HomeMy WebLinkAboutItem GFebruary 12, 2001
STAFF REPORT
To: Mayor Campbell and Members of the City Council
Attention: Donald F. McIntyre, Acting City Manager
From: Lee Whittenberg, Director of Development Services
Subject: APPROVAL OF COMMENT LETTER RE:
"FOCUSED SITE INSPECTION PHASE JI
REPORT", NAVAL WEAPONS STATION
RECOMMENDATION
Authorize the Mayor to sign the draft comment letter, with any additional comments determined
appropriate, and instruct staff to forward to the Environmental Quality Control Board a copy of the
signed letter. Receive and File Staff Report.
DISCUSSION
The Department of the Navy is requesting comments on the "Focused Site Inspection Phare 11
Report" by February 16, 2001.
Purpose of the Focused Site Inspection Phase 11
The overall purpose of the subject report is to close existing data gaps by:
❑ Better delineating the lateral and vertical extent of chemicals of potential concern (COPC) in
soils, sediments, and groundwater (as necessary).
❑ Evaluating COPC concentrations in soil, sediment, and groundwater (as necessary) to assess the
potential threat to human health and the environment through risk screening.
❑ Evaluating the IRP locations for potential No Further Action (NFA), removal actions, or further
evaluations (with an emphasis on the former two types of decisions). .
The recommendations of the report, as set forth in Section 6.0, are as follows
AGENDA ITEM G
C.-Wyn um ntMA`/WPSTATSI Phan n R pon.CC Sm Rep n.do W\01-25 I
City Comment Lener re:
"Focused Site Inspection Phase If Report", Seal Beach Naval Weapons Station
City Council Staff Report
February /2, 2001
No Further Action
Site 12
Site 13
Site 16
Site 25
Site 37
Site 38
Site 42 (Sump Release)
Site 44/45 (Outside Drainage Ditch)
AOC6
SWMU 56
Building 128 Strip Pit
Review by Environmental Quality Control Board
Removal Action
Site 42 (within Wildlife Refuge)
Site 44/45 (Drainage Ditch)
SWMU 24
SWMU 57
Site 73
Site 74
The Environmental Quality Control Board (EQCB) reviewed and discussed this matter at their
January 24, 2001 meeting. A copy of portions of the document was provided for the information of
the Board. Given some of the issues raised in the document, staff prepared a draft comment letter
for the review and approval of the EQCB and the City Council. The draft comment letter is
provided as Attachment 1. The comment letter incorporates revisions recommended by the EQCB,
with those revisions being indicated by double-strikethrough for lmguaga w be 4giwim and by bold
and double -underlined for antra to add d.
Overview of Previous Board/City Council Action re: "Focused Site Inspection Phase II Work
Plan":
On September 29, 1999, the Board reviewed the "Work Plan" submitted by the Navy and
authorized the Chairperson to sign a comment letter, after review and approval by the City
Council. The City Council considered the report and approved the letter on October 11, 1999
and authorized the Mayor to sign the comment letter. The City Council/Board letter indicated:
"The City also supports the following proposals contained within the FSI Phase II
Work Plan document:
❑ The proposed "Study Boundaries" set forth in Step 4, Table 3-1.
o The proposed "Decision Rules" set forth in Step 5, Table 3-1.
❑ The proposed "Optimize the Sampling Design" set forth in Step 7, Table 3-1".
"In regards to Site 73, Water Tower Area, the City supports the required presence of
a "qualified archaeological monitor" during fieldwork at this site. However, given
FSI Phase n Repon.CC Staff Report
City Comment Letter re.
"Focused Site Inspection Phase 11 Report Seal Beach Naval Weapons Station
City Council StafRepon
February 12.2001
the potential significance of the archaeological site, which overlaps the Water Tower
site, it is requested that a qualified Native American monitor also be present during
all fieldwork activities at this site." (See Attachment 3 of the EQCB Staff Report of
January 24, 2001 for a copy of the complete letter)
Issues of Concern to Board re "Focused Site Inspection Phase II Report";
In reviewing the subject report, staff has focused its efforts in reviewing the recommendations of
"no further action" and "removal action" set forth above, and the information provided within
Appendixes K and L. relative to "Screening Human Health Risk Assessment" and "Screening
Ecological Risk Assessment".
In reviewing the information contained within the subject report, including Appendixes K and L,
there appear to be some issues of concern that should be clarified or explained in greater detail
regarding the determinations of "No Further Action" and "Removal Action. The main areas of
concern are related to the lack of clarity in explaining the determinations of the Navy as to "No
Further Action" regarding Sites 37, 38 and AOC 6. Please refer to the proposed comment letter,
Attachment 1, to review the concerns regarding the recommendations for "No Further Action"
relative to these IR sites.
Proposed Response Letter
The Navy is requesting comments on the subject document by February 16, 2001. Staff has
prepared the initial draft of the response letter for consideration by the EQCB and ultimately the
City Council, indicating general concerns of the City (See Attachment 1, indicating revisions
approved by the EQCB).
RECOMMENDATION
Authorize the Mayor to sign the draft response letter, with any additional comments determined
appropriate, and instruct staff to forward to the Environmental Quality Control Board a copy of the
signed letter. Receive and File Staff Report.
Whittenberg, Director
Development Services Departmn3
FSI Phan n Repon= Suff Repon
NOTED AND APPROVED
Donald F. McIntyre
Acting City Manager
City Comment Letter re:
"Focused Site Inspection Phase 11 Report". Seal Beach Naval Weapons Station
City Council Staff Report
February 12, 2001
ATTACHMENTS: (2)
Attachment 1: Draft Comment Letter from City Council and EQCB re: "Focused Site
Inspection Phase 11 Report", prepared by Seal Beach Naval Weapons
Station, dated December 18, 2000
Attachment 2: EQCB Staff Report re: "Focused Site Inspection Phase II Report", dated
January 24, 2001, without Attachments. The Attachments consisted of the
Comment Letter provided as Attachment 1, prior to consideration by the
EQCB, portions of the subject "Focused Site Inspection Phase II Report",
and a copy of the October 11, 1999 City Continent Letter regarding the
"Work Plan" for this report.
The "Focused Site Inspection Phase 11 Report", is not provided due to the
length of the document, 1,005 pages in two volumes. The complete report is
available at the Department of Development Services for review.
FSI Phew n RepoaCC Stift Report
February 12, 2001
Department of the Navy
Naval Weapons Station, Seal Beach
Atm: Pei -Fen Tamashim, Installation Restoration Coordinator
800 Seal Beach Boulevard
Seal Beach, CA 90740-5000
Dear Mrs. Tamashim:
SUBJECT: CITY OF SEAL BEACH COMMENTS RE:
"FOCUSED SITE INSPECTION PHASE 77
REPORT"
The City Council and the Environmental Quality Control Board ("Board') of the City of
Seal Beach have reviewed the above referenced project report, relating to screening risk
assessments for human and ecological receptors.
In reviewing the document, the information provided within Section 3.0, Conceptual Site
Models (CSM), is helpful in obtaining an understanding of the subject sites for the purposes
of evaluating potential risks to human health and the environment. The CSMs serve as the
basis for identifying the data quality objectives (DQOs), sampling and analytical strategy,
assessing human health risks and ecological risks, and developing recommendations and
conclusions. The presentation of the CSM information within Figures 3-1 through Figure 3-
30 is particularly helpful in obtaining:
❑ an understanding of the site location within the Naval Weapons Station
❑ a more detailed overview of the appropriate site
❑ the location of previous sampling/testing activities
❑ a summary of the primary sources of contamination
❑ a summary of the potential release mechanisms
❑ summary of potential secondary sources of exposure
❑ potential release mechanisms
❑ overview of pathways of exposure
❑ and an overview of exposure routes to both human and ecological receptors, with an
overview of determinations relating to:
C:vveyD umnMWAVWPSTATSI Pe uapon.City Com nt 1otw.do\LWW1-25o1
City of Seal Beach Comment Lener re.,
FSI Phase 11 Report, Seal Beach Naval Weapons Station
February 12, 2001
❑ chemicals present at concentrations below risk concerns, and
❑ screening risk assessment to be addressed in this report.
The graphic "Conceptual Site Moder' models presented by Figures within Section 3.0 are
particularly helpful in obtaining a broad overview of the overall potential for each site to
serve as an exposure point to either human or ecological receptors at the identified risk
assessment levels.
Section 5.0, Results and Conclusions, presents an understandable and concise overview of
the sampling activities conducted at each site, the analytical results of those sampling
activities, screening risk assessment results for human and ecological receptors, and
conclusions. The summary information provided in relation to the human health and
ecological risk screening analysis is particularly helpful in providing basic information as to
the conclusions regarding "No Further Action" or "Removal Action" at each of the subject
sites.
Table 6-1 is extremely helpful in providing to the lay reader an overall summary of the
findings of the Phase II Focused Site Inspection, the Rationale for Recommendation, and the
Recommendation for each site evaluated. It would helpful to provide this table within the
Executive Summary, or to provide a cross reference to this table within the Executive
Summary. The information provided in the concise manner of Table 6-1 would allow the
lay reader to more clearly grasp the thought process employed within the study to reach the
conclusions of "No Further Action" or `Removal Action" set forth within the Executive
Summary.
In reviewing Table 6-1, the City has the following comments regarding Site 74, the Old
Skeet Range:
Site 74 — Old Skeet Ranee
City Agreement The City agrees with the recommended removal action for areas
where lead and PAHs in sediments pose a human risk concern and where lead and antimony
pose an ecological risk concern, as discussed in Table 6-1, page 5 of 6 of Volume I of the
subject report. It is recognized this IR Site is located within a sensitive wildlife habitat area.
The City would request the opportunity to review subsequent documents that will develop
the appropriate criteria for lead that will balance the reduction of environmental risks with
potential damage to the sensitive wildlife habitat area.
In reviewing Appendixes K and L, the City has the following questions, requests for
clarification regarding specific sites, or agreement with proposed removal actions:
Aonendix K-1—Screenine Human Health Risk Assessment Technical Memoranda.
Site 37 — Bolsa Avenue Storage Yard
FSI Phew n Rep mCity Comment Letter
City of Seal Beach Comment Letter re:
FS/Phase 11 Report, Seal Beach Naval Weapons Station
Febraory 11, 2001
Appendix K-1, page K-1-3, discussing Site 37 indicates "As shown in Table 3b, the 95
percent UCL concentration of arsenic (22 milligrams per kilogram [mg/kg] just exceeded
the ULBV (15 mg/kg) to yield an ELCR of 7 x 10-5. Only arsenic exceeded it's
corresponding ULBV at sufficiently high concentration to yield a noncancer HQ equal to 1."
City Concern: The 95 percent UCL concentration of arsenic exceeds the ULBV by 46%,
which would seem more than "just exceeding". The City requests clarification as to why a
site with an identified noncancer HQ equal to 1 is recommended for "No Further Action".
This recommendation for NFA is unclear as to the basis of that determination, when the
document indicates on page 4-23 that an HI exceeding 1 is the numerical indicator of the
transition between acceptable and unacceptable exposure levels and that EPA considers
action may be warranted at a site where the HI exceeds 1.
Site 38 — X-ray Shoo Leach Field
Appendix K-1, page K-1-4, discussing Site 38 indicates "As shown in Table 4b, arsenic
exceeded its ULBV to yield an ELCR of 6 x 10. Also, only arsenic exceeded it's
corresponding ULBVs to yield a noncancer HI equal to 1."
City Concern: The City requests clarification as to why a site with an identified noncancer
HI equal to 1 is recommended for "No Further Action". This recommendation for NFA is
unclear as to the basis of that determination based on comments regarding Site 37 above.
AOC 6 — External Paint Area
Appendix K-1, page K-1-4, discussing AOC 6 indicates "All metals, VOCs and SVOCs had
individual noncancer His less than 1, with the cumulative HI for soil and sediment at the site
approximately equal to 1.3."
City Concern: The City requests clarification as to why a site with an identified noncancer
HI approximately equal to 1.3 is recommended for "No Further Action". This
recommendation for NFA is unclear as to the basis of that determination based on comments
regarding Site 37 above.
Appendix LI — Screening Ecoloelcal Risk Assessment Technical Memoranda:
Site 42 — Auto Shot) Sump/Waste Oil Sump Discharge Point in NWR
City Agreement: The City would concur with the recommended additional
investigations of disposal practices for engine coolant and other liquids that might contain
copper and other metals in the vicinity of Site 42. In addition, the City agrees with the
recommended removal action for areas where metals pose an ecological concern, as
discussed in Table 6-1, page 3 of 6 of Volume 1 of the subject report.
FSI Phase n Report.City Comtneot later 3
City of Seat Beach Comment Letter re:
FSI Phase If Report, Seal Beach Naval Weapons Station
February I$ 2001
Site 44/45 — Former Waste Otto Fuel Drum StomeeBuildine 88 Floor Drain Outlet
City Agreement. The City agrees with the recommended removal action for areas
where nickel and zinc in sediments pose an ecological concern, as discussed in Table 6-1,
page 3 of 6 of Volume 1 of the subject report.
SWMU 24 — Stationary Demilitarization Furnace
City Agreement: The City agrees with the recommended removal action for areas
where lead and other metals in sediments pose an ecological concern, as discussed in Table
6-1, page 4 of 6 of Volume 1 of the subject report.
Site 73 — Water Tower Area
City Agreement: The City agrees with the recommended removal action for areas
where lead in sediments pose an ecological concern, as discussed in Table 6-1, page 5 of 6
of Volume 1 of the subject report. It is recognized this B2 Site is located within an area of
archaeological concern, and the City of Seal Beach Archaeological Advisory Committee
will be providing input regarding the proposed archaeological monitoring and evaluation
program presented in the report as Appendix A.
The City of Seal Beach appreciates the opportunity to review and comment on the
continuing activities of the Naval Weapons Station in the analysis and completion of
remediation activities related to the Installation Restoration Program. The ability to
comment on the activities on the Weapons Station to reduce overall human and ecological
risks within the community are sincerely appreciated, and the level of cooperation between
your various staff personnel and City personnel is to be commended.
If you have any questions regarding this matter, please contact Mr. Lee Whittenberg,
Director of Development Services, at (562) 431-2527, extension 313. He will be most
happy to respond to any questions or concerns you may have regarding this matter.
�Si/1nncerely, J/�J
PTatQri>c�iiaLlE'.t.8Campbell �
P
Er, IIroMayor Ch En rsumemal
Quality Control Board
City of Seal Beach Civof Seal Beach
ce: City Council
Environmental Quality Control Board
Archaeological Advisory Committee
City Manager
Director of Development Services
FSI Ph se n Repoa.City Com , Letter
City Comment Letter re:
"Focused Site Inspection Phase II Report", Seal Beach Naval Weapona Station
City Council Swff Repon
February 12, 2001
ATTACHMENT 2
EQCB STAFF REPORT RE: "FOCUSED SITE
INSPECTION PHASE II REPORT', DATED
JANUARY 24, 2001, WITHOUT ATTACHMENTS.
THE ATTACHMENTS CONSISTED OF THE
COMMENT LETTER PROVIDED AS
ATTACHMENT 1 (PRIOR TO CONSIDERATION
BY THE EQCB), PORTIONS OF THE SUBJECT
"FOCUSED SITE INSPECTION PHASE II REPORT",
AND A COPY OF THE OCTOBER 11, 1999 CITY
COMMENT LETTER REGARDING THE "WORK
PLAN" FOR THIS REPORT
THE "FOCUSED SITE INSPECTION PHASE II
REPORT', IS NOT PROVIDED DUE TO THE
LENGTH OF THE DOCUMENT, 1,005 PAGES IN
TWO VOLUMES. THE COMPLETE REPORT IS
AVAILABLE AT THE DEPARTMENT OF
DEVELOPMENT SERVICES FOR REVIEW
FSI Phase 11 Report.CC Staff Report 11
January 24, 2001
STAFF REPORT
To: Members of the Environmental Quality Control Board
From: Lee Whittenberg, Director of Development Services
Subject: APPROVAL OF COMMENT LETTER RE: "Focused
Site Inspection Phase 1I Report", report dated December
18, 2000
SUMMARY OF REQUEST
Authorize Chairperson to sign proposed comment letter and refer to City Council for approval and
authorization of the Mayor to also sign (Refer to Attachment 1). Receive and File subject report_
DISCUSSION
Overview of "Focused Site Inspection Phase II Report":
The City has received a copy of the "Focused Site Inspection Phase II Report", prepared by
CH2MHil1 for Naval Facilities Engineering Command, dated December 18, 2000. This
document presents the results of additional field characterization work conducted at the Naval
Weapons Station to fill data gaps from previous site investigation activities. The Board
previously reviewed and recommended approval by the City Council of a comment letter on the
"Work Plan" for these investigations in September 1999, with the City Council ultimately
approving the recommended comment letter on October 11, 1999 (refer to the discussion
immediately following for an overview that review activity by the Board/City Council). In
March 2000 the Board was provided a Staff Report indicating receipt of the "Draft Final
Focused Site Inspection Phase II Work Plan", and providing the Board with a copy of the
comments and responses to comments received on the "draft" document in 1999.
This "Focused Site Inspection Phase 11 Report" conducted additional investigations in accordance
with the previously reviewed and approved "Work Plan" at the following Installation Restoration
Program (IRP) sites:
Site 12 —NASA Island Site 13 — Raw Sewage Spill
Site 16 — Primer/Salvage Yard Site 25 — Building 95 Fire Fighting Test Area
CAMyD =iiiaWAVWPSTA�SI Phase a Re MEQCB Siff RepoM.E LMBW"[
Consideration of Cam enr Letter re:
"Focused Site Inspection Phase 11 Report ", Seal Beach Naval Weapons Station -
Enmronmeraal Quality Control Board Staff Report
January 24, 2001
Site 37 — Bolsa Avenue Storage Yard
Site 38 — X-ray Shop Leach Field
Site 42 — Auto Shop Sump/Waste Oil Tank
Site 44/45 — Former Waste Otto Fuel Drum Storage/
❑ Section 5.0
Building 88 Floor Drain Outlet
AOC 6 — External Paint Area
SWMU 24 — Stationary Demilitarization Furnace
SWMU 56 — Hazardous Waste Drum Storage
SWMU 57 — Paint Locker Area
Site 73 — Water Tower Area
Site 74 — Old Skeet Range
Building 128 Strip Pit
Provided for the information of the Board are the following portions of the subject document (Refer
to Attachment 2):
❑ Executive Summary
❑ Contents
❑ Section 1.0
Introduction
❑ Section 3.0
Conceptual Site Models, Figures 3-1 through 3-30
❑ Section 5.0
Results and Conclusions
❑ Section 6.0
Recommendations
❑ Section 7.0
References
Purpose of the Focused Site Inspection Phase II:
The overall purpose of the subject report is to close existing data gaps by:
❑ Better delineating the lateral and vertical extent of chemicals of potential concern (COPC) in
soils, sediments, and groundwater (as necessary).
❑ Evaluating COPC concentrations in soil, sediment, and groundwater (as necessary) to assess the
potential threat to human health and the environment through risk screening.
❑ Evaluating the IRP locations for potential No Further Action (NFA), removal actions, or further
evaluations (with an emphasis on the former two types of decisions).
The recommendations of the report, as set forth in Section 6.0, are as follows:
No Further Action
Site 12
Site 13
Site 16
Site 25
Site 37
Site 38
Site 42 (Sump Release)
RN Phew II Re n.EQCB Sun Report
Removal Action
Site 42 (within Wildlife Refuge)
Site 44/45 (Drainage Ditch)
SWMU 24
SWMU 57
Site 73
Site 74
Consideration of Conarrent Letter re:
"Focaved Site Impecrion Phase 11 Report Seal Beach Naval Weapons Smtion -
£mironmeraal Quality Comrot Board Staff Report
January 24, 2001
Site 44/45 (Outside Drainage Ditch)
AOC6
SWMU 56
Building 128 Strip Pit
Issues of Concern to Board re "Focused Site Inspection Phase II Report"
In reviewing the subject report, staff has focused its efforts in reviewing the recommendations of "no
further action" and "removal action" set forth above, and the information provided within
Appendixes K and L, relative to "Screening Human Health Risk Assessment' and "Screening
Ecological Risk Assessment'.
In reviewing the information contained within the subject report, including Appendixes K and L,
there appear to be some issues of concern that should be clarified or explained in greater detail
regarding the determinations of "No Further Action" and "Removal Action". The main areas of
concern are related to the lack of clarity in explaining the determinations of the Navy as to "No
Further Action" regarding Sites 37, 38 and AOC 6. Please refer to the proposed comment letter,
Attachment 1, to review the concerns regarding the recommendations for "No Further Action"
relative to these IR sites.
It is recommended that the Committee authorize the sending of the prepared comment letter (Refer
to Attachment 1), forward to the City Council for approval, and receive and file this Staff Report
Overview of Previous Board/City Council Action re: "Focused Site Inspection Phase II Work
Plan":
On September 29, 1999, the Board reviewed the subject report from the Navy and authorized the
Chairperson to sign the proposed comment letter, after review and approval by the City Council.
The City Council considered the report and recommended letter on October 11, 1999 and
authorized the Mayor to sign the comment letter. The City Council/Board letter indicated:
"I'he City also supports the following proposals contained within the FSI Phase II
Work Plan document:
❑ The proposed "Study Boundaries" set forth in Step 4, Table 3-1.
❑ The proposed "Decision Rules" set forth in Step 5, Table 3-1.
❑ The proposed "Optimize the Sampling Design" set forth in Step 7, Table 3-1".
"In regards to Site 73, Water Tower Area, the City supports the required presence of
a "qualified archaeological monitor" during fieldwork at this site. However, given
the potential significance of the archaeological site, which overlaps the Water Tower
FSI Phase 11 R.,mMQCB Sun Report 3
Consideration of Comment Lener re:
'Focused Site Inspection Phase 71 Report', Seat Beach Nava! Weapons Station -
Envimnauntal Quality Control Board Staff Report
lanuory 24, 2001
site, it is requested that a qualified Native American monitor also be present during
all fieldwork activities at this site." (See Attachment 3 for a copy of the complete
letter)
RECOMMENDATION
Authorize Chairperson to sign proposed comment letter and refer to City Council for approval and
authorization of the Mayor to also sign (Refer to Attachment 1). Receive and File subject report.
Whittenberg, Director
Department of Development Servic
Attachments: (3)
ATTACHMENT 1: Draft Comment Letter re: "Focused Site Inspection Phase II
Report", prepared by Seal Beach Naval Weapons Station,
dated December 18, 2000
ATTACHMENT 2: "Focused Site Inspection Phase 11 Report", prepared by Seal
Beach Naval Weapons Station, dated December 18, 2000
Note: the following sections are provided to the Board
❑ Executive Summary
❑ Contents
❑ Section 1.0 - Introduction
❑ Section 3.0 - Conceptual Site Models, Figures 3-1
through 3-30
❑ Section 5.0 - Results and Conclusions
❑ Section 6.0 - Recommendations
❑ Section 7.0 - References
Complete document available at the Department of
Development Services for review. Not provided due to
length, 1,005 pages in two volumes.
FS1 Phase a Repat.EQCB Seen Report 4
Consideration of Conunent Letter re:
"Focused Site Inspection Phase II Report', Seal Beach Naval Weapons Station -
Emironmental Quality Control Board StafjReport
January 24, 2001
ATTACWVMNT 3: City Comment Letter of October 11, 1999 re: "Draft Focused
Site Inspection Phase II Work Plan, Naval Weapons Station'
PSI Phase n Rep MEQCB Suff Report