cots
103,669
198,515
7,000
Webbing
292,819
241,882
98,766
Clothing
209,744
168,773
124,909
Gas Cans
106,671
182,233
24,942
Water Cans
5,410
25,981
Metal
18 tons
88 tons
199 tons
Figure 13 - Salvage Processing at the Base General Depot, March - April 194458
In addition to those noted above, large amounts of other items were processed in
the days before the BGD closed. Eventually the equipment processed at the BGD included
approximately 100,000 tents, 400,000 cots, and 300,000 gasoline cans. Other shipments
from the BGD included about 45 tons of scrap rubber, 90 tons of rags, and 90 tons of tin
cans.59
58 Salvage numbers from "History of Communications Zone, CAMA," p. 24 (SBC 7780), National Archives.
59 Meller, pp. 88-92 (U.S. 00021680-00021684); deposition of Clifford D. Scherer, 10 June 1999, pp. 12-18.
41
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Figure 15 - Metal and Other Items, Including Gasoline Cans, to be Salvaged at the
Base General Depot61
60 Photo from National Archives, Pacific Region, Laguna Niguel, Entry 55A CAMA, Box 1268.
61 Photo from National Archives, Pacific Region, Laguna Niguel, Entry 55A CAMA, Box 1268.
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Establishment of the Mira Loma Quartermaster Repair Sub-Depot. On 7 June
1944, the BGD was deactivated and control of the depot area at Camp Ono was split. The
Quartermaster Corps assumed responsibility for the westernmost 380 acres, which became
a sub-depot of the major quartermaster depot located at Mira Loma, California, some 28
miles to the west. The remainder of the old BGD was taken over by the Corps of Engineers
for use by the San Bernardino Engineer Depot. Quartermaster activities continued at the
newly designated Mira Loma Quartermaster Repair Sub-Depot, which continued and
expanded the old BGD mission of repairing and refurbishing material to include tents,
canvas products, web gear, and other items from the disbanded DTC/C-AMA, as well as
material shipped from other locations in the United States and returned from overseas.
In July 1944, the Mira Loma Quartermaster Depot recommended that the
Quartermaster General close the sub-depot at San Bernardino and consolidate all repair and
refurbishment activities at the main Mira Loma depot, thus saving money and manpower
and increasing efficiency by eliminating duplicate supply operations and simplifying
supervisory responsibilities. The Quartermaster General disapproved the request because
of the critical shortage of canvas and web items and the potential delay in canvas and web
repair operations if they were shifted from San Bernardino to Mira Loma. Instead, the
Quartermaster General directed that the Mira Loma Quartermaster Repair Sub-Depot at
San Bernardino be rapidly converted into a larger facility to concentrate primarily on the
repair of tents, other canvas products, and web items. A goal of 10,000 repaired tents per
month was established.
62 Clifford R. Davis, "A Short History of Camp Ono," 16 November 1993, inclosure to letter from Clifford R.
Davis, Civil Investigator, U.S. Environmental Protection Agency, to Chris Shovey, 16 November 1993 (SBC
9222-9226); this document is a summary drawn from the base historian's papers. The initial correspondence
concerning the transfer of quartermaster activities from San Bemadino to Mira Loma is contained in Letter,
43
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Figure 16 - Aerial photograph of the old Base General Depot Area at Camp Ono.
Overlaid on the original 1945 photograph is the usage of the area after the BGD
closed. Below the old hospital area, at the top of the photograph, were located the
salvage facilities of the Mira Loma Quartermaster Repair Sub-Depot. At the bottom
of the photograph was the area occupied by the San Bernardino Engineer Depot.63
Commanding General Mira Loma Quartermaster Depot to The Quartermaster General, Washington, D.C.,
Subject: Transfer of Mira Loma Quartermaster Repair Sub-Depot, 15 July 1944 (SBC 9985-9987) and Letter,
Office of the Quartermaster General, Washington, D. C. to Commanding General, Mira Loma Quartermaster
Depot, 25 July 1944 (SBC 9981-9982). For an attempted rebuttal by the Mira Loma commander and the final
directive from the Quartermaster General, see letter, Commanding General, Mira Loma Quartermaster Depot
to Quartermaster General, 3 August 1944 (SBC 9988-9989) and letter, Quartermaster General to
Commanding General, Mira Loma Quartermaster Depot, 14 August 1944 (SBC 9983-9984).
63 Aerial photograph from Power Point Presentation, P4382, San Bernardino - Newmark, 10 August 2004,
Aero Data Corporation, Slide 4.
44
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The conversion of the Mira Loma Quartermaster Repair Sub-Depot primarily to
handle the repair of tent and web-items proceeded. The sub-depot's shoe repair and metal
shops were dismantled and converted to tent repair. Work on the refurbishment of canvas
and web items was handled by a force of civilians (numbering about 100 when the sub-
depot was activated) and approximately 1,000 former Italian prisoners of war formed into
Italian Service Units (ISUs) after the surrender of Italy. New buildings were constructed;
additional machinery was installed, and operations were streamlined. Innovative
procedures were introduced to increase productivity, such as combining the washing and
waterproofing cycles for tents. Eventually, the sub-depot became the largest tent repair
facility in the United States, although the goal of 10,000 tents repaired per month was not
achieved. For example, in February 1945 only 8,600 tents were received at the depot and
40 percent of these were condemned.
After the end of the war, all repair operations were transferred to the Mira Loma
Quartermaster Depot, and the facilities of the Quartermaster Repair Sub-Depot were taken
over by the San Bernardino Engineer Depot. Thus ended a logistics operation that had been
vital to training the Army for World War II and then had been transformed to provide a
critical supply function as the fighting was brought to a close. However, logistics activities
did not cease at the Camp Ono site but continued under the Army Corps of Engineers.64
64 James W. Bennett, "The Mira Loma Quartermaster Repair Sub-Depot: A Historical Survey and a Study in
Operational Procedures and Problems," no date. For individual experiences at the Mira Loma Repair Sub-
Depot, see depositions of A1C. Ballard, 7 January 1998, pp.9-48; Carmine Angeloni, 8 June 1999, pp. 7-10,
17-28; Lena De'Maio, 7 January 1998, pp. 14-35; and Declaration of Elpidio Estrada, 29 September 1999.
45
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The San Bernardino Engineer Depot. The Corps of Engineers had maintained a
depot in the San Bernardino area since 1942, utilizing a number of leased facilities.
Because of increased responsibilities in 1943, the engineer depot leased additional
facilities. In May 1943 the depot acquired a winery adjacent to the Mira Loma
Quartermaster Depot for storage of oil drilling and oil refining equipment to be used by
engineer petroleum units for contingency missions in the Dutch West Indies. This was
designated the Mira Loma Engineer Sub-Depot. In December 1943 the San Bernardino
Engineer Depot leased a facility near San Bernardino known as the National Orange Show,
consisting of over 170,000 square feet of buildings on 70 acres of land. The Orange Show
facility provided the major storage and operating space for the depot until its move to
Camp Ono. The missions of the San Bernardino Engineer Depot were to serve as:
• A Distribution Depot to receive and store general engineer supplies for
distribution to military installations in southern California. Distribution Depots
supplied items to designated areas of the Continental United States.
• A Filler Depot to receive and store general engineer supplies for shipment to
the Los Angeles Port of Embarkation, which served the China, Burma, India
(CBI) Theater of Operations and beginning in 1944, the South Pacific Area.
Filler Depots provided supplies to fill overseas requisitions or supply last-
minute shortages for deploying forces.
• A Key and a Reserve Depot. As a Key Depot, San Bernardino stored selected
items to supply military stations, other depots, and ports. As a Reserve Depot,
San Bernardino stored designated items in bulk for special purposes as well as
supplies in excess of current needs for shipments to other depots and ports.
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• A Receiving Depot for return of serviceable engineer supplies from overseas
through the Los Angeles Port of Embarkation.
The Mira Loma Engineer Sub-Depot, in addition to providing in transit storage of the
petroleum drilling and refining equipment, was assigned the missions of repairing and
storing heavy construction equipment and modifying 1,350 tractors for artillery use and
processing them for overseas shipment.65
After the DTC/C-AMA closed in the spring of 1944, the San Bernardino Engineer
Depot acquired additional facilities at Camp Ono, sharing the former location of the Base
General Depot with the Mira Loma Quartermaster Repair Sub-Depot. With the end of the
war, quartermaster activities were relocated to Mira Loma, and in November 1945 the San
Bernardino Engineer Depot assumed control of the entire Camp Ono site. Between
December 1945 and May 1946 supplies stored at the Orange Show were transferred to
Camp Ono, and in September 1946 the winery at Mira Loma was relinquished, thus
consolidating almost all of the engineer depot activities at Camp Ono.
65 Corps of Engineers, Historical Record, San Bernardino Engineer Depot, 30 June 1947, National Archives,
Pacific Region, Laguna Niguel, Record Group 77, pp. 1-6 (SB7487-7492) and Exhibit D (SB 7505). For
depot definitions and assigned missions of the San Bernardino Engineer Depot, see Blance D. Coll, Jean E.
Keith, and Herbert H. Rosenthal, The Corps of Engineers: Troops and Equipment (Washington: CMH,
1988), pp. 534-535.
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Figure 17 - Aerial View of the San Bernardino Engineer Depot at Camp Ono,
6 September 1945. The storage area is clearly shown.66
In November 1945 the San Bernardino Engineer Depot received a new mission to
receive, store, and dispose of surplus engineer property from within California and
Arizona, as well as all types of surplus equipment and supplies returned from overseas
through the ports of Los Angeles and San Francisco. Working with the Reconstruction
Finance Corporation (later the War Assets Corporation and after March 1946, the War
Assets Administration), engineer depot personnel established procedures to dispose of
much of the surplus material through a series of sales to the public. The first sale, which
began on 5 June 1946, generated considerable interest with some 2,500 interested buyers
attending the event. A military police company was used to handle the parking of the 750
civilian vehicles that arrived to move the sold items from the site. Seven additional public
66 Power Point Presentation, P4382, San Bernardino - Newmark, 10 August 2004, Aero Data Corporation,
Slide 330.
48
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sales were held to dispose of property valued at over $10.7 million. The program was so
successful and efficiently administered that the War Assets Administration used the Camp
Ono site as a school and training ground for personnel designated to operate future surplus
disposal sites in other areas of the country.67
The importance of the new mission is reflected in the increase in personnel
assigned to the San Bernardino Engineer Depot, rising from 791 in 1944 to 1,347 in 1945.
The extent of the activity at the San Bernardino Engineer Depot can be determined by the
amount of tonnage handled at the facility. The figures for 1943 are incomplete. Tonnage
for the period 1944 through June 1947 is shown in the figure below. The amount of
tonnage shipped includes surplus items sold and shipped to purchasers, which is listed
separately in the right hand column.
1944
Received
74,735
Shipped
43,878
Surplus Shipped
0
1945
189,300
101,017
1,950
1946
30,867
125,757
54,441
1947
178
34,260
28,670
Figure 18 - Tonnage
Handled by the San Bernardino Engineer Depot'
With considerable progress made in disposing of the surplus left from World War
II, the San Bernardino Engineer Depot was no longer required. On 30 June 1947, the San
Bernardino Engineer Depot closed, ending all military logistical activities at the Camp Ono
67 Corps of Engineers, Historical Record, San Bernardino Engineer Depot, 30 June 1947, National Archives,
Pacific Region, Laguna Niguel, Record Group 77, pp. 6, 12-13 (SB7492,7498-7499) and Exhibit E, E.T.
Taylor, "Surplus Property Disposal," pp. 1-5 (SB7508-7512).
68 Corps of Engineers, Historical Record, San Bernardino Engineer Depot, 30 June 1947, National Archives,
Pacific Region, Laguna Niguel, Record Group 77, p. 8 (SB7494).
49
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June 2, 2005
site. Camp Ono's role during World War II and immediately after was significant - serving
as the Base General Depot or main logistical support for almost one million soldiers
training at the Desert Training Center, helping to solve a critical supply shortage of tents
and canvas in the last months of the war, providing engineer supply support for the western
United States and overseas, and afterwards assisting in disposing of the surplus equipment
and supplies left from the war effort
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June 2,2005
Glossary of Common Military Terms Used in this Paper
Military Organizations
The Army has a wide variety of organizations and units that can be combined as
necessary for accomplishing specific tasks.
Squad. The smallest unit in the Army, a squad consists of four to ten enlisted
soldiers led by a noncommissioned officer. The comparable sized unit in artillery is a
section, and in armor units it is a crew. Three or four squads make up a platoon.
Platoon. A platoon ranges from thirty to fifty soldiers in size. The organization of a
platoon varies. Platoons are led by a lieutenant. Three or four platoons make up a
company.
Company. The company is the Army's basic organizational unit. Except for large
administrative headquarters units, most companies consist of two or more platoons usually
of the same type with a headquarters. Companies are commanded by captains and can
contain 100 to more than 200 soldiers. Four or five companies constitute a battalion. An
artillery unit of this size is a battery; a comparable cavalry unit is a troop.
Battalion. A battalion consists of two or more companies or batteries and is
commanded by a lieutenant colonel. An infantry battalion may contain 900 officers and
men, while artillery or armor battalions could be half that size. Cavalry equivalents are
called squadrons.
Regiment. A regiment consists of two or more battalions and is commanded by a
colonel.
Division. The organization and structure of divisions has been evolutionary. In
World War II most divisions were "triangular," that is they consisted of three regiments
and a number of supporting battalions and companies. The division was the smallest Army
organization designed to fight independently and was commanded by a major general.
Corps. A corps consists of two or more divisions and a number of supporting
regiments, battalions, and companies. It does not have a fixed organization but is tailored
for a specific mission. Traditionally corps use Roman numerals as designations, such as V
Corps. A corps is commanded by a lieutenant general.
Combat Branches
Infantry units are trained and equipped to fight on foot, although they may be
transported onto the battlefield by truck (motorized infantry), armored personnel carriers
(mechanized infantry), or parachute (airborne infantry).
Armor units are trained and equipped to fight from tanks.
Artillery units fire large weapons (howitzers, cannon, missiles) in support of
infantry and armor units.
Other Terms
Bivouac. A temporary encampment made by soldiers in the field.
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June 2,2005
Bibliographic Note
Specific sources consulted for this study are indicated in the footnotes. The sources
mainly consisted of official documents from the National Archives, Army manuals from
World War II, witness statements and depositions, and official histories produced by the
Army during World War II and afterwards.
In my last assignment in the Army as chief of the Histories Division at the U.S.
Army Center of Military History in Washington, D.C. (1992-1995), I was responsible for
the writing of the Army's official histories. The Army began this activity during World
War II because of the failure to produce an official record of U.S. Army activities and
operations after World War I that could be used by World War II planners as guides to
mobilization of the Army, preparing it for combat, and conducting and sustaining combat
operations in multiple overseas theaters under a variety of conditions. Army leaders vowed
that they would capture the administrative and operational lessons of World War II so that
in the future mistakes would not be repeated and successes could be duplicated. The result
was "The U.S. Army in World War II" or "Green Book" series consisting of seventy-nine
volumes, organized in several sub-series covering the War Department, Army Ground
Forces, Army Service Forces, Technical Services (Chemical, Engineers, Medical,
Ordnance, Quartermaster, Signal, and Transportation), overseas theaters of operation, and
special studies.
During World War II, official historians, many obtained from civilian universities
and all highly qualified as historical writers and researchers, were assigned at War
Department level and at all major command levels. These historians gathered source
documents and began the writing of the official history of their commands or
52
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June 2,2005
organizations. During and immediately after the war, a number of monographs were
completed that documented Army activities and operations. The task of completing the
official history (Green Book series) was taken up by historians who remained in the Army
after the war.
Many of the sources for this paper, which detailed training and logistics activities at
the Desert Training Center and the Base General Depot/Mira Loma Quartermaster Repair
Sub-Depot, were drawn from the work of the World War II official historians in the Army
Ground Forces and Army Service Forces, as well as a number of the technical services.
Some of this material was published as part of the Green Book series. Other material, such
as produced by the Mira Loma Quartermaster Depot historian, Mr. James W. Bennett, and
a historian of the Army Ground Forces, Sergeant Sidney Meller, remained in the form of
monographs and collected documents. All of these historical products are objective,
reliable, and written with the guidance of General Eisenhower always in mind:
The history of the Army in World War II now in preparation must without
reservation, tell the complete story of the Army's participation, fully documented
with references to the records used [and] without reservations as to whether or
, not the evidence of history places the Army in a favorable light.69
69 John E. Jessup and Robert W. Coakley, A Guide to the Study and Use of Military History (Washington:
Center of Military History, 1979), p. 285-292; quote from page 290.
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June 2, 2005
About the Author
Colonel William T. Bowers graduated from Texas Christian University in 1968 and
received a Master of Arts Degree in History in 1969 from the same institution. He was
commissioned as an artillery officer in the U.S. Army in 1969. He served in artillery units
in West Germany, South Vietnam and the United States and as an infantry advisor in South
Vietnam before being reassigned as an instructor and branch chief in the Tactics and
Combined Arms Department at the U.S. Army Field Artillery School. In this position he
was responsible for all instruction in nuclear, biological, and chemical weapons at the
Artillery School. He later served in the Pentagon as a staff officer in the Nuclear and
Chemical Directorate, Office of the Deputy Chief of Staff for Operations and Plans where
he was responsible for the Lance and Pershing Missile Systems and a number of other
programs. Colonel Bowers returned to Germany in 1987 to command an artillery
battalion. From 1989 to 1992 he was Chief of the G-2 Targets Section, Central Army
Group and Fourth Allied Tactical Air Force (NATO), Heidelberg, Germany.
During his career, Colonel Bowers was an instructor in the History Department of
the U.S. Naval Academy. He was a guest lecturer at the Army War College and the NATO
School in Oberammergau, Germany, and since 1977 has led numerous battlefield staff
rides in Europe and the United States. In 1992 he joined the U.S. Army Center of Military
History as Chief of the Histories Division, where he supervised fifteen professional
historians engaged in writing the official history of the U.S. Army. He retired from the
Army in 1995 but remains active in the field of military history.
His publications include Black Soldier, White Army (coauthor, U.S. Army Center of
Military History, 1996), a history of the last segregated infantry regiment in the U.S.
Army, and "Department of the Army" in A Historical Guide to the United States
Government (Oxford University Press, 1998). He was also the general editor of the U.S.
Army Center of Military History's pamphlet series on World War II campaigns and author
of an unpublished pamphlet in the series, Building Divisions: Preparing the Army Ground
Forces for Combat in World War II.
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Exhibit 3
February 28, 2018 Water Department Letter to EPA regarding PCE Mass Estimates
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CITY OF SAN BERNARDINO
MUNICIPAL WATER DEPARTMENT
CITY OF SAN BERNARDINO
WATER BOARD
Commissioners
JUDITH VALLES
LOUISA FERNANDEZ
WAYNE HENDRIX
DAVID E MLYNARSKI
TONI CALLICOTT
President
MIGUEL.I GUERRERO. P E.
Director of Water Utility
KEVIN T. STEWART. P E
Director of Water Reclamation
JENNIFER SHEPARDSON
Director of Environmental &
Regulatory Compliance
TERR) WILLOUGHBY
ROBIN L. OHAMA
Acting General Manager
Director of Finance
"Trusted, Quality Service since 1905"
February 28, 2018
Ms. Mariam Fawaz
Remedial Project Manager
Superfund Division
United States Environmental Protection Agency, Region 9
75 Hawthorne Street, SFD-7-3
San Francisco, CA 94105
Dear Ms. Fawaz:
RE: REVISED CALCULATION OF PCE MASS REMAINING IN NEWMARK
GROUNDWATER CONTAMINATION SUPERFUND SITE FOR FIVE-YEAR
REVIEW REPORT
This letter transmits the City of San Bernardino Municipal Water Department's (City) comments
on the planned calculations of the mass of PCE remaining in the Newmark Groundwater
Contamination Superfund Site. It is our understanding that as part of the EPA Five-Year
evaluation, EPA's contractor (Tetratech) will update the calculation of the PCE mass remaining
in the Newmark and Muscoy plumes using 3-dimensional visualization and analysis (3DVA)
methods presented in the report titled "Final Technical Memorandum Source Identification,
Plume Delineation, Restoration Timeframe Estimation and Transition from Interim to Final
Remedy Newmark Groundwater Contamination Superfund Site," prepared by EPA and dated
May 19, 2014 (2014 Tech Memo). Stantec has provided Tetratech with groundwater sampling
laboratory analytical data and water level data in support of this effort.
The City is requesting additional steps be taken to those completed in preparation of the 2014
Tech Memo. The 2014 Tech Memo limited the estimation of remaining PCE mass to areas of
the plume that are interpreted to be in excess of the PCE MCL of 5 (ig/L. This approach is
somewhat misleading, and may result in incorrectly suggesting that remedial action can be
1350 South "E" Street, San Bernardino, California 92408 P.O. Box 710, 92402 Phone: (909) 384-5141
FACSIMILE NUMBERS: Administration: (909) 453-6399 Customer Service: (909) 453-6396 Finance: (909) 453-6383 Engineering: (909) 453-6385
Corporate Yards: (909) 453-6389 Water Reclamation Plant: (909) 453-6395 Environmental & Regulatory Compliance: (909) 453-6391
Environmental Control: (909) 453-6394
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Ms. Mariam Fawaz
Page 2
February 28, 2018
terminated, when in fact the Consent Decree terms expressly require the City to continue to treat
such contaminants to drinking water permit levels, which are non-detect for PCE, TCE, and
other VOCs because of the State's impaired water's policy, which is imposed on the City
through the water supply permits and has been since 1997.
As you are aware, much of the remaining PCE mass in the Newmark and Muscoy OU plumes
resides in areas where concentrations of these contaminants are below 5 (xg/L. As was
contemplated in the Remedial Design for both the Muscoy and Newmark Operable Units, the
Remedial Action (RA) extraction wells are being operated under the City's water supply permit
administered by the State Water Resources Control Board Division of Drinking Water (Permit).
Per the terms of the Permit, SBMWD is required to treat PCE in groundwater to 0.5 (xg/L
standard, essentially non-detect under the test method.
This permit requirement is in accordance with Policy Memo 97-005 Policy Guidance for Direct
Domestic Use of Extremely Impaired Sources. Therefore, under the Consent Decree's terms, the
persistence of PCE in most of the extraction wells at concentrations between 0.5 (xg/L and 5
jxg/L will require that remedial operations continue for a substantial time into the future before
the aquifer is capable of producing drinking water in the PCE plume area that will not require
treatment. It would be beneficial for the 3DVA based plume mass estimates of PCE include
mass in areas between 0.5 and 5 (xg/L to better understand the full mass of remaining PCE
groundwater impacts that will require treatment. That visualization will also prevent premature
recommendations to terminate remedial action before the legal requirements are met for such
completion of the remedial work.
In addition, the 2014 Tech Memo provides an estimated time to remove the remaining mass with
the remedy extraction wells. The method utilizes historical mass removal data for the three
remedy treatment plants to predict future mass removal rates of PCE. The PCE mass removal
rates are then utilized in conjunction with estimates of mass remaining in excess of 5 (xg/L to
predict how long it will take to remove PCE in excess of 5 (xg/L. An estimated time of
completion of four (4) years corresponding to the end of 2016 was predicted for the 19th Street
North Treatment Plant extraction wells. Groundwater sampling results through 2017 do not
support this prediction. This is partly due to the fact that much of the PCE mass being extracted
by the RA systems originates from areas where the PCE concentrations are between 0.5 (xg/L
and 5 fxg/L, yet the method attributes the mass reduction to areas that exceed 5 fxg/L.
Considering the entire mass of the plume, including areas between 0.5 fxg/L and 5 (xg/L, would
provide a better indication of the time required to remove the remaining mass of PCE requiring
treatment, though we note that the method has significant limitations and is an overly simplistic
method of estimating cleanup time. Facts such, as the time needed for PCE impacted
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Ms. Mariam Fawaz
Page 3
February 28, 2018
groundwater to migrate towards the extraction wells, as well as the effects of contaminant
dispersion, diffusion and retardation are not considered in the visualization, but need to be
accounted for to obtain a more accurate forecast of completion.
Obviously, the optimum way of estimating cleanup time is through the use of the Newmark
Groundwater Flow Model (NGFM) and Regional Basin Solute Transport Model (RBSTM),
which are currently being updated. The Final ROD indeed establishes the groundwater model as
the ultimate tool for evaluating whether the remedial action has been completed. In 2014, EPA
mistakenly sought to rely on the visualization to suggest termination of the work would occur
when the 5 fig/L limit was reached in all the wells, without acknowledging the different permit
standards which apply here and without addressing the very significant limitation on using the
visualization model for such predictions. The NGFM and RBSTM are far better tools to make
such forecasts, and the ones under the Final ROD.
Please consider our recommendations in the Five-Year review analysis and report. If you have
any questions or comments, please contact me at (909) 453-6101.
Sincerely yours,
Miguel J. Guerrero, P.E.
Director, Water Utility
MJG:swd
cc: Stephen Niou
Robin Ohama
Russ Randle
Mark Eisen
W:\3010 WD Administration\WU Director\Miguel\Letters\Letter to EPA Re PCE Plume Modeling 2-2B-18.doc
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