Transcript
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FINAL FORMER MCAS TUSTIN RAB SUMMARY (11 October 2018) Page 1 of 10 Document Control Number: MMEC-2405-0007-0034

Meeting Location: Tustin Senior Center, 200 South C Street, Tustin, California Meeting Date/Time: 11 October 2018/7:00 PM to 8:23 PM Summary Prepared by: Gabriela Staehle, Multi-Media Environmental Compliance Group (MMEC Group)

Attachments:

Presentation Slides:

Results of Groundwater Sampling for Per- and Polyfluoroalkyl Substances (PFAS) in Operable Unit 3 and Carve-Outs 5 and 6

Results of Groundwater Sampling for 1,2,3-Trichloropropane (1,2,3-TCP) in Operable Unit 1A

Attendees: A total of 16 people were in attendance for the Former MCAS Tustin RAB meeting:

Navy: Jim Callian, Base Realignment and Closure (BRAC) Environmental Coordinator (BEC) and RAB Co-Chair; Guy Chammas, Navy Lead Remedial Project Manager (LRPM); Rich Pribyl, Contracted Environmental Engineering Support (EES); and Alex Bollweg, Contracted EES.

Regulatory Agencies: Patricia Hannon, California Regional Water Quality Control Board, Santa Ana Region (RWQCB).

RAB Members: Desiré Legé, RAB Community Co-Chair; Ken Piguee, City of Tustin (City); Matt West, City; Chris Crompton, Orange County Public Works Department; and Mary Opel, South Orange County Community College District (SOCCCD).

Other Attendees: Erika Rodriguez, Community Member; Harry Takach, Community Member; Medhanie Ephrem, SOCCCD; Tony Guiang and Gabriela Staehle, MMEC Group; and Zoila Finch, County of Orange.

WELCOME/INTRODUCTIONS/AGENDA REVIEW:

Mr. Callian (BEC and RAB Co-Chair) welcomed everyone to the 107th Former MCAS Tustin RAB meeting and thanked everyone for attending. Mr. Callian asked for self-introductions from those in attendance.

Mr. Callian presented the general slides, including the following: the RAB Meeting Agenda; points-of-contact information for the Former MCAS Tustin BRAC Cleanup Team (BCT), including RWQCB and California Department of Toxic Substances Control (DTSC); information and contact information for the Administrative Record and Information Repository; environmental websites; the schedule for the next RAB meeting; and the process for review of RAB Meeting Summaries.

Mr. Chammas (Navy LRPM) noted that the figure on the poster board at the front of the room had been updated to show the current groundwater plume delineations.

Final FORMER MARINE CORPS AIR STATION (MCAS) TUSTIN

107th Restoration Advisory Board (RAB) Meeting Summary

11 October 2018

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RAB PRESENTATION 1:

Results of Groundwater Sampling for PFAS in Operable Unit (OU) 3 and Carve-Outs (COs) 5 and

6 (Presented by Mr. Bollweg, Contracted ESS [Attachment 1])

Slide 1 – Presentation Title

Slide 2 – Presentation Overview

Slide 3 – OUs and Groundwater Plumes (Figure)

Mr. Bollweg described the figure on Slide 3: CO-5 and -6 are outlined with yellow dashed lines, the trichloroethene (TCE) and 1,2,3-TCP plumes are shown as pink and yellow polygons, respectively, and the groundwater flow direction is shown with blue arrows. Mr. Bollweg explained that Mr. Pribyl would discuss the TCE and 1,2,3-TCP plumes in depth during his presentation.

Slide 4 – OUs and Groundwater Plumes (continued)

Mr. Bollweg briefly discussed the locations, characteristics, and established remedies for the groundwater plumes in OU-1A, OU-1B North/South, OU-3, and OU-4B.

Slide 5 – PFAS Background

Mr. Bollweg discussed the nature and historical use of PFAS compounds in industrial and consumer products and indicated that although PFAS are not currently regulated as a hazardous substance, the Navy is voluntarily and proactively conducting groundwater investigations

Slide 6 – Potential PFAS Source Areas

Mr. Bollweg introduced the Fire/Rescue Station Area of Concern (AOC) in OU-1A and the Crash Crew AOC in OU-1B North.

Slide 7 – Potential PFAS Source Areas (continued)

Mr. Bollweg discussed potential source areas in OU-3 (Crash Crew Burn Pits) and the Warehouse AOC in OU-4B. He also mentioned that although the Navy has not identified any general or specific AOCs in CO-6, PFAS releases may have been associated with wastewater treatment in this area.

Slide 8 – OU-3 Investigation – Technical Approach

Mr. West (City) asked Mr. Bollweg to clarify the detection limits for perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), and PFOA+PFOS. Mr. Bollweg explained that the detection limits depend on the lab and dilution factors. Mr. Chammas added that the detection limits are in the range of single digits in parts per trillion (ppt). The screening level for PFOA, PFOS, and PFOA+PFOS is 70 ppt, and the Navy can detect concentrations at single-digit ppt.

Regarding the sampling conducted in November 2017, Mr. Bollweg explained that only 9 of 10 wells were sampled because one well was dry.

Slide 9 – OU-3 Investigation – Results (Table)

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Mr. Bollweg presented the results from the November 2017 investigation at OU-3 and noted that concentrations in the second water-bearing zone (WBZ) were up to 3 orders of magnitude less than those in the first WBZ.

Slide 10 – OU-3 Investigation – Results (continued), First WBZ (Figure)

Mr. Bollweg explained that the groundwater flow direction is west toward Peters Canyon Channel and that a steel-reinforced concrete containment wall on the western side of Peters Canyon Channel is in place to prevent groundwater migration into the channel.

Slide 11 – OU-3 Investigation – Results (continued), Second WBZ (Figure)

Mr. Bollweg noted again that PFOA and PFOS concentrations in the second WBZ were significantly less than those in the first WBZ.

Slide 12 – COs 5 and 6 Investigation – Technical Approach

Mr. Bollweg indicated that similar to the previous investigation at OU-3, the Navy was interested in determining the presence or absence of PFAS in shallow groundwater in COs 5 and 6. The Fire/Rescue Station, Warehouse, and Crash Crew AOCs along with the OU-1A/1B North and OU-1B South Groundwater Treatment Facilities were the focus of the investigation.

Slide 13 – COs 5 and 6 Investigation – Fire/Rescue Station and Warehouse AOCs Results (Figure)

Mr. Bollweg indicated that PFOA, PFOS, and/or PFOA+PFOS exceedances were detected in each of the permanent and temporary monitoring wells that were sampled.

Slide 14 – COs 5 and 6 Investigation – Crash Crew AOC Results (Figure)

Mr. Bollweg indicated that PFOA, PFOS, and PFOA+PFOS exceedances were detected in each of the permanent and temporary monitoring wells that were sampled.

Slide 15 – COs 5 and 6 Investigation – OU-1A/1B North Groundwater Treatment Facility Results (Figure)

Mr. Bollweg indicated that although there were PFOA, PFOS, and PFOA+PFOS exceedances detected in the influent, the liquid-phase granular activated carbon (GAC) treatment train effectively reduced their concentrations to non-detect concentrations in the effluent sample.

Slide 16 – COs 5 and 6 Investigation – OU-1B South Groundwater Treatment Facility Results

Mr. Bollweg indicated that, similar to the OU-1A/1B North Groundwater Treatment Facility results, although there were PFOA, PFOS, and PFOA+PFOS exceedances detected in the influent, the liquid-phase GAC treatment train effectively reduced their concentrations to non-detect concentrations in the effluent sample.

Mr. Callian pointed out that the numbers preceding the “U” or nondetect values in the callout boxes are the detection limits. The number means that the constituent was not detected at or above that concentration.

Slide 17 – Next Steps

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Mr. Bollweg indicated that the Navy was currently finalizing its summary report for the COs 5 and 6 investigation and strategizing with the regulatory agencies and stakeholders regarding the next steps. Additional groundwater investigation is being planned, with fieldwork expected to be completed in Spring 2019 and reporting to be completed in Summer 2019.

Slide 18 – Acronyms

Slide 19 – Questions

Ms. Opel (RAB Member) asked what the difference in depth is between the first and second WBZs. Mr. Bollweg responded that the first WBZ extends to 30 feet below ground surface (bgs) and the second WBZ extends from 30 feet to 60 feet bgs.

Ms. Legé (RAB Community Co-Chair) asked whether the Navy has a conceptual strategy for the second round of sampling. Mr. Bollweg responded that the Navy is still discussing the strategy, but will likely return to CO-5, CO-6, and OU-3. Mr. Callian added that the Navy will use a phased approach and will continue to adjust the plan according to the locations of detections.

Ms. Legé noted that the highest concentrations were detected in OU-3, west of Peters Canyon Channel and she expressed concern with the likelihood of contaminants migrating into the channel. Mr. Chammas responded that a containment wall is installed between OU-3 and the channel, which acts as an effective barrier. It was previously estimated via groundwater modeling that it will take approximately 60 years for groundwater to travel around the containment wall.

Ms. Legé asked about the degradation rates of the PFAS constituents. Mr. Chammas responded that the PFAS constituents undergo minimal degradation. Ms. Legé asked whether the Navy was required to conduct stormwater sampling in Peters Canyon Channel. Mr. Chammas responded that the Navy is not required to sample stormwater in the channel and added that because PFAS compounds are still unregulated, the Navy’s current actions are not only proactive, but also voluntary.

Ms. Legé asked for an explanation of the inconsistency between the boundaries of CO-9 and OU-4B. Mr. Chammas responded that CO-9 was delineated in accordance with the shape of a historical drainage ditch that was believed to be the source of groundwater impacts, but as investigations proceeded over the years, it was determined that impacted groundwater flows in a direction slightly offset to the location of the historical drainage ditch.

In response to Ms. Legé’s inquiry to Ms. Hannon (RWQCB) whether she was concerned about the PFAS detections, Ms. Hannon stated that the RWQCB is asking the Navy to continue its PFAS investigation, but noted that PFAS are still emerging contaminants.

Mr. Callian added that the lifetime health advisory (LHA) discussed in the presentation is for drinking water, and that the groundwater discussed in the presentation is not used for drinking water.

Ms. Legé asked the City whether the inconsistency between the boundaries of CO-9 and OU-4B is affecting property issues. Mr. West responded that the City does not have a problem with the inconsistency, as long as the Navy continues to implement the remedy in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process. The Navy has notified the property owners and the City of Irvine that investigations are ongoing. Mr. West continued that there are no production wells within Former MCAS Tustin. The City and Irvine Ranch Water District (IRWD) provide drinking water to residents of the City. IRWD and the City have been testing the drinking water for PFAS, and the results have been non-detect.

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Ms. Legé asked whether there is an initiative to correct the CO-9 boundary. Mr. West responded that the property around CO-9 has already been transferred, and that the City has not self-imposed covenants, notifications, or restrictions because the Navy is sharing information about the contamination at the property and continues to implement the remedy. Mr. West continued that the issue of institutional controls on the property outside of CO-9 had not been resolved among the Navy, DTSC, and the City.

Ms. Legé noted that the restrictions should not be self-imposed, but rather that DTSC should impose them. Mr. West said that the necessity of restrictions is part of the ongoing discussion.

RAB PRESENTATION 2:

Results of Groundwater Sampling for 1,2,3-TCP in OU-1A (Presented by Mr. Pribyl, Contracted

EES [Attachment 2])

Slide 1 – Presentation Title

Slide 2 – Presentation Overview

Mr. Pribyl explained that the presentation is divided into five general categories:

1. Background including site history and a summary of the remedy implementation 2. Discussion of the new California 1,2,3-TCP maximum contaminant level (MCL) 3. Review of 1,2,3-TCP historical plume stability and concentration trends 4. Presentation of 2017 and 2018 monitoring results 5. Review of the new MCL impacts to the remedy and the draft strategy for incorporating the

MCL into the remedy

Slide 3 – Installation Restoration Program (IRP) Site 13S Location (Figure)

Mr. Pribyl explained that the area within the blue oval is the focus of the presentation.

Slide 4 – IRP Site 13S Background

Mr. Pribyl briefly reviewed the various investigation areas that OU-1A comprises.

Slide 5 – Pre-Record of Decision (ROD) Actions

Mr. Pribyl explained that three response actions had been completed prior to the remedy selection for other groundwater contaminants that also addressed the co-located 1,2,3-TCP plume.

Slide 6 – OU-1A Remedial Design

Mr. Pribyl reviewed the ROD objectives and the current remediation goals (RGs).

Slide 7 – OU-1A Remedial Action Implementation

Mr. Pribyl stated that the OU-1A/1B North Groundwater Treatment Facility contains three liquid-phase GAC vessels, each containing 2,000 pounds of GAC. Only two vessels are operated at a time, which provides system flexibility. Currently, 11 extraction wells in OU-1A and OU-1B North produce a combined 17 gallons per minute, and as of 1 October 2018 the treatment system had successfully treated 75,470,000 gallons.

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Slide 8 – OU-1A/1B North Groundwater Treatment Facility (Pictures)

Slide 9 – New California 1,2,3-TCP MCL

Mr. Pribyl noted that the new California MCL of 5 ppt is two orders of magnitude lower that the current RG and that currently there is not a federal MCL. He also noted that the MCL is applicable to concentrations in drinking water.

Mr. Pribyl explained the next set of slides showed the 1,2,3-TCP and TCE plumes stabilities and concentration trends over time. Mr. Pribyl added that he would move through the next set of slides fairly quickly and would not go into detail.

Slides 10–12 – 1,2,3-TCP Plume Stability: First WBZ (Figures)

Mr. Pribyl described the stability of the 1,2,3-TCP and TCE plumes between 2008 and 2017, indicating that their lateral extents have remained relatively consistent over time. As of 2016 and 2017, the TCE plume had elongated somewhat, but the 1,2,3-TCP plume has generally remained stable.

Slides 13–15 – 1,2,3-TCP Plume Stability: Second WBZ (Figures)

Mr. Pribyl similarly noted that the TCE plume has elongated somewhat, but the 1,2,3-TCP plume has generally remained stable between 2008 and 2017. Mr. Pribyl explained that the Navy does not have historical figures showing the plume in the third WBZ over time, because historically only two wells have been monitored in the third WBZ.

Mr. West asked whether there are wells in the third WBZ in the vicinity of the plumes. Mr. Pribyl said that there are and added that the third WBZ did have detections historically. Mr. Callian added that there is a localized area where the confining layer between the second and third WBZs is thinner and allows communication between the WBZs.

Mr. West asked whether the area below the third WBZ had been characterized. Mr. Callian responded that the principal aquifer is below the third WBZ and that the Navy has not investigated potential impacts to date, in part out of concern of potentially creating vertical conduits for downward migration as a result of well drilling and installation. Mr. West expressed concern about finding chemicals in the WBZ directly above the principal aquifer. Mr. Callian responded that the Navy is concentrating on using the nearby extraction wells in the second WBZ to reestablish a localized upward hydraulic gradient from the third WBZ, which effectively controls downward migration.

Slide 16 – 1,2,3-TCP Concentration Trends: First WBZ (2012–17)

Mr. Pribyl indicated that with one exception the trends were either decreasing or were not established. In cases where historical values were less than the RG, Mr. Pribyl explained that no conclusion was made regarding the significance of those trends relative to the MCL as they likely contained non-detect results. The samples were analyzed using United States Environmental Protection Agency (U.S. EPA) Method 8260B, which has a detection limit of approximately 0.25 micrograms per liter (µg/L) or 250 ppt. Therefore, it is possible that samples previously reported as non-detect could actually have had concentrations of 1,2,3-TCP exceeding 5 ppt (but less than 250 ppt).

Slide 17 – 1,2,3-TCP Concentration Trends: Second WBZ (2012–17)

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Mr. Pribyl indicated that concentration trends for the wells shown were either not present or decreasing. He also pointed out that three monitoring wells at the toe of the plume (222MW08D, 222MW10D, and IS72MW12DR) had decreasing trends.

Slide 18 – 1,2,3-TCP Concentration Trends: Third WBZ (2012–17)

Mr. Pribyl indicated that the two wells historically sampled had increasing trends at concentrations exceeding both the MCL and RG.

Slide 19 – April 2018 1,2,3-TCP Results: First WBZ (Figure)

Mr. Pribyl explained that the black and yellow polygon on the figure outlined the estimated extent of 1,2,3-TCP at 5 ppt based on the limited data collected in April 2018. Nine wells were analyzed for 1,2,3-TCP using U.S. EPA Method 8260B selected ion monitoring (SIM), which has a lower detection level. Solid portions of the polygon indicate where there is more certainty, and dashed portions of the polygon indicate where there is less certainty.

Mr. West asked what the bolded numbers in the table represent. Mr. Pribyl responded that all data displayed on the figure are in µg/L and that the bolded data are in exceedance of the RG of 0.5 µg/L (500 ppt), which is 100 times greater than the MCL (0.005 µg/L or 5 ppt).

Slide 20 – April 2018 1,2,3-TCP Results: Second WBZ (Figure)

Mr. Pribyl explained that the black and yellow polygon on the figure outlined the estimated extent of 1,2,3-TCP at 5 ppt based on the limited data collected in April 2018. Eight wells were analyzed for 1,2,3-TCP using U.S. EPA Method 8260B-SIM. Solid portions of the polygon indicate where there is more certainty, and dashed portions of the polygon indicate where there is less certainty.

Slide 21 – April 2018 1,2,3-TCP Results: Third WBZ (Figure)

Mr. Pribyl explained that the black and yellow polygon on the figure outlined the estimated extent of 1,2,3-TCP at 5 ppt based on the limited data collected in April 2018. Three wells were analyzed for 1,2,3-TCP using U.S. EPA Method 8260B-SIM. Solid portions of the polygon indicate where there is more certainty, and dashed portions of the polygon indicate where there is less certainty. Concentrations of 1,2,3-TCP in groundwater had remained stable.

Slide 22 – September 2018 1,2,3-TCP Results: First WBZ (Figure)

Mr. Pribyl stated that, overall, the estimated extent of the 1,23-TCP plume generated with the September 2018 data is consistent with the estimated extent generated from the April 2018 data.

Slide 23 – September 2018 1,2,3-TCP Results: Second WBZ (Figure)

Mr. Pribyl stated that five new wells were sampled during September 2018. Compared to the estimated shape of the 1,2,3-TCP plume at 5 ppt in April 2018, the estimated shape of the September 2018 1,2,3-TCP plume at 5 ppt had expanded in the downgradient direction (based on the recent data from downgradient monitoring well IS72MW05S). Although there is still uncertainty regarding the downgradient extent of impacts, the September 2018 data provided more confidence regarding the limits of the eastern edge of the plume (additional data are required to establish trends).

Slide 24 – September 2018 1,2,3-TCP Results: Third WBZ

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Mr. Pribyl stated that the 1,2,3-TCP concentration in groundwater monitoring well IS72MW07D2 dropped by an order or magnitude from 4.1 µg/L in April 2018 to 0.4 µg/L in September 2018.

Slide 25 – New MCL Impacts on the Remedy

Mr. Pribyl indicated that the Navy has optimized its monitoring plan to address the fact that the 1,2,3-TCP plume at 5 ppt is not fully defined (at 5 ppt) in the downgradient direction (based on the September 2018 sampling result from downgradient monitoring well IS72MW05S).

Slide 26 – Draft 1,2,3-TCP Strategy

Mr. Pribyl stated that the Navy needed to collect at least two more semiannual rounds of data to better define the downgradient extent of the plume. Based on the additional data, the Navy will be in a better position to make recommendations for modifying or augmenting the remedy.

Slide 27 – Questions

Ms. Legé asked Mr. Pribyl to clarify the significance of decrease in concentrations of 1,2,3-TCP in groundwater monitoring well IS72MW07D2 from April 2018 to September 2018. Mr. Pribyl responded that the decrease is promising, but will not be considered a trend until at least two more rounds of data are available.

Ms. Legé asked about the depths of each WBZ. Mr. Callian explained that, generally, the first WBZ extends to approximately 30 feet bgs, the second WBZ extends from approximately 30 to 60 feet bgs, and the third WBZ extends from approximately 60 to 90 feet bgs.

Mr. Crompton (RAB Member) asked how the remedy is operated. Mr. Pribyl explained that the Operation and Maintenance (O&M) Plan dictates the operation of the extraction system. The decision to turn off the extraction system in approximately 2012 and turn it back on in 2014 was consistent with direction from the O&M Plan. Mr. Callian added that there are no extraction pumps in the third WBZ.

Mr. Crompton asked for clarification of the methods used to analyze the sample. Mr. Pribyl responded that through 2017, samples were analyzed using U.S. EPA Method 8260B, which provided detection limits generally in the range of 0.2 to 0.3 µg/L (200 to 300 ppt). Where results are reported as non-detect, there is uncertainty about where the concentration in groundwater might exceed the new MCL of 5 ppt. During the April 2018 monitoring event, the Navy analyzed samples that were previously non-detect or close to the RG using U.S. EPA Method 8260B-SIM.

Mr. West asked whether the Navy will search for additional plumes now that a more sensitive analytical method is available. Mr. Callian responded that normally 1,2,3-TCP releases are characterized by very high concentrations in the area of release, which would have been detected using U.S. EPA Method 8260B. Mr. Callian continued that the Navy has already investigated areas where 1,2,3-TCP contamination was suspected. The Navy will not return to look for additional areas. Mr. Pribyl directed the question to Ms. Hannon, who replied that it is possible that the RWQCB could ask the Navy to return to sites that have been investigated previously now that we have new MCLs.

Slide 28 – Acronyms

Slide 29 – Navy Contact Information

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REGULATORY AGENCY UPDATE

Ms. Hannon said that the RWQCB has reviewed various performance evaluation and monitoring reports. The Navy has completed the investigation and cleanup of Neighborhood D South, and the RWQCB has issued a no-further-action letter. Neighborhood D South was the last petroleum site at Former MCAS Tustin.

MEETING EVALUATION/FUTURE TOPICS/SCHEDULE FOR NEXT RAB MEETING AND

CLOSING

Ms. Legé led the evaluation discussion. She asked where additional PFAS information is available. Mr. Chammas responded that the summary from the 19 April 2018 RAB meeting [since finalized] will include links to online resources. Mr. Callian added that RAB members could search for PFAS on the U.S. EPA (clu-in.org) or Interstate Technology and Regulatory Council (itrcweb.org) websites.

Mr. Callian asked whether the RAB members wanted to consider meeting annually. The RAB members voted and agreed to an annual meeting frequency. The next meeting will take place on October 10, 2019.

The RAB meeting adjourned at 8:23 PM.

LIST OF HANDOUTS PROVIDED AT THE MEETING:

11 October 2018 Former MCAS Tustin RAB Meeting Agenda Presentation Slides: “Results of Groundwater Sampling for PFAS in OU-3 and COs 5 and 6,

Former Marine Corps Air Station Tustin, Tustin, CA” Presentation Slides: “Results of Groundwater Sampling for 1,2,3-TCP in OU-1A, Former Marine

Corps Air Station Tustin, Tustin, CA” Figure 9, “OU-1A/-1B North COCs in First Water-Bearing Zone,” from the Internal Draft 2018

Annual Groundwater Monitoring Report, Operable Units 1A and 1B, Former Marine Corps Air Station Tustin, Tustin, California

Figure 10, “OU-1A/-1B North COCs in Second Water-Bearing Zone,” from the Internal Draft 2018 Annual Groundwater Monitoring Report, Operable Units 1A and 1B, Former Marine Corps Air Station Tustin, Tustin, California

Figure 11, “OU-1A/-1B North COCs in Third Water-Bearing Zone,” from the Internal Draft 2018 Annual Groundwater Monitoring Report, Operable Units 1A and 1B, Former Marine Corps Air Station Tustin, Tustin, California

Former MCAS Tustin Carve-Out Areas and Plume Map Former MCAS Tustin RAB Fact Sheet/Membership Application Former MCAS Tustin Mailing List Coupon

Copies of the meeting summaries and handouts are available at the Information Repository for Former MCAS Tustin located in the Ayala Science Library of the University of California at Irvine, Irvine, California. Library hours vary; please check online at http://www.lib.uci.edu/hours. The library phone number is (949) 824-3692. Copies of the meeting summaries and handouts are also available in the CERCLA Administrative Record File.

Final summaries from previous RAB meetings are available on the internet at the Navy BRAC PMO website: www.bracpmo.navy.mil.

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INTERNET SITES:

Navy and Marine Corps Internet Access: BRAC PMO website (includes RAB meeting summary): http://www.bracpmo.navy.mil/

U.S. EPA:

Homepage: www.epa.gov

National Center for Environmental Assessment: www.epa.gov/ncea

Contaminated Site Clean-Up Information: https://clu-in.org

California Agencies:

California Environmental Protection Agency Homepage: www.calepa.ca.gov

DTSC: www.dtsc.ca.gov

Department of Health Services: www.cdph.ca.gov

Santa Ana RWQCB: www.waterboards.ca.gov/santaana

Additional Websites: Reuse and Redevelopment

City of Tustin: www.tustinlegacy.com

Additional Websites: PFAS Information

Interstate Technology and Regulatory Council: https://pfas-1.itrcweb.org/

Assistant Secretary of the Navy (Energy, Installations, and Environment): http://www.secnav.navy.mil/eie/pages/pfc-pfas.aspx

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FORMER MCAS TUSTIN

Results of Groundwater Sampling for Per-and Polyfluoroalkyl Substances (PFAS) in Operable Unit 3 and Carve-Outs 5 and 6Former Marine Corps Air Station (MCAS) Tustin, Tustin, CA

Alex BollwegContracted Environmental Engineering Support

107th Restoration Advisory Board Meeting11 October 2018

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2 BRAC Program Management Office

Presentation Overview

• Operable Units (OUs) and Groundwater Plumes• Per- and Polyfluoroalkyl Substances (PFAS) Background• Potential PFAS Source Areas• OU-3 Investigation (November 2017)

– Technical Approach– First Water-Bearing Zone (WBZ) Results– Second WBZ Results

• COs 5 and 6 Investigation (July 2018)– Technical Approach– Fire/Rescue Station and Warehouse Areas of Concern (AOCs) Results– Crash Crew AOC Results– OU-1A/1B North Groundwater Treatment Facility Results– OU-1B South Groundwater Treatment Facility Results

• Next Steps

11 October 2018

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3 BRAC Program Management Office

OUs and Groundwater Plumes

11 October 2018

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4 BRAC Program Management Office

OUs and Groundwater Plumes (cont.)

• OU-1A– Volatile organic compound (VOC)–impacted groundwater

• 1,2,3-trichloropropane• trichloroethene (TCE)

– OU-1A/1B North Groundwater Treatment Facility• OU-1B North/South

– VOC-impacted groundwater (TCE)– OU-1A/1B North and OU-1B South Groundwater Treatment Facilities

• OU-3– Landfill/former firefighting training area (cap/groundwater containment wall)– Groundwater/surface water sampling once every 5 years

• OU-4B– Mingled Plumes Area (TCE) in CO-5– Installation Restoration Program Site 5S(a) (TCE within/near CO-9)– Installation Restoration Program Site 6 (1,1-dichloroethene) within CO-2– In situ bioremediation and monitored natural attenuation

11 October 2018

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5 BRAC Program Management Office

PFAS Background

• Synthetic organofluorine compounds• Thermally stable, hydrophobic, and lipophobic• Decades of use in industrial and consumer products

– Firefighting foams (e.g., aqueous film-forming foam)– Stain-resistant/waterproof textiles (e.g., GORE-TEX®)– Nonstick cookware (e.g., Teflon™)– Cleaning products – Carpeting– Upholstery– Food wrappings– Metal plating

• Not currently regulated as a hazardous substance and no promulgated standards exist

• U.S. Department of the Navy voluntarily and proactively conducting PFAS presence/absence investigations

11 October 2018

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Potential PFAS Source Areas

• OU-1A– Building 49 – Firehouse Annex– Building 13 – Fire/Rescue Station– Miscellaneous Wash Area (MWA)-15– Miscellaneous Potential Disposal Area (MDA)-5

• OU-1B North– Building 259 – Crash Crew Storage Area– Building 183 – Fire/Rescue Station– Building 103 – Crash Crew Training Classroom– Treatment Oil/Water Separator (TOW)-13– MWA-14 – wash area adjacent to Building 183– MDA-09 – 40-foot-diameter crash crew pond– TOW-14 – fire training wastewater treatment– Miscellaneous Crash Drill Site (MCD)-02 – burn pit used for firefighting training

11 October 2018

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Potential PFAS Source Areas (cont.)

• OU-3– Crash Crew Burn Pits– Firefighting training from 1971–83– 250,000–350,000 gallons liquid wastes burned/extinguished

• OU-4B– Building 71 – General/Fire Department Warehouse

• CO-6– No obvious sources, but may berelated to wastewater treatment

11 October 2018

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OU-3 Investigation – Technical Approach

• Assess presence/absence of PFAS in shallow groundwater• Focus on 3 compounds for which screening levels exist

– perfluorooctanoic acid (PFOA)– perfluorooctane sulfonate (PFOS)– perfluorobutanesulfonic acid (PFBS)

• Use available (unpromulgated) screening levels for drinking water– PFOA, PFOS, and PFOA+PFOS = 0.07 microgram per liter (µg/L)

• United States Environmental Protection Agency (U.S. EPA) Lifetime Health Advisory (LHA) (May 2016)

– PFBS = 400 µg/L • U.S. EPA Regional Screening Level (RSL) (May 2018)

• Obtain regulatory agency input/concurrence• Conduct two sampling events

– July 2017 (initial event: 3 wells in first WBZ)– November 2017 (second event: 9 out of 10 wells in first and second WBZs)

11 October 2018

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9 BRAC Program Management Office 11 October 2018

OU-3 Investigation – Results

PFOA PFOS PFOA+PFOS PFBS

μg/L μg/L μg/L μg/L

U.S. EPA Lifetime Health Advisory¹ 0.07 0.07 0.07 -

U.S. EPA Tap Water Regional Screening Level² - - - 400

Well Identification WBZ Sample Date

I001BC43S First 11/15/2017 0.337 0.0490 0.386 0.0659

I001BC47S First 11/15/2017 0.315 0.0391 0.354 0.0353

I001BC50S First 11/14/2017 7.05 D 1.48 8.53 1.170

I001MW52S First 11/13/2017 345 11.4 356 78.3

I001MW43D Second 11/15/2017 0.00812 J <0.00539 0.00812 J 0.00308 J

I001MW47D Second 11/15/2017 0.00631 J <0.00548 0.00631 J 0.00280 J

I001MW50D (duplicate)

Second 11/14/2017 0.00884 J (0.0101)

<0.00579 (0.00247 J)

0.00884 J (0.0125 J)

0.00292 J (0.0325)

I001BC52D Second 11/14/2017 0.137 <0.00573 0.137 0.0325

I001MW53D Second 11/14/2017 0.0575 <0.00517 0.0575 0.0115Notes:1. PFOA, PFOS, and PFOA+PFOS screening levels are based on the U.S. EPA Lifetime Health Advisory for drinking water.2. PFBS screening level is based on the U.S. EPA tap water Regional Screening Level.

= Result exceeds U.S. EPA screening level

Bold = detection; D = dilution; µg/L = micrograms per liter; PFOA = perfluorooctanoic acid; PFOS = perfluorooctane sulfonate; PFBS = perfluorobutanesulfonic acid; WBZ = water-bearing zone

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10 BRAC Program Management Office 11 October 2018

OU-3 Investigation – Results (cont.)First WBZ

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11 BRAC Program Management Office 11 October 2018

OU-3 Investigation – Results (cont.)Second WBZ

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12 BRAC Program Management Office

COs 5 & 6 Investigation – Technical Approach

• Assess presence/absence of PFAS in shallow groundwater• Focus on PFOA, PFOS, and PFBS• Use U.S. EPA LHA and RSL • Address 3 AOCs and COs 5 & 6 in general

– Fire/Rescue Station AOC• 3 existing, 1 temporary groundwater monitoring wells

– Warehouse AOC• 1 temporary groundwater monitoring well

– Crash Crew AOC• 2 existing, 2 temporary groundwater monitoring wells

– OU-1A/1B North and OU-1B South Groundwater Treatment Facilities• Influent “composites” from extraction wells• Effluent “composites” from extraction wells• Assess effectiveness of liquid-phase granular activated carbon treatment

• Obtain regulatory agency input/concurrence• Conduct sampling event (July 2018)

11 October 2018

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COs 5 & 6 Investigation – Fire/Rescue Station and Warehouse AOCs Results

FIRE/RESCUESTATION AOC

WAREHOUSE AOC

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14 BRAC Program Management Office

COs 5 & 6 Investigation –Crash Crew AOC Results

CRASH CREW AOC

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COs 5 & 6 Investigation – OU-1A/1B North Groundwater Treatment Facility Results

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16 BRAC Program Management Office

COs 5 & 6 Investigation – OU-1B South Groundwater Treatment Facility Results

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17 BRAC Program Management Office

Next Steps

• Finalize PFAS Summary Report for COs 5 and 6 (early November)• Develop strategy with regulators and stakeholders (ongoing)• Complete fieldwork (Spring 2019)• Complete reporting (Summer 2019)

11 October 2018

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18 BRAC Program Management Office

Acronyms

11 October 2018

AOC – Area of Concern

BRAC – Base Realignment and Closure

CO – Carve-Out

LHA – Lifetime Health Advisory

MCAS – Marine Corps Air Station

MCD – Miscellaneous crash drill site

MDA – Miscellaneous disposal area

MWA – Miscellaneous wash area

OU – Operable Unit

PFAS – per- and polyfluoroalkyl substances

PFBS – perfluorobutanesulfonic acid

PFOA – perfluorooctanoic acid

PFOS – perfluorooctane sulfonate

RSL – Regional Screening Level

TCE – trichloroethene

TOW –treatment oil/water separator

U.S. EPA – United States Environmental Protection Agency

VOC – volatile organic compound

WBZ – water-bearing zone

µg/L – microgram(s) per liter

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19 BRAC Program Management Office

Questions

11 October 2018

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FORMER MCAS TUSTIN

Results of Groundwater Sampling for 1,2,3-Trichloropropane (1,2,3-TCP) in Operable Unit 1AFormer Marine Corps Air Station (MCAS) Tustin, Tustin, CA

Richard PribylContracted Environmental Engineering Support

107th Restoration Advisory Board Meeting11 October 2018

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Presentation Overview

11 October 2018

• Installation Restoration Program (IRP) Site 13S− Location− Background

• Pre–Record of Decision (ROD) Actions• Operable Unit (OU) 1A Remedial Design• OU-1A Remedial Action Implementation• New California Maximum Contaminant Level (MCL) for 1,2,3-TCP• 1,2,3-TCP Plume Stability

− First and Second Water-Bearing Zones (WBZs)• 1,2,3-TCP Concentration Trends (2012–17)

− First, Second, and Third WBZs• April 2018 1,2,3-TCP Results

− First, Second, and Third WBZs• September 2018 1,2,3-TCP Results

− First, Second, and Third WBZs• New MCL Impacts to the Remedy• Draft 1,2,3-TCP Strategy

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3 BRAC Program Management Office

IRP Site 13S Location

11 October 2018

OU-1A(IRP-13S)

OU-1B North(IRP-12)

OU-1B South(IRP-3)

CARVE-OUT 5

CARVE-OUT 6

LEGEND:

1,2,3-TCP Plume (approx.)

TCE Plume (approx.)

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IRP Site 13S Background

• OU-1A• Drum Storage Area Number 3• Temporary Storage Area 72

– Former vehicle maintenance garage and lubrication facility– Main source of 1,2,3-TCP impacts– Located north of the current plume extents

• Miscellaneous Wash Area 18 (MWA-18)– Formerly used for cleaning generators and other field equipment– Main source of trichloroethene (TCE) impacts– Located near the head of the plume

• Disposal Storm Drain 07– Located primarily within the boundary of MWA-18

11 October 2018

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5 BRAC Program Management Office

Pre-ROD Actions

• Time-Critical Removal Action (Jan 2002–Sep 2007) – Groundwater extraction and treatment– Seven original extraction wells

• Soil source removal (Jan 2005–Mar 2005)– Potential continuing source of TCE to groundwater– Focused on [TCE] in soil > 400 micrograms per kilogram – Primarily around MWA-18

• Petroleum Corrective Action Program (completed by 2007)– Nearby former underground storage tank site 222– Methyl tertiary-butyl ether– TCE-impacted groundwater from the soil source removals– Groundwater extraction and treatment; air sparging and soil-vapor

extraction

11 October 2018

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6 BRAC Program Management Office

OU-1A Remedial Design

11 October 2018

AREA 1 EXTENSION

• Remedy Features– Chemicals of concern: 1,2,3-TCP, TCE and

its breakdown products– Includes hot spot groundwater extraction and

hydraulic containment, performance monitoring

– 1,2,3-TCP Remediation Goal (RG) • 0.5 microgram per liter (µg/L) (risk based)• Based on the best science, limitations of

laboratory analysis, and the best available technology at the time

– TCE RG• 5 µg/L (state and federal MCL)

– Source soil removal to optimize the groundwater remedy

• no further action for soil– Institutional controls to prevent/control

contact with or extraction and use of shallow impacted groundwater

• Final ROD in Dec 2004

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7 BRAC Program Management Office

OU-1A Remedial Action Implementation

• Remedial action implemented from Jun to Nov 2007• OU-1A/1B North Groundwater Treatment Facility started 16 Nov 2007

– Process equipment• holding tank• feed pump• three liquid-phase granulated activated carbon vessels

– Control equipment• level sensors• pressure gauges• master control panel• communication system

– Extraction wells• eight in OU-1A• three in OU-1B North• combined production of approximately 17 gallons per minute

– Total treatment volume of 75,470,000 gallons as of 1 Oct 2018

11 October 2018

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8 BRAC Program Management Office

OU-1A/1B North Groundwater Treatment Facility

Treatment Building at OU-1A/1B North Granular Activated Carbon Filter Units and Manifold

11 October 2018

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9 BRAC Program Management Office

New California 1,2,3-TCP MCL

• 0.005 µg/L (or 5 parts per trillion [ppt]: 100 times < the current RG)• Promulgated in December 2017• Applies to concentrations in drinking water• Responsive to changes in health risk assessments• Refinement of analytical methods allows lower detection limits• No federal MCL

11 October 2018

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10 BRAC Program Management Office

1,2,3-TCP Plume Stability: First WBZ

11 October 2018

2008 APER 2009 APER

2010 APER 2011 APER

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary

20112010

20092008

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11 BRAC Program Management Office

1,2,3-TCP Plume Stability: First WBZ (cont.)

2012 APER 2013 APER

2014 APER 2015 APER

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary

20152014

20132012

11 October 2018

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12 BRAC Program Management Office

1,2,3-TCP Plume Stability: First WBZ (cont.)

11 October 2018

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary 2016 2017

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13 BRAC Program Management Office 11 October 2018

2008 APER

2010 APER 2011

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary

1,2,3-TCP Plume Stability: Second WBZ

20092008

2010

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14 BRAC Program Management Office 11 October 2018

2012 2013

2014 2015

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary

1,2,3-TCP Plume Stability: Second WBZ (cont.)

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15 BRAC Program Management Office 11 October 2018

LEGEND:

1,2,3-trichloropropane (TCP)

Trichloroethene (TCE)

Groundwater elevation contour

Direction of groundwater flow

Carve-out boundary 2016 2017

1,2,3-TCP Plume Stability: Second WBZ (cont.)

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16 BRAC Program Management Office 11 October 2018

WELL ID TREND SIGNIFICANCEIS72MW03S NONE <RGIS72OW01S NONE >RG; >MCLIS72MW11S NONE <RG222MW04S NONE >RG; >MCLIS72MW17S INCREASING >RG; >MCL222MW05S NONE >RG; >MCLIS72MW02S NONE >RG; >MCLIS72MW12S DECREASING <RG

1,2,3-TCP Concentration Trends: First WBZ (2012–17)

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17 BRAC Program Management Office 11 October 2018

WELL ID TREND SIGNIFICANCEIS72OW05D NONE >RG; >MCLIS72MW01D N/A >RG; >MCL222MW04D DECREASING >RG; >MCL222MW05D DECREASING >RG; >MCL

IS72MW02D NONE >RG; >MCLIS72MW03D DECREASING <RG; >MCL222MW11D NONE >RG; >MCL222MW06D NONE <RG; >MCL222MW08D NONE <RG222MW10D NONE <RG

IS72MW12DR NONE <RG

1,2,3-TCP Concentration Trends: Second WBZ (2012–17)

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18 BRAC Program Management Office 11 October 2018

WELL ID TREND SIGNIFICANCEIS72MW02D2 INCREASING >RG; >MCLIS72MW07D2 INCREASING >RG; >MCL

1,2,3-TCP Concentration Trends: Third WBZ (2012–17)

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19 BRAC Program Management Office 11 October 2018

April 2018 1,2,3-TCP Results: First WBZ

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20 BRAC Program Management Office 11 October 2018

April 2018 1,2,3-TCP Results: Second WBZ

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21 BRAC Program Management Office 11 October 2018

April 2018 1,2,3-TCP Results: Third WBZ

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22 BRAC Program Management Office 11 October 2018

September 2018 1,2,3-TCP Results: First WBZ

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23 BRAC Program Management Office 11 October 2018

September 2018 1,2,3-TCP Results: Second WBZ

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24 BRAC Program Management Office 11 October 2018

September 2018 1,2,3-TCP Results: Third WBZ

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25 BRAC Program Management Office

• Plume at 5 ppt is not fully defined in the downgradient extent• Sampling program changes

– Added wells to the program• Continue to evaluate and include additional wells

– Changed the analytical method to achieve lower detection limits• Implemented in 2018• 2 rounds complete• Shifted timing of sampling rounds to better support property transfer

documents and upcoming 5-year review– Increased sampling frequency

11 October 2018

New MCL Impacts to the Remedy

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26 BRAC Program Management Office

• Further evaluate plume stability– Collect additional data (at least 2 more semiannual events)– Consider groundwater modeling based on additional data– Present conclusions/recommendations in 2018 and 2019 annual reports

• Expand the monitoring well network– Add existing wells to program as recommended in annual reports

•Evaluate potential need to modify/augment remedy?

11 October 2018

Draft 1,2,3-TCP Strategy

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27 BRAC Program Management Office

Questions?

11 October 2018

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28 BRAC Program Management Office 11 October 2018

Acronyms

g/L micrograms per liter1,2,3-TCP 1,2,3-trichloropropaneBRAC Base Realignment and ClosureID identifierIRP Installation Restoration ProgramMCL maximum contaminant levelMWA-18 Miscellaneous Wash Area 18OU Operable Unitppt parts per trillionRG remediation goalROD Record of DecisionTCE trichloroethene[TCE] concentration of TCEWBZ water-bearing zone

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29 BRAC Program Management Office

DON Contact Information

11 October 2018

Jim Callian, PG BRAC Environmental Coordinator for Former MCAS TustinDesk Phone: (619) [email protected]

Guy Chammas, PG Lead Remedial Project Manager Desk Phone: (619) [email protected]

Rich Pribyl Contracted Environmental Engineering SupportDesk Phone: (619) [email protected]


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