PEM staff, under subcontract to Battelle, managed the RCRA Facility Assessment (RFA) program at Marine Corps Base (MCB) Camp Pendleton, CA. The program consisted of over 100 sites where petroleum wastes were discharged to the ground at waste storage areas and above ground storage tank (AST) sites. Because the 100 RFA sites impacted planning and future construction activities on Base as part of the MCB Grow the Force initiative, it was imperative that sites become available to support the effort. To allow the Base to proceed with construction unhindered by land use controls (LUCs), PEM together with Battelle, NAVFAC SW and the Base, prepared a site summary and recommendations report that documented the history, current site status, and recommendation for 93 RFA sites after a screening process was performed.
PEM staff developed a proven, cost-saving screening process for closing low-threat RFA sites without performing additional field investigations. It provided a recommendation for site closure (if site contaminants were associated with a closed UST or IR case), transfer (if site contaminants were associated with an open UST or IR case), NFA, or further investigation.
Extensive research was performed gathering and evaluating historical site information for all 93 RFA sites to accurately document site conditions and determine current data gaps. In the report, a recommendation was made for NFA for 78 RFA sites and 25 sites required further investigation. Throughout the process, PEM personnel worked closely with project stakeholders including the Navy client, MCB Camp Pendleton Environmental staff, and the California regulatory agency, Regional Water Quality Control Board (RWQCB) to negotiate the criteria for screening sites. Through a technically sound approach and effective negotiations with the RWQCB, three quarters of the RFA program was granted closure with no land use restrictions, saving $10M in future investigation and remediation costs, and allowing unrestricted use of the land.
PEM staff performed site investigations at the 25 RFA sites that were recommended for further investigation. The field activities consisted of determining the current nature and extent of site contaminants through the collection and analysis of soil and groundwater samples. Based on analytical results of the collected samples, PEM staff recommended 22 RFA sites for no further action and 3 RFA Sites for corrective action. Site closure was granted for the additional 22 RFA. PEM staff performed corrective action at 2 of the 3 RFA Sites in 2015.