5Th 5-Year Review Rpt, Former 915 Deguigne Dr, W/Appendices A-D
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SEMS-RM DOCID # 100016970 www.haleyaldrich.com ~ ~ ICH FIFTH FIVE‐YEAR REVIEW REPORT FORMER 915 DEGUIGNE DRIVE SUNNYVALE, CALIFORNIA by Haley & Aldrich, Inc. Oakland, California for Advanced Micro Devices, Inc. Austin, Texas File No. 127839‐004 January 2019 Haley & Aldrich, Inc. 1956 Webster Street Suite 300 ~ ~ ICH Oakland, CA 94612 510.879.4544 29 January 2019 File No. 127839‐004 California Regional Water Quality Control Board San Francisco Bay Region 1515 Clay Street, Suite 1400 Oakland, California 94612 Attention: Mr. Ron Goloubow, P.G. Subject: Fifth Five‐Year Review Report Former 915 DeGuigne Drive Sunnyvale, California Dear Mr. Goloubow: Please find enclosed the Fifth Five‐Year Review Report prepared by Haley & Aldrich, Inc. on behalf of Advanced Micro Devices, Inc. (AMD) for the former AMD facility located at 915 DeGuigne Drive in Sunnyvale, California. This five‐year report has been prepared to address a requirement of the Site Cleanup Order (91‐101) issued by the California Regional Water Quality Control Board – San Francisco Bay Region. Please feel free to call the undersigned if you have questions regarding this report. Sincerely yours, HALEY & ALDRICH, INC Michael Calhoun, P.G., C.H.G. Peter Bennett, P.G., C.H.G. Senior Project Manager Principal Hydrogeologist CA P.G. #8525, CA C.H.G. #976 CA P.G. #7902, CA C.H.G. #921 c: Advanced Micro Devices, Inc.; Attn: Ms. Heather O’Cleirigh City of Sunnyvale; Attn: Mr. Ron Staricha Santa Clara Valley Water District; Attn: Mr. George Cook United States Environmental Protection Agency; Attn: Ms. Melanie Morash www.haleyaldrich.com Table of Contents Page List of Tables iii List of Figures iii List of Acronyms and Abbreviations iv 1. Introduction 1 1.1 REGULATORY ORDERS 1 1.2 PURPOSE OF THIS REPORT 1 1.3 ISSUES RAISED IN THE 2014 EPA 5‐YEAR REVIEW 2 2. Site Background 4 2.1 SITE HISTORY AND CHEMICAL USE 4 2.2 NEARBY OFF‐SITE VOC RELEASE SITES 5 2.3 HYDROGEOLOGIC CONDITIONS 5 2.4 DISTRIBUTION OF COCS IN GROUNDWATER 6 2.5 GROUNDWATER EXTRACTION AND TREATMENT 7 3. Progress Since Last Review 8 3.1 GROUNDWATER MONITORING PROGRAM 8 3.2 GROUNDWATER EXTRACTION AND TREATMENT SYSTEM 8 3.3 CONFIRMATION GROUNDWATER SAMPLING WITHIN FORMER PAD C EXCAVATION AREA 9 3.4 VAPOR INTRUSION EVALUATION 9 3.5 WORK COMPLETED BY OTHERS 10 3.5.1 Soil Excavation in the Former Pad IV Area and Northern Basement Edge 10 3.5.2 Soil Excavation Near Former PG&E Substation 11 3.5.3 Organochlorine Pesticide Soil Excavation 12 3.5.4 GETS Relocation and Well Replacement Activities 12 3.5.5 Vapor Intrusion Mitigation 13 4. Remedial System Performance and Effectiveness 14 4.1 REMEDIAL OBJECTIVES 14 4.2 SOIL 14 4.3 GROUNDWATER 15 4.3.1 Evaluation of Hydraulic Containment 15 4.3.2 Concentration Trends 16 4.3.3 Concentrations in the PAD C Excavation Area 18 4.3.4 Extraction Mass Removal and Efficiency 18 4.4 VAPOR INTRUSION 19 4.5 INSTITUTIONAL CONTROLS 19 4.6 COST EVALUATION 19 i ~~ICH Table of Contents Page 5. Conclusions and Recommendations 21 6. References 23 TABLES FIGURES APPENDIX A – Historical Water Level Data APPENDIX B – Historical TCE, cDCE, and Total VOC Concentrations APPENDIX C – Concentrations Trends from 2014 Five‐Year Review Report APPENDIX D – Title Search and Deed Restriction ii ~~ICH List of Tables Table No. Title 1 Site Chronology 2 Summary of Groundwater Monitoring Data, 2014 through 2018 3 Status of Chemicals Removed Through 2018 4 Groundwater Extraction and Treatment System Efficiency and Cost Analysis List of Figures Figure No. Title 1 Site Location Map 2 Site Plan and Vicinity 3 Former Pad C Area Excavation 4 A‐Zone Water Levels, October 2018 5 B1‐Zone Water Levels, October 2018 6 B2‐Zone Water Levels, October 2018 7 Concentration Trends for A‐Zone Monitoring Wells 8 Concentration Trends for B1‐Zone Monitoring Wells 9 Concentration Trends for B2‐Zone Monitoring Wells 10 Mass Removal Efficiency, 1997 – 2018 iii ~~ICH List of Acronyms and Abbreviations Acronym Description 5YR Five‐Year Review AMD Advanced Micro Devices, Inc. AMEC AMEC Geomatrix, Inc. ANS acid neutralization system bgs below ground surface cDCE cis‐1,2‐dichloroethene COCs chemicals of concern EPA United States Environmental Protection Agency EPA 5‐Year Review EPA’s Five‐Year Review Report ES Engineering Science ESL Environmental Screening Level FFS Focused Feasibility Study GAC granular activated carbon Geomatrix Geomatrix Consultants, Inc. GETS groundwater extraction and treatment system gpm gallons per minute Haley & Aldrich Haley & Aldrich, Inc. HVAC heating, ventilation, and air conditioning LandSea LS‐Sunnyvale, LLC MCL Maximum Contaminant Level MDL laboratory method detection limit NPDES National Pollutant Discharge Elimination System OOU Companies’ Offsite Operable Unit PG&E Pacific Gas and Electric Company Philips Philips Semiconductors RL laboratory reporting limit ROD Record of Decision Site Former AMD Facility Located at 915 DeGuigne Drive SMP Soil Management Plan Stantec Stantec Consulting Services, Inc. iv ~~ICH Taylor Morrison Taylor Morrison of California, LLC TCE trichloroethene TPHd total petroleum hydrocarbons in the diesel range the Order Site Cleanup Requirements Order Number 91‐101 TRW Former TRW Microwave USTs underground vaulted and un‐vaulted storage tanks VIM system vapor intrusion mitigation system VISL Vapor Intrusion Screening Level VMP Vapor Mitigation Plan VOCs volatile organic compounds Water Board California Regional Water Quality Control Board, San Francisco Bay Region Watt Watt Investments at Sunnyvale, LLC µg/L micrograms per liter v ~~ICH 1. Introduction On behalf of Advanced Micro Devices, Inc. (AMD), Haley & Aldrich, Inc. (Haley & Aldrich) has prepared this Fifth Five‐Year Review (5YR) Report for the former AMD facility located at 915 DeGuigne Drive, in Sunnyvale, California (the Site; Figure 1). This 5YR Report, covering the reporting period of 2014 through 2018, is submitted in response to Task 7 of Site Cleanup Requirements Order No. 91‐101 (the Order) issued by the California Regional Water Quality Control Board, San Francisco Bay Region (Water Board). The four previous 5YR Reports for the Site were submitted to the Water Board on behalf of AMD in June 1996, June 2001, December 2008, and January 2014. The Water Board, on behalf of the United States Environmental Protection Agency (EPA), Region 9, submitted its previous 5YR for the Site in September 2014 (EPA 5YR; EPA, 2014) based on AMD’s Fourth Five‐Year Review Report, submitted in 2014 (Haley & Aldrich, 2014a). 1.1 REGULATORY ORDERS The Site was added to the National Priorities List in September 1990, and a Record of Decision (ROD) was issued by the EPA in August 1991 (EPA, 1991). The Site is currently regulated under the Order issued in June 1991 by the Water Board (Water Board, 1991). The Water Board is the lead regulatory oversight agency for the Site pursuant to the South Bay Multi‐Site Cooperative Agreement and the South Bay Groundwater Contamination Enforcement Agreement, established on 2 May 1985 by the Water Board, the Department of Health Services, and the EPA. The Order documents the cleanup goals for Site groundwater and designates groundwater extraction and treatment as the final remedy for the Site. During this 5YR period, treated groundwater was discharged to an on‐Site storm drain under Water Board Order No. R2‐2012‐0012 and National Pollutant Discharge Elimination System (NPDES) Permit No. CAG912002. A new Water Board Order No. R2‐2017‐ 0048 replaced Order No. R2‐2012‐0012 and became effective on 1 January 2019. 1.2 PURPOSE OF THIS REPORT The purpose of the 5YR is to determine whether the remedy at the Site is, and will continue to be, protective of human health and the environment (EPA, 2014). This Fifth 5YR Report assesses the effectiveness and efficiency of the ongoing remediation program over the past 5 years, and addresses issues raised in the previous EPA 5YR. This report is organized into five sections, as described below: Section 1 – Introduction; Section 2 – Site Background: this section includes a Site description and history and summarizes the Site’s hydrogeology and current environmental conditions, distribution of chemicals of concern (COCs) in groundwater, and current remedial alternative; Section 3 – Progress Since Last Review: this section describes the groundwater monitoring program, groundwater extraction and treatment system (GETS), vapor intrusion evaluation, and work performed by others; 1 ~~ICH Section 4 – Remedial System Performance and Effectiveness: this section summarizes remedial objectives, evaluates the conditions of Site soil and groundwater, and summarizes a vapor intrusion evaluation, institutional controls, and Site cleanup costs; Section 5 – Conclusions and Recommendation: this section summarizes the findings from the 5YR and provides recommendations for remedial activities for the next 5‐year period. 1.3 ISSUES RAISED IN THE 2014 EPA 5‐YEAR REVIEW The three issues and recommended follow‐up actions were presented in the 2014 EPA 5YR: Issue #1: The groundwater extraction and treatment system may not be able to restore the groundwater to its beneficial use as a potential source of drinking water due to VOCs from upgradient (off‐site) sites migrating onto the AMD 915 Site. Recommendation and Follow‐up Action: Establish a broader strategy for groundwater restoration for the AMD 915 upgradient sites. Issue #2: California Civil Code section 1471 has changed since the restrictive covenant was recorded. Recommendation and Follow‐up Action: A new restrictive covenant that complies with California Civil Code section 1471 should be recorded. Issue #3: A State MCL [Maximum Contaminant Level] for hexavalent chromium has recently been established and the MCLs for chloroform, ethylbenzene and 1,2,4‐trichlorobenzene has changed. Recommendation and Follow‐up Action: An Explanation of Significant Differences should be issued to set new cleanup goals for the chemicals considering the new MCLs.