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

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

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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.
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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
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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
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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.
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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?
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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
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9. Navy’s Five-Year Review
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10. Estimated TCE Shallow
Groundwater Contamination
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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. 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
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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
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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. 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.
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