Five Year Review
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street Sa n Francisco, CA 941 05-3901 September 30, 2010 Jerry W. Bingham, YD-02 Program Manager/COR AFCEEJEXC 2261 Hughes Ave, Suite 155 Lackland AFB, TX 78236 Re: Final Third Five-Year Review Report fo r Former Norton Air Force Base Dear Mr. Bingham: We have received the Final Third Five-Year Review Report!or Fonner NOrlon Air Force Base, San Bernardino County, California, dated September 2010 (5YR Report). EPA reviewed the 5YR Report along with other supporting documents and concurs with the findings, recommendations, and protectiveness statements of the 5YR Report. We agree that the current remedy for CBA OU Component 1 is prOleclive in the short term since there is no exposure to contaminated groundwater, and in the long term due 10 the presence of institutiona1 controls to prevent use of groundwater as a drinking source. Nonetheless, the 5YR confirms the uncertainty regarding the relationship between long term management of the groundwater table and remaining vadose zone contamination, ifany. As documented in the 5YR and other site reporting, there has been a general decline in groundwater elevation attributed to an extended period of drought and continued production of groundwater for municipal uses. As a result of this decline, monitoring wells that previously had shown contamination above ARARs have gone dry and are no longer able to provide information on remedy effectiveness. We are concerned about the potential that remaini ng vadose zone contamination could be mobilized to groundwater if the groundwater table returns to historic levels at some point in the future. Consequently, we propose that the Air Force. EPA and the State work coll aboratively to develop an approach to resolve any uncertainty about performance of the remedy in addressing long tenn risk associated with this potential pathway. Thank you for the opportuni ty to review this document. [f you have any questions about these issues. do not hesitate to contact Nadia HoUan Burke (415-972-3187). rMichael M. Montgo ery Assistant Director Federal Facilities & Site Cleanup Branch United States Air Force Installation Restoration Program Final Third Five-Year Review Report for Former Norton Air Force Base San Bernardino County, California September 2010 THIS PAGE INTENTIONALLY LEFT BLANK United States Air Force Installation Restoration Program Final Third Five-Year Review Report for Former Norton Air Force Base San Bernardino County, California September 201 0 Prepared by: AECOM Technical Services, Inc. Colton, CA Contract No. FA8903-08-D-8779. Task Order No. 0090 Date: Approved bY(/?~ ~ Ah>< Robert M. Moore Director. Air Force Real Property Agency U.S. Air Force THIS PAGE INTENTIONALLY LEFT BLANK Former Norton AFB THIRD FIVE-YEAR REVIEW Content Checklist Table ES-1. Content Checklist for Five-Year Review Reports, Former Norton AFB Page 1 of 5 Required Item Location in Document General Report Format [ ] Signed concurrence memorandum (as appropriate) Pending [ ] Title page with signature and date Title Page [ ] Completed five-year review summary form After List of Acronyms [ ] List of documents reviewed Section 7 [ ] Site maps See List of Figures [ ] List of tables and figures Table of Contents [ ] Interview report (as appropriate) Appendix B [ ] Site inspection checklist Appendix A [ ] Photos documenting site conditions (as appropriate) Not applicable Introduction [ ] The purpose of the five-year review Section 1.0 [ ] Authority for conducting the five-year review Section 1.0 [ ] Who conducted the five-year review (lead agency) and when Section 1.0 and 4.0 [ ] Organizations providing analyses in support of the review Section 1.0 and 4.0 (e.g., the contractor supporting the lead agency) [ ] Other review participants or support agencies Section 1.0 [ ] Review number (e.g., first, second) Section 1.0 [ ] Trigger action and date Section 1.0 [ ] Number, description, and status of all operable units at the site Section 3.10 [ ] lf review covers only part of a site, explain approach Not applicable [ ] Define which areas are covered in the five-year review Not applicable [ ] Summarize the status of other areas of the site that are not Not applicable covered in the present five-year review Site Chronology [ ] List all important site events and relevant dates (e.g., date of Section 2.0 initial discovery of problem, dates of pre-NPL responses, date Table 2-1 of NPL listing, etc.) Background [ ] General site description (e.g., size, topography, and geology) Sections 3.1 through 3.8 [ ] Former, current, and future land use(s) of the site and Section 3.3 surrounding areas [ ] History of contamination Section 3.9 WP/27-Sep-10/058-10 Page v Former Norton AFB THIRD FIVE-YEAR REVIEW Content Checklist Table ES-1. Content Checklist for Five-Year Review Reports, Former Norton AFB Page 2 of 5 Required Item Location in Document [ ] Initial response (e.g., removals) Section 3.0 [ ] Basis for taking remedial action (RA) (e.g., contaminants) Section 3.0 Remedial Actions (CBA OU and BW OU) [ ] Regulatory actions (e.g., date and description of Records of Section 2.0 Decision (RODs), Explanations of Significant Difference, Administrative Orders on Consent, Consent Decrees and Action Memorandum) [ ] Remedial action objectives (RAOs) Section 4.1 and 4.2 [ ] Remedy description Section 4.1.1, 4.2.1, 4.3.1, 4.4.1, 4.5.1, 4.6.1, 4.7.1, 4.8.1, 4.9.1, 4.10.1 [ ] Remedy implementation (e.g., status, history, enforcement Section 4.1.2, 4.2.2, 4.3.2, 4.4.2, actions, performance) 4.5.2, 4.6.2, 4.7.2, 4.8.2, 4.9.2, 4.10.2 [ ] Systems operations/Operations & Maintenance Section 4.1.3, 4.2.3, 4.3.3, 4.4.3, 4.5.3, 4.6.3, 4.7.3, 4.8.3, 4.9.3, 4.10.3 [ ] Systems operations/O&M requirements Section 4.1.3 and 4.2.3, [ ] Systems operations/O&M operational summary Section 4.2.3 (e.g., history, modifications, problems, and successes) [ ] Summary of costs of system operations/O&M Section 4.2.3 effectiveness (i.e., are requirements being met and are activities effective in maintaining the remedy?) Progress Since Last Five-Year Review (CBA OU and BW OU) [ ] Protectiveness statements from last review Section 4.1.4 [ ] Status of recommendations and follow-up actions from last Section 4.1.4 review [ ] Results of implemented actions, including whether they Section 4.1.4, 4.2.4, 4.3.4, 4.4.4, achieved the intended effect 4.5.4, 4.6.4, 4.7.4, 4.8.4, 4.9.4, 4.10.4 [ ] Status of any other prior issues Section 4.1.4 Five-Year Review Process (CBA OU and BW OU) [ ] Administrative Components Section 4.0 [ ] Notification of potentially interested parties of initiation of Section 4.0 review process [ ] Identification of five-year review team members (as Section 4.0 appropriate) [ ] Outline of components and schedule of your five-year Section 4.0 review WP/27-Sep-10/058-10 Page vi Former Norton AFB THIRD FIVE-YEAR REVIEW Content Checklist Table ES-1. Content Checklist for Five-Year Review Reports, Former Norton AFB Page 3 of 5 Required Item Location in Document [ ] Community Involvement Section 4.0 [ ] Community notification (prior and post review) Section 4.0 [ ] Other community involvement activities (e.g., notices, fact Section 4.0 sheets, etc., as appropriate) [ ] Document review Section 4.0 [ ] Data review Section 4.0 [ ] Site inspection Appendix A [ ] Inspection date Appendix A [ ] Inspection participants Appendix A [ ] Site inspection scope and procedures Appendix A [ ] Site inspection results, conclusions Appendix A [ ] Inspection checklist Appendix A [ ] Interviews Appendix B [ ] Interview date(s) and location(s) Appendix B [ ] Interview participants (name, title, etc.) Appendix B [ ] Interview documentation Appendix B [ ] Interview summary Appendix B Technical Assessment (CBA OU and BW OU) [ ] Answer Question A: Is the remedy functioning as intended by Section 4.1.5, 4.2.5, 4.3.5, the decision documents? 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] RA performance (i.e., is the remedy operating as Section 4.1.5, 4.2.5, 4.3.5, designed?) 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] system operations/O&M Section 4.1.5, 4.2.5, 4.3.5, 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] cost of system operations/O&M not applicable [ ] opportunities for optimization Section 4.1.5, 4.2.5, 4.3.5, 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] early indicators of potential issues Section 4.1.5, 4.2.5, 4.3.5, 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] implementation of institutional controls and other measures Section 4.1.5, 4.2.5, 4.3.5, 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5, 4.10.5 [ ] Answer Question B: Are the exposure assumptions, toxicity Section 4.1.5, 4.2.5, 4.3.5, data, cleanup levels, and RAOs used at the time of the remedy 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, selection still valid? 4.9.5, 4.10.5 WP/27-Sep-10/058-10 Page vii Former Norton AFB THIRD FIVE-YEAR REVIEW Content Checklist Table ES-1.