Moffett RAB EPA Five-Year Review

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Presentation to the Moffett Field Restoration Advisory Board May 13, 2010: EPA Five-Year Reviews, Alana Lee, EPA

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Moffett RAB EPA Five-Year Review

  1. 1. EPA Five-Year Review Process Former Naval Air Station Moffett Field Restoration Advisory Board Meeting May 13, 2010 Alana Lee, EPA Project Manager Lee.Alana@epa.gov
  2. 2. 2
  3. 3. Purpose of Five-Year Review To determine whether the Site remedy is or upon completion will be protective of human health and the environment. 3
  4. 4. Roles and Responsibilities Navy’s Role as Lead Agency • Navy is responsible for conducting and writing the Five-Year Review report • Conducting community involvement activities • Tracking and implementing issues and recommendations identified 4
  5. 5. EPA’s Role • EPA reviews the report and provides comments including recommendations for follow-up actions • EPA is responsible for concurring or non- concurring on the protectiveness statement • EPA signs the report or issues a concurrence/non-concurrence memo • EPA maintains authority to determine protectiveness statements for ALL sites regardless of lead agency 5
  6. 6. Five-Year Review Process •Notify the community. • Conduct data and document review. • Conduct interviews and site inspections • Identify issues. • Develop recommendations and follow-up actions. • Develop protectiveness statement. 6
  7. 7. Assessing protectiveness of the remedy Question A: Is the remedy functioning as intended by the decision documents? Question B: Are the exposure assumptions, toxicity data and remedial action objectives used at the time of remedy selection still valid? Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 7
  8. 8. Protectiveness Statements • Protective - The remedy is protective of human health and the environment • Protective in the Short-Term - The remedy is protective of human health and the environment in the short-term • Will be Protective - The remedy will be protective of human health and the environment • Not Protective - The remedy is not protective of human health and the environment • Protectiveness Deferred - The protectiveness of the remedy is deferred until further information is obtained 8
  9. 9. Navy’s Five-Year Review 9
  10. 10. Estimated TCE Shallow Groundwater Contamination 10
  11. 11. Site 28 Issues Follow-up Actions Issues and Follow-up Actions Indoor air sampling has not been Sample and evaluate unsampled performed at many of the buildings buildings within the Vapor Intrusion within EPA’s Vapor Intrusion Study Study Area on Moffett Field. Area Existing groundwater remedy does Amend the 1989 Record of Decision not address the vapor intrusion for the MEW Study Area to address pathway. the vapor intrusion pathway. Potential contaminant sources in Implement Treatability Study Pilot former Building 88 area, associated Tests, consider the results in Site-wide sewer lines, and the Traffic Island Feasibility Study, and implement any Area. recommended actions. Mass removal efficiency of current Prepare Site-wide Groundwater groundwater remedy ineffective. No Feasibility Study to evaluate alternate institutional controls for groundwater technologies to effectively expedite groundwater cleanup. 11
  12. 12. Protectiveness Statements • Protective - The remedy is protective of human health and the environment • Protective in the Short-Term - The remedy is protective of human health and the environment in the short-term • Will be Protective - The remedy will be protective of human health and the environment • Not Protective - The remedy is not protective of human health and the environment • Protectiveness Deferred - The protectiveness of the remedy is deferred until further information is obtained 12
  13. 13. The Remedy is Not Protective when: • An immediate threat is present (e.g., exposure pathways that could result in unacceptable risks are not being controlled) • Migration of contaminants is uncontrolled and poses an unacceptable risk to human health or the environment • Potential or actual exposure is clearly present or there is evidence of exposure (e.g., institutional controls are not in place or not enforced and exposure is occurring) or • The remedy cannot meet a new cleanup level and the previous cleanup level is outside of the risk range 13
  14. 14. EPA Protectiveness Assessment • The remedy at Site 28, WATS Area, is NOT protective because it does not adequately address the potential long-term health risks from TCE from the vapor intrusion pathway. • Remedial actions are necessary to ensure the protection of human health. • The vapor intrusion remedy will be incorporated into the overall MEW Site remedy through an Amendment to the 1989 MEW Record of Decision (ROD).
  15. 15. Follow-up Actions to Ensure the Protectiveness of the Remedy • Finalize the ROD Amendment for the vapor intrusion pathway. • Complete baseline sampling and evaluation of buildings within the Vapor Intrusion Study Area • Implement remedial actions on buildings, as needed. • Enhance groundwater cleanup efforts by implementing facility-specific and Regional optimization plans • Evaluate and perform treatability studies of alternative groundwater cleanup technologies to expedite cleanup. 15

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