HomeMy WebLinkAboutItem L February 8, 1999
STAFF REPORT
To: Mayor and Members of the City Council
Attention: Keith R fl, Qty Manger
From: Lee Whittenbag, Director of Developmalt Smvica
Subject: CITY RESPONSE LEITER REt "DRAFT - EXTENDED
REMOVAL SITE EVALUATION REPORT, INSTALLATION
RESTORATION SITES 40 and 70, NAVAL WEAPONS
STATION, SEAL BEACH"
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 signal letter. Receive and File Staff Report.
DISCUSSION
The Department of the Navy is requesting comments on the `DrgR Extended Renewal Site
Evaluation Wont Plan, IR Sites 40 and 70, Naval Weapons Station, Seal Beach" by March 1,
1999.
Thi Extended Removal Site Evaluation (FRSE) presents the findings, conclusions and
recommendations of the ERSE investigation performed at die subject Installation Restoration (IR)
Sites. The ERSE investigation for the subject sites defined the nature and extent of mil and
groundwater contamination; further refined existing geological and hydrogeologi al site models;
evaluated die fate and transport of denials of potential cancan (COPCs) from soil to
groundwater, aid within groundwater, and evaluated soil and groundwater to assess the potential
threat to human health and the environment through screening risk assessments.
AGENDA ITEM L
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Clay Cerra Ste Report
February 8.1999
lie Environmental Quality Control (bard (BQCB) reviewed and discussed this matter at their
January 27, 1999 meeting. A copy of the complete document this provided to the BQCB for the
information of the Board Given some of the ins raised in the document, staff prepared a draft
enmment lens far the inview aid approval of the BQCB and the City Carel. The draft
anent letter is provided as Attachment 1. The comment letter incorporates two minor
Male= recommended by the BQCB, with those redskins being indicated by trilxlhmugh for
iaagnagentrdekted and by bold and italic for 6ngnag,So ha added.
brinitalaulai
In February 1997, the City responded to a request from the Deparonent of the Navy to comment
on the "Pre-Final Extended Rmawl Sire Evafuanon Wolk Plan, IR Sites 40 And 70, Nam:
%gnu Station, Seal Beach"by Mardi 26, 1997.
A copy of that moment Iener is provided as Attachment 3 for the information of the City
Camdl. Responses to the City Comment letter of February 1997 by the Department of the Navy
are provided as Attadunan 4.
rethen r 1lnuiria. of Cnae aid. T n rot A - -
ch
In reviewing the information regarding existing pollutants which exit at IR Sites 40 and 70, the
major cancan of the City is relative to the ICE and WE plumes in groundwater. At IR Site 40
the plume appears to consist of two commingled plumes of differed origins; one located north of
Building 240, in the vicinity of the concrete pit sump discharge, and the other bated west of the
building. PCE concentrations define the vertical and lateral extent of the impacted groundwater.
The ICE plume extends venially to a depth of approximately 66 feet, and laterally
appmxinatdy 250 feet in the north-south direction and 450 fret in the east-west direction (Please
it to Figure IS-1 of the report). TCE mmcamations extend vertically to a depth of
approximately 42 fat, and laterally approximately 250 feet in the north-south direction and 390
feet in the east-west direction.
At IR Sate 70 a chlorinated solvent groundwater plume has been defected beneath the Sc
extending vertically to a depth of approximately 195 feet. Laterally, inclusive of all depth ranges,
the WE plume achieves a maximum north-nab dimension of approximately 2,500 fret, and
2,000 feet in an eau-west direction. The exception as the deep interval of 150-195 fat, where the
plume dimensions are approximately 2,400 feet an a northwest-southeast direction, sed 1,000 feet
from northeast to southwest(Please it to Figure ES-2 of the report).
Dail aME u am 40 a A.nity Carol 2
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Raft 40 a d 70.Abel Weyer Srebi,Sod Bah
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ReLrny 8,1999
EMPOSOLECERanfiela
The Navy is requesting comments on the subject document by Mardi 1, 1999. Staff has prepared
the initial daft of the response letter for consideration by the BQCB and ultimately the City
Counsel, indicating general concerns of the City(See Atadunent 1, indicating revisions approved
by the EQCB).
RECOMMENDATION
Authorize the Mayor to sign the draft response letter, with any additional corn ments determined
appropriate, and instruct staff to forward to the Fnvi,aimental Quality Control Board a Copy of
the signed letter. Receive and File Staff Report.
�/// NOTED AND APPROVED /nf
Ate " � ` ` �jcCtG1
i. Wh iuenberg, Director Keith R. Tib
Development Services Departm t City Manager
ATTACHMENTS: (4)
Atadnment 1: Draft Comment Leiter from EQCB and City Council to Department of
Navy re: "Drq11 Euaded Removal Site animation Report, IR Sites 40 and
70, Navel Wagons Station, Seal Bradt", as revised by the EQCB on
January 27, 1999
Atadimai 2: •Deet lltended Removal Site Evaluation Report. IR Sites 40 and 70,
Naval Weapons Station, Seal Reath*, prepared by Bechtel National, Inc.
for Southwest Division, Naval Facilities Engineering Command, dated
December 1998
Note: Document not provided to City Council due to length, 27 pages. It
is available at the Department of Development Services for review.
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Altxfimmt 3: Comment Letter from BQCB and City Cannel to Department of Navy re:
'Pre-FTnal Emended Removal Site Emareadat Wont Plan, IR Sites 40 and
70, Mawal Weapons Station, Seal Beach% dated February 25, 1998
Amdunan 4: Rewonse b Comment lar from EQCB and City Coatdl b Department
of Navy re: 'Drat Emended Removal Ste Evalaarbn Wont Plan, IR Sites
40 and 70, Navel weapons Station,Seal Beach',dated April 23, 1997.
Dirt ERS4aSibs ionncyc. i 4
Qty Response Letter re:Dnyl Extended Removal Site Evaluation Report,
Q saes 40 and 70,Maul Weapons Station,Seal Bead,
My Coosa Staff Report
February 8,1999
ATTACHMENT 1
Draft Comment Letter from EQCB and City Council to
Department of Navy re: "Draft Extended Removal Site
Evaluation Report, IR Sites 40 and 70, Naval Weapons
Station, Seal Beach", as revised by the EQCB on January
27, 1999
Dud ERSE,It ams 40 a 70.Cily Cased 5
My Ras LS it Theft Eaedd Raraad Sar Erlawtar Report,
R Ste"40 ed A.Navel Weevers Seaton,SS Mach
Qty CsaerB Sour Repot:
February 8.1999
•
February 8, 1999 •
Weapons Support Facility
800 Seal Beach Blvd.
Atm: Robert Robinson, Installation Restoration Coordinator
Seal Beath, CA 907445000
SUBJECT: "Duff Extended Removal Site Evaluation Report, JR Sites 40 and
70, Naval Weapons Station, Seal Beach"
Dear Mr. Robinson: DRAFT
The City of Seal Beach has reviewed the request from the Department of the Navy relative to
"Deep! Extended Remowl Site Evatuadon Report, IR Sires 40 and 70, Abut Weapons Station,
Seal Beach". It should be noted that the City has only reviewed the "Executiw Summary" of the
subject docwn nt, that is the only portion of the document presented to us for review. It appears
that an additional, more detailed document exists, of which the reviewed document is only the
"Executive Summary". The City requests a appy of this document for its information purposes.
Upon a review of the document by the Environmental Quality Control Board and the City Council
of the City of Seal Beach, the City has the following genal and specific comments.
GestraLCummisauttbeiloommol
The Environmental Quality Control Board and the City Council understand this document
provides a summary of the nature, extent and appropriate removal actions for certain identified
dnemicals of potential concern (COPCs) identified during previous site investigations at IR Sites
40 and 70. Upon completion of the characterization of the nature and extent of the contamination
existing at these two sites, appropriate determinations regarding final remediation actions have
been presented in the subject report.
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Febnry 8,1999
The general format of the doauned is helpful to readers in darty indicating the existing
conditions at IR Sites 40 and 70, the reasons for conducting additional analysis at these sites, the
poloods used to achieve the necessary test results, and the decision-making process and an the
at results.
Table ES-1, Recommended Future Actions, is extremely helpful in providing a quick overview
of the recommended removal axions, if required, Sating to the subject sites. This type of
presentation would be helpful in future documents as a way to provide an easily understood
summary of the particular site problan, the recommended action, and the rationale for the
recommended action. DRAFT
The(Sty concurs with the damn:a on an page l3S-iii that IR Site 40 soils are recommended for
no further action. However, the City requests clarification of the determination regarding IR Site
70 soils. It is unclear why AOC 2, AOC 3, and AOC 11 are not recommended for further
evaluation to more precisely estimate the risk through the use of a baseline human health risk
assessment and the 95` percentile upper limit on the arithmetic mean of all measured chemical
concentrations, as is recommended for AOC 4, set forth on page ES-viii. Please refer to
Attachment A for further discussion regarding this concern.
In reviewing the information regarding existing pollutants which exist at IR Sites 40 and 70, the
major concern of the City, as expressed in our comment letter of February 25, 1997 regarding the
"Pre-Final Extended Removal Site Evaluation Work Plan", is relative to the ICE and TCE
plumes in groundwater. In reviewing the discussion regarding these groundwater plumes in the
current document, the proposed further evaluation under the remedial progran is certainly
supported. However, the City is concerned as to the timing of these further evaluations, and
particularly in relation to IR Site 70, feels this evaluation should not be defused to a far distant
doe, ibis cancan exists due the appearance in Figure ES-2 that the TCE concentration plume
achrgy extends off-base axon Seal Bach Boulevard to the northwest and appears to underlie a
small porton of the Pat of Long Beach(POLE)Pond 2 to the southeast. This pond is part of the
wetland cabman activities undertalmn within the base and the pond does have tidal connections
to the Anaheim Bay Wetlands.
The(Sty is pleased to note the response of the Navy to our earlier comm regarding the proposed
protocol for groundwater Investigations being limited to a depth of approximately 80 feet bgs.
The current evaluations, particularly for IR Site 70, extended to a far grate depth,
approximately 195 feet, and the City appreciates the response of the Navy to this concern.
The Environmental Quality Control Board of the City of Seal Beach considered and reviewed the
Draft ERSE Report and an accompanying Staff Report on January 27, 1999, with the City
n.a ERSE.r N1.40 in 70.cay c.aca 7
City Response Luer re:Dealt Extended Removal Site Evaluation Report,
IR Sas 40 and 70,Naval Weapons Station,Seal Bead
Qty Council Sat Report
Ferry 8,1999
Council considering and dimming these same documents and reports on February 8, 1999. Both
the Environmental Quality Control Board and the City Council authorized the respective
Chairman and the Mayor to sign this leper indicating the official comments of the City of Seal
Beach, including the "Formal Staff Comments Regarding the "Draft Emended Removal Site
Evnhtation Report, IR Sites 40 And 70, Naval Weapons Station, Seal Beach" (Attachment A).
Thank you for your consideration of the comments of the City of Seal Beach. Please do not
hesitate to contact Mr. Lee Whitt nberg, Director of Development Services, City Hall, 211
Eighth Street, Seal Beach, 90740, telephone (562) 431-2527 if you have any questions regarding
this matter. In addition, please provide a copy of the Final ERSE Report to Mr. Whittenberg for
City information purposes when it is available.
Sincerely, DRAFT
Paul Yost Donna McGuire, Chairperson
Mayor, City of Seal Beach Environmental Quality Control Board
ATTACHMENT A: 'Formal Staff Comments Regarding the "Drift Emended Removal Site
Evaluation Report, IR Sites 40 and 70, Naval Weapons Station, Seal
Beach"
Distribution: City Council City Manager
Planning Commission Director of Development Services
Environmental Quality Control Board
Archaeological Advisory Committee
Draft ERRE,m Shea 40 a 70.City Carrell 8
(Sty Rapaur rater re:Drgt EvoddRa,owl Site Ewlrlo•Ripon,
R Sites 40 ad 70,Niwl Weapon Soria%Seal Reach
ern'Caordl Sh$R•port
DRAFT February 8,1999
ATTACHMENT A
"Formal Staff Comments Regarding the Dnpt
Extended Removal Site Evaluasat Report, IR Sites 40
and 70, Naval Weapons Station, Seal Beach"
• Page ES-Ill, first full paragraph - the document indicates that "Estimates of blood lead
canantrations for a resident child, resident adult, and industrial adult were also below
benchmark values. Accordingly, no further action is required for human health
considerations." It would be helpful in the Executive Summary Tables to indicate the
bencunark values, and the estimated blood lead concentrations for the appropriate child
and adult classifications. At this time, there is no way to determine the validity of this
statement.
• Page .FS-iv, third paragraph - indicates the impacted groundwater does not presently
serve as a source of water for beneficial uses as set forth in the Water Quality Control
Plan and that the potential for COPCs to eventually impact groundwater beyond the study
area is considered low to moderate, and that a removal action does not appear warranted.
It is farther stated that IR Site 40 groundwater is recommended for further evaluation
under the remedial program. The City requests information as to the timing of this further
evaluation and as to any on-going monitoring of the groundwater at Et Site 40 that will
occur during the interval of time to-what before the remedial program evaluation will
occur. Given the human health cancer risk and the chronic hazard index values, it is
imperative that an on-going monitoring program be in place to as are that groundwater
contamination does not expand and potentially impact an aquifer subject to the Water
Quality Control Plan.
• Page ES-iv - Evaluation of Monitored Natural Attenuation - IR Site 40, indicates a
data analysis evaluating the potential for implementing monitored natural attenuation
(MNA)for groundwater impacted by chlorinated aliphatic hydrocarbons was conducted by
Parson Engineering Science, Inc. The City requests a copy of this report for its
information.
• Page ES-v - AOC 2: Former Storm Water Drainage Channel, indicates VOC
concentrations within the vadose zone soils generally increase with depth and reach the
nM ERSE,n.ails 40&70.c y(:ash 9
arobears Laare:Dn s----JWRarnn!Site&dabs Rywt,
a Sirs 40 tat 70,Naval W- ---Sidon,Seal Lori
ad Clam*AtRepro
?draw 8,1999
maximum ooacmhatioo at the 10$ 12 foot depth range. It would be helpful to indicate
what Nose maxum eataltrations are.
• Page FS-•111, AOC 4: Perimeter Doge Monad, continuing paragraph finm page
ES-vii, Yat sentence states 'Farther evaluation is dterdbir recommended t0 more
predsely estimate the disk through the sae ea basin htmmt health rist atrnsmrnt and
the 95'percentile upper confidence Ong an the addancdc meat Qjall meaared chemical
aonaoamdans at AOC 4." Earlier in this section it is indicated the incremental canoe
risk is 1.1x10` and 1.8x104 for the residential and industrial land use scenarios,
respectively. Hazard indices also were estimated at 11.8 and 0.74 for die residential and
industrial land use, respectively. The discussion regarding AOC 2, AOC 3 and AOC 11
indicates in omental canoe risks and hazard indices similar to those set forth above, but
there is no rerommadation regarding additional "baseline human health risk assessment"
for
these
AOCs.
DRAFT
AOC 2 is determined to have an risks due to COPCs of 4.9x10' and 1.4x10' for
residential and industrial land uses and the hazard indices due to COPCs are estimated at
4.0 and 0.41 for residential and industrial land use scenarios, respectively (page ES-v).
AOC 3 is determined to have cancer risks due to COPCs of 7.6x10` and 1.2x104 for
residential and industrial land uses and the hazard indices due to COPCs are estimated at
2.5 and 0.12 for residential and industrial land use scenarios, respectively (page ES-vi).
AOC 11 is determined to have can risks due to COPCs of 4.1x104 and 6.5x10` for
residential and industrial land uses and the hazard indices due to COPCs are estimated at
3.1 and 0.15 for residential and industrial land use scenarios, respectively(page ES-vi).
It is unclear as to why these other AOCs are not recommended for further analysis.
Please clarify this issue and if appropriate, revise the recommendations to include baseline
human health risk assessments for these AOCs.
• Page ES-Y, third full paragraph - the document indicates that "Estimates of blood lead
concentrations for a resident child, resident adult, and industrial adult were also below
benchmark values. Accordingly, no flit action is required for human health
censidmations." It world be helpful in the Executive Summary Tables to indicate the
benchmark values, and the estimated blood lead mwendatians for the appropriate child
and adult classifications. At this time, there is no way to determine the validity of this
*Manernt.
• Page ESC, last paragraph - indicates the impacted groundwater does not presently serve
as a source of water for beneficial uses as set forth in the Water Quality Control Plan and
that the chlorinated VOCs are not expected to reach the downgradient Navy Well No. 2
red MIS R Ora a 7OCly Cord 10
ab Rrpors Lm re:Dr*Ermdai Reword Ms E- --.'n Mpmr,
R Sas 40 ad 70.Wild weyrr Srslor.Sat Ando
City arra aqfRgar
Parc&1999
for nearly a decade, and that a tanoval action does not appear warranted. It is further
Mated that IR Site 70 poadwater is recommended for further evaluaum arida the
remedial program. The (Sty requests information as to the timing of this further
valuation and as to any on-going mating of the groundwater at IR Site 70 that will
mew during the intaval of time le-when Wore the remedial program evaluation will
occur. Given the human health a.— risk and the chronic herd index values, the
potential impact upon Navy Well No.2 and the Pat of Lang Bach Pond No. 2, it is
imperative that an on-going monitoring program be in place to assure that groundwater
contamination does not expand and potentially impact an aquifer subject to the Water
Quality Control Plan or Pert of Long Beach Pond No. 2.
• Page FS-id, Evahutm of Modtaed Natural Attenuation – 1R Ske 70, indicates a
data analysis evaluating the potahtial for implementing monitored natural attenuation
(MNA)fix groundwater impacted by chlorinated aliphatic hydrocarbons was cc ducted by
Parson Engineering Science, Inc. The DRAFT
reqmsts
a copy of this report for its
infarrotion.
. . . •
xlr SE,RSarasraQlyc.pa II
Qty Response Later re:Drat Emended Removal Site Emission Report,
IR Sive 40 and 70,Navel Weapons Station,Seal Beach
Ery Coandl ate Report
February 8,1999
ATTACHMENT 2
"DRAFT EXTENDED REMOVAL SITE
EVALUATION REPORT, IR SITES 40 AND 70,
NAVAL WEAPONS STATION, SEAL BEACH",
PREPARED BY BECHTEL NATIONAL, INC. FOR
SOUTHWEST DIVISION, NAVAL FACILITIES
ENGINEERING COMMAND, DATED DECEMBER
1998
Note: Document not provided to City Council due to
length, 27 pages. It is available at the Department of
Development Services for review.
a.n rxss,m sr 40 a w.ciycau"dl 12
L79 Response Lester re:Draft Extended Removal Site Evaluation Repot,
R Stet 40 and 70,Naval Weapons Station,Seal Bmrh
Uy Coastal 9e$Repon
February ry 8,1999
ATTACHMENT 3
COMMENT LETTER FROM EQCB AND CITY
COUNCIL TO DEPARTMENT OF NAVY RE:
"PRE-FINAL EXTENDED REMOVAL SITE
EVALUATION WORK PLAN, IR SITES 40 AND 70,
NAVAL WEAPONS STATION, SEAL BEACH",
DATED FEBRUARY 25, 1998
Draft ERSE,Q Sites 40&70.Cay Council 13
*77 I
•
•
February 25, 1997 FILE COPY
Naval Weapons Station
800 Seal Beach Blvd.
Attn:Code 045,Beth Crinigan
Seal Beach, CA 90740-5000
SUBJECT: City of Seal Beach Comments re: "Pre-Final Extended Removal Site
Evaluation Work Plan, IR Sites 40 and 70, Naval Weapons Station,
Seal Beach"
Dear Ms. Crinigan:
The City of Seal Beach has reviewed the request from the Department of the Navy relative to"Pre-
Final Extended Removal Site Evaluation Work Plan, IR Sites 40 and 70, Naval Weapons Station,
Seal Beach".
Upon a review of the document by the Environmental Quality Control Board and the City Council
of the City of Seal Beach,the City has the following general and specific comments.
General Comments on the Document
The Environmental Quality Control Board and the City Council understand this document provides
a detailed work plan to determine the nature, extent and appropriate removal actions for certain
identified chemicals of concern (COCs) identified during previous site investigations at IR Sites 40
and 70. Upon a complete characterization of the nature and extent of the contamination existing at
these two sites, appropriate determinations regarding final remediation actions, if any, will be
presented in a final report scheduled for completion in early 1998.
The general format of the document is helpful to readers in clearly indicating the existing conditions
at IR Sites 40 and 70, the reasons for conducting additional analysis at these sites, the protocol to
achieve the necessary test results, and the decision-making process based on the test results.
C:Hy DowmsntsWAV WPSTRERSE,IR Sites 40&70.City Comment l<ner.doc LW‘02-24.97
RN of Seal Beach Cemmem Letter re:
Pre-Fiwf Extended Removal Site Evaluation Work Plan,
IR Ste:40 and 70,Naval Weapons Station,Seal Beach
February 14,997
Table 4-1, Summary of DQOs for IR Sites 40 and 70, is extremely helpful in providing a quick
overview of the decision making process and investigations which will be undertaken to determine
ultimate removal actions, if required, relating to the subject sites. This type of presentation would
be helpful in future documents as a way to provide an easily understood summary of the particular
site problem, the decisions to be made, the information necessary to make an appropriate decision,
and the procedures to be utilized to achieve the desired information needs.
In reviewing the information regarding existing pollutants which exist at 1R Sites 40 and 70, the
major concern of the City is relative to the PCE and TCE plumes in groundwater. In reviewing the
discussion regarding these groundwater plumes,the proposed sampling locations and sampling plan
appear to provide the appropriate coverage to fully define the lateral and vertical extent of the
plume. The City also concurs with the recommendation to undertake additional step-out sample
collections until the extent of area with elevated PCE and TCE concentrations is defined.
Page 4-158 and Page 4-159, discusses the methodology for determining the extent of the TCE
plume at IR Site 70, indicating the northern boundary of the study area is defined as Seal Beach
Boulevard. The City is concerned that this boundary imposition may result in the full extent of the
TCE plume not being fully investigated. The City strongly insists that the full extent and nature of
the TCE plume at IR Site 70 be fully investigated, even if that involves investigations off of the
Naval Weapons Station Property. The City will cooperate fully in assisting with any analysis which
would be appropriate to undertake on City property, e.g., Seal Beach Boulevard.
In several locations in the document the statement is made that "Time constraints will limit soil
sampling to a single event", and regarding groundwater samples "This process will be repeated to
the top of a component or to a depth of approximately 80 feet bgs." Please provide an explanation
as to what the time constraint is, why it exists, and the impact of having only a single event for soil
sampling. Also what is the significance of limiting the groundwater investigations to a depth of
approximately 80 feet bgs? Do these constraints in some way have the potential to compromise the
results of the testing and result in either understated or overstated findings?
In reviewing all Tables which provide information regarding COCs which exceed identified
significance levels, the highlighting and bolding of that information is extremely helpful to the
general public in quickly having an understanding where the areas of concern are. Please use this
methodology in all Figures and Table in this document and in subsequent documents.
The description of the Transport Modeling Approach is very thorough and allows the general
reader to more fully understand the reasons that certain models are being utilized in the study to
determine transport in groundwater. The discussion of the VLEACH Model and the ATI23D
models were particularly helpful.
2
ERSE,IR Sites 40 It 70,City Comment Isaendoc
City of Seal Beach Comment letter re:
Pre-Final Extended Removal Ste Evaluation Work Plan,
IR Sites 40 and 70,Naval Weapons Station,Seal Beach
February 24, 997
The Environmental Quality Control Board of the City of Seal Beach considered and reviewed the
Pre-Final ERSE and an accompanying Staff Report on February 18, 1997, with the City Council
considering and discussing these same documents and reports on February 24, 1997. Both the
Environmental Quality Control Board and the City Council authorized the respective Chairman and
the Mayor to sign this letter indicating the official comments of the City of Seal Beach, including
the "Formal Staff Comments Regarding the "Pre-Final Extended Removal Site Evaluation Work
Plan,IR Sites 40 And 70,Naval Weapons Station, Seal Beach" (Attachment A).
Thank you for your consideration of the comments of the City of Seal Beach. Please do not hesitate
to contact Mr. Lee Whittenberg, Director of Development Services, City Hall, 211 Eighth Street,
Seal Beach, 90740, telephone (562) 431-2527 if you have any questions regarding this matter. In
addition,please provide a copy of the Final ERSE to Mr. Whittenberg for City information purposes
when it is available.
Sincerely,
,tet (-7/2424,410
Given Forsythe Mario Voce,Chairman
Mayor, City of Seal Beach Environmental Quality Control Board
ATTACHMENT A: "Formal Staff Comments Regarding the "Pre-Final Extended Removal Site
Evaluation Work Plan, IR Sites 40 and 70, Naval Weapons Station, Seal
Beach"
Distribution: City Council City Manager
Planning Commission Director of Development Services
Environmental Quality Control Board
Archaeological Advisory Committee
3
ERSE,IR Sites 40&70,City Comment teaer.doc
City of Seal Beads Comment Leiter re:
Pre-Final Extended Removal Lee Evaluation Work Plan,
LR Sites 40 and 70,Naval Weapons Station,Sea!Beads
February 24,997
ATTACHMENT A
•
"Formal Staff Comments Regarding the Pre-Final
Extended Removal Site Evaluation Work Plan, IR Sites 40
and 70, Naval Weapons Station, Seal Beach"
• The Document references "Summary of Results from the Relative Risk Site Evaluation
Model (RRSEM)Data Collection Effort at Naval Weapons Station, Seal Beach, California",
Bechtel National, Inc.,February 1996. The City does not have a copy of this document and
requests that it be provided to Mr. Lee Whittenberg, Director of Development Services, 211
Eighth Street, Seal Beach, CA 90740.
• Page 4-5, Table 4-1, Summary of DQOs for IR Sites 40 and 70, sets forth distances from
the edges of Building 240 for the initial study boundary areas. Please explain how these
distances were determined.
• Page 4-7,Table 4-1, Summary of DQOs for IR Sites 40 and 70, Inputs to the Decisions,
bullet five, indicates "Information needed to establish applicable regulatory criteria (e.g.,
US EPA Region LKResidentia4" Should this be revised to indicate "Region IX Residential
PRGS"?
• Page 4-39, Figure 4-1, IR Site 40 Site Plan would be more explanatory if an indication of
the land use/pavement treatment in the areas of HydroPunch Sample Location 40-P10, 40-
P11,and 40-P12 was indicated.
• Page 4-61, Subsection 4.2.3.6, second paragraph, second sentence states "Since the •
available scoping information based on previous sampling results and the groundwater data
suggest that the approximately sources in soil are located within IR Site 40, the planned soil
sample locations will be near the potential source areas." The sentence is not clear, and the
word _'approximately_ seems to be the confusing word. Please review and revise as
appropriate.
• Page 4-67, Figure 4-8, Maximum Concentration of VOCs, SVOCs, and Metals Detected in
Groundwater in 1993 -IR Site 40, indicates by italicized printing those results which exceed
US EPA Region TX MCL or Tap Water PRGs. In reviewing the information, it appears that
4
ERSE.IX Situ 40 @ 70.City Comment Leaer.d«
City of Sed Reach Comment Letter re:
Pre-Find Extended Removal Site Evaluation Work Plan,
IR Sas 40 and 70,Naval Weapons Station,Seal Beach
February 24, 997
the PCE levels at 40MW-01 and 40MW-02 exceed the MCL and should be italicized.
Please review and confirm, or revise as appropriate.
• Page 4-71, Figure 4-9, PCE& TCE Concentration Map -IR Site 40, does not indicate the
TCE Concentration found at Monitoring Sample Location 40-P05. Please provide
appropriate concentration number. Also, it would be helpful to indicate the PCE and TCE
values which exceed MCL concentration by either italicizing or bolding those results, as has
been done on other Figures.
• Page 4-33, Table 441, SVOCs, Pesticides and PCBs Detected in Soil During the RRSEM
Investigation, indicates certain analytes by bold text which exceed the US EPA Region IX
Residential Soil PRGs. It would be helpful if another column was added to the Table
indicating EPA Residential Soil PRGs levels.
• Appendix A, Statistical Analysis and Geochemical Assessment of Soils, Page A-1,
Section Al,. Statistical Analysis, indicates that for the metals antimony, barium, cobalt,
silver and thallium, stationwide background levels have not been determined. The
document goes on to say that stationwide background levels of these metals will be
determined using existing data from IR Site 70. We seriously question the adequacy of
using data from one IR Site to determine the entire station-wide background levels of
these particular metals.
• Appendix A, Page A-11, Section A.2.6, Lead, second sentence does not provide the
stationwide background level number determined appropriate. Please revise and provide the
determined numerical value.
• Appendix A, Page A-15, Section A.2.10, Zinc, does not provide the stationwide
background level number determined appropriate. Please provide the determined numerical
value.
• • • •
5
ERSE,IR Sites 40&70,City Comment t.eaa.doc
pry Response Later re:Drat Extended Rewwl Six Embalm Report,
IR Sifter 40 ad 70,Naval Weapons Sado,Seal Beach
Qry Cowell SafRepare
February 8,1999
ATTACHMENT 4
RESPONSE TO COMMENT LETTER FROM EQCB
AND CITY COUNCIL TO DEPARTMENT OF
NAVY RE: "DRAFT EXTENDED REMOVAL SITE
EVALUATION WORK PLAN, IR SITES 40 AND 70,
NAVAL WEAPONS STATION, SEAL BEACH",
DATED APRIL 23, 1997
Drdl ERSE,IR Sils 40 a 70.Cirycaunil 14
4,4T o.A:
DEPARTMENT OF THE NAVY
4 Y NAVAL WEAPONS STATION
I; " BOO SEAL BEACH BLVD
.�f4.�• SEAL BEACH.0 907405000
per.
' W PEECP TO
_ 5090
- -- Ser 045/040418
I _. - - April 23, 1997
Mr. Lee Whittenberg • APR 2 81997
City of Seal Beach
211 Eighth Street
Seal Beach CA 90740 L-`-_ _ _- . . . __
Dear Mr. Whittenberg:
Enclosed for your review and concurrence is a copy of the
responses to agency comments on the Pre-Final Extended Removal
Site Evaluation Work Plan for Installation Restoration (IR)
Sites 40 and 70, Naval Weapons Station Seal Beach. Please send
your written concurrence with our responses within fourteen days
of receipt of this letter to the following address.
Naval Weapons Station
800 Seal Beach Blvd.
Attn: Code 045, Beth Crinigan
Seal Beach CA 90740-5000
A comment-resolution meeting has been scheduled for April 30, 1997
at Bechtel' s Offices in Norwalk to facilitate the review process
and resolve all outstanding comments on the Pre-Final Work Plan.
The Final Work Plan will be issued following satisfactory
resolution of the comments.
My point of contact is Beth Crinigan (Installation Restoration
Program Manager) , (562) 626-7608.
Sincere
DAVID BAILLIE
Environmental Director
By direction of
the Commanding Officer
Encl:
(1) Response to Comments, Pre-Final Extended Removal Site
Evaluation Work Plan, IR Sites 40 and 70
Copy to:
Mario Voce
211 Eighth Street
Seal Beach CA 90740
RESPONSE TO CITY OF SEAL BEACH COMMENTS
(COMMENTS BY: MARIO VOCE)
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CITY HAII • 211 EIGHTH $IREH
SLAT BEACH CALIFORNIA 90740 6319
15621 A31 2527
February 8, 1999
Weapons Support Facility
800 Seal Beach Blvd.
Atm: Robert Robinson, Installation Restoration Coordinator
Seal Beach, CA 90740-5000
SUBJECT: "Draft Extended Removal Site Evaluation Report, IR Sites 40
and 70, Naval Weapons Station, Seal Beach"
Dear Mr. Robinson:
The City of Seal Beach has reviewed the request from the Department of the Nary relative
to "Draft Extended Removal Site Evaluation Report, IR Sites 40 and 70, Naval Weapons
Station, Seal Beach". It should be noted that the City has only reviewed the "Executive
Summary" of the subject document, that is the only portion of the document presented to
us for review. It appears that an additional, more detailed document exists, of which the
reviewed document is only the "Executive Summary". The City requests a copy of this
document for its information purposes.
Upon a review of the document by the Environmental Quality Control Board and the City
Council of the City of Seal Beach, the City has the following general and specific
comments.
General Comments on the Document
The Environmental Quality Control Board and the City Council understand this document
provides a summary of the nature, extent and appropriate removal actions for certain
identified chemicals of potential concern (COPCs) identified during previous site
investigations at IR Sites 40 and 70. Upon completion of the characterization of the nature
and extent of the contamination existing at these two sites, appropriate determinations
regarding final remediation actions have been presented in the subject report.
C:VAy Documa bWAV WPSTA\Dna ERSE,IR Sites 40 A',Wily Council Leaa.doc\LW002-08-99
City of Seal Beach Comment Letter re:
"Draft Extended Removal Site Evaluation,
IR Sites 40& 70,Naval Weapon Station,Seal Beach"
Febnmry8, 1999
The general format of the document is helpful to readers in clearly indicating the existing
conditions at IR Sites 40 and 70, the reasons for conducting additional analysis at these
sites, the protocols used to achieve the nereccary test results, and the decision-making
process based on the test results.
Table ES-1, Recommended Future Actions, is extremely helpful in providing a quick
overview of the recommended removal actions, if required, relating to the subject sites.
This type of presentation would be helpful in future documents as a way to provide an
easily understood summary of the particular site problem, the recommended action, and
the rationale for the recommended action.
The City concurs with the determination on page ES-iii that IR Site 40 soils are
recommended for no further action. However, the City requests clarification of the
determination regarding IR Site 70 soils. It is unclear why AOC 2, AOC 3, and AOC 11
are not recommended for further evaluation to more precisely estimate the risk through the
use of a baseline human health risk assessment and the 95" percentile upper limit on the
arithmetic mean of all measured chemical concentrations, as is recommended for AOC 4,
set forth on page ES-viii. Please refer to Attachment A for further discussion regarding
this concern.
In reviewing the information regarding existing pollutants which exist at IR Sites 40 and
70, the major concern of the City, as expressed in our comment letter of February 25,
1997 regarding the "Pre-Final Extended Removal Site Evaluation Work Plan", is relative
to the PCE and TCE plumes in groundwater. In reviewing the discussion regarding these
groundwater plumes in the current document, the proposed further evaluation under the
remedial program is certainly supported. However, the City is concerned as to the timing
of these further evaluations, and particularly in relation to IR Site 70, feels this evaluation
should not be deferred to a far distant date. This concern exists due the appearance in
Figure ES-2 that the TCE concentration plume actually extends off-base across Seal Beach
Boulevard to the northwest and appears to underlie a small portion of the Port of Long
Beach (POLB) Pond 2 to the southeast. This pond is part of the wetland restoration
activities undertaken within the base and the pond does have tidal connections to the
Anaheim Bay Wetlands.
The City is pleased to note the response of the Navy to our earlier concern regarding the
proposed protocol for groundwater investigations being limited to a depth of
approximately 80 feet bgs. The current evaluations, particularly for IR Site 70, extended
to a far greater depth, approximately 195 feet, and the City appreciates the response of the
Navy to this concern.
The Environmental Quality Control Board of the City of Seal Beach considered and
reviewed the Draft ERSE Report and an accompanying Staff Report on January 27, 1999,
with the City Council considering and discussing these same documents and reports on
OM ERSE,IR Sites 40170.City Council Letter 2
City of Seal Beach Comment Letter re:
"Draft Extended Removal Site Evaluation,
• IR Sites 40& 70,Naval Weapons Station,Seal Beach"
February 8, 1999
February 8, 1999. Both the Environmental Quality Control Board and the City Council
authorized the respective Chairman and the Mayor to sign this letter indicating the official
comments of the City of Seal Beach, including the "Formal Staff Comments Regarding the
"Draft Extended Removal Site Evaluation Report, IR Sites 40 And 70, Naval Weapons
Station, Seal Beach" (Attachment A).
Thank you for your consideration of the comments of the City of Seal Beach. Please do
not hesitate to contact Mr. Lee Whittenberg, Director of Development Services, City Hall,
211 Eighth Street, Seal Beach, 90740, telephone (562) 431-2527 if you have any questions
regarding this matter. In addition, please provide a copy of the Final ERSE Report to Mr.
Whittenberg for City information purposes when it is available.
Sincerely, nnAAe inw
Paul Yost Donna McGuire, Chairperson
Mayor, City of Seal Beach Environmental Quality Control Board
ATTACHMENT A: "Formal Staff Comments Regarding the "Draft Extended Removal
Site Evaluation Report, /R Sites 40 and 70, Naval Weapons Station,
Seal Beach"
Distribution: City Council City Manager
Planning Commission Director of Development Services
Environmental Quality Control Board
Archaeological Advisory Committee
Draft ERSE,IR Sites 40&70.City Council Letter 3
City of Seal Beach Comment Letter re:
"Dmfl Extended Removal Site Evaluation,
IR Sites 40& 70,Naval Weapons Station,Seal Beach"
February8, 1999
ATTACHMENT A
"Formal Staff Comments Regarding the Draft
Extended Removal Site Evaluation Report, IR Sites
40 and 70, Naval Weapons Station, Seal Beach"
• Page ES-iii, first full paragraph - the document indicates that "Estimates of blood
lead concentrations for a resident child, resident adult, and industrial adult were
also below benchmark values. Accordingly, no further action is required for
human health considerations." It would be helpful in the Executive Summary
Tables to indicate the benchmark values, and the estimated blood lead
concentrations for the appropriate child and adult classifications. At this time,
there is no way to determine the validity of this statement.
• Page ES-iv, third paragraph - indicates the impacted groundwater does not
presently serve as a source of water for beneficial uses as set forth in the Water
Quality Control Plan and that the potential for COPCs to eventually impact
groundwater beyond the study area is considered low to moderate, and that a
removal action does not appear warranted. It is further stated that IR Site 40
groundwater is recommended for further evaluation under the remedial program.
The City requests information as to the timing of this further evaluation and as to
any on-going monitoring of the groundwater at IR Site 40 that will occur during
the interval of time before the remedial program evaluation will occur. Given the
human health cancer risk and the chronic hazard index values, it is imperative that
an on-going monitoring program be in place to assure that groundwater
contamination does not expand and potentially impact an aquifer subject to the
Water Quality Control Plan.
• Page ES-iv - Evaluation of Monitored Natural Attenuation - IR Site 40,
indicates a data analysis evaluating the potential for implementing monitored
natural attenuation (MNA) for groundwater impacted by chlorinated aliphatic
hydrocarbons was conducted by Parson Engineering Science, Inc. The City
requests a copy of this repo for its information.
• Page ES-v - AOC 2: Former Storm Water Drainage Channel, indicates VOC
concentrations within the vadose zone soils generally increase with depth and reach
the maximum concentration at the 10 to 12 foot depth range. It would be helpful
to indicate what those maximum concentrations are.
Oran ERSE,IR Sites 40&70.City Council Letter 4
•
Ci y cfSeal Beach Comment Letter re:
"Drs Extended Removal Site Evaluation,
IR Sites 40&70,Naval Weapons Station,Seal Beach"
February 8, 1999
• Page FSviu, AOC 4: Perimeter Drainage Channel, continuing paragraph from
page ES-vii, last sentence states "Further evaluation is therefore recommended to
more precisely estimate the risk through the use of a baseline human health risk
assessment and the 95^percentile upper confidence limit on the arithmetic mean of
all measured chemical concentrations at AOC 4." Earlier in this section it is
indicated the incremental cancer risk is 1.1x10'and 1.8x104 for the residential and
industrial land use scenarios, respectively. Hazard indices also were estimated at
11.8 and 0.74 for the residential and industrial land use, respectively. The
discussion regarding AOC 2, AOC 3 and AOC 11 indicates incremental cancer
risks and hazard indices similar to those set forth above, but there is no
recommendation regarding additional "baseline human health risk assessment" for
these AOCs.
AOC 2 is determined to have cancer risks due to COPCs of 4.9x10' and 1.4x105
for residential and industrial land uses and the hazard indices due to COPCs are
estimated at 4.0 and 0.41 for residential and industrial land use scenarios,
respectively (page ES-v). AOC 3 is determined to have cancer risks due to COPCs
of 7.6x106 and 1.2x10" for residential and industrial land uses and the hazard
indices due to COPCs are estimated at 2.5 and 0.12 for residential and industrial
land use scenarios, respectively (page ES-vi). AOC 11 is determined to have
cancer risks due to COPCs of 4.1x105 and 6.5x106 for residential and industrial
land uses and the hazard indices due to COPCs are estimated at 3.1 and 0.15 for
residential and industrial land use scenarios, respectively (page ES-vi).
It is unclear as to why these other AOCs are not recommended for further
analysis. Please clarify this issue and if appropriate, revise the recommendations
to include baseline human health risk assessments for these AOCs.
• Page ES-k, third full paragraph - the document indicates that "Estimates of blood
lead concentrations for a resident child, resident adult, and industrial adult were
also below benchmark values. Accordingly, no further action is required for
human health considerations." It would be helpful in the Executive Summary
Tables to indicate the benchmark values, and the estimated blood lead
concentrations for the appropriate child and adult classifications. At this time,
there is no way to determine the validity of this statement.
• Page ES-x, last paragraph - indicates the impacted groundwater does not presently
serve as a source of water for beneficial uses as set forth in the Water Quality
Control Plan and that the chlorinated VOCs are not expected to reach the
downgradient Navy Well No. 2 for nearly a decade, and that a removal action
does not appear warranted. It is further stated that IR Site 70 groundwater is
recommended for further evaluation under the remedial program. The City
requests information as to the timing of this further evaluation and as to any on-
Dna ERSE,IR Sites 40 R 70.City Council Lena 5
City of Seal Beach Comment Letter re:
'
"On*Extended Removal Site Evaluation,
IR Sites 40&70,Mont Weapons Station,Seal Beach"
Febeaary8, 1999
going monitoring of the groundwater at IR Site 70 that will occur during the
interval of time before the remedial program evaluation will occur. Given the
human health cancer risk and the chronic hazard index values, the potential impact
upon Navy Well No.2 and the Port of Long Beach Pond No. 2, it is imperative
that an on-going monitoring program be in place to assure that groundwater
contamination does not expand and potentially impact an aquifer subject to the
Water Quality Control Plan or Port of Long Beach Pond No. 2.
• Page ES-xi, Evaluation of Monitored Natural Attenuation IR Site 70,
indicates a data analysis evaluating the potential for implementing monitored
natural attenuation (MNA) for groundwater impacted by chlorinated aliphatic
hydrocarbons was conducted by Parson Engineering Science, Inc. The City
requests a copy of this report for its information.
• • •
Draft ERSE,IR Sites 40&70.City Council Letter 6