FIVE YEAR REVIEW · 2 five-year review sites and operable units appendix a response to comments on the draft five-year review report, first five-year review report for fort ord superfund

Draft Final Five-Year Review ReportFirst Five-Year Review Report ForFort Ord Superfund SiteMonterey, California

August 23, 2002

Department of the ArmyU.S. Army Corps of Engineers, Sacramento District1325 J StreetSacramento, California 95814-2922

s&'*Eo UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

75 Hawthorne Street San Francisco, CA 941 05

SEP 2 0 2002

Department of the Army Defense Language Institute Foreign Language Center and Presidio of Monterey Director, Environmental and Natural Resources Management Attn: Jim Willison P.O. Box 5004 Presidio of Monterey, California 93944-5004

Re: Draft Final Five-Year Review Report, First Five-Year Review Report For Fort Ord Supe$und Site, Monterey, California, August 23,2002

Dear Mr. Willison:

The U.S. Environmental Protection Agency Region 9 (EPA) has reviewed the Draji Firzul Five-Year Review Report, First Five-Year Review Report For Fort Ord Superfund Site, Monterey, California, dated August 23, 2002. This document addresses completed and ongoing remedial actions taken pursuant to a number of Record of Decisions at the Fort Ord Superfund Site, as identified in the Report. EPA agrees with the findings, conclusions, and recommendations provided in the Report, and concurs with the Army that the remedies for groundwater and soil remain protective of human health and the environment at the former Fort Ord.

We appreciate the opportunity to work with you on this project and look forward to continued success at the former Fort Ord. If you have any questions, please contact John Chesnutt, Remedial Project Manager, at (415) 972-3005.

Sincerely,

Deborah ~ o r d a l Chief, Federal Facility and Site Cleanup Branch Superfund Division

cc: Tony Landis, DTSC Grant Himebaugh, RWQCB

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army iiAugust 23, 2002

CONTENTS

ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii

FIVE-YEAR REVIEW SUMMARY FORM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Five-Year Review Report Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2.0 SITE CHRONOLOGY TABLE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.0 FORT ORD BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.1 Physical Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53.1.1 History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.2 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53.2.1 Developed Land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53.2.2 Undeveloped Land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.2.3 Transferred Land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.3 History of Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73.4 Initial Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73.5 Basis for Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4.0 FIVE-YEAR REVIEW PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.1 Administrative Component . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84.2 Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84.3 Data Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84.4 Site Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.4.1 OU 2 Landfill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84.4.2 RI Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84.4.3 Site 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4.5 Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.0 OU 1 ROD FRITZSCHE ARMY AIRFIELD FIRE DRILL AREA . . . . . . . . . . . . . . . . . . . 10

5.1 OU 1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.3 Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115.3.1 Question A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115.3.2 Question B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125.3.3 Question C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.4 Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125.5 Recommendations and Follow-Up Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135.6 Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

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6.0 OU 2 ROD – FORT ORD LANDFILLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

6.1 OU 2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14




7.0 BASEWIDE REMEDIAL INVESTIGATION SITES ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

7.1 Sites 2/12 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 207.1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

7.1.1.1 Site 2 – Main Garrison Sewage Treatment Plant (MGSTP) . . . . . . . 207.1.1.2 Site 12 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

7.1.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 217.1.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227.1.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 237.1.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . 25

7.1.3 Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 257.1.3.1 Question A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 257.1.3.2 Question B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 267.1.3.3 Question C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

7.1.4 Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 267.1.5 Recommendations and Follow-Up Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . 267.1.6 Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

7.2 Sites 16 and 17 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 277.2.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 277.2.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

7.2.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 297.2.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 297.2.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . 29



7.3 Site 31 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 307.3.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 307.3.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

7.3.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 317.3.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

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7.3.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . 327.3.3 Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

7.3.3.1 Question A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 327.3.3.2 Question B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 327.3.4.3 Question C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32


7.4 Site 39 (Includes Sites 5 and 9) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 337.4.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 337.4.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33




7.5 Surface Water Outfalls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 367.5.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 367.5.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36




7.6 Site 25 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 377.6.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 377.6.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38




7.7 Site 33 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397.7.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army vAugust 23, 2002

7.7.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397.7.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397.7.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397.7.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . 39



8.0 SITE 3 INTERIM ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

8.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 418.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

8.2.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 418.2.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 428.2.3 System Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42



9.0 NO ACTION SITES ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

9.1 No Action Sites Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 449.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44


9.3 Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 469.3.1 Question A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 469.3.2 Question B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

9.3.2.1 Changes in Standards To Be Considered . . . . . . . . . . . . . . . . . . . . . 479.3.3 Question C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47


10.0 INTERIM ACTION SITES ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

10.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4810.2 Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48


10.3 Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5310.3.1 Question A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army viAugust 23, 2002

10.3.2 Question B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5310.3.2.1 Changes in Standards To Be Considered . . . . . . . . . . . . . . . . . . . . . 53

10.3.3 Question C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5310.4 Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5310.5 Recommendations and Follow-Up Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5310.6 Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

11.0 STATUS OF OTHER INVESTIGATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

11.1 Carbon Tetrachloride Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5411.1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5411.1.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

11.2 Monterey Bay Enhanced Preliminary Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5511.2.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5511.2.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

11.3 East Garrison Magnetic Anomalies Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5611.3.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5611.3.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

11.4 Fritzsche Army Airfield (FAAF) Three Sites Investigation . . . . . . . . . . . . . . . . . . . . . 5611.4.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5611.4.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

11.5 Freon 113 Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5711.5.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5711.5.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

11.6 Fort Ord Soil Treatment Area (FOSTA)/ Underground Storage Tank RemediationArea (USRA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5711.6.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

11.6.1.1 Fort Ord Soil Treatment Area (FOSTA) . . . . . . . . . . . . . . . . . . . . . 5711.6.1.2 Underground Storage Tank Remediation Area (USRA) . . . . . . . . . 58

11.6.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5811.6.2.1 Fort Ord Soil Treatment Area (FOSTA) . . . . . . . . . . . . . . . . . . . . . 5811.6.2.2 Underground Storage Tank Remediation Area (USRA) . . . . . . . . . 58

11.7 Resource Conservation and Recovery (RCRA) Closures . . . . . . . . . . . . . . . . . . . . . . . 5811.7.1 Defense Reutilization and Marketing Office (DRMO) . . . . . . . . . . . . . . . . . . . 5811.7.2 Silver Recovery Unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5911.7.3 Building T-111 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5911.7.4 Range 36A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6011.7.5 Solid Waste Management Units (SWMUs) . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

11.8 Ordnance and Explosives Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6111.8.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6111.8.2 Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

12.0 NEXT FIVE-YEAR REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

13.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army viiAugust 23, 2002

TABLES

Site Chronology Table (Section 2.0)

PLATES

1 Fort Ord Location Map2 Five-Year Review Sites and Operable Units

APPENDIX

A RESPONSE TO COMMENTS ON THE DRAFT FIVE-YEAR REVIEW REPORT, FIRSTFIVE-YEAR REVIEW REPORT FOR FORT ORD SUPERFUND SITE, MONTEREY,CALIFORNIA DATED FEBRUARY 27, 2002

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army viiiAugust 23, 2002

ACRONYMS AND ABBREVIATIONS

AAFES Army and Air Force Exchange ServiceACL Aquifer Cleanup LevelAMPI Action Memorandum Plug-In (Phase 2 EE/CA Action Memorandum)ARARs Applicable or Relevant Appropriate RequirementsArmy U.S. Department of the ArmyASR Archive Search ReportAST aboveground storage tankAEHA Army Environmental Hygiene AgencyBCT Base Closure TeamBEC BRAC Environmental CoordinatorBRAC Base Realignment and Closurebgs below ground surfaceBLM Bureau of Land ManagementBRAC Base Realignment and ClosureCAMU Corrective Action Management UnitCAO Cleanup and Abatement OrderCERCLA Comprehensive Environmental Response, Compensation and Liability ActCFR Code of Federal RegulationsCIW Community Involvement WorkshopCNCC California Natural Coordinating CouncilCOC Chemical of ConcernCOPC Chemical of Potential ConcernCT carbon tetrachloridecy cubic yardsDCA dichloroethaneDCE dichloroetheneDDESB Department of Defense Explosive Safety BoardDEH Directorate of Engineering and HousingDoD Department of DefenseDOL Department of LogisticsDRMO Defense Reutilization and Marketing OfficeDTSC/Cal EPA Department of Toxic Substance Control, Cal EPAEE/CA Engineering Evaluation/Cost AnalysisEG East GarrisonEOD Explosive Ordnance DisposalEPA U.S. Environmental Protection AgencyERA Ecological Risk AssessmentESD Explanation of Significant DifferencesESS Explosive Safety SubmissionEW extraction wellFAAF Fritzsche Army AirfieldFDA Fire Drill AreaFFA Federal Facilities AgreementFOSTA Fort Ord Soil Treatment AreaFO SVA Fort Ord Salinas Valley AquicludeFS Feasibility Study

Acronyms

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army ixAugust 23, 2002

GAC Granular Activated Carbongpm gallons per minuteGTP Groundwater Treatment PlantHarding ESE Harding ESE, Inc. (formerly Harding Lawson Associates [HLA])HCRS Heritage Conservation and Recreation ServiceHLA Harding Lawson Associates (now Harding ESE, Inc.)HMX cyclotetramethylenetetranitramineIA Interim ActionIT International Technology GroupJMM James M. Montgomery Consulting EngineeringLDSP Land Disposal Site PlanLRTC Leadership Reaction Training CompoundMCL Maximum Contaminant LevelMCPD Monterey County Planning DepartmentMCWD Marina County Water Districtmg/kg milligrams per kilogramMGSTP Main Garrison Sewage Treatment PlantMOUT Military Operations on Urban TerrainMRTP Monterey Regional Treatment PlantMW monitoring wellNCP National Contingency PlanNoA No ActionNPDES National Pollutant Discharge Elimination SystemNRMA natural resource management areaOD/OB Open Detonation/Open BurningOE Ordnance and ExplosivesOF outfallO&M Operations and MaintenanceOU 1 Operable Unit 1OU 2 Operable Unit 2PAH polynuclear aromatic hydrocarbonsPA/SI Preliminary Assessment/Site InvestigationPCB polychlorinated biphenylPCE tetrachloroethenePOL petroleum/oil/ lubricantPOTW Publicly Owned Treatment WorksPRG Preliminary Remediation GoalQAPP Quality Assurance Project PlanRAO Remedial Action ObjectiveRCRA Resource Conservation and Recovery ActRDX cyclotrimethylenetrinitramineRWQCB Regional Water Quality Control BoardRI Remedial InvestigationRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionRWQCB Regional Water Quality Control BoardSAP Sampling and Analysis PlanSites 2/12 Sites 2 and 12SOC semi-volatile organic compoundSPRR Southern Pacific Railroad Spur

Acronyms

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army xAugust 23, 2002

SRE Screening Risk AssessmentSRU Soil Remedial UnitSWOI Surface Water Outfall InvestigationSWMU Solid Waste Management UnitTASC Training and Audiovisual Service CenterTCE trichloroetheneTCL Target Cleanup LevelTCRA Time-Critical Removal ActionTPH total petroleum hydrocarbonTRC Technical Review Committee:g/l micrograms per literUSAEDH U.S. Army Design Engineering and Support Center, HuntsvilleUST underground storage tankUV-Ox ultraviolet chemical oxidationUSACE United States Department of the Army Corps of EngineersUSRA Underground Storage Tank Remediation AreaUXO unexploded ordnanceVOC Volatile Organic Compound

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army xiAugust 23, 2002

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site name (from WasteLAN): Fort Ord

EPA ID (from WasteLAN): CA7210020676

Region: 9 State: CA City/County: Monterey/Monterey

SITE STATUS

NPL status: W Final Deleted Other (specify)

Remediation status (choose all that apply): W Under Construction W Operating W Complete

Multiple OUs?* W YES NO Construction completion date: / / 2015

Has site been put into reuse? W YES NO

REVIEW STATUS

Lead agency: EPA State Tribe W Other Federal Agency – U.S. Army

Author name: U.S. Army

Author title: Author affiliation:

Review period:** 5 / 17 / 97 to 5 / 17 / 02

Date(s) of site inspection: 1 / 30 / 02

Type of review:W Post-SARA Pre-SARA NPL-Removal only

Non-NPL Remedial Action Site NPL State/Tribe-lead Regional Discretion

Review number: W 1 (first) 2 (second) 3 (third) Other (specify)

Triggering action:Actual RA Onsite Construction at OU # W Actual RA Start at OU#2Construction Completion Previous Five-Year Review ReportOther (specify)

Triggering action date (from WasteLAN): 5 / 17 / 97

Due date (five years after triggering action date): 5 / 17 / 02

* [“OU” refers to operable unit.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in

WasteLAN.]

Signature Sheet for the foregoing Five Year Review Report for the FormerFort Ord, California

This document has also been reviewed and approved by representatives of theUnited States Environmental Protection Agency, California EnvironmentalProtection Agency, Department of Toxic Substances Control and the CaliforniaRegional Water Quality Control Board.

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army xiiAugust 23, 2002

FIVE-YEAR REVIEW SUMMARY FORM

1.0 ISSUES

1.1 OU 1

Solvent contamination in groundwater has beenidentified outside the capture area of the OU 1remedy. TCE is present over an area ofapproximately 50 acres downgradient of theexisting OU 1 remedy. Concentrations of TCEin downgradient locations exceed the ACLsspecified in the OU 1 ROD and will requireremediation to be compliant with the RODobjectives and ARARs.

1.2 OU 2

1.2.1 Landfill Cap

A portion of landfill Cell E has not been closed.Final closure of this cell is scheduled for late2002 after excavation of soil at Range 18.

Landfill gas is monitored around all landfill cellsand meets regulatory requirements, with theexception in the vicinity of the eastern boundaryof Cell F, where the landfill gas extractionsystem is operating.

1.2.2 Groundwater Treatment

This technical assessment did not identify anyissues that could affect current or futureprotectiveness of the groundwater remedy.Additionally, this assessment did not identifyany unresolved issues previously raised byregulatory agencies, the community, or otherinterested parties.

1.3 Site 31

The post remediation risk assessment concludedthat unacceptable human health risks andhazards are considered unlikely to be associatedwith future recreational, commercial orresidential development of Site 31 under theexposure conditions evaluated. The DTSCreviewer isolated an area around the remainingsoil with the highest lead concentration and

calculated an average lead concentration of 550ppm for a sample depth range of 5 to 10 feet.DTSC indicated that this concentration couldresult in a child blood level of over 10 ug/dLbased on a residential scenario. DTSC stated thata land use covenant should be completed toprohibit excavation, exposure of soil and the useof the area as part of any residentialdevelopment. Based on the data present in theresponse to DTSC comment, the Army did notchange the conclusion of the post remediationrisk assessment. The land use covenant issuesassociated with Site 31 are still being negotiatedbetween the Army and DTSC.

1.4 Site 39

The remedy cannot be fully implemented untilordnance has been removed from the site.

The proposed future reuse of a portion on Site 39 has been changed to mixed residentialand commercial development. For thedevelopment areas within Site 39, EPA Region IX PRGs for lead, antimony and copperare used as action levels.

The sampling and analysis plan for Site 39Ranges 18 and 19 proposes placement ofexcavated soil at the OU 2 Landfill, Cell E. TheArmy issued the Draft Sampling and AnalysisPlan for Characterization and RemediationConfirmation for Site 39 (Ranges 18 and 19) inApril 2002. Comments have not yet beenreceived from the regulatory agencies.

The OU 2 Landfill may not have sufficientremaining capacity to contain the excavatedsoils as stated in the selected remedy. A pilotstudy is underway to evaluate potentialtreatment options.

1.5 Site 33

There is a potential for a change in the reuse ofSite 33. A deed restriction must be maintained torestrict the site to non-residential uses unless thesite is remediated to residential standards.

Five Year Review Summary Form

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1.6 Site 3

There remains a potential for post remediationactivities related to shifting sands and thepossible subsequent discovery of areas withgreater than 10 percent surface coverage of spentammunition, and additional habitat monitoringat Site 3. These issues will be resolved beforethe Proposed Plan and Record of Decisionfinalizing the remedy selection for the site areissued.

2.0 RECOMMENDATIONS

2.1 OU 1

To achieve the objectives specified in the OU 1ROD, operation of the existing groundwaterremedy should continue until ACLs have beenachieved and maintained within the designedcapture area. To address the downgradientcontamination the groundwater remedy shouldbe expanded as described in the ConceptualDesign, OU 1 Groundwater Remedy Expansion(IT, 2001), and alternative technologies shouldbe evaluated as enhancement or substitution forthe conceptual design.

2.2 OU 2

2.2.1 Landfill Cap

Complete closure of landfill Cell E and prepareclosure report for the OU 2 Landfill. Continue

operation of the landfill gas treatment systemuntil the landfill gas levels remain belowregulatory standards. Continue to inspect andmonitor the OU 2 Landfill in accordance withthe Post Closure Operation and MaintenancePlan (IT, 2000a).

2.2.2 Groundwater

The OU 2 Groundwater Remedy shouldcontinue to be implemented as designed untileither ACLs are reached or the next technicalassessment is conducted.

2.3 Sites 2/12

The Sites 2/12 Groundwater Remedy shouldcontinue to operate as designed until eitherACLs are reached or subsequent evaluationindicates that a modification is in order.

3.0 PROTECTIVENESS STATEMENT

All immediate threats at the site have beenaddressed, with the exception of Site 39 (InlandRanges). The Site 39 remedy cannot be fullyimplemented until the ordnance removal iscomplete. The groundwater remedies areexpected to be protective of human health andthe environment after the groundwater cleanupgoals are achieved. Restrictions, including deedrestrictions on transferred property and a countyordinance, are in place to prevent access tocontaminated groundwater.

Draft FinalEJT/LF/YL58873DF1 -FO United States Department of the Army 1August 23, 2002

1.0 INTRODUCTION

The purpose of the five-year review is todetermine whether the remedy at a site continuesto be protective of human health and theenvironment after a period of 5 years from thetime the remedy was implemented (or from thetime of a previous five-year review). Themethods, findings, and conclusions of the five-year review are documented in a Five-YearReview report. In addition, the Five-YearReview report documents any newly identifiedsite-related data or issues identified during thereview, and identifies recommendations toaddress them as appropriate.

The Army is preparing this Five-Year Reviewreport pursuant to ComprehensiveEnvironmental Response, Compensation andLiability Act (CERCLA) §121 and the NationalContingency Plan (NCP). CERCLA §121states:

If the President selects a remedial action thatresults in any hazardous substances, pollutants,or contaminants remaining at the site, thePresident shall review such remedial action noless often than each five years after the initiationof such remedial action to assure that humanhealth and the environment are being protectedby the remedial action being implemented. Inaddition, if upon such review it is the judgementof the President that action is appropriate atsuch site in accordance with section [104] or[106], the President shall take or require suchaction. The President shall report to theCongress a list of facilities for which suchreview is required, the results of all suchreviews, and any actions taken as a result ofsuch reviews.

The Army interpreted this requirement further inthe NCP; 40 Code of Federal Regulations (CFR)§300.430(f)(4)(ii) which states:

If a remedial action is selected that results inhazardous substances, pollutants, orcontaminants remaining at the site above levelsthat allow for unlimited use and unrestricted

exposure, the lead agency shall review suchaction no less often than every five years afterthe initiation of the selected remedial action.

The Army conducted the five-year review of allremedies implemented at the Fort OrdSuperfund Site in Monterey County, California(Figure 1). This document was developed duringthe period from December 2001 through May2002. This report documents the results of thereview, which is the first Five-Year Reviewconducted for remedies implemented at Fort Orddocumented in Records of Decision (RODs) andother areas shown on Plate 2 and summarizedbelow:

• Operable Unit 1 (OU 1) Record of Decision(ROD) Fritzsche Army Airfield

• Operable Unit 2 (OU 2) ROD Fort OrdLandfills

• Basewide Remedial Investigation Sites ROD

– Sites 2/12 (Site 2: Main GarrisonSewage Treatment Plant (MGSTP); Site12: Lower Meadow Disposal Area,Department of Logistics (DOL)Automotive Yard, Cannibalization Yardand Industrial Area, Southern PacificRailroad (SPRR) Spur, Outfall 31 Area

– Sites 16 and 17 (Site 16: DOLMaintenance Yard, Pete’s Pond, Pete’sPond Extension; Site 17: Disposal Areaand Other Areas)

– Site 31 (Former Dump Site)

– Site 39 (Inland Ranges)

– Surface Water Outfalls (OF-1 throughOF-14; OF-16 through OF-30; OF-32,OF-33)

– Site 25 (Equipment Storage Area)

Introduction


– Site 33 (Golf Course Maintenance Area)

• Site 3 Interim ROD Beach TrainfireRanges

• No Action Sites ROD

• Interim Action Sites ROD

• Other Investigations (not addressed underone of the RODs above)

– Carbon Tetrachloride Investigation

– Monterey Bay Enhanced PreliminaryAssessment

– East Garrison Magnetic AnomaliesInvestigation

– Fritzsche Army Airfield Three SitesInvestigation

– Freon 113 Investigation

– Fort Ord Soil Treatment Area (FOSTA) /Underground Storage Tank RemediationArea (USRA) Investigation

– Resource Conservation and Recovery Act(RCRA) Closures

– Ordnance and Explosives Program

The triggering action for this statutory reviewwas the initiation of remedial action at the OU 2Landfill on May 17, 1997. The five-year reviewis required since hazardous substances,pollutants, or contaminants remain at the siteabove levels that allow for unlimited use andunrestricted exposure.

1.1 Five-Year ReviewReport Organization

This Five-Year Review Report is organized asfollows:

Section 1 – Introduction. Describes the purposeand scope of the Five-Year Review report andsummarizes its organization.

Section 2 – Site Chronology Table.Summarizes the chronology of cleanup-relatedevents at Fort Ord that are reviewed in thisreport.

Section 3 – Fort Ord Background. Describesthe general physical characteristics and land usesat Fort Ord; the history of contamination; initialresponses to the presence of contamination; andthe basis for actions taken to address thecontamination.

Section 4 – Five-Year Review Process.Summarizes the components of the Five-YearReview process, including administrative andcommunity involvement components; and datareview, site inspection, and interviewprocedures.

Section 5 – OU 1 ROD Fritzsche ArmyAirfield. Presents background information onOU 1 Fritzsche Army Airfield; a summary ofremedial actions and a technical assessment ofthe actions taken at the site; identifies any issuesrelated to the protectiveness of the remedy basedon the review; presents recommendations andfollow-up actions, if needed, to address issuesidentified during the review; and provides astatement regarding the protectiveness of the siteremedies.

Section 6 – OU 2 ROD - Fort Ord Landfills.Presents background information on OU 2 FortOrd Landfills; a summary of remedial actionsand a technical assessment of the actions takenat the site; identifies any issues related to theprotectiveness of the remedy based on thereview; presents recommendations and follow-up actions, if needed, to address issues identifiedduring the review; and provides a statementregarding the protectiveness of the site remedies.

Section 7 – Basewide Remedial InvestigationSites ROD. Presents background information onthe Basewide Remedial Investigation sites; asummary of remedial actions and a technicalassessment of the actions taken at these sites;identifies any issues related to the protectivenessof the remedies based on the review; presentsrecommendations and follow-up actions, if

Introduction


needed, to address issues identified during thereview; and provides a statement regarding theprotectiveness of the site remedies.

Section 8 – Site 3 Interim ROD. Presentsbackground information on the Site 3 InterimROD; a summary of remedial actions and atechnical assessment of the actions taken at thissite; identifies any issues related to theprotectiveness of the remedy based on thereview; presents recommendations and follow-up actions, if needed, to address issues identifiedduring the review; and provides a statementregarding the protectiveness of the site remedy.

Section 9 – No Action Sites ROD. Presentsbackground information on the No Action SitesROD; a summary of remedial actions and atechnical assessment of the actions taken at thesesites; identifies any issues related to theprotectiveness of the remedies based on thereview; presents recommendations and follow-up actions, if needed, to address issues identifiedduring the review; and provides a statementregarding the protectiveness of the site remedies.

Section 10 – Interim Action Sites ROD.Presents background information on the InterimAction Sites ROD; a summary of remedialactions and a technical assessment of the actionstaken at these sites; identifies any issues relatedto the protectiveness of the remedies based onthe review; presents recommendations andfollow-up actions, if needed, to address issuesidentified during the review; and provides astatement regarding the protectiveness of the siteremedies.

Section 11 – Status of Other Investigations.Provides background information and statusreports on other investigations at Fort Ord notaddressed under one of the RODs describedabove.

Section 12 – Next Review. Describes theschedule for the next Five-Year Review to beconducted at Fort Ord.

Section 13 – References. Provides a list ofreferences to pertinent documents cited in thereport.


2.0 SITE CHRONOLOGY TABLE

The table below presents a summary of the chronology of cleanup-related events at Fort Ord that have

occurred prior to the preparation of this five-year review document. The remaining actions that have

occurred since 1997 are discussed throughout this document.

Event Date

Pre-NPL ResponsesOU 1 (Fritzsche Army Airfield Fire Drill Area)Investigation

1984

OU 2 (Fort Ord Landfill) Investigation 1986NPL Listing 2/90Federal Facility Agreement signed 7/90BRAC Listing 7/91Panetta Legislation (Public Law 102-190) 12/91Interim Action ROD 3/94OU 2, Fort Ord Landfills, Record of Decision(ROD)

8/94

No Action Plug-In ROD 4/95OU 1, Fritzsche Army Airfield, ROD 9/95OU 2 Explanation of Significant Differences(ESD) #1

8/95

Remedial Investigation/Feasibility StudyCompleted

10/95

OU 2 ESD #2 8/96OU 2 ESD #3 1/97Interim ROD, Site 3 Beach Trainfire Ranges 1/97Basewide Remedial Investigation Sites ROD 1/97


3.0 FORT ORD BACKGROUND

This section describes the general physicalcharacteristics and land uses at Fort Ord; thehistory of contamination; initial responses to thepresence of contamination; and the basis foractions taken to address the contamination.

3.1 PhysicalCharacteristics

Fort Ord is adjacent to Monterey Bay innorthwestern Monterey County, California,approximately 80 miles south of San Francisco(Plate 1). The base consists of approximately28,000 acres adjacent to the cities of Seaside,Sand City, Monterey, and Del Rey Oaks to thesouth and Marina to the north. The SouthernPacific Railroad and Highway 1 pass throughthe western part of Fort Ord, separating thebeachfront portions from the rest of the base.Laguna Seca Recreation Area and ToroRegional Park border Fort Ord to the south andsoutheast, respectively. Land use east of FortOrd is primarily agricultural.

3.1.1 History

Beginning with its founding in 1917, Fort Ordserved primarily as a training and stagingfacility for infantry troops. From 1947 to 1975,Fort Ord was a basic training center. After 1975,the 7th Infantry Division (Light) occupied FortOrd. Light infantry troops operate without heavytanks, armor, or artillery. Fort Ord was selectedin 1991 for decommissioning, but troopreallocation was not completed until 1993.Although Army personnel still operate the base,no active Army division is stationed at Fort Ord.

In 1917, the U.S. Army bought the present dayEast Garrison and nearby lands on the east sideof Fort Ord to use as a maneuver and trainingground for field artillery and cavalry troopsstationed at the Presidio of Monterey. Before theArmy’s use of the property, the area wasagricultural, as is much of the surrounding landtoday. No permanent improvements were made

until the late 1930s, when administrativebuildings, barracks, mess halls, tent pads, and asewage treatment plant were constructed.

In 1938, additional agricultural property waspurchased for the development of the MainGarrison. At the same time, the beachfrontproperty was donated to the Army. The MainGarrison was constructed between 1940 and the1960s, starting in the northwest corner of thebase and expanding southward and eastward.During the 1940s and 1950s, a small airfieldwithin the Main Garrison was present in what isnow the South Parade Ground. In the early1960s, Fritzsche Army Airfield (FAAF) wascompleted. The Main Garrison airfield was thendecommissioned and its facilities wereredeveloped as motor pools and other facilities.

3.2 Land Use

Fort Ord consists of both developed andundeveloped land. The three principaldeveloped areas are the East Garrison, theFAAF, and the Main Garrison; these areascollectively comprise approximately 8,000acres. The remaining 20,000 acres are largelyundeveloped areas. Land uses in both thedeveloped and undeveloped areas are describedbelow

3.2.1 Developed Land

With the presence of up to 15,000 active dutymilitary personnel and 5,100 civilians during itsactive history, developed areas at Fort Ordresembled a medium-sized city, with familyhousing, medical facilities, warehouses, officebuildings, industrial complexes, and gas stations.Individual land use categories were as follows:

• Residential areas included military housing,such as training and temporary personnelbarracks, enlisted housing, and officerhousing.

Fort Ord Background


• Local services/commercial areas providedretail or other commercial services, such asgas stations, mini-markets, and fast foodfacilities.

• Military support/industrial areas includedindustrial operations, such as motor pools,machine shops, a cannibalization yard (areawhere serviceable parts are removed fromdamaged vehicles), and the FAAF.

• Mixed land use areas combined residential,local services/commercial, and militarysupport operations.

• Schools included the Thomas HayesElementary, Roger S. Fitch Junior High,General George S. Patton Elementary, andGladys Stone schools. High school studentsattended Seaside High, outside Fort Ord’ssouthwest boundary.

• Hospital facilities included the Silas B.Hayes Army Hospital, medical and dentalfacilities, and a helipad.

• Training areas included a central runningtrack and athletic field, firing ranges, andobstacle courses.

• Recreational areas included a golf courseand club house, baseball diamonds, tenniscourts, gymnasiums, and playgrounds.

The three principal developed areas aredescribed below.

East Garrison: The East Garrison is on thenortheast side of the base, adjacent toundeveloped training areas (Plate 2).Military/industrial support areas at the EastGarrison include tactical vehicle storagefacilities, defense recycling and disposal areas, asewage treatment plant, and a small arms range.The East Garrison also contains recreationalopen space, including primitive campingfacilities, baseball diamonds, a skeet range, andtennis courts. Recreational open space comprises25 of the approximately 350 acres of the EastGarrison.

Fritzsche Army Airfield: The FAAF is in thenorthern portion of Fort Ord, on the north sideof Reservation Road and adjacent to the citylimits of Marina (Plate 2). The primary land useis for military/industrial support operations;facilities include air strips, a motor park, aircraftfuel facilities, a sewage treatment plant, aircraftmaintenance facilities, an air control tower, afire and rescue station, and aircraft hangars.

Main Garrison: The Southern Pacific Railroadright-of-way and Highway 1 separate the coastalzone from Fort Ord’s Main Garrison (Plate 2).The Main Garrison consists of a complexcombination of the various land use categories.Facilities include schools; a hospital; housing;commercial facilities including a dry cleaner anda gasoline service station; and industrialoperations including motor pools and machineshops.

3.2.2 Undeveloped Land

Coastal Zone: A system of sand dunes liesbetween Highway 1 and the shoreline (Plate 2).The western edge of the dunes has an abruptdrop in elevation of 40 to 70 feet, and the dunesreach an elevation of 140 feet above mean sealevel on the gentler, eastern slopes. The dunesprovide a buffer zone that isolates the BeachTrainfire Ranges (RI Site 3) from the shorelineto the west. In some areas, spent ammunitionaccumulated on the dune slopes as the result ofyears of range operation. Stilwell Hall(previously used as a recreation center),numerous former target ranges and ammunitionstorage facilities, and two inactive sewagetreatment facilities lie east of the dunes.

Because of the presence of rare and/orendangered species and because of its visualattributes, Monterey County has designated FortOrd’s coastal zone an environmentally sensitivearea. The California Natural CoordinatingCouncil (CNCC) and the Heritage Conservationand Recreation Service (HCRS) have identifiedthe dunes at Fort Ord as among the best coastaldunes in California because of significantfeatures including coastal strand vegetationcomprising many exotic ice plants

Fort Ord Background


and the habitat of the black legless lizard(Monterey County Planning Department[MCPD], 1984).

Inland Areas: Undeveloped land in the inlandportions of Fort Ord includes infantry trainingareas and open areas used for livestock grazingand recreational activities such as hunting,fishing, and camping. A large portion of thisundeveloped land is occupied by the InlandTrainfire Ranges (part of Site 39); this area wasused for advanced military training operations.

These undeveloped areas occur primarily in theirnatural state, and typically do not containdevelop facilities.

3.2.3 Transferred Land

Over 10,000 acres of former Ford Ord propertyhas been transferred. Parcel sizes ranged from0.1 acre to over 4900 acres. The major propertyrecipients have been the Bureau of LandManagement (BLM), California State UniversityMonterey Bay, University of California, the Cityof Marina and the City of Seaside.

3.3 History ofContamination

The history of contamination is discussed on asite-by-site basis in Sections 5.0 through 11.0.

3.4 Initial Responses

After completion of the first phase of RemedialInvestigation/Feasibility Study (RI/FS) fieldwork, it was evident that the sites could becategorized based on: (1) whether a release wasidentified at a site and (2) if a release hadoccurred, the nature and extent of the release.Therefore, using the initial site characterizationinformation and existing pre-RI/FS data, the 43 sites were categorized as: (1) BasewideRemedial Investigation (RI) sites, (2) InterimAction (IA) sites, or (3) No Action (NoA) sites(Plate 2). These three categories are defined asfollows; the individual RI, IA, and NoA sites arelisted in Sections 7.0, 9.0, and 10.0, respectively:

• RI Sites: RI sites have sufficientcontamination to warrant a full RemedialInvestigation, (RI), Baseline RiskAssessment (BRA), Ecological RiskAssessment (ERA), and Feasibility Study(FS)

• NoA Sites: NoA sites do not warrantremedial action under CERCLA

• IA Sites: IA sites have limited volume andextent of contaminated soil and, as a result,are easily excavated, as an interim action

To accelerate the cleanup process, IA and NoAsites were addressed in separate remedialcategories from the RI sites and were supportedby their own records of decision (RODs). TheseRODs provided a process for acceleratedtransfer of NoA sites and cleanup of IA sitesunder BRAC, rather than delaying cleanup ortransfer actions until a final ROD for Fort Ord issigned. The NoA ROD was signed in April1995, and the IA ROD was signed in March1994. The RI sites ROD was signed in January1997, and addressed cleanup of a range of sitesfor which full RI/FSs were deemed necessary.

In addition to the RI, NoA, and IA sites RODs,two operable units at Fort Ord (OU 1, theFritzsche Army Airfield (FAAF) Fire Drill Area,and OU 2, the Fort Ord Landfills; Plate 2) werealso supported by their own RODs and followindividual paths to the final ROD for Fort Ord.The ROD for OU 1 was signed in September1995, and the OU 2 ROD was signed in August1994.

3.5 Basis for Action

The basis for the action is discussed on asite-by-site basis in Sections 5.0 through 11.0.


4.0 FIVE-YEAR REVIEW PROCESS

This section summarizes the components of theFive-Year Review process, includingadministrative and community involvementcomponents; and data review, site inspection,and interview procedures.

4.1 AdministrativeComponent

Members of the Base Closure Team (BCT) werenotified of the initiation of the five-year reviewon November, 2000. The Fort Ord Five-YearReview team was led by Gail Youngblood, theBase Realignment and Closure (BRAC)Environmental Coordinator (BEC), and the teamincluded members from the United States ArmyCorps of Engineers (USACE) staff and theircontractors, with expertise in hydrogeology,geology, treatment system operations and riskassessment.

4.2 CommunityInvolvement

Activities to involve the community in the five-year review were initiated with anannouncement that was made available at theCommunity Involvement Workshop (CIW),Technical Review Committee (TRC) meetingand on the Fort Ord web page in February 2002.

4.3 Data Review

This five-year review consisted of a review ofrelevant documents including operations andmaintenance (O&M) records and monitoringdata; records of decision (RODs); Explanationof Significant Differences to the RODs (ESDs),where appropriate; confirmation reports; closurereports; applicable groundwater cleanupstandards; Preliminary Remediation Goals(PRGs); and others reports listed in Section 13.0(References) and referenced herein.

4.4 Site Inspections

Inspections at the sites were conducted onJanuary 30, 2002, by Mark Reese, Fort OrdDepartment of Environmental and NaturalResources Management; Marc Edwards,USACE; and Edward Ticken, Harding ESE. Thepurpose of the inspections were to assess theprotectiveness of the remedies at Operable Unit2 (OU 2; Fort Ord Landfills), and the BasewideRemedial Investigation (RI) Sites, including Site3, the Beach Trainfire Ranges. Operable Unit 1(OU-1; Fritzsche Army Airfield) is routinelyinspected as part of the groundwater treatmentsystem operation and was not included in thesite inspection.

4.4.1 OU 2 Landfill

The former Area A appears to be revegetatedand no signs of erosion were evident. There waserosion of the vegetative layer in a section ofCell F where the liner is now exposed. Theseerosional problems were believed to be causedby an animal burrow near the drainage systemwhich caused a small section of the liner to beexposed. The area will be repaired after the endof the rainy season and the areas around thedrainage system will be periodically inspectedfor animal burrows. A pilot test is in progress toreduce the amount of landfill gas at the propertyline of Cell F to meet regulatory standards. TheOU 2 groundwater treatment system isperiodically inspected by the USACE and wasnot included in this inspection. No new uses ofgroundwater within the OU 2 plume area wereobserved.

4.4.2 RI Sites

Sites 2/12 – The excavation area at LowerMeadow at Site 12 is revegetated and there areno signs of erosion. The 2/12 groundwatertreatment system is periodically inspected by theUSACE and was not included in this inspection.

Five-Year Review Process


No new uses of groundwater within the 2/12plume area were observed.

Sites 16/17 – The excavation area at Pete’s Pondat Sites 16/17 is revegetated and there are nosigns of erosion except in one area where therewas recent a break in the water main which wasrepaired by the installation staff.

Site 25 – No activities or changes were notedwithin Site 25.

Site 31 – The excavation area at Site 31 isrevegetated and there are no signs of erosion orother activities on the excavated slope.

Site 33 – There were no residential developmentnoted at Site 33 where restrictions limit the reuseto other than residential-type uses. The site iscontinuing to be used as a golf coursemaintenance area.

Site 39 – This site was not inspected because theremedy has not yet been implemented andordnance and explosive cleanup activities are inprogress at the site.

4.4.3 Site 3

The remediation areas at Site 3 are revegetatedand there are no signs of erosion.

4.5 Interviews

Interviews specific to the Five-Year Reviewwere not conducted because the Army currentlymaintains an active community relationsprogram that allows continuous communityinvolvement in the cleanup of the former FortOrd. This is accomplished through severaloutreach activities aimed at establishing andsustaining two-way communication between theArmy and members of the local communities.Participants include, but are not limited to:Technical Review Committee (TRC) members,local political and civic leaders, special interestgroups, minority, ethnic, and religiousorganizations. Interviews and surveys areconducted by the community relations staffwithin affected communities to support theCommunity Relations Plan. Interviews allow thecommunity relations staff to maintain a currentevaluation of the community membersassessment of the Fort Ord cleanup activities.Monthly Community Involvement Workshopsand Quarterly TRC Meetings provide acontinuing forum for input from members of thelocal communities, representatives of local andregional regulatory agencies and commissions,natural resource trustees, civic and educationalinstitutions.


5.0 OU 1 ROD 9 FRITZSCHE ARMY AIRFIELD FIRE DRILL AREA

This section presents background information onOU 1, Fritzsche Army Airfield Fire Drill Area; asummary of remedial actions and a technicalassessment of the actions taken at the site;identifies any issues related to the protectivenessof the remedy based on the review; presentsrecommendations and follow-up actions, ifneeded, to address issues identified during thereview; and provides a statement regarding theprotectiveness of the site remedies.

5.1 OU 1 Background

The Fritzsche Army Airfield Fire Drill Area(FDA) was established in 1962 as a training areafor the Fort Ord Fire Department (Plate 2). Aspart of training activities, fuel was dischargedfrom an onsite storage tank into a pit, ignited,and then extinguished. Training activities at theFDA were discontinued in 1985 and theassociated structures were removed. Fort Ord’sfirst site investigation was conducted at theFDA, and concluded that soil and groundwatercleanups were required in this area. About4,000 cubic yards of contaminated soil wasremoved from the FDA, and the area was thenbackfilled with clean fill (soil). In addition tothe soil cleanup, a water treatment facility wasconstructed in 1988 in order to remediatetrichloroethylene (TCE) and other relatedgroundwater contaminants. During operation ofthe treatment system, surrounding groundwateris sampled and checked to verify the treatmentsystem is operating effectively. Since 1988,water samples have been collected every threemonths (and were collected more frequentlyduring the initial operation period). Thisinformation has been compiled into annualreports to show the long-term trends of systemoperation (Harding ESE, Annual EvaluationReport, October 1999 through September 2000,OU 1 and OU 2 Groundwater Remedies,Former Fort Ord, California, June 20, 2001). Inaddition, a large-scale study of all data issummarized in the OU 1 site-specific 5-YearReview, Draft Final, Five-Year Status Report

and Effectiveness Evaluation, Operable Unit 1Groundwater Treatment System, Fort Ord,California (HLA, 1999c).

5.2 Remedial Actions

5.2.1 Remedy Selection

Groundwater

The remedial alternatives listed in the OU 1RI/FS (HLA, 1987) are as follows:

Alternative 1

• Air stripping of groundwater with vaporphase carbon treatment of effluent andbiodegradation of soil.

Alternative 2

• Air stripping of groundwater with vaporphase carbon off-gas treatment, aqueouscarbon polishing of effluent andbiodegradation of soil.

Alternative 3

• Aqueous carbon effluent treatment ofgroundwater and biodegradation of soil.

Soil

The OU 1 ROD approved no further action forsoil based on the results of the RemediationConfirmation Study (HLA, 1999d).

5.2.2 Remedy Implementation

Alternative 3 was selected, approved andimplemented in June 1987 based on the RI/FSand was approved in the OU 1 ROD.

OU 1 ROD 9 Fritzsche Army Airfield


5.2.3 System Operations andMaintenance

Operations and maintenance (O&M) of the OU 1 remedy have kept the groundwatertreatment system functioning in accordance withdesign parameters and the objectives stated inthe ROD since the inception of operations in1988. To date, the system has processed over100 million gallons of water and removed over25 pounds of contaminants, of whichapproximately 88 percent is TCE. The systemcontinues to use two 33-cubic-foot (1,000-pound) carbon vessels connected in series fortreatment with a third off-line unit used forreplacement of spent carbon. The systemoperates continuously except for periods ofroutine maintenance, carbon servicing, andreplacement of worn equipment. In general, thesystem is in operation approximately 99% of thetime. Carbon replacement in the system occursapproximately every 4 to 6 months.

No design changes have been made to thesystem since the modifications that were madein 1989, which increased the flow capacity ofthe system by 33%. The only operational changethat has been made is cessation of pumping fromextraction well EW-OU1-18-A, asrecommended in the 5-Year Status Report andEffectiveness Evaluation (HLA, 1999c) for OU1, because cleanup levels have been achievedand maintained in that well’s capture area. Anadditional benefits recognized from this changeincludes cost savings from reduced carbonconsumption. Groundwater monitoring of thisarea is continuing to evaluate changes that mayresult from discontinued pumping.

5.3 Technical Assessment

5.3.1 Question A

Is the remedy functioning as intended by thedecision document?

Operations and maintenance (O&M) of thetreatment system is performed as described inthe O&M Manual (HLA, 1996m). Detailsregarding operation and system performance are

described in the June 20, 2001 AnnualEvaluation Report, October 1999 ThroughSeptember 2000, OU 1 and OU 2 GroundwaterRemedies, Former Fort Ord, California(Harding ESE/IT 2001 b). The OU 1groundwater remedy is continuing to effectivelyreduce the total mass of solvents in groundwater,and is functioning in accordance with designparameters and the objectives stated in the OU 1ROD (Army, 1995b). Concentrations ofchemicals of concern (COCs) have continued todecrease within the designed capture area exceptwhere recent increased precipitation rechargeand groundwater elevation increases havelocally remobilized vadose zone solventspreviously held in capillary suspension. Withinthe designed capture area this contaminant massis expected to be adequately addressed by theexisting remedy. Other than occasionalequipment failures and replacement, andperiodic shutdowns for routine maintenance andtesting, the system has operated continuouslyand effectively.

Evaluation of monitoring and test data haveindicated that aquifer cleanup levels (ACLs) inthe vicinity of extraction well EW-OU1-18-Ahave been achieved and sustained for asignificant period of time. Furthermore, aquifertest data has indicated that the existing systemmay be optimized by cessation of pumping fromEW-OU1-18-A (already achieved), and doublingthe pumping rate in EW-OU1-17-A, whichwould increase the area of hydraulic capture.

Increasing pumping rates will enhance hydrauliccapture in the vicinity of the former burn pit andadjacent areas. However, COCs above theACLs have been identified and the additionalarea delineated northwest (downgradient), of theformer burn pit and outside of the capture area(Harding ESE/IT, 2001 c) for which remediationwill be required. A conceptual designdescribing a proposed expansion of the OU 1remedy to include the downgradient area hasbeen issued (Harding ESE/IT, 2001f).Concurrently, a pilot study program is beingdeveloped by the Army to evaluate the potentialeffectiveness of additional treatmenttechnologies, such as in situ oxidation, to



supplement remediation of the downgradientareas.

5.3.2 Question B

Are the exposure assumptions, toxicity data,cleanup levels and remedial action objectives(RAOs) used at the time of the remedy selectionstill valid?

The property in and around the OU 1 area hasbeen transferred, and the land use has changedslightly since the time the ROD was issued(currently a biological reserve). However, landuse has not changed sufficiently to alter theexposure assumptions used for development ofthe ACLs specified in the ROD. The standardsfor site ACLs were based on state and federalmaximum contaminant levels (MCLs) exceptwhere more stringent values were developedfrom the health risk assessment. The MCLs forthe OU 1 COCs have not changed since theROD was signed, so the ACLs remaincompliant, or more conservative than MCLs. Insummary, no concentrations of COCs have beendetected in excess of the maximums indicated inthe ROD, potential exposure pathways have notappreciably changed, and the ACLs are still incompliance with, or more conservative than,federal and State standards. Therefore, thestandards continue to be protective of humanhealth, and no re-evaluation of health risks forthe OU 1 remedy is necessary.

5.3.3 Question C

Has any information come to light that couldcall into question the protectiveness of theremedy?

The OU 1 remedy is operating in accordancewith design parameters and is compliant with theobjectives of the ROD within the designedhydraulic capture area. However, groundwatermonitoring has indicated that COCs are presentin groundwater outside, and downgradient of,the capture area of the current remedy (HardingESE/IT 2001c). This appears to be anuncaptured portion of the original groundwaterplume. The existing groundwater remedy is

inadequate to address these downgradient areasin a manner sufficient to comply with the RODand regulatory parameters. Modification of thecurrent system is necessary to address thedowngradient areas in order to protect potentialbeneficial uses of the groundwater and to beprotective of human health Planning for thismodification is underway.

5.4 Issues

Changes under consideration for the treatmentsystem include increasing the pumping rate fromextraction well EW-OU1-17-A to increase thepotential capture area and potentially reducecontaminant residence time. This would requireno modifications to the treatment systembecause of the additional processing capacityavailable from shutting down extraction wellEW-OU1-18-A. These changes and proposedchanges are in accordance with the establishedsystem operation parameters and objectives ofthe ROD.

Solvent contamination in groundwater has beenidentified outside the capture area of the OU 1remedy. TCE is present over an area ofapproximately 50 acres downgradient of theexisting capture of the OU 1 remedy.Concentrations of TCE in downgradientlocations exceed the ACLs specified in the OU 1ROD and will require remediation to becompliant with the ROD objectives andapplicable or relevant and appropriaterequirements (ARARs).

The existing OU 1 groundwater remedy isprotective over the area for which it wasdesigned, but cannot remediate thedowngradient contamination withoutmodification. Solvent contamination in thedowngradient areas poses a potential risk tohealth via degradation of water quality.Treatment system modification or expansion, oralternative remediation methods will need to beimplemented in order to apply the cleanupstandards of the ROD to the entire area of theplume as it is now known.



No unresolved issues raised by regulatoryagencies, the community, or other interestedparties have been identified.

5.5 Recommendations andFollow-Up Actions

To achieve the objectives specified in the OU 1ROD, operation of the existing groundwaterremedy should continue until ACLs have beenachieved and maintained within the designedcapture area. To address the downgradientcontamination, the groundwater remedy shouldbe expanded as described in the ConceptualDesign, OU 1 Groundwater Remedy Expansion(Harding ESE/1T, 2001f), and alternativetechnologies should be evaluated asenhancement or substitution for the conceptualdesign.

5.6 ProtectivenessStatement

The remedy is protective of human health andthe environment within the designed capture

area by maintaining hydraulic control of thecontaminant plume and by actively reducingcontaminant levels. The remedy is compliantwith ARARs in the area for which it wasdesigned, but does not address the downgradientaspect of the solvent plume and is not currentlyprotective of human health and the environmentin that area. The Army is presently evaluatingmethods to remediate the downgradient aspectof the plume. All transferring parcels, which arelocated over the groundwater plume, willinclude a Covenant To Restrict Use Of Property(CRUP) recorded with the deed. The CRUP willprohibit construction of wells for injection orextraction of any groundwater until the ACLsare attained. In addition, there is a MontereyCounty ordinance that regulates water wellinstallation within either the “GroundwaterProhibition Zone” or “GroundwaterConsultation Zone” which include the knowngroundwater plumes at the former Fort Ord. It isanticipated that the next five-year evaluation ofOU 1 will be completed in 2007 in conjunctionwith the Basewide Five-Year Evaluation for theFormer Fort Ord.


6.0 OU 2 ROD – FORT ORD LANDFILLS

This section presents background information onOU 2 Fort Ord Landfills; a summary ofremedial actions and a technical assessment ofthe actions taken at the site; identifies any issuesrelated to the protectiveness of the remedy basedon the review; presents recommendations andfollow-up actions, if needed, to address issuesidentified during the review; and provides astatement regarding the protectiveness of the siteremedies.

6.1 OU 2 Background

Operable Unit 2 (OU 2), the Fort Ord Landfillssite, consists of landfills covering approximately150 acres, the immediate surrounding area, andthe underlying contaminated groundwater (Plate2).

The landfills were used for over 30 years forresidential and commercial waste disposal. Thelandfills include the main landfill and the northlandfills. The north landfills were operated from1956 to 1966. The main landfill was operatedfrom 1960 until 1987, and may have received asmall amount of chemical waste along withhousehold and commercial refuse. The mainlandfill facility stopped accepting waste fordisposal in May 1987 because of the initiation ofinterim closure of the facility.

As a result of detections of volatile organiccompounds (VOCs) in Fort Ord and MarinaCounty Water District (MCWD) water supplywells, the Regional Water Quality Control Board(RWQCB) issued Cleanup and Abatement Order (CAO) 86-87 that required Fort Ord toinitiate studies of soil and groundwater to assessthe potential impact of the Fort Ord Landfills onunderground water resources. The RWQCBalso issued CAO Nos. 86-317 and 88-139 for theinvestigation and cleanup of groundwatercontamination caused by the landfills and WasteDischarge Report (WDR) No. 87-153 requiringlandfill closure by 1989. The Army initiatedstudies (HLA, 1988a) to evaluate whetherchemicals from the landfills had affected either

soil beneath the landfills or the quality ofgroundwater beneath the sites, or both.

The Final Remedial Investigation Report (Damesand Moore, 1993) indicated the presence of lowlevels of semi-volatile organic compounds (SOCs)and pesticides in soil at maximum total detectedconcentrations of 5.6 milligrams per kilogram(mg/kg) and 0.12 mg/kg, respectively. Metalswere also detected in all soil samples. Soil gassampling detected VOCs and methane atmaximum concentrations of 6.0 micrograms perliter (:g/l) and 550,000 :g/l, respectively. VOCswere also detected in groundwater samplescollected from both the A-aquifer and the 180-footaquifer. TCE was the most frequently detectedchemical in groundwater with a maximumconcentration of 80 :g/l. Other VOCs detected ingroundwater samples included: tetrachloroethene (PCE), benzene,cis-1,2-dichloroethene, and dichloromethane.Recent data indicates that a portion of the carbontetrachloride plume described in Section 11.1, hasmigrated to the southeast where it commingleswith the OU 2 plume.



Using the RI data, a Baseline Risk Assessment(Dames and Moore, 1993) and a feasibility study(Dames and Moore, 1993) were prepared. Thesedocuments provided evaluations of the potentialrisks to human health and the environment fromcontamination in soil and groundwater at thelandfills, and alternatives for remediatingcontamination.

The following five remedial alternatives wereevaluated in the FS:

OU 2 ROD – Fort Ord Landfills


Alternative 1

• No Action: This alternative assumes currentsite conditions will be unchanged except forimplementation of a groundwatermonitoring program to assess the status ofthe groundwater plume. The no actionalternative is required to be consideredunder CERCLA to provide a baseline forcomparison to the other proposedalternatives.

Alternative 2

• Containment: This alternative consists ofcontainment of groundwater and wastewithin the present boundaries of thecontamination.

Alternative 3

• A-Aquifer Cleanup and Landfill Capping:Under this alternative, groundwaterextraction wells are screened only in theA-aquifer, with a system designed toachieve groundwater and chemical removalas well as containment in the A-aquifer. Thisalternative also includes construction of alandfill cap to minimize exposure, and reuseor recharge of treated water to thesubsurface.

Alternative 4

• A-Aquifer Cleanup and Landfill Capping –Interim Action on the 180-Foot Aquifer: Inaddition to the actions identified inAlternative 3, this alternative includesremoval and treatment of groundwater andchemicals from the 180-foot aquifer.

Alternative 5

• A-Aquifer Cleanup and Removal,Treatment, and Disposal of Landfill Waste –Interim Action on 180-foot Aquifer:Groundwater from both the A- and 180-footaquifers is removed and treated as inAlternative 4. Instead of capping, the wastefrom the landfill areas is excavated using

conventional earthmoving equipment. Theexcavated waste is then segregated anddisposed according to current regulations.

Selected Remedy

The Army’s preferred cleanup for OU 2 wasAlternative 4: Upper Aquifer Cleanup andLandfill Capping - Interim Action on the180-Foot Aquifer. The Federal FacilitiesAgreement (FFA) parties approved Alternative4, and a ROD for OU 2 was signed by the FFAparties in August 1994. The followingdocuments identified additional remediationcriteria that were not specified in the OU 2ROD:

Explanation of SignificantDifferences (ESD) 1

In August, 1995, the Explanation of SignificantDifferences, Operable Unit 2, Fort Ord Landfills(U.S. Army, 1995c) was signed. This ESDfinalized the 180-foot aquifer cleanup goalsconsistent with those established for theA-aquifer in the OU 2 ROD.

ESD 2

In August, 1996, the Explanation of SignificantDifferences, Area A, Operable Unit 2, Fort OrdLandfills (U.S. Army, 1995d) was signed. ThisESD addressed the identification of cleanupcriteria for areas outside the main landfill thatwould be excavated and consolidated within themain landfill boundaries.

ESD 3

In January 1997 the Explanation of SignificantDifferences, Consolidation of RemediationWaste in a Corrective Action Management Unit(CAMU), Operable Unit 2, Fort Ord Landfills(U.S. Army, 1997a) was signed. This ESDaddressed soil and debris (remediation waste)that would be excavated from remediation areasat Fort Ord and consolidated within the mainlandfill boundaries.



6.2.2 RemedyImplementation

Landfill Cap

A cap has been constructed over the mainportion of the landfill containing debris. Anapproximate 25-acre area of the landfill (AreaA) was excavated and transferred to the mainportion of the landfill to consolidate the debris inone area. This soil consolidation action allowedfor clean closure of Area A, which is nowavailable for unrestricted use (IT, 2001a). Theremaining areas of the landfill (Cells B, C, Dand F) have been closed, and they are coveredby a landfill cap constructed after consolidationactivities were completed. A seven-acre portionof Area E is covered with an interim cap, butwill be completely closed pending completion ofsoil excavations at Range 18.

Groundwater Treatment

A groundwater treatment facility wasconstructed in 1995 to remediate groundwaterunderlying the landfill. Remediation is expectedto take about 30 years. During the operation ofthe treatment system, groundwater is sampled toconfirm that the treatment system is operatingeffectively. Since 1995, groundwater sampleshave been collected and analyzed every threemonths. This information has been compiledinto quarterly and annual reports to show thelong-term trends of system operation.


Landfill Cap

Operations and maintenance of the landfillincludes inspection and maintenance of thelandfill cover, landfill gas vents surveymonuments, and settlement plates; and erosionand drainage control. Landfill gas emissions andlandfill cover settlement are also monitoredperiodically (IT, 2000a).


Operations and maintenance have kept the OU 2groundwater treatment system functioning inaccordance with design parameters since theinception of operations in 1995. The OU 2groundwater remedy is operated in accordancewith the Work Plan, Revision 0, Operation andMaintenance, Groundwater Treatment Systems,former Fort Ord, California (Harding ESE/IT,2000a) and Sampling and Analysis Plan,Revision 1, Operable Unit 1, Operable Unit 2,and Sites 2 and 12 Groundwater TreatmentSystems, Former Fort Ord, California (HardingESE/IT 2001 e). Operations and maintenanceactivities are summarized for every three-monthquarterly period in treatment system datasummary reports. The most recent quarterlyreport describing OU 2 operations andmaintenance is the Quarterly GroundwaterTreatment Systems Operation Data SummaryReport, July through September 2001, OperableUnit 1, Operable Unit 2, Sites 2/12, Former FortOrd, California (Harding ESE/IT 2001 c). Todate, the system has processed over 1.77 billiongallons of water and removed over 240 poundsof contaminants, of which approximately 63percent is TCE. The system operatescontinuously except for periods of routinemaintenance, carbon servicing, and replacementof worn equipment. To date, the system has beenin operation approximately 97% of the time.Carbon replacement in the system has occurredapproximately every 2 to 4 months sinceoperation began.

The OU 2 groundwater treatment systemoriginally consisted of carbon adsorptionfollowed by catalyzed ultraviolet chemicaloxidation (UV-Ox) polishing. The carbonadsorption was accomplished using two 20,000-pound carbon vessels connected in series. Theoriginal system extracted water from two Upper180-foot aquifer extraction wells and 13A-aquifer extraction wells to produce a totalflow of approximately 600 gallons per minute(gpm). Following treatment, the extracted waterwas injected back into either the A-aquifer orUpper 180-foot aquifer.



Expansion of the OU 2 treatment system wasinitiated following discovery that the aquiferarea with COCs greater than ACLs was largerthan originally recognized during thegroundwater treatment system design. Hydrauliccapture of the resulting plume by the originalsystem was not complete, and a systemexpansion was initiated to enable completeplume capture and fulfill the remediationobjectives of the OU 2 ROD. Groundwatermonitoring is continuing throughout the OU 2treatment area and within all the effectedaquifers to evaluate changes that may resultfrom the expanded system and to monitor theeffectiveness of the remedy.

System modifications were completed in April2001, in accordance with the GroundwaterRemedial Action Work Plan, Operable Unit 2Groundwater Remedy System Expansion (IT,1999d). Modifications included removal of theUV-Ox system, installation of a second set oftwo additional 20,000-pound carbon vesselsconnected in series, and installation of sevenadditional extraction wells. A portion of the OU2 effluent is piped to the Sites 2/12 area and isinjected with the Sites 2/12 effluent.


6.3.1 Question A


Landfill Cap

The landfill cap is functioning as intended.


The OU 2 groundwater remedy is functioning asintended. Both the original system installed in1995 and the expanded system completed in2001 achieved the groundwater extraction andtreatment design parameters described in designdocuments. System operation has beenrelatively constant (97% of the time) sincesystem startup in 1995. Details regardingoperation and system performance are described

in the Annual Evaluation Report, October 1999Through September 2000, OU 1 and OU 2Groundwater Remedies, Revision 0, FormerFort Ord, California (Harding ESE/IT, 2001b).

Statistical evaluation of data obtained from OU2 treatment system influent samples indicate thatconcentrations are generally decreasing overtime. The influent chemistry data indicates thatthe OU 2 groundwater remedy is effectivelyreducing the total mass of COCs in groundwater,and is functioning in accordance with theobjectives stated in the OU 2 ROD (Army,1994c), Final Record of Decision, Operable OU2, Fort Ord Landfills Army, Fort Ord,California, dated July 15.

The expanded OU 2 groundwater remedy isoperating at the designed flow rates. Based onmonitoring performed since systemmodification, it appears to have achievedhydraulic capture of the groundwater containingCOCs at concentrations above ACLs. Thegroundwater contaminant mass within thehydraulic capture area is expected to beadequately addressed by the existing remedy.

Opportunities for future system optimizationinclude discontinued groundwater pumping fromindividual wells where cleanup goals (ACLs)have been attained. Ending extraction at anindividual well will allow for increasedextraction from other existing wells and willreduce operations and maintenance costsassociated with the well.

6.3.2 Question B


Landfill Cap

The exposure and toxicity criteria used toevaluate health risks are still valid.




The property in and around the OU 2 plume areahas been transferred for civilian use. However,land use has not changed sufficiently to alter theexposure assumptions that were used during theoriginal risk assessment and development ofACLs. The aquifer cleanup levels for the COCsidentified in the OU 2 ROD were based on Stateor federal MCLs with the exceptions ofchloroform, 1,2-dichloropropane,tetrachloroethene, and vinyl chloride, for whichthe ACLs are lower than State or federal MCLs.The lower ACLs were based on risk calculationsfor each COC that estimated a combined excesscancer risk of 6 x10-5 (Dames and Moore, 1993).Since the original risk assessment, the State orfederal MCLs that were selected as ACLs havenot changed, and toxicity values for theadditional calculated ACLs have not changed,with the exception of vinyl chloride. Thetoxicity values for vinyl chloride are still withinthe parameters used for the original riskcalculations, and the ACLs designated for OU 2remain protective of human health and theenvironment.

6.3.3 Question C


Landfill Cap

Perimeter gas probes indicated that landfill gasconcentrations exceed the regulatory standardsalong the eastern boundary of Cell F. Migrationof landfill gas is addressed by CaliforniaIntegrated Waste Management Boardregulations for Solid Waste Landfills, Title 14California Code of Regulations, Chapter 3,Article 7.8 – an ARAR as identified in the OU 2ROD.” A landfill gas extraction and treatmentsystem pilot study is in progress. Ambient airmonitoring near the closest residence (368 feetfrom the landfill perimeter) has been initiated.The treatment system appears to be successfullyremediating the landfill gas problem.


The OU 2 groundwater remedy has consistentlyoperated in accordance with either the originaldesign or the more recent system expansiondesign. Current system operation is compliantwith the objectives of the OU 2 ROD, and isprotective of human health and the environment.To date, the system has processed over 1.77billion gallons of water and removed over 240pounds of contaminants. In the 5 years ofoperation, the OU 2 remedy has reduced theaverage TCE concentration influent to thetreatment plant from approximately 20 parts perbillion to approximately 10 parts per billion, anda trend of decreasing concentrations of COCsappears to be continuing.

6.4 Issues

Landfill Cap

A portion of landfill Cell E has not been closed.Final closure of this cell is scheduled for late2002 after excavation of soil at Range 18.

Landfill gas is monitored around all landfill cellsand meets regulatory requirements, with theexception in the vicinity of the eastern boundaryof Cell F, where the landfill gas extractionsystem is operating.


This technical assessment did not identify anyissues that could affect current or futureprotectiveness of the groundwater remedy.Additionally, this assessment did not identifyany unresolved issues previously raised byregulatory agencies, the community, or otherinterested parties.


Landfill Cap

Completed closure of landfill Cell E and prepareclosure report for the OU 2 Landfill. Continueoperation of the landfill gas treatment system



until landfill gas levels remain below regulatorystandards. Continue to inspect and monitor theOU 2 Landfill in accordance with the PostClosure Operation and Maintenance Plan (IT,2000a).


The OU 2 Groundwater Remedy shouldcontinue to be implemented as designed untileither ACLs are reached or the next technicalassessment is conducted.


The OU 2 groundwater remedy is compliantwith ARARs and is expected to be protective ofhuman health and the environment uponattainment of the ACLs. The groundwater

remedy is actively maintaining hydraulic controlof the VOC plume areas and reducing levels ofCOCs in groundwater. All transferring parcels,which are located over the groundwater plume,will include a Covenant To Restrict Use OfProperty (CRUP) recorded with the deed. TheCRUP will prohibit construction of wells forinjection or extraction of any groundwater untilthe ACLs are attained. In addition, there is aMonterey County ordinance that regulates waterwell installation within either the “GroundwaterProhibition Zone” or “GroundwaterConsultation Zone” which include the knowngroundwater plumes at the former Fort Ord.

The OU 2 landfill remedy is compliant withARARs, with the addition of the landfill gastreatment system, and is expected to beprotective of human health and the environment.


7.0 BASEWIDE REMEDIAL INVESTIGATION SITES ROD

This section presents background information onthe Basewide Remedial Investigation sites; asummary of remedial actions and a technicalassessment of the actions taken at these sites;identifies any issues related to the protectivenessof the remedies based on the review; presentsrecommendations and follow-up actions, ifneeded, to address issues identified during thereview; and provides a statement regarding theprotectiveness of the site remedies.

7.1 Sites 2/12

7.1.1 Background

7.1.1.1 Site 2 - Main GarrisonSewage TreatmentPlant (MGSTP)

The Main Garrison Sewage Treatment Plant(MGSTP) occupied an unpaved area ofapproximately 28 acres west of Range Roadbetween Trainfire Range No. 9 and Stilwell Hall(Plate 2). The MGSTP was the primary sewagetreatment facility for Fort Ord, serving themajority of the housing areas and the mainindustrial areas from the late 1930s until May1990 when it was decommissioned. The formertreatment facility was fenced and containedseveral buildings and two large trickling filters.Outside of the fenced area were three unlinedsewage ponding areas and 10 asphalt-linedsludge-drying beds. During operation, effluentfrom the MGSTP was discharged under aNational Pollutant Discharge EliminationSystem (NPDES) permit to a storm drain thatemptied onto Indianhead Beach during low tideand discharged to Monterey Bay during hightide. Sewage from Fort Ord now flows viagravity feed to a pumping station in Marina andis then pumped to the Monterey RegionalTreatment Plant (MRTP), also in Marina.Potential contaminants associated with theformer MGSTP included metals, pesticides, andhydrocarbons.

7.1.1.2 Site 12

The four major areas of Site 12 include theLower Meadow Disposal Area, the Departmentof Logistics (DOL) Automotive Yard, theCannibalization Yard, and the Southern PacificRailroad Spur, as described below (Plate 2).

Lower Meadow Disposal Area

The Lower Meadow was a grassy field ofapproximately 2 acres east of Highway 1 nearthe Twelfth Street gate. The site is bounded tothe east by the DOL Automotive Yard and to thewest by First Avenue. The Lower Meadow wasapproximately 5 feet lower than the DOLAutomotive Yard and received runoff from it.Several drainpipes (including Outfall 31) are inthe southeast corner and the eastern side of thesite. It is uncertain if the pipes were designed asdrainage lines. No buildings were present in theLower Meadow. The Lower Meadow waspreviously used to dispose of waste materialsuch as scrap metal, oil, and batteries generatedby the DOL. The area also appeared to containroad construction waste. Contaminated soils andassociated debris were excavated during cleanupactivities at the site, and the area was backfilledwith clean soil.

DOL Automotive Yard

The DOL Automotive Yard is east of Highway 1and northeast of the Southern Pacific RailroadSpur (SPRR) that runs east from First Avenue.The 8.5-acre fenced site is bounded by TwelfthStreet to the north and the Lower Meadow to thewest. The site included a paint shop, two washracks, one temporary hazardous waste containerstorage area, an oil/water separator, anaboveground storage tank (AST), and severalbuildings used for automotive repair. The site ispaved and slopes gently to the west. Previoussite activities included transmission repair,degreasing, engine testing, steam cleaning andwashing vehicles, and petroleum/oil/lubricant

Basewide Remedial Investigation Sites ROD


(POL) storage. A buried container, which wasoriginally used as a muffler for exhaust fromengine testing, may also have been used forliquid waste storage. Tanks and contaminatedsoils were excavated during cleanup activities atthe site, and the area was backfilled with cleansoil.

Cannibalization Yard and IndustrialArea

The Cannibalization Yard is a small (0.5-acre)paved and fenced area located within the larger(18.5 acre) paved and fenced Industrial Area.The entire 18.5-acre area is bounded byHighway 1 to the west, a baseball field to theeast, and Tenth Street to the south. The SPRRspur separates the Industrial Area from the DOLAutomotive Yard to the north. The area includeda machine shop, a furniture repair shop, alaundry facility, a temporary hazardous wastecontainer storage area, an oil/water separator,and an aboveground storage tank (AST) used forstoring waste oil. Beginning in 1964, theCannibalization Yard was used to disassembleold equipment, primarily decommissionedmilitary vehicles. Used motor oil was collectedand stored onsite in 55-gallon drums. BetweenJanuary 1988 and August 1988, waste oil wasstored in a 450-gallon AST in the hazardouswaste storage area at the machine shop adjacentto the yard. Other vehicle maintenance activitiesincluded removal and storage of the followingtypes of fluids and parts gasoline (leaded andunleaded), diesel fuel, brake fluid, asbestos-containing brake shoes and linings,antifreeze/coolants, lead and acid from batteries,lubricating greases, and transmission fluids.Prior to the installation of the oil/water separatorat the northeast corner of the yard, runoff fromthe site flowed down the sloped area northeast ofthe Cannibalization Yard toward the baseballfield. The site is no longer active, andcontaminated soils were excavated duringcleanup activities at the site, and the area wasbackfilled with clean soil.

Southern Pacific Railroad (SPRR)Spur

The SPRR spur (part of Site 13), an area ofapproximately 0.8 acres, consisted of the right-of-way along a portion of the railroad spur thatextends northward from the Southern PacificRailroad track west of Highway 1 and curveseast through an industrial complex. The portionof the railroad track discussed here extends eastfrom the main track east of Highway 1, acrossFirst Avenue, and between the DOL AutomotiveYard and the Cannibalization Yard andsurrounding Industrial Area. The rest of therailroad spur was investigated during thecharacterization of Site 13. The relatively flatright-of-way is mostly unpaved except in theareas adjacent to loading docks and where thespur crosses First Avenue. The railroad spur wasused to transport troop materials and equipmentfrom the main rail line to storage facilitiesbetween the DOL Automotive Yard and theIndustrial Area. The SPRR spur is of concernbecause oil or fuels may have been sprayed inthis area for dust control. Contaminated soilswere excavated during cleanup activities at thesite, and the area was backfilled with clean soil.

7.1.2 Remedial Actions

One groundwater and three soil remedial unitswere defined at Sites 2 and 12, as describedbelow.

Groundwater Remedial Unit (VOCPlume at Sites 2 and 12)

The groundwater remedial unit is defined asgroundwater at Sites 2 and 12 containing thedissolved volatile organic compounds (VOCs)TCE, 1,2-dichloroethane (DCA), dichloroethene(DCE), and tetrachloroethene (PCE) that exceedaquifer cleanup levels (ACLs).

The vertical extent of the affected groundwaterranges from the top of the water table to the topof the sandy silt layer that divides the 180-footaquifer into upper and lower zones. The



affected water-bearing zone beneath Sites 2 and12 is the Upper 180-foot aquifer, which is theuppermost water-bearing zone in the vicinityand has approximately 75 to 80 feet of saturatedthickness. Depth to water is approximately 70 to80 feet below ground surface (bgs) at the easternedge of the plume (Site 12) and approximately40 feet bgs at the western edge (Site 2). Thesandy silt layer dividing the 180-foot aquiferappears to have limited vertical migration ofdissolved VOCs.

Soil Remedial Unit 1 (LowerMeadow Disposal Area)

The Lower Meadow Disposal Area is anapproximately 0.5-acre portion of the LowerMeadow on Site 12, a grassy field east ofHighway 1 near the Twelfth Street Gate definedas Soil Remedial Unit 1 (SRU 1), whichcontained concrete rubble and other constructiondebris intermixed with total petroleumhydrocarbon (TPH)-contaminated soil.

Soil Remedial Unit 2 (Outfall 31Area)

Soil Remedial Unit 2 (SRU 2) was defined asthe Outfall 31 Area east of SRU 1, a grass-covered depression that received surface runoffand storm drainage flow from Outfall 31 andseveral other pipes. It had a catch basin area thatcollected precipitation and rainfall runoff. Thecatch basin was connected to subsurface piping,which ran to the west from the Outfall 31 Areato Outfall 15. The primary contaminants in soilassociated with the outfall included totalpetroleum hydrocarbons (TPH) of unknownorigin (TPH-unknown) and as diesel (TPH D).

Soil Remedial Unit 3(Cannibalization Yard Area)

Soil Remedial Unit 3 (SRU 3) was theCannibalization Yard Area. This area was ashallow surface drainage subject to runoff fromthe DOL Automotive Yard, and the IndustrialArea to the west and south, respectively. Surface and shallow borings near an oil/water

separator and along the eastern margin of theCannibalization Yard indicated shallow soilcontained elevated concentrations (greater than500 mg/kg) of TPH. No TPH concentrationsgreater than 500 mg/kg were detected in soilsamples collected below 0.5 feet below groundsurface. The vertical and horizontal limits weredefined by soil borings and surface samples.

7.1.2.1 Remedy Selection

Sites 2 and 12: Description ofAlternatives

The following four remedial alternatives wereevaluated in the Sites 2 and 12 Feasibility Study.

Alternative 1

• No action other than groundwater andsurface water outfall monitoring. The noaction alternative is required to beconsidered under CERCLA to provide abaseline for comparison to the otherproposed alternatives.

• Assumes long-term monitoring program forexisting groundwater wells and two surfacewater outfalls.

Alternative 2

• Extraction of groundwater containing VOCsabove cleanup goals and discharge ofuntreated groundwater to a Publicly OwnedTreatment Works (POTW).

• Deed restriction on groundwater use.

• Capping and surface water controls for soilat the Lower Meadow Disposal and OutfallAreas, which would prevent leaching ofchemicals to groundwater.

• Excavation of approximately 1,000 cubicyards of shallow soil containingconcentrations of TPH above the cleanuplevel of 500 milligrams per kilogram(mg/kg) from the Cannibalization Yard, andplacement at the OU 2 landfill.



Alternative 3

• Groundwater extraction and treatment bygranular activated carbon.

• Disposal of treated groundwater by: (1)reuse aboveground, or (2) injection orinfiltration of treated water back into theaquifer.


• Capping of debris and selective excavationof approximately 1,600 cubic yards of soilcontaining TPH concentrations above thecleanup goal of 500 mg/kg from the LowerMeadow Disposal Area, and placement atthe OU 2 landfill.

• Excavation of approximately 3,800 cubicyards of soil containing TPH concentrationsabove the cleanup goal of 500 mg/kg fromthe Outfall Area and Cannibalization Yard,and placement at the OU 2 landfill.

Alternative 4

• Groundwater extraction, treatment, anddisposal as described for Alternative 3.


• Excavation of approximately 16,000 cubicyards of soil and debris containing TPHconcentrations above the cleanup goal of500 mg/kg from the Lower MeadowDisposal Area, and placement at the OU 2landfill.

• Excavation of approximately 3,800 cubicyards of soil containing TPH concentrationsabove the cleanup goal of 500 mg/kg fromthe Outfall Area and Cannibalization Yard,and placement at the OU 2 landfill.

Selected Remedy

Alternative 4 was selected as the remedy inaccordance with the EPA’s nine evaluationcriteria because it provided the greatest degree

of protection for the environment, removed anypotential unknown risks associated with debris,complied with ARARs, was effective in theshort and long term, was cost effective, and wasreadily implementable.

7.1.2.2 RemedyImplementation

Soil Remedy

The soil component of the remedy wasaddressed in accordance with approved plans(HLA, 1995f) by a series of soil removal actionswhich were completed and are documented inRemedial Action Confirmation Report and Post-Remediation Health Risk Assessment, Site 12Remedial Action, Basewide Remediation Sites,Fort Ord, California (IT, 1999c). The soilremediation resulted in the site being availablefor unrestricted reuse.

Groundwater Remedy

Construction of a groundwater pump and treatsystem was initiated in April 1999 to remediatethe plume of COCs in groundwater.Remediation is expected to take about 30 years.During the operation of the treatment system,groundwater has been sampled biweekly toverify that the treatment system is operatingeffectively. Since 1999, water samples and waterlevels from groundwater monitoring wells havebeen collected every three months. Thisgroundwater monitoring information has beencompiled into quarterly and annual reports toshow the long-term trends resulting from systemoperation.

The groundwater treatment system componentsinclude groundwater extraction, aqueous phasecarbon adsorption treatment of groundwater, andsubsurface injection of treated groundwater. Thecarbon adsorption is accomplished using two10,000-pound carbon vessels connected inseries. The Sites 2/12 groundwater remedyconsists of eight extraction wells located at Site12, the groundwater treatment plant, and fiveUpper 180-foot aquifer recharge structures (2injection wells and 3 infiltration galleries)



located at Site 2. Extracted groundwater is pipedto the 2/12 Groundwater Treatment Plant(GWTP) where it undergoes pH adjustment bysulfuric acid addition and subsequent treatmentof COCs via adsorption to granular activatedcarbon. Treated water from Site 12 extractionand OU 2 extraction is combined at the 2/12GWTP and piped to the Site 2 aquifer rechargeinjection structures where it is injected into theUpper 180-foot aquifer. The performance goalof the design is groundwater extraction andhydraulic capture of the VOC plume whilemaintaining a groundwater mound at the Site 2injection area adjacent to Monterey Bay. Thepurpose of the groundwater mound is to preventadditional seawater intrusion into the 180-footaquifer as a result of groundwater extraction atSite 12.

The extraction capacity of the eight extractionwells was designed to allow for systemoperation flexibility in the event that salinegroundwater (seawater) infiltrated Site 12extraction wells. It was anticipated that ifseawater appeared to be drawn toward or arrivedat a Site 12 extraction wells, the extraction atthat well would be reduced or discontinued andcompensated for by an increased extraction rateat another extraction well assumed to have alesser effect on saltwater movement intogroundwater in the plume.

During the initial 3-month period of systemoperation, vinyl chloride concentrations greaterthan anticipated were observed in extractedgroundwater from individual wells and in thecombined influent to the Granular ActivatedCarbon (GAC) treatment system. Vinyl chloridetwice exceeded the discharge compliance limitof 0.1 :g/L at the treatment system effluentsampling point. In response to the dischargeexceedances, operational changes wereimplemented that used the extraction flexibilitydesigned into the system to comply withdischarge limits. The modifications consisted ofreducing flow from extraction wells in whichvinyl chloride was elevated, and moving thedischarge compliance sampling point to alocation that included both the treated OU 2 andSites 2/12 water. Following the operational

changes, no vinyl chloride or any other COCdischarge exceedances have occurred.

System adjustments in response to the elevatedvinyl chloride discharges included adjustment ofextraction well flow rates and temporaryshutdown of five extraction wells. As individualextraction wells were shut off, flow rates of theremaining wells were increased to maximizetotal system extraction. In addition, extractionpumps in extraction wells EW-12-04-180U andEW-12-04-180M were replaced with largerpumps to increase pumping rate capacities.Current extraction system operation consists ofthree wells pumping at a combined total ofapproximately 240 gallons per minute (gpm).

Treated water was initially supplied to the Site 2aquifer injection structures only by the Sites2/12 treatment plant while the pipeline to OU 2was being constructed. Piping connectionsbetween the OU 2 treatment system and theSites 2/12 system were completed in June 1999,and excess treated OU 2 water was initiallydiverted to the Site 2 aquifer injection structuresin July 1999. Additional plumbing modificationsto the OU 2 transfer pipeline were completed onOctober 1999, allowing increased transfer rates.The Sites 2/12 system currently requires theaddition of OU 2 treated water to the 2/12system discharge stream to maintain vinylchloride discharge compliance.

A temporary discharge limit modification forvinyl chloride was requested and granted by theregulatory agencies for a period of one-yearstarting in March of 2002. The discharge limitwas temporarily changed from 0.1 ug/L to 0.5ug/L to allow for the operation of extractionwells currently not operating due to the 0.1 ug/Lvinyl chloride discharge limit. The temporaryoperation of the groundwater remediationsystem at the elevated discharge limit isexpected to allow for accelerated chemical massremoval.

A pilot study evaluating the effectiveness of in-situ chemical oxidation of vinyl chloride in Sites2 and 12 groundwater was initiated in March2002. Vinyl chloride concentrations in



groundwater observed at some of the Sites 2 and12 extraction wells are in excess of the Sites 2and 12 groundwater treatment systemcapabilities and are not effectively remediatedby the GAC treatment. The in-situ oxidationpilot study is designed to evaluate the use ofpotassium permanganate to preferentiallyoxidize vinyl chloride in-situ as a pretreatmentfor the existing GAC treatment system. The pilotstudy evaluation is expected to be completed byOctober 2002.

All transferring parcels, which are located overthe groundwater plume, will include a CovenantTo Restrict Use Of Property (CRUP) recordedwith the deed. The CRUP will prohibitconstruction of wells for injection or extractionof any groundwater until the ACLs are attained.In addition, there is a Monterey Countyordinance that regulates water well installationwithin either the “Groundwater ProhibitionZone” or “Groundwater Consultation Zone”which include the known groundwater plumes atthe former Fort Ord.

7.1.2.3 System Operations andMaintenance

The Sites 2 and 12 groundwater treatmentsystem has been in operation since April 1999.The Sites 2 and 12 groundwater remedy isoperated in accordance with the Work Plan,Revision 0, Operation and Maintenance,Groundwater Treatment Systems, former FortOrd, California (Harding ESE/IT, 2001a) andSampling and Analysis Plan, Revision 1,Operable Unit 1, Operable Unit 2, and Sites 2and 12 Groundwater Treatment Systems,Former Fort Ord, California (Harding ESE/IT,2001e). Operations and maintenance activitiesare summarized in treatment system datasummary reports for every three-month quarterlyperiod. The most recent quarterly reportdescribing Sites 2 and 12 operation andmaintenance is Quarterly GroundwaterTreatment Systems Operation Data SummaryReport, July through September 2001, OperableUnit 1, Operable Unit 2, Sites 2/12, Former FortOrd, California dated November 29,2001(Harding ESE/IT, 2001c). The report

summarizing the entire period of systemoperation is Revision C, Sites 2 and 12Groundwater Remedy, Operating Properly andSuccessfully Evaluation Report Former FortOrd, California dated November 8, 2001(Harding ESE/IT, 2001d). To date, the systemhas processed over 300 million gallons of waterand removed over 130 pounds of contaminants,of which approximately 60 percent is TCE. Thesystem operates continuously except for periodsof routine maintenance, carbon servicing, andreplacement of worn equipment, and has beenoperational approximately 93% of the time.Carbon replacement in the system has occurredapproximately every 2 to 3 months sinceoperation began.

7.1.3 Technical Assessment

7.1.3.1 Question A


The Sites 2 and 12 groundwater remedy isfunctioning as intended, and is achieving theperformance goals of the original conceptualdesign. An analysis of system performance todate is provided in Revision C, Sites 2 and 12Groundwater Remedy, Operating Properly andSuccessfully Evaluation Report Former FortOrd, California (Harding ESE/IT, 2001d).

The Sites 2 and 12 system operation dataindicate the system has been pumping, treating,and discharging water in accordance with theapproved plans. The system has extracted waterat an average rate of 211 gallons per minute(gpm) and recharged water at an average rate ofapproximately 513 gpm (including effluent fromthe OU 2 treatment system). Groundwaterchemistry monitoring data indicate thecontaminant plume is decreasing in size as aresult of Sites 2/12 groundwater remedyoperation. Evaluation of water-level dataindicates the presence of hydraulic featuresresulting from system operation that areconsistent with hydraulic capture and an inwardgradient throughout the plume.



The groundwater flow modeling of systemoperation indicates the groundwater remedy isreversing the original hydraulic gradientbetween Sites 2 and 12 and is hydraulicallycapturing the plume in this area. Although thesimulated groundwater streamlines do nottraverse areas east of EW-12-01-180 and EW-12-02-180, the presence of the plume in this areais uncertain. The interpreted presence of theplume in this eastern area is uncertain due to thelarge distances between the extraction wellsEW-12-01-180 and EW-12-02-180 and easternmonitoring wells MW-12-03-180 and MW-12-09-180 and chemical contouring procedures. Inview of this uncertainty in the area east of EW-12-01-180 and EW-12-02-180, conclusionsabout hydraulic capture in this area can not bemade. The Army is evaluating techniques toincrease groundwater extraction from EW-12-01-180 and EW-12-02-180 to increase the areaof hydraulic capture and accelerate remediation.Increasing the pumping rates and resulting areaof hydraulic capture will compensate for theuncertainties associated with the existingmonitoring net work.

7.1.3.2 Question B


Land use has not changed sufficiently to alterthe exposure assumptions that were used duringthe original risk assessment and development ofACLs. The aquifer cleanup levels for the COCsidentified in the OU 2 ROD were based on Stateor federal MCLs with the exceptions ofchloroform, 1,2-dichloropropane,tetrachloroethene, and vinyl chloride, for whichthe ACLs are lower than State or federal MCLs.The lower ACLs were based on risk calculationsfor each COC that estimated a combined excesscancer risk of 6 x10-5. Since the original riskassessment, the State or federal MCLs that wereselected as ACLs have not changed, and toxicityvalues for the additional calculated ACLs havenot changed, with the exception of vinylchloride. The toxicity values for vinyl chloride

are still within the parameters used for theoriginal risk calculations, and the ACLs remainprotective of human health and the environment.

7.1.3.3 Question C


The Sites 2 and 12 groundwater remedy isachieving the performance goals of the originaldesign, reducing concentrations and the arealextent of COCs. Current system operation iscompliant with the objectives of the BasewideROD.

7.1.4 Issues

This technical assessment did not identify anyissues that could affect current or futureprotectiveness of the Sites 2 and 12 groundwaterremedy. Additionally, this assessment did notidentify any unresolved issues previously raisedby regulatory agencies, the community, or otherinterested parties.

7.1.5 Recommendations and Follow-Up Actions

The Sites 2/12 groundwater remedy shouldcontinue to operate as designed until eitherACLs are reached or subsequent evaluationindicates that a modification is in order.Opportunities for future system optimizationinclude discontinuing groundwater pumpingfrom individual wells where cleanup goals(ACLs) have been attained, and initiatingpumping from additional wells followingreduction of vinyl chloride concentrations.Ending extraction at an individual well willreduce the electricity and operations andmaintenance costs associated with that well andallow for increased extraction from otherexisting wells. Initiating extraction at wells thatare currently off line due to high concentrationsof vinyl chloride would accelerate cleanup ofCOCs in those areas.



7.1.6 ProtectivenessStatement

Soil – The remedial actions completed for soilcontamination at Sites 2/12 are protective ofhuman health and the environment for any reuse.

Groundwater – The Sites 2 and 12 groundwaterremedy is expected to be protective of humanhealth and the environment upon attainment ofthe ACLs, and in the interim, exposure pathwaysthat could result in unacceptable risks are beingcontrolled. The groundwater remedy iscompliant with ARARs and is activelymaintaining hydraulic control of thecontaminant plume and reducing levels of COCsin groundwater.

All transferring parcels, which are located overthe groundwater plume, will include a CovenantTo Restrict Use Of Property (CRUP) recordedwith the deed. The CRUP will prohibitconstruction of wells for injection or extractionof any groundwater until the ACLs are attained.In addition, there is a Monterey Countyordinance that regulates water well installationwithin either the “Groundwater ProhibitionZone” or “Groundwater Consultation Zone”which include the known groundwater plumes atthe former Fort Ord.

7.2 Sites 16 and 17

7.2.1 Background

Site 16 consists of the DOL Maintenance Yard,Pete’s Pond (a surface water drainage area), andPete’s Pond Extension. Site 17 consists of aDisposal Area and other areas (Plate 2). Sites 16and 17 were combined into one site after the firstphase of the RI activities because of the similarcontamination identified at both sites.

Site 16

DOL Maintenance Yard

The DOL Maintenance Yard was used as aheavy equipment maintenance facility from the1950s until base closure. The yard consisted of

an approximately 4.5-acre facility containingfive buildings, a former underground storagetank (UST), a steam-cleaning shed, a wash rackand associated oil/water separator, and a dieselfuel aboveground storage tank (AST). Run offfrom the DOL Yard drains in Pete’s Pond.

The following potential sources ofcontamination were identified for investigationduring the RI:

• A former UST location adjacent to Building4900

• The oil/water separator and associated washrack

• The diesel fuel AST

• Potential past spills from vehicles andequipment at the unpaved stained area nearBuilding 4900

• A former paint shop

• Storm drain inlets.

Pete’s Pond

Pete’s Pond consisted of an approximate3.3-acre triangular depression between FifthAvenue, the Fifth Avenue Cut-Off, and EighthStreet. Six storm drains discharge to Pete’sPond; although the depression is dry most of theyear, it occasionally fills with up to 5 feet ofwater for short periods of time during heavyrainfall.

The following potential sources ofcontamination were identified for investigationduring the RI:

• Past dumping activities: Before the RI,trenching performed to improve drainage atPete’s Pond encountered scrap metal and adrum containing a clear, gel-like substance.Evidence of earthwork was also observed inhistorical aerial photographs reviewedduring the RI.

• Potential chemical spill: A potentialchemical spill was identified in 1951 aerial



photographs reviewed during Phase 1 of theRI.

• Storm drain outfalls: Discharge ofpotentially contaminated stormwater toPete’s Pond was suspected.

Pete’s Pond Extension

Pete’s Pond Extension consisted of a vacant areaof approximately 3.5 acres between the DOLMaintenance Yard, Fifth Avenue, and the FifthAvenue Cut-Off. Before the RI, trenchingperformed in this area to repair a stormwaterdrain encountered stained soils and debrisincluding concrete, ordnance (a bazooka round),and other scrap metal. Evidence of earthworkand potential dumping was also observed inhistorical aerial photographs reviewed duringPhase 1 of the RI.

Site 17

Disposal Area

The Disposal Area, part of the 1400 BlockMotor Pool, consisted of an approximate 8-acrearea used from 1977 until 1994 to service,maintain, and store light and heavy trucks andother army vehicles. The area is paved withasphalt except for a landscaped area alongEighth Street and Fifth Avenue, and contains astorage building and Buildings 1481 and 1483.Information available before Phase 1 of the RIsuggested that waste, including medical debrisgenerated at a former Fort Ord hospital andincinerated at Site 17’s Building 1442(incinerator), had been disposed at the adjacentbaseball field. However, the Phase 1 RIindicated that disposal also occurred at the areanow designated as the Site 17 Disposal Area.Therefore, as part of this RI, suspectedlandfilling activities at the Disposal Area andadjacent baseball field were investigated.

Other Areas

Other areas at Site 17 that were investigatedduring the RI consist of the 1400 Block MotorPool excluding the 8-acre Disposal Area

descibed above. The following potential sourcesof contamination were identified forinvestigation during the RI:

• A former UST at Building 1426

• An oil/water separator near Building 1490

• Two reported fuel spills of unknown volumeinto a drainage ditch near the Building 1497fueling facility

• Leakage from sanitary sewer and stormdrain joints.


Description of Remedial Units

Groundwater

Because the chemical compounds ingroundwater at Sites 16 and 17 appear to beassociated with the OU 2 plume, thegroundwater is captured and treated as part ofthe OU 2 groundwater remediation and is notconsidered as a separate remedial unit for Sites16 and 17.

Soil Remedial Unit 1

SRU 1 consisted of soil impacted by TPH at theDOL Maintenance Yard and containedapproximately 1,100 cubic yards of soilexceeding the Target Cleanup level (TCL) of500 mg/kg for TPH. TPH-impacted soil wasestimated to be up to 8 feet below groundsurface and extend over an area of 4,700 squarefeet.


SRU 2 consisted of medical and miscellaneousdebris and associated impacted soil at Pete’sPond, Pete’s Pond Extension, and the Site 17Disposal Area. Approximately 3,600 cubic yardsof soil and debris was identified as requiringremediation at Pete’s Pond and Pete’s PondExtension, and the rest of the debris identified atthe Site 17 Disposal Area extended



to depths of 20 feet below ground surface with athickness of up to 15 feet containing anestimated 67,000 cubic yards of soil distributedover an area of approximately 14 acres.


The following four remedial alternatives wereevaluated in the FS.

Alternative 1

• No action would be taken at the site exceptcontinued groundwater monitoring. The noaction alternative is required to beconsidered under CERCLA as a basis forcomparison to other alternatives.

Alternative 2

• Construction of a cap over the areascontaining debris and TPH-affected soil tolimit contact and prevent surface waterinfiltration. Deed restrictions would berequired.

Alternative 3

• Excavation of soil and debris from Pete’sPond and Pete’s Pond Extension.

• Consolidation of debris from Pete’s Pondand Pete’s Pond Extension into the Site 17Disposal Area, and placement of animpermeable cover layer material and 1foot-thick layer of clean soil.

• Placement of TPH-affected soil at the OU 2landfill, or treatment at the Fort Ord SoilTreatment Area (FOSTA), with onsite reuse.

Alternative 4

• Excavation of soil and debris containingconcentrations of TPH above the cleanupgoal of 500 mg/kg from Pete’s Pond, Pete’sPond Extension, and the Site 17 DisposalArea.

• Placement of soil and debris from theseareas at the OU 2 landfill as part of thefoundation layer material.

• Placement of TPH-affected soil at the OU 2landfill.

Selected Remedy

Alternative 4 was the selected remedy based onthe assessment in the FS. Alternative 4 met thefirst two screening criteria and was judged to besuperior in the following balancing criteria:

• Long-term effectiveness and permanence

• Reduction of toxicity, mobility, and volumethrough treatment


The Army has completed the remedial action atSites 16 and 17 in accordance with CERCLAand the Basewide Remedial Investigation SitesROD (U.S. Army, 1997b). The remedial actionincluded removing debris and soil contaminatedwith TPH. Approximately 27,770 cubic yards ofimpacted soil was removed from Site 16, andapproximately 107,000 cubic yards of soil wereremoved from Site 17. The soil was placed inthe OU 2 Landfill, Area E, as general fill. Allfinal confirmation samples contained less than500 mg/kg of TPH. Field personnel observedand documented the removal of all debris,stained or odorous soil from the excavation. Thepost remediation risk assessment recommendedthat restrictions on land use at these sites was notwarranted based on the analysis of the finalconfirmation soil samples results (IT, 1999a).The soil remediation resulted in the site beingavailable for unrestricted reuse.


There are no ongoing activities related to theremedy that require operations and maintenance.




7.2.3.1 Question A


The completed remedial actions continue toallow unrestricted use at Sites 16 and 17.

7.2.3.2 Question B


The cleanup levels for TPH were based on theFort Ord preliminary remediation goal (PRG) of500 mg/kg for TPH. Because there is no EPARegion IX PRG for TPH, the Fort Ord PRG forTPH is still valid.

7.2.3.3 Question C


There is no new information that calls intoquestion the effectiveness of the remedy.

7.2.4 Issues

A deed restriction will be placed on the propertyprohibiting drilling of wells because the sites arelocated over the OU 2 Landfill groundwaterplume.

7.2.5 Recommendations andFollow-Up Actions

There are no recommendations or follow-upactions.


The post-remediation risk assessment indicatedthat the implemented remedy was protective of

human health and the environment for any reuse(IT, 1999a). None of the associated health riskcriteria have changed, therefore the remedycontinues to be protective of human health andthe environment. All transferring parcels, whichare located over the groundwater plume, willinclude a Covenant To Restrict Use Of Property(CRUP) recorded with the deed. The CRUP willprohibit construction of wells for injection orextraction of any groundwater until the ACLsare attained. In addition, there is a MontereyCounty ordinance that regulates water wellinstallation within either the “GroundwaterProhibition Zone” or “GroundwaterConsultation Zone” which include the knowngroundwater plumes at the former Fort Ord.

7.3 Site 31

7.3.1 Background

Site 31 is a former dump site in the southern partof the East Garrison in, and is adjacent to aravine approximately 0.2 miles southeast of theintersection of Watkins Gate Road and BarloyCanyon Road. This dump site was at theboundary of the Leadership Reaction TrainingCompound (LRTC) on the northern side of theravine. The visible extent of disposalencompassed an approximately 500-foot-longsection of the northern slope of the ravine. Thedump site was reportedly used in the 1940s and1950s. Apparently, during this time, refuse waswholly or partially incinerated in a 500-tonincinerator, which was adjacent to the ravine andthe incineration waste was dumped over the sideof the north side of the ravine.

The site is underlain by fine- to medium- sand tosilty- or clayey-sand. Undisturbed and slightlycemented sand outcrops in several areas adjacentto, and north of the ravine, as well as at the baseof the western portion of the ravine.





Groundwater

No groundwater remedial units were defined forSite 31 because no chemicals were identified insoil that pose a threat to groundwater.

Soil Remedial Unit

On the basis of the health-based level of concernfor lead (1860 mg/kg), a single soil remedial unitwas defined on the North Slope of Site 31 basedon lead contamination in the soil. The area issteep (1 foot horizontal per 1 foot vertical) andheavily vegetated. Despite the heavy vegetation,the steep slope and sandy, non-cohesive soilmake it unstable. The soil remedial unitconsisted of shallow soil (up to 3 feet belowground surface) at five sample locations wherelead in soil was above 1,860 mg/kg.

The remainder of the debris and soil at the sitehas not been shown to pose a human-health risk,and therefore does not require remediation. Inaddition, debris removal or treatment will not beperformed in these other areas of Site 31because of (1) the steep topography andinaccessibility of the ravine and associatedbiological hazards (e.g., poison oak); (2)sensitive habitat that could be disturbed; (3)overhead power lines traversing the site, whichwould make equipment difficult to maneuver;and (4) unstable soil conditions.



Alternative 1

• No action would be taken at the site. The noaction alternative is required to beconsidered under CERCLA as a basis forcomparison to other alternatives.

Alternative 2

• Excavation and segregation ofapproximately 350 cubic yards of soil anddebris containing lead above the health-based level of concern of 1,860 mg/kg.

• Placement of soil and debris at the OU 2landfill as part of the foundation layer.

• Deed restrictions.

Alternative 3

• Excavation of approximately 350 cubicyards of soil and debris containing leadabove the health-based level of concern of1,860 mg/kg, and consolidation onsite. Theconsolidated soil and debris would becapped to limit potential direct humanexposure to the waste materials and waterinfiltration and to limit offsite migration ofdebris and lead-containing soil. Deedrestrictions would be required.

Alternative 4

• Excavation of approximately 350 cubicyards of soil and debris containing leadabove the health-based level of concern of1,860 mg/kg.

• Offsite transportation and disposal at a ClassI landfill facility.

• Deed restriction.

Selected Remedy

Alternative 2 was the selected remedy based onthe assessment in the FS. Alternative 2 met thefirst two screening criteria and was judged to besuperior in the following balancing criteria:

• Long-term effectiveness and permanence

• Reduction of toxicity, mobility, and volumethrough treatment

• Short-term effectiveness




The Army has completed the remedial action atSite 31 in accordance with CERCLA and theBasewide Remedial Investigation Sites ROD(U.S. Army, 1997b). The remedial actionincluded removing soil contaminated with lead.Approximately 1,500 cubic yards of impactedsoil was removed from Site 31. The soil wasplaced in the OU 2 Landfill, Area E, as generalfill. All final confirmation samples containedless than 1860 mg/kg and therefore met thecleanup objectives defined in the ROD. The postremediation health risk assessment stated thatunacceptable human health risks and hazards areconsidered unlikely to be associated with futurerecreational, commercial, or residentialdevelopment of Site 31 under the exposureconditions evaluated (IT, 1999b). The postremediation ecological risk assessmentconcluded that significant risks to ecologicalreceptors that are exposed to chemicalsremaining at Site 31 are not expected (IT,1999b).


There are no ongoing activities related to theremedy that require operations and maintenance.


7.3.3.1 Question A


The Army has completed the remedial action atSite 31 in accordance with CERCLA and the RISites ROD, and met the objectives defined in theROD. Therefore, the remedy is functioning asintended by the decision document.

7.3.3.2 Question B

Are the exposure assumptions, toxicity data,cleanup levels and remedial action objectives

(RAOs) used at the time of the remedy selectionstill valid?

The exposure and toxicity criteria used toevaluate health risks are still valid.

7.3.4.3 Question C



7.3.4 Issues

The post remediation risk assessment concludedthat unacceptable human health risks andhazards are considered unlikely to be associatedwith future recreational, commercial orresidential development of Site 31 under theexposure conditions evaluated. The DTSCreviewer isolated an area around the remainingsoil with the highest lead concentration andcalculated an average lead concentration of 550ppm for a sample depth range of 5 to 10 feet.DTSC indicated that this concentration couldresult in a child blood level of over 10 ug/l basedon a residential scenario. DTSC stated that aland use covenant should be completed toprohibit excavation, exposure of soil and the useof the area as part of any residentialdevelopment. Based on the data present in theresponse to DTSC comment, the Army did notchange the conclusion of the post remediationrisk assessment. The land use covenant issuesassociated with Site 31 are still being negotiatedbetween the Army and DTSC.


The remedy is functioning as intended, thereforeno follow-up actions are recommended.




The post-remediation risk assessment indicatedthat the implemented remedy was protective ofhuman health and the environment (IT, 1999b).None of the associated health risk criteria havechanged, therefore the remedy continues to beprotective of human health and the environment.

7.4 Site 39 (Includes Sites5 and 9)

7.4.1 Background

Site 39 is in the southwestern portion of theformer Fort Ord and includes the Inland Ranges(approximately 8,000 acres) and the 2.36-inchRocket Range (approximately 50 acres). TheInland Ranges are bounded by Eucalyptus Roadto the north, Barloy Canyon Road to the east,South Boundary Road to the south, and North-South Road to the west. The 2.36-inch RocketRange is immediately north of Eucalyptus Road,near the north-central portion of the InlandRanges.

The Inland Ranges were reportedly used sincethe early 1900s for ordnance training exercises,including onshore naval gunfire. Over the years,various types of ordnance have been used orfound in the Inland Ranges, including handgrenades, mortars, rockets, mines, artilleryrounds, and small arms rounds. Some trainingactivities using petroleum hydrocarbons werealso conducted. The 2.36-inch Rocket Rangewas reportedly used for anti-armor (bazooka)training during and shortly after World War II.

The proposed future use of most of the InlandRanges will be as a natural resourcemanagement area (NRMA). This area will bemanaged by the U.S. Department of the Interior,Bureau of Land Management, and public accesswill be restricted. Several areas within, but alongthe periphery of, the Inland Ranges have aproposed future land use other than as a NRMA.The Military Operations on Urban Terrain(MOUT) Area, in the northeastern edge of the

Inland Ranges, are proposed for use as a peaceofficer training area. The areas along the southboundary of the Inland Ranges are proposed forseveral uses, including city and county parks, aschool expansion, and relocation of Highway 68.



Groundwater

No groundwater remedial unit was defined forSite 39 because (1) the vertical extent ofcontamination is limited to shallow soil, (2) thedepth to groundwater beneath Site 39 isestimated to range from 60 to 180 feet belowground surface, (3) the presence of potentialcontaminants (i.e., antimony and nitrates) ingroundwater has not been confirmed, and (4)groundwater data from monitoring wellsindicated there is little potential forcontamination of groundwater as a result of siteactivities.


SRU 1 includes soil with detectableconcentrations of cyclotrimethylenetrinitramine(RDX), beryllium, or TPH at or above theTarget Cleanup Levels of 0.5 mg/kg, 2.8 mg/kg,and 500 mg/kg, respectively, from the followingareas: Range 36A, Range 40A, Range 33, andthe Explosive Ordnance Target Areas.

Based on the chemical data presented in the RIfor Site 39, SRU 1 is defined by the distributionof chemicals present in the soil as discussedbelow.

• Range 40A – One area with concentrationsof TPH above the Target Cleanup Level thatconsists of approximately 175 cubic yards ofsoil.

• Range 33 – Two locations at isolated targetareas where concentrations of RDX areabove the Target Cleanup Level. Theremedial unit area extends to 2 feet below



ground surface and contains a total ofapproximately 60 cubic yards of soil.

• Explosive Ordnance Target Areas – Threegeneral areas where concentrations of RDXare above the Target Cleanup Level. Thefirst area is in the vicinity of Ranges 35, 36,and 37 and the 2.36-Inch Rocket Range andcontains approximately 30 cubic yards ofsoil. The second area is in the vicinity ofRanges 43, 45, and 48, and containsapproximately 120 cubic yards of soil. Thethird area is in the vicinity of Ranges 30 and30A and contains approximately 30 cubicyards of soil. The remedial unit areas extendto about 2 feet below ground surface andcontain a total of approximately 180 cubicyards of soil.


SRU 2 primarily includes soil containing leadabove the heath-based level of concern of 1,860mg/kg in the explosive ordnance target areas andsmall arms ranges. For the explosive ordnancetarget areas, the distribution of lead withconcentrations at or above 1,860 mg/kg definesthe remedial unit. For the small arms ranges,chemical data for lead in soil and the distributionof lead above 1,860 mg/kg is believed tocorrespond to the distribution of spentammunition based on the Site 3 investigation.Because the conditions at the small arms rangesare similar to Site 3, the same model for sitecharacterization was applied to these ranges.SRU 2 consists of the following:

• Explosive Ordnance Target Area – Twoareas in the vicinity of Ranges 37 and 48that extend to 2.5 feet below ground surface.These two areas consist of approximately 60cubic yards of soil, and include onedetection of beryllium above the TargetCleanup Level of 2.8 mg/kg.

• Small Arms Ranges – Based on visualobservations of bullet distribution madeduring the RI for Site 39, the following areasare included in the remedial unit:

– Range 19 – The sand backstop and up to100 feet behind the backstop, consistingof approximately 550 cubic yards ofspent ammunition and soil.

– Range 21 – The backstop and up to 100feet behind the backstop, consisting of1,650 cubic yards of spent ammunitionand soil.

– Range 22 – Within 1 meter of targets,this area consists of approximately 25cubic yards of spent ammunition andsoil.

– Range 23 – The fronts of the bunker andtarget areas, consisting of approximately50 cubic yards of spent ammunition andsoil.

– Range 25 – The backstop area,consisting of approximately 900 cubicyards of spent ammunition and soil.

– Range 26 – The firing lines, consistingof approximately 150 cubic yards ofspent ammunition and soil.

– Range 39 – The backstop and firinglines, consisting of approximately 550and 225 cubic yards, respectively, ofspent ammunition and soil.



Alternative 1

• No action would be taken at the site exceptcontinued groundwater monitoring. The noaction alternative is required to beconsidered under CERCLA as a basis forcomparison to other alternatives.

Alternative 2

• Institutional controls including:(1) construction of a perimeter fence to



restrict and completely enclose the remedialunits at Site 39, (2) posting of warningplacards at appropriate intervals along thefence, and (3) land use (deed) restrictionsplaced on the property for futuredevelopment.

Alternative 3

• Excavation of approximately 4,520 cubicyards of soil.

• Soil containing TPH and RDX above thecleanup goal and health-based level ofconcern of 500 and 0.5 mg/kg, respectively,would be placed at the OU 2 landfill.

• Soil containing lead and berylliumconcentrations above the health-based levelsof concern of 1,860 and 2.8 mg/kg,respectively, would be placed in the OU 2landfill.

• Deed restrictions until remaining ordnanceand explosives are removed.

Alternative 4

• Excavation of approximately 4,520 cubicyards of soil.

• Soil containing TPH and RDX above thecleanup goal and health-based level ofconcern of 500 and 0.5 mg/kg, respectively,would be placed at the OU 2 landfill.

• Soil containing lead and beryllium above thehealth-based levels of concern of 1,860 and2.8 mg/kg, respectively, would betransported offsite and disposed at a Class Ilandfill facility, and spent ammunitionwould be screened and recycled.

• Deed restrictions until remaining ordnanceand explosives are removed.

Selected Remedy

Alternative 3 was the selected remedy based onthe assessment in the FS. Alternative 3 met the

first two screening criteria and was judged to besuperior in the following criteria:

• Long-term effectiveness and permanence.

• Reduction of toxicity, mobility, and volumethrough treatment.

• Short-term effectiveness.


The remedy for Site 39 has not been fullyimplemented due to the presence of ordnanceand explosives (OE) at the site. Leadcontaminated soils were excavated from portionsof Ranges 24, 25 and 26 after the OE hazard wasremoved (IT, 2000c). The remedy will continueto be implemented as areas are cleared of OE.


There are presently no operations andmaintenance required based on the chemicalcontamination. Operations and maintenancerelated to OE issues will be evaluated in theOrdnance and Explosives RI/FS.


7.4.3.1 Question A


The remedy has not been implemented.

7.4.3.2 Question B


The remedy has not been implemented.However, criteria used for the remedial designhave not changed and remain valid.



7.4.3.3 Question C


No information has been identified that couldcall the protectiveness of the remedy intoquestion.

7.4.4 Issues

The remedy cannot be fully implemented untilordnance has been removed from the site.

The proposed future reuse of a portion of Site 39has been changed to mixed residential andcommercial development. For the developmentareas within Site 39, EPA Region IX PRGs forlead, antimony and copper are used as actionlevels.

The sampling and analysis plan for Site 39Ranges 18 and 19 proposes placement ofexcavated soil at the OU 2 Landfill, Cell E. TheArmy issued the Draft Sampling and AnalysisPlan for Characterization and RemediationConfirmation for Site 39 (Ranges 18 and 19) inApril 2002. Comments have not yet beenreceived from the regulatory agencies.

The OU 2 Landfill may not have sufficientremaining capacity to contain the excavatedsoils as stated in the selected remedy. A pilotstudy is underway to evaluate potentialtreatment options.


Remove ordnance from the site to enableimplementation of the remedy. Additionalinvestigations of small arms ranges within Site39 are being conducted under the BasewideRange Assessment (IT, 2001b)


Once implementation is complete, the remedy isexpected to be protective of human health andthe environment.

7.5 Surface Water Outfalls

7.5.1 Background

The Basewide Surface Water OutfallInvestigation (SWOI) evaluated contaminationwithin, and adjacent to, thirty-five outfalls andmanholes. The outfalls at Fort Ord are part of asurface water drainage system made up ofaboveground natural and engineered drainagesthat discharge to, or receive discharge from, thesubsurface storm drain system. Water in thedrainage system may have come in contact withareas of known historical chemical usage. Thesurface water outfalls OF-1 through OF-14,OF-16 through OF-30, OF-32, and OF-33 wereincluded in RI Sites ROD because they wereinvestigated as part of the Basewide RI/FS.

Results of the SWOI indicated that soil andsediment near or in the surface water outfallscontained the following contaminants: TPH,organic chemicals, pesticides, lead, cadmium,and polychlorinated biphenyls (PCBs).



Chemicals of potential concern (COPC) in soiland sediment from the surface water outfallswere evaluated in a Human Health ScreeningRisk Assessment (SRE). The SRE indicated thatsoil and sediment from OF-15, OF-34, andOF-35 should be removed for the protection ofhuman health. These areas were excavated underthe Interim Action program at Fort Ord (Section10.0). Details of the soil remedial activities arepresented in Section 10.2.2. No further actionwas required for the other outfalls investigated.




Soil and sediment have been removed fromOF-15, OF-34, and OF-35. The selected remedyfor the remaining outfalls was no further actionand allows for unrestricted reuse.


No operations or maintenance are necessary forthe selected remedy.


7.5.3.1 Question A


Soil and sediment were removed from 3 outfallsin accordance with the IA ROD (Army, 1994a).The SRE indicated that no further action wasrequired on remaining outfalls. Therefore, theremedy is functioning as intended by theappropriate decision documents.

7.5.3.2 Question B


There have been no changes in the physicalconditions of the site that would affect theprotectiveness of the remedy.

Changes in Standards To BeConsidered

Fort Ord specific Preliminary RemediationGoals (PRGs) listed in the No Action ROD wereused as the basis for the No Action decision. The Fort Ord specific PRGs were compared tothe most recent EPA Region IX PRGs (EPA, 1999). Four chemicals, arsenic, 1,3-dichlorobenzene, ethylbenezene, and

naphthalene, now have a published Region IXEPA PRG which are lower than the Fort Ordspecific PRGs. For arsenic, although the FortOrd-specific PRG exceeds the new EPA PRG,the exceedances are equivalent to Fort Ordbackground concentrations and therefore wouldnot require reassessment of the need forremediation. For the other three chemicals, therewere no detections at the No Action sites thatexceed either of the new EPA Region IX PRGs.

7.5.3.3 Question C



7.5.4 Issues

There are no unresolved issues pertaining to theSurface Water Outfalls that have been identifiedin regard to the protectiveness of human healthand the environment.


No follow-up actions are necessary.


Soil and sediment were removed from threeoutfalls and the remaining outfalls were found torequire no further action. Therefore, the selectedremedy is protective of human health and theenvironment and is available for unrestrictedreuse.

7.6 Site 25

7.6.1 Background

Site 25 is an 11-acre, unpaved field in the MainGarrison used from 1950 to 1972 to storedecommissioned equipment, including



transformers containing polychlorinatedbiphenyls (PCBs). It was later used for militarytraining and vehicle parking.

The Human Health Risk Assessment for soil atSite 25 evaluated exposure of a constructionworker and resident to chemicals of potentialconcern (COPCs). Based on the assessment,adverse health effects are not expected, and nofurther action was required at the site. Aquantitative Ecological Risk Assessment (ERA)was also performed (HLA, 1996l). Ecologicalimpacts were evaluated by collecting plants andanimals and measuring chemical concentrationsof COPCs in their tissues. The results of theERA indicated that tissue concentrations in preywere not likely to produce adverse effects in theanimal populations. Furthermore, tissueconcentrations in plants also did not indicate thesurrounding habitat would be adversely affected.



The risk evaluation for Site 25 indicated that nofurther action was required at this site.


The selected remedy was no further action andallows for unrestricted reuse.


No operations or maintenance are necessary forthe selected remedy.


7.6.3.1 Question A


The selected remedy for the site was no furtheraction.

7.6.3.2 Question B


The exposure and toxicity criteria used toevaluate health risks are still valid. Therefore theselected “No Further Action” remedy is stillvalid.

7.6.3.3 Question C


No new information has been identified thatcould call the protectiveness of the remedy intoquestion.

7.6.4 Issues

There are no unresolved issues pertaining to theSite 25 that have been identified in regard to theprotectiveness of human health and theenvironment.


No follow-up actions are necessary.


Because the human health and ecological riskassessments determined that adverse health andecological effects are not expected, and nofurther action was required at the site, the siteremedy is protective of human health and theenvironment and is available for unrestrictedreuse.



7.7 Site 33

7.7.1 Background

Site 33 includes the golf course maintenancearea, which consists of a pesticide mixing area,an unpaved surface drainage area, and a formerpesticide storage area. The golf course wasestablished in the early 1950s, and pesticidesand herbicides were used regularly sinceoperations began. Pesticides, herbicides, andmetals were detected in soil at concentrationsbelow Preliminary Remediation Goals (PRGs)set for reuse of this site.

The Human Health Risk Assessment for soil atSite 33 evaluated exposure of a golf coursemaintenance worker to COPCs. Based on theassessment, adverse health effects are notexpected for the proposed reuse. A quantitativeEcological Risk Assessment was also performed(HLA, 1996g). Ecological impacts wereevaluated by collecting plants and animals andmeasuring chemical concentrations of COPCs intheir tissues. Results of the ecological evaluationindicated that tissue concentrations in prey werenot likely to produce adverse effects in animalpopulations, nor would tissue concentrations inplants within the surrounding habitat beadversely affected.



The remedy for Site 33 will be a deed restrictionon the property for nonresidential use.


The remedial action was to maintain restrictionson the deed to the property for other thanresidential uses.


Periodic review of deed restrictions may berequired, and continuing five-year reviews willbe required at this site.


7.7.3.1 Question A


The remedy is functioning as intended bymaintaining deed restrictions to protect humanhealth and the environment.

7.7.3.2 Question B


The exposure and toxicity criteria that were usedfor the risk evaluation are still valid.

7.7.3.3 Question C


No additional information has been identifiedthat could call the protectiveness of the remedyinto question.

7.7.4 Issues

There is a potential for a change in the reuse ofSite 33. A deed restriction must be maintained torestrict the site to non-residential uses unless thesite is remediated to residential standards.


Maintain the deed restriction.




Maintenance of the deed restriction will limituse of the site to non-residential purposes, whichis consistent with the selected remedy for thesite, and is protective of human health and theenvironment.


8.0 SITE 3 INTERIM ROD

This section presents background information onthe Site 3 Interim ROD; a summary of remedialactions and a technical assessment of the actionstaken at this site; identifies any issues related tothe protectiveness of the remedy based on thereview; presents recommendations and follow-up actions, if needed, to address issues identifiedduring the review; and provides a statementregarding the protectiveness of the site remedy.

8.1 Background

Site 3, the Beach Trainfire Ranges, extendsapproximately 3.2 miles along the coastline ofMonterey Bay at the western boundary of FortOrd, and was used for small arms training sincethe 1940s. In general, trainees fired small armsweapons from firing lines in the eastern portionof the site toward targets spaced at varyingintervals to the west. Spent ammunitionaccumulated on the east-facing (leeward) sidesof the sand dunes that formed the “backstops”for the targets. Site 3 is proposed for reuse as astate park consisting of hiking trails,campgrounds, and ancillary facilities. Theexcavation of contaminated soil on this site iscomplete. A post remediation risk assessmentfor both ecological and human health wascompleted (HLA, 1998c, IT, 2000c). In addition,the Army will complete a proposed plan, publiccomment period, and Record of Decisionaddressing ecological risks at this site.


Soil Remedial Unit

A health-based level of concern of 1,860 mg/kgfor lead in soil was developed. Concentrations oflead above 1,860 mg/kg occur mainly in areaswhere greater than 10 percent of the surface iscovered by spent ammunition. Although someareas with moderate bullet distribution containlead above the health-based level of concern, theecological risk assessment (ERA) recommendedremediation only in areas of heavy bullet

distribution to minimize impacts to the sensitiveecological habitat in other areas. Therefore, thesoil remedial unit is defined by those areas ofheavy bullet distribution (greater than 10%).


Alternative 1

Alternative 1 consists of taking no further actionto control or remediate contamination at the site.The No Action alternative is required forconsideration under CERCLA guidance, andforms a baseline against which to compare otheralternatives.

Alternative 2

Alternative 2 consists of mechanical and handexcavation of areas with greater than 10 percentcoverage of spent ammunition and soil followedby mechanical separation using screens andgravity-feed separation techniques. In addition,spent ammunition and fragments would becleaned by a scrap metal dealer and recycled at arefinery. Depending on the residualconcentrations of lead after separation, the soilwould be treated by one of three methods:stabilization, soil washing, or asphalt batching.

Alternative 3

Alternative 3 consists of excavation andseparation as described above for Alternative 2.However, instead of recycling and treatment,spent ammunition would be recycled, and soilwould be placed in a Corrective ActionManagement Unit (CAMU) at the OU 2 landfillas foundation layer, or would be disposed of atan appropriate landfill facility. This alternativeprovides flexibility in planning and managementof the large volume of soil to be excavated fromSite 3 through consideration of two options.Disposal Option 1, placement of the soil in aCAMU at the OU 2 landfill, would meet theintent and purpose of the CAMU regulations in

Site 3 Interim ROD


that it would offer an onsite location formanagement of the soil in an innovative, cost-effective, and protective manner. DisposalOption 2, transportation, pretreatment, anddisposal at a Class I landfill, could be used inconjunction with Option 1 for excess soil notneeded for the OU 2 foundation layer.

Selected Remedy

Alternative 3 was selected as the preferredalternative because it would protect humanhealth and the environment and would complywith ARARs. It would also provide flexibility inmanagement of the large volume of soil fromSite 3, long-term effectiveness, is readilyimplementable, reduces the mobility and volumeof contamination (soil and spent ammunition),and is the most cost-effective remedialalternative if a significant volume of soil isplaced at the OU 2 CAMU.


The Army has completed the remedial action atSite 3 in accordance with CERCLA and the Site3 Interim ROD (U.S. Army, 1997c). Theremedial action included excavation of soilcontaminated with lead and associated spentammunition. Approximately 162,800 cubicyards of impacted soil were removed from Site3, of which approximately 129,200 cubic yardsof soil were transported to the screening plantfor separation of spent ammunition from soil.The remaining 33,600 cubic yards, composed ofapproximately 26,700 cubic yards of vegetationand 6,900 cubic yards of soil from overexcavated areas (containing little spentammunition) were not screened and were usedas general fill at the OU 2 Landfill, Area E. Ofthe screened material, approximately 42,000cubic yards were used for the foundation layer atArea E; 49,200 cubic yards for the foundationlayer at Area F; and 38,000 cubic yards wereused as general fill at Area E. Approximately719,000 pounds of spent ammunition recoveredfrom the screening plant was recycled andreclaimed at an offsite facility.

All final confirmation samples contained lessthan 1860 mg/kg and therefore met the health-based cleanup level of 1,860 mg/kg lead asdefined in the ROD. The post remediationhealth risk assessment stated that unacceptablehuman health risks and hazards are consideredunlikely to be associated with futurerecreational, commercial, or residentialdevelopment of Site 3 under the exposureconditions evaluated (IT, 2000c). The postremediation health ecological risk assessmentconcluded that significant risks to herbivorousbirds and carnivorous/omnivorous mammalsfrom exposure to residual chemicals remainingin the soil at Site 3 are not expected (HLA,1998c). Potentially significant risks wereidentified for two “hot spot “areas where soilconcentrations were elevated. However,significant risks to populations of smallmammals and plants from exposure to residualchemicals in soil are not expected. The soilremediation resulted in the site being availablefor unrestricted reuse.


There are presently no operations andmaintenance requirements identified for Site 3.


8.3.1 Question A


The remedy is functioning as intended.However, the Interim ROD has not beenfinalized.

8.3.2 Question B


Site 3 Interim ROD


The exposure and toxicity criteria used toevaluate health risks are still valid. Therefore theselected remedy is valid.

8.3.3 Question C


No new information has been identified thatcould call the protectiveness of the remedy intoquestion.

8.4 Issues

There remains a potential for post remediationactivities related to shifting sands and thepossible subsequent discovery of areas withgreater than 10 percent surface coverage of spentammunition, and additional habitat monitoring

at Site 3. These issues will be resolved beforethe Proposed Plan and Record of Decisionfinalizing the remedy selection for the site areissued.


The Interim ROD for Site 3 should be finalized.


The post-remediation risk assessment indicatedthe implemented remedy was protective ofhuman health and the environment (IT, 2000c)and is available for unrestricted reuse. None ofthe associated health risk criteria have changed,therefore the remedy continues to be protectiveof human health and the environment.


9.0 NO ACTION SITES ROD

This section presents background information onthe No Action Sites ROD; a summary ofremedial actions and a technical assessment ofthe actions taken at these sites; identifies anyissues related to the protectiveness of theremedies based on the review; presentsrecommendations and follow-up actions, ifneeded, to address issues identified during thereview; and provides a statement regarding theprotectiveness of the site remedies.

9.1 No Action SitesBackground

A No Action Record of Decision (NoA ROD)was signed in April 1995 and is based on theU.S. Army’s No Action Proposed Plan (NoAction Proposed Plan for Selected Areas at FortOrd, California, August 30, 1994). The NoAROD defines the criteria that a site must meet toqualify as a No Action (NoA) site and describesthe approval process. NoA sites at Fort Ord areeither:

• Category 1 Sites: already in a protectivestate and pose no current or potential threatto human health or the environment.

• Category 2 Sites: where CERCLA does notprovide authority to take any remedialaction. These sites may be regulated by Stateor local agencies and follow theirrequirements.

The criteria and approach for these sites areconservative and consistent with those presentedfor the operable units (OUs) and RI sites.

For each proposed NoA site, the evaluationprocess began with a site characterizationinvestigation and report. The regulatoryagencies reviewed the report and approved itafter their comments were addressed. If the sitemet the criteria, a No Action approvalmemorandum was submitted for publiccomment and regulatory agency approval. If the

approval memorandum was accepted, the sitewas included in the NoA ROD process. Ifapproval was not granted, the site wastransferred to the interim action category(Section 10.0).



The selected remedy for the NoA sites consistedof no further action.


Site 11 – Army and Air ForceExchange Service Fueling Station

Site 11, the Army and Air Force ExchangeService (AAFES) Main Service Station, is in theMain Garrison. The site consists of a garage forautomotive engine work, a small store for autosupplies and sundries, and an active gas stationthat includes six gasoline underground storagetanks, one waste oil underground storage tank,and one oil/water separator (HLA, 1996n). Thissite has completed the no action approvalprocess. Subsequent cleanup actions have beencompleted as required under regulationsgoverning underground storage tanks.

Site 13 – Railroad Right-of-Way

Site 13 is a 5,000-foot-long railroad spur andright-of-way adjacent to an industrial area in theMain Garrison. Third Street, Eleventh Street,Highway 1, and First Avenue bound the site.The railroad tracks head north (immediately eastof and paralleling Highway 1) then curveeastward into the industrial area (HLA, 1994b).This site was included in the no action processand has completed the approval process.

No Action Sites ROD


Site 18 – 1600 Block Facility

Site 18, the 1600 Block Facility in the MainGarrison, is a multi-purpose complex thatincludes maintenance and support facilities formotor pool vehicles, the DOL Busworks Yard,and several light industrial buildings. Potentialareas of concern were former undergroundstorage tanks (waste oil, diesel, and gasoline),six wash racks with associated oil/waterseparators, five grease racks, drum storage areasat the DOL Busworks Yards and the Trainingand Audiovisual Service Center (TASC) PlasticsShop, and a dry well at the TASC GraphicsShop. Approximately 99 percent of the site iscovered with either asphalt or concrete.Investigations determined this site required nofurther action (HLA, 1995c). This site wasincluded in the no action process and hascompleted the approval process.

Site 19 – 2200 Block Facility

Site 19, the 2200 Block Facility in the MainGarrison, is 90 percent paved and consists ofstorage, administration, and light industrialbuildings. Three potential areas of concern wereBuildings T-2241, T-2251, and T-2253.Building T-2241 (the photographic laboratory,formerly the telephone and telegraph building)consisted of an area where wastes werereportedly discharged through a floor drain intoa suspected dry well beneath the building.Building T-2251 consisted of an area where anoily substance reportedly flowed to a drain eastof the building during wet weather. BuildingT-2253 (a former gasoline service station)consisted of an area where one soil samplecollected during tank removal activities in 1991contained TPH constituents. Investigationsdetermined this site required no further action(HLA, 1995d). This site was included in the noaction process and has completed the approvalprocess.

Site 23 – 3700 Block Motor PoolComplex

Site 23, the 3700 Block Motor Pool Complex, isan approximate 19-acre parcel in the eastern

portion of the Main Garrison where vehiclemaintenance activities were performed. Potentialareas of concern included six formerunderground storage tanks, three former greaseracks, three oil/sand interceptors with oil/sandseparators, and three hazardous waste storagesheds. A previous investigation consisted ofdrilling three soil borings and installing threemonitoring wells. The borings were at theformer underground storage tanks, and themonitoring wells were along the east siteboundary, in the central portion of the site, andalong the west site boundary to determine thegroundwater flow direction. Investigationsdetermined this site required no further action(HLA, 1997d). This site was included in the noaction process and has completed the approvalprocess.

Site 26 – Sewage Pump Stations,Buildings 5871 and 6143

The Imjin sewage pump station is in Building5871, and the Clark sewage pump station is inBuilding 6143. Both buildings are southwest ofthe Fritzsche Army Airfield. There have beeneight documented sewage spills from thesestations since 1988; however, soil contaminationfrom the sewage spills is not expected.Investigations determined this site required nofurther action (HLA, 1995e). This site wasincluded in the no action process and hascompleted the approval process.

Site 27 – Army Reserve Motor Pool

Site 27, the Army Reserve Motor Pool, isimmediately south of the former Fritzsche ArmyAirfield (FAAF). Potential areas of concern arethe wash rack and the associated oil/waterseparator, a 500-gallon waste oil undergroundstorage tank, and a hazardous materials storagearea. The assessments of the existing waste oilunderground storage tank and the hazardousmaterials storage area are being handled underthe current underground storage tankmanagement program and the ResourceConservation and Recovery Act (RCRA)-typefacility program, respectively. Investigationsdetermined this site required no further action

No Action Sites ROD


(HLA, 1994e). This site was included in the noaction process and has completed the approvalprocess.

Site 28 – Barracks and MainGarrison Area

Site 28 consists of three buildings in the MainGarrison Area: the Visual Information Center(Building T-2842), the Photo Developing Unit(Building T-2850), and the Print Shop (BuildingT-2353). Potential chemicals of concernassociated with Site 28 include solvents, PCE,and chemicals used for photographdevelopment. Investigations determined this siterequired no further action (HLA, 1995b). Thissite was included in the no action process andhas completed the approval process.

Site 29 – Defense ReutilizationMarketing Office

Site 29, the Defense Reutilization MarketingOffice, is in the East Garrison and centersaround Buildings 110 and 111, wherepolychlorinated biphenyl (PCB)-containingtransformers may have been stored in the past,and an unpaved field adjacent to the DefenseReutilization and Marketing Office (DRMO)hazardous materials storage area. Potentialcontaminants are PCB-containing waste oil,metals, and PCBs. Investigation determined thatthis site required no further action (HLA, 1994c).This site was included in the no action processand has completed the approval process.

Site 35 – Fritzsche Army Airfield(FAAF) Aircraft CannibalizationYard

Site 35, the FAAF Aircraft CannibalizationYard, is an approximate 11-acre undevelopedarea across which aircraft debris has beenscattered, west of the northern portion of theFAAF. The FAAF burn pit is approximately 800feet north of the site. Debris consisted ofhelicopter and small plane fuselages, jet engines,and wing sections. Potential contaminantsassociated with the site are engine oils and fuels

that may have leaked from the aircraft parts, andpossibly solvents from aircraft cannibalizationactivities. Investigations determined this siterequired no further action (HLA, 1995a). Thissite was included in the no action process andhas completed the approval process.

Site 37 – Trailer Park MaintenanceShop

Site 37, the Trailer Park Maintenance Shop, isnear the northwest portion of Fort Ord andserves as the maintenance storage yard for theadjacent trailer park. Potential areas of concernwere the waste oil drum storage area, degradedand stained asphalt at a former location of anaboveground tank, and the storm drain inlet thatcollects runoff from the site. Investigationdetermined that this site required no furtheraction (HLA, 1994a). This site was included inthe no action process and has completed theapproval process.

Site 38 – Army and Air ForceExchange Service Dry Cleaners

Site 38 is a Army and Air Force ExchangeService (AAFES) dry cleaning facility in theMain Garrison. The site consisted of threeunderground storage tanks, all of which havebeen removed. Investigations determined thatthis site required no further action (HLA, 1995g).This site was included in the no action processand has completed the approval process.


There are no operations and maintenancerequirements for the NoA sites.


9.3.1 Question A


No Action Sites ROD


The selected remedy was no further action,which is continuing to function as the intended.

9.3.2 Question B


There have been no changes in the assumptionsfor the NoA site that would affect theprotectiveness of the remedy.

9.3.2.1 Changes in StandardsTo Be Considered

Fort Ord specific Preliminary RemediationGoals (PRGs) listed in the No Action ROD wereused as the basis for No Action decisions. TheFort Ord specific PRGs were compared to themost recent EPA Region IX PRGs (EPA, 1999).Four chemicals, arsenic, 1,3-dichlorobenzene,ethylbenezene, and naphthalene, now have apublished Region IX EPA PRG which are lowerthan the Fort Ord-specific PRGs. For arsenic insoil, although the Fort Ord-specific PRGexceeds the new EPA PRG, the exceedances areequivalent to Fort Ord background soilconcentrations and therefore would not requirereassessment of the need for remediation. Forthe other three chemicals, there were nodetections at the No Action sites that exceedeither of the new EPA Region IX PRGs.

9.3.3 Question C



9.4 Issues

There are no unresolved issues that have beenidentified in regard to the protectiveness ofhuman health and the environment.


There are no recommendations for follow-upactions.


The risk assessment indicated that theimplemented remedy was protective of humanhealth and the environment and the sites areavailable for unrestricted reuse. None of theassociated health risk criteria have changed,therefore the remedy continues to be protectiveof human health and the environment.


10.0 INTERIM ACTION SITES ROD

This section presents background information onthe Interim Action Sites ROD; a summary ofremedial actions and a technical assessment ofthe actions taken at these sites; identifies anyissues related to the protectiveness of theremedies based on the review; presentsrecommendations and follow-up actions, ifneeded, to address issues identified during thereview; and provides a statement regarding theprotectiveness of the site remedies.

10.1 Background

An Interim Action Record of Decision (IAROD)was signed in March 1994(Army, 1994a). TheIAROD was based on the interim action FS andproposed plan (HLA, 1993a; HLA, 1993b). TheIAROD defined criteria that a site must meet toqualify as an IA site, and described the approvalprocess for implementing interim actions. Theprimary criteria include: (1) the maximum depthof affected soil that could be addressed as anInterim Action was 25 feet below groundsurface, and (2) the volume of affected soil thatcould be addressed as an Interim Action waslimited typically to between 500 and 5,500 cubicyards. The cleanup goals and approach for thesesites were consistent with those presented for theoperable units (OUs) and RI sites at Fort Ord.

For each proposed Interim Action (IA) site, theprocess began with a site characterizationinvestigation and report. The regulatory agenciesreviewed the report and approved it after theircomments were addressed. If the site met thecriteria, an Interim Action approvalmemorandum was submitted for regulatoryagency approval. The public was notified that anapproval memorandum was submitted, and if theapproval memorandum was approved, publicnotice of the proposed action was provided twoweeks before work began. The interim actionwas then implemented and a ConfirmationReport was prepared. If the report was approved,the site was included in the Interim Action RODprocess. If the confirmation report

was not approved, it was resubmitted afteradditional action was taken to address agencyconcerns. If it was determined that thecontamination was too extensive to beremediated under the IAROD, the site wastransferred to the RI sites category. An RI/FSreport would then be prepared for the site and itwould be included in the Basewide RI SitesROD.



Alternative 1

• No Action and was considered, as required,under CERCLA as a baseline forcomparison to the other proposedalternatives.

Alternative 2

• Excavating, treating, recycling and/ordisposal of contaminated soil from IA areasand backfilling with clean soil.

Selected Remedy

Alternative 2 was the selected remedy because itwas protective of human health and theenvironment, complied with ARARs andallowed timely transfer of Army property.


Site 1 – Ord Village SewageTreatment Plant

Site 1 is the former Ord Village SewageTreatment Plant in the southwest corner of FortOrd within the coastal dunes. Sewage treatmentoperations ceased in 1964; currently, the facilityis used as a sewage pump station. Potentialchemicals of interest include petroleum

Interim Action Sites ROD


hydrocarbons, VOCs, SOCs, mercury and othermetals, fecal coliform, and nitrates. The cleanupof the site included excavation of the sludgedrying beds and additional soil excavations inareas noted in the original site investigation. Allcleanup is complete and the Interim ActionConfirmation Report, Site 1 - Ord VillageSewage Treatment Plant, Fort Ord, California(HLA, 1997j) was submitted in 1997. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.

Site 6 – Range 39, Abandoned CarDump

Site 6 is an approximate 400-foot by 1,000-footundeveloped parcel 1.5 miles southeast of theintersection of Eucalyptus and Parker Flatsroads, within the multi-range area, wherevehicles, scrap metal, and other items weredisposed. All contaminated soil in this area hasbeen removed, and the Interim ActionConfirmation Report, Site 6 – Range 39(Abandoned Car Dump), Fort Ord, California(HLA, 1997a) was submitted in 1997. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.

Site 8 – Range 49, Molotov CocktailRange

Site 8, an undeveloped parcel at Inland Range49, was a former training area where troopspracticed using Molotov cocktails.Contamination associated with Site 8 includesflammable liquids (possibly leaded gasoline,transmission oil, and motor oil) in soils adjacentto the two armored vehicles that were used aspractice targets for the Molotov cocktails. Allcontaminated soils were removed under theinterim action process. The Interim ActionConfirmation Report, Site 8 – Range 49(Molotov Cocktail Range), Fort Ord, California(HLA, 1996j) was submitted in 1996. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.

Site 10 – Burn Pit

Site 10 is a former burn pit approximately 160feet south of the Fort Ord Fire Station in theMain Garrison. The site was an unlined,rectangular pit (approximately 45 feet long, 25feet wide, and 2 feet deep) into which flammableliquids were placed, ignited, and subsequentlyextinguished for firefighting training. A 2-inchdiameter pipe apparently was used to regulatefluid levels in the pit, and a narrow drainageditch exits the pit to the south. The southernportion of the 2-inch-diameter pipe is buriedwithin surface soils. The pit is no longer in useand is partially overgrown with grass. Allcontaminated soils have been removed and theInterim Action Confirmation Report, Site 10 -Burn Pit, Fort Ord, California (HLA, 1996k) wassubmitted in 1996. The confirmation reportreceived concurrence from EPA and is pendingconcurrence from DTSC.

Site 14 – 707th MaintenanceFacility

Site 14 is an approximate 19-acre area at thenorthwest corner of the intersection of 3rd Streetand 6th Avenue in the Main Garrison. The sitewas used as a maintenance and fueling facilityfor military vehicles, beginning in the early1950s. Potential areas of concern include soilassociated with gasoline, diesel, and waste oilunderground storage tanks; hazardous materialsstorage areas; grease racks; wash racks, andoil/water separators. Through a series of soilexcavation actions, all contamination has beenremoved. All underground storage tanks in thisarea have been removed and clean-closed. Thecleanup of this site is complete and theConfirmation Report, Site 14 - 707thMaintenance Facility, Fort Ord, California(HLA, 1996b) was submitted in 1996. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.



Site 15 – Directorate of Engineeringand Housing (DEH) Yard

Site 15, the Directorate of Engineering andHousing (DEH) Yard is an approximate 10-acre,developed parcel in the Main Garrison. The siteconsists mainly of administration buildings, withsome areas used for light industry and/orstorage. Soil contaminated with pesticides andmetal has been excavated and removed from thisarea in accordance with the Interim Actionprocess. The Confirmation Report Site 15Directorate of Engineering and Housing Yard,Fort Ord (HLA, 1996i) was submitted in 1996and received concurrence from the regulatoryagencies in 1998.

Site 20 – South Parade Ground and3800 and 519th Motor Pools

Site 20 is in the Main Garrison and consists ofthe 9.5-acre South Parade Ground, the 27-acretroop training area west of the parade ground,the 6-acre 3800 Motor Pool, and the 20-acre519th Motor Pool. With completion of thenotification process as outlined for the eligibleInterim Action sites, contaminated soils wereexcavated. The cleanup of this area is complete.The Interim Action Confirmation Report, South20 - South Parade Ground 3800 and 519thMotor Pools, Fort Ord, California (HLA, 1996e)was submitted in 1996 and received concurrencefrom the regulatory agencies in 1998.

Site 21 – 4400/4500 Block MotorPool East

Site 21, the 4400/4500 Block Motor Pool East,was used for motor vehicle service,maintenance, and storage, and is in the easternportion of the Main Garrison. Potential areas ofconcern included a 400-gallon gasoline fuel spillnear Building 4495 that occurred in 1979, sixoil/water separators, a concrete-lined canal andits unpaved discharge area, nine wash racks andnine grease racks, and twenty current and formerunderground storage tanks. The cleanup of thissite is complete. The Interim ActionConfirmation Report, Site 21 - 4400/4500 Motor

Pool, East Block, Fort Ord, California (HLA,1996f) was submitted in 1996. The confirmationreport received concurrence from EPA and ispending concurrence from DTSC.

Site 22 – 4400/4500 Block MotorPool West

Site 22, the 4400/4500 Block Motor Pool West,was used for motor vehicle service,maintenance, and parking, and is in the easternportion of the Main Garrison. Potential areas ofconcern included 16 current and formerunderground storage tanks, a fueling facility,maintenance shops, four grease racks, and threeoil/water separators. The cleanup of this site wascompleted. The Site Interim ActionConfirmation Report, Site 22 - 4400/4500 MotorPool, West Block, Fort Ord, California (HLA,1996d) was submitted in 1996 and receivedconcurrence from the regulatory agencies in1998.

Site 24 – Old Directorate ofEngineering and Housing (DEH)Yard

Site 24 is a grassy vacant lot (including a1/4-mile jogging track), and is the location ofthe former DEH Yard and a former plant nurserywithin the Main Garrison. Areas within Site 24that may have been potential sources ofcontamination included a maintenance facility, agrease rack, drum and asphalt storage areas,aboveground tanks, and the nursery. With theremoval of the contaminated soil and burieddrums at this site, the cleanup of this site iscomplete. The Interim Action ConfirmationReport, Site 24 - Old DEH Yard, Fort Ord,California (HLA, 1997b) was submitted in 1997and received concurrence from regulatoryagencies in 1998.

Site 30 – Driver Training Area

Site 30, the Driver Training Area, is a partiallydeveloped parcel in the East Garrison. Formerfacilities at the site representing potential areasof concern included a former grease rack with



stained surface soils, a former gasoline stationwith two underground storage tanks, and anabandoned wash rack. The site cleanup iscomplete. The Confirmation Report, Site 30 -Driver Training Area, Fort Ord, California(HLA, 1996c) was submitted in 1996. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.

Site 32 – East Garrison SewageTreatment Plant

Site 32, the East Garrison Sewage TreatmentPlant in the northern portion of the EastGarrison, consists of sludge beds, a percolationpond, and Dotton-sedimentation tanks. Potentialcontaminants include TPH as gasoline (TPHg),TPHd, VOCs, metals, fecal coliform bacteria,and nitrogen. The contaminated soils at this sitewere excavated and the cleanup is complete. TheInterim Action Confirmation Report, Site 32 -East Garrison Sewage Treatment Plant, FortOrd, California (HLA, 1998a) was submited in1998. The confirmation report receivedconcurrence from EPA and is pendingconcurrence from DTSC.

Site 34 – Fritzsche Army Airfield(FAAF) Fueling Facility

Site 34 includes the former Fritzsche ArmyAirfield (FAAF) Fueling Facility and developedareas. Potential areas of concern included: fourhelicopter wash aprons, one vehicle wash rack,and associated oil/water separators at variouslocations. Helicopters were cleaned at the washaprons using solvent solutions, and vehicleswere cleaned at the wash rack using soap andwater. Each wash apron or wash rack is arelatively large, 12-inch-thick concrete padwhere helicopters or vehicles were washed. Eachpad either sloped inward toward a central drainor sloped uniformly in the direction of aperimeter drain adjacent to an associatedoil/water separator. The contaminated soil wasexcavated in accordance with the remedyoutlined in the Interim Action Record ofDecision, and additional soil contaminationresulting from former underground storage tanks

was removed. The underground storage tanksand contaminated soil has been removed and thecleanup is complete. The Interim ActionConfirmation Report, Site 34, Fritzsche ArmyAirfield Fueling Facility, Fort Ord, California(Uribe, 1998) was submitted in 1998. Theconfirmation report received concurrence fromEPA and is pending concurrence from DTSC.

Site 36 – Fritzsche Army Airfield(FAAF) Sewage Treatment Plant

Site 36 is the inactive FAAF Sewage TreatmentPlant near the northern border of Fort Ord. Thefacility consisted of an Imhoff tank, twoevaporation ponds, and two sludge beds.Potential contaminants included TPH asgasoline, TPH as diesel, volatile organiccompounds (VOCs), metals, fecal coliformbacteria, and Kjeldahl nitrogen. Thecontaminated soil in this area was remediated inaccordance with the Interim Action Record ofDecision and is complete. The Interim ActionConfirmation Report, Site 36 - Fritzsche ArmyAirfield Sewage Treatment Plant, Fort Ord,California (HLA, 1997g) was submitted in 1997and received concurrence from the regulatoryagencies in 1998.

Site 39A – East Garrison Ranges

The East Garrison Ranges are on the west sideof the East Garrison. The ranges included threesmall-bore shooting ranges (EG-1, EG-2, andEG 3), a skeet range, and a target area thatappears to have been part of a decommissionedmoving target range. Weapons use was limitedto pistols (.45 caliber or less) at Ranges EG-1and EG-2, and to small-bore (.22 caliber) riflesat Range EG-3. Bullets were fired at targets 25or 50 meters away and became embedded in thehillsides at the back of the range. The skeetrange was primarily a recreational shootingrange for trap and skeet. Potential contaminantswere arsenic, antimony, copper, and leadassociated with spent ammunition, andpolyaromatic hydrocarbons (PAHs) from claypigeons that contain 32 percent petroleum pitch(asphalt). Soil was excavated and the cleanup ofthis area is complete. The Interim Action



Confirmation Report, Site 39A - East GarrisonRanges, Former Fort Ord, California (HLA,1998d) was submitted in 1998. The confirmationreport received concurrence from EPA and ispending concurrence from DTSC.

Site 39B – Inter-Garrison TrainingArea

Site 39B is located east of the Main Garrison,south of Inter-Garrison Road between EighthAvenue and Abrams Drive. In 1994, when anunexploded ordnance (UXO) clearance crewfound a small container while excavating a site,two crewmembers became dizzy and nauseated.The crew also noted metal debris and odors at asecond location within 50 feet of the containers.An emergency response action was initiated totreat the UXO crew and secure the site. Otheritems found in the vicinity of the incidentincluded oil filters, scrap metal, paint cans,engines, and ammunition canisters. A Time-Critical Removal Action was completed in 1994,and soil was determined to be contaminated withlead, oil and grease, and diesel fuel. The soilcontamination in this area was excavated and thecleanup is complete. The Interim ActionConfirmation Report, Site 39B - Inter-GarrisonSite, Fort Ord, California (HLA, 1997e) wassubmitted in 1997. The confirmation reportreceived concurrence from EPA and is pendingconcurrence from DTSC.

Site 40 – Fritzsche Army Airfield(FAAF) Helicopter Defueling Area

Site 40, the FAAF Helicopter Defueling Areas,is near Building 533 in the northwest portion ofthe FAAF. Based on interviews with Building533 employees, four separate potential areas ofconcern were identified as locations wherehelicopters were defueled or where chemicalsassociated with helicopter maintenance mayhave been released. One of these areas was alsoa suspected landfill site. The cleanup of this siteis complete. The Interim Action ConfirmationReport, Site 40 - Fritzsche Army AirfieldDefueling Area, Fort Ord, California (HLA,1997a) was submitted in 1997 and

received concurrence from regulatory agenciesin 1998.

Site 41 – Crescent Bluff Fire DrillArea

Site 41 consists of four small fire-fightingtraining pits identified during personnelinterviews located on a bluff approximately 0.75mile southeast of the East Garrison. The trainingpits were overgrown and contained pondedwater during wet seasons. Potentialcontaminants associated with training pits wereflammable liquids (e.g., fuels and solvents). Thecontaminated soil in this area was excavated andremoved in accordance with the Interim ActionRecord of Decision and all the cleanup related tothe site is complete. The Interim ActionConfirmation Report, Site 41 - Crescent BluffFire Drill Area, Fort Ord, California (HLA,1997c) was submitted in 1997. The confirmationreport received concurrence from EPA and ispending concurrence from DTSC.

Outfall OF-15

Outfall OF-15 included a storm drain andchannel immediately west of Trainfire RangeNo. 11 on the Beach Trainfire Ranges (Site 3).The contaminated soil in this area was excavatedand removed in accordance with the InterimAction Record of Decision and the cleanuprelated to this site is complete. The InterimAction Confirmation Report, Outfall 15, FormerFort Ord, California (HLA, 1998b)was submittedin 1998. EPA provided minor comments whichare being addressed. The site is pendingconcurrence from the regulatory agencies.

Outfalls OF-34 and OF-35

Outfalls OF-34 and OF-35 discharged into avegetated drainage channel west of Building 533at the western end of FAAF. Interviews withformer base employees and research indicatedchemicals used in Building 533 and/or otherbuildings at FAAF may have entered stormdrain inlets upstream of OF-34 and OF-35. Thecontaminated soil in this area was excavated andremoved in accordance with the Interim Action



Record of Decision and the cleanup related tothis site is complete. The Interim ActionConfirmation Report, Outfalls 34 and 35 -Fritzsche Army Airfield, Fort Ord, California(HLA, 1997f) was submitted in 1997 andreceived concurrence from the regulatoryagencies in 1998.

102.3 System Operations andMaintenance

There are no operations and maintenancerequirements under the Interim Action ROD.


10.3.1 Question A


The completed interim actions continue to allowunrestricted use of the Interim Action Sites.

10.3.2 Question B


There have been no changes in the physicalconditions of the IA sites that would affect theprotectiveness of the remedy.

10.3.2.1 Changes in StandardsTo Be Considered

Fort Ord specific Preliminary RemediationGoals (PRGs) listed in the Interim Action RODwere used as the basis for No Action decisions.The Fort Ord specific PRGs were compared tothe most recent EPA Region IX PRGs (EPA,1999). Four chemicals, arsenic,

1,3-dichlorobenzene, ethylbenezene, andnaphthalene, now have a published Region IXEPA PRG which are lower than the Fort Ord-specific PRGs. For arsenic in soil, although theFort Ord- specific PRG exceeds the new EPAPRG, the exceedances are equivalent to Fort Ordbackground soil concentrations and thereforewould not require reassessment of the need forremediation. For the other three chemicals, therewere no detections at the Interim Action Sitesthat exceed either of the new EPA Region IXPRGs.

10.3.3 Question C



10.4 Issues

There are no unresolved issues that have beenidentified in regard to the protectiveness ofhuman health and the environment.


There are no recommendations for follow-upactions.


The post-remediation risk assessment indicatedthat the implemented remedy was protective ofhuman health and the sites with agencyconcurrence are available for unrestricted reuse.None of the associated health risk criteria havechanged, therefore the remedy continues to beprotective of human health and the environment.


11.0 STATUS OF OTHER INVESTIGATIONS

This section provides background informationand status reports on other investigations at FortOrd not addressed under one of the RODspreviously described.

11.1 Carbon TetrachlorideInvestigation

11.1.1 Background

Carbon tetrachloride (CT) was originallydetected in groundwater samples collected fromtwo wells in 1992. The continued but erraticdetection of CT in both the A- and Upper 180-Foot aquifers as part of the quarterly monitoringprogram suggested the presence of a nearbyvertical conduit through the laterally extensiveFort Ord Salinas Valley Aquiclude (FO-SVA)clay. Nearby abandoned municipal wells wereevaluated and determined to have beeninadvertently constructed with insufficientsanitary seals, providing vertical conduits to theUpper and Lower 180-Foot Aquifers. Soil gassamples collected as part of a separateinvestigation in 1987 indicate a possible CTsource area; however, land use of this area doesnot indicate any obvious source of solvents,including CT.

Current data suggests that CT migrated from thesuspected source area downward to theA-Aquifer, then migrated northwest where itwas intercepted by several vertical conduitsdownward through vertical conduits into theUpper 180-Foot Aquifer. A portion of the Upper180-Foot Aquifer plume continued to migratedownward where it eventually entered theLower 180-Foot Aquifer; another portionmigrated to the southeast where it commingledwith the OU 2 plume and entered the Lower180-Foot Aquifer through the Intermediate180-Foot Aquitard about a mile away. This hasresulted in two distinct CT plumes in the Lower 180-Foot Aquifer, each representing a differentpathway.

This plume represents complex pathways andvolatile organic compound (VOC) distributiondue to the previous vertical conduits at themunicipal wells and varying groundwater flowdirections in each aquifer. The A-Aquifer plumeextends about 1.5 miles from the source area tothe northwest; the Upper 180-Foot Aquiferplume extends at least one mile from the verticalconduits to the southeast; and the Lower180-Foot Aquifer plume extends about one mileeast of the vertical conduits (based onpreliminary data from Westbay wells). Theinvestigation to delineate CT in each aquifer isongoing and will be documented in a separateROD.

11.1.2 Status Report

As of January 2002, the carbon tetrachlorideplume has been observed in the A-Aquifer, theUpper 180-Foot Aquifer, and the Lower180-Foot Aquifer. The A-Aquifer plume extendsabout one mile northwest of the suspectedsource area and is delineated by 38 monitoringwells, of which carbon tetrachloride isconsistently in 19 wells. The highestconcentration detected to date has been 18micrograms per liter (:g/L) at monitoring well(MW)-BW-27-A, which exceeds the Statemaximum contaminant level (MCL) for carbontetrachloride of 0.5 :g/L. The source of carbontetrachloride is still unknown, but an area ofelevated soil gas concentrations indicates thesuspected source area location may be nearImjin Road within the Preston Park housingarea.

The Upper 180-Foot Aquifer plume extendsfrom several vertical conduits surroundingpreviously used, and now destroyed, drinkingwater wells. The plume extends about 4,000 feetfrom these conduits to the southeast where itappears to migrate through the underlyingaquitard and enters the Lower 180-Foot Aquifer.The Upper 180-Foot Aquifer is delineated bynine monitoring wells, of which

Status of Other Investigations


carbon tetrachloride is consistently detected insix wells. The highest concentration of carbontetrachloride detected to date in the Upper 180-Foot Aquifer has been 9.8 :g/L atMW-B-13-180.

The Lower 180-Foot Aquifer is delineated by aseries of Westbay monitoring wells, a privateirrigation well, a USACE monitoring wellinstalled in 1963 for monitoring seawaterintrusion, and historical data from now-destroyed drinking water wells.

The Westbay wells include 35 monitoring portsinstalled in the Lower 180-Foot and 400-FootAquifers. These wells were recently installedand preliminary data indicates carbontetrachloride is present only in the Lower180-Foot Aquifer. Carbon tetrachloride has alsobeen consistently detected at a private irrigationwell at concentrations ranging from 4.5 :g/L to6.95 :g/L. However, the highest concentrationfrom the now-destroyed drinking water wells(also screened in the Lower 180-Foot Aquifer)prior to their destruction was 11 :g/L (FO-28).Samples from a well installed to monitorseawater intrusion recently indicated thepresence of carbon tetrachloride at aconcentration of 1.6 :g/L. This plume appears toextend about 5,000 feet east of the verticalconduits and is almost 2,000 feet wide at itswidest point, based on available data.

In addition to the Lower 180-Foot Aquiferplume emanating from vertical conduitssurrounding the now-destroyed drinking waterwells, a second plume has formed downgradientof where the Upper 180-Foot Aquifer apparentlymigrates into the Lower 180-Foot Aquifer. Datafrom wells installed to delineate the OU 2 plumeindicate that the Upper 180-Foot Aquifer plumecommingles with the OU 2 plume in the Lower180-Foot Aquifer further south and west of thesource area. Carbon tetrachloride hasconsistently been detected at MW-OU2-66-180,and recent data indicate it is also present atMW-OU2-69-180; however, concentrationshave not yet exceeded the State MCL of 0.5 :g/L in this area. This second Lower180-Foot Aquifer plume may extend across an

area with an approximate diameter of 2,000 feetand is expected to migrate to the east/southeast.

An evaluation of natural attenuation of carbontetrachloride in groundwater identified in recentinvestigations was conducted by Harding ESEfor the A-Aquifer and the Upper 180-FootAquifer (Harding, 2001d) and will be evaluatedduring the RI/FS process. After additional datacollection, an RI/FS will be prepared to start theROD process for the carbon tetrachloride plume.

11.2 Monterey BayEnhanced PreliminaryAssessment

11.2.1 Background

An investigation was performed to evaluate pastArmy activities at Fort Ord and adjacent areasthat could have affected the restricted zone inMonterey Bay, and to assess the likelihood ofcurrent and future impacts from these activities.The restricted zone is an area of 18 squarenautical miles adjacent to the west side of FortOrd, to which access was restricted in order toprotect the public during Army trainingexercises. The investigation includedcompilation of a chronological history of Armyactivities in, and around, Fort Ord based on thefollowing:

• Review of Federal Register

• Literature on sediments/currents, andbiological studies in the bay

• Previous investigations

• Reported sewage releases and chemicaldischarges

• Historical aerial photographs

• Review of regional newspapers

• Personal communications/interviews.

The Army participated in an effort with theMonterey Bay National Marine Sanctuary, the



US Geological Survey, regulatory agencies, andlocal marine research facilities to investigatesediment and biota, and map the ocean floor inthe restricted zone and adjacent areas inMonterey Bay off the former Fort Ord.


Review of data indicated minor impacts to therestricted zone occurred during the Army’stenure in the area, but these impacts were notsignificant with regard to environmentalconcerns. Some of the impacts that were notedincluded the potential for limited small armsprojectiles and ordnance and explosives (OE) onthe ocean floor, a sunken amphibious vehicle,physical disturbance of beaches, and thedischarge of contaminants and effluent throughstorm drain outfalls. However, these impacts areinsufficient to adversely effect marine biota orhuman usage of the area and no additional actionis necessary (HLA, 1999a).

11.3 East Garrison MagneticAnomaliesInvestigation

11.3.1 Background

The Central Coast Regional Water QualityControl Board was notified that metal drumsmay have been buried in the East Garrison of theformer Fort Ord in open areas betweenBuildings T-29, T-30, T-33, T-34, 35, and T-36.Subsequent investigations using magnetic andground-penetrating radar surveys identifiedseven shallow subsurface magnetic anomalies inthe suspect areas. One of the anomalies wasidentified as being associated with undergroundutilities. A detailed investigation was initiated toidentify the remaining six anomalies.


Investigations of the anomalies includedtrenching and soil sampling to identify themagnetic anomalies and evaluate whether therewas a potential for associated chemicalcontamination. The investigation was

completed in 1998, and included excavation ofthe anomalies, air monitoring in the work areas,sampling soil adjacent to the anomalies forchemical analysis, and confirmation that themagnetic anomalies had been removed usinggeophysical methods. In addition, a screeningrisk evaluation (SRE) of chemical data wasperformed to evaluate whether additionalinvestigation was needed. Chemical analysesincluded volatile and semi-volatile organiccompounds, petroleum hydrocarbons, andpriority pollutant metals. The results of theinvestigation indicated that no buried drumswere present, no chemical contamination waspresent in excess of Preliminary RemediationGoals (PRGs), and that each of the magneticanomalies was associated with inert metal scrap,metal grounding rods, or buried asphaltpavement. Details of the investigation aredescribed in the Draft Data Summary Report,Investigation of Magnetic Anomalies, EastGarrison Area, Former Fort Ord, California(Harding, 2001a) has been approved by theregulatory agencies and a draft final report willbe issued. No further action will be required atthis site.

11.4 Fritzsche Army Airfield(FAAF) Three SitesInvestigation

11.4.1 Background

An investigation was initiated to evaluate threesuspected sites in the vicinity of the formerFritzsche Army Airfield (FAAF) which werediscovered after completion of the BasewideRI/FS. The three sites included a debris disposalsite, a former unpaved vehicle staging area, anda possible former burn pit. A fourth suspectedlocation where a geophysical anomaly wasidentified during borehole clearance activity foran adjacent site investigation (OU 1) was addedto the investigation. The purpose of theevaluation was to evaluate whether contaminantswere discharged or leached to soil at any of thesites.




Chemical analyses of soil samples indicatedconcentrations of metals were below Fort Ordbackground soil concentrations at all sites. Noorganic compounds were detected in samplesfrom the vehicle staging area or the geophysicalanomaly area, other than common laboratorycontaminants. Samples from the debris disposalarea contained concentrations of petroleumhydrocarbons that were considerably lower thanthe Fort Ord PRG. At the potential burn pit site,several organic compounds were detected alongwith elevated concentrations of petroleumhydrocarbons in the soil.

The investigation report (Harding, 2001b),concluded that no further work was necessary atany of the sites other than the former burn pit.The report recommended excavation of soilunder the IA ROD. The draft report is currentlyunder agency review.

11.5 Freon 113 Investigation

11.5.1 Background

Freon 113 was discovered in the subsurface nearthe former Fritzsche Army Airfield (FAAF)(now the Marina Airport) during investigationsintended to identify the extent of TCE ingroundwater at OU 1. In December 1996, agroundwater investigation performed by theUSACE identified the presence of Freon 113 ingroundwater northeast of the OU 1 monitoringwell network. Previous investigation at theadjacent Site 40 in 1993 and 1994 indicatedcontamination associated with former sitepractices appeared to be limited to surface soiland did not affect groundwater (HLA, 1996a);however, low concentrations of Freon 113 weresubsequently reported in groundwater samplesfrom the Site 40 monitoring well.

An investigation was performed by Harding in1997 to evaluate the nature and extent of Freon113 in the OU 1/Site 40 area and attempt toidentify a source of Freon. Field activitiesincluded geophysical testing, drilling andsampling 13 test borings, and installing four

groundwater monitoring wells. The investigationidentified Freon 113 in groundwater over anarea of approximately 600 by 1,600 feetdowngradient of Site 40 at concentrations up to420 micrograms per liter. Only two of thesamples from monitoring wells in which Freon113 was identified contained concentrations ofFreon greater than 300 micrograms per liter. Allother samples contained concentrations of Freonunder 21 micrograms per liter.


Based on the results of the 1999 investigation, itwas concluded that concentrations of Freon 113in groundwater were below the maximumcontaminant level (MCLs) established by theState of 1,200 micrograms per liter.Consequently, no further work wasrecommended. The Technical MemorandumRegarding Freon 113 in the Subsurface NearOU 1 and Site 40, Former Fort Ord, California(Harding ESE, 2000b)concluded on the basis ofthe identified concentrations and areal extent ofFreon 113 in the subsurface, and the presence ofexisting monitoring wells in appropriatelocations to monitor the plume for changes, thatno further action was necessary.

11.6 Fort Ord Soil TreatmentArea (FOSTA)/Underground StorageTank Remediation Area(USRA)

11.6.1 Background

11.6.1.1 Fort Ord Soil TreatmentArea (FOSTA)

The FOSTA was designed as a bioremediationsoil treatment facility constructed forremediation of TPH-containing soil from IAsites at Fort Ord. From 1995 to 1998, soilsexcavated during Fort Ord Interim Actions werestored and/or bioremediated at the FOSTA.After treatment, the soils were transported to the



OU 2 Landfill. Closure activities began inNovember 1998 and were completed April 1999.

11.6.1.2 Underground StorageTank Remediation Area(USRA)

The USRA was designed as a Class II waste pilefor receiving non-hazardous soils from regulatedunderground storage tank (UST) sites at FortOrd. From 1995 to 1998, soils excavated duringUST remediation were stored and/orbioremediated at the USRA. After treatment, thesoils were transported to the OU 2 Landfill.Closure activities began in November 1998 andwere completed April 1999.


11.6.2.1 Fort Ord Soil TreatmentArea (FOSTA)

All phases of the construction and field samplingactivities for the FOSTA were completed inaccordance with the Closure Plan (Uribe, 1999a)and the Quality Control Project Plan/Samplingand Analysis Plan (QCPP/SAP) (Uribe, 1999b).The Final Closure Report, (Uribe, 1999d) wassubmitted in December 1999. Based on thelaboratory analytical results, no detrimentalimpacts to underlying soil occurred during theoperation of the FOSTA (Uribe, 1999d).

11.6.2.2 Underground StorageTank Remediation Area(USRA)

All phases of the construction and field samplingactivities for the USRA were completed inaccordance with the Closure Plan (Uribe, 1999a)and the QCPP/SAP (Uribe, 1999b). The FinalClosure Report, (Uribe, 1999c) was submittedDecember 1999. Based on the laboratoryanalytical results, no detrimental impacts tounderlying soil occurred during the operation ofthe USRA (Uribe, 1999c).

11.7 Resource Conservationand Recovery (RCRA)Closures

11.7.1 Defense Reutilizationand Marketing Office(DRMO)

Background

The Defense Reutilization and Marketing Office(DRMO) was used for the storage and ultimatedisposition of all hazardous waste, surplushazardous materials, and other non-hazardoussurplus items generated at the former Fort Ord.When the base was active, these wastes,materials, and surplus items were also receivedfrom other selected installations in thesurrounding area for storage and ultimatedisposal. Site usage began in 1973, and storageof hazardous materials on paved areas began in1975. Paving of the entire site was completed in1976, and hazardous materials were accepted forstorage until November 1994.

The DRMO waste container storage unitcomprised eight storage bays that were used tosegregate various waste types. Each bay wassurrounded by an asphalt berm to isolatepotential spills and prevent mixing ofincompatible wastes. Evaluation of the site forclosure was initiated with the Draft FinalClosure Plan, DRMO Hazardous WasteContainer Storage Unit, Former Fort Ord,California (HLA, 1999b). Closure activitiesincluded installation of soil borings, soilexcavation, removal of sediment from stormdrains, and a video survey of the storm drainsystem. Additional activities included chemicalanalysis of soil, sediment, and rinsate samplescollected from borings, surface rinsate, andstorm drains.

Status Report

The closure investigation indicated the presenceof contaminants at various locations onsite;however, residual concentrations were all belowthe target cleanup levels. Excavated soil was



transferred to the Fort Ord landfill for use ascover material, the storm drains weresufficiently cleaned, and the site was closed.Details of the closure investigation are presentedin the Closure Certification Report, DRMOHazardous Waste Container Storage Unit,Former Fort Ord, California (HLA, 2000a).

11.7.2 Silver Recovery Unit

Background

The silver recovery unit(unit) was located in thebasement of the Silas B. Hayes Hospital(Building 4385), and was operated until 1993and removed in 1994. Solutions containingrecoverable silver were transported to the unitfrom Fort Ord’s photography and dentallaboratories, the hospital’s x-ray facility, andFort Hunter Liggett, the Presidio of Monterey,Camp Roberts, and the Consolidated MedicalClinic. The original unit consisted of twostainless steel open vats. A bermed cage wasconstructed adjacent to the unit in 1989, whichcontained various subsequent configurations ofthe unit and associated equipment and storagecontainers. The system was upgraded in theearly 1980s to include a fiberglass collectioncontainer on the first floor of the hospital, andpiping that drained to the original basementlocation where the actual recovery unit andadditional holding tanks were located. Inaddition, the hospital’s nine x-ray developingmachines discharged used photochemicals intothe unit via a dedicated drain system.

Army documents indicate that work wasperformed in 1988 to repair concrete that wasdamaged by spilled acetic acid associated withthe recovery process. The unit was temporarilymoved, the damaged concrete was removed, andunderlying soil was sampled and excavated.Analysis of soil samples indicated that silverwas present in soil to a depth of 30 inches. Soilwas excavated to a depth of 36 inches, replacedwith clean fill, and the concrete floor wasreplaced along with construction of the bermedcage area.

In September 2000, the Department of ToxicSubstances Control (DTSC)/Cal-EPAdetermined that the silver recovery unit was nolonger regulated under State law. The Armyidentified the unit as Solid Waste ManagementUnit (SWMU) FTO-021 and developed a siteclosure plan, the Draft Final Work Plan, SilverRecovery Unit (Solid Waste Management UnitFTO-021), Former Fort Ord, California, datedMarch 26, 2001(Harding, 2001c).

Status Report

Site closure sampling was performed in June,2001, to evaluate whether residualcontamination was present in the area of theformer silvery recovery unit. Sampling wasperformed in accordance with the closure plan,which included wipe samples and chip samplingof porous surfaces associated with the formerunit. Analysis of samples indicated that silverresidue was present at the site. However, allresults were below the cleanup goals developedfor the site, and no additional remedial work wasdetermined to be necessary. Details of siteclosure activities are described in the ClosureReport, Silver Recovery Unit (Solid WasteManagement Unit FTO-021), Former Fort Ord,California (Harding ESE, 2002).

11.7.3 Building T-111

Background

The Building T-111 site was used for temporarycontainer storage of wastes contaminated withpolychlorinated biphenyls (PCBs) from 1985through January 1995. The building containedthree epoxy-lined storage bays separated byfour-foot high cement block berms, and anadjoining concrete-surfaced yard. Hazardouswaste storage permit application data indicatesthat the facility anticipated handling anestimated 3,000 kilograms of PCB andassociated material annually. A variety of otherhazardous wastes also were stored at the site fora 10-month period in 1989. Specific waste typesthat were stored onsite and other site details arepresented in the Draft Closure Plan, DRMO



PCB Storage Building T-111, Former Fort Ord,California (HLA, 2002b).

Status Report

Comments have been received on the draft siteclosure plan and the draft final closure plan willbe issued in June 2002.

11.7.4 Range 36A

Background

Range 36A was an explosive ordnance disposal(EOD) range and was used for disposal ofvarious types of commercial explosives andmilitary ordnance and ammunition. Disposal ofordnance and explosives (OE) occurred by openburning and open detonation (OB/OD). Therange was used until October 1992, when FortOrd’s EOD unit was deactivated as part of theclosure of Fort Ord. In January 1994, Range36A was reactivated for disposal of OEidentified from Fort Ord’s Time-CriticalRemoval Action Program for OE found outsidethe Inland Ranges. Potential contaminantspresent at the range as a result of past activitiesinclude explosive compounds and metals.

Investigations were conducted at Range 36A byJames M. Montgomery Consulting Engineering(JMM) and by HLA. In 1990, JMM performed aPreliminary Assessment/Site Investigation(PA/SI) at Range 36A to evaluate the presenceof explosive compounds and metals as a resultof past activities at the site. The JMMinvestigation consisted of drilling two soilborings and installing three wells. Twenty-foursoil samples, plus one split sample and oneduplicate sample, were collected from the twoborings and three monitoring well boreholes,and the samples were analyzed for explosivecompounds and metals.

In 1992, HLA performed an RI at Range 36A.This investigation included:

• Drilling 23 borings to depths of 15 to 20 feetbelow ground surface on an approximate 50-foot grid

• Collecting 69 surface and subsurface soilsamples for lithologic characterization andchemical and physical analysis

• Analysis of soil samples for explosivecompounds and priority pollutant metals.

The findings of the field investigations at Range36A indicated the following:

• The explosive compoundscyclotetramethylenetetranitramine (HMX)and cyclotrimethylenetrinitramine (RDX)were present at low levels (maximumconcentrations of 1.84 and 16.5 mg/kg,respectively), were generally limited toshallow soil, and were below PRGs. ThePRG for HMX is 803 mg/kg and the PRGfor RDX is 4 mg/kg.

With the exception of beryllium detected at amaximum concentration 0.89 mg/kg in shallowsoil, metals in soil at the site were belowbackground or PRG concentrations. The FortOrd PRG for beryllium is 0.39 mg/kg. The mostrecent EPA Region 9 PRG for beryllium is 150mg/kg.

Status Report

The Draft Closure Plan, Range 36A, FormerFort Ord, California (HLA, 1997i) was submittedin 1997. A work plan for additional sampling toinvestigate the areas used after the previousinvestigations and to verify the presence of RDXabove the PRG will be issued in June 2002. TheDraft Closure Plan will be revised based on theresults of the proposed additional sampling.

11.7.5 Solid WasteManagement Units(SWMUs)

Background

In support of Fort Ord’s Resource Conservationand Recovery Act (RCRA) Part B permitapplication, the Army Environmental HygieneAgency (AEHA) identified 58 SWMUs in 1988.All but two of these 58 SWMUs were in areas



investigated during the RI/FS or were previouslyidentified as Operable Units. In 1996, the Army identified 14 additional SWMUs. The DraftField Investigation and Data Review, SolidWaste Management Units, Fort Ord, California(HLA, 1996h) recommended no additionalsampling under the SWMU program.

Status Report

The following SWMUs are presently active:

• FTO-010 – AAFES Service Station

• FTO-027 – Building 4495 TemporaryContainer Storage

• FTO-068 – Auto Craft Shop TemporaryContainer Storage

• FTO-055 – Army Reserve Center MotorPool Temporary Container Storage

• FTO-017 – Golf Course Maintenance AreaTemporary Container Storage

The SWMU report will be updated in 2002 toreflect present conditions.

11.8 Ordnance andExplosives Program

11.8.1 Background

The Army is in the process of preparing anRI/FS for ordnance and explosives (OE) at FortOrd. Prior to and concurrent with the preparationof the OE RI/FS, the Army has been conductingOE cleanup activities that consist ofimplementing and documenting OE removalactions in areas with imminent OE hazards.These removal actions have not only reducedimminent OE hazards but have also providedinformation about the type of OE and level ofOE hazard at each of the sites for use in the OERI/FS.

Work for the existing OE program has beenconducted in accordance with the followingdocuments:

• Time-critical removal actions have beenimplemented as described in the Fort OrdOrdnance and Explosive Waste Time-Critical Removal Action Memorandum(Army, 1994b).

• Non-time-critical removal actions are beingaddressed via protocols outlined the ActionMemorandum, Phase 2 EngineeringEvaluation/Cost Analysis, Ordnance andExplosives Sites, Former Fort Ord,Monterey County, California (Army, 1999).The Phase 2 EECA Action Memorandumidentified and described the rationale forcontinuing with OE removal actions at OEsites while the OE RI/FS is being conductedand addressed recommendations for futureOE removal actions.

• All removal actions have been implementedin accordance with the Land Disposal SitePlan (LDSP), LDSP amendments, andexplosive safety submissions (ESSs), whichhave been approved by the Department ofDefense Explosives Safety Board (DDESB).These plans are required to describe thenature, extent, and types of known orsuspected OE contamination, the proposedfuture use of each area, and procedures formitigating OE hazards in a mannercompatible with the proposed land reuse andin accordance with Department of Defense(DoD) safety standards.

• Known or suspected OE sites have beenidentified and listed in the 1997 DraftRevised Archive Search Report (ASR;USAEDH, 1997), which is an update ofprevious ASRs (USAEDH, 1993; 1994).

• Previously identified, known, or suspectedOE sites, identified at the time the ASR wasissued, were listed in the Phase 1Engineering Evaluation/Cost Analysis(Phase I EE/CA; USAEDH, 1997) and thePhase 2 Engineering Evaluation/CostAnalysis (Phase 2 EE/CA; Army, 1998c).Because past military training activitiesresulted in the deposition of UXO in someareas on the former Fort Ord, the Phase 1



and Phase 2 EE/CAs (USAEDH, 1997;Army, 1998c) were developed to describethe OE removal and management activitiesfor sites known or suspected to contain OE.The Phase 1 EE/CA addressed 29 OE sitesand subsites (USAEDH, 1997). The Phase 2EE/CA addressed the remaining OE sites,including future sites (Army, 1998c). Sitesfor which no further OE removal actionswere recommended in the Phase 1 EE/CA(USAEDH, 1997) were addressed in theAction Memorandum 1, Phase 1 EE/CA,Twelve Ordnance and Explosives Sites(Army, 1998a). The Phase 2 EE/CAestablished a “plug-in” evaluation processdesigned to address cleanup of any OE siteson the former Fort Ord (Army, 1998c), andthe Action Memorandum Plug-In (AMPI),Phase 2 EE/CA documented the process(Army, 1999).

• The Phase 2 EE/CA process addressedadditional known or suspected OE sites notevaluated in Action Memorandum 1 bydeveloping categories for each site based on:(1) expected type of OE present, (2) soiltype, and (3) future land use of the site(USAEDH, 1998). Five removal alternativeswere developed to address each category ofsite. OE data was obtained from theArchives Search Report (ASR) prepared inDecember 1993, the ASR Supplementprepared in November 1994, and theRevised Draft ASR completed in 1997(USAEDH, 1993; 1994; 1997). Apreliminary site reconnaissance wasconducted as part of the ASR to furtheridentify/characterize potential OE sites; theresults are contained in the 1997 ASR. ThePhase 2 EE/CA provided a summary of theamounts and types of OE found duringremoval actions at OE sites on the formerFort Ord at the time the EE/CA wasprepared (Army, 1998c). OE-related dataidentified since that time (and on an ongoingbasis as removal actions are performed) willbe provided in After Action Reports and inthe OE RI/FS.

Area of the former Fort Ord will be managedduring the OE RI/FS process within one of fourproposed tracks (Tracks 0 through 3) which willidentify their status based on establisheddecision criteria.

• Track 0 areas are those that contain noevidence of OE and have never beensuspected as having been used for OE-related activities of any kind based on thecurrent knowledge.

• Track 1 areas are those where OE wassuspected to have been used but was notfound.

• Track 2 areas are those where OE was foundand a removal action has been completed.

• Track 3 areas are those where OE issuspected or known to exist, butinvestigations are not yet complete.


A Proposed Plan proposing no action at theTrack 0 areas was submitted in February 2000(U.S. Army, 2000), and a ROD for the Track 0Areas has been prepared and is awaiting finalregulatory agency approval. The Army is alsopreparing RI/FS reports for Tracks 1 through 3based on an agency-approved schedule.

The Army is proposing OE-related interimactions at three areas at Fort Ord prior tocompletion of the OE RI/FS. The Draft FinalOrdnance and Explosives RemedialInvestigation/Feasibility Study for Ranges 43-48, Range 30A and Site OE-16, Former FortOrd, California was issued on January 18, 2002.A Proposed Plan and ROD for OE InterimAction are also scheduled to be issued in 2002.


12.0 NEXT FIVE-YEAR REVIEW

The next five-year review will be submitted inMay 2007. The next review will include onlythose sites with ongoing remediation, sites thathave not received final agency approval for

closure prior to this report, and sites whereinstitutional controls are in place to precluderesidential use.


13.0 REFERENCES

Dames and Moore, 1993a. Final RemedialInvestigation Report, RemedialInvestigation/Feasibility Study, Fort OrdLandfills, Fort Ord, California. Prepared forUSACE. June 8.

, 1993b. Baseline Risk AssessmentPrepared for USACE. June.

, 1993c. Final Feasibility Study, Fort OrdLandfills, Fort Ord, California. Prepared forUSACE. October 1.

Harding Lawson Associates, 1987. RemedialInvestigation/Feasibility Study of Ground-WaterContamination, Fire Drill Area, Fort Ord,California. Prepared for USACE. June 5.

, 1988a. Fort Ord Landfills: PreliminaryHydrogeologic Investigation, Fort Ord,California. Prepared for USACE. June.

, 1988b. Operation and MaintenanceManual, Soil and Groundwater TreatmentSystem, Fritzsche Army Airfield Fire Drill Area,Fort Ord, California. Prepared for USACE.July.

, 1993a. Final Interim Action FeasibilityStudy, Impacted Surface Soil Remedy, Fort OrdCalifornia. Prepared for USACE. November 4.

, 1993b. Interim Action Proposed PlanImpacted Surface Soil Remedy, Fort OrdCalifornia. Prepared for USACE. November 4.

, 1994a. Draft Final Site CharacterizationSite 37 – Trailer Park Maintenance Shop, FortOrd, California. Prepared for USACE. March18.

, 1994b. Draft Final Site Characterization Site 13 – Railroad Right-Of-Way Fort Ord, California. Prepared for USACE.April 11.

, 1994c. Draft Final Site CharacterizationSite 29 – Defense Reutilization And MarketingOffice, Fort Ord, California. Prepared forUSACE. April 29.

, 1994d. Draft Final OU 1 RemediationConfirmation Study, Fort Ord California.Prepared for USACE. Prepared for USACE.May 3.

, 1994e. Draft Final Site Characterization, Site 27 – Army Reserve MotorPool, Fort Ord, California. Prepared forUSACE. May 16.

, 1995a. Draft Final Site CharacterizationSite 35 – FAAF Aircraft Cannibalization Yard,Fort Ord, California. Prepared for USACE.February 14.

, 1995b. Draft Final Site Characterization Site 28 – Barracks And MainGarrison Area Fort Ord, California. Preparedfor USACE. July 3.

, 1995c. Draft Final Site CharacterizationReport, Site 18 – 1600 Block Facility, Fort Ord,California. Prepared for USACE. July 20.

, 1995d. Draft Final Site Characterization Report, Site 19 – 2200 BlockFacility, Fort Ord, California. Prepared forUSACE. August 8.

, 1995e. Approval Memorandum,Proposed No Action, Site 26 – Sewage PumpStations (Buildings 5871 and 6143), Fort Ord,California. Prepared for USACE. August 10.

, 1995f. Draft Final Basewide RemedialInvestigation Report, RemedialInvestigation/Feasibility Study, Fort Ord,California. Prepared for USACE. October.

References


, 1995g. Draft Final Site Characterization Report, Site 38 – Army and AirForce Exchange Service Dry Cleaners, FortOrd, California. Prepared for USACE.December 18.

, 1996a. Draft Final Site Characterization, Site 40 – Fritzsche ArmyAirfield Defueling Area, Fort Ord, California.Prepared for USACE. January 9

, 1996b. Confirmation Report, Site 14 –707th Maintenance Facility, Fort Ord,California. Prepared for USACE. February 12.

, 1996c. Confirmation Report, Site 30 –Driver Training Area, Fort Ord, California.Prepared for USACE. February 20c.

, 1996d. Site Interim Action Confirmation Report, Site 22 – 4400/4500Motor Pool, West Block, Fort Ord, California.Prepared for USACE. May 22.

, 1996e. Interim Action ConfirmationReport, South 20 – South Parade Ground 3800and 519th Motor Pools, Fort Ord, California.Prepared for USACE. July 1.

, 1996f. Interim Action ConfirmationReport, Site 21 – 4400/4500 Motor Pool, EastBlock, Fort Ord, California. Prepared forUSACE. July 10.

, 1996g. Draft Final Site Characterization Report, Site 33 - Golf Course,Fort Ord, California. Prepared for USACE.August 1.

, 1996h. Draft Field Investigation andData Review, Solid Waste Management Units,Fort Ord, California. Prepared for USACE.August 8.

, 1996i. Confirmation Report Site 15Directorate of Engineering and Housing Yard,Fort Ord. Prepared for USACE. August 13.

, 1996j. Interim Action ConfirmationReport, Site 8 – Range 49 (Molotov CocktailRange), Fort Ord, California. Prepared forUSACE. August 26.

, 1996k. Interim Action ConfirmationReport, Site 10 – Burn Pit, Fort Ord, California.Prepared for USACE. August 30.

, 1996l. Site Characterization Report, Risk Assessment, Site 25 - Former DRMO, FortOrd, California. Prepared for USACE. October14.

, 1996m. Draft Final Operation &Maintenance Manual OU1, GroundwaterTreatment System, Fort Ord. Prepared forUSACE. November 12.

, 1996n. Draft Final Site Characterization Report, Site 11 – Army and AirForce Exchange Service Fueling Station, FortOrd, California. Prepared for USACE.December 3.

, 1997a. Interim Action ConfirmationReport, Site 40 - Fritzsche Army AirfieldDefueling Area, Fort Ord, California. Preparedfor USACE. January 2.

, 1997a. Interim Action ConfirmationReport, Site 6 -Range 39 (Abandoned CarDump), Fort Ord, California. Prepared forUSACE. January 2.

, 1997b. Interim Action ConfirmationReport, Site 24 – Old DEH Yard, Fort Ord,California. Prepared for USACE. January 23.

, 1997c. Interim Action ConfirmationReport, Site 41 - Crescent Bluff Fire Drill Area,Fort Ord, California. Prepared for USACE.February 4.

, 1997d. Draft Final Site CharacterizationReport, Site 23 – 3700 Block MotorpoolComplex, Fort Ord, California. Prepared forUSACE. May 16.

References


, 1997e. Interim Action ConfirmationReport, Site 39B – Inter-Garrison Site,Fort Ord, California. Prepared for USACE.April 2.

, 1997f. Interim Action ConfirmationReport, Outfalls 34 and 35 – Fritzsche ArmyAirfield, Fort Ord California. Prepared forUSACE. June 20.

, 1997g. Interim Action ConfirmationReport, Site 36 – Fritzsche Army AirfieldSewage Treatment Plant, Fort Ord, California.Prepared for USACE. June 20.

, 1997h. Draft Final Closure Plan, DRMOHazardous Waste Container Storage Unit,Former Fort Ord, California. Prepared forUSACE. March 25.

, 1997i. Draft Closure Plan, Range 36A,Former Fort Ord, California. Prepared forUSACE. August 8.

, 1997j. Interim Action ConfirmationReport, Site 1 – Ord Village Sewage TreatmentPlant, Fort Ord, California. Prepared forUSACE. December 10.

, 1998a. Interim Action ConfirmationReport, Site 32 – East Garrison SewageTreatment Plant, Fort Ord, California. Preparedfor USACE. March 5.

, 1998b. The Interim Action ConfirmationReport, Outfall 15, Former Fort Ord,California. Prepared for USACE. September 3.

, 1998c. Draft Final Additional EcologicalRisk Evaluations, Site 3 - Beach TrainfireRanges, Former Fort Ord, California. Preparedfor USACE. October 14.

, 1998d. Interim Action ConfirmationReport, Site 39A – East Garrison Ranges,Former Fort Ord, California. Prepared forUSACE. October 16.

, 1999a. Final Enhanced PreliminaryAssessment of Monterey Bay, Fort Ord,California. Prepared for USACE. January 12.

, 2002b. Draft Closure Plan, DRMO PCBStorage Building T-111, Fort Ord, California.Prepared for USACE. .

, 1999c. Draft Final, Five-Year StatusReport and Effectiveness Evaluation, OperableUnit 1 Groundwater Treatment System, FortOrd California. Prepared for USACE.November 29.

, 2000a. Closure Certification Report,DRMO Hazardous Waste Container StorageUnit, Former Fort Ord, California. Prepared forUSACE. December 6.

, 2000b. Technical MemorandumRegarding Freon 113 in the Subsurface NearOU 1 and Site 40, Former Fort Ord, California.Prepared for USACE. December 15.

Harding ESE, 2001a. Draft Data SummaryReport, Investigation of Magnetic Anomalies,East Garrison Area, Former Fort Ord,California. Prepared for USACE. January 11.

, 2001b. Draft Data Summary Report,FAAF Three Sites, Former Fort Ord, California.Prepared for USACE. January 29.

, 2001c. Draft Final Work Plan, SilverRecovery Unit (Solid waste Management UnitFTO-021), Former Fort Ord, California.Prepared for USACE. March 26.

, 2001d. Draft, Natural AttenuationSummary Report, Carbon TetrachlorideInvestigation, Former Fort Ord, California.Prepared for USACE. November 29.

, 2002a. Draft Final Ordnance andExplosives Remedial Investigation/FeasibilityStudy for Ranges 43-48, Range 30A and SiteOE-16, Former Fort Ord, California. Preparedfor USACE. January 18.

, 2002b. Closure Report, Silver RecoveryUnit (Solid Waste Management Unit FTO-021),Former Fort Ord, California. Prepared forUSACE. January 24.

References


and IT Corp (Harding ESE/IT), 2001a.Work Plan, Revision 0, Operation andMaintenance, Groundwater Treatment Systems,Former Fort Ord, California. Prepared forUSACE. March 14.

and IT Corp (Harding ESE/IT), 2001b.Annual Evaluation Report, October 1999through September 2000, OU 1 and OU 2Groundwater Remedies, Former Fort Ord,California. Prepared for USACE. June 20.

and IT Corp (Harding ESE/IT), 2001c.Quarterly Groundwater Treatment SystemsOperation Data Summary Report, July throughSeptember 2001, Operable Unit 1, OperableUnit 2, Sites 2/12, Former Fort Ord, California.Prepared for USACE. November 29.

and IT Corp (Harding ESE/IT), 2001d.Revision C, Sites 2 and 12 GroundwaterRemedy, Operating Properly and SuccessfullyEvaluation Report Former Fort Ord, California.Prepared for USACE. November 8.

and IT Corp (Harding ESE/IT), 2001e.Sampling and Analysis Plan, Revision 1,Operable Unit 1, Operable Unit 2, and Sites 2and 12, Groundwater Treatment Systems,Former Fort Ord, California. Prepared forUSACE. December 20.

and IT Corp (Harding ESE/IT), 2001f.Revision C, Conceptual Design, OU 1Groundwater Remedy Expansion, Former FortOrd California. Prepared for USACE. December20.

IT Corp, 1999a. Draft Final Remedial ActionConfirmation Report and Post-RemediationHealth Risk Assessment, Site Sites 16 & 17, FortOrd, California. Prepared for USACE. April 27.

, 1999b. Draft Final Remedial ActionConfirmation Report, Site 31 Remedial Action,Basewide Remedial Sites, Fort Ord, California.Prepared for USACE. April 29.

, 1999c. Draft Final Remedial ActionConfirmation Report and Post-RemediationHealth Risk Assessment, Site 12 RemedialAction, Fort Ord, California. Prepared forUSACE. June 1.

, 1999d. Groundwater Remedial ActionWork Plan, Operable Unit 2 GroundwaterRemedy System Expansion. Prepared forUSACE. December.

, 2000a. Post Closure Operations andMaintenance Plan Areas B through F, OperableUnit 2 Landfills, Remedial Action, Fort Ord,California. Prepared for USACE. May 2000

, 2000b. Final Remedial ActionConfirmation Report and Post-RemediationHealth Risk Assessment, Revision 0, Site 3Remedial Action, Fort Ord, California. Preparedfor USACE. August 8.

, 2000c Remedial Action ConfirmationReport, Site 39, Ranges 24 And 25 And Post-Remediation Risk Assessment Site 39, Ranges24, 25, 26, Fort Ord, California. Prepared forUSACE. March 1.

, 2001a. Draft Remedial ActionConfirmation Report And Post-RemediationScreening Risk Evaluation Area A, OperableUnit 2 Landfills. Prepared for USACE. April 30.

, 2001b. Draft Final Basewide RangeAssessment Work Plan and Contractor QualityControl Plan Small Arms and Multi-UseRanges, Fort Ord, California. Prepared forUSACE. July 26.

, 2002. Draft Operation and MaintenanceManual Operable Unit 2 Groundwater Remedy,Former Fort Ord, California. Prepared forUSACE. January 1.

Monterey County Planning Department[MCPD], 1984. Greater Monterey PeninsulaArea Plan (Part of Monterey County GeneralPlan). Prepared for Monterey County.

References


Uribe and Associates, 1998. Interim ActionConfirmation Report, Site 34, Fritzsche ArmyAirfield Fueling Facility, Fort Ord, California.Prepared for USACE. September 8.

, 1999a. Final Closure Plan, CleanClosure Project, Fort Ord Soil Treatment Area(FOSTA) and Underground Storage TankRemediation Area (USRA), 519th Motor Pool,Fort Ord California, Revision 3.

, 1999b. Final Quality Control ProjectPlan and Sampling and Analysis Plan, CleanClosure Project, Fort Ord Soil Treatment Area(FOSTA) and Underground Storage TankRemediation Area (USRA), 519th Motor Pool,Fort Ord, California, Revision 3.

, 1999c. Final Closure Report, CleanClosure Project, Underground Storage TankRemediation Area (USRA), 519th Motor Pool,Fort Ord, California, Revision C.December 1999.

, 1999d. Final Closure Report, CleanClosure Project, Former Fort Ord SoilTreatment Area (FOSTA), 519th Motor Pool,Fort Ord, California, Revision C.December 1999.

U.S. Army (Army), 1994a. Interim ActionRecord of Decision, Contaminated Surface SoilRemediation, Fort Ord, California.

, 1994b. Fort Ord Ordnance andExplosive Waste Time-Critical Removal ActionMemorandum, Former Fort Ord, MontereyCounty, California. Final. September.

, 1994c. Final Record of Decision,Operable Unit 2, Fort Ord Landfills, Fort Ord,California. July 15.

, 1995a. No Action Record of DecisionFort Ord, California. February.

, 1995b. U.S. Army Record of Decision,Operable Unit 1, Fritzsche Army Airfield FireDrill Area, Fort Ord, California. July 25.

, 1995c. Explanation of SignificantDifferences, Operable Unit 2, Fort OrdLandfills. August 3.

, 1995d. Explanation of SignificantDifferences, Area A, Operable Unit 2, Fort OrdLandfills. August 3.

, 1997a. Explanation of SignificantDifferences, Consolidation of RemediationWaste in a corrective Action Management Unit(CAMU), Operable Unit 2, Fort Ord Landfills.January 13.

, 1997c. Interim Record of Decision Site 3Beach Trainfire Ranges Fort Ord. January 13.

, 1997b. Record of Decision, BasewideRemedial Investigation Sites, Fort Ord,California. January 13.

, 1998a. Final Action Memorandum 1,Twelve Sites, Phase 1 EngineeringEvaluation/Cost Analysis, Ordnance andExplosives Sites, Former Fort Ord, MontereyCounty, California. January 23.

, 1998c. Engineering Evaluation/CostAnalysis – Phase 2, Former Fort Ord, MontereyCounty, California. Final. April.

, 1999. Final Action Memorandum, Phase2 Engineering Evaluation/Cost Analysis,Ordnance and Explosives Sites. Former FortOrd, Monterey County, California.

, 2000. No Action is Proposed for Selected Areas at Fort Ord, California. February 1.

U.S. Army Design Engineering and SupportCenter, Huntsville (USAEDH), 1993. ArchivesSearch Report. Fort Ord, California, MontereyCounty, California. Prepared by U.S. ArmyCorps of Engineers, St. Louis District.December.

References


, 1994. Archives Search Report(Supplement No. 1). Fort Ord, California,Monterey California. Prepared by U.S. ArmyCorps of Engineers, St. Louis District.November.

, 1997. Draft Revised Archives SearchReport, Former Fort Ord, California. MontereyCounty, California. Prepared by U.S. ArmyCorps of Engineers, St. Louis District.

U.S. Environmental Protection Agency, 1993.Region IX Preliminary Remediation Goals(PRGs) Fourth Quarter 1993. November 1.

U.S. Environmental Protection Agency, 1999.Region IX Preliminary Remediation Goals(PRGs) 1999. October 1.

PLATES

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION lX

75 nanrlhorne sweet San Francisco. CA 94105

April 22,2002

Department of the Army Environmental and Natural Resources Attn: Gail Youngblood P.O. Box 5004 Prcsi&o of Monterey, California 93944-5004

Re: Drafl Five-Year Review Report Firsi Five-Year Review Report for FoH Ortl Superfund Site Monterey, California, February 27,2002

Dear Ms. Youngblood:

The U.S. Environmental Protection Agency's (EPA's) comments on the referenced report are attached. EPA's comments are minor in nature, us your first five-year review substantially conforms to EPA's Comprehensive Five-Year Review Guidance. Pursuant to our Guidance, all comments received from agencies and the community should be attachcd to the final report.

If you would like to discuss these comments, I may be reached at (415) 972-3005.

Sincerely,

John D. Chesnutt Remedial Project Manager

cc; Rizgar (ihazi, DTSC Grant Himebaugh, RWQCB

US. EPA Comments on the Drafr Five-Year Review Reporl First Five-Year Review Report for Fort Ord Superfund Site Monterey, California, February 27,2002

GENERAL CObIMENTS

1. Institutionill controlsldeed reshictions - A number of soil and groundwater remedies include the use of instirutional controlddeed resuictions, at least until the remedy is complete. These are treated inconsistently throughout the report. Please clearly identify where institutional controlddeed restrictions are components of a remedy. and how each controYrcstriction was implemented (e.g., County GW Ordinance, CRUP, deed restriction, notice). Also differentiate between affected properties that have already been transfe~~ed and those still within Army control.

2. Where soil remedies were completed and allow for unresticted reuse, please make that clear in thc remedy implementation and protectiveness sections.

SPECIFIC COMMENTS

Site Inspections

3. Page 15, Section 4.4.2 -In the description of the site inspection results it says there was extensive (dune erosion noted from the "Stormwater Outfdls". This doesn't seem to be mentioned anywhere in the RI Sites section. Since the Counry and others have designated the dune area an "environmentally sensitive area" it would be good to say more (e.g. funding selcured to fix problem, erosion unrelated to the cleanup work).

Operable Unlt (OU) 1

4. Page 19, Question A - The EPA Five-Year Review guidance suggests this Quesrion address the issue of whether monitoring is adequate. Arc additional monitoring wells required to address the downgradient contamination not currently being captured? If so, ir would be good to mention them here.

5. Page 20, Question C - This would be a good place to note whether any addmonal source area investigation is needed. or if the new plume portton is an uncaptured piece of the existing plume.

6. Page 31, Question C, Cell F landfill gas issue - Additional discussion of the landfill gas issue is wrmnted here, since on page 14 this gas extraction system is described as "a pilot test ... to icduce the amount of landfill gas at the property line of Cell P to meet regulatory standards." This discussion here on page 31 needia little more detail. Is it an ARAR in ,the ROD that is the issue? How is the pilot system working so far? If it 's working, does it need to be expanded? If it isn't working, what will be tried next? In the meantime, describe whether anyone is living or working nearby.

7. Page 32, S,ection 6.6 -The prorecdveness statement only addresses groundwater, not the landfill calp. Need to add a statement for the landfill that includes the gas issue.

Basewide RI Sites

8. Page 39, Sites 2/12 groundwater, Selected remedy - The groundwater remedy includes deed restrictions on groundwater use. Please include in the remedy implementation section 7.1..2.2 and protectiveness statement section 7.1.6 a description of deed restrictions used (e.g., County GW Ordinance) until the ACLs are met.

9. Page 40, Siite 2/12 soils, Section 7.1.2.2, and Page 45, Section 7.1.6 (Protectiveness Statement:) - Please indicate the soil remedy resulted in the site being available for unrestricte:d reuse.

10. Page 51, Slites 16117, Section 7.2.6 (Protectiveness Statement) - Please indicate the remedy is protective of human health and the environment for anv use.

11. Page 62, Site 39, Section 7.4.6 - The protectiveness statement should read "is expected to be protecti~ve," not "is intended to be protective," assuming we do expect that. The remedy includes "deed restrictions until remaining ordnance and explosives are removed." Are these deed restricttons in place?

12. Page 63. Site 39, Section 7.5.2.2 (Rcmedy Implementation) -Please indicate the remedy was no fu~ther action, and allows for unrestricted reuse.

Interim Action Sites

13. Pages 82-89, Section 10.2.2 - Many of the site writcups indicate the IA Confirmatton Reports h ~ v e been submitted and are pending approval from regulatory agencies. Please note that EPA has approved all confirmation reports with the exception of the Outfall 15 Report, which we have reviewed and requested additional information.

Carbon Tetrachloride Ptumes

14. Page 92 -The discussion mentions one of the Carbon Te1 plumes is co-mingled with the OU2 plume. This should also be noted in the OU2 discussion.

Monterey Bay Enhanced Preliminary Assessment

15. Pages 95-!)6, Section 11.2 -This discussion should also include reference to the Army's participation in an effort with the Monterey Bay National Marine Sanctuary, the US Geological Survey, regulatory agencies, imd local m&ne research facilities to investigate sediment 2nd biota, and map the ocean floor in the restricted zone and adjacent areas in Monterey Bay off Fort Ord.

Range 36A

16. Page 103, Section 11.7.4 -The Background section describes how the site wns used for additional actlvit~es after the 1992 RI was performed. Please include information on your additional closure plan activities to invest~gate any contamnation associated with the act~vities which began in 1994.

OE Program

17. Page 107, Section 11.8.2 (Status Report) - Please include a short description of the fact that the Army is preparing RT/FS reports for OE Tracks 1-3 pursuant to agency-approved schedules.

Minor comments

18. The NCP criterion is "Reduction of toxicity, mobility, and volume thou& trearrnent." Please cite col~ectly for excavation and containment remedies.

19. Page 101, Section 11.7.2 (Silver Recovery Unit), first sentence -Please correct the date the unit was removed.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

75 Hawthorne Street San Francisco, CA 94105

Department of the Army Environmental and Natural Resources Attn: Gail Youngb~lood P.O. Box 5004 Presidio of Monterey, California 93944-5004

Re: Draft Five-Year Review Report First Five-Year Review Report for Fort Ord Superfund Site Monterey, California, February 27,2002

Dear Ms. Youngbl'ood:

The U.S. Environmental Protection Agency's (EPA's) comments on the referenced report are attached. EPA's comments are minor in nature, as your first five-year review substantially conforms to EPA's Comprehensive Five-Year Review Guidance. Pursuant to our Guidance, all comments received from agencies and the community should be attached to the final report.

If you would like to discuss these comments, I may be reached at (415) 972-3005

Sincerely,

John D. Chesnutt Remedial Project Manager

cc: Rizgar Ghazi, DTSC Grant Himebaugh, RWQCB

U.S. EPA Comments on the Drafi Five-Year Relview Report First Five-Year Review Report for Fort Ord Superfund Site Monterey, California, February 27,2002

GENERAL COMMENTS

1. Institutional controlsldeed restrictions - A number of soil and groundwater remedies include the use of institutional controlddeed restrictions, at least until the remedy is complete. Tliese are treated inconsistently throughout the report. Please clearly identify where institutional controlsldeed restrictions are components of a remedy, and how each control/restriction was implemented (e.g., County GW Ordinance, CRUP, deed restriction, notice). Also differentiate between affected properties that have already been transferred and those still within Army control.

2. Where soil remedies were completed and allow for unrestricted reuse, please make that clear in the remedy implementation and protectiveness sections.

SPECIFIC COMMENTS

Site Inspections

3. Page 15, Sect.ion 4.4.2 - In the description of the site inspection results it says there was extensive dune erosion noted from the "Stormwater Outfalls". This doesn't seem to be mentioned anywhere in the RI Sites section. Since the County and others have designated the dune area an "environmentally sensitive area" it would be good to say more (e.g. funding secured to fix problem, erosion unrelated to the cleanup work).

Operable Unit (OU) 1

4. Page 19, Question A -The EPA Five-Year Review guidance suggests this Question address the issue of whether monitoring is adequate. Are additional monitoring wells required to address the downgradient contamination not currently being captured? If so, it would be good to mention them here.

5. Page 20, Quelstion C - This would be a good place to note whether any additional source area investigation is needed, or if the new plume portion is an uncaptured piece of the existing plume.

6. Page 31, Question C, Cell F landfill gas issue - Additional discussion of the landfill gas issue is warranted here, since on page 14 this gas extraction system is described as "a pilot test ... to reduce the amount of landfill gas at the property line of Cell F to meet regulatory st;andards." This discussion here on page 31 needs a little more detail. Is i t an ARAR in the ROD that is the issue? How is the pilot system working so far? If it's working, does it need to be expanded? If it isn't working, what will be tried next? In the meantime, describe whether anyone is living or working nearby.

7. Page 32, Section 6.6 -The protectiveness statement only addresses groundwater, not the landfill cap. Need to add a statement for the landfill that includes the gas issue.

Basewide RI Sites

8. Page 39, Sites 2/12 groundwater, Selected remedy -The groundwater remedy includes deed restrictions on groundwater use. Please include in the remedy implementation section 7.1.2.2 and protectiveness statement section 7.1.6 a description of deed restrictions used (e.g., County GW Ordinance) until the ACLs are met.

9. Page 40, Site 2/12 soils, Section 7.1.2.2, and Page 45, Section 7.1.6 (Protectiveness Statement) - Please indicate the soil remedy resulted in the site being available for unrestricted reuse.

10. Page 51, Siteis 16/17, Section 7.2.6 (Protectiveness Statement) - Please indicate the remedy is protective of human health and the environment for anv use.

11. Page 62, Site 39, Section 7.4.6 - The protectiveness statement should read "is expected to be protective," not "is intended to be protective," assuming we do expect that. The remedy includes "deed restrictions until remaining ordnance and explosives are removed." Are these deed restrictions in place?

12. Page 63, Site 39, Section 7.5.2.2 (Remedy Implementation) - Please indicate the remedy was no further action, and allows for unrestricted reuse.

Interim Action Sites;

13. Pages 82-89, Section 10.2.2 - Many of the site writeups indicate the IA Confirmation Reports have been submitted and are pending approval from regulatory agencies. Please note that EPA has approved all confirmation reports with the exception of the Outfall 15 Report, which1 we have reviewed and requested additional information.

Carbon Tetrachloride Plumes

14. Page 92 - Thl: discussion mentions one of the Carbon Tet plumes is co-mingled with the OU2 plume. This should also be noted in the OU2 discussion.

Monterey Bay Enhanced Preliminary Assessment

15. Pages 95-96, Section 11.2 -This discussion should also include reference to the Army's participation in an effort with the Monterey Bay National Marine Sanctuary, the US Geological Survey, regulatory agencies, and local marine research facilities to investigate sediment and biota, and map the ocean floor in the restricted zone and adjacent areas in Monterey Bay off Fort Ord.

Range 36A

16. Page 103, Section 11.7.4 - The Background section describes how the site was used for additional acl.ivities after the 1992 RI was performed. Please include information on your additional closure plan activities to investigate any contamination associated with the activities which began in 1994.

OE Program

17. Page 107, Section 11.8.2 (Status Report) - Please include a short description of the fact that the Army is preparing RI/FS reports for OE Tracks 1-3 pursuant to agency-approved schedules.

Minor comments

18. The NCP criterion is "Reduction of toxicity, mobility, and volume through treatment." Please cite correctly for excavation and containment remedies.

19. Page 101, Section 11.7.2 (Silver Recovery Unit), first sentence - Please correct the date the unit was removed.

Documents

FIVE YEAR REVIEW · 2 five-year review sites and operable units appendix a response to comments on the draft five-year review report, first five-year review report for fort ord superfund