HomeMy WebLinkAboutSupplemental Information - Correspondence re: Naval Weapons StationMs. Joanne Yeo
City of Seal Beach
211 8th Street
Seal Beach, CA 90740
Dear Ms. Yeo:
DEPARTMENT OF THE NAVY
SOUTHWEST DIVISION
NAVAL FACILITIES ENGINEERING COMMAND
12M PACIFIC HIGHWAY
SAN DIEGO, CA 9 21 9 2 519 9
5090
Ser 5NEN.SL/444
23 MAR 01
Pursuant to the Federal Facility Site Remediation Agreement for Naval Weapons
Station, Seal Beach, Section 7.7(C), we request your organization to identify potential
state chemical- specific, location - specific and action - specific Applicable or Relevant and
Appropriate Requirements (ARARs) for proposed non -time critical removal actions at
Site 5, Clean Fill Dirt Area, and Site 7, Station Landfill. We sent the ARAR requests for
sites 5 and 7 to the Department of Toxic Substances Control (DTSC) on November 9,
2000. Subsequently, DTSC sent letters to your agency in November and December
2000 requesting ARARs. Your agency did not respond to DTSC's requests.
To expedite the removal process, the Department of the Navy (DoN) is requesting
action - specific ARARs along with the chemical - specific and location- specific ARARs
within 30 days receipt of this letter. The attached enclosures are the engineering
evaluation /cost analysis summaries for Installation Restoration (IR) sites 5 and 7 to
assist you with this effort.
In addition, the DoN is requesting your agency to identify any other criteria,
advisories, guidance, and proposed standards that your agency requests to be
considered for the above identified IR sites.
The DoN is requesting timely identification of potential ARARs consistent with
Section 121 (d) (2) (A) of CERCLA and the National Contingency Plan 40 CFR
§ §300.400 (g) and 300.515(d) &(h). Experience to date around the country has shown
that a failure to identify ARARs with sufficient precision, early in the process, can cause
severe disruptions in timely implementation of removal actions. To ensure timely and
complete ARARs identification, for the IR sites listed above, please include the following
information:
a. A specific citation to the statutory or regulatory provision(s) for the potential
ARAR and the date of enactment or promulgation.
5090
Ser 5NEN.SU444
23 MAR 01
b. A brief description of why the potential ARAR is applicable or relevant and
appropriate to the particular IR site.
c. A description of how the potential ARAR would apply to the potential remedial
action, including: specific numeric discharge, effluent, or emission limitations; hazardous
substance /constituent action or cleanup levels; where your agency intends to adopt the
potential ARAR, including such clean -up limitations, levels, etc.
d. If your agency believes its proposed ARAR is more stringent than the
corresponding federal ARAR, please provide the rationale and technical justification for
this position.
e. If your agency determines that there is not enough information to fully respond
to our request, please identify any additional information that would be required to
support identification of ARARs and their application.
Consistent with 40 CFR §S300.515 (h) (2), we are requesting that you send a
response via first class mail addressed to me and postmarked within thirty (30) calendar
days of receipt of this request. Please direct any technical questions that you may have
concerning this request to Si Le at (619) 532 -1235 and any legal questions to Marc
Rosen, Associate Counsel (Environmental) at (619) 532 -1662.
Sincerely,
YZ�
Environmental Team Leader
By direction of the Commander
Enclosures: 1. Summary of Background, Site 5
2. Summary of Background, Site 7
Copy to:
Department of Toxic Substances Control (Katherine Leibel)
Summary of Background Information and Removal
Action Alternatives for Installation Restoration Site 7
Naval Weapons Station Seal Beach
Seal Beach, California
1.0 Introduction
The background information and removal action alternatives presented below have been compiled to
assist the Department of the Navy (Navy) and state regulatory agencies in identifying chemical -
specific, location- specific and action - specific applicable or relevant and appropriate requirements
(ARARs) to support the Engineering Evaluation/Cost Analysis (EE/CA) for a Non -Time Critical
Removal Action at Site 7 Station Landfill (Site 7), Naval Weapons Station (NAV WPNSTA) Seal
Beach, California. A number of general response actions, removal technologies, and process options
generally considered capable of addressing removal action items similar to those identified at Site 7
will be evaluated and screened in the Draft EE/CA based on expected effectiveness, technical
implementability, and relative cost. Technologies and process options that passed the screening
process will be assembled into three comprehensive removal action alternatives capable of achieving
the removal action objectives (RAOs) established for Site 7. A fourth altemative, No Action, will
also be considered for comparative purposes as required under the National Oil and Haumlous
Substances Pollution Contingency Plan (NCP). Detailed and comparative evaluations of these
alternatives will then be prepared based on effectiveness (including compliance with ARARs),
implementability, and cost. More detailed information will be found in the Draft EE/CA.
2.0 Facility Description and Background
NAV WPNSTA Seal Beach, located about 30 miles south of the Los Angeles urban center, consists of
about 5,000 acres of land located on the Pacific Coast within the City of Seal Beach in Orange
County, California. NAV WPNSTA Seal Beach is part of the Commander Navy Region Southwest,
and its major claimant is the Commander -in -Chief Pacific Fleet. The station provides fleet
combatants with ready- for -use ordnance. Because of its geographic location, the station serves as a
supply point for the operating Navy and Marine Corps forces in the Southern California region.
2.1 Site Location
Site 7 Station Landfill, a waste disposal site, is situated at the southern boundary of NAV WPNSTA
Seal Beach, adjacent to Perimeter Road and the Orange County (Bolsa Chica) Flood Control Channel
(see attached map). The site is within Sections 17 and 18 of Township 5 South, Range I I West, of
the San Bernardino Meridian. The longitude and latitude of Site 7 are 118 005'3" west and 33 °44'
north, respectively.
Site 7 Station Landfill is an approximately 33 -acre site located near the southern boundary of the
Station and at the eastern boundary of the Seal Beach National Wildlife Refuge (NWR). A portion of
Site 7 is located within NWR (see attached map). The NWR was established to preserve one of the
largest remaining salt marshes in Southern California. It provides essential habitat for the California
SCO UM7 5C_166167V16
WMMARY OF BACKGROUND INFORMATION AND REMOVAL ACTION ALTERNATNES FOR
V .
least tern and light- footed clapper rail and maintains quality habitat for the California brown pelican,
peregrine falcon, and Belding's savannah sparrow.
Site 7 is bounded on the north by a railroad spur and oval laydown area, and on the south by a
drainage ditch and Perimeter Road. The eastern boundary is not delineated, but appeared in aerial
photographs (by previous investigations) to extend to the southern projection of the marshalling yard.
The western boundary parallels a dirt road and cuts diagonally across the tidal saltmarsh at the
southeast comer of NWR. The abandoned roadbed has been lowered to the level of the tidal
saltmarsh, but can still be seen onsite.
2.2 Type of Facility and Operational Status
The landfill reportedly began operations some time between October 1955 and December 1957, and
operated until about 1973, when a contract was awarded for off - Station disposal of wastes.
According to interviews of long -time Station employees and a review of historical aerial photographs
conducted by the 1985 Initial Assessment Study (IAS), it is reported that the landfill was developed in
three stages. A different trench was used in each of these three stages. Each trench was reported to
be about 80 feet wide by 300 feet long and was excavated to about the water table. The total volume
of the three trenches is reportedly about 27,000 cubic yards. However, results of the aerial
photograph review and geophysical survey conducted for the Remedial Investigation indicate
landfrlling was not limited to three trenches.
Almost any waste produced on- Station may have been disposed at the landfill. Full, partially full, and
empty drams and cans may have been disposed at Site 7. The largest volume of waste was reportedly
empty paint and solvent containers, mostly 1- and 5- gallon cans. Other reported wastes include
lumber, metal banding, construction debris, asbestos insulation, rags, paint, mineral spirits, alcohol,
solvents, paint thinner, transformer oil filters, and petroleum products. (NEESA, 1985). During the
1960s, non - Station personnel were allowed to enter NAV WPNSTA Seal Beach and dispose of wastes
at the landfill. The road - oiling contractor's truck was reportedly observed at the landfill during this
time; whether the tank track discharged to the landfill is unknown (NEESA, 1985).
Subsequent field investigations of Site 7 conducted under the Navy's IR Program confirmed the
presence of trenches (SWDIV, 19956). Investigations to date have demonstrated that much of the
material in these trenches appears to be predominantly domestic refuse, construction debris, and
earthen fill material (SWDIV, 19966). In addition, results of the previous investigations concluded
that the degree and types of chemical contamination that may be attributable to Site 7 did not warrant
remediation. Descriptions of the previous investigations are briefly summarized in Section 3.0.
Currently, no disposal activity occurs at the site. The current and future uses of the land occupied by
the refuge are the same. (National wildlife refuges are established by Congress and are considered
permanent entities.)
3.0 Previous Investigations
NAV WPNSTA Seal Beach and the Navy have been actively engaged in the Installation Restoration
Program (IRP) since 1980. Since 1985, Site 7 has been the subject of nine environmental
investigations including:
• Initial Assessment Study (NEESA, 1985)
• Resource, Conservation and Recovery Act (RCRA) Facility Assessment (AT. Kearney, 1989)
• Plan of Action/Site Inspection (SWDIV, 1990)
SCaMW3A6C_I M72116
SUMMARY OF BACKGROUND INFORMATION AND REMOVAL ACTION ALTERNATIVES FOHINSTALUTION RESTOMTION SITE 7
NAVAL WEAPONS STATION SEAL BEACH
SEAL BEACH. CALIFORNIA
• Remedial Investigation (SWDIV, 1995b)
• Landfill Closure Plan (SWDIV, 19966)
• Ecological Risk Assessment Phase 11 Validation (SWDIV, 1999a)
• Supplemental Groundwater Monitoring (SWDIV, 19996)
• Supplemental Characterization of Perimeter Pond Trenches (SWDIV, 1999c)
• Aquatic Ecological Risk Assessment (SWDIV, 2000)
Investigations and studies to date have indicated that the risk to human health and ecological
receptors are marginal (SWDIV, 19956 and 1999a).
4.0 Description of Removal Action Alternatives
The EE /CA identifies removal action alternatives to address the removal action items for Site 7. Four
alternatives were identified and considered:
• Alternative 1, No Action
• Alternative 2, Capping with Monolithic Cover
• Alternative 3, Groundwater Monitoring and Existing Soil Cover Repair
• Alternative 4, Excavation and Offsite Disposal
These alternatives are summarized in the attached table and discussed in further detail below.
As shown in the attached table, for Alternatives 2, 3, and 4, the Navy proposes the following common
removal actions for Areas 3, 4, 5, and 6:
Areas 3, 4, and 6: Removal of Surface Debris, followed by confirmation of removal effectiveness
by performing a geophysical survey.
Based on geophysical survey data, only surface debris is known to exist within Areas 3, 4, and 6.
Therefore, selective removal of debris from the top few feet of soil at the site is proposed in these
areas. The debris material will be transported offsite and disposed in a landfill or recycled. Prior to
commencement of debris removal activities, the vegetation habitat in these areas will be relocated and
protected. After completion of removal action activities, replanting will restore the vegetation
habitat.
Area 5: Excavation and Otfsite Disposal, followed by backfLll with imported soil.
Based on long -temL risks to aquatic receptors in the Perimeter Pond, excavation and offsite disposal
of wastes in Area 5 is proposed as a common removal action for Altematives 2, 3, and 4. The
removal action would involve excavation of wastes and debris (approximately 1,068 cubic yards (cy)
in -place volume [SWDIV, 1999c]) present below approximately 3 feet of overburden soil in the area.
The excavation volume, however, may vary quite significantly based on conditions encountered
during excavation. It is anticipated that in -place excavation volumes (excavated soils and waste) at
Area 5 could range from as low as 1,600 cy to as high as 14,700 cy. The wastes will then be
transported offsite and disposed in a permitted landfill. Imported clean fill will be used to backftll the
excavation.
SCQ1A%2735C_I MM72716
SUMLNRY OF BACKGROUND INFORMATION AND REM Al. ACTION ALTERHATNES FOR INSTALIARON RESTORATION SITE
NAVAL WEAPONS STATION SEAL BEACH r
SEAL BEACH, CALIFORNIA
4.1 Alternative 1, No Action
Alternative 1 does not include additional characterization of the site or further action to remove waste
materials or reduce risk posed by wastes at the site. Under this alternative, the buried refuse and
surface debris at Site 7 (Areas I to 6) are left in place. This removal action alternative was retained as
a baseline against which other response actions could be compared.
4.2 Alternative 2, Capping with Monolithic Cover
Alternative 2 involves containment via capping, which is the U.S. Environmental Protection Agency
(EPA )-recommended presumptive remedy for landfills. Alternative 2 consists of the following
removal actions for the different areas identified at Site 7:
• Area I: Capping
• Area 2: Groundwater monitoring
• Areas 3, 4, and 6: Surface debris removal
• Area 5: Excavation followed by offsite disposal, and clean imported backfill
As discussed previously, common removal actions involving excavation/surface debris removal are
proposed for Areas 3, 4, 5, and 6. A description of removal actions proposed at Areas I and 2 are
presented below.
For Area 1, capping with 2 feet of imported fill is proposed to provide adequate separation of the
buried waste from receptors adjacent to and within Area I at Site 7. Area 1 is approximately
7.6 acres, and the cap will be uniformly placed across this entire area. The removal action at Area I
(from bottom to top) will consist of the following:
• Construction of a 24- inch -thick soil cover layer consisting of fine- grained soil (USCS: ML).
• Revegetation of the soil cover for erosion control. The plant species selected will have rooting
depths no greater than 2 feet, and will be consistent with the NAV WPNSTA Seal Beach
Integrated Natural Resources Management Plan (INRMP).
• Construction of drainage channels to provide stormwater drainage.
• Postclosure maintenance.
For Area 2, a groundwater monitoring program to evaluate the potential long -term risks from buried
wastes present in the area is proposed. Results of past investigations at Area 2 have indicated low
risks to terrestrial receptors and humans from buried wastes at Area 2. In addition, significant risks to
aquatic receptors are not likely due to the predominant groundwater flow away from the nearest
surface water bodies at Site 7. Therefore, a groundwater monitoring program involving the
installation of three additional monitoring wells is proposed to demonstrate the low risks from
groundwater at Area 2.
4.3 Alternative 3, Groundwater Monitoring and Existing Soil Cover Repair
Alternative 3 involves groundwater monitoring and other common removal actions as described
previously. Alternative 3 consists of the following removal actions for the different areas identified at
Site 7:
• Area 1: Groundwater monitoring and existing soil cover repair
• Area 2: Groundwater monitoring
• Areas 3, 4, and 6: Surface debris removal
• Area 5: Excavation followed by offsite disposal, and clean imported backfill
SCQ'UVRTBSCJ 0ON72716
SUMMARY O FACKGFOUND INFORMATION AND REMOVAL ACTION ALTERNATIVES FOR INSTALLATION USTOMnON SITE 7
NAVAL WEAPONS STATION SEAL BEACH
SEALBEACH.CALIFORNN
As discussed previously, common removal actions involving excavation /surface debris removal are
proposed for Areas 3, 4, 5, and 6. A description of removal actions proposed at Areas I and 2 are
presented below.
Groundwater monitoring involving a total of eight wells is proposed at Areas I and 2 based on the
minimal risks to receptors identified at the site. In addition, at Area I, the existing soil cover will be
patched to provide for a sufficient cap thickness that will reduce direct contact with buried waste
onsite. In Area I, a network of four existing groundwater monitoring wells will be used to collect
groundwater samples and monitor for potential trends in chemical concentrations in groundwater. In
Area 2, three additional monitoring wells are proposed, to monitor groundwater concentrations south
of Area 2. One existing monitoring well, north of Area 2, will also be included in the monitoring
program. The groundwater will be monitored for potential trends or offsite migration of chemicals
from Area 2. The purpose of this groundwater monitoring program is to serve as a sentinel well
network to monitor potential groundwater contamination from Site 7. These wells are strategically
located between buried wastes at Site 7 and the nearest potential aquatic receptors. Thus, these
groundwater monitoring wells would serve as an "early detection system."
4.4 Alternative 4, Excavation and Offsite Disposal
Alternative 4 consists of the following removal actions for the different areas identified at Site 7:
• Areal: Excavation followed by offsite disposal, and clean imported backfill
• Area 2: Excavation followed by offsite disposal, and clean imported backfill
• Areas 3, 4, and 6: Surface debris removal
• Area 5: Excavation followed by offsite disposal, and clean imported backfill
As discussed previously, common removal actions involving excavation/surface debris removal are
proposed for Areas 3, 4, 5, and 6. A description of removal actions proposed at Areas 1 and 2 are
presented below. It is estimated that approximately 34,032 cy and 3,660 cy of in -place waste exist in
Areas 1 and 2, respectively. The excavation volume, however, may vary quite significantly based on
conditions encountered during excavation. It is anticipated that in -place excavation volumes
(excavated soils and waste) in Area I could range from as low as 71,900 cy to as high as 183,000 cy.
Similarly in Area 2, the in -place excavation volumes could range from as low as 7,400 cy to as high
as 17,400 cy.
The removal actions at Areas 1 and 2 comprise the following activities:
• Excavation of waste and soils within Areas I and 2.
• Offsite disposal of excavated waste and soil.
• Backfill with clean imported fill.
• Revegetating the imported fill for erosion control. The plant species selected will be consistent
with the NAV WPNSTA Seal Beach INRMP.
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