EPA Five-Year Review Process

Former Naval Air Station Moffett FieldRestoration Advisory Board Meeting

May 13, 2010

Alana Lee, EPA Project ManagerLee.Alana@epa.gov

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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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Roles and ResponsibilitiesNavy’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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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

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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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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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

Navy’s Five-Year Review

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Estimated TCE ShallowGroundwater Contamination

Issues and Follow-up ActionsSite 28 Issues Follow-up Actions

Indoor air sampling has not been performed at many of the buildings within EPA’s Vapor Intrusion Study Area

Sample and evaluate unsampled buildings within the Vapor Intrusion Study Area on Moffett Field.

Existing groundwater remedy does not address the vapor intrusion pathway.

Amend the 1989 Record of Decision for the MEW Study Area to address the vapor intrusion pathway.

Potential contaminant sources in former Building 88 area, associated sewer lines, and the Traffic Island Area.

Implement Treatability Study Pilot Tests, consider the results in Site-wide Feasibility Study, and implement any recommended actions.

Mass removal efficiency of current groundwater remedy ineffective. No institutional controls for groundwater

Prepare Site-wide Groundwater Feasibility Study to evaluate alternate technologies to effectively expedite groundwater cleanup. 11

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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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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

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).

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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