N40003.AR PUERTO RICO NS a

Transcription

1 N40003.AR PUERTO RICO NS a FINAL WORKPLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) FACILITY ASSESSMENT FOR PERFLUORINATED COMPOUNDS NAVAL ACTIVITY PUERTO RICO 1/1/2017 CH2M HILL

2 FINAL TECHNICAL MEMORANDUM Work Plan for Conducting a Resource Conservation and Recovery Act Facility Assessment for Perfluorinated Compounds, Naval Activity Puerto Rico, Ceiba, Puerto Rico PREPARED FOR: PREPARED BY: DATE: January 2017 United States Environmental Protection Agency Puerto Rico Environmental Quality Board CH2M HILL, Inc. on behalf of the Department of the Navy, Naval Facilities Engineering Command Atlantic Introduction This work plan presents the approach for conducting a Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) to determine locations of suspected environmental release of perfluorinated compounds (PFCs) at Naval Activity Puerto Rico (NAPR), located in Ceiba, Puerto Rico. This work plan has been prepared under the Department of the Navy (Navy), Naval Facilities Engineering Command (NAVFAC) Atlantic, Comprehensive Long Term Environmental Action Navy (CLEAN) 8012, Contract No. N D 8012, Contract Task Order JM17. Although an Environmental Condition of Property (ECP) report has been finalized for NAPR to document the environmental conditions and determine the presence, likely presence, release, or likely release of any hazardous substance or petroleum product, PFCs were not assessed for the ECP report. This is because these compounds were identified as emerging contaminants by the United States Environmental Protection Agency (USEPA) following finalization of the report and subsequent RCRA 7003 Administrative Order on Consent in 2007, which established the Navy s obligations for cleanup at NAPR. USEPA defines an emerging contaminant as a chemical or material characterized by a perceived, potential, or real threat to human health or the environment or by a lack of published health standards. A contaminant also may be "emerging" because of the discovery of a new source or a new pathway to humans. Objectives This work plan presents the procedures that will be followed for conducting the first two steps (the preliminary review and visual site inspection [VSI] steps) of the RFA process to assess potential PFCs releases at NAPR. The objectives of this assessment are as follows: Identify and gather information on potential PFCs releases Evaluate solid waste management units (SWMUs) and other areas of concern for PFCs releases to all media and regulated units for releases to media other than ground water Make preliminary determinations regarding PFCs releases of concern and the need for further actions and interim measures at the facility Screen from further investigation those SWMUs and other areas of concern which do not pose a threat to human health or the environment To accomplish these objectives, the following activities will be completed: A preliminary review of the following will be conducted to identify and characterize potential PFCs releases and focus activities conducted during the VSI: Existing information, such as inspection reports, permit applications, historical monitoring data Supplemental information obtained by interviews conducted with relevant site personal EN VBO 1

3 WORK PLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT FACILITY ASSESSMENT FOR PERFLOURINATED COMPOUNDS A visual site inspection of the facility will be conducted to identify any evidence of PFCs releases, ensure that all SWMUs and areas of concern have been identified, fill data gaps identified in the preliminary review, and focus recommendations concerning the need for interim measures, a RCRA Facility Investigation (RFI), or no further action. Findings will be summarized in a report with recommendations on the path forward for SWMUs and areas of interest identified. Facility Background and Description NAPR, formerly Naval Station Roosevelt Roads (NSRR), consists of approximately 8,600 acres (USEPA, 2007) of land located on the east coast of Puerto Rico (Figure 1). NAPR is bordered to the west by mainland Puerto Rico, with the nearest municipality, Ceiba, to the west and north, and the municipality of Naguabo to the southwest. Fajardo is the nearest major town, located 8 miles to the north. NAPR is bordered to the east and south by the Vieques Passage, which opens up into the Caribbean Sea. Military activity in the area started in 1941 when Fort Bundy was established on what is now the southwest portion of NAPR (NAVFAC, 2005). Fort Bundy was the headquarters for coastal artillery emplacements. In 1943, NSRR was established on the northeast portion of what is now NAPR. NSRR provided both training and support to the Atlantic fleet operations throughout the Caribbean. Fort Bundy and NSRR both remained active until the end of World War II, and were then maintained between World War II and 1957, both being deactivated and reactivated several times throughout this time. In 1957, Fort Bundy was incorporated into NSRR. NSRR then became home to the Atlantic Fleet Guided Missile Training Operations Center, which provided missile support facilities and training to Atlantic fleet submarine units. The facility was then commissioned separately as the Atlantic Fleet Weapons Training Facility shortly after the Cuban Missile Crisis in As a result of the United States treaty with Panama in 1979 that stipulated the United States would remove its military presence from Panama, the United States relocated the Special Operations Command South to NSRR in 1999 and When the 2004 Defense Appropriations Act was signed on September 30, 2003, it required that NSRR was to be disestablished within 6 months, and that the real estate disposal and transfer would be carried out according to procedures outlined per the Defense Base Closure and Realignment Act of 1990 (NAVFAC, 2005). Therefore, on March 31, 2004, NSRR was closed and NAPR was established to oversee the property as caretaker and to assist in the property transfer (NAVFAC, 2005). The Navy has transferred the majority of the land as part of the Economic Development Conveyance parcel on January 12, However, the Navy retained the responsibility for site characterization and, if necessary, corrective action. Prior to the NSSR closure property transfer, a Draft Phase I ECP Report was prepared to document the environmental conditions of NSRR based on investigations, interviews, and a review of available information and data. The objective of the ECP Report was to categorize all of the property on NSRR and to determine the presence, likely presence, release, or likely release of any hazardous substance or petroleum product. A Phase II ECP investigation was performed to provide supplemental data to evaluate the SWMUs, areas of concern, and ECP sites that had been identified and to determine the path forward for each. The Phase I/II ECP Report (NAVFAC, 2005) recommended that further investigation activities occur for many sites. Following the Phase II ECP investigation, the USEPA issued RCRA 7003 Administrative Order on Consent in 2007, which established the Navy s obligations for cleanup at NAPR (USEPA, 2007). Subsequent to the Consent Order, PFCs were identified by the Navy as emerging contaminants and Navy policy issued in 2014 and 2015 required assessment of possible impacts from PFCs. This RFA is being performed in response to that Navy directive. Assessment and Reporting The PFCs assessment will involve collecting and reviewing existing and available information associated with PFCsrelated activities at NAPR. When possible, data collection will be conducted using internet based data sources. Some data collection activities will warrant onsite activities such as archival research, interviews, and site visits. 2 EN VBO

4 Preliminary Review WORK PLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT FACILITY ASSESSMENT FOR PERFLOURINATED COMPOUNDS The preliminary review will be conducted to gather and evaluate existing information to identify and characterize potential releases and focus the activities to be conducted during the VSI. Gathering Information The first step of the preliminary review will consist of collecting information that will provide evidence of the potential for a PFCs release. The information will be obtained from existing written information and documents and interviews conducted with relevant individuals. Written Information and Documents The majority of the information gathered will be through national and local archive/file searches and desktop information collection. National archive data sources and data repositories may include NAVFAC real estate archives and National Archives centers in Washington, D.C.; College Park, Maryland; and Philadelphia, Pennsylvania. The National Archives rules, procedures, and practices 1 will be followed when researching records. Desktop data sources may include internet websites (NAPR Environmental Restoration Program [ERP] website, USEPA website, Puerto Rico Environmental Quality Board website, municipality of Ceiba website), previous investigation reports, newspapers, municipality of Ceiba public records, and NAPR Facilities Operations records. The following information will be gathered where available: Maps and aerial photographs of NAPR Environmental, cultural, and historical conditions Locations of registered private wells and public/municipal water supply wells Drinking water population served by both private and public/municipal wells Floodplain boundaries and quantified flood frequency for surface water bodies Population within a 1 mile radius of the base boundary Sensitive environments (e.g., wetlands, threatened or endangered species habitat, designated wilderness areas, critical habitat, etc.). Schools (day care, pre school, primary, secondary, colleges) within a quarter mile radius of the base boundary Environmental surveys, studies, or assessments, including: Physical investigations Groundwater quality data Chemical sample results Results from previous surface clearances/maintenance, geophysical surveys, and sampling programs Identification of potential pathways and receptors Reports of aircraft crashes or other emergency uses of aqueous film forming foam (AFFF) Real estate records Environmental cleanup records, including documentation of releases, incident reports, and spill logs 1 card.html#orientation EN VBO 3

5 WORK PLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT FACILITY ASSESSMENT FOR PERFLOURINATED COMPOUNDS Newspaper articles Property re use, transfer plans (zoning plans, deeds), and installation master plans Available geographic information system (GIS) data Desktop Data Documentation Copies of pertinent data will be kept and filed as allowed. A Document Log Sheet (Attachment 1) entry will be made at the time of collection. This log will include the following information: Data source Date/time collected Employee name Building/activity providing document Document title Disposition of document Documentation collected will be scanned (if hard copy) and uploaded to a specified site file on a CH2M secure server. The documentation will be kept on the server until the assessment report is finalized and the information associated with the report will be archived for the project. Geographic Information Systems/Spatial Data Documentation GIS/spatial data collected will be uploaded and verified by CH2M GIS personnel for spatial correctness. Metadata will be kept to identify any adjustments made to collected spatial data. Adjustments can include the following: Geographic coordinate adjustments Data set reduction/extraction File structure changes A Document Log Sheet (Attachment 1) entry will be made at the time of data collection. Interviews Interviews will be scheduled with current NAPR personnel and active and retired Department of Defense civilian and government personnel capable of providing pertinent information regarding NAPR history and operations. The goals of these interviews are to validate and verify data collected during the desktop data collection and review, and to identify other potential information not previously identified. Personnel to be interviewed will be identified through the following sources: Referral by base personnel Identification during archival records review Solicitation through approved base resources Targeted interviewees will include Fire Chiefs or their designees, fire suppression system managers for hangars, chrome plating operation managers, wastewater treatment plant operators, hazardous waste managers, base engineers, and base historians. Names of potential interviewees will be provided to the Navy for approval before any interviews are conducted. No contact will be made with potential interviewees until proper approval has been received. Interviews will be conducted both in person and by telephone, as required. Interview Documentation A list of interview questions developed for this project are provided in Attachment 2. Additional questions may be asked as necessary to clarify responses to the questionnaires and/or develop additional information to further clarify a potential site or release. Each interview session will be logged using an Interview Log Sheet 4 EN VBO

6 WORK PLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT FACILITY ASSESSMENT FOR PERFLOURINATED COMPOUNDS (Attachment 2). To expedite the interview process, log entrees may be transcribed from recordings collected during the interview, or notes taken during the interview. Evaluating Information The information gathered during the initial stage of the preliminary review will be evaluated to gain an understanding of the waste generation process at NAPR as it applies to PFCs and identify SWMUs and areas of concern with potential PFCs releases. The SWMUs and areas of concern with potential PFCs releases will be identified on a map. Once the potential PFCs releases have been identified, the likelihood of release at each SWMU and area of concern will be estimated by evaluating the following categories of information gathered in the initial stage of the preliminary review: Area of Concern Characteristics Design/operating characteristics Period of operation Location General physical characteristics Method used for closure Waste Characteristics Type of waste Migration and dispersal characteristics of waste Toxicological characteristics Physical and chemical characteristics Pollutant Migration Pathways Geologic and hydrogeologic setting Atmospheric conditions Topographic conditions Evidence of Release Prior inspection reports Citizen complaints Monitoring data Visual evidence Exposure Potential Proximity to affected population Proximity to sensitive environments Likelihood of potential migration to receptors Before proceeding to the VSI, significant data gaps will be identified. Visual Site Inspection The VSI will be conducted to collect visual evidence of PFCs storage, use, and/or releases to assist in recommending and planning further steps in the corrective action process. In most cases, the locations inspected will be areas where AFFF was used or released. However, each site identified in the desktop search will be visited, regardless of the nature of the potential PFCs release. Visual observation of known sites as well as potential PFCs sources and areas of previous releases will be performed. During the VSI, the information collected during the preliminary review for each area with a known or EN VBO 5

7 WORK PLAN FOR CONDUCTING A RESOURCE CONSERVATION AND RECOVERY ACT FACILITY ASSESSMENT FOR PERFLOURINATED COMPOUNDS potential PFCs release identified will be verified to the extent possible and attempts will be made to estimate or measure source areas or volumes wherever possible. The following actions will occur during the VSI: Descriptions of the suspected PFCs releases determined during the preliminary review will be expanded on Detailed descriptions of each PFCs release including source type, location, dimensions, and evidence of containment will be recorded Visual evidence of migration of PFCs releases will be documented Descriptions of observed areas of stained soil or stressed vegetation will be recorded Wells (including monitoring wells as well as base/off base drinking water production wells) and on site sensitive environments will be identified Site sketches will be prepared to include locations and dimensions of suspected PFCs releases, distance from release to major site structures, locations and distances from release to potential receptors, significant site features, and the drainage pattern and overland flow route to surface water Findings will be documented with digital photographs Photographs will be taken at each site visited. Photography of any kind will be coordinated through the Base point of contact. A photograph log will be used (Attachment 3). Reporting The preliminary review and VSI activities and results will be documented in a report. The report will also provide conclusions and recommendations of the preliminary review and VSI. Each of the SWMUs and area of concerns that were identified as having a potential PFCs release will be recommended for an interim measure, further investigation in an RFI, or no further action. Recommendation for no further action for a SWMU or area of concern will not be made solely on the absence of visual evidence of a release. If recommendations are made to conduct further investigation as an RFI, a separate sampling and analysis plan will be developed. References The following references were consulted during the preparation of this work plan. Not all are cited in the text. Department of the Navy (Navy) Environmental Restoration Program Manual. August. Navy Perfluorinated Compounds An Emerging Environmental Issue. October 21. Navy Perfluorinated Compounds Interim Guidance/Frequently Asked Questions. January 29. Naval Facilities Engineering Command (NAVFAC) Phase I/II Environmental Condition of Property Report, U.S. Naval Station Roosevelt Roads, Ceiba, Puerto Rico. July. United States Environmental Protection Agency (USEPA) RCRA Facility Assessment Guidance. October. USEPA RCRA 7003 Administrative Order on Consent. In the Matter of: United States. The Department of the Navy, Naval Activity Puerto Rico formerly Naval Station Roosevelt Roads, Puerto Rico. Environmental Protection Agency, EPA Docket No. RCRA January EN VBO

8 Figure

9 VICINITY MAP N o r t h A t l a n t i c O c e a n Puerto Rico Project Location C a r i b b e a n S e a LEGEND Boundary Naval Activity Puerto Rico Ceiba, Puerto Rico Imagery: DigitalGlobe WorldView2 May 3, m resolutiion. $ Miles FIGURE 1 Naval Activity Puerto Rico Location Naval Activity Puerto Rico (Former Roosevelt Roads Facility) Ceiba, Puerto Rico R:\USNavyPuertoRico \MapFiles\_MiscRequests\2016\Figure1_NAPR_Location.mxd 7/13/2016 JCarr_ch2mhillenvgis

10 Attachment 1 Document Log Sheet

11 RCRA Facility Assessment Document Log Employee Name: Facility/Activity: Date/Time: Document Title: Area Affected: Data Source: Digital Data File Name: Disc Title: Nature of Document/File: Notes:

12 Attachment 2 Interview Questions and Log Sheet

13 INTERVIEW LOG SHEET Interviewee: Date and Location: Interviewer: Note: This record was not transcribed from a recorded conversation. It was reconstructed from interview notes, so the conversation is paraphrased. What is/was your affiliation with the site? What is/was your position? What is the timeframe you worked at the facility? What activities were you involved with? Additional questions based on interviewee (see Interview Questions)

14 Interview Questions Fire Chief/fire chief designee/fire suppression system manager AFFF 1. What type of AFFF were used on this installation? (e.g. 3%, 6%, High Expansion Foam)? 2. What manufacturer s AFFF products were used on this installation (i.e. 3M, Ansul, and Chemguard)? 3. Where was the AFFF solution handled (mixed, contained, transferred, etc.)? Hangars and Buildings 4. Were the automated fire suppression systems ever retrofitted for use of high expansion foam? 5. Are historical inventories of the amount of AFFF stored on the installation available? 6. Can you describe the procedure on how the suppression systems were supplied with AFFF? 7. Were there any inadvertent releases of AFFF from hangar fire suppression systems? When? 8. How were releases handled (i.e. when the suppression system goes off)? Trucks and Trailers 9. Can you provide a list of trucks and trailers which carried AFFF and where they were parked/stored? 10. How much AFFF (gallons) was carried/stored in the specified trucks and trailers? 11. Were the trucks tested for spray patterns to make sure equipment was working properly? 12. How often were these spray tests performed and where were the tests performed?

15 13. Can you describe the procedure on how trucks and trailers were supplied with AFFF? Where did this resupply occur? Was there secondary containment in this area? 14. Can you provide the procedures on how these vehicles were cleaned/decontaminated and where vehicle cleaning was performed? 15. When AFFF was used during a fire training exercise, how was the AFFF cleaned up and disposed of? Records, Spill logs, Historical Information 16. Do you have recollection or records of AFFF being used in response to: a. Fuel releases to prevent fires b. Historical emergency response sites (i.e. crash sites and fires) c. Emergency runway landings where foam might have been used as a precaution 17. If no written records or incomplete written records, do you have anecdotal/verbal information and locations of spills or other emergency response incidents where AFFF was used? 18. What are the non fire training areas locations where: a. AFFF release systems were installed (i.e. Hangars, Wastewater Treatment Plants, and Fire Stations) b. Where are these locations that have contained AFFF (Building numbers) c. If converted from AFFF, when did they convert the system to high expansion foam 19. Can you provide any other locations where AFFF was stored, released, or used (i.e. hangars, buildings, fire stations, firefighting equipment testing and maintenance areas, emergency response sites, storm water/surface water, waste water treatment plants, and AFFF ponds/lagoons)?

16 Fire Chief (designee)/environmental Manager Fire Training Areas 20. Can you confirm all fire training areas identified during research are correct, and identify any fire training areas not identified during research? 21. What are the years of operation for each fire training area? 22. How much AFFF was released at each fire training area? 23. What types of fuels/flammables were used at the fire training areas? 24. For inactive fire training areas, when was the last time that fire training using AFFF was conducted at each one? 25. Are there any fire training areas where remedial action was conducted and a new fire training area was constructed on top of that fire training area? 26. How was unused AFFF managed and where (if applicable) was it disposed? Environmental Manager/Base Engineer 27. Do you have a chrome plating shop on base? Years of operation? Location? 28. Were JP 7 fuels used, mixed, or stored on base? Locations? 29. Where does your water supply come from? 30. Is there an elementary school and/or daycare facility on the installation? 31. How is sludge from the waste water treatment plant currently managed and disposed? How was it managed and disposed historically? 32. Are/were there areas where sludge from the waste water treatment plant was temporarily staged prior to dewatering/disposal? 33. Are you aware of construction and demolition or solid waste disposal areas that have not been identified at this installation? 34. Is there anyone else that you would recommend we interview? Name, organization, position, phone number, e mail.

17 Attachment 3 Visual Site Inspection Checklist and Photograph Log

18 RCRA Facility Assessment Visual Site Inspection Checklist Identify potential and observed perfluorinated compounds (PFCs) releases (e.g., fire stations, metal chroming operations). Record detailed descriptions of each PFCs release including source type, location, dimensions, quantity, and evidence of containment. Measure and record geodetic coordinates of approximate center of each site; if approximate center of site is not safely accessible, record nearest safely accessible location in close proximity to site and include a note on the difference. Mark on hard copy map approximate location and dimensions of PFCs releases. Look for signs of migration of PFCs releases. Obtain copies of any written records, especially for new releases: Fire Department, Emergency Response Records, etc. (The records can be burned to a CD or scanned using the TurboScan application if fax machine not available). Record descriptions of observed areas of stained soil or stressed vegetation. Identify any wells on site and any onsite sensitive environments. Identify surface waterbodies and residences, schools, or sensitive environments on or adjacent to the site. Prepare a site sketch to include locations and dimensions of all PFCs releases, distance from release to major site structures, locations and distances from release to all targets, significant site features, and the drainage pattern and overland flow route to surface water. Identify specific areas where PFCs disposal, storage, or handling may have occurred. Identify targets for each pathway. Take two photographs of each site from two different directions and record photo numbers and descriptions on the photograph log. Obtain copies of existing ERP reports (RI, FS, other documents) if not available from Administrative Record.

19 Obtain most recent copy of existing water well survey showing locations of wells within 4 mile radius of the installation. Obtain electronic file on CD of facilities GIS layer. Obtain electronic file on CD of ERP sites (or whatever appropriate layer) GIS layer. Obtain electronic file on CD of natural resources (sensitive environments) GIS layer. Obtain electronic file on CD of storm water and drainage system GIS layer. Obtain electronic file on CD of sanitary sewer system GIS layer. Obtain electronic file on CD of monitoring wells GIS layer.

20 PHOTOGRAPH LOG Team: Date: Weather: Photo No. Time View Direction Location/Description

21 Certification Page and Response to Comments

22 Document Certification (RequiredperSectionXIIIoftheRCRA 7003AdministrativeOrderonConsent): IcertifyunderpenaltyoflawthatIhaveexaminedandamfamiliarwiththeinformationsubmittedin thisdocumentandallattachmentsandthatthisdocumentanditsattachmentswerepreparedeitherby mepersonallyorundermydirectionorsupervisioninamannerdesignedtoensurethatqualifiedand knowledgeablepersonnelproperlygatherandpresenttheinformationcontainedtherein.ifurther certify,basedonmypersonalknowledgeoronmyinquiryofthoseindividualsimmediatelyresponsible forobtainingtheinformation,thattheinformationistrue,accurateandcomplete.iamawarethat therearesignificantpenaltiesforsubmittingfalseinformation,includingthepossibilityoffinesand imprisonmentforknowinglyandwillfullysubmittingamateriallyfalsestatement. MARTIN.STACIN.R Signature: Digitally signed by MARTIN.STACIN.R DN: c=us, o=u.s. Government, ou=dod, ou=pki, ou=usn, cn=martin.stacin.r Date: :52:08-05'00' Name: StacinMartin Title: NAVFACAtlanticRemedialProjectManager Date:

23 Responses to Regulatory Comments Draft Work Plan for Conducting a RCRA Facility Assessment for Perfluorinated Compounds Naval Activity Puerto Rico (NAPR), Ceiba, Puerto Rico PREPARED FOR: PREPARED BY: Gloria M. Toro Agrait/PREQB Nilda Del Mar Sánchez Santiago/PREQB Juan J. Babá Peebles/PREQB Douglas Pocze/ERRD SPB Jessica Mollin/USEPA Ramón Torres/EPA CEPD Stacin Martin/NAVFAC Atlantic CH2M HILL, Inc. DATE: December 13, 2016 No comment notification received from EPA on November 7, 2016 Comments from PREQB, provided October 12, Comment: Page 1, Objectives: a. The second objective listed for this assessment of PFCs is to Evaluate Solid Waste Management Units (SWMUs) and other areas of Concern for PFC releases to all media and regulated units for releases to media other than groundwater. Please clarify in the text why groundwater will not be evaluated as a media of concern for regulated units. In addition, please note that Puerto Rico Water Quality Standards Regulation states the following: For those ground waters that flow into other water bodies, the applicable water quality standard for ground waters is the most stringent criteria resulting from the comparison between the standard applicable to the classification of the water body into which it flows and DW or HH criteria applicable to ground waters Please ensure that this requirement is considered in making recommendations for further investigation/action. b. The fourth objective of this evaluation is to Screen from further investigation those SWMUs and other areas of concern which do not pose a threat to human health or the environment. It does not appear that the data being collected is sufficient to conduct such an assessment. Please revise this objective to eliminate only those sites where sufficient data is available to conclude that PFCs are not likely to have impacted the SWMU or area of concern. Note that for sites where the potential exists for PFCs to have impacted groundwater, consideration of whether PFCs could be migrating off site to areas with potable groundwater needs to be considered in making recommendations for further investigations/action.

24 Response: a. Groundwater will be considered as a potential media of concern during the RFA. The second objective has been changed to, Identify all areas of potential PFC releases to all media: air, surface water, groundwater, and soils. b. The objective has been changed to, Determine the need for further action. Offsite groundwater migration will be taken into consideration when making recommendations for further investigations/action. 2. Comment: Page 2, Objectives: It should be noted that the absence of visual evidence of a release is not a line of evidence that can be used to conclude that releases of PFCs have not occurred at an SWMU. For example visual evidence of a release may not be apparent in areas where aqueous film forming foam (AFFF) has not been used for several years (e.g., at a crash site, where wastewater sludge was historically dewatered but are no longer present or were disposed, or where C&D or municipal solid waste was landfilled). Also, PFCs are of significant concern for groundwater. Please clarify how a visual site inspection will be used to provide information to support an assessment of PFC releases to the subsurface and groundwater. Response: The following has been added as the third sentence of the Recommendations section, Recommendation for no further action for a SWMU or area of concern will not be made solely on the absence of visual evidence of a release. In addition to noting visual evidence of a potential release, the visual site inspections will provide information that will be used to help plan for further investigation if warranted, such as current site conditions and potential migration pathway. For clarification and planning has been added to the first sentence of Visual Site Inspection section so that the sentence reads: The VSI will be conducted to collect evidence of PFCs storage, use, and/or releases to assist in recommending and planning further steps in the corrective action process. 3. Comment: Page 3, Written Information and Documents: Please include a review of all pertinent site investigation reports to provide data concerning groundwater quality at sites across NAPR. The site specific groundwater quality assessments need to be used to evaluate where groundwater is potable at NAPR. Response: Groundwater quality data has been added as a sub bullet under the Environmental surveys, studies, or assessments, including: bullet in the Written Information and Documents section. 4. Comment: Page 4, Interviews: Please consider interviewing the base Engineers (or their designees) for information concerning potential sources of PFCs (e.g., construction debris disposal areas). In addition, please include landfills that received municipal solid waste as potential sources of PFCs. Response: Base engineers has been added to the targeted interviewees in the Interviews section and after Environmental Manager in the list of interview questions. AFFF and waste water treatment plant sludge disposal practices will be assessed during the RFA and landfills/disposal areas in which AFFF and waste water treatment plant sludges could have been disposed of will be considered for additional action.

25 5. Comment: Attachment 2, Interview Questions: Please add the following questions: Base Fire Chief (or designee) How was unused AFFF managed and where (if applicable) was it disposed? Environmental Manager o o o Where sludge from the WWTF was/is currently/historically managed and disposed Are/were there areas where sludge from the WWTF was temporarily staged prior to dewatering/disposal? Are you aware of construction and demolition or solid waste disposal areas that have not been identified at NAPR? Response: The questions have been added as requested.